complaint of Hen Abbott the younger of Coggeshall in Essex yeoman says that about the beginning of .9.1685 Hen Abbott the elder of Earls Colne in Essex clothier his father was seised of a farm in Coggeshall of the yearly value of 50li and was possessed of several quantities of barley and bullimong then growing on the land belonging to the farm or lying in the granary and chambers belonging to the farm and the orator's said father being so seised and possessed the farm being then untenanted and in the hands of Hen Abbott the elder did offer to the orator the farm at the yearly rent of 50li and to encourage the orator to hold the same his father offered to him to let him have all the corn and grain upon the farm and the orator should not pay him anything for the same upon which offer his father by an agreement in writing by him and the orator signed in the presence of credible witnesses was made between them to this or the like effect that is to say that the orator should hold the farm for three years from michaelmas.last rendering the yearly rent of 50li at the feast of annunciation and michaelmas by equal proportions and pursuant to the agreement the orator about .10.last entered upon the ground and was possessed thereof and of the barley and bullimong being one hundred and five quarters of barley and thirty six quarters of bullimong about and the orator since his entry has duly paid all the rent grown due upon the agreement and ought peaceably to enjoy the farm corn and grain but now the orator's father being informed of the orator's intention by some ill persons who have designed to prejudice the orator have prevailed with him to commence an action at law against the orator for the barley and bullimong in the court of kings bench Westminster w ho have in the action declared against the orator in a quantum meruit for one hundred quarters of barley and thirty six quarters of bullimong averring the same to be worth 150li and proceeded earnestly in the action to recover damages for the same against the orator which doings of his father tend to apparent prejudice of the orator contrary to equity in tender consideration whereof and whereas the orator c annot be relieved by strict process of common law asks for his father to be compelled to perform the agreement in specie he cannot defend himself against the action at law the witnesses who can prove the agreement being since dead or in such places remote and unknown to him so that he cannot have them at a trial at the common law but is only relievable the premises in this court to the end that Hen Abbott the elder may true and perfect answer make to the premises and be compelled to perform the agreement and that his action at law may be stayed by an injunction out of this court asks for writ of subpoena to Hen Abbott the elder