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Court of Requests (PRO REQ2/77/82 Margt Game widow v Jn Felix)

14.10.4Eliz1 (Wednesday 14 October 1562)

document 19500322

the said defendant not knowledging or confessing to be true anything in the said bill of complaint contained effectual or material to be answered unto and saving the advantage of exception to the insufficiency of the said bill of complaint for declaration of truth and for answer to the said insufficient bill of complaint the said defendant saith that the said Robt Goldwire in the said bill of complaint named over and besides certain freehold land called Holmes Jannings Kings and Bacons whereof he was seised in his demesne as of fee as also lawfully seised in fee according to the custom of the manor mentioned in the said bill of complaint of and in one cottage with 4a by estimation of customary land called Coordes and Jennings of which premises customary the said Robt Goldwire also died seised by whose death the same did descend to Wm Goldwire his son and heir and by the death of the same Wm Goldwire the same premises did descend to Margt the daughter of the said Robt Goldwire and the sister and heir of the said Wm Goldwire which Margt and the said defendant her husband were of the said premises customary lawfully seised in their demesne as of fee in her right according to the custom of the said manor and so seised the said defendant had issue by her yet living and she died after whose death the said defendant was and yet is of the said premises customary seised for term of his life as tenant by courtesy according to the custom of the said manor and the rents and profits thereof by a long time the said defendant and his late wife having lawfully and quietly enjoyed and that by the hands of the said complainant and her late husband as their undertenants which by the letters of the lord of Oxford lord of the said manor and by other means shall evidently appear and own the said party is not ashamed to challenge the same in her own right like as she also doth wrongfully deforce the said defendant of other the said freehold lands against all right and equity without that the said Robt Goldwire did according to the custom of the said manor surrender the said premises customary to the use and performance of the said last will or that the said supposed surrender was duly presented or that the said party or her husband according to the custom of the said manor by force of the supposed surrender and will were lawfully seised of the said premises customary or that the said party by survivor is lawfully seised of the premises thereof she hath taken and had otherwise but as undertenants to the said defendant and those by whom he claimeth and paid rent for the same accordingly without that the pretended legacy or any other thing in the said bill of complaint contained effectual or material to be answered unto and herein not confessed and avoided denied or traversed is true all which matters the said defendant is ready to aver as this court shall award and prayeth to be restored to his possession and to be dismissed to the court of the said manor where the whole matter is known with his costs for his wrongful vexation in this behalf contained etc