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<DATE>2014-08-25</DATE>
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<NAME>Zev Berger</NAME>
<RESP>MURP</RESP>
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<ITEM>Checklist: x Add TEMPHEAD, change DATE, validate Add DIV TYPEs, validate Review structure, use BODY or rarely GROUP Check PB placement and completeness, ensure sequence of N="" Proof title page(s) Check HEAD TRAILER ARGUMENT EPIGRAPH OPENER CLOSER SIGNED SALUTE BYLINE Check ^, oe, abq, italic I / J, _Initals, space between &amp;c. Check # @ -- UNCLEAR LB FIGURE Check q; startq endq Q&#62; Correct illegibles from proofsheet Check illegible page, para, line, span, word, dollar signs Final validate Corrected [ ] illegible groups out of [ ]. Converted [43] illegible groups to GAP DESC="illegible". DONE</ITEM>
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<IDG S="marc" R="UM" ID="B25594">
<STC T="W">L166C</STC>
<BIBNO T="oclc">[ocm]27245325</BIBNO>
<VID>205732</VID>
</IDG>
<TEXT LANG="eng">
<BODY>
<DIV1 TYPE="text">
<PB N="1" REF="1">
<HEAD>The Lady Ivy</HEAD>
<P>HAving thought fit &s;ome &s;hort time before <HI>Ea&s;ter</HI>-Term, 1687. to cau&s;e to be printed and publi&s;hed a Paper intituled, An Ab&s;tract of the Title to the Lands in <HI>Wapping</HI>-Mar&s;h, and other Places neer adjoyning, belonging to the Mannor of <HI>Stepney</HI> or <HI>Stebonheath,</HI> called <HI>Ewell,</HI> alias <HI>Tile-hou&s;e,</HI> thereby ma|king Title in general to more Ground (great part of it built) than the City of <HI>London</HI> &s;tands upon; but particularly to none of the Lands in que&s;tion. She af|firms, That the 14th of <HI>June</HI> 1573. 15 <HI>Eliz. John Stepkins,</HI> one of her Ance&s;tors, being in|debted to the Queen as Surety for <HI>William Patent,</HI> in the 19th of <HI>Eliz. Stepkins</HI>'s Lands were Extended, and that therein are expre&s;t mo&s;t of the Lands mentioned in the Extent of 4 <HI>Eliz.</HI> taken out again&s;t <HI>Richard Hill</HI>'s Lands, upon a Statute entred into by him 32 <HI>Hen.</HI> 8. being 113 Acres, and particularly all the Lands now in di&s;pute; which is confidently affirm'd, but very untrue: for in the Deed from <HI>Stepkins,</HI> to convey all his Lands to the Queens Tru|&s;tees, and in the Extent 19 <HI>Eliz.</HI> and the Lea&s;e from the Queen to <HI>Alice Stepkins,</HI> and the Relea&s;e from King <HI>James,</HI> 7 <HI>Jac.</HI> to <HI>John Stepkins,</HI> all the particulars of <HI>Stepkins</HI>'s Lands are Enumerated, and the Tenants names, whereof there was but a few Acres lying in the Mar&s;h mentioned as convey'd to Tru&s;tees for the Queen, and fifty Acres only Extended (being all they had) in <HI>Wapping</HI>-Mar&s;h at that time, but not the lea&s;t part of the Lands in di&s;pute named, they being all that time (and long before and ever &s;ince) in other mens po&s;&s;e&s;&s;ion, under whom Sir <HI>Anthony Bateman,</HI> and the Tru&s;tees for <HI>Rebecca Whichcot,</HI> purcha&s;ed.</P>
<P>And le&s;t the World &s;hould by the &s;aid Paper be made to believe that the Lands in que|&s;tion were (as part of the Land then belonging to <HI>Stepkins</HI>) a&s;&s;igned to the u&s;e of the Crown and there remained till 1609, and &s;o mu&s;t have been <HI>Stepkins</HI>'s Land at that time,</P>
<P>The Creditors of Sir <HI>Anthony Bateman</HI> have thought fit to print &s;o much of their Ti|tle as remains on Record, to ten Acres of Freehold, and twelve Acres of Copyhold-Land, as have al&s;o the Heirs of <HI>Rebecca Whichcot,</HI> to above three, and not exceeding four Acres, all lying in <HI>Wapping</HI>-Mar&s;h, and de&s;ire the Readers to take notice of the Boundaries in the old Deeds by which this Land is de&s;cribed, exactly an&s;wered by the Lands in di&s;|pute: And that &s;everal of the Sales made (on Record) of the Freehold, and Surrenders (al&s;o on Record) of the Copyhold, were made during the time that the E&s;tate of the <HI>Stepkin&s;es</HI> did remain in the Crown, and &s;o cannot be rea&s;onably thought to have been any part of that Land.</P>
<DIV2 TYPE="section">
<HEAD>The Creditors Title to Ten Acres of Freehold-Land.</HEAD>
<P><HI>JOhn Nelthorpe,</HI> and <HI>Elizabeth</HI> his Wife, Daughter and &s;ole Heir of <HI>John Starkey,</HI><NOTE PLACE="marg">27 <HI>July,</HI> 10 <HI>Eliz.</HI> 1568.</NOTE> conveys by Deed enrolled to <HI>Richard Sleford</HI> and his Heirs, all tho&s;e ten Acres of Mar&s;h-ground, with its Appurtenances, in <HI>Wapping</HI>-Mar&s;h in the County of <HI>Middle&s;ex,</HI> between the Lands late of <HI>Ja&s;per Hill,</HI> and <HI>Gravel-Lane,</HI> on every part.</P>
<P>The&s;e Lands lie butting on one &s;ide on <HI>Gravel-lane,</HI><NOTE PLACE="marg">Note.</NOTE> and on the Copyhold late <HI>Hill</HI>'s on the other, <HI>Ja&s;per Hill</HI> being the man that la&s;t &s;urrendred the &s;ame, even to one of the <HI>Stepkin&s;es,</HI> but the 4th of <HI>Eliz.</HI> before, as appears by Copy of Court-Roll on Record, 5 <HI>Eliz.</HI> 1563.</P>
<P>A Fine by <HI>Nelthorpe</HI> and his Wife, pur&s;uant to the Deed.</P>
<P><HI>Richard Sleford</HI> &s;ells the &s;ame ten Acres to <HI>Henry Tailford,</HI><NOTE PLACE="marg">12 <HI>Oct.</HI> 24 <HI>Eliz.</HI> 1582.</NOTE> but butts it (as it did at that time) We&s;t on <HI>Gravel-lane,</HI> Ea&s;tward on <HI>Gla&s;cock</HI>'s, and North on <HI>Stukeley</HI>'s Land.</P>
<P>The Land late <HI>Hill</HI>'s, was 23 <HI>Eliz.</HI> &s;urrendred to <HI>Gla&s;cock,</HI> as appears by the Copy;<NOTE PLACE="marg">Note.</NOTE> and that the North Buttal was on <HI>Stukeley</HI>'s Land, appears by the Sale <HI>Stukeley</HI> made of Land lying North of it, 4 <HI>Jacobi</HI> enrolled.</P>
<PB REF="2">
<PB REF="2" MS="y">
<PB REF="3">
<PB REF="3">
<PB REF="4">
<P><FIGURE>
<FIGDESC>map of Desputed Land</FIGDESC>
<P>6 Acres Sold to Thomas Ea&s;tfeild alias Lucas by John Stepk<GAP DESC="illegible" RESP="UOM" EXTENT="3 letters"> in Elis N<GAP DESC="illegible" RESP="UOM" EXTENT="1 letter">w S.^r Caen Iames his Land.</P>
<P>EAST</P>
<P>Sewer</P>
<P>Here lyes 4 Acres of Land down to the Thames through which Cora|rel Lane is made with the Ground wherein here<GAP DESC="illegible" RESP="UOM" EXTENT="1 chunk"> was both a Pond and Island whereof the 3 upperm<GAP DESC="illegible" RESP="UOM" EXTENT="3 letters"> Acres were Sold to M^r Weed <GAP DESC="illegible" RESP="UOM" EXTENT="1 word"> and the rest to M^rathbear 1656 both by deeds Inre<GAP DESC="illegible" RESP="UOM" EXTENT="2 letters">ed by Lady Ivy</P>
<P>Wa<GAP DESC="illegible" RESP="UOM" EXTENT="1 letter"> Pond</P>
<P>Was now Ar lo y^e Bl<GAP DESC="illegible" RESP="UOM" EXTENT="1 letter">w</P>
<P><GAP DESC="illegible" RESP="UOM" EXTENT="1 word"> libears Land <GAP DESC="illegible" RESP="UOM" EXTENT="1 word"></P>
<P>Island</P>
<P>New Crane Staires</P>
<P>y^e River of Thames</P>
<P>New Gravel Lane</P>
<P>New Gravel Lane</P>
<P>Ratcliffe High W<GAP DESC="illegible" RESP="UOM" EXTENT="1 chunk"></P>
<P>The Deanes Linches</P>
<P>Land Sold by Lady Ivy 1656 to Weed Buttins South on y^e Sewwer that Devides it from Batemans Land</P>
<P>Sewer or Pond</P>
<P>7 Acres Co<GAP DESC="illegible" RESP="UOM" EXTENT="2 letters">y Hold late held by Hamm<GAP DESC="illegible" RESP="UOM" EXTENT="1 letter">n</P>
<P>22 Acres within the Red Line whereof to Butting all along West on Gravel Lane down to the Prickt Lane East on Hills afterwards Glasecks and North on - Sh<GAP DESC="illegible" RESP="UOM" EXTENT="3 letters">keleys Land to Claimd as 10 Acres of Freehold as 12 Acres of Co<GAP DESC="illegible" RESP="UOM" EXTENT="2 letters">y hold that was late Mills in the 10^t^h and Gla&s;<GAP DESC="illegible" RESP="UOM" EXTENT="1 letter">ocks in the 24^t^h Eliz</P>
<P>10 Acres Free Hold butting West on Old Gravell Lane</P>
<P>Here was a Rope Walk</P>
<P>5 Acres Co<GAP DESC="illegible" RESP="UOM" EXTENT="3 letters">y hold mixt y^e Red and Prickt Line Lot by Richard Glover to Aaron Williams for <GAP DESC="illegible" RESP="UOM" EXTENT="1 word"> from 1630 And y^e Lea&s;e thereof purchased by the Lady Ivy 1659 <GAP DESC="illegible" RESP="UOM" EXTENT="1 word"> thereby get the Po&s;se&s;sion</P>
<P>King Street in Wa<GAP DESC="illegible" RESP="UOM" EXTENT="2 letters">ing Marsh</P>
<P>Pru&s;ons Island</P>
<P>a-boue 3</P>
<P>but not within</P>
<P>4 Acres the Blow Lane</P>
<P>Sluce</P>
<P>114 Ea-<GAP DESC="illegible" RESP="UOM" EXTENT="1 letter">t</P>
<P>Bridwell Land betwixt Pru&s;ens Island</P>
<P>King Edward Stairs</P>
<P>SOUTH</P>
<P>NORTH</P>
<P>Starch House Stewkeleys now <GAP DESC="illegible" RESP="UOM" EXTENT="1 word"> Land</P>
<P>and Old Gravell Lane</P>
<P>Old Gravel Lane Old Gravel Lane</P>
<P>WEST</P>
<P>Scaled of Feet</P>
</FIGURE></P>
<PB N="1" REF="4">
<GAP DESC="duplicate" EXTENT="1 page">
<PB N="2" REF="5">
<P><NOTE PLACE="marg">Note.</NOTE>There are two <HI>Gravel-lanes,</HI> one called <HI>Old Gravel-lane,</HI> the other <HI>New Gravel-lane</HI> (be|tween which all the Land now in que&s;tion does lie) but that <HI>Old Gravel-lane,</HI> on which the&s;e Lands Abutt We&s;t, was the <HI>Gravel-lane</HI> meant by the&s;e Deeds, is plain; for that <HI>New Gravel-lane</HI> was a Rope-Walk long &s;ince the memory of many alive, and &s;old by Lady <HI>Ivy</HI> her &s;elf, with the Land on each &s;ide of it, to <HI>Brian H<GAP DESC="illegible" RESP="UOM" EXTENT="1 letter">rri&s;on,</HI> Tru&s;tee for <HI>Wil|liam Word,</HI> by Deed enrolled, dated the fir&s;t of <HI>July</HI> 1658. by the name of three Acres, heretofore u&s;ed for a Rope-ground, and now converted into a Street called <HI>New Gravel-lane.</HI></P>
<P><HI>Henry Tailford</HI> had a Daughter who was his Heir, and married <HI>John Cro&s;&s;e,</HI> who &s;o became &s;eized thereof.</P>
<P><NOTE PLACE="marg">34 &amp; 35 <HI>Eliz. Trin.</HI> 43 <HI>Eliz.</HI> 1601. <HI>Hill.</HI> 9 <HI>Jac.</HI> 1611. 5 <HI>Aug.</HI> 13 <HI>Jac.</HI> 1615. 14 <HI>Aug.</HI> 1647.</NOTE>A Recovery <HI>per Cro&s;&s;e</HI> and his Wife.</P>
<P><HI>Cro&s;&s;e</HI> and his Wife levied Fine to <HI>Bennet.</HI></P>
<P><HI>Richard Bennet</HI> and <HI>Lettice</HI> his Wife, levy a Fine to <HI>Richard Glover.</HI></P>
<P><HI>Richard Glover</HI> &s;ettles by his Will, the&s;e Lands, among others, on his Son <HI>Richard;</HI> who dying about 1646. left a Son whole name was al&s;o <HI>Richard.</HI></P>
<P><HI>Richard Glover</HI> the Grand&s;on's Conveyance enrollod, to Sir <HI>Anthony Bateman</HI> and others of the premi&s;&s;es, among other things, in Tru&s;t to pay Debts; and a Lea&s;e of five Acres, part of the Lands in que&s;tion from <HI>Richard Glover,</HI> to <HI>Aaron Williams</HI> for fifty years, from 1630. at 20 <HI>l.</HI> yearly, recited in the Schedule to it, which Lea&s;e Lady <HI>Ivy</HI> purcha&s;ed in 1659. for about 2000 <HI>l.</HI> and &s;o got the po&s;&s;e&s;&s;ion of it. See her An&s;wer to Sir <HI>Robert Cotton</HI>'s Bill put in, in 1676.</P>
<P><NOTE PLACE="marg"><HI>Trin.</HI> Term. 1656.</NOTE><HI>Smith, Harrington, Anthony Bateman,</HI> and <HI>Richard Glover</HI> the Grand&s;on, levy a Fine to <HI>Tirrill</HI> and <HI>Harris,</HI> Tru&s;tees for <HI>Bateman.</HI></P>
<P><NOTE PLACE="marg">15 <HI>July</HI> 1656.</NOTE>A Deed enrolled, reciting a Deed from the Parties to the afore&s;aid Fine, to <HI>Tirrill</HI> and <HI>Harris,</HI> the 20th of <HI>June</HI> la&s;t; whereby <HI>Tarrill</HI> and <HI>Harris</HI> convey the &s;aid Lands to <HI>Anthony Bateman</HI> and his Heirs, who held the po&s;&s;e&s;&s;ion thereof, and received the Rents till he failed about 1666. and under whom Sir <HI>Robert Cotton,</HI> as Tru&s;tee for the Creditors, claims, and in <HI>Ea&s;ter</HI>-Term 1686. after a full Hearing in the <HI>Kings-Bench,</HI> had a Verdict for this, and the twelve Acres Copyhold-Land.</P>
</DIV2>
<DIV2 TYPE="section">
<HEAD>Title to the Copyhold-Land.</HEAD>
<P><NOTE PLACE="marg">5 <HI>Ed.</HI> 6. 1551.</NOTE><HI>EDward A&s;cugh</HI> and his Wife, &s;urrender twelve Acres in <HI>Wall</HI> and <HI>Wapping</HI>-Mar&s;h, to <HI>Ri|chard Hill.</HI></P>
<P><NOTE PLACE="marg">5 <HI>Eliz.</HI> 1563.</NOTE>Copy whereby <HI>John Stepkins</HI> &s;urrenders the twelve Acres to <HI>John Harding,</HI> and recites they had been <HI>Alwine</HI>'s and <HI>Gib&s;on</HI>'s, and that he had them by Grant of the Lord of the Mannor, and Relea&s;e of <HI>Ja&s;per Hill.</HI></P>
<P><NOTE PLACE="marg">Note.</NOTE>There is not known to be any but this twelve Acres Copyhold, in the whole Mar&s;h.</P>
<P><NOTE PLACE="marg">13 <HI>Eliz.</HI> 1571.</NOTE><HI>John Harding</HI> &s;urrenders to <HI>John Osborne.</HI></P>
<P><NOTE PLACE="marg">18 <HI>Eliz.</HI> 1576.</NOTE><HI>John Osborne</HI> &s;urrenders to <HI>Richard Wotton</HI> and <HI>Robert Harrell.</HI></P>
<P><NOTE PLACE="marg">20 <HI>Eliz.</HI> 1576.</NOTE><HI>John Osborne</HI> having forfeited for having Lett without Licen&s;e, the Lord of the Mannor ad|mitted <HI>Walthal</HI> and <HI>Finch.</HI></P>
<P><NOTE PLACE="marg">23 <HI>Eliz.</HI> 1581.</NOTE><HI>Walthal</HI> and <HI>Finch</HI> &s;urrender to <HI>Jo. Gla&s;cock.</HI></P>
<P><NOTE PLACE="marg">26 <HI>Eliz.</HI> 1584.</NOTE><HI>Gla&s;cock</HI> &s;urrenders to <HI>Tho. Cook</HI> and his Wife.</P>
<P><NOTE PLACE="marg">1 <HI>Jac.</HI> 1603. 1616.</NOTE><HI>Cock</HI> and his Wife &s;urrender to <HI>Richard Glover,</HI> Citizen and Pewterer of <HI>London.</HI></P>
<P><HI>Richard Glover</HI> dying, the Copyhold being Gavelkind, fell to his &s;everal Sons, who all after &s;urrendred to <HI>Richard</HI> the Elde&s;t; who dying in 1646. his Son (after admittance) in 1647. &s;urrendred to <HI>Robert Smith</HI> and <HI>Anthony Bateman,</HI> who was (till he broke) in po&s;&s;e&s;&s;ion, and received the Rents.</P>
<P>Sir <HI>Robert Smith</HI> died 12 <HI>June,</HI> 21 <HI>Car.</HI> 2. &s;o Sir <HI>Anthony</HI> was the Survivour.</P>
<P>Sir <HI>Anthony</HI> became a Bankrupt. See the Commi&s;&s;ion.</P>
<P><NOTE PLACE="marg">27 <HI>Nov.</HI> 25 <HI>Car.</HI> 2.</NOTE>The Commi&s;&s;ioners A&s;&s;ignment of the ten Acres Freehold, and twelve Acres Copyhold to Sir <HI>Robert Cotton,</HI> enrolled.</P>
<P><NOTE PLACE="marg">13 <HI>May,</HI> 26 <HI>C.</HI> 2 <HI>Ea&s;ter</HI>-Term, 1686.</NOTE>Sir <HI>Robert Cotton</HI> admitted to the twelve Arcres Copyhold.</P>
<P>A Verdict for Sir <HI>Robert Cotton.</HI></P>
</DIV2>
<DIV2 TYPE="section">
<PB N="3" REF="5" MS="y">
<HEAD>The Heirs of <HI>Whichcot</HI>'s Title to <HI>Pru&s;on</HI>'s I&s;land.</HEAD>
<P><HI>PEter Osborne</HI> conveys the Breach, <HI>&amp;c.</HI> to <HI>Wood&s;haw,</HI><NOTE PLACE="marg">25 <HI>Eliz.</HI> 1583.</NOTE> by E&s;timation three (not exceeding four) Acres, butting <HI>East</HI> on a Sluce, <HI>South</HI> on the <HI>Thames, North</HI> on <HI>Wapping</HI>-Mar&s;h, <HI>West</HI> on a piece of Ground, next a-butting and adjoyning on a certain Way or Lane there, called <HI>Gravel-Lane.</HI> Enroll'd.</P>
<P><HI>James Wood&s;haw</HI> conveys the &s;ame to <HI>Richard Glover.</HI> Livery and Sei&s;in Endor&s;ed.<NOTE PLACE="marg">20 <HI>M.</HI> 3 <HI>Ja.</HI> 1604. 1616.</NOTE></P>
<P><HI>Richard Glover</HI> Devi&s;es, by general Words, <HI>Wapping</HI>-Land to <HI>Richard Glover</HI> his Son. Book of <HI>Wills.</HI></P>
<P>The &s;aid <HI>Richard Glover</HI> conveys the &s;ame to <HI>Warren</HI> and his Heirs. Enroll'd.<NOTE PLACE="marg">26 <HI>Mar.</HI> 1646.</NOTE></P>
<P>The &s;aid <HI>Richard</HI> confirms the &s;ame to <HI>Warren.</HI> Enroll'd.<NOTE PLACE="marg">28 <HI>Mar.</HI> 1646.</NOTE></P>
<P><HI>Richard Glover,</HI> the Grand-&s;on, confirms the &s;ame.<NOTE PLACE="marg">16 <HI>May</HI> 1646.</NOTE></P>
<P><HI>George Warren</HI> &s;ells the &s;ame to <HI>Richard Lloyd</HI> and <HI>John Wicken.</HI> Enroll'd.<NOTE PLACE="marg">19 <HI>Mar.</HI> 1646.</NOTE></P>
<P><HI>Richard Lloyd</HI> and <HI>John Wicken,</HI> by Lea&s;e and Relea&s;e, &s;ell to <HI>William Crowder,</HI><NOTE PLACE="marg">24 <HI>Apr.</HI> 1649. 25 <HI>Apr.</HI> 1649.</NOTE> <HI>Thomas Jor|den, Thomas Horton,</HI> and <HI>John Jolliff,</HI> Tru&s;tees for <HI>Rebeca Whichcot,</HI> late <HI>Glover</HI>'s Wife.</P>
<P><HI>Crowder, Jorden,</HI> and <HI>Horton,</HI> Die before 1680, <HI>John Jolliff</HI> in 1680, being the &s;urviving Tru&s;tee, and in <HI>William Jolliff,</HI> his Son and Heir, the Inheritance of the&s;e Lands remains, in Tru&s;t for the Heirs of the &s;aid <HI>Rebecca Whichcot,</HI> to this Day: And,</P>
<P><HI>Note,</HI> The Land now called <HI>Pru&s;on</HI>'s I&s;land, (which name it a&s;&s;uredly took from having been long in po&s;&s;e&s;&s;ion of one <HI>Pru&s;on,</HI> under <HI>Glover</HI>'s Title) is above three, and not four Acres; butted <HI>East</HI> on (a place where there was) a Sluce, <HI>South</HI> on the <HI>Thames, North</HI> on <HI>Wapping</HI>-Mar&s;h, and <HI>West</HI> on <HI>Bridewel</HI>-Ho&s;pital-Land, heretofore a piece of Ground which butted and adjoyned upon <HI>Gravel-Lane;</HI> and was held under <HI>Glover</HI>'s Title by Mrs <HI>Rebecca Whichcot,</HI> till outed by Lady <HI>Ivy,</HI> 1679.</P>
<P>And if Lady <HI>Ivy</HI> can &s;hew what Land 'tis po&s;&s;ible the ten Acres in <HI>Wapping</HI>-Mar&s;h &s;hould be, but the Lands in que&s;tion, butting <HI>West</HI> on <HI>Gravel-Lane,</HI> and where the twelve Acres of Copyhold in <HI>Wapping</HI>-Mar&s;h &s;hould be, (that was late <HI>Hill</HI>'s in the 10th, and <HI>Gla&s;cock</HI>'s the 23d of <HI>Eliz.</HI>) and lying <HI>East</HI> of the la&s;t ten Acres, but the Lands in que&s;tion, and which have been always enjoyed by tho&s;e the Creditors Claim under, by Copy of Court Roll, &s;ince <HI>Edw.</HI> the Sixth's time, and where there &s;hould be three, and not exceeding four Acres, that butted <HI>East</HI> on a Sluce, <HI>South</HI> on the <HI>Thames, North</HI> on <HI>Wapping</HI>-Mar&s;h, and <HI>West</HI> on a piece of Ground that butted on <HI>Gravel-Lane,</HI> unle&s;s the Ground now called <HI>Pru&s;on</HI>'s I&s;land, which really does &s;o a butt, they will then quit their Claim to the&s;e Lands, which they o|therwi&s;e hope will at &s;ometime or other be allowed to be theirs.</P>
<P>As to what Lady <HI>Ivy</HI> is plea&s;ed to &s;ay concerning the &s;everal Verdicts &s;he has had for her Title, the Reader is hereby informed, That tho&s;e Verdicts were got on producing of Deeds, which are not mentioned in her printed Paper, nor yet to be found on Record.</P>
<P>And as to what &s;he is plea&s;ed to &s;ugge&s;t concerning the Conviction of her Adver&s;aries At|torney, one <HI>John&s;on.</HI></P>
<P><HI>Note,</HI> There was one <HI>Duffet,</HI> a notorious common Forger of Deeds, and an intimate Ac|quaintance of my Lady's: He fir&s;t applied him&s;elf to Mr. <HI>John&s;on</HI> as a Witne&s;s, without <HI>John&s;on</HI>'s &s;eeking to him, and di&s;covering his Treaty with <HI>John&s;on,</HI> drew him into a &s;nare, being, as &s;uppo&s;ed, employed by &s;ome-body el&s;e.</P>
<P>As for the Records and Deeds, which made up three parts of her Paper, they are mo&s;t of them &s;uch as were never made u&s;e of at any Tryal, and &s;erve onely for a &s;hew, and an a|mu&s;ement, and when rightly con&s;idered, are nothing to the purpo&s;e at all.</P>
<P>And that the World may al&s;o &s;ee what Title, both on Record and otherwi&s;e, the Lady <HI>Ivy</HI> has yet been plea&s;ed to produce for the Lands in que&s;tion, with what may rea&s;onably be objected again&s;t it by Arguments, onely deduced from other Deeds on Records, the &s;ame is incerted here, and if any mi&s;take be made in't, it is not wilfully done, and will be un|doubtedly An&s;wered by Lady <HI>Ivy</HI>'s Direction, if there be any thing in it untrue, her Lady|&s;hip having already appeared twice in Print in the&s;e matters, and thereby given occa&s;ion for the Printing of this.</P>
</DIV2>
</DIV1>
<DIV1 TYPE="title dispute">
<DIV2 TYPE="section">
<PB N="4" REF="6">
<AB TYPE="claim"><LABEL>The Lady <HI>Ivy</HI>'s Title.</LABEL> THat <HI>Wapping</HI>-Mar&s;h being one Hun|dred and Thirty Acres drowned Land, was, for a Moyty thereof, undertaken be|fore the <HI>27 Hen. 8.</HI> to be Inned and Drain|ed by one <HI>Vanderdelfe,</HI> who &s;old his Moy|ty to one <HI>Richard Hill,</HI> on whom that Moyty was by Act of Parliament, <HI>27 Hen. 8.</HI> &s;etled.</AB>
<AB TYPE="rebuttal"><LABEL>The An&s;wer to it.</LABEL> THe Act of Parliament was undoubtedly &s;o, and onely &s;hews there was a Hundred and Thirty Acres to be Drained, and that <HI>Richard Hill</HI> having purcha&s;ed <HI>Vanderdelfe</HI>'s intere&s;t, was to have one Moyty of it.</AB>
<AB TYPE="claim"><NOTE PLACE="marg">2 <HI>Edw.</HI> 6.</NOTE>A Lea&s;e produced by which <HI>Richard Hill</HI> lets &s;ixteen Acres to one <HI>Clayton,</HI> a Butcher, for five years, lying along <HI>Gra|vel-Lane.</HI></AB>
<AB TYPE="rebuttal"> This Lea&s;e (if really true) onely &s;hews that <HI>Ri|chard Hill</HI> had Land there; which it may be he had, and probably he or his Son <HI>Ja&s;per</HI> might after &s;ell it to <HI>John Starkey</HI> (under whom it is Claimed now) before they &s;old any to <HI>Stepkins</HI> at all.</AB>
<AB TYPE="claim"><LB><NOTE PLACE="marg">23 <HI>March</HI> 5 <HI>Edw.</HI> 6th.</NOTE>A Deed whereby <HI>Richard Hill</HI> &s;ells to <HI>Thomas Stepkins</HI> and his Heirs, for e|ver, &s;ixteen Acres in <HI>Wapping</HI>-Mar&s;h, in the Tenure of one <HI>Clayton,</HI> and fifteen A|crees and three Roods of Land in <HI>Wap|ping</HI>-Mar&s;h, then in the po&s;&s;e&s;&s;ion of <HI>Ri|chard Hill,</HI> lying by the Pond in the &s;aid Mar&s;h, and all tho&s;e his Me&s;&s;uages, Pond, Lands, and Soil, in the Pari&s;hes of <HI>Step|ney</HI> and St. <HI>Mary Matfellon,</HI> or el&s;e|where in the County of <HI>Middle&s;ex;</HI> and were parcel of hundred and thirty Acres, formerly Drowned, but not of the fifty three Acres that were <HI>Stepkins</HI>'s before the Drowning.
<LB>Note, <HI>The word is Drowning, and not Draining, in the Deed.</HI>
<LB><HI>See Lady</HI> Ivy<HI>'s An&s;wer to Dr.</HI> Which|cot<HI>'s Bill, 1677.</HI></AB>
<AB TYPE="rebuttal"> This (if true) purports a mo&s;t ab&s;olute &s;ale of all the Lands <HI>Richard Hill</HI> had in the County of <HI>Middle&s;ex;</HI> and yet the &s;aid <HI>Richard Hill,</HI> the 20 <HI>Oct.</HI> 6 <HI>Edw.</HI> 6. <GAP DESC="illegible" RESP="UOM" EXTENT="1 span"> la&s;t Will and Te&s;tament, &s;ettles the La<GAP DESC="illegible" RESP="UOM" EXTENT="1 chunk"> <GAP DESC="illegible" RESP="UOM" EXTENT="1 chunk">e bought of <HI>Vanderdelfe</HI> (of which, by the Deed, this appears to be part) on his Son <HI>Ja&s;per Hill,</HI> with &s;everal Remainders over in Taile, which 'tis not likely he would have done, had he &s;old it away before; and as a very good Argument that it was &s;o Entailed by <HI>Richard Hill</HI>'s Will, there appears on Record, a Fine and Re|covery &s;uffered by <HI>Ja&s;per Hill (Richard Hill</HI>'s Son) to <HI>Machelin</HI> and <HI>John Stepkins,</HI> of twenty Acres of Land, and a hundred Acres of fre&s;h Mar&s;h in <HI>White-Chappel, Stepney,</HI> and <HI>Wapping,</HI> the 3d of <HI>Eliz.</HI> which had been needle&s;s had it not been &s;o En|tailed, and is an argument that <HI>Stepkins</HI> bought no|thing of <HI>Hill</HI> till that time: And yet in <HI>Trinity</HI>-Term, 1684, in a Cau&s;e 'twixt the Dean of Saint <HI>Paul</HI>'s, <HI>London,</HI> and Lady <HI>Ivy,</HI> about <HI>Shadwell</HI> Lands, a Deed was then given in Evidence, Da|ted 16 <HI>Apr.</HI> 6 <HI>Edw.</HI> 6. whereby <HI>Richard Hill</HI> &s;old twenty four Acres, and all the Lands he had in <HI>Stepney</HI> and <HI>Middle&s;ex,</HI> to <HI>Thomas Stepkins:</HI> But this Deed having had the misfortune to be markt as found, and Sworn to be &s;o, with a long Lea&s;e of a hundred twenty eight Years, and other Deeds, among the Writings of the Churches Le&s;&s;ee, it was not believed then, and one of the Witne&s;&s;es that &s;wore to the &s;o finding tho&s;e Deeds, was Per|jur'd upon't, and &s;tood in the Pillory for it; and &s;ome of the &s;aid Deeds were then left in Court; by Rule of which, Dated <HI>June</HI> 1687, upon an In|formation again&s;t Lady <HI>Ivy</HI> for it, a Tryal is or|dered next Term.</AB>
<AB TYPE="claim"><NOTE PLACE="marg">12 <HI>Nov.</HI> 5 <HI>&amp;</HI> 6, Phil. <HI>and</HI> Mary.</NOTE>A Deed whereby <HI>Ja&s;per Hill,</HI> Son of <HI>Richard Hill,</HI> &s;ells all his Lands a|bout ninety two Acres, in the Mar&s;h, and County of <HI>Middle&s;ex,</HI> to <HI>Machelin</HI> and <HI>John Stepkins,</HI> and their Heirs; and is the Deed whereby Lady <HI>Ivy,</HI> in <HI>Ea&s;ter</HI>-Term, <HI>1686,</HI> Claimed the&s;e Lands, with|out producing the foregoing Deed of the <HI>23d Mar. 5 Edw. 6.</HI> but in <HI>Ea&s;ter</HI> and <HI>Tri|nity</HI> Term, <HI>1687,</HI> Lady <HI>Ivy</HI> to make Title to the&s;e Lands, produced that of the <HI>5th
<PB N="5" REF="6"> Edw. 6th,</HI> without bringing out this at all.</AB>
<AB TYPE="rebuttal"> <HI>Note,</HI> Lady <HI>Ivy</HI>'s <HI>Wapping</HI>-E&s;tate, came intirely into her power to &s;ell and di&s;po&s;e of it in 1655; and when her Lady&s;hip, in 1656, &s;old Land in <HI>Wapping</HI> to Mr. <HI>Arlibear,</HI> and in 1658, to <HI>Brian Harri&s;on,</HI> Tru&s;tee for Mr. <HI>Wood,</HI> Copies of this Deed were given them; by which it appears (if they were rightly taken) that Livery and Sei&s;in was Endor&s;ed on the back of that Deed the 20th of <HI>Nov.</HI> in the 5th and 6th year of <HI>Philip</HI> and <HI>Ma|ry,</HI> and 'tis notoriou&s;ly known that Queen <HI>Ma|ry</HI> Died the Seventeenth of that Month, and
<PB N="5" REF="6"> that Queen <HI>Elizabeth</HI> was Proclaimed the &s;ame day.</AB>
<AB TYPE="claim"><NOTE PLACE="marg">3 <HI>Eliz.</HI> &amp; 12 <HI>May,</HI> 4 <HI>Eliz.</HI></NOTE>And that <HI>Ja&s;per Hill</HI> by Fine and Re|covery <HI>3 Eliz.</HI> and by Deed <HI>12th May 4 Eliz.</HI> conveyed twenty Acres of Land, and a hundred Acres of Mar&s;h in <HI>White-Chappel, Stepney,</HI> and <HI>Wapping,</HI> to <HI>Macheline</HI> and <HI>John Stepkins</HI> and their Heirs.</AB>
<AB TYPE="rebuttal"> This is not denied to be true, and is a great argument again&s;t the truth of the foregoing Deeds, it being not credible that this Fine was levied in pur&s;uance of either of tho&s;e Deeds, it being done &s;o long after, and there being al&s;o a Deed by Lady <HI>Ivy</HI>'s own &s;hewing, dated the 12th of <HI>May</HI> following, 4 <HI>Eliz.</HI> to convey the Lands in that Fine comprized; but that Deed not naming the Lands in que&s;tion, was neither produced in <HI>Ea&s;ter</HI>-Term 1686, nor in <HI>Ea&s;ter</HI> nor <HI>Trinity</HI>-Term 1687, but was in a Tryal in <HI>Trinity</HI>-Term 1684, but 'twas in another cau&s;e, and the contents of it took at that time.</AB>
<AB TYPE="claim"><NOTE PLACE="marg">4 <HI>Eliz.</HI></NOTE><HI>Richard Hill,</HI> having the <HI>3</HI> Dec. <HI>32 Henry</HI> the <HI>8th,</HI> entred into a Statute to one <HI>Vivald,</HI> and <HI>Salvago,</HI> all the Lands which he was po&s;&s;est of after that time, being one hundred and thirteen Acres were extended, and among them the Lands in que&s;tion, and that that Extent was pur|cha&s;ed in by <HI>Stepkins.</HI></AB>
<AB TYPE="rebuttal"> This Extent was undoubtedly made, but af|fects not at all the Creditors nor <HI>Jolliff</HI>'s Title, for the ten Acres of Freehold-Land that was <HI>Nel|throp</HI>'s in right of his Wife, &s;ole Heir of <HI>John Star|key,</HI> in the 10 <HI>Eliz.</HI> and <HI>Pru&s;on</HI>'s I&s;land might have been (we do not &s;ay 'twas) <HI>Richard Hill</HI>'s &s;ince the 32 <HI>Hen.</HI> 8. and yet no part of what was &s;old to <HI>Stepkins</HI> the 3 <HI>Eliz.</HI> and for the twelve Acres of Copyhold, 'tis plain it was <HI>Richard Hill</HI>'s, and by his Son <HI>Ja&s;per</HI> &s;old to <HI>John Stepkins,</HI> under whom the Creditors, by uninterrupted Surrenders, all a|long down on Record, do make out their Title to it.</AB>
<AB TYPE="claim"><NOTE PLACE="marg">14 <HI>Eliz.</HI></NOTE>A Pre&s;entment of <HI>Sewer</HI>'s finding twelve Acres in po&s;&s;e&s;&s;ion of <HI>Walthall</HI> and <HI>Wood|cock,</HI> as the Freehold of <HI>Stepkins,</HI> and part of the Lands in que&s;tion.</AB>
<AB TYPE="rebuttal"> It &s;eems to be very much, and in many places razed, and not legible; and is not produced by the hands of the proper Officer.</AB>
<AB TYPE="claim"><NOTE PLACE="marg">14 <HI>June,</HI> 15 <HI>Eliz.</HI></NOTE><HI>John Stepkins,</HI> as Surety for <HI>William Patent,</HI> Convenanted to Pay to the Queen <HI>7928 <HI>l.</HI> 7 <HI>s.</HI> 11 <HI>d.</HI> &frac12;.</HI> and to &s;ecure it, le|vied a Fine, and conveyed an E&s;tate to Tru&s;tees for the Queen: in which Convey|ance, <HI>inter alia,</HI> is mentioned four Acres of Meadow, with a Pond and I&s;land, in the po&s;&s;e&s;&s;ion of <HI>Alice Woodcock;</HI> which La|dy <HI>Ivy</HI>'s Council do &s;ay, is the Ground now called <HI>Pru&s;on</HI>'s I&s;land. And the &s;aid <HI>John Stepkins</HI> at that time did give Bond to perform Covenants, which Bond being for|feited, in the <HI>19 Eliz.</HI> the rest of his E|&s;tate was extended, and not relea&s;ed till <HI>7 Jacobi, 1609,</HI> and then re&s;tored to the <HI>Stepkin&s;es</HI> again. And Lady <HI>Ivy</HI> in her printed Paper affirms, that most of the Lands in the Extent <HI>4 Eliz.</HI> are mentioned in this, and particularly all the Lands in di&s;pute; and thence would infer, that the&s;e were <HI>Stepkins</HI>'s Lands at that time, and, if &s;o, ought to be hers now.</AB>
<AB TYPE="rebuttal"> That <HI>John Stepkins,</HI> as Surety for <HI>Patent,</HI> being in Debt to the Queen, made over his E&s;tate to Tru|&s;tees for her u&s;e, and that 'twas after Extended, and not relea&s;ed till 7 <HI>Jac.</HI> is true. But, <HI>Note,</HI> in the Conveyance to the Tru&s;tees for the u&s;e of the Queen, there is but a very few Acres mentioned as lying in <HI>Wapping</HI>-Mar&s;h; and in the extent and Lea&s;e to <HI>Alice Stepkins,</HI> by the Queen, 19 <HI>Eliz.</HI> fifty Acres in <HI>Wapping</HI>-Mar&s;h onely are mentioned, which &s;eems to make out that <HI>Stepkins</HI> had no more there at that time; and among tho&s;e, none of the Lands now in que&s;tion are any way named or de&s;cribed: For, as for the four Acres of Meadow, with a Pond &amp; I&s;land, in the po&s;&s;e&s;&s;ion, at that time, of <HI>Alice Woodcock,</HI> it may, with much more of rea|&s;on, be taken to be the four Acres of Land, with the place where there was then both a Pond and I&s;land, lying <HI>East</HI> of <HI>Pru&s;on</HI>'s I&s;land; whereof three Acres was &s;old to <HI>Brian Harri&s;on,</HI> Tru&s;tee for <HI>William Wood,</HI> 1658; and the re&s;t to Mr. <HI>Arlibear</HI> in 1656; both by Deeds enrolled by Lady <HI>Ivy</HI> her &s;elf. Be&s;ides, had the&s;e Lands now in que&s;tion, been then &s;o convey'd to the u&s;e of the Queen, and extended, and &s;o remained till 1609, 'tis not to be imagined that they could during that time have been &s;old, as plain 'tis they were on Record, by <HI>Sleford</HI> to <HI>Tailford,</HI> the 24 <HI>Eliz.</HI> and by <HI>Cro&s;s</HI> to <HI>Bennet,</HI> the 43 <HI>Eliz.</HI> of whom <HI>Richard Glover</HI> bought; and &s;everal Sur|renders were made of the Copyhold-Land in that time, and particularly that to <HI>Richard Glo|ver</HI> (under whom the Creditors Claim) in 1603: As were al&s;o the Sales by <HI>Peter Osborne</HI> to <HI>Wood&s;haw,</HI> 25 <HI>Eliz.</HI> 1583. and by <HI>James Wood&s;haw</HI> to <HI>Richard Glover,</HI> 3 <HI>Jac.</HI> 1604; under which <HI>Pru&s;on</HI>'s I&s;land was quietly enjoyed till 1679; and under which the Heirs of <HI>Rebecca</HI> now Claim.</AB>
</DIV2>
<DIV2 TYPE="section">
<PB N="6" REF="7">
<AB TYPE="counterclaim"><LABEL>To An&s;wer the Po&s;&s;e&s;&s;ion, Lady <HI>Ivy</HI> &s;ays, That</LABEL>
<NOTE PLACE="marg">6 <HI>Novemb.</HI></NOTE><HI>14 Eliz. 1572. John Stepkins</HI> Demi&s;ed twelve Acres and other Lands, of which the&s;e were part, with an I&s;land and Pond, to <HI>Anthony Walthall</HI> and <HI>John Wood|cock,</HI> for <HI>62</HI> years: And that</AB>
<AB TYPE="rebuttal"> If there was &s;uch a Lea&s;e as <HI>per contra</HI> made by <HI>John Stepkins</HI> to <HI>Walthall</HI> and <HI>Woodcock</HI> for &s;ixty two years, from 1572. and that the &s;ame was made o|ver to <HI>Richard Glover</HI> in 1602.</AB>
<AB TYPE="counterclaim"><LB><NOTE PLACE="marg">13 <HI>Nov.</HI></NOTE><HI>44 Eliz. 1602. Walthall</HI> and <HI>Wood|cock</HI> mortgaged the &s;ame to <HI>Richard Glo|ver.</HI>
<LB><NOTE PLACE="marg">1 <HI>Novemb.</HI> 1613.</NOTE>That <HI>Anthony Walthall</HI> and <HI>Thomas Woodcock,</HI> Son of <HI>John,</HI> &s;urrendred and relea&s;ed to <HI>John Stepkins.</HI>
<LB><NOTE PLACE="marg">8 <HI>Septemb.</HI> 1619.</NOTE>That <HI>Richard Glover</HI> being in po&s;&s;e&s;|&s;ion, under the Lea&s;e to <HI>Walthall</HI> and <HI>Woodcock,</HI> and one <HI>Pru&s;on</HI> claiming &s;ome Intere&s;t under <HI>Glover,</HI> they both relea&s;ed to <HI>John Stepkins.</HI></AB>
<AB TYPE="rebuttal">'Tis very &s;trange, that the &s;aid <HI>Richard Glover,</HI> if he had no other Title but that Lea&s;e at that time, &s;hould pre&s;ume to let Lea&s;es of Lands there|in comprized, as he really did to <HI>Pru&s;on</HI> and <HI>Watts,</HI> for Terms that would not expire till long after that Lea&s;e, (and Enjoyment went with them) and much &s;tranger it is that they &s;hould accept of &s;uch Lea&s;es, and con&s;ider his Title no better, it be|ing Building-ground on which they laid out their E&s;tates. Be&s;ides, if <HI>Walthall</HI> and <HI>Woodcock</HI> mortga|ged the &s;ame to <HI>Richard Glover</HI> in 1602. and that he was in po&s;&s;e&s;&s;ion of it under that Lea&s;e in 1619. as the Surrender made by <HI>Pru&s;on</HI> and him of it, &s;hews he was till that time, how came <HI>Anthony Walthall</HI> and <HI>Thomas Woodcock</HI> to have it to &s;urren|der or relea&s;e to <HI>John Stepkins,</HI> 1 Nov. 1613. which Serjeant <HI>Francis Bramp&s;ton</HI> &s;wears was the date of that Relea&s;e? And if <HI>Walthal</HI> and <HI>Woodcock</HI> had it to &s;urrender, and did &s;urrender it in 1613. to <HI>John Stepkins,</HI> how came <HI>Glover</HI> and <HI>Pru&s;on</HI> to have it again to &s;urrender in 1619? This is very &s;trange, if true. <HI>Note,</HI> The Relea&s;e dated in 1613. was produced when the following fifty &s;ix years Lea&s;e fir&s;t was in 1675. and the other Relea&s;e not till &s;ome years after, when di&s;covered, it was that <HI>Richard Glover</HI> was po&s;&s;e&s;t of that Land all the time between 1613. and 1620. &s;o that the fir&s;t Relea&s;e was not late enough to ju&s;tifie the making of the next Lea&s;e for fifty &s;ix years.</AB>
<AB TYPE="counterclaim"><LB><NOTE PLACE="marg">5 <HI>Augu&s;t</HI> 1620.</NOTE><HI>John Stepkins</HI> demi&s;es the Premi&s;&s;es in que&s;tion, <HI>inter alia,</HI> to <HI>Richard Glover</HI> for fifty &s;ix years, at a red Ro&s;e for the fir&s;t ten years, and after that, at <HI>20 <HI>l.</HI></HI> yearly payable to Mr. <HI>Stepkins,</HI> his Executors, and A&s;&s;ignes; and the Rent being &s;o re&s;erved, and not to his Heirs, the Council for Lady <HI>Ivy,</HI> &s;ays, It was not payable to his Heirs, and &s;o cea&s;ed, but that <HI>120 l.</HI> was paid for the fir&s;t &s;even years, to Lady <HI>Ivy</HI>'s Father, as did appear by <HI>Whitfield</HI> her Fathers Stewards Book of Accounts, which had been produced at a former Tryal, and al|lowed as Evidence, but was &s;ince burnt in the Fire at <HI>Wapping.</HI>
<LB>Sir <HI>John Bramp&s;ton</HI> &s;wore he believed 'twas his Fathers Hand that was &s;et as a Witne&s;s to it; and Serjeant <HI>Bramp&s;ton</HI> in his Depo&s;ition taken <HI>1675.</HI> to perpetuate his Te&s;timony, &s;wears &s;o too; and that about &s;ix or &s;even years before his Examination in <HI>1675.</HI> looking among Lady <HI>Ivy</HI>'s Writings, left with him by his Brother Sir <HI>John,</HI> who was Executor to his Father, he did find a Deed with the name <HI>Richard Glover</HI> &s;et thereto as a Party, but did not then read the &s;ame, but believes the Deed on which he
<PB N="7" REF="7"> was examined (being the &s;aid fifty &s;ix years Lea&s;e) was the &s;ame Deed he &s;o found, and on the Suit with <HI>Bateman,</HI> did deliver many Writings and Evidences to Lady <HI>Ivy,</HI> and advi&s;ed her to read them over, and that among them &s;he told him &s;he found this fifty &s;ix years Lea&s;e; and in her An&s;wer to Sir <HI>Robert Cotton</HI>'s Bill, put in again&s;t her, <HI>1675.</HI> &s;he al&s;o &s;wears &s;he &s;o found the &s;aid Lea&s;e in <HI>May 1675.</HI> and does acknowledge in that her &s;aid An&s;wer, that &s;he did not know of the &s;aid Lea&s;e, nor of the Rent thereon received.</AB>
<AB TYPE="rebuttal"><LB>Again&s;t the probability of the truth of this Lea&s;e,
<LB><HI>Note,</HI> Likene&s;s of Hands, and payment of Rent, no better proved than <HI>per contra,</HI> without any thing el&s;e, is but a &s;lender Te&s;timony to &s;upport a &s;u|&s;pected Deed, which this may de&s;erve to be, for the following Rea&s;ons.
<LB>'Tis not pretended 'twas known to Lady <HI>Ivy,</HI> till found by her, when wanted in 1675: and if it had been known,
<LB>What is &s;aid as an excu&s;e why the Rent was not paid, (being re&s;erved to the Le&s;&s;or, his Executors, and not Heirs) is of no weight; for it might have been helpt in Chancery. Be&s;ides, had that been the rea&s;on why the Rent was not asked nor paid, <HI>Note,</HI>
<LB><HI>Richard Glover</HI> (who Lady <HI>Ivy</HI> goes about to prove paid the fir&s;t &s;ix years Rent) would ne|ver have paid any to her Father <HI>John Stepkins,</HI> he being the Son of that <HI>John Stepkins,</HI> who is &s;up|po&s;ed to have lett this Lea&s;e in 1620, and died in 1624. &s;o that way no Rent had been due at all.
<LB><HI>Richard Glover</HI> in 1616. died, and by his Will gave &s;everal of his Children 500 <HI>l.</HI> apiece, and particularly <HI>Mary;</HI> and if the Money was not paid accordingly by <HI>Richard Glover</HI> his Son, who is &s;up|po&s;ed to have taken this Lea&s;e, he devi&s;es his <HI>Wap|ping</HI>-Lands
<PB N="7" REF="7"> over to his &s;aid Children, and <HI>Mary</HI>'s Portion being not paid, <HI>George Almery,</HI> her Hus|band, enters; and on payment of the &s;aid 500 <HI>l.</HI> in 1624. re&s;ettles (by Fine and Deed particularly naming the&s;e Lands) the &s;ame on <HI>Richard Glover</HI> again; who&s;e thus accepting a Fine, had been a forfeiting the Lea&s;e, had he held it by one at that time.
<LB>Lady <HI>Ivy</HI>'s Father's and Grandfather's Wills, e|numerating all their Lands to very &s;m<GAP DESC="illegible" RESP="UOM" EXTENT="1 chunk"> <GAP DESC="illegible" RESP="UOM" EXTENT="1 letter">arcels, take no <GAP DESC="illegible" RESP="UOM" EXTENT="1 chunk">ce at all of this Lea&s;e, nor of any Land in it comprized, but only as a Boundary to their own.</AB>
<AB TYPE="counterclaim"><LB>And yet as
<LB>A farther proof of this Lea&s;e (it having been &s;ometime &s;worn that one <HI>Duffett</HI> &s;aid, he was making a Writing he called <HI>Glover</HI>'s Lea&s;e about <HI>1671.</HI>)
<LB>Lady <HI>Ivy,</HI> to &s;hew 'twas known in <HI>1664.</HI> and if &s;o, could not be made in or about <HI>1671.</HI> does produce.
<LB>A Deed wherein the &s;aid Lea&s;e is recited, being a Conveyance (executed by Sir <HI>Tho|mas Ivy</HI> and his Lady, of the Inheri|tance of five Acres of Land on which <HI>King-&s;treet</HI> in <HI>Wapping</HI> is built, to <HI>Edward Burtbee</HI> and <HI>Edward Temple,</HI> in Tru&s;t to &s;ecure <HI>800 l.</HI> to Sir <HI>Thomas Ivy,</HI> by <HI>100 l.</HI> yearly, till Principal and Intere&s;t paid, with a Covenant to levy a Fine. And to prove this Deed, &s;he produced <HI>Edward Burtbee</HI> him&s;elf, who &s;wears very home to the matter, and &s;ays, he was Party to it, but the Witne&s;&s;es are all dead.
<LB>A Fine was levied to <HI>Burtbee</HI> and <HI>Tem|ple,</HI> of five Acres of Land in <HI>Stepney</HI> and <HI>Middle&s;ex.</HI>
<LB>And that under the Lea&s;e to <HI>Walthall</HI> and <HI>Woodcock</HI> for &s;ixty two years, and this Lea&s;e thus taken of <HI>John Stepkins</HI> by <HI>Richard Glover</HI> for fifty &s;ix years.
<LB>All the Po&s;&s;e&s;&s;ion of &s;uch as have claim|ed all along under him, has been.
<LB>Several Verdicts, and in favour of the foregoing Title, are by Lady <HI>Ivy</HI> produced; and as a very great Argument of the truth of her Deeds, is alledged the very great dif|ficulty of making &s;o many, as there mu&s;t have been made, if any there be in her Ca&s;e.</AB>
<AB TYPE="rebuttal"><LB><HI>Note,</HI> There was a Lea&s;e lett by <HI>Richard Glover</HI> to <HI>Aaron Williams</HI> of the five Acres, being part of the twelve Acres of Copyhold-Land, on which <HI>Kingstreet</HI> in <HI>Wapping</HI> is built, for fifty years (with Licen&s;e from the Lord of the Mannor to lett for &s;o long) from 1630. at 20 <HI>l.</HI> yearly Rent; 'twas a building-Lea&s;e, and &s;uch part of it as <HI>Aaron Wil|liams</HI> built not him&s;elf, he di&s;po&s;ed of to others. And as 'tis &s;omething hard to imagine that <HI>Richard Glover</HI> (who was a man of Repute) if he had but forty &s;ix years in it in 1630. &s;hould lett it for fifty years, &s;o 'tis very much harder to believe that <HI>Aaron Williams,</HI> (who was a great Builder in &s;everal places) and tho&s;e under him, &s;hould accept of a Lea&s;e (and build on it) for a longer term than <HI>Richard Glover</HI> could have lett, had he held it by this now produced Lea&s;e for fifty &s;ix years from 1620. which if true, could not have been but pub|lickly known at that time; which very Lea&s;e &s;o lett to <HI>Aaron Williams</HI> as afore&s;aid, Lady <HI>Ivy</HI> pur|cha&s;ed in 1659. and gave about 2000 <HI>l.</HI> for it, and &s;o got the po&s;&s;e&s;&s;ion of it, as &s;he in her own An&s;wer to Sir <HI>Robert Cotton</HI>'s Bill in 1676. does confe&s;s, and is a great Argument &s;he believed it a good Lea&s;e; and that 20 <HI>l.</HI> yearly Rent was paid to <HI>Bateman</HI> for it, is plain, if the An&s;wer of one <HI>Michael Old&s;worth</HI> (of whom Lady <HI>Ivy</HI> purcha&s;ed the &s;aid Lea&s;e) to a Bill put in again&s;t him by the Relations of one <HI>William Thomas</HI> (to whom <HI>Old&s;worth</HI> was Execu|tor, and &s;o came po&s;&s;e&s;t of this Lea&s;e) for an Ac|count of the E&s;tate of the &s;aid <HI>William Thomas,</HI> may be believed, as it mu&s;t in other ca&s;es, (though no Evidence in this, becau&s;e it being in another Cau&s;e, may not in this be read) That in the Ac|count &s;ays thus: Paid Sir <HI>Anthony Bateman</HI> Arrears of Rent at <HI>Wapping,</HI> 20 <HI>l. per ann.</HI> 150 <HI>l.</HI>
<LB>And the &s;aid Lady <HI>Ivy</HI> being &s;o in po&s;&s;e&s;&s;ion of the five Acres, on which <HI>King&s;treet</HI> is built, by ha|ving got <HI>Aaron Williams</HI> his Lea&s;e into her own hands, brought an Ejectment about 1675. again&s;t the Creditors of Sir <HI>Anthony Bateman,</HI> who then were po&s;&s;e&s;t of the other &s;eventeen Acres, and they claiming under a Bankrupt, who refu&s;ed to a&s;&s;i&s;t them, and knowing not how to defend their Title, and Lady <HI>Ivy</HI> having the good fortune to make tho&s;e Deeds again&s;t which &s;o much is &s;aid in this Paper, and e&s;pe|cially the fifty &s;ix years Lea&s;e from 1620, to be believed as true Deeds, &s;he got a Verdict and Judgment then for the &s;aid &s;eventeen Acres about 1676. and held the &s;ame till a Verdict was given again&s;t her in <HI>Ea&s;ter</HI>-Term 1686. for the whole twenty two Acres, upon the now Cre|ditors Title, &s;uch Evidence being then given, as made this fifty &s;ix years Lea&s;e, and other Deeds, not believed.</AB>
</DIV2>
<DIV2 TYPE="section">
<P>The Deed dated <HI>February</HI> 1664. &s;etling the Inheritance of the five Acres of Land, on which <HI>King-&s;treet</HI> in <HI>Wapping</HI> is built, on one <HI>Edward Burtbee</HI> and <HI>Edward Temple,</HI> for the &s;e|curing 800 <HI>l.</HI> by 100 <HI>l.</HI> yearly to Sir <HI>Thomas Ivy,</HI> in which the 56 years Lea&s;e is recited,
<PB N="8" REF="8"> &s;eems to have been made for the &s;ake of that very Recital, and cannot in rea&s;on be true: for, <HI>Note,</HI> Lady <HI>Ivy</HI> having purcha&s;ed <HI>Aaron Williams</HI> his Lea&s;e, as afore&s;aid, and that being in <HI>December</HI> 1664. mortgaged to <HI>Jo&s;eph Sabberton</HI> and <HI>Edward Simonds</HI> for 800 <HI>l.</HI> and Sir <HI>Tho|mas Ivy</HI> then offering to lay down that Money, &s;o he might have it &s;ecured him out of the &s;aid Lea&s;e, the &s;ame Lea&s;e was made over 26 <HI>Decemb.</HI> 1664. to <HI>Richard</HI> and <HI>John E&s;tcourt,</HI> and <HI>Thomas Nevil,</HI> who the 25th of <HI>February</HI> 1665. a&s;&s;igned the &s;ame to Sir <HI>Robert Killigrew,</HI> Sir <HI>William Salkeild,</HI> and <HI>Benjamin Thornburgh,</HI> new Tru&s;tees for that purpo&s;e: but Sir <HI>Thomas</HI> not receiving the Rents, and his 800 <HI>l.</HI> remaining unpaid, and he differing with his Lady in 1671. put in a Bill again&s;t her and Serjeant <HI>Bramp&s;ton,</HI> about this very bu&s;ine&s;s, charging the Serjeant with Confederacy with his Wife: and &s;etting out the whole matter of the Securi|ty made him of that Lea&s;e, complain <GAP DESC="illegible" RESP="UOM" EXTENT="1 word"> the ill u&s;age he had had, and de&s;ires relief, and yet &s;ays not one word of the Inheritance now pretended to be made over to <HI>Burtbee</HI> and <HI>Tem|ple</HI> for him, and to which Deed he him&s;elf, 'tis pretended, was Party. And Lady <HI>Ivy</HI> in her An&s;wer to the &s;aid Bill, takes only notice of the Lea&s;e by her Purcha&s;ed, and &s;o Mortgaged to <HI>Sabberton</HI> and <HI>Simonds,</HI> as afore&s;aid, and not one word of this Inheritance-Deed: Nor does a Bill exhibited again&s;t Sir <HI>Thomas Ivy</HI> in <HI>Feb.</HI> 1669. by Sir <HI>Robert Killigrew,</HI> Sir <HI>William Salkeild,</HI> and <HI>Benjamin Thornburgh,</HI> the Tru&s;tees by Lady <HI>Ivy</HI>'s direction, &s;etting out al&s;o this Security thus made of the Lea&s;e (therein named to be made by <HI>Richard Glover</HI> to <HI>Aaron Williams</HI> for fifty years from 1630.) for 800 <HI>l.</HI> by 100 <HI>l.</HI> yearly to Sir <HI>Thomas Ivy,</HI> nor Sir <HI>Thomas Ivy</HI>'s An&s;wer to it, (confe&s;&s;ing the &s;ecurity was &s;o made to him of the Lea&s;e) &s;ay any thing at all of this Inhe|ritance-Deed, nor take any notice of <HI>Edward Burtbee,</HI> but as one only who being authorized by the la&s;t-named Tru&s;tees, and Lady <HI>Ivy,</HI> to receive the Rents, did employ one <HI>Edward Temple,</HI> for &s;ome time, for that purpo&s;e, and that afterwards one <HI>Perrot</HI> was by Lady <HI>Ivy</HI> au|thorized and employed to receive tho&s;e Rents. So that 'tis &s;ence to believe that <HI>Edward Burtbee</HI> and <HI>Edward Temple</HI> were no otherwi&s;e (with the knowledge of Sir <HI>Thomas Ivy</HI>) concern'd in this matter, but as Rent-gatherers only in manner afore&s;aid: and non&s;ence it is to imagine there could be &s;uch an Inheritance-Deed made and a&s;&s;igned in Tru&s;t for Sir <HI>Thomas</HI> to <HI>Burtbee</HI> and <HI>Temple</HI> at that time, and no notice in that Controver&s;ie be taken of it at all, con&s;idering al&s;o that that Lea&s;e was at that time within nine years of expiring, and al&s;o not worth any thing, had the fifty &s;ix years Lea&s;e been true.</P>
<P>And farther, to demon&s;trate that it cannot be with rea&s;on believed that the fifty &s;ix years Lea&s;e from 1620. could be recited in a Deed made in 1664 that was peru&s;ed by Serjeant <HI>Bramp&s;ton</HI> and he a Witne&s;s, and Lady <HI>Ivy</HI> a Party to it: <HI>Note,</HI> Serjeant <HI>Bramp&s;ton,</HI> when examined for Lady <HI>Ivy</HI> in this Cau&s;e in 1675. to perpetuate his Te&s;timony, being in the fourth Interrogatory asked, When and how long it was &s;ince he FIRST &s;aw the Counterpart of the Lea&s;e (explained to be this fifty &s;ix years Lea&s;e in the &s;econd Interro|gatory) and where and among who&s;e Evidences, Papers, and Writings, he did FIRST &s;ee the &s;ame; in an&s;wer depo&s;eth, That having &s;everal Boxes and Bags of Writings to him delivered by his Brother Sir <HI>John,</HI> that were in the po&s;&s;e&s;&s;ion of Sir <HI>John Bramp&s;ton</HI> his Fa|ther, at the time of his death, to be by him kept, he was de&s;ired by one Sir <HI>Charles Stepkins,</HI> about &s;ix or &s;even years &s;ince, to &s;earch among the &s;aid Writings for the Counterpart of a Lea&s;e made to one <HI>Bourne;</HI> and that upon this Deponents THEN &s;earching, he did find a Deed with the name <HI>Richard Glover,</HI> as a Party &s;et to it; but &s;aith, he did not THEN read the &s;ame, and that the&s;e Bags and Boxes of Writings, he after delivered to Lady <HI>Ivy,</HI> and among them &s;he told him &s;he found this Lea&s;e.</P>
<P>Now if Serjeant <HI>Bramp&s;ton</HI> &s;wears true, that the FIRST time he found (which in common Speech is as much as to &s;ay he knew not of it before) a Deed under <HI>Glover</HI>'s hand, (which might well be the Lea&s;e lett by <HI>Richard Glover</HI> to <HI>Aaron Williams,</HI> which Lady <HI>Ivy</HI> had purcha&s;ed) were but &s;ix or &s;even years before 1675. how then was it po&s;&s;ible that it could be (by him) for &s;o <HI>Burtbee</HI> &s;wore 'twas) recited in a Deed made in 1664? And had it been &s;o recited as now 'tis pretended it was, in a Deed made in 1664. to which Lady <HI>Ivy</HI> was Party, it mu&s;t have been known to her &s;elf; which in her An&s;wer to Sir <HI>Ro|bert Cotton</HI>'s Bill, &s;he &s;wears it was not, but that it was by her found in <HI>May</HI> 1675. in an old Bag of Writings. And Serjeant <HI>Bramp&s;ton</HI>'s Depo&s;ition al&s;o &s;ays, That &s;he at that time told him that &s;he did find it &s;o; &s;o that it is not hard to believe this Deed (never produ|ced till <HI>Ea&s;ter</HI>-Term 1686.) was made for the purpo&s;e afore&s;aid, &s;ince to &s;upport the truth of this Deed, there is nothing more than barely the Oath of one <HI>Edward Burtbee,</HI> a man well known about Town, and that has been all a long employed by the Lady <HI>Ivy;</HI> and &s;o not unlikely to have been in the Secret.</P>
<P>For the Fine, if the Deed of U&s;es be not true, it may be of any other five Acres: But, <HI>Note,</HI> 'twas Levied two years after 1664. Ju&s;t about the time that Sir <HI>Anthony Bateman</HI> fail|ed, and when Lady <HI>Ivy</HI> &s;et up to Claim the Inheritance of it, nor is it without &s;ome &s;u&s;pi|cion of having been unduly levied (it may be) by pa&s;&s;ing the Offices without the knowledge of Sir <HI>Tho. Ivy,</HI> and Lord Chief Ju&s;tice, the Roll where the Caption of it, to which the Lord
<PB N="9" REF="8"> Chief Ju&s;tices Hand &s;hould be in the <HI>Cu&s;tos Bremium</HI> Office, being lo&s;t. And if that Fine was really levied by Sir <HI>Thomas Ivy,</HI> which is &s;till to be doubted, for the rea&s;on afore&s;aid, 'tis not however to be wondred at much, con&s;idering that he had covenanted to do any Act with the Land in that Lea&s;e, his Lady &s;hould de&s;ire, &s;o it might be no prejudice to the pay|ment of his 800 <HI>l.</HI> as afore&s;aid. And it may be he was made believe at that time, that it was her Inheritance by being &s;howed the Deed of the 12 <HI>Nov.</HI> 5 and 6 <HI>Ph.</HI> and <HI>Mary,</HI> which was before that time made, and if any Deed there was made to <HI>Edward Burtbee</HI> and <HI>Edward Temple</HI> to lead the u&s;e of this Fine of five Acres, 'tis plain it could not be a Deed dated in <HI>Fe|bruary</HI> 1664. reciting this fifty &s;ix years Lea&s;e for the rea&s;ons afore&s;aid; but mu&s;t have been &s;ome other Deed, after that time made and de&s;igned as this Fine &s;e<GAP DESC="illegible" RESP="UOM" EXTENT="1 chunk"> <GAP DESC="illegible" RESP="UOM" EXTENT="1 word"> have been in future times to make out &s;ome Colourable T<GAP DESC="illegible" RESP="UOM" EXTENT="1 chunk"> to the <GAP DESC="illegible" RESP="UOM" EXTENT="1 span"> <HI><GAP DESC="illegible" RESP="UOM" EXTENT="1 letter">vy</HI> held only by <HI>Aaron Williams</HI> his Lea&s;e, that <GAP DESC="illegible" RESP="UOM" EXTENT="2 letters">pired at <GAP DESC="illegible" RESP="UOM" EXTENT="1 span"> 1681. And that 'twa privately done, is plain: for neither the Fine nor the Deed was ever in any Tryal produced, till <HI>Ea&s;ter</HI>-Term, 1686.</P>
<P>All that is to be &s;aid to the Verdicts is, They were given at times when the Creditors Title, and that to <HI>Pru&s;on</HI>'s I&s;land, were not well made under&s;tood to the Court and Jury, and when Lady <HI>Ivy</HI>'s Deeds were believed.</P>
<P>As for the difficulty of making of Deeds, a great many may as well be imagined to be made, as one &s;ingle Deed, where the ingenuity of the party concerned, and the nature of the Title and place, afford good materials for it. And</P>
<P>The Reader is now de&s;ired to take Notice,</P>
<P>That <HI>Wapping</HI>-Mar&s;h was one hundred and thirty Acres drowned Land in <HI>Henry</HI> the 8th's time, undertook to be Drained by one <HI>Vanderdelfe,</HI> and &s;o &s;etled by Parliament, that when Drained, it &s;hould be equally divided 'twixt the Proprietors and <HI>Richard Hill,</HI> who had bought <HI>Vanderdelfe</HI>'s half. And</P>
<P>That no Divi&s;ion (though undoubtedly one there was (it may be among them&s;elves) made) is now to be found on Record: And <HI>Ja&s;per Hill,</HI> 3 <HI>Eliz.</HI> by Fine and Recovery ha|ving &s;old to <HI>Macheline</HI> and <HI>John Stepkins,</HI> 20 Acres of Land, and 100 Acres of Mar&s;h in <HI>Stepney</HI> (that being the fir&s;t Sale on Record.) 'Tis in the power of Lady <HI>Ivy</HI> (as Heir of <HI>Stepkins</HI>) to Claim any part of the Mar&s;h by alledging, 'twas part of what her Ance&s;tors purcha&s;ed; if to an&s;wer the Po&s;&s;e&s;&s;ion, there can any way Lea&s;e be &s;e<GAP DESC="illegible" RESP="UOM" EXTENT="1 chunk"> and by <GAP DESC="illegible" RESP="UOM" EXTENT="1 word"> Lady <GAP DESC="illegible" RESP="UOM" EXTENT="1 span"> onely, in finding <GAP DESC="illegible" RESP="UOM" EXTENT="1 word"> Lea&s;es, since long Di&s;puted have been <GAP DESC="illegible" RESP="UOM" EXTENT="1 span"> Prop<GAP DESC="illegible" RESP="UOM" EXTENT="2 letters">etors (no Divi&s;ion appearing) being able to make no Title, unle&s;s to the Copyhold, before that pur|cha&s;ed by <HI>Stepkins,</HI> 3 <HI>Eliz.</HI> By &s;uch Lea&s;e &s;he may claim any parcel &s;he will, though the Owners thereof have had it ever &s;ince the Draining thereof; which could not be done in a|nother place, and makes it much ea&s;ier to have been done, than it can be imagined here.</P>
<P>And to remember, That</P>
<P>The Title by which the Creditors claim the Ten Acres of Free-hold, and Twelve Acres of Copy-hold Land, and whereby the Heirs of <HI>Whichcot</HI> do claim <HI>Pru&s;on</HI>'s I&s;land, and under which tho&s;e Lands were all quietly held and enjoyed, till after Sir <HI>Anthony Bateman</HI> failed, is, by Copies of Court Roll, and Deeds on Record, again&s;t the truth of which there has never yet been, nor ever can be the lea&s;t &s;ort of Pretence; And that</P>
<P>The Title whereby Lady <HI>Ivy</HI> Claims in particular any of the afore&s;aid Lands, and where|by &s;he both Got and does Hold the &s;ame, is by Deeds, not only not on Record, but mo&s;t of them &s;uch, as fir&s;t have been Lo&s;t, and then Found, and that are lyable to more Exceptions by many, then are herein before expre&s;t, which will be made u&s;e of again&s;t them when oc|ca&s;ion &s;hall &s;erve.</P>
</DIV2>
<TRAILER>FINIS.</TRAILER>
</DIV1>
</BODY>
<BACK>
<DIV1 TYPE="errata">
<HEAD>ERRATA.</HEAD>
<P><HI>Page</HI> 2 <HI>for</HI> 20 Eliz. 1576. <HI>read</HI> 1578. <HI>Pag.</HI> 6. 25 <HI>line, for</HI> 7 <HI>read</HI> 6 <HI>years.</HI></P>
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</DIV1>
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</TEXT>
</EEBO>
</ETS>
