National Archives File C9/426/66
Bill of Complaint
10th November 1683
Humbly complaining showeth unto your Lordship your Orator Henry CLIFTON of Wipley in the parish of Worplesdon and County of Surrey and // that your Orator having occasion for some monies did on or about the month of June in the year of our Lord God one thousand six hundred sixty and six [1666] now of one Hugh ROBINSON since that time departed this life the sum of one hundred and fifty pounds and for the securing of the repayment // thereby with interest after the rate of six pounds [per?] annum on or about the seventh day of June which was in the year of Our Lord God one thousand // six hundred and sixty and seven [1667] your Orator did by indenture of bargain and sale for one thousand years mortgage unto the said Hugh ROBINSON // One close of meadow ground called or know by the name West Meade containing by estimation five acres or thereabouts lying in the tithing of Normandy // In the parish of Ash and County of Surrey aforesaid and close of meadow ground called Cobbetts Meade containing five acres or thereabouts in Ash aforesaid // and one parcel of meadow ground in Worplesdon aforesaid containing five acres or thereabouts and in some short time after that the said Hugh ROBINSON departed // this life intestate without issue and administration of all and singular the goods and chattels rights and credits of the said intestate was duly committed by the Lord // Bishop of Winchester in the month of June in the said year one thousand six hundred and sixty seven [1667] unto William ROBINSON and George ROBINSON his // Brothers but one Elianor BIGNOLD of Worplesdon aforesaid widow and relict of John BIGNOLD deceased then Eleanor BURT pretending and suggesting to your Orator // that she was well entitled to the said security and monies thereon due did by her crafty insinuation prevail with your Orator to give her the said Elianor // a new security for the said monies and at the same time the better to induce your Orator to enter into such new security she the said Elianor did promise and // Engage to your Orator very speedily to produce her title which she had to the said old security from the said Hugh ROBINSON and also to deliver up to // Your Orator the said old security in regard that your Orator alleged and she the said Elianor did agree that it was reasonable that she should have two // securities for the said monies and your Orator hath since that time paid unto Angelo BURT a brother of the said Elianor the sum of one hundred pounds // part of the said monies due on the said securities and hath also discounted with her the said Elianor eighty pounds being a debt originally due unto your Orator // from the said John BIGNOLD the late husband of the said Eleanor both which sums do amount unto the sum of one hundred and eighty pounds and did // clear if not altogether yet to a very small matter all money which was due upon the securities or either of them. But now so it is may it please // Your Lordship that the said Elianor BIGNOLD combining and confederating with the said Angelo BURT and William ROBINSON the surviving administrators of the said // Hugh ROBINSON (the said George ROBINSON being as in truth he is departed this life) to charge your Orators with a [?] payment of the said one hundred and fifty // pounds and interest doth not only refuse to produce her title to the old security and monies thereon due and to deliver up the said old security and to allow // the aforesaid monies paid to the said Angelo BURT and monies discomputed as aforesaid or any of them but doth endeavour to recover the said one hundred // and fifty pounds and interest on the said old security and also as much likewise on the said new security and the said William ROBINSON the surviving // [administrator?] doth thereafter your Orator that he will force your Orator to pay the said one hundred and fifty pounds and interest to him the said William ROBINSON // And the said Elianor for the better offering and bringing about those her [?] designs hath caused a declaration in [?] to be delivered for // the premises and hath brought the same to trial and hath obtained a verdict against your Orator at the last summer assizes [?] for the said // County of Surrey and doth give in speeches that she will strip your Orator as the possession of the same albeit that she knows in her [?] // conscience that the said monies are all discharged or at least very little thereof is due and arrears all which doings of the said confederates are // contrary to equity and good conscience in tender consideration whereof and for as much as your Orator is not able to [?] the said payment // The said hundred pounds and discount of the said eighty pounds nor other the premises but by the oaths of the said confederates for what that // Your Orators witnesses who should and could prove the same are either dead or gone into places remote unknown unto your Orator for [?] your orator // Cannot produce the same to the end therefore that the said confederates may as true and particular answer make unto all [?] the premises as if her // Repeated and interrogated and that the said Elianor BIGNOLD may be compelled to allow of the said one hundred pounds and eighty pounds paid // Discounted as aforesaid and may set forth her title to the said old security and if she hath not any but that the said monies shall appear to be // The said William ROBINSON that the said one hundred pounds and eighty pounds may be repaid to your Orator and that the said new security may be // delivered up to be cancelled and that the said old one also on payment of which shall appear to be due thereon to the [?] concerned in justice to receive // the same may be discharged and that your Orator may on payment thereof be quitted against the said confederates several claims and may be // relived in all and [?] the premises as to justice and equity shall [?] and that the said proceedings at Common Law may be [payed?] by the // Injunction of this Honorable Court may it please your Lordships to grant unto your Orator His Majesty’s gracious writ of Subpoena [?] of the High Court of Chancery // To be directed unto them the said Elianor BIGNOLD Angelo BURT and William ROBINSON commanding them and either of them thereby at certain time // and under a certain pain therein to be limited personally to be and appear before your Lordships in His Majesty’s said High Court of Chancery // Then and there to answer the premises and to abide such order therein as to Your Lordship shall seem meet. And your Orator shall [always?] pray.
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