National Archives File C5/419/79

Answer of Thomas STUDWICKE of London

The Several Answer of Thomas STRUDWICKE of London Grocer one of the defendants to the Bill of Complainant of Jane CLIFTON Widow Complaint

1660

All advantages of exception to the manifold uncertainties insufficiencies and other apparent imperfections of the said Complainants Bill of Complainant now and at all times hereafter saved and reserved to this defendant. And for a full and perfect answer to so much as concerns him make any answer // thereunto this defendant sayeth that true it is that Henry STRUDWICKE in the Bill mentioned deceased was Brother to him this defendant but whether the complainant be executor administrator to John CLIFTON in the bill mentioned or what transactions were between the said Henry STRUDWICKE and John CLIFTON concerning // the loans of money or otherwise or concerning any security given as by the Bill is pretended this defendant knows not but is a mere stranger thereunto. And saith that he believes the said Henry STRUDWICKE died about the time as by the bill is observed and that his three daughters were disposed in marriage in his // life time but how well this defendant cannot say and that his son is about the age in the Bill expressed but what estate real or person the said Henry STRUDWICKE left or to what value this defendant knows not but is likewise a mere stranger thereunto but hath heard and doth believe that the same // Is not sufficient to satisfy such [?] debts as he the said Henry was engaged to pay. And this Defendant doth deny all manner of combination confederacy or undue practice whatsoever with Richard STRINGER Philip TULLET Henry YOUNG and William STRUDWICKE in the Bill mentioned or with any of them or with // any other person or persons whatsoever to any such or other purposes as in the Bill Mentioned is falsely and scandalously suggested. And absolutely denies the having [?] intermeddled with any the estate of the said of the said Henry other than this defendant doth confess that for and in consideration of one penal bond of the sum if twelve // hundred pounds wherein this defendant became bound as security with the said Henry STRUDWICKE unto one Thomas ASPLY conditioned for payment of the sum of six hundred and eighteen pounds of like money at a day long since past. As also for and in consideration of the sum of one hundred and fifty pounds lent unto this // Said Henry to be repaid with interest he the said Henry STRUDWICK by his indenture bearing date in or about the second day of day in the year of our Lord one thousand six hundred fifty two [1652] did convey unto this defendant and his heirs and assigns all that his messuage and farm and all those lands and tenements // and hereditaments called Foxbridge Strudwicke lands alias Preist and Chapel field or by any or other name or names or by any other name or names whatsoever situate lying and being in Kirdford in the County of Sussex. And all other the messuages and lands tenements and hereditaments // of him the said Henry late purchased to him and his heirs of William STRUDWICKE of Hill Green in the parish of Kirdford aforesaid and of Henry STRUDWICKE his son together with his barns and buildings in Plaiste in the parish of Kirdford aforesaid with the appurtenances which this defendant [?] // is lawful for him to enjoy. But doth again deny the ever having enjoying or intermeddling with any other the estate belonging to the said Henry STRUDWICKE nor [?] that any other the defendants by confederacy or otherwise hath so done without that any other mater or thing // material or effectual in the law to be answered unto by this defendant and not herein and herby confessed or avoided transversed or denied or otherwise sufficiently answered unto is true to the knowledge of this defendant. All which this defendant is ready to answer maintain and prove as this // Honourable Court shall award. And humbly prays to be hence dismissed with his reasonable costs and charges in this behalf wrongfully suffered. //

William BEVERSHAM

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