National Archives File C6/162/44
Contents
People Mentioned in the Proceeding. 1
Bill of Complaint of Jane CLIFTON.. 1
Answer of William STRUDWICKE. 4
Answer of Richard STRINGER the Younger and Henry YOUNG.. 8
People Mentioned in the Proceedings
- John CLIFTON (1595-1659) lived at Worplesdon and Wanborough Surrey, married to Jane.
- Jane CLIFTON (-) lived at Worplesdon and Wanborough Surrey, married to John. Complainant in the Chancery Bill.
- Henry STRUDWICKE (1603-1660?) of Crouchland, Kirdford, Sussex
- William STRUDWICKE son of Henry
- Jane STRUDWICKE daughter of Henry but not named in this document (Souce Henry’s PCC 1662 Will)
- Katherine STRUDWICKE daughter of Henry but not named in this document (Source Henry’s PCC 1662 Will)
- Jane STRUDWICKE daughter of Henry but not named in this document (Source Henry’s PCC 1662 Will)
- Dullsabella STRUDWICKE daughter of Henry but not named in this document (Source Henry’s PCC 1662 Will)
- Richard STRINGER, of Petworth, Sussex (Trade Token 1652) PCC Will 1662
- Philip TULLETT of Dunsfold, died 1684 Dunsfold, possible 1638 baptism.
- Henry YOUNG, servant to Henry STRUDWICKE
- Richard GILMAN, tenant
- John BROMWELL, of Dunsfold
- John SHERLOCK, Shalford, died 1666, Will Proved London 1666.
- John TANNER
- Mr STEPHENS, of Ash
- John CAPLIN,
- John WALDEN,
- Thomas MILLS,
Bill of Complaint of Jane CLIFTON
?th November 1660
To the right Honourable Edward Lord HIDE Lord Chancellor of England
Humbly Complaining showeth unto your Honour your daily Oratrix Jane CLIFTON of Worplesdon in the County of Surrey widow relict and executor of John CLIFTON [?] // late of Worplesdon aforesaid Gent deceased. That whereas one Henry STRUDWICK late of Crouchland in the parish of Kerford [Kirdford] in the County of Sussex Gent. deceased did [in?] his [life?] // time that is to say in or about the month of June in the year of our Lord 1650 borrow of the aforesaid John CLIFTON your Oratrix late husband the sum of one hundred and [twenty?] // of lawful English money. And for the repayment thereof and three pounds and seventeen shillings for interest upon the second day of December then next [?] // he entered into to your Oratrix said husband and obligation of the penal sum of two hundred and forty pounds bearing date on or about the first day of June in the [?] // year of our Lord 1650 but the said Henry STRUDWICK did not pay the said one hundred and twenty pounds or interest or any part thereof on the said // day since but in or about the month of December last past suddenly died intestate leaving three daughters who were all in his life time well-disposed [in?] // marriage and only one son named William about the age of nineteen years and the said Henry STRUDWICK left a very great personal estate much of it [?] // a stock of iron and iron work he being an Iron Master and of wood coals and timber and a great deal of it likewise in [?] with household stuff and in Cattle [?] // oxen, cows, horses, sheep, swine and of corn hay and good debts for iron and timber sold by him in his life time and in same leases of Iron works and [hammers?] [?] // [?] then of a far greater yearly value then the rent reserved by reason of fines which he paid and charged of Materials and Utensils which himself bought and [?] // the said works [withal?]. All the said personal estate amounting to sufficient all his debts with a surplus to such person as should have [?] // of Administration of the same. But so it may please your Honour that shortly after the said Henry STRUDWICK was dead one Richard STRINGER of Petworth in the County of // Sussex Gent. Thomas STRUDWICK of London grocer and brother of the Henry STRUDWICK, and Philip TULLETT of Dunsfold in the County of Surrey aforesaid yeoman [?] // [servant?] to the said Henry in his life time Henry YOUNGE a servant to him also at his death, and the said William STRUDWICK the son (And diverse others yet to [?] unknown whose names when they shall be discovered she prayeth may be inserted into this Bill, that they may be likewise made defendants ) combined and confederated // Themselves together to possess carry away conceal and convert to their own uses and to share amongst themselves. All the said personal estate of the said Henry STRUDWICK // and in pursuance of their said confederacy they the said confederates have accordingly possessed carried away concealed and shared the said estate amongst themselves [?] // Richard STRINGER pretending that the Sheriff of the County had in the life time of the said Henry STRUDWICK seized such part of the said goods and chattels as he doth [?] // By virtue of [?] [?] which he had against the goods of the said Henry. And that by virtue thereof he sold them unto him, and the said Philip TULLETT pretendeth that [?] // A bill of Sale from the said Henry in his life time of a great deal of Iron and [?] and wood and coal. And in assignment of a lease of an Iron works which [?] // Possession in Kirdford or in Dunsfold aforesaid. And the said William STRUDWICK having sold and otherwise disposed of much household stuff linen plate pewter [?] // Cows and cattle and possessed himself of the ready money left by his said father giveth he that done it as servant to the other confederates or some or another [?] // and the said Thomas STRUDWICK hath possessed himself of other part of the said Goods and privately conveyed the same away. And the said Henry YOUNG hath likewise [?] // Himself of a great part of the said personal estate. Although your Oratrix (to whom the said 120 pounds and interest due for the same is now due as executrix [of the ?] // Will of the said John CLIFTON who made the same about November last and about January last dyed […] hath in [?] manner sent unto and requested the said confederates [?] // unto him the said money so one as aforesaid or to discover unto her wherefore and [?] what [?] they have so concealed and shared the said estate amongst themselves [?] // Refuse to give her any satisfaction therein or to declare or acknowledge particularly what good goods (or of what value they are) which they do possess or have possessed which [?] // of the said Henry STRUDWICK. And therefore and for that the said confederates do pretend title and interest to those several parts of the said personal estate which each of them // By some acts or deeds done or made by the said Henry STRUDWICK in his life time but refuse to produce or show them to your said Oratrix. And your Oratrix living many miles [?] // From Kirdford the place where the said Henry STRUDWICK died and his estate did by the said confederates had better opportunity to conceal the same which they did. And [?] // Also for that the said William STRUDWICK who hath possessed himself and sold and disposed of much of the said estate is yet within the age of ne and twenty years there is [?] // All and by the Common Law to recover the said debt but is likely to lose the same in delay and hindrance of payment of the debts and legacies of her deceased husband which now [?] // To right equity and good conscience. In tender consideration whereof and to the end that the said confederates may discover upon their oath severally and respectively // and what particular goods and chattels household stuff linen plate pewter brass lease on lease stock of iron [?] coal wood timber ready money cows oxen household [?] // Corn, hay or other goods or chattels whatsoever they had possessed or do possess or have possessed which was the said Henry STRUDWICK’s or in his use or occupation or possession [at the?] // Time off his decease and by what means and by what agreement and with whom and when they came by on to the same and how they have disposed the same And [?] // If they can wherefore your Oratrix should not be satisfied the debt of 120 pounds and interest aforesaid for the same out of the said personal estate. And to the end that the [?] // Confederates may answer to all and every the charges of this your Oratrix Bill that she may be relieved in the premises according to Justice and Equity. May it please your // [Honour?] to grant unto your said Oratrix the Kings Majesties’ Most gracious writ of subpoena to be directed to the said William STRUDWICK, Thomas STRUDWICK, Philip [TULLETT] // Richard STRINGER and Henry YOUNGE commanding them thereby at a certain day and under a certain pain therein to be limited personally to be and appear before your // In the High Court of Chancery to answer the premises. And to stand to and abide such further order and direction therein as to your Honour shall seem to be most [?] // Right equity and good conscience. And your Oratrix shall dayly pray.
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[IMG_7914]
Answer of William STRUDWICKE
The several answer of William STRUDWICKE an infant by [?] COUCHMAN his Guardian to Bill of Complaint of Jane CLIFTON widow Complainant
This defendant saving to himself now and at all times hereafter all advantage and benefit of exception to the uncertainties and in of the sufficienices of the said Bill of Complaint for a full and perfect answer // to so much thereof as concerns him this defendant to answer unto, this defendant saith as followeth. And first this defendant saith he verily believes that it may be true that Henry STRUDWICKE this defendants late // father in the Bill named did in his life time about the time in the Bill set forth borrow of John CLIFTON in the Bill mentioned in his life time the sum of money in the Bill set forth. But what security he gave for the // repayment of the same or when the same was to be repaid or whether the same be as yet repaid he this defendant knoweth not. And this defendant also verily believes that it is likewise true that the defendant’s // father did die on or about the latter end of the month of December in the year of our Lord one thousand six hundred and fifty nine [1659]. But whether he made a Will in his lifetime or not this defendant // knoweth not nor how well this defendants three sisters are disposed in marriage. And this Defendant saith that he verily beleiveth he is of and hath attained the age of nineteen years or thereabouts. And that // the said Henry STRUDWICKE this defendant’s father at the time of his decease left a very great stock of Iron and Iron Works and wood coals and timber. And a great deal of it in rich household stuff // [?] in Cattle to wit Oxen, Cows, Horses, Swine, sheep and of corn hay and good debts for iron and timber and of [diners?] leases of iron works and hammers. To wit Dunsfold Hammer, Burton Hammer[1] // and Mill, Dedisham Furnace[2] and Cranlye [Cranleigh] Hammer. But the hard value thereof this defendant knoweth not or what [fines?] were given or paid by this defendant’s father at the time of the taking thereof for the obtaining of the same // and also of Materials and utensils which this defendant father bought and made for the [?] of the said several works with all But whether the said personal estate is sufficient to satisfy all this defendant’s father’s debts this defendant // Knoweth not for that he dies [?] debted and this defendant knoweth not of the Accounts or values of this Defendant’s father’s personal estate the several books of accounts still being and remaining in this Defendant’s // Father’s casks hands and for that this defendant cannot find any account of the same given in at all either in this defendants fathers life time or of any amongst that were paid in to this defendants father in his life time as // profits or part or parts of the [stock?] of the said several works. And this defendant for further answer confesses that upon and [?] after the [?] [?] of this Defendant’s father he this Defendant did possess himself // of all the goods household stuff cattell and chattels of this defendant’s father left in his then dwelling house of Crouchland and on his lands which was not nor had been privately conveyed away by others [?] know to this // defendant and sold corn and other goods and chattels part thereof for the payment of this defendant’s father’s funeral expenses and to pay servants wages and for and about manuring and tilling [?] he going and [?] the // said lands and repairing of the pond heads on the said lands and had [through?] this defendant’s [?] and care sowed fifty acres part of the said lands or thereabout with wheat and a great part of the rest of // the land with oats and pease amounting in all to a very great value which this defendant hopeth under [favour?] of this Honourable Court it was lawful for him so to do he this defendant being the only son and heir // of the said Henry STRUDWICKE deceased. And this defendant being so possessed saith that one Richard STRINGER one of the defendants whether by virtue of some old mortgage of the premises long ago paid and discharged // or of some extent upon some statue merchant or staple or of some judgement or mortgage lease made of the premises by this defendant’s father in his life time to one Christopher COLES of Pulborough in the said County of // of Sussex for some [?] all sum of money but the certain time thereof this defendant knoweth not which said lease this defendant verily beleiveth the said COLES hath assigned to the said Richard STRINGER did on or about the month of // of July last past before this defendant could take any benefit of his Crop enter into and upon the possession of the messuage and dwelling house of this defendant’s late father called Crouchland aforesaid and upon all or // most of the lands there unto belonging and did possess himself of all this Defendants late father’s goods then being in the same messuage and barns thereunto belonging and about the house to the value of four hundred // pounds and upwards and did possess himself of all the corn grain utensils of husbandry then there standing growing or being to a very great value to this Defendant unknown and hath set out the said Messuage // and lands to one Richard GILHAM at undervalued rent as this defendant hath heard so that this defendant [?] of his charge of tilling the said land, payment of servants wages, charge of his father’s // funeral and of housekeeping during the time this defendant did manage the dealings these is left much out of wise [quit?] outed of the possession of all the messuages and fee simple of his late father // And of all the said gods Chattells Cattell house household stuff and utensils of husbandry and the said Richard STRINGER hath either sold and converted the same to his own use or otherwise disposed thereof to then the said // GILHAM or other others. And this defendant for further answer saith that he did [?] to have obtained letters of Administration of his late Father’s goods Cattell Chattels and debts but hath been hindered from the // obtaining of the same by real or pretended creditors of his said late father. And this defendant for further answer denies that he did ever confederate himself with the rest or any one or more of the defendants to conceal // or [convert?] or share the personal estate of his said father under any pretence whatsoever as in and by the said Bll l is entirely furnishes. And this defendant verily believes that the defendants Phillip TULLETT Richard STRINGER // Henry YOUNG due John TANNER and the said Richard GILHAM have possessed themselves of all the rest and remainder of this Defendant’s father said personal estate and of all his leases of his said Ion Works and furnaces // But whether it be by virtue of any executor or executor’s Bill or Bills of Sale or any other format conveyances or judgments this defendants knoweth not without that any other matter or thing in the said // Bill of Complainant contained material and effectual in Law for this defendant to make answer unto and not [?] [?] hereby well and sufficiently answered unto confesses and avoided [?] or denied is true to the // knowledge of this defendant. All which matters and things this defendant is ready to [?] maintain and give as this Honourable Court shall award. And humbly prayeth to here dismissed with his reasonably costs and // charges in this behalf most wrongfully sustained.
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Answer of Phillip TULLETT
6th May 1661
The answer of Phillip TULLETT one of the defendants to the Bill of Complaint of Jane CLIFTON widow Complainant
The said defendant saving to himself now and at all times hereafter all and all manner of exception to the manifold uncertainties and insufficiencies of the said Bill of Complainant for answer // unto so much thereof as concerns this defendant to make answer unto he saith as follows. And first this defendant saith the he doth not know that the said Henry STRUDWICK // deceased in the Bill named in his life time borrowed of John CLIFTON the complainant’s husband the sum of one hundred and twenty pounds or any other sum neither // doth this defendant not know the [?] repayment thereof with interest of the said Henry STRUDWICK did enter into such obligation or any obligation as in the Bill is alleged // neither doth this defendant know whether the said Henry STRUDWICK in his life time paid unto the said John CLIFTON in his life time or unto the Complainant since his // [decease?] the said one Hundred twenty pounds with interest or any part thereof But this defendant doth believe that the said Henry STRUDWICK about the latter end of the month of // December in the year of our Lord one thousand six hundred and fifty nine [1659] did [?] estate leaving three daughters and one son that the [?] three daughters // were all married as in the Bill is set forth. And this defendant for further answer saith that he knoweth not what personal estate or of what value the personal estate [?] the said // Henry STRUDWICK deceased possessed of nor what are or were the [?] thereof nor what debts were owing to the said Henry STRUDWICK at the time of his death // Neither hath he this defendant or any other person or persons to his this defendants use possession themselves of any the personal estate of the said Henry STRUDWICK save only a certain // Personal estate hereafter mentioned in a certain deed of bargain and sale bearing date the twenty eight day of December in the year of our Lord one thousand six // hundred and fifty nine [1659] made from the said Henry STRUDWICK in his life time unto this defendant and the other defendant Henry YOUNG whereby the said Henry STRUDWICK for the consideration // Mentioned in the said deed [?] this defendant and if … for him [after?] his [proper?] debts unto the several person following to wit to one John BROMWELL of Dunsfold // in the county of Surrey in of sum of four hundred pounds also to one John SHERLOCK of Shalford in the said County in the sum of one hundred and nine pounds to one Mr // STEPHENS of Ash in the same County Gent in the sum of one hundred pounds to one John CAPLYN forty pounds. To one Thomas MILLES in the sum one hundred // Fifty pounds which debts in truth they did fraud [?] for the said STRUDWICK alleged for if considerably that the said Henry STRUDWICK owed to the defendant YOUNG upon [?] the // sum of one hundred pounds of the sum of forty pounds owing by the said STRUDWICK to this Defendant did by the same deed of bargain and sale give grant bargain sell assign // And [?] unto the defendant YOUNG. All that the indenture of lease of one forge called by the name of Dunsfold forge and [five] [work..?] houses and all Garden [?] [?] // to [?] forge with all other the appurtenances thereto belonging, to have and to hold all and singular of said indenture of lease and [?] therein comprised during the term of three years from the // date of the same deed of bargain and sale. And the said Henry STRUDWICK for the consideration aforesaid by that same deed did [?] assign and set over unto the said defendant YOUNG all that // his stock of coals and sows of Iron [?] Iron lying and being about said Dunsfold [?] and all the tools and all casts [?] about the forge. And all Iron sower lying [?] // // Between Dedisham furnace and the said forge. And all the bargain of wood and timber in certain [lands?] of the said John BROMWELL in Dunsfold aforesaid and all the stuff of barrel boards // cannot [?] hollow ware there in the workhouse to have and to hold the said coals sows timber stuff and [?] to this defendant and the said defendant YOUNG as their own [?] // And chattels. As in [?] the same deed duly executed by the said Henry STRUDWICK in the life time and when he was of perfect mind and memory and remaining in the defendants custody // Whereto this defendant for more certainty thereof refers himself more plainly and at [?] doth and may appear. And this defendant saith that said lease of the said forge [?] // [?] by reason it was in great decay for want of repair was little worth above the yearly rent there upon received for that this defendant together with the said defendant YOUNG // Did affirm the same lease to Mr John WALDEN for the consideration of five pounds which was as much or more then the same was worth. And this defendant confesses that // he was an agent and servant to the said Henry STRUDWICK in his life time. And he further saith that by the fair [?] that the said Henry STRUDWICK in his life time he // this defendant became bound to the said John BROMWELL for the [?] debt of the said STRUDWICK by several obligations for the [true?] payment of the said sums of four hundred // hundred pounds mentioned in the deed aforesaid. And also to the said SHERLOCK by obligation for the [true?] payment of one hundred pounds and interest and also to the // Said Mr STEPHENS by obligation for the true payment of the like sum of [?] hundred pounds with interest which were the [?] debts of the said STRUDWICK in his life // time a mentioned in the deed aforesaid and this defendant had no satisfaction for the same sum passing by the bargain and sale aforesaid. And this defendant saith that since the death of // the said Henry STRUDWICK he hath paid for principal and interest on the said several obligations aforesaid charges in law by reason this defendant could not raise so [?] [?] // At an instant the sum of five hundred and twenty one pounds or thereabouts. And that the personal estate which came to this defendants hands by virtue of the said deeds of bargain // Estate did not amount to above the value of five hundred pounds at the most. So that this defendant hath paid for the said Henry STRUDWICK person debts the sum // Of two hundred and twenty one pounds at the least more than in he hath received of the said personal estate which came to this defendants hands as aforesaid over and besides [?] // the said sum of forty pounds and interest for the same due to this defendant by the said STRUDWICK in his life time. And this defendant denies that he hath refused [?] to this // Complainant satisfaction […] or to declare what wood or what value they were the he did possess himself of which were the said Henry STRUDWICKE but hath declared the Jane // Complainant or some or one on her behalf and hath formerly showed the said deed of bargain estate to the Complainant’s Counsel. And this defendant denies that he // or any other person or persons to his use have or hath possessed him or themselves of all or any the personal estate of the said Henry STRUDWICKE save only what // Is before [?] by way of answer set forth which the [?] under this favour of this of this Honourable Court was lawfully him so do. And this defendant denies all [?] // The [?] combination confederacies charged in and by the said Bill upon him this defendant without that that any other matter or thing in the said Bill of Complainant claimed material or effectual // [? [?] for him this defendant to make answer unto and not therein and thereby by sufficiently answered unto confessed and avoided answer, denied true to the // Knowledge of him this defendant. All which matters and things this defendant is ready to declare prove as this most Honorable Court shall award. And the Defendant // Humbly prayeth to be hence dismissed with the reasonable costs and charges in this most wrongfully suffered.
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[IMG_7921]
Bill of Jane CLIFTON
[Transcript fairly rough as original handwriting is hard for me to read]
To the right Honourable Edward Lord HIDE Lord Chancellor of England
[?] Jane CLIFTON of Worplesdon in the County of Surrey Widow executrix of John CLIFTON [Gent] deceased the one Henry STRUDWICK of Crouchland in the parish of Kerford [Kirdford] in the County of Sussex Gent. deceased about June 1650 borrow of the said CLIFTON 120 pounds for [?] thereof // [?] upon the second December then next did himself in the penalty of 240 [?] June 1650 but the said // STRUDWICKE did not pay the said principal debt nor interest. But in to [?] case died intestate [?] being three daughters// [?] disposed of in marriage and but one son named William about the the 19 years […] personal // estate much of it in [?] and [?] in some leases of Iron [?] [?] leases of greatly […] // [?] personal estate being sufficient to satisfy his [?] debt that [?] [?] the said STRUDWICK [?] [?] one Richard STRINGER // of Petworth in County of Sussex Gent. And Thomas STRUDWICKE of London grocer his brother and Philip TULLETT of Dunsfold in the County of Sussex yeoman, Henry YOUNG the said William STRUDWICKE the son and others as yet unknown to your Oratrix, when discovered may be // [?] combined to [?] to themselves the personal estate of the said STRUDWICKE the said STRINGER pretending that the [Sherriff?] // of the county did in his life time seized only the price of his goods as he doth possess by virtue of an [?] and by virtue the [?] [?] // to pretend title to the personal estate which [?] of them [?] enjoy but [?] to these them to your said Oratrix and for that // by the said William STRUDWICKE [?] hath sold much of the said estate to yet [?] ago she is […] but is likely // to lose the same in delay of payment of debts and legacies of her [deceased?] Husband contrary to equity prays [?] // may be made of what goods of the said Thomas STRUDWICKE they hath possessed and by what means and agreement and may she cause [?] // is [oratrix?] should be satisfied by all debts interest and that the said confederates may [?] [?] made is the scope of // [mebitt?].
Richard [GATTS?]
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[IMG_7923]
Answer of Richard STRINGER the Younger and Henry YOUNG
The several answer of Richard STRINGER the Younger and Henry YOUNG two of the defendants unto the Bill of Complaint of Jane CLIFTON widow Complainant
These defendants now and at all times hereafter saving unto themselves all advantages of exception unto the many uncertainties and insufficiencies of the said Bill of Complaint for // answer unto for much thereof as doth materially concern these defendants or either of them to make answer unto say. And first these defendants say that they do not know that the said // Henry STRUDWICKE deceased, in his life time borrowed of John CLIFTON the Complainants husband the sum of one hundred and twenty pounds, neither do these defendants know that further repayment thereof // [with interest] the said Henry STRUDWICKE did enter any obligation as in the Bill is alleged neither do these defendants know whether the said Henry STRUDWICKE in his life time paid unto the said John CLIFTON in // [?] time or unto the complainant since his decease the said one hundred and twenty pounds with interest or any part thereof. But these defendants do believe that the said Henry STRUDWICKE about in the Bill // mentioned died intestate leaving issue three daughters and one son as in the Bill is set forth. And the defendant STRINGER for himself answering saith that he knoweth not of what personal estate or what // value the said Henry STRUDWICKE did possess nor what are or were the particulars thereof nor what debts were owing to the said Henry STRUDWICKE at the time of his decease neither did this defendant since the decease // of the said Henry STRUDWICKE [meddle?] with or interest himself in the personal estate or any parts thereof, neither doth this defendant know that the said Henry STRUDWICKE did possess of any [?] a lease. And // this defendant denies that he combined with any of the defendants in the Bill named or any other person whatsoever to conceal or convert unto his own use any part of the said personal estate. And this defendant also // denies that he by virtue of any execution or otherwise hath carried away or possessed himself of any part of the personal estate and that no other person or person whatsoever (to this Defendant’s knowledge or by // his [?] or direction have disposed or meddled with any part thereof to our for the defendants use. And this defendant Henry YOUNG for himself answering saith that he hath not possessed himself neither hath any // other person or persons (to this defendants knowledge) possessed him or them [?] of the personal estate whatsoever of the said Henry STRUDWICKE deceased save only certain personal estate he [?] mentioned in a certain // Deed of [bargain] estate bearing date the twenty eighth day of December in the year of our Lord one thousand fifty nine from the said Henry STRUDWICKE unto this defendant and the defendant Phillip TULLETT // hereby the said Henry STRUDWICKE for the consideration that this defendant and the said TULLETT stood engaged for him and for his purposes unto the several persons following that is to say to one John BROMHALL of // Dunsfold in the County of Surrey in the sum of four hundred pounds to one John SHERLOCK of Shalford in the same County in the sum of one hundred and nine pounds. To one Mr STEPHENS of Ash in the same // County in the sum of one hundred pounds. To one John CAPLOIN in the sum of forty pounds. To one Thomas MILLS in the sum of one hundred and fifty pounds. And also for the consideration that the // The Henry STRUDWICKE and unto this defendant upon and the sum of one hundred pounds. And the sum of forty pounds unto the defendants TULLETT and did by the same deed of bargain and sale grant sell assign and // Settle over unto this defendant and the defendant TULLETT, all that his indenture of lease of one forge called Dunsfold Forge two iron works [?] houses and all the garden plots belonging to the said forge // With all other appurtenances thereto belonging to have and to hold the said Indenture of lease and premises therein comprised during the term of two years from the date of the same deed of bargain and sale // lying and being about the said Dunsfold Forge and all the tooled and cast iron about the forge and all Iron [?] being in the way between Deyham Furnace and the said forge. And all his // Bargain of [?] and timber lying in the lands of the said John BROMHALLL and all his stuff of barrel bands [pimes?] [?] and hollows [?] there in the workhouses. And in and by the same // Deed who this defendant answereth himself more plaining may appear. And this defendant answereth that the said lease of the forge was of no value to this defendant or the said TULLETT as he believes for that // the same and not worth anything above the yearly rent there upon [?] and that the personal estate by the said deed granted and which thereby came to the hands of this defendant in any wise did not // [amount?] to the value of [two?] hundred pounds lawful money of England which is not sufficient to satisfy the said sums of money unto him owing and for which his [?] engaged // for the said Henry STRUDWICK as above said and which he hath there with since [privately] paid and satisfied [?] (besides the said sum of one hundred pounds unto him owing) [?] he hath paid the said John [CAPLIN?] the // Sum of forty and two pounds and unto [insert] Thomas MILLS one hundred pounds for the debts for the said Henry STRUDWICKE so that they this defendant cannot [?] pay the said hundred pounds to him owing. But is a [?] thereby sixty pounds and more [end insert]. And this defendant denies that he or other person to or for his use (to the knowledge of this defendant) since the decease of the said Henry STRUDWICKE possessed him or // themselves or meddled with or disposed of any the personal estate of the said Henry STRUDWICKE other than the personal estate not being of the part to value of three hundred pounds granted by the deed aforesaid. And both these defendants deny all and every the // [?] combination and confederacy in and by the said Bill charged upon them without that that any other matter charge or thing in the said Bill of Compliant contained material or effectual in // the law for these defendants or either of them to make answer unto. And not [?] by these defendants or one them sufficiently confessed avoided [?] or denied is true to the knowledge of these defendants or either of // them. All which matters and things [?] these defendants and either of them are ready to answer maintain and prove to this Honourable Court shall award. And humbly pray to be [?] dismissed with [?] // reasonable costs and charges in the behalf most wrongfully sustained. //
[Sentence written in Latin] Joh: PAYNE Ro: JOHNSON
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[1] Near Petworth, Sussex
[2][2] Near Slinford, Sussex