Court of Requests (PRO REQ2/269/40 Rich Underwood v Geo Pilgrim and Jas Wakering)

30.4.42Eliz1 (Wednesday 30 April 1600)

document 19700040

answer of Geo Pilgrim and Jas Wakering two of the defendants of the bill of complaint of Rich Underwood complainant they say the bill is uncertain etc and that the complainant now is and was outlawed at the suit of Jas Wakering for certain debts which Rich Underwood does yet owe Jas and also that Underwood at the time was and yet is outlawed at the suit of divers others of the queen's subjects for divers debts due unto them and that the complainant lives as a fugitive or outlaw by deceitful and unhonest shifts for all these causes these defendants do demur in law and demand judgement of this court if they or either of them shall be compelled to make any further answer to the insufficient bill nevertheless the said Geo Pilgrim answers to so much of the bill as concerns him he says that about the latter end of .5.38Eliz1 the complainant for 70li did surrender into the hands of the lord of the manor of Earls Colne certain copyhold lands and tenements of the manor for the use of this defendant and his heirs on the condition that the complainant or his heirs or executors should pay to the defendant or his executors or assigns 70li at or before easter next following that the surrender to be void and that the plaintiff did not pay nor tender to the defendant the money at the day nor any time before nor since the defendant at the next court holden for the manor being upon saturday in easter week 39Eliz1 was admitted to the lands and tenements according to the surrender and paid his fine for the lands and by force of the same the defendant does still enjoy them as is lawful for him to do but further says that the plaintiff before the first day of the next term will pay unto him the defendant the sum of 70li and also the sum of 6li which the defendant has paid to the lord of the manor for his fine for the same lands and also the sum of 27s4d which the defendant has paid for the debt of the complainant to one Robt Sandeford gentleman allow to the defendant such reasonable costs and charges as he has bestowed in buildings and other necessary reparations and charges upon the premises and in this suit and also allow to the defendant a lease of the premises for three years from for the yearly rent of 6li in such manner as the plaintiff had a lease of the premises before the acceptance of the surrender then the defendant upon the payment of the said sums of money and performance of the lease will reassure the premises to Rich Underwood himself and his heirs according to the custom of the manor without that and any other thing in the bill contained material or effectual to be answered etc