Jn Hayes says sir Jn Jacob the father owed him 1200li or more on about the time mentioned on account of his wife's portion and he importuned him several times in his lifetime for this but he could not prevail and the debts remain due and it is true that he had several conferences with sir Jn Jacob in his lifetime about it and he promised to settle securities but whether he did sign or seal any warrants for judgement or whether any judgement was entered on record Hayes does not know he humbly craves the recovery of his 1200li says that Robt Trelawney having about 1642 obtained a judgement against Jn Jacob for 1800li he Hayes did about seventeen years since purchase the same of Jn Trelawney son and heir of Robt for 300li there being then due on the judgement about 900li he took an assignment in trust for himself in the name of Hen Elwes esq with whom he did then entrust his said deed of assignment and he says that he has been informed that Elwes without his order for money assigned the said judgement to either Jn Jacob the father or to someone else for his use so that Hayes never got any benefit or got his 300li he says that anything done was done without his knowledge and denies any confederacy