Court of Wards (PRO WARD13/174 Earl of Oxford v: Rich Harlakenden etc)

7.2.1640 (Friday 7 February 1640)

document 20100253

the several rejoinder of Rich Harlakenden esq one of the defendants to the replication of sir Rowl Wandeford knight attorney of his majesty's court of wards and liveries for and on the behalf of the said right honourable Aubery earl of Oxford his majesty's ward repliant the said defendant saving to himself all advantages etc that the said replication is incertain and insufficient in the law to be rejoined unto for the said defendant saith that the said Roger and Rich Harlakenden in the said answer mentioned did purchase the said manors of Earls Colne and Colne Priory and other the lands and tenements therein mentioned for a full and valuable consideration in money by them or one of them duly paid for the same to the right honourable Edw earl of Oxford in the said information and answer mentioned and that the said several manors lands tenements were at the time of the said several purchases in lease for divers years then to come and unexpired upon which leases very small rents were reserved and were likewise encumbered with divers other charges and encumbrances which the said Roger Harlakenden and Rich Harlakenden did afterwards buy in and discharge for very great sums of money and they did much improve the yearly value of the said manors lands and tenements by building upon the same and in other charges and reparations about the same by which the yearly value was exceedingly increased and that ever since their said several purchases the said Roger Harlakenden and Rich Harlakenden their heirs and assigns have taken and had the issues rents and profits of the same without eviction notwithstanding that the said Edw late earl of Oxford and after his decease Hen earl of Oxford his son and heir did endeavour to avoid the conveyances of the said manor of Colne Priory and other lands and tenements conveyed to the said Rich Harlakenden upon divers pretences and commenced suits in this honourable court and in his majesty's high court of chancery and at common law for the recovery of the same in which suits the said Roger and Rich Harlakenden were wrongfully put to extraordinary expenses in defending their just and rightful estates therein without that that the said manors of Earls Colne and Colne Priory and other the lands and tenements in the said answer mentioned or any part thereof were fraudulently and deceitfully or without true and valuable consideration bought or obtained from the said Edw earl of Oxford and without that that any other matter or thing in the said replication contained material for this defendant to rejoin unto etc Jn Joscelyn