the complaint of Hen Abbott the younger of Earls Colne in Essex and wife Abigail daughter and heir of Jn Park late of Kersey in Suffolk deceased that the orator in right of the oratrix Abigail now are seised of an estate of inheritance of and in divers messuages and lands tenements and hereditaments both freehold and copyhold in the several parishes of Kersey and Witham in Suffolk and Much Tey in Essex and in divers other parishes in Essex and Suffolk which lands and tenements descended and came to her as heir to her father and Joseph Park her late brother by the settlement of Wm Park her grandfather on her father's side or by Joseph Hunt her grandfather on her mother's part or by some other person or persons and that Mary Clark of Kersey widow her mother during her minority as guardian did possess herself of the lands and premises and took the rents and profits and did likewise possess herself of the deeds and copies of court rolls and the writings and evidences touching and concerning the premises and every of them that about a year since and as soon as she attained her full age of one and twenty years and when there was a treaty of the marriage to be made by and between her and the orator save the oratrix to show duty and kindness to Mary Clark did in due form of law release to her mother one legacy of 200li given unto her by her grandfather Park and all the rents and profits of the lands now your orator's received by Mary during her minority and divers other just and lawful demands amounting to 500li whereby the oratrix had reason to believe that Mary Clark would be abundantly satisfied and with the release she your oratrix and Hen Abbott his father were acquainted or willing to proceed in the marriage and to settle a considerable jointure of lands on her your oratrix to convey other lands upon their issues so as the lands of the oratrix were settled upon her and her issue and a little before her marriage she left in her mother's house a box wherein were divers deeds and writings concerning her estate and therein one or two more deeds sealed by her your oratrix and kept in the box to the intent the same should not be made use of until some conditions were performed and she your oratrix kept the key of the box and now has the same and Mary promised to deliver the box with the writings therein at any time when she required the same but Mary Clark intending some further advantage to herself and to her children by Peregrine Clark gentleman her second husband and knowing how entirely the oratrix was governed by her and her advice and that she had undoubted confidence in her mother that she would not desire her to do anything her real disadvantage she Mary Clark confederating with Geo Brooks of Kersey yeoman and Simon Dove of Hadley in Suffolk gentleman during the treaty of marriage of her and without her knowledge and consent or her father did procure deeds writings surrenders and conveyances of her your oratrix's lands to be drawn and made and afterwards obtained of her your oratrix's seal and execution of the same to certain uses intents and purposes therein contained which are unknown unto her or the orator having no copies or counterparts of the same and Mary Clark Geo Brooks and Simon Dove the better to persuade her to seal and execute the same did severally allege divers specious pretences and allegations to wit that the conveyances were not to her disadvantage and they were with power of revocation and would not hinder her marriage or the settlement of the lands of Hen Abbott the elder on her whereby she sealed them after she and the orator were induced to intermarry without any settlement made by Hen Abbott the elder they hoping that the deeds surrenders and assurances made by her should be produced revoked and vacated or destroyed whereby some reasonable settlement might be made of the lands of hers and a suitable and proportionable jointure and settlement might be made of the lands of Hen Abbott the elder as was discoursed and treated before their intermarriage but shortly after their marriage Mary Clark conveyed the deeds copies writings and evidences concerning her lands and the box together with the deeds and surrenders sealed and made by her or most of them secretly into the custody of possession of Geo Brooks and Simon Dove or one of them or into the hands and possession of some other person or persons in trust for the confederates or one of them or with their knowledge privity or consent or Mary Clark detaining the box or writings or some of them secretly in her own possession and the confederates Mary Clark Geo Brooks and Simon Dove although often were requested by the orators or one of them do severally refuse to deliver to them the box of deeds copies writings and evidences which concern her lands and the confederates severally though requested refuse to let the orators have a sight of the deeds and surrenders whereof they cannot know or defend their title of interest to the lands by means of such concealment and Hen Abbott the elder does refuse to settle the lands or tenements for the present maintenance of the orators or for her jointure or for the provision for their issue as he intended to have done to the great damage of them and Mary has opened the box and intends to take advantage of some deeds in it which are not to be made use of all which matters and things are contrary to right etc and because they know not the particular dates and contents of the deeds writings and evidences concerning the estate of land to sue at common law and have no counterpart or copies of the same the confederates to set forth the truth concerning the deeds and writings etc writ of subpoena for the appearance of Mary Clark Geo Brooks and Simon Dove signed Jn Eldred