National Archives File C2/CHASI/H109/35
To Right Honourable Edward Lord Littleton Lord Keeper of the Great Seal of England
Humbly complaining showeth unto your good Lordships your daily Oratrix Elizabeth HARLOW the [?] widow of Mountague HARLOW late of St Andrews Holborn in the County of Middlesex Gentleman, that whereas about fifteen years since in the year of our Lord 1627 your Oratrix said husband did deposit the sum of one hundred pounds of lawful English money into the hands of his brother Pedaell HARLOW late Chancery Lane on the county aforesaid [also?] who [?] for it. And whereas the said Mountague HARLOW being determined to go beyond the seal did in or about the year 1629 make his last Will and Testament in writing and thereby made your Oratrix sole executrix giving and bequeathing unto her the sum of four score pounds to be paid out of that hundred deposited as aforesaid by the said will relation there unto being had and will appear more at large.
And whereas the said Mountague HARLOW did upon going his voyage give unto your Oratrix the bond aforesaid willing her at two years end to call in the money from his brother Pedaell and within a few years after died without ever altering or revising the said Will.
And whereas your Oratrix did on or about the third of December in the year of Lord 1636 due form of Law prove the said Will in the Prerogative Court of Canterbury. And after the will so proved [?] demanded of the said Pedaell HARLOW the hundred pounds deposited as aforesaid but could never yet obtain the sum nor the particular interest nor any part of it from him but [?] of your Oratrix poverty and [?] and to [prevent?] her of all relief [?] he the said Pedaell HARLOW [?] and fraudulently got from your Oratrix his fore said bond and caused her to subscribe and seal a writing which she being illiterate and not knowing what it was hath since heard to be a general acquittal or release. And about Christmas last the said Pedaell HARLOW died processed of a great personal estate sufficient to satisfy all his debts with a great surplus laving Elizabeth his Wife and one William STUDDELL of Drury Lane in the county of Middlesex his executors, who since his death hath possessed themselves of his estate and proved his said Will in due form of Law. And the said Elizabeth since the death of her said husband hath intermarried with one Edward ANDREWS of Grays Lane Gentlemen who together with the said Elizabeth and William STUDDELL refuse to pay the said hundred pounds or any part thereof unto your Oratrix although they have [?] there unto diverse times requested by your Oratrix in regard she cannot produce the bond aforesaid and that they pretend they have a writing from your Oratrix which they give out to be a general release which if it be was yet [?] fraudulently obtained from your Oratrix as aforesaid by the said Pedaell HARLOW by means [whereby?] your Oratrix is like to lose the said debt and greatly to be [dismissed?] unto your Lordships relieve her in this Honourable Court. In consideration where and for as much as your Oratrix can have no relief at the Common Law for the said hundred pounds for that the said Pedaell HARLOW a little before his death, cunningly and fraudulently got the said bond he entered into for the payment thereof into his own hands may it therefore please your good Lordships to grant unto your Oratrix his Majesty’s Most Gracious writ of subpoena to be directed to the said Elizabeth ANDREWS Edward ANDREWES and William STUDDELL and to every of them thereby commanding them and every of them at a certain day and under a certain pain therein to be limited personally to be and appear before your Lordships in his Majesty’s Court of Chancery then and there to answer to the premises and further to [?] such order and direction therein as to your Lordships shall seem to [?] with right equity and good conscience. And your Oratrix shall duly pray.
William Lying.