to the right honourable Thos lord Ellesmere lord chancellor of England in most humblewise complaining showeth unto your honourable lordship your daily suppliant Edw Potter of Earls Colne Essex weaver son and heir of Edm Potter late of Earls Colne aforesaid yeoman deceased that whereas the said Edm Potter father unto your said suppliant was in his lifetime lawfully seised in his demesne as of fee of and in one messuage or tenement commonly called or known by the name of Gilberts and of and in divers lands meadows and pastures woods and hereditaments with the said messuage occupied and enjoyed amounting in the whole to the number of 20a or thereabouts set lying and being in the parish and county aforesaid and he the said Edm being thereof so seised in or about 5.8.39Eliz1 borrowed of one Jas Godscall of London merchant the sum of 50li and for the payment thereof at the end of one whole year your suppliant's said father did in and by one recognizance in the nature of a statute staple taken and acknowledged in due form of law stand and become bound unto the said Jas Godscall in the sum of 200marks or thereabouts the defeasance of the said statute being for the payment of the sum of 40li or thereabouts at or within one whole year next after the acknowledgement of the said recognizances in and by the said recognizance and defeasance thereof to which relation being had and made may unto this honourable court more fully and at large appear and the said Edm being seised as aforesaid and having entered into the said statute as aforesaid the said Edm died after whose death the said messuage and premises descended and came as of right it ought to descend and come unto your said suppliant as son and heir of the said Edm your said suppliant being then of very tender age viz of the age of six years or thereabouts but so it is may it please your good lordship that the said Godscall having a purpose by unjust and wrongful dealing to enrich himself by the spoil of your said suppliant and his said father's estate he the said Godscall taking opportunity of your suppliant's infancy and want of friends shortly after the death of your suppliant's said father and long before the said 40li grew to be due by the defeasance of the said recognizance very unduly and unconscionably caused an extent to be had and sued for and upon the said recognizance and by means of the said extent possessed himself of the goods and chattels of your suppliant's deceased father and of the said messuage or tenement and lands in this your suppliant's bill formerly mentioned together with the said defeasance of the said statute and also the evidences charters escripts muniments and writings concerning the messuage and lands aforesaid and by colour thereof detaineth possession of the premises of right belonging unto your suppliant and further may it please your singular good lordship he the said Godscall not satisfied with the said extent of the premises being well worth 10li per annum ultra reprises and having peaceably and quietly enjoyed the same by the space of ten years now last past nor yet with the extent of the said goods and chattels of your suppliant's deceased father amounting to more than the due debt or the forfeiture of the said recognizance he the said Godscall having gotten into his custody the evidences concerning the premises aforesaid out of a longing and thirsting desire to strip your suppliant out of the inheritance of the said messuage and premises hath most fraudulently covenously and unconscionably practised and combined with one Geo Maxey late of Rivenhall in the county aforesaid gentleman and hath entitled the said Maxey of and in the premises alleging and pretending that your suppliant's deceased father had mortgaged the said premises unto him the said Maxey and had suffered the same to become forfeited unto him the said Maxey and that now he the said Godscall held the same under the title of the said Maxey whereas in truth there was never any such mortgage made by your suppliant's said father or if there were the money due upon the said mortgage were either paid or lawfully tendered to the very day of the mortgage according to the form of law as your suppliant hopeth manifestly to prove unto this most honourable court but so it is may it please your singular good lordship that he the said Godscall by colour of the pretended title of the said Maxey and by the abetment practise confederacy and procurement of him the said Maxey he the said Godscall holdeth and detaineth the possession of the said premises from your suppliant and the profits issues and revenues of the premises doth receive and take to his own use contrary to equity and good conscience and hath made and contrived divers secret estates of the premises to themselves and others to your suppliant unknown to the end and purport your suppliant should not know against whom to bring his action at the common law for the recovery of his right and title to the premises and notwithstanding your suppliant hath at divers and sundry times in very friendly and gentle manner requested and entreated the said Godscall to deliver the possession of the premises unto your suppliant yet he the said Godscall utterly refuseth so to do contrary to all equity and good conscience in tender consideration of all which premises and for as much as your suppliant hath not the custody of the evidences concerning the premises but the same are in the possession or custody of the said Maxey or Godscall or one of them or in the custody or possession of some other by their or one of their bailment or delivery and for as much likewise as your suppliant knoweth not the certain number date nor contents of them nor whether they be in box or chest locked or sealed without the which your suppliant is void of all remedy by the strict course of the common law of this realm by reason he cannot without the said evidences so sufficed title make proof of his estate and interest of and in the premises may it therefore please your good lordship to grant unto your said suppliant his majesty's most gracious writ of subpoena to be directed to Jas Godscall etc Joscelyn