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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

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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
then delivers it to the use of Robert Dun having witnesses in readinesse who upon examination affirm that they knew neither the persons of Read or Dawson to subscribe to the delivery thereof as the Act and Deed of Dawson Upon which Warrant so given by himself he procured a Judgement to be entred and Execution taken out and levyed on the Goods of Dawson in the County of Norfolk where by a Combination between him and the Sheriff with his under Officers who knew very well the Judgement to be grounded upon a forged Warrant of Attorney before the Execution of the Writ 1000l worth of Goods were seized and sold yet valued but at 150l which Goods so under valued were bought by one John Prat whom Read procured to buy them upon a joynt account between them both Which 1000l being thus swallowed up between these two devourers and the Execution still unsatisfied more than one half in the next place Read sues forth a Commission of Bankruptship against Dawson in the name of Dun for the unconscionable remainder of the pretended Execution to sit upon which he pickt up Commissioners of his own Confederates who in a very short time after the Commission came to their hands declared Dawson a Bankrupt and discharged Read from payment of any monyes to him no other pretence of Debt being brought before these Commissioners to prove this Statute against Dawson but only the forged Warrant for Judgement as is before at large recited and testified by those very witnesses who were present at the Sealing and Delivering that Warrant of Attorney who deposed that Read whom then they had no personal knowledge of Subscribed Sealed and Delivered it in the name and counterfeiting the Person of Dawson Things being thus corruptly and unjustly carryed Dawson to prevent if possible the ruine which he saw inevitably hanging over the heads of himself and Family unlesse such villanies were redressed in Michaelmas Term 1659. made his complaint before the Judges of the Kings Bench of the fore-recited horrible Forgery of Read in his name as also of false witnesses which were suborned by him and in readinesse to swear that Dawson was the very person who Signed and Sealed the Warrant of Attorney to the use of Dun upon which complaint the Court referred the matter of fact in the Case to the examination of Mr. Herne Secondary of the same Court who upon examination of Dun and several other witnesses found that no monyes were due from Dawson to him but on the contrary Dun was indebted to Dawson in the Sum of 400l due upon Bond who had a general release from him under Hand and Seal before the forging that Warrant of Attorney by Read in his name nor did ever Dawson deal with him since as he hath confessed in the hearing of several persons To make which more evident Dawson hath now from Dun a Judgement upon Record acknowledged by himself for that same debt of 400l then due when this forgery was committed Dun having moreover confessed on his Oath that Read to acquit himself of the Judgement for 718l and 100 Marks Costs did Sollicite him to consent to and own this forgery and suing forth the Statute of Bankruptship against Dawson thereupon Mr Herne having carefully sifted the whole truth of the Case made thereof a just report to the Court who thereupon ordered a Tryal at Law and the rule was that this Tryal should be according to the Election of Dawson at the next Assizes in Norfolk or Suffolk upon a feigned Action whether the Warrant of Attorney were the Act and Deed of Dawson or no which if upon tryal the Jurors should find in the affirmative then the monyes in the Sheriffs hand made of the goods levied in Execution to be delivered to Dun but if they should find in the Negative then the Judgement to be vacated and the moneys restored to Dawson Dawson upon this order moved that the Tryal might be either in London or Middlesex where the Forgery was committed because at so great distance Knights of the post might stand for substantial witnesses Yet in this he was overborne by the Court and the Tryal ordered in one of those two Counties who because he could have it no better chose of two Evils the least and had his Tryal at Bury St. Edmonds at the Assizes holden Sept. 10. 1660. for the County of Suffolk Read making Cock-sure of the Tryal to goe on his side being at such a distance carries down the Record and with it Witnesses that knew how to swear home Dawson also knowing the justice of his Cause fearing the other should neglect it though Defendant he also carried the Record with him to tryal in case Read and Dun should not So two Juryes were Impannelled one on the Plaintiffes another on the Defendants score And although Dawson might have just cause to fear the packing of a Jury on the behalf of Read and Dun whom his former experience had taught him to be notoriously villanous yet trusting to the righteousnesse of his Cause rather than contend was content to lose the benefit of his own Record and proceed to tryal by their Jury Who being sworn upon the Case between Dun and Dawson Read who was at the charge of that Tryal and carrying the witnesses out of London as hath been since confessed upon Oath by the Plaintiff Dun and several other witnesses and may be concluded by this undenyable Circumstance that Read gave Ten thousand pound security to the Warden of the Fleet to whom Dun was then a prisoner to have him personally present at the Tryal to own the same yet this Read appears as one witness in the behalf of Dun and swore that Warrant of Attorney was a true Warrant and Signed and Sealed by Dawson to Dun for 220l which Dawson owed him although in truth Read did himself Forge Sign and Seal that Warrant as hath been already said and also made appear by Oath upon Record Having thus led the Dance he next produceth another witness like himself to confirm his testimony who went by the name of William Holmes which name also was so subscribed to the Warrant of Attorney but that person being dead this Counterfeit swears positively that he was the same William Holmes who subscribed his Hand to that Warrant of Attorney which he upon Oath said was Signed Sealed and Delivered by that same Richard Dawson who was then Defendant in that Cause But it was discovered in Court that this pretended William Holmes was indeed Isaack Harding a Scrivener now and for thirty years last past dwelling in Swan-Alley near Holborn-Bridge and was hired by Read for the Sum of 45s paid him in hand by his appointment besides what was promised him afterward to make that desperate Oath which he knew to be false in every Circumstance of it Now how God was pleased to discover the falshood and perjury of these Villains whose feared Consciences durst attest his Divine Majesty so solemnly yet so falsely it
will not be amiss to declare briefly In the time of the hatching and prosecuting the afore-mentioned Villany against Dawson one Thomas Gunning was by Robert Dun perswaded to goe to a certain person unknown but only to the Procurers and Abbetters of the intended Cheat to make demand of 220l of him as if he had been Richard Dawson which sum he was to pay unto him upon Defeasance of a Warrant of Attorney to confesse a Judgement for 350l which Dun told Gunning Richard Dawson had Signed and Sealed and that Party to whom he sent him was the same person Gunning at that time not knowing Dawson made demand accordingly That Counterfeit person owning the name of Richard Dawson promised payment of the Sum demanded in a Weeks time Of which demand and an answer thereto returned by the supposed Richard Dawson Gunning being perswaded by Dun made Affidavit The true Dawson hearing this news so strange to him testified upon Oath was alarum'd thereby to look about and being Authorized by an Order to bring in this Deponent Gunning to see if he would make good his Deposition the whole Plot was in part discovered for seeing the true Richard Dawson in presence he not only upon his Oath denied him to be the same of whom he made the aforesaid demand of 220l who then professed himself to be the same Party but also Deposed that Dun in the name of Read had offered him 40l to swear that Warrant of Atorney to be the Act and Deed of Dawson and bringing him to Read's Chamber in Davids-Inne there Read himself proffered him in Case he would so make Oath to maintain him at his Country-House furnish him with a good Horse and give him forty pounds in money as is at large declared in the Deposition of Thomas Gunning before the Right Honourable Justice Mallet taken July 27. 1660. This first light in short time with Gods blessing discovered the whole design For afterward Richard Ramsey one of the witnesses to that Warrant of Attorney being Subpaena'd by Read four dayes before the Tryal at Bury Assizes at his Chamber in Davids-Inne to be witness in the Case between Dun and Dawson there Read proffer'd him five pound in hand to swear that the Defendant Dawson did Sign Seal and deliver that Warrant of Attorney to the use of Dun he when he came in Court ingeniously related the truth viz. that he was present at signing and sealing that Warrant of Attorney and subscribed his Mark as a Witness thereto but then knew not either Dun or Dawson but since knowing both he on his Oath affirmed Dawson not to be present at that time but Read was the very person who signed sealed and delivered it in the name of Dawson he also upon Oath declared the proffer of five pound in hand made him by Read in case he would swear as was before related also that then and several other times he saw Read give Dun money to prosecute the said Suit of Forgery and that Jacob Wrag Clerk to Read told him after the Tryal that had not he been at Bury Assizes his Master Read and Dun had overthrown Dawson by the evidence of Isaac Harding who there swore by the name of William Holmes Which William Holmes being then dead on his death bed did declare that he was sollicited but was not witness to the Warrant of Attorney against Dawson to Dun yet his name was subscribed his person and hand counterfeited and though at the Tryal he were dead yet Harding who as a Scrivener had attested several Leases and Deeds for above thirty years space by the name of Isaac Harding for the sum of forty five shillings paid in hand besides what was afterward promised he desperately swore what he knew to be false under the counterfeit name of William Holmes whose name and hand was at first only forged as before was said Thus it pleased God to defeat the Devices of these two malicious desperate Villains and to discover their forgeries so that the old perjured Wretch that swore by a disguised name got nothing by his counterfeiting and forswearing himself not those who employed him but a bare detection of their Villany to the confusion of themselves and the amazement of the hearers Dawson having this ground to work upon proceeds to the examination of Dun whose Conscience beginning to relent had compelled him to acknowledge what he had acted against him to several of his acquaintance which he hearing of procured his examination before the Right Honourable Lord Chief Justice Foster Nov. 26 1660. who there upon Oath confessed that the Warrant for Judgement to an Atturney and Commission for Bankruptship sued forth thereupon were both carried on in his name by the instant importunity of Read and at his Costs and Charge with design only to defraud Dawson of the 718l Judgement recovered by him against Read and the Costs taxed in Chancery upon the dismission of his Bill by the Lords Commissioners and that he did verily believe the Commissioners who sat upon the Statute taken out in his name did declare Dawson a Bankrupt under their hands and seals only at the request and importunate desire of Read He also confirmed upon his Oath Reads suborning Isaack Harding to swear at Bury Assizes under the false borrowed name of William Holmes that he saw the Warrant of Attorney which was made to Dun for 350l signed and sealed by that very Dawson who appeared Defendant in that Case in the Court for which Oath so to be made Read gave him forty five shillings in hand Likewise that by the Confession of Read as well as the information of divers credible persons he was assured that Read was often in company with the Under-Sheriffe of Norfolk during that very time he had a Writ of Execution against him at the Suit of Dawson for a Judgement of 718l recovered by law And lastly that one Jacob Wrag Servant to Read came to him the Deponent in his Masters name to desire him not to discover any of these things before mentioned and for so doing he would be careful for him and not suffer him to want Thus at length was made a compleat discovery of all the windings and turnings of these Serpentine Monsters in Villany one of them in whose name and by whose industry in great measure things were thus corruply or rather hellishly carried upon his Oath discovering himself and accusing and so branding his wicked partner with a black note of infamy not to be wiped off by all the cunning he or his accursed Tutor in these Forgeries Perjuries and subornation to perjury can find out or invent To God the true Author of this discovery be ascribed the sole praise and glory thereof The several chief heads of the testimonies of these three Deponents I thought fit here to set down with what perspicuity and brevity I could not swerving in the least from the true intent and meaning of the Affidavits themselves which are at large upon Record taken
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