9 Oct 1591 Pr the Chanc'

To the ryghte honorable S^r Chrystofer Hatton of the moste noble order of

the garter knighte Lord Chauncello^r of England:

In moste humble wyse complaynynge sheweth unto yo^r good Lordshippe yo^r dailye Orato^r Willm Dokenfeild of Dokenfeild

in the Countie of Lancaster [sic] That whereas one Thomas Marland of [blank] in the said Countye yeoman was

seised in his demesne as of Fee of and in certen lands lyeinge in Rediche in the said Countie of the yerelie valewe of

three pounds or thereabouts and beinge thereof so seised by good and sufficient conveyaunce and assuraunce in the lawe for

good causes and consideracons him movinge hathe bargayned and sould the said lands and all the evidencs concernynge the

same to yo^r Lordshipps said orato^r and to his heires forever. But so yt is yf yt maye please yo^r good Lordshippe that one

John Marland of the said Countie husbandman brother to the said Thomas havinge by casuall meanes gotten into his

hands and possession certen p[ar]cells of the evidences and wrytings concernynge the presmysses and rightfullie

belongyng to yo^r said orato^r dothe not onlie make title to the said lands, but also interruptethe the possession of yo^r Lo: said

orato^r therein And also as yo^r said orato^r is informed hathe made dyvers secrett and fraudulent conveyauncs of his supposed

title to p[er]sons unknowen to yo^r said orato^r whiche maye be verye dangerous and prediudiciall to yo^r Lordshipps poore orato^r

his tytle in and to the premysses. And for asmoche as yo^r orato^r hathe dyvers and sundrye tymes in moste gentle and

and frendlie manner desired and required the said John Marland not onlie to suffer and p[er]mitte yo^r Lordshipps said

orato^r quyetlie to occupie and enjoye the said premysses accordinge to his lawfull ryght and tytle therein but also to

delyver to your said orato^r said evidencs and writings belonginge to him and wrongefullie deteyned from him by the

said John Marland yet that to doe the said Marland hathe utterlie refused and denyed contrarye to all ryghte

equytye and good conscience And for that yo^r Lordshipps poore orato^r is is voide of remedye by the ordynarye course

of the comon lawes of this realme for and towchinge the premysses for that he knoweth not the certen dates

nor contente of the said evidencs and wrytings nor wherein they be conteyned whethe[r i]n bagge or boxe

sealed or cheste locked It maye therefor please yo^r Lordshippe to graunte to yo^r said orato^r the Quenes

majesties moste gracyous wrytte of S[ub]p[oen]a to be directed to the said John Marlande comanding him

thereby at a certen daye and under a certen payne p[er]sonallye to appeare before yo^r good Lordshippe in

her majesties highe Courte of Chauncerye then and there to aunswere unto the premysses. And also to

stande to and abide suche further order and direccon therein as to yo^r good Lordshippe shall seeme to stande w^th

righte equytye and good conscyence And yo^r said orato^r shall dailye praye to god for yo^r good Lordshippe in

healthe and hono^r longe to contynewe

Johnson [copying clerk?]

Second copy in a different hand, but also signed "Johnson"

[transcript/translation in progress]

The answere of John Marlande Def[endan]t to the Bill of Complaynte of Willyam Duckenfelde Esquier Compl[ainan]t
The sayd Deft saythe that the bill of Complaynte agaynste him exhibited ys very incerteyne and
Insuffyciente in the lawe to bee answered unto and devised of purpose onely to put this Deft to
wrongfull costes and Expence in the lawe w^thout any iuste cawse or matter soe to doe Nevrthelesse
The insufficiencye therof at all tymes hereafter to this deft saved the sayd deft for answere
& playne declaracon of the truthe saythe that Willm Marlande father of this Deft and also
fath^r to the sayd Thoms Marlande in the bill named was in his lyffe tyme Lawfullye seised in his
demeane as of fee of and in the Lands and tenem^ts in the bill menconed And he soe beinge therof
seised by suffyciente & Lawfull conveyance & assurance in the lawe in or aboute the nintenthe yeare
of the Quenes ma^tie that nowe ys [1576-77] did lawfully Conveye and assure the same to one Myles
Marlande and his heyres one of his sonnes & brother to this deft by force whereof the sayd
Myles toke the yssues and proffytts thereof Afterwards the sayd Myles Marlande had yssue of
his bodye Lawfullye begotten one Willm Marlande & after the sayd Myles Marlande dyed, by &
after whose decease all and singuler the sayd p^rmisses w^th their appurtenncs did discende and
come to the sayd Willm Marlande as sonne and heyre of the sayd Myles beinge as yet an
Infante about viij yeares of age by force whereof the sayd Willm Marlande th infante ys
Lawfullye seised of the same p^rmisses by force of the discente aforesayd w^thout that that
the sayd Thom^as Marlande in the bill named was seised in his demeane as of fee of and in
the Lands in the bill menconed Lyinge in Reddiche in the countye of Lanc in manner & forme as
in the sayd bill of Comp^lt ys untrulye alledged & that he did & coulde by good and sufficiente
conveyance and assurance in the Lawe Bargayne & sell the same Lands & tenements and all
the Evidences concerninge the same to the sayde Complt and his heyres in manner & forme as in
the sayd bill of complaynte ys also untrulye set forthe to the knowledge of this Deft
And this Deft further sayth that a lytle before the deathe of the sayd Myles Marlande he the
sayd Myles did delyver to this Deft certeyne pcelles of Evidences tuchinge and concerninge the
landes in the bill named and at the same tyme wylled this Deft safflye to keepe the same
to the use of his sonne Willm and at his full age to delyver the same to the sayd Willm
Marlande the Infante w^ch Evidences this Deft keepethe to the usses affroresayde as he thinkethe
ys Lawfull for him to doe w^thout that that this Deft hathe by any force Casuall meanes
gotten into his handes & poss' [possession] the deeds and Evidences belonginge to the p^rmisses & As the Complt

in suche manner & forme as yn the sayd bill of Complay^nt ys also untrulye surmysed or that he
maketh any tytle to the sayd Evidencs in any other manner than ys before expressed or makethe
any tytle to the sayd Landes or interrupted the Comp^t of or from the possession of the same Landes
or hathe made any secrette or fraudulente estate of conveyance Landes to psons
unknowne in suche manner & forme as in the sayd bill of Complt ys moste scanderouslye set forthe
w^thout that that any other matter or thinge materiall in the sayd bill of Complt to be answered unto
and is in this answere sufficientlye answered [rest of line under fold]
all w^ch matter this Deft ys Readye to Averre ... as this honorable Courte shall Awarde and
prayethe to bee dysmissed out of this moste honorable Courte w^th his Reasonable costes and chardges