the several answers of Thos Nichols of Coggeshall yeoman one of the defendants to the bill of complaint of Hen Abbott esq complainant this defendant saving to himself at all times hereafter and all manner of advantage of exception to the manifold errors incertainties and imperfections and insufficiencies in the complainant's said bill of complaint contained material or effectual for this defendant to make answer unto as he is advised he saith as followeth and first this defendant saith that he doth not of his own knowledge know that the complainant hath been or is seised or possessed of any estate or interest in the rectories or vicarage of Great and Little Coggeshall in the county of Essex or either of them in the bill mentioned or in any part thereof or in anywise entitled to any part of the tithes of Great and Little Coggeshall or ought to have had received or enjoyed or now doth receive or enjoy any such tithes as in the bill of complaint is for that purpose set forth and expressed or any rate or composition or sum of money for the same but this defendant saith that true it is that he this de fendant doth hold and enjoy by lease from Math Elliston of Coggeshall aforesaid clerk a small piece or parcel of meadow or pasture ground containing by estimation 3a or thereabouts and have held and enjoyed the same by the space of eleven years last past and saith that for each of the years in the said bill of complaint contained this defendant hath mowed grass from the said 3a of meadow ground and hath made the same into hay each year five loads at the most and did constantly pay unto the vicar of Great Coggeshall for ten years of the said eleven years in lieu and in full satisfaction of all the tithes arising renewing and increasing yearly out of the said premises the sum of 10s and no more to whom as this defendant hath been informed by the ancient inhabitants of Coggeshall the same did of right belong and appertain and this defendant hath been credibly informed that the said rate tithe or composition of 10s for all the tithes of the said 3a of meadow ground hath been by prescription paid to the vicar of Coggeshall for the time being in lieu and contentation of all tithes growing increasing and renewing of and from the premises and this defendant saith that the complainant pretending a tithe and making a claim unto the moiety of the tithe of the said 3a of meadow ground sometime before last hay harvest and other persons claiming title to the other moiety besides the claim of the said vicar as this defendant did justly and honestly set out the tithe in kind of all the hay that was cut and made for that year growing and increas ing on the premises and the plaintiff might if he had pleased and had any good right and title thereto took received and carried away the same and this defendant saith that he this defendant did not feed depasture anything upon the said 3a save that after the hay cut made and carried away as aforesaid this defendant hath fed his milch cows in each of the said two years not exceeding seven and his horses for the plough at particular times and this defendant verily believes that nothing in kind is due for the said 3a but a rate tithe of 10s a year payable to the vicar aforesaid and this defendant saith that he had good reason to believe that the complainant hath no good right nor title to the premises for that he did not take and carry away the hay so set forth as aforesaid for the tithe in the presence of his servants but left the same to rot on the ground to the loss and prejudice of this defendant for which this defendant as he is advised were he as troublesome as the complainant and had the complainant a good title this defend ant had good cause of action against him and this defendant further saith that he doth not hold or enjoy any more or other lands or things whatsoever within the parish precinct or titheable places of Great and Little Coggeshall for any tithe rate or composition nor hath at any time been demanded or paid and to all the other matters and things in the bill of complaint contained this defendant saith that he is a stranger and denies all combination in the bill laid to his charge without that that any matter or thing etc Jon Squibb 16.2.1693 before Jn Turton