[an error occurred while processing this directive]

Chancery Depositions (PRO C3/273/36 Rich and Thos Harlakenden v Michael Blackwell and Rich Wilkinson)

1605 (1605)

document 15800057

(date uncertain) reply of Rich Harlakenden esq and Thos Harlakenden gentleman complainants to the joint and several answers of Mich Blackwell gentleman and Rich Wilkinson defendants (rough transcript of the preamble) to say that every thing they have said in their original bill of complaint was true in every article and the answer of the defendants is uncertain insufficient in law to be replied to by them the bill was not only grounded on the two points by the defendants mentioned in their answer but on divers other matters and circumstances of equity apt for this court as in the bill say that if there was any such conveyance made whereby the parcel of land Bandon was entailed as surmised in answer the same was made in such manner and such indirect purpose as set forth in the bill and was revoked before the lease made to Wm Symonds and the deed of revocation cancelled or concealed as in the bill is likewise truly set forth without that the pretended marriage was had and celebrated between Edw Blackwell and Alice Webbe in the answer named and without that there was or is any such office or inquisition whereby the pretended conveyance or marriage or any other thing in the answer surmised were or are found as by the said answer is surmised without that Wm Symonds either before or at any time of the making of the said lease for five hundred years or at any time since did know or could not be ignorant of the pretended conveyance whereby the premises as is pretended were entailed as in the answer surmised further say that before and at the time of the making of the lease both his father and himself affirmed that his father was seised in fee simple of the parcel of land and he was of the full age of twenty one years whereby Symonds was induced to purchase the same and without that the father of the defendant Mich Blackwell died at such time as in the answer surmised and did make the defendant's mother his executrix or that letters of administration were granted to her as in the answer and without that the said Wm Parkinson possessed himself of the personal estate of the defendant's father or of any deeds or evidences or exemplifications or that thereby the defendant was kept ignorant of his estate or title as surmised in the answer and without that the 430li mentioned in the lease was paid for the other lands of inheritance to him the said Symonds bought of the defendant's father or that Symonds made no account of the lease or feared the title thereof or discovered so much to any whomsoever as surmised in answer without that any other material article clause or allegation in answer material to be replied unto and not sufficiently replied unto etc ready to answer and prove