Selected quad for the lemma: judgement_n

Word A	Word B	Word C	Word D	Occurrence	Frequency Band	MI	MI Band	Prominent
judgement_n	action_n	debt_n	plaintiff_n	3,439	5	10.4588	5	true

Text snippets containing the quad

ID	Title	Author	Corrected Date of Publication (TCP Date of Publication)	STC	Words	Pages
A37282	The humble addresse and remonstrance of Richard Dawson gentleman, now prisoner in the Fleet To the Right Honourable Lords and Commons in Parliament assembled. With all possible submission, representing the sad oppressures under which he groans, his estate being pluckt away from him by injustice, perjury, and subornation thereto, forgery, counterfeiting his hand and seal, and other unjust, illegal unconscionable grievances; by the ... confederacy of Roger Porrington gentleman, Philip Read attorney of the Kings Bench, Edward, and Francis Luttrel, solicitor, and counsellor of law, Sir John Lenthall knight marshall of the Kings Bench, and others, set on, encouraged, and defended by them.	Dawson, Richard.	1661 (1661)	Wing D459B; ESTC R215262	24,858	36

THE HUMBLE ADDRESSE AND Remonstrance OF RICHARD DAWSON Gentleman now Prisoner in the FLEET To the Right Honourable the Lords Commons in Parliament Assembled With all possible Submission Representing the sad Oppressures under which he groans his Estate being pluckt away from him by Injustice Perjury and Subornation thereto Forgery Counterfeiting his Hand and Seal and other Unjust Illegal Unconscionable Grievances By the 〈…〉 Confederacy of Roger Portington Gentleman Philip Read Attorney of the Kings Bench Edward and Francis Luttrel Sollicitor and Counsellor of Law Sir John Lenthall Knight Marshall of the Kings Bench and others set on incouraged and defended by them Because of the Cry of the Oppressed and the Groans of Prisoners I will Arise saith the Lord. Let God Arise and His Enemies will be Scattered London Printed for the Author 1661. Right Honorable Lords and Worthy Gentlemen THE External happynesse of mankind consisting in Society of which the briole or check is the Law which curbs and restrains the unruly exorbitances of unreasonable men what can be fall more miserable in this life than to have this remedy by the Injustice of its Execution made worse than the disease to find Judgement turn'd into Gall and Wormwood as is evident in your poor Petitioners Case who to the ruine of his Wife and Children hath for several years found experimental proof thereof which being his lot in those times when our Sun of Earthly happyness was eclipsed and only the Screetchowles of Horror and Distraction were heard in our almost ruined Land when Corruption and Villany was the natural milk to feed our Infant Monster the Commonwealth His hope and assurance is that the return of our Sun of Majesty will be like unto that of him who hath been and is his true pattern the Sun of Righteousnesse with healing under his wings to poor oppressed and otherwise despairing Prisoners among whose number your Petitioner humbly acknowledgeth himself Nor is he only prickt forward to this Addresse by the sharpnesse and tediousnesse of his sufferings and present distress brought upon him thereby but is also incouraged nay more assured of successe in confidence of your Honors true Gallantry Justice and Wisdom who your selves in these late overturning times have tasted of the same cup of affliction many of you drunk thereof deeply Yea His Most Sacred Majesty hath not escaped the same Lot but in imitation of our Saviour his immediate Lord and pattern hath suffered in the like kind though not in the same manner and therefore my confident assurance is that having in this Humble Addresse to deal with such a King the like of whom England never saw nor brought forth experimentally by Gods inscrutable providence made sensible of the distresses and sufferings of his meanest Subjects such Lords and Nobles who themselves have been tryed in the same Furnace of Affliction and for many years last past have not through their Princes displeasure but for being Loyal to their Prince by the meanest and worst of Plebeians been plundered and stript of all and afterwards imprisoned with as much reproa●h and contempt as if they had been Chips of the same Block with the most Contemptible Commoner Such Knights and Burgesses to Sit in Parliament who if in these times of distraction they lived in England and are unacquainted with the miseries of Imprisonment it argues in them little Cordial Fidelity to their Soveraign Lord or his Father of Blessed memory whose real friends mildest Lot was reiterated and severe Imprisonments others being Banished not a few Murthered On which Considerations your Humble Petitioner begs of and Humbly beseecheth you who by the good hand of our most Gracious God have been dragged many of you out of the Dungeon some recalled from Exile to injoy your Antient Priviledges and Freedoms and sit according to your true desert and merits at the Helm of State to cast back your Gracious Eyes upon such who once were fellow Sufferers with you and not like Pharaohs Butler being now your selves restored to forget the languishing Estate of Joseph viz. your once fellow Prisoner This my Lords and Honorable Gentlemen I speak not as in the least doubting or fearing any such thing but out of the meer sense of my long and most unjust suffering pardon my boldnesse that I am thus importunate if possible to find an effectual and speedy remedy And not to trouble your Honours with a long Preamble whose very weighty occasions cannot admit a tedious discourse I shall come Humbly to represent my Grievances so illegal so many and carryed on with a high hand on purpose to ruine your Petitioner whom several persons of note and power have confederated to undoe and destroy in so barbarous and wickedly malicious a manner and way as I question not but in the following particulars to make so plainly evident to your Honors and Wisdoms as will cause your hearts in reading of them to relent and commiserate your poor Petitioners Case yea so to pity him as effectually to relieve him In the year of our Lord 1648 Octob. 21. Richard Dawson Gentleman then residing in the County of Norfolk and dealing in the Capacity of a Grasier had at one time forcibly taken from him 267 Oxen which were all driven into the Castle of Pomfret by some who pretended themselves Souldiers of that place and there came to the possession of one Roger Portington the Governour denying that he had any thing to do with them when Dawson owner of the Cattle demanded them of him but sent him to Portington to treat with him concerning them being as he affirmed wholly in his power and withall required Portington to rostore them to Dawson but he refused to return them or any part of them using this exasperating expression to the owners face That would he give 100 l. for ten of the worst he should not have them with which most rugged answer Dawson being justly provoked as well as exasperated by his great losse in the year 1649 he brought his Action of Trover and Conversion against Portington which being tryed by Nisi prius at Guild Hall in the year 1650. the Plantiff recovered against the Defendant Portington with costs of Suit 1297l 13s 4d according to which verdict Judgement was entred and Dawson had granted him a Writ of Execution thereupon A man would now have thought that the Plantiff had not been far from his mony having able bail for bringing forth the Body of the Defendant and him a man of sufficient estate to satisfie a greater debt But the sequel of this discourse will make it most evident that as our Laws have been and are in the Execution of them still abused there is no Case so notoriously corrupt and injust but meeting with a suitable Conscience joyned with ability of Purse he may be provided with Lawyers who for the sake of gain will maintain and defend the same in despight of Justice For this Portington to discharge his Bayl rendred himself Prisoner to the

Kings Bench where Dawson charged him in Execution upon the sore-recited Judgement and there he to this time continues a Prisoner although for many years he hath been and still is at large dwelling at his own house in Yorkshire to the defrauding and great dammage of the injured Creditor who can look upon such actions no otherwise than Cheats however seemingly backt with Colour of Law But of this I shall have cause given to speak more fully hereafter in this discourse I will now come to shew by what vexatious troubles the Condemned Defendant hath for ten years molested the greatly suffering Plantiff by which he hath been put to so much cost besides molestation that he had better have been himself Condemned in as much more money and clearly lost his debt then recovered against the Defendant that Judgement of 1297l 13s 4d For to avoid payment thereof the Defendant Portington hath not only himself endeavoured but combined with others to bring Dawson to ruine and hath effected it so far as tedious Law-Suits and Imprisonments could do the same to the Expence and Dammage of him the forenamed Plantiff more than 8000l which he can make appear and this by such monstrous courses of Villany as can scarce be believed but that the Plantiff can by many Records make out the same His first vexatious Dog-trick was when that invention of Salters-Hall was hatched for the relief as was pretended of Creditors and Debtors To these Commissioners Portington Addressed himself by Petition which was granted and Dawson Summoned thereupon to have the Case heard by them who instead of relieving the Creditor ordered only a rehearng of the Cause before themselves to which order patience perforce Dawson submitted but the event proved neither relief to Creditor or Debtor for that Court after hearing the Cause and with mature deliberation weighing the merits thereof on both sides dismist Portingtons Petition which cooled his hopes and expectation of relief and for the Creditor Dawson all his relief was that after the expence of 200l in that second hearing and Tryal several of his Witnesses living 200 miles from London besides other ways of great charge and cost he had only his former Judgement confirmed and yet as far from his mony as before This Dog-trick failing Portington was soon provided with another which was to Petition the usurper Oliver for relief against so due a debt doubly now confirmed by two Tryals in which Petition being on Record and the Copy of it in Dawsons hands to be shewed any that desire satisfaction therein Portington to his praise be it spoken who would by all means be thought a Cordial Royalist did basely and perfidiously acknowledge the Supreme Legislative Power to be in that bloody Rebel betraying both his Conscience and the Cause he pretended to maintain with design only to cheat his Creditor Dawson of a just debt so injuriously detained The Usurper in answer to his Petition ordered several references In attendance upon which the Creditor was put to a new charge of 100l or thereabout the Prisoner finding as little relief as he before had at Salters-Hall that is none at all not do I believe he ever expected relief from either only used these delatory means if not to defraud at least to retard his Creditor from getting what by Law he had recovered and by multiplying expensive proceedings although illegal to weary him out and tire his patience seeing more monies dayly thrown away after the former of which he could now have but little hopes to receive either Principal Interest or Costs of Suit Yet for all these disappointments he is not weary but since his Majesties happy Restauration presented his Petition against Dawson in the Upper House of Parliament where the Lords after several hearings thought no relief fit to be granted in the Case wherein the Law had no lesse than twice had its full and due course however his restlesse spirit hath lately prompted to him another poor shift and that is to bring an Audita querela in which he pretends an acquittance by the Act of Indempnity although he hath been a Prisoner in Execution therefore now above ten years since he was first charged therewith Howbeit although I call him a Prisoner yet thanks to good Sir John Lenthall he is one at large this Gentleman when great Rogues come to be Cannonized shall passe for a pretious Saint the rules of whose Prison where he meets with one like himself that makes no more Conscience of giving than he of taking a bribe reach as far as Constantinople some say to the East-India's by which means those who can dispense with their Consciences va●ue the Execution of the Law not a rush as particularly appears in Portington who being suffered though in Execution to live at home and sometimes for nigh three years together not to come so much as to Town hath taken up a resolution never to pay his Credit or Dawson a groat yet boasts that he can and will have his Liberty in spight of him although the hopes of Dawson are that this Parliament will take such effectual course against these kind of tricks as may truly relieve the oppressed and curb the insolencies o● unconscionable men And so at present I shall leave my first Customer of this kind and proceed to new and more prodigious Villanies acted by others but countenanced and fomented by this Portington who to secure himself in his unjust proceedings hath not been backward in the most hellish designs to act his part to the shame of those who have abetted him and his Associates who were men of Rank and Repute In the year of our Lord 1656. Novemb. 11. Dawson being then in Norfolk had occasion to make use of three hundred pounds for the manageing of his Trade which he offered to repay in London by Exchange nine days after which Sum one Phillip Read an Attorney in the Court of the Kings Bench undertook to furnish him with all in two dayes time provided Dawson would give him a Warrant to an Attorney to confesse a Judgement to him for five hundred pounds with a Defeasance for nine dayes for his better security of the payment of the said 300l which Dawson consented to Signed and Sealed a Warrant and Read also Signed and Sealed the foresaid Defeasance annexed thereto which being delivered mutually by both parties Dawson came at the time appointed viz. two dayes after to receive the 300l according to agreement but could have no more paid him then 158l which was repayed by Dawson to Read and his appointment in London by the time limited and allowed in the Defeasance yea in truth two dayes before with 15 pounds more which was lent by him to Read to be repaid upon demand upon which payment Dawson called for his Warrant of Attorney which Read at that time put off with this excuse That he had forgot and left it at his house in the Country promising the delivery of it as soon as he returned to

Norfolk but not performing his word Dawson made several times other demands of the said Warrant but had for answer It was lost Yet before several persons of Repute and Credit Read acknowledged himself fully satisfied by Dawson and nothing to remain due to him from the same However Sept. 12 1657. Read having privately without the least knowledge or suspition of Dawson entred that Judgement took out Execution upon it against the goods of Dawson and by virtue thereof did levy in the County of Norfolk to the value of 700l and after sent one Thomas Hide into Huntingtonshire who by his order without Writ of Execution or any other Authority but his direction took away 47 fat Bullocks worth 200l and sold them nor content with this he in the same year and month in the County of Norfolk at a place called Wallpool in Marshland did by Colour of the said Execution seize of the proper goods of the said Dawson viz. Hay in Stacks and Reecks to the value of 500l which though he had no power to condemn and dispose of yet he detained by colour of his own Execution till he could and did procure one Robert Dun by a pretended Execution to Levy the same and sell it Upon which illegal abuse Dawson made complaint to the then judges of the Kings Bench in those dayes called the Upper Bench by whose order Read was committed Prisoner in the Custody of Sir John Lenthall but by favour of some of his Fraternity forthwith had his Liberty which he imployed so well that before the end of the same Term he procured one Disney to commit wilful perjury with intent to overthrow Dawson in his most just cause he when Read first moved to him that he should make such an Oath replyed Master I know no such thing who then swore by his Maker that unlesse he would make that Oath as he directed him he was utterly undone so partly by importunity partly by promises he procured the said Disney desperately to swear against his own knowledge Whereupon Dawson endicted Disney for this perjury and this Master for subornation thereto since which Disney's Conscience accusing him he hath confest to several persons of worth and repute that his Master Read would never permit him to be at rest till he had perswaded him to make Oath of such things of which he had not the least knowledge For which Cause in Easter Term 1658. Dawson filed a Declaration in the Kings Bench against Read who did and still doth practise there as an Attorney upon the Case in a special Action which the first of July he brought to a Tryal and recovered 700l dammage besides costs of Suit 18l for which the following Michaelmas Term he had Judgement and Execution granted thereupon against the person of Read which Writ being delivered to the Sheriff of Norfolk the businesse was so jugled between them that although Read was often in the Sheriffs Company yet he was not taken in Execution nor would the Sheriff at the instance of Dawson return the Writ for several Terms and at last returned a non est inventus thereupon when Read during the time of detaining this Writ without Execution or Return had embroyled Dawson in a tedious and chargeable Chancery Suit which because of its Exemplary Injustice and Corruption discovered in the manageing thereof shall be particularly here set down Not long after Dawson had got against Read this Judgement and Execution the Defendant sues for relief in Chancery and serves Dawson with a Subpaena to that purpose and proceeds the Vacation following to examine witnesses and by favour with the Master of the Rolls William Lenthall procures the cause to be forthwith set down for a hearing in Easter Term suddenly then following 1659. which Term being adjourned the Cause was again set down for hearing at the Rolls the 9th of June following where as soon as it was opened by Reads Counsel Lenthall the Consciencious Master of the Rolls called for Dawson and in seeming familiar friendship told him he would make a bargain with him viz. that Read should within two dayes pay him Four hundred pounds and the differences between them made up and fully ended thereupon to whom Dawson replyed his debt was 718l in recovery of which it had cost him no lesse then 500l When Lenthall saw that this bait would not allure Dawson to bite at it who had sufficient former experience of his corrupt basenesse and dissembling villany as before the Close of this discourse shall be discovered in another case he then demanded of Reads Counsel if they could produce any Presidents where relief in Equity had been granted in the like case after recovery Judgement and Writ for Execution who replyed there were several Presidents upon which answer Lenthall put off the hearing till the 18th following of the same month against which time he willed them to have those presidents in readinesse and then he would determine the Cause but in the mean time tyed up Dawson not to take Read in Execution the appointed day for hearing being come upon reading the first president Lenthall told them plainly it made not at all for but against them but he had since the last hearing Considered of the Cause on his pillow and so forthwith without farther hearing Counsel on either side ordered them to go to a new Tryal at Law after which he would reserve the Equity to himself but in the mean time Read should not be taken in Execution with which orders Dawson being much agrieved Petitioned the then Lords Commissioners of the Great Seal as they were called complaining of the great injustice he suffred thereby in answer to which Petition they granted him a rehearing before them upon which Counsel having spoken on both sides they dismist Reads Bill and discharged the several orders made by the Master of the Rolls with costs to be taxt by a Master of Chancery which were accordingly taxed at an hundred marks Whereupon Sir John Lenthall one of the Rebel Olivers mock Knights Son to the Master of the Rolls being at that time a Member of that thing then called a Parliament seeing Read thus left to the Law notwithstanding his honest Fathers devices to obstruct the same gives him his protection during the sitting of that Convention Read finding himself thus countenanced by the Master of the Rolls and his Son for which as himself confesseth it cost him three hundred pounds thinks he is now armed Capape for any villany and having a prodigiously villanous wit goes thorow stitch to the purpose and thus performs it First he perswades and prevails with one Robert Dun that he might make use of his name at his own charge and costs to confesse and enter a Judgement against Dawson for the Sum of 350l upon which grant Read as representing the person and taking upon him the name of Richard Dawson forged the foresaid Warrant of Attorney Subscribes and Seals it as if himself had been the person of Dawson and

before Honourable Persons as was before touched in each of them the name of the Right Honourable the Judge before whom taken being particulary remembred in giving their testimonies in brief for the Readers fuller satisfaction and further confirmation To which I might adde many more of the like Kind thirty several at least but that I here account needlesse since in the mouth of two or three witnesses each thing in controversy is and ought to be confirmed and here we have not only witnesses but ipsos fatentes reos the persons concerned in the forgery either ignorantly or knowingly drawn in thereto upon Oath confessing against both themselves and one another which is a testimony as firm as can be desired or expected I shall now speak a little more particularly to the Statute of Bankruptship sued forth by Read in the name of Dun against Dawson and firmed by Commissioners pickt and packt for the same purpose only to discharge Read from paying any monies to Dawson whose just debt upon a legal recovery was upward of 800l For taking forth and granting or affirming the same Dawson brought his action against Read and those Commissioners his Confederates and upon Tryal in Jan. 1660. recovered against them 500l notwithstanding which upon an Affidavit of Reads read openly in the Court at the Kings Bench Bar a motion was made to have a second hearing which was had by the consent of both Plantiff and Defendants the Hillary Term following where Read according to his old wont procured in readinesse four several witnesses to swear Dawson a real Bankrupt viz. Thomas Wigge one of Honest Sir John Lenthalls Engineers a villain so notorious in that kind that if in any Case where he is well paid his Evidence come short that is be not sworn home enough blame the Lawyer that gave him not better and larger instructions and not him who wants only to be informed what manner of Oath will serve turn then as for performance let him alone for one The second Jacob Wragge servant to Read one who had learned so much of his Masters qualities that no wise man can trust his Word or believe his Oath the third Robert Coghill a neighbour to Read who by this hopeful beginning gives great assurance what a compleat Knight of the Post he may prove in time if he continue the acquaintance and follow the direction of Read the last Thomas Adamson formerly a Clerk to Read who it seems still wants his help at a dead lift knowing his abilities though at present he hath left his Service These four being pre-instructed could if occasion had required have sworn any man of dealing in England a Bankrupt for to give them their due in their depositions there wanted nothing but Truth Malice enough and Formality sufficient with a home shot to reach the mark aimed at by Read their Tutor who put cruel words of falsehood into their mouths and told them what manner of Oaths would serve his turn and they accordingly swore as dangerously desperately and resolutely against the Credit and Reputation of their innocent Neighbour whom some of them knew not others very little all of them knew certainly that what they swore against him was absolutely false and so God by his providence hath plainly since discover'd it to be to the great shame of those poor perjured wretches but most especially of that Monster who suborned them to doe it as he had done others often before For which wilful perjury palpably now detected these four abovenamed stand indicted at the Old Bayly in London by Dawson who doubts not but to have them brought to Condigne and Exemplary punishment Thus have I in brief decyphred out to you a great Monster in villany as in a Landskip given you a large volume of Roguery contracted into an Epitome a short narrative of what to his cost and trouble Dawson who hath still been the sufferer hitherto hath felt for these many years to the ruine almost of his Wife Children and Family and whose Case or Lot may it not be next nay who can escape for future if such Villanies be countenanced as they will be if not prohibited and severely punished to the terror of others It is reported of a Bravoe that he would vauntingly boast how he had at his beck ready an hundred to swear for him an hundred to fight for him and an hundred more to supply him with money The thing though I cannot affirm the number is most true of this Read who as for swearers hath made his boasts that he is so provided with a stock of them as never to fail in any Case and that his manner of dealing with such Knights of the Post is suitable to that of the Dutch before a Sea-fight with their Marriners viz. to give them 20 or 30 glasses of Sack just before they come upon their Oaths then quoth he they are fit to serve my turn and swear resolutely bravely and boldly without making the least scruple of any thing that is told them makes absolutely for the good of the Cause depending to have it sworn either thus or otherwise And for fighting or rather maintaining his quarrel 't would make a man blesse himself to see prodigious Villains so favoured before one that mannageth a Cause as just as Justice it self having been so often determined just by the reiterated Sentences of Common-Law Commissioners for Equity c. How did the honest Master of the Rolls Speaker to the reforming Rump endeavour to entrap Dawson in favour of Read How was Read with great charge brought into a Prison where he deserved to lye till death yet Presto be gone Sir discharged forthwith and Dawson brought in upon a large Scroll of Fob'd Actions to keep the other and such as he procured to commit Perjury wilfully and maliciously from Condigne punishment How ready was the Sheriff of Norfolk to Execute a Writ upon a forged Warrant for Judgement against Dawson and yet knew it to be so using this expression He would Execute 1000 the like if they were brought to him and Goods of Dawsons to be found in his Balywick yet how loth nay absolutely unwilling to Execute a true Writ upon a Judgement justly recovered in Court after the discovery of a pack of Roguery against Read though oft in his Company nor would be perswaded to make return of the same till Reads Cockatrise Eggs of Villany were hatched How have the Gaolers and their fetting dogs complyed with this perjured Monster and his Confederates to ruine one in defence of the other Portington a Condemned Debtor to Dawson and Prisoner to Sir John Lenthall in Execution having liberty to choose whether he would live in restraint or no and Read cast into Prison for Perjury and Subornation thereto Forgery personating other men and taking upon him their names not without great cost and charge to the Plaintiff yet he in short time let out upon inconsiderable Bayl though Dawson wrongfully imprisoned upon feigned

he had met with such a bargain from Dawson that he would put 500l into his own purse thereby which it were strange if he could do any other way than by cheating him of the whole and that was the course he took in which he was incouraged and supported by his Brother And suitable to the dealing of him in this Case of Hay and Leases of Land was another trick of knavery put upon Richard by Edward about the sale of a Coach which costing Richard 40. l. he sold it to Luttrell for 30l by a Deed of Sale which 30l he the said Richard ordred Edward to pay 5l to his Brother Francis Luttrell and 25l to Richard Norwich which payments so ordred Edward Luttrell did assume and promise to make upon which only consideration the Bill of Sale for the Coach was by Richard delivered to Edward Francis Luttrell who ordered the Deed to be made accepted of this payment from his Brother Edward and did thereupon discharge Dawson of the Debt of five pounds though since the Coach is sold by Edward and the money for it received and spent Francis makes new demand of the money from Dawson Edward refusing to pay either his Brother Francis or Richard Norwich but when sued for this Debt of thirty pounds by Dawson he first by Levata querela removed it into the Mayors Court where by his Bill he pretended himself only a Trustee for the Coach as before he was for the Hay though such trusts so discharged will shortly bring him to be trusted by none For these have been his continual Subterfuges first to pretend only a trust in Dawsons Goods that he might have colour to sue for relief in Chancery and there in stead of making answer material to the Cause depending to plead old reversed Outlawryes in Bar so that at once Dawson is tied up from his legal course of proceeding by Injunctions and debarred in Chancery to prosecute those his Bills till he hath with great cost and trouble disproved the pretended Outlawryes to be in force of which Luttrel hath made his brags to several of his Companions as is by some of them testified upon Oath and also upon Record Nor is this all though it argue a mind as bad as bad may be but by compliance with the Clerks of Chancery this Luttrel hath not seldome penned his own Orders which have been entred down according to his own words as can be proved against him undeniably upon which advantage it is not to be wondred at that Dawson is still the sufferer when his Enemies profell are in effect the Contrivers of their own Orders which no doubt having that liberty they pen with the greatest advantage for themselves To prove which Charge real the last Order which was left for Richard at the Registers Office was every word thereof the hand-writing of Edward Luttrel which he hath in readinesse to shew in case it be required of him Now how sad the Case of Dawson is may be collected briefly if we consider his present Condition and compare it with what he was formerly one who dealt for at least 20000 l. per annum Rented in Land for feeding of Cattle and for Hay 900 l. annually and by Gods blessing upon his Endeavours had by his Industry gotten such an Estate by which He and his Family lived comfortably and plentifully whose Credit would have past without scruple for 3. or 4. thousand pounds now to find him a Prisoner his Estate pluckt away from him by Knavery Injustice Perjury and Subornation thereto Forgery and Counterfeiting his Name and Person by which means he is damnified at the least 8000 l. besides what by his Industry in this time he might have got thereby in his way of dealing for want of which money although he hath made legal recovery of the greatest part of it he hath Contracted some Debts which he is unable to satisfie unless he might have his due from others one of which Debts due to him upon Judgement if paid would discharge every real Creditor that could justly make demand of moneys from him But in stead of payment these honest Debtors to Dawson have all combined together in a mutual engagement never to discharge one Farthing yet are men of able Estates Portington a man responsible detaining 1297 l. 13 s. 4 d. for above 12. years and putting Dawson to at least 1000 l. charge first and last in recovering and defending that Judgement against him In Execution for which although he hath been 10. years and upwards one of Sr. John Lenthall● fast and loose prisoners yet so he is resolved rather to dye than to pay a Farthing of this Debt Read also against whom Dawson hath recovered 718l for his deceitful seizing his Goods by vertue of a Warrant of Attorney which was satisfied and 500 l. against him and other his Confederates for Dammages sustained by a Commission of Bankruptship sued out against Dawson upon a forged Warrant to confesse a Judgement as hath at large been declared yet he boasts that rather than pay a Groat he will rot in prison though he hath at command several thousand pounds to maintain him which with his Land he will so make over to Feoffees in trust that the Plaintiff shall never get penny not know how to find his Estate And although at another time he took away a thousand pounds worth of the Goods of Dawson upon a forged Judgment In disproveing of which and discovering the Forgery Perjury and Subornation to Perjury committed therein it cost Dawson several hundred pounds and though the order of Court were that upon disproving that Warrant to be real the Goods levied in Execution should be returned to the Owner of the same yet he hath not yet received nor can get the least satisfaction therefore Nor will the Sheriff of Norfolk make return of that Writ of Execution upon which he took away the Goods of Dawson and sold them almost two years since To which oppressions may be added the giving away a Judgement of 805 l. recovered against Binks by Nabbs upon Commission granted him by Lenthal then Master of the Rolles to hear and determine that Cause without appeal which he determined without hearing Dawson or any Witnesse Counsellor or Sollicitor in his behalf giving away moreover besides the Debt 200 l. and upwards for Costs And lastly Edward Luttrell upon pretence of securing Dawson from the like future plots of Read and his complices with promise as hath been related of paying Dawsons real Debts and bringing an overplus into his purse for the maintenance of him his Wife and Family hath cheated him of all he had left his Brother and he now complying with Read and Portington not only to defraud but to grind and squeeze Dawson and bring him to utter ruine a bad requital of the many years kindnesses shewed by Richard to Edward whom he kept from starving who now if it lay in his power would starve him and his And that the falsehood

and basenesse of these two Brothers in iniquity may be made more evident besides the ingratitude of Edward which according to the Aphorism in Ethicks Ingratum si dixeris omnia dixisti includes all that can be spoken evil concerning any person it will not be amiss to hint in brief the remarkable honesty of the Counsellor Francis who being summoned by Richard at the Tryal between him and his Brother Edward concerning the Debt of thirty pounds due upon Sale of a Coach at which Deed of Sale Francis was present and ordred the making thereof and thereupon accepted 5 l. from his Brother Edward which was due to him from Dawson yet he against his own Conscience and Knowledge swore that the Deed was there made fraudulently for the defrauding of some Creditors which Edward upon a former Deed of Sale of Hay and Leases of pasture ground made to him by Richard had a year before undertaken to discharge yet Francis upon Oath declared that to Evade those Debts the Coach was only colourably made over to Edward in trust and no otherwise to be redelivered upon demand at the pleasure of Dawson At the time of making which Oath all of the Long Robe present in Court blessed themselves to hear him so swear the Judge telling him openly that Oath could not be true or if it were it would argue himself to be a very Knave not long after which Tryal the Coach was sold and the mony shar'd but not a penny paid either to Dawson or his Order Now what Justice can be expected against such persons that can and dare so swear let the World Judge Nor was this only a failing at that present in the Counsellor Francis but according to the relation of his Brother Edward to Dawson in the hearing of several persons Francis the Counsellor made offer to him the said Edward of 300 l. sterling conditionally that he should make Oath against Sir Allein Appesly that he was one in Sir George Booths design in those times to have brought both the life of that worthy person into danger and confiseated his Estate which he in his conceit was just grasping only wanted such a desperate swearer fully to accomplish this intended Villany from whom and such as he is God of his Mercy deliver each honest man For of late Edward Luttrell hath gone from party to party with whom Dawson had formerly any dealing to procure them to enter Actions against him and several with whom he never had to do nor doth know the persons have by his perswasion and Reads brought against Dawson great Actions upon which to the number of 30 and upwards amounting to the Sum of about 1600 l. he is now deteined Prisoner of which there is not an hundred pounds due but some of the parties dead two years since in whose names Actions are now brought others satisfied as long time agoe nor know of the entring any such Actions at their Suit others never known to or heard of by the Defendant Dawson yet have Actions against him viz. 560 l. pretended to be due upon Bond unto William Marriot and Thomas Bre●tford of whom he never had knowledge much lesse dealing with them Also 200 l. entred at the several Suits of Thomas Osborne and John Bates with whom likewise Dawson never had dealing besides other Fob'd Actions too tedious to name particularly The greater part of which were not charged upon Dawson at his first imprisonment although then the Luttrels Read and their Confederates boasted they had him fast for his life time To accomplish which design to their power Sir John Lenthal with whom Dawson never had to do more than to sue him for the wilfull escape of Portington whereby he is damnified at least 1500 l. this last Easter Term 1661. by Habeas Corpus fetch'd him over to his prison where he was loaded with fob'd Actions to hinder his prosecution of that escape of Portington and the several in●ictments of perjury which are found against Read and such as were suborned by him and his procurement among whom one is an Enginee● to and Servant of Sir John Lenthal that keeps many such Cattle who it is to be feared serve his turn in the like Cases oftner than I hope will hereafter be suffered or else woe to those whom he and others of such Conscience design to ruine From which prison with very great costs and charges which were encreased by the number of feigned Actions Dawson was compelled to remove himself back to the Fleet not accounting his person safe in the Kings Bench Prison where the Keeper is so great a Confederate with his most malicious implacable Adversaries HAving thus with as much brevity as I could related my great grievances under which I have long groaned and for remedy whereof I have tryed many wayes for divers years both in Law and Equity But by reason of the Corruption of former times the power and number of my Adversaries and mine own inability at length to prosecute them in a Legal Course being reduced by these long oppressures to great streights and at present a Prisoner loaded with many Malicious Forged Actions to hinder my Liberty upon reasonable security such as my present conditition will afford me to procure Some of my Creditors by the instigation of Read Portington and the Luttrells having prosecuted me to Judgement and charged me in Execution thereupon only to hinder my going abroad without charge of an Habeas Corpus or Day Writ which with the allowance for a keeper Chamber-rent and Outgoing Fees amounting to at least 10 or 12 s. each day is so great a burthen that while I am so Confined or have Liberty at such rates I can expect nothing but utter ruine to my self and all that are neerly related and dear unto me Wherefore all other hopes failing me the last remedy left me is to fly unto the shelter of the most Honourable the Lords and Commons in Parliament now Assembled to spread most Humbly my Cause before them and with all possible Submission to Beg and Implore their Gracious Help and Assistance My Case Right Honourable Lords and Worthy Gentlemen although private is not of private Concernment nor bounded within private limits for as Read hath dealt by me and mine so hath he dealt by divers others twenty Families at least I could name whom by the like A●ts he hath ruined and destroyed and several fellow-Prisoners I meet with daily oppressed by the same courses of injustice false Oaths counterfeit Warrants for confessing Judgments false Actions under which they are detained c. by which wayes of unjust vexation together with the excessive unreasonable charges which through the corruption of times now accompany imprisonment many are reduced to that extremity that they want for the conveniences of life much more unable are they by any means of addresse to seek for relief My Lords and Gentlemen You are your selves the fathers of Children whom God long preserve and blesse Howbeit none of you can promise to them a future immunity from the like miseries unlesse this Cockatrice-Egge of corruption and injustice be crushed which no foot but such a foot of Authority can do These unjust vexatious Law Suits or rather Law Cheats bringing sweet gain to very many who though they will not openly defend yet will connive at such practises so lucriferous and beneficial to themselves and their dependants But considering there is legal profit sufficient allowed to all honest Ministers of Justice and what comes in this way is squeezed out of the heart blood of his Majesties most faithful Subjects thousands of whom have been ruined in their Estates Credit or both by such illegal proceedings My case also being so grossely and fouly exemplary that it causeth amazement in all who hear it I doubt not but that your Honours and Wisdomes will think of a way of relief as for all the like oppressures in general so for your most humble Supplicant in particular that we may have cause from our hearts to blesse God for the happy change of times when our bowels shall be refreshed our miseries considered and out unjust vexatious oppressures relieved by your power prudence and justice I shall not dare to prescribe any means to so grave wise and honourable a Council but with all humble submission expect and wait for such a remedy as shall appear meet to your judicious breasts praying the great God who sits in your Assembly so to assist you with his blessing from above that you may your selves become a blessing to this Kingdome a Sanctuary to the distressed a defence against wrongs and injustice and a refreshment in particular to Your poor ruined Petitioner if not by your Piety and justice relieved RICHARD DAWSON