Chancery Depositions (PRO C2 Jas1 P.26/4 Partridge v: Harlakenden etc)

1622 (no date) (1622)

document 16300162

the several rejoinder of Rich Harlakenden esq defendant to the replication of Edw Rosse gentleman and Rose his wife complainants the said defendant for himself severally saith that the replication of the said complainants is unjust and untrue and very insufficient in the law to be rejoined unto by this defendant notwithstanding all advantage of exception to the incertainty and insufficiency thereof to this defendant always hereafter saved for rejoinder thereunto this defendant saith in all and everything as in his said answer he hath formerly said and doth and will aver maintain and prove and all an every other matter thing clause therein contained to be good just and true in such sort manner and form as by the said defendant in the said answer the same are truly expressed declared and set forth and whereas the said complainants in their said replication do suggest that the carefulness of the defendant's late father and himself that the said copyhold lands of the said Jeff Cuckoke the father after the decease of her the said Rose should come to the children of the said Cuckoke was not for any love or commiseration which they or either of them did bear towards the said children but for their own ends and purposes out of a hope and desire to buy the same at their own rates this defendant saith that the said suggestion is very scandalous and false and as he verily thinketh contrary to the conscience and knowledge of her the said Rose and for the clearing of his said father's reputation and justifying of his doings concerning the premises this defendant saith that notwithstanding that the said copyhold lands were forfeited to this defendant's said father and that he had at his great charge tried his said title of the forfeiture and thereupon recovered the same yet freely out of his good disposition not compelled by any legal course he granted the same afterwards by copy of court roll to the said Robt Partridge and Rose with remainder to the children of the said Jeff Cuckoke in such manner as this defendant in his answer hath set forth which plainly manifesteth as this defendant conceiveth that his said father did not aim at any private end of his own or to get the said lands to himself as by the said complainants is uncharitably suggested but to settle the same in the children of the said Jeff Cuckoke who was the owner thereof and this defendant further for himself saith that the said forfeiture trial and grant being in his said father's time he had no intermeddling or dealing concerning the same and denieth that he hath or ever had any sinister or dishonest intention to get the same lands for himself but wisheth the same may be enjoyed according to right and equity and denieth that he hath done anything concerning the premises but what in conscience and honesty he was bound to do without that that any other matter or thing etc Fr Sydner