Will of John Palmer, 1558

Herts RO 1 AW86

In the name of god Amen the Fyfte day of Aprill in the year of o(ur) lord god 1558. I John Palmer of Wynselow in the Countie of Buck' Beyng somewhat sycke in bodie but having a p(er)fytt memory thanks be to god do ordein and make this my last will and testam(ent) in manor and forme following That is to say Fyrst I bequeythe my Soull unto allmyghty god The blessed virgyn Marie and to all the holye Compeny of Heven and my bodie to be buried in the Churche of saint Laurence in Wynselowe aforesaid in the myddell space of the same Churche. Item I geve and bequethe to the mother churche of saint Albans iiij d  To the high alter of the Churche of saint Laurence aforesaid viij d To the rep(ar)acons of the Belles there iij s iiij d To the repairing & making of the brydge next Addington called the Newbrydge vj s viij d To the poore \folkes/ of Wynselowe aforesaid [sum omitted] to praye for Agnes solle Roger and Alice Soulles and all Cristen Soulles thone half therof at the Buryall and thother at my monethes mynde. I will and bequethe also to Will(ia)m Coxe x s Thomas Coxe x s To George Coxe xx s & The Cheste w(it)hout Fete Item to Marye Coxe x s my wyffes best kyrtell a patten Basen and a Candelstycke. Item to Johanne Coxe thelder x s a Charger, a lytle brasse potte A pewter disshe a Sawcer and a pottynger. And to the Johanne Coxe the yonger xx s and a Chaffer a Coffer w(it)hout a Locke a Basen, a pewter disshe a pottynger and a Sawcer.  Item to Thomas Hedland x s Item to John Stretton xl s xl s my dawghter Johannes sonne xl s To Sybbell Stretton xiij s iiij d and a charger a pewter disshe a Basen a paire of shetes and a table clothe To Elizabeth Stretton xiij s iiij d a Charger, a pewter disshe a Candelstyck & a paire of Shetes & a table Clothe.  Item I will and bequethe to Michell Coxe my Sonne in law my Coate that my nevewe Raffe gave me & my blacke Coate and a Fustyan dublet. And to Alice my daughter my Second bedsted second Fetherbed the second Bolster the second ij pyllowes & pyllowers the second paire of Blanketts and the second Cov(er)lett The Best Candelstyck The best Chaffing disshe The Frying panne, twoo old pannes & a long blacke Chest. Item I will and bequethe to Agnes Stratton xx s and the thryd bedsted the thryd \Fether/ bedde the thryd Bolster the thryd paire of shetes and the thryd Cov(er)lett, my Red Cheste, my wyffes best gowne and the redde petycote, a White Cappe a Charger, a pewter disshe A Sawcer my second panne and my Second best potte. I will and bequethe to my Nevewe syr Roger Palmer a blacke hose clothe and my best dublet and the rest of mine apparell to be disposed amongs poore Folkes of Wynselowe aforesaid. Item I will & bequethe that the hanging Candelstyck of Blasse The Iron Barre in the Chymney, Three hokes of Iron hange on pottes, The Table the Trestells & the Forme now beying in the parlor, my standing Counter in the haulle and an old Chere w(i)th a closse stole in yt shall be & remayne as Implementes of the howse & w(i)th the howse contynually to remayne. Item I will & orden that my best bedsted best bolster, the best Fetherbed the best ij pillows the best ij planketts the best ij pillows the best Cov(er)let the best paire of shetes, my best gowne, my best coate my best brasse potte my best brasse panne my Iron Beme and scholes, my todde wayte & my brasen morter to be sold to [aid?] the p(er)formyng of this my last will and payin of my debts Item to the use of the churche of Winslowe aforesaid for brekyng of the grounde vj s viij d Item I geve to Johanne Palmer \my god daughter/ daughter of my nevewe Thomas vj s viij d And to ev(er)y other of my god childerne & of my wyffes iiij d Item I will & bequethe unto su(m?) honest preest [to sing?] for the Soulles of John John John & John Thomas Richard Henry John Richard Richard Walter Robert & all [Christian?]

[page 2] Soules xx s. And to the mending of the [high?]ways iij s iiij d And to the Regard of thornaments of the said church iij s iiij d And of this my last will & testam(ent) I make & ordein myne Executor my nevewes Thomas Palmer and Rauffe Palmer Ite(m) conc(er)nynge my lands and ten(emen)ts in Winselowe aforesaid and Greneborough in the sayd county of Buck, This is my last will and testament That is to saye I will geve and bequethe all my sayd lands and ten(emen)tes lying & beinge yn Wynselowe and Greneborough aforesaid w(hi)ch I the sayd John Palm(er) doo possesse at the makinge of this my pr(esen)te last will and testament unto my sayd nevewe Thomas Palm(er) to have and to holde the same to him and to his heyres males of of his body lawfully begotten after the deceasse of me the sayd John Palm(er) and of Alys for lacke of soche yssue I will geve and bequethe all my sayd lands and t(eneme)nts w(i)th thpp(ur)ten(an)ces unto my sayd nevewe Rauffe Palm(er) To have and to holde the same to him the sayd Rauffe and to his heirs males of hys body lawfully begotten after the decease of me the sayd John Palm(er) accordyng to the custom(m)e of the mann(or) of Wynslowe And for the default of suche Issue to Remayne to the Right heyres of me the said John for ev(er) accordinge to the custom(m)e of the sayde mann(or), Provided also and this is my laste will and testament further that he to whom theis my sayd lands and ten(emen)ts shall after my decease and c(o)mme by vertue of this my laste will & testament at anny \tyme/ w(ith)in fourtene yeres next after the deceasse of me the sayd John, shall p(er)mytt and suffer my Daughter Alice Cocks peaceably and quietly to have holde occupie and enioye all the said lands and ten(emen)ts and eny p(ar)te and p(ar)cell of the same w(i)th thapp(ur)ten(an)ces for and during the hole terme of Fourtene yeres next and im(m)ediatly followinge after the decease of me the sayd John Palm(er) w(ith)owte payinge any thinge for the same saving that the said Alice shall bere and paye all mann(er) of quytrents and dutyes goyng owte and being due of or for the same lands and ten(emen)ts or of any p(ar)te or p(ar)cell of the same and also making sufficiently From tyme to tyme during the sayde terme all mann(er) of Rep(ar)ac(i)ons of the howses and buyldings of the same p(re)mysses w(i)the thapp(ur)ten(an)ces And that he the sayd p(er)sonne to whom(m)e the sayd p(re)mysses shall com(m)e in mann(er) and forme before declared shall stande bounde by obligac(i)on unto the sayd Alyce my daughter to p(er)mytte and suffer her to have and occupie the same p(re)mysses accordingly And yf he to whom the same p(re)mysses shall com(m)e shall other refeuse so to be bounden or shall not p(er)mytt and suffer the same Alice my daughter to have and occupie the saide p(re)mysses w(i)the thapp(ur)ten(an)ces accordinge as before is declared Then I will that this

[page 3] my sayd Gyfte of the p(re)mysses and ev(er)yethyng therein conteyned to be utterly voyde and of none effecte. Item I will also that my said howse and Land w(i)th thapp(ur)ten(an)ces shall be yerely charged w(i)th iij s iiij d to kepe my obyte for my \soulle/ my wyffes soulle & all my Frendes Soulles and all cristen soulles after the xiiijtene yeres expired \next/ after my deceasse. Wytnes to this my last will John Boston, Michaell Coxe, Will(ia)m Parott, John Cowper Will(ia)m Jackson Richard Forest, and Thom(a)s Horwood

[Latin] Probatum fuit presens testamentum decimo septimo die mensis Novembris Anno Domini 1558 Commissaque fuit administratio &c Thome Palmer uni executorum in huiusmodi testamento nominatis, Primitus [insertion deleted] in debita Juris forma Jurato, Salvo &c.

[l. margin] in persona Willelmi filii et procuratoris sui

[translation] The present will was proved on 17 November 1558, and administration was entrusted, etc., to Thomas Palmer, one of the executors named in this will, having first been sworn in due form of law in the person of his son and proxy William, notwithstanding etc.

Inventory of John Palmer, 1558

Herts RO A25/337

An Inventory made the xxxth day of September 1558 & between [----] of the goods & chattells late John Palmers of Wynslowe in the Countie of Buck' deceassed Praiysed By Will(ia)m Jackeson, Rob(er)t Webbe, Roger Shelton, Will(ia)m Glanester, John Cowp(er) & Thomas Leche

In primis the best bed & beddinge all (tha)t belongethe therto viz the best Cov(er)let, ij good blanketts a paire of shetes, a bolster ij pillows ij pillobers ye best fetherbed & a bedsted standinge all \in/ the p(ar)lar
xx s
Item ye best gowne & ye best Cote
xvj s
Ite(m) ye best panne & ye pott
xx s
Ite(m) ye morter & ye pestell
viij s
Ite(m) ye todde waite ye balance & ye scoles
vj s
Ite(m) a salthouche, a chest & a Troffe
vj s viij d
Ite(m) iij latin basons, ij yores iiij candlestiks an hangging candlestike & pewter basen
xiij s iiij d
Ite(m) ye folded table
xij s
Ite(m) ye square barre of yron & iij hangings
iij s
Ite(m) vj paire of shetes an odde shete iij table clothes & iij towells
xx s
Ite(m) iiij Charg(er)s five pewter dyshes iij porring(er)s, iij sawcers & ij pewter potts
x s
Ite(m) ye coberd, iiij cofers a table w(i)th a paire of tressells & a ioyned forme standing all in the parler
xv s viii d
Ite(m) iiij old pannes, ij potts & a porring(er)
xxj s
Ite(m) ij old cotes, a paire of hose an ell of kersey & ij dobletts
xij s viij d
Ite(m) a fatte, ij kemmills, an old arke & a verges barrel
iiij s
Ite(m) ij old fetherbedds ij old bolsters ij old blanketts, ij old matresses & iiij old Cov(er)letts
xxvj s viij d
Ite(m) a blynd mare & a colte
vj s viij d
Ite(m) on(e) acr(e) of barlie lyinge in the barne of Coldom on thest p(ar)te next unto ye pore & j acr(e) of beanes lyinge nethermust on the Owell
viij s
Ite(m) iij toodds of woolle ye tithe res(er)ved owt
xlij s
Ite(m) xviij teggs aft(er) xx d ye pece
xxx s
Item one Rame, vj wethers, and xiiij Ewes aft(er) xviij d ye pece
xxxj s vj d
Ite(m) x Ewes goynge at Waddsdon after xviij d the pece
xvj s viij d


John Palmer's brother Thomas Palmer died in 1518 and his father Walter Palmer in 1521. There were two cases in Chancery brought by Thomas's son Thomas against John in 1525(?), in which Thomas claimed all his grandfather's estate. It appears that there was a settlement in which John kept the estate but left it to Thomas; hence his preference for his nephew over his daughter in his will, and her alleged agreement to give up her claim (see below). There is no reference to this in the litigation of c.1566, so it must have been an out-of-court settlement.

my monethes mynde: i.e. month’s mind, a requiem service one month after the death or burial.scholes: i.e. scales

todde wayte: a tod is “a weight used in the wool trade, usually 28 pounds or 2 stone, but varying locally” (OED).

salthouche: i.e. salt-hutch, either a box for storing salt or a trough for salting.

latin: i.e. latten

yores: i.e. ewers

ell: A linear measure, usually 45 inches (Buckinghamshire Probate Inventories 1661-1714).

kersey: A coarse narrow cloth woven from long wool , originally made at Kersey, in Suffolk (Buckinghamshire Probate Inventories 1661-1714).

kemmills: Kimmell – a household tub, of varying sizes and purposes (Buckinghamshire Probate Inventories 1661-1714).

ark: A chest, box, coffer, close basket, or similar receptacle (OED).

verges barrel: ?a barrel with a metal rim (OED, s.v. verge 13b). Or a barrel for verjuice.

Coldom: presumably "the croft called Coldehome" mentioned in the Court Books of 1362.

Owell: presumably Orwell Hill, marked on the map of 1599.

tegg: A sheep in its second year, or from the time it is weaned till its first shearing; a yearling sheep (OED).

wether: A ram, male sheep (Buckinghamshire Probate Inventories 1661-1714).

Thomas Palmer the nephew and heir was evidently the Thomas Palmer of Tring, gentleman, who made his will on 4 Jan 1558/9 (National Archives, Prob/11/42A). He left money to the poor of Tring, the Woodside, Wiggington, Watford and Winslow. The poor of Winslow were to get 20s. He made bequests to his sons William and Thomas, and his daughter Joan Carter. He mentions other children who were under age: Bridget, Geoffrey, Alice, Bess, John and Mary. William received the reversion of his office of Auditor of Christ Church, Oxford, where he had a chamber. If the younger children died before coming of age, their share (or half of it if his wife Elizabeth was still alive) was bequeathed "towardes the mariage p(ar)tly of som(m)e of my poore kynnesfolke and p(ar)tly of poore maydens after xl s the pece whiche then shall fortune to be maryed in Wynselowe, Trynge, Wygynton, Watford and Swanbo(ur)ne." He also leaves clothing to his brother Sir Roger, money to his brother(-in-law) Clerk and his sister and her children, an annuity to his sister Thomasyn Gardyner and her daughter Mary payable from lands to be purchased in Sinckelborough. He also mentions "cosyns" Thomas Cotton and his wife and Bartholomew Cotton, the wife of his brother Ralph Palmer, his brother Master Henry Heydon's wife, cosynne Franc(i/e)s Trewesonne, brother Ralph Haydon. The will was proved on 15 Feb 1558/9 at the PCC on the oath of Thomas Palmer the testator's son, the sole executor.

The marriage of Thomas Palmer the nephew took place in 1530 to Elizabeth Heydon, 3rd daughter of William Heydon of The Grove, Watford. He is described as "Thomas Palmer of Winslow, Bucks, gent, son & heir of Thomas Palmer, gent, deceased". As part of the marriage settlement, Thomas Palmer was to convey property worth £10 a year in Berkhampstead and Winslow to William Heydon and various other trustees including "John Palmer, gent"., in trust for the marriage (Herts Archives DE/Z120/45059, 20 Aug 1530). Later Thomas conveyed more property in Berkhampstead and Northchurch to the trustees for the use of himself and his wife. (DE/Z120/45060, 26 Sept 1530; DE/Z120/44423, 12 June 1531).

This Thomas was the son of John Palmer's younger brother Thomas (see below), whose will was proved in 1518. According to the VCH Herts, in 1544, Thomas Palmer (together with Richard Carter) was granted the manor of Garston, Watford, in 1544, and he owned the manor of Newhall, Watford, 1543-6. He is presumably "Thomas Palmer of Sarratt, gent" mentioned in a document of 1546 (Herts Archives DE/Z120/44841).

Thomas Palmer v Robert and Alice Hassall, c.1566

National Archives C3/138/27

A dispute about this will ended up in the Court of Chancery, c.1566. In the will, John Palmer bequeathed all his lands and tenements in Winslow and Granborough to his nephew Thomas Palmer and his male heirs, on condition that John's daughter Alice Cocks/Cox could occupy them for 14 years after his death. As John was a copyhold tenant, he could not legally do this in his will; the legal device for getting round it was a deathbed surrender (which later became known as a surrender-to-will).

According to the survey of the manor in 1556, John's holdings were:

There are also references to property which had passed from Walter Palmer to Thomas Palmer (John's brother) and then to Robert Piggott, gent.:

The case in Chancery was brought by Thomas's son Thomas Palmer (i.e John's great-nephew) of St John's College, Oxford, against Alice and her second husband Robert Hassall [they were married on 13 Feb 1561]. Thomas said that Alice, while she was a widow, had agreed to surrender all her claim on the property. Now she and her second husband claimed that the property was freehold not copyhold, and that they had documents to prove their title to it, and refused to surrender possession. Thomas asked for a writ of sub-poena against them.

Robert and Alice answered that after John's death 8 years ago his copyhold lands and tenements came by custom of the manor to his daughter and heir Alice. John did not make a valid surrender to the elder Thomas, although he did leave the property to him in his will. The property was surrendered to John Bostock, but he died before John Palmer, and the surrender was never presented to the manor court. John was still alive at the next court [i.e. it was not a valid deathbed surrender]. Alice did not give up her claim to the younger Thomas, and only made an agreement with him subject to a payment of money which she did not receive.

To the right honorable Sir Nicholas Bacon knight lord kep(er) of the greate Seal of England

In most honorable wyse complayninge sheweth to your good lordship your poore Orator Thomas Palmer of St Johns Colledge in Oxford gent, that whereas one John Palmer was seised in his demesne as of Fee of & in certen lands and ten(emen)ts custumarye & holden of the mannor of Wynslowe in the Countie of Buck’, w(hi)ch lands & ten(emen)ts have be(e)n demisable demised by Copie of Co(urt) Roole accordinge to the custome of the said mannor from tyme to tyme to the cont(ra)rie wherof the memory of mane extende not. And he so beinge therof seised in his liff tyme ded surrendre the same p(re)misses accordinge to the custome of the said mannor for & to the use of one Thomas Palmer thelder father of yo(ur) said Orator deceassed & the heires males of the bodie of the said Thomas thelder lawfullie begotten, and for defaut of suche issue the Remainder therof to Rauff Palmer & the heires males of his bodie lawfullie begotten, and for defaute of suche issue the Remainder therof to the right heires of the said John Palmer, by reason of w(hi)ch surrender the said Thomas Palmer thelder was therto admitted accordinge to the custome of the said mannor & seisin therof was to him deliv(er)ed to be holden in forme aforsaid by the verge accordinge to the custome of the said mannor. After w(hi)ch surrender the said Thomas Palmer thelder died of soch estate of the p(re)misses seised, by & after whose death the same p(re)misses descended & came to yo(ur) said Orator as issue male of the bodie of the said Thomas Palmer thelder, by reason of w(hi)ch discent yo(ur) said Orator was therunto admitted accordinge to the custome of the mannor aforesaid.  And afterwards it is agreed betwene yo(ur) said Orator & one Alice Cocks of Winslowe aforsaid wedowe daughter of the said John Palmer, that she the said Alice shuld have the occupac(i)on of the p(re)misses p(re)misses for certein yeres yet to come accordinge to a clause menc(i)oned in the last will of the forsaid John Palmer deceassed. And at that tyme the said Alice beinge sole & in her widowed ded Releas all other demaunds & rights & claymes in the same p(re)misses to yo(ur) said Orator & his heires males of his bodie begotten as is aforsaid. So it is & it may please yo(ur) good lordship that sith the death of the forsaid John Palmer & sithe thagream(en)t aforsaid divers copies co(n)trotts & other writings conc(er)ninge the said p(re)misses ben casuallie cu(m)men to the possession & custodie of the said Alice & one Rob(er)t Hasall of Wynslowe aforsaid now husband of the said Alice, who by color of havinge the sa[id wr]itings have not only p(re)tended the same lands to be frehold & frelie holden of the same mannor & not by copie, but also have therbye claymed the same to be descended from the said John Palmer to the said Alice, by color of which pretensed clayme they have conveyed & made secreat estates therof to the disinheritance of yo(ur) said Orator to divers p(er)sonnes to yo(ur) Orator unknowen.  And although yo(ur) said Orator have often tymes Required the said Rob(er)t Hasall & Alice his wiff to deliv(er) to him those writings & Copies as is aforsaid & to desist from soche p(re)tensed demaunds to the slaunder of his lawfull estate therin as is abovemenc(i)oned & therwith to purge soche secret estates as therof be secretlie & unlawfullie demised as is aforsaid, yet the said Rob(er)t & Alice still Refuse so to do, Deteyninge both the said writings & the said land by such undewe clayme & cont(ra)rie to the former acceptance of the said Alice. In considerac(i)on wherof & for that by the ordinary course of the co(mm)en lawe yo(ur) said Orator hath not any Remedie for the same, for that he knoweth not the certaintie of the said Copies or writings nor wether they be Inclosed or shot in bagge boxe or chest, yt may therfore please yo(ur) good lordship, the p(re)misses considered to grant unto yo(ur) said orator the Quenes most gratious writt of subpena to be directed unto the said Rob(er)t Hasall & Alice his wiff, Co(m)maundinge them & either of them p(er)sonallie to appeare before the quenes highnes in her gra(ce)s most honorable Cou(rt) of Chancery at a certen day & upon a certen payne by yo(ur) lordship to be lymited therin, and there to make answer to the p(re)misses, and further to be ordered therin As shall accord w(i)th right & good conscience.  And yo(ur) said Orator shall dailie pray to god for the preservac(i)on of yo(ur) good lordship in honor longe to contynewe.

[signed] Lynnte[?]

[page 2] The answer of Robart Hassall & Alice his wyfe defendants to the bill of complaynt of Thomas Palmer complainant

[The de]fendants for & by way of answere to the said surmysed byll of complaynt, sayen that true it is that the said deceassed John Palmer named in the said bill of complaynt was in his [life ti]me lawfully seised of & in the said lands w(i)th thapp(ur)tnauncs in the said bill specified in his demean as of fee, to hym & his heires accordinge to the custome of the said manor of Wynslowe in the said [bill] mencyoned and the same helde as of the said manor by copye of courte Rolle as copye holder & customarie tenante of the said manor, and the said John Palmer so beinge & contynewinge therof of suche estate custumarie seised, about eight yeres nowe past dyed therof of such estate seised by & after whose deathe the p(re)misses w(i)th thapp(ur)tenancs by right of inheritance customarie therof, by & after the custome of the said manor of Wynslowe did discende & come to the said Alice nowe one of his desendants as sole dowghter & heire of the said Jhon Palmer, by forme wherof the said Alice whyle she was sole & in her wydowhod & nowe sythence the intermariage betwene her & the said Rob(er)t Hassall the other defendant, the said Rob(er)t Hassall & she hath & have soughte endevoryd & travayled to have reteyne & kepe the p(re)misses w(i)th thapp(ur)tenancs & suche copies as do concerne the same accordinge to the rightfull tytle of inheritance customarie to her the said Alice from the said Jhon Palmer her said fath(er) discended as real[?] & lawfull was & ys for theym to do, W(i)thowt that that it is true[?] that the said Jhon Palmer dyd ev(er) at any tyme lawfully & accordinge to the custome of the said manor of Wynslow surrender the p(re)misses w(i)th thapp(ur)tenancs for & to the use of the said Thomas Palmer fath(er) to the said complaynant mencyoned in the said bill, & of his heires males of the body of the said Thomas Palmer w(i)th such further remainder thereof ove(r) as in & by the said byll of complaynt is p(re)tended & untruely alledged butt the said defendants sayen & indede confessen that true it is that the said Jhon Palmer in his lyffe tyme declared his last will & testament in writtinge & in & by the same dyd amongst other thyngs will & devyse the p(re)misses to the said Thomas Palmer fath(er) of the said complaynant & to the h[ei]res males of his bodye lawfully begotten w(i)th suche remainder ove(r) as in the said bill & in effect is specifyed in w(hi)ch will this p(ro)viso & condic(i)on was comprised & mencyoned, that is to saye that the said Thomas Palmer & oth(ers) in remaind(er) should quyetly p(er)mitt to suffer the said Alice (beinge dowghter of the said John Palmer) peasably to have holde occupye & enioye the same duringe fou[rte]ne yeres after the death of the said Jhon Palmer, and also that the said p(er)son to whome the p(re)misses shoulde come by force of the said will should stande bownde by obligac(i)on to the said Alice for the same, and afterwards the said Thomas Palmer mean[ing]e to passe a surrender for the p(er)formance of the same, his son will(ing)[?], dyd surrender the p(re)misses w(i)th app(ur)tenancs into the hands of one Jhon Bostoke one of the tenants butt the said defendants sayen & will avere that the said Jhon Palmer hym self & also the said Jhon Bostocke were in full lyffe att a courte after that tyme holden at & in the same mannor of Wynslowe and also the said Jhon Bostocke dyed, lyvinge the said Jhon Palmer, before the said surrender was p(re)sented or exhibited into the said courte, for all w(hic)h causes and also for that that the condic(i)on lymited in the said wyll to be p(er)formed by the said Thomas Palmer was broken & nott kepte, the said p(re)tensed surrender of the p(re)misses was & is merely voyde & of none effect by the lawe & custome of the said manor for that the said Jhon Palmer was in good health & full lyff at the next court holden aft(er) the said surrender att & in the \said/ manor as aforsaid w(i)thout that that it is true that the said Alice the one of theis defendants dyd when she was sole in her wydowheade att any tyme release[?] to the said complaynant all oth(er) demaundes rights & claymes in & to the p(re)mysses w(i)th app(ur)tenancs other then for suche terme & tyme as in & by the said bill of complaynt is p(re)tended & alledged or that it is true that any full or [?part]e agreeme(n)t was att any tyme hadd taken or made by & Betwene the said complaynant and the said Alice in her wydowheadd butt only a [.....] & comunic(aci)on[?] w(hi)ch [?was r]eserved to writti[ng][?] & also depended uppon paiment of certen money by the said complaynant of his part nott p(er)formed as in & by the said surmised byll [?com]playnt is also p(re)tended & untruely alleged or that any other thinge materiall or worthie to be answered unto by this defendants not before in this answer[?] confessed & avoyded [den]yed or trav(er)sed is true, all w(hi)ch maters the said defendants are redye to avere & p(ro)ve as this most honorable courte shall award.  And prayen & desiren[?] to be dis[missed] owt of the same and their reasonable costs & expencs in this behalf by theym susteyned to theym by this court to be allowed & adiudged.