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Latin: not yet transcribed and translated.
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Interrogations to be ministered for John Jones playntiffe to examine his
Witnesses uppon ag[ainst] Mathewe Price and Margarett his wife deffen[dants]
Doe you knowe the said parties playntiffe and deffen[dants] declare etc
Did you know Edward Morgan late of Langattock Lyngoode in the Counte of Monmoth an Attorney att Lawe And doe you know of any Bill or specialty which the said deffendant Margarett when she was sole togeather with the pl[ain]t[iff] entered into, sealed and delivered unto the said Edward Morgan in his life time; Whither did the pl[ain]t[iff] seale the saide Bill as suretie for and with the said def[endan]t Margarett and whose debt realy was the same and what was the penalty of the said Bill and howe much was the inst-- debt therein contained declare the truth of yo[ur] knowledge herein att large and the reasons howe yo[u] know [th]e same and the circumstances thereof
Do you know to to[ur] own knowledge or have you hard what forme or formes of money the said pl[ain]t[iff] paid to discharge the said debt and to take upp the said Bill and to whom and in what maner and howe much was the said pl[ain]t[iff] dampnified by reason thereof declare yo[ur] knowledge att large
What other thinge or matter can you depose in this matter materially effetuall for the pl[ain]t[iff] ag[ainst] [th]e deffend[ants] declare
Will[iam] Price
David Morgan
Rich[ard] Lewiss
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Depos[it]ion of Witness sworn [and] Examined taken att the dwelling house of John Lewis of the
towne of Bergavenny in the Countie of Monmoth Inn--- uppon the twelvth day of Januarie
Anno D[omin]i 1675 In a case depending all Issue in his Ma[jes]ties Courte of Exchequer Chamber
Betweene John Jones gent Complayn[an]t And Mathew Price and Margarett his wife defendants
this on the said Complayn[an]ts behalfe before William Price Gent David Morgan Gent and Richard
Lewis gent Comissoners by vertue of his Ma[jes]ties Comission out of the said Courte unto
them and untoRowland Jennings in that behalfe director
John Parry of the p[ar]ish of Aberystuth in the Countie of Monmoth gent Aged seventy [and] five years or thereabouts a Witnes produced sworn and Examined on the said Comp[lainan]ts behalf Deposeth and sayth as followeth;
To the First Interrogatory this deponent sayth, that he knoweth both p[ar]ties Complaynant and defendants hath knowne the Compl[ainan]t and the Defendant Margarett for aboute thirty yeares now last past
To the second Interrogatory this Deponent sayth, that it fortuned that this Deponent sometyme before the Decease of Edward Morgan in that Interrogatory named (whom this Deponent then well knew) Came to the Chamber of the said Edward Morgan About ^his^ this deponents own buisnes, att the dwelling house of one Phillipp Morgan of the Towne of Bergavenny in the County of Monmoth where the defendant Margarett (who was then sole and unmarried) Requested the said Edward Morgan (being an Attorney att Lawe) to prosecute and sollicite a suite att Lawe for her the said Margarett uppon an Action of Debt upon a specialty against one ^Mr^ Thomas Williams of Caerlyon And that thereupon the said Edward Morgan promised to undertake the prosecution of the said suite (as Attorney att Lawe) if shee the said Margaret would then give to him the said Edward Morgan security for the payment of Eight Pounds towards the Charges of the prosecution of the said suite; And that thereuppun the said defendant Margarett went foorth (to the Best remembrance of this deponent) and w[ith]in a litle syane afterwards came in to the s[ai]d Chamber w[ith] the Complainant and one Mathewe Prichard (whoo ^was^ since married to the said Margarett) And that then the said defendant Margaret together w[ith] the said Complaynant John Jones as surety for the said Margarett as this deponent then app[re]hended and verily beleeveth did in the presence of this deponente signe and seale a Bill for the secure m[one]y & paying of Eight Pounds to the said Edward Morgan; And this deponent further sayeth and deposeth that the said Edward Morgan did not then desire this deponent to subscribe his name as a witness to the Executing of the said speciallty, butt that some other p[er]sons being then in the said Chamber did subscribe their names as witnesses to the specialty in the p[re]sence of this deponent; And further he deposeth not;
Sheldon Powell of Whyte Castle in the p[aris]h of Lantillio Gressenny [in the] County of Monmoth gent Ag[e]d Fiftye [and] six years or thereabouts, sworne and Examined on the Compl[ainan]ts behalfe; Deposeth as followeth;
(1 to the First Interrogattory this deponent sayth, that he knoweth the Compl[ainan]t John Jones, And doth beleeve that he hath seene the deffendants;
(2 (3 to the second and Third Interrrogatory he sayth, that he knew Edward Morgan in the Interogatorry named, And sayth that after his decease; aboute the yeare 1658 there was a bill of the penalty of Twenty Pounds (Dated about August 1655) for paym[en]t of Eight Pounds about October then following; written w[ith] the handwriteing of the said Edward w[ith] the Interlineation therein (as this Deponent Beleveth) who Practized as an Attorney) And was in greate practice) deliv[er]ed ^to^ the deponent to be putt in suite against the Complaynant and one Margaret William, by Charles Morgan gent Executor of the s[ai]d Edward Morgan, And a Judgm[en]t was obteined against the said John Jones uppon the said Bill, And doth beleve there was Tenn Pounds Payd by the Complayn[an]t Jones unto the said Charles Morgan for that this deponent sayth — — — for the said sum[m]e written by the said Charles Morgan (as this deponent beleiveth) And this deponent sayth further that he retained Forty shillings in p[ar]te of the Charges of the s[ai]d suite; And ^this^ Deponent doth not well remember whether the said Margarett was married to one Mathewe Prichard the Complayn[an]ts brother att the tyme of the suite Concerned uppon the said Bill or not And if married this deponent beleiveth, that there was a prosecution against them or one of them uppon the s[ai]d Bill; And this deponent further sayth that John Jones was First named in the Bill And his name putt last — — — (as surety use to doe) but whether the said John Jones seale as surety for her the said Margarett this depon[en]t — — — but sayeth the marke of one named Margarett William was to the First seale, And sayeth that the Complain[an]t very much damniffied, And Expended much money aboute the moneys payd uppon the said Bill;
Charles Morgan of the p[ar]ish of Langattocke Llingoed in the County of Monmoth gent Aged Fifty or thereabouts, a witnes p[ro]duced sworne [and] Examined on the Complain[an]ts behalfe deposeth & sayeth
(1 To the First Interrogatory this depon[en]t sayeth, that he knoweth the Complain[an]t John Jones & Margarett? heretofore the wife of Mathewe Prichard;
(2 (3 To the Second and Third Interrogatorys this depon[en]t sayeth, that he did know Edward Morgan in the — — —
(continued on reverse)
Named in his life tyme, being this depon[en]ts father [and] being after an Attorney att Lawe, And that to — — —
sole Executor of the Last will and Testament of the said Edward Morgan, did after the decease of the said Edward — — —
specialty wherein the Complain[an]t John Jones, [and] the deffend[an]t Margarett while she was sole (as this deponent — — —
bownd unto the said Edward in the pe[n]alty of Twenty Pounds for the paym[en]t of Tenn pounds (to the best Remembrance — — —
deponent) in suite against the said Complain[an]t and the said deffendant Margaret; upon which suite the said John Jones — — —
hereafter, And Payd unto this deponent the sume of Tenn Pounds in satisfa[cti]on of the said debt as surety for the said
Margarett; as this deponent then app[re]hended, And after us he was then Informed by the said John Jones And this deponent
further sayeth that he this deponent Could not finde in any of his said fathers books that the said John Jones — — —
in any ways Indebted unto the said Edward Morgan this depon[en]ts father; for any Charges of lawe uppon — — —
(to the best of this deponents knowledge) And that it app[ear]eth by the said books that the said defendant Margarett was — — —
unto the said Edward Morgan, Aswell for one suite att Lawe against one Thomas Williams, as after for one other suite against
Another p[er]son whose name this depone[n]t doth not very well remember att p[re]sent; And this deponent further sayeth that — — —
Bill or specialty (to the best of this deponents remembrance) Did beare date in or aboute the month of August in the yeare
of our Lord God one Thousand six hundred Fifty and Five; And this deponent further sayeth that in or about the — — —
day of February in the yeare of our Lord God one Thousand six hundred Fifty & Nine, he this deponent delivered upp the said — — —
or specialty, [and] Gave a receipte w[ith] his this deponents owne handwriteing unto the said Complainant for the said Tenn Pounds
soe received by hin, this deponent, from the said Complainant in satisfa[c]tion of the debt due by the said Bill or specialty
And that the writeing purporting a receipte nowe showed to this deponent att the tyme of his Examina[t]ion in the proper
handwriteing of him this deponent;
Will[iam] Price
David Morgan
Rich[ard] Lewis
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Interrogations to be Administered to witnesses to be p[ro]duced sworn and Examined
on the parte and behalfe of Mathewe Prichard Margarett his wife deffend[an]ts
at the suite of John Jones jont complaynant
In primis doe you know the parties complaynants and deffend[an]ts and did you know the deffend[an]t Margarett while shee was sole and before shee was married And did you know Mathew Prichard former husband of the said Margarett and Edward Morgan gent one of the Attorneys of his majesties Court of Common pleas or eyther and which of them in their severall life tyme
2) Item doe you know beleeve or have heard ^that^ the deffend[an]t Margarett before shee was married did employ the said Edward Morgan to be her Attorney and whem to p[ro]secute a suite against Thomas Williams Esquier upon a bond of twentie pounds for the payment of tenn pounds how longe was the same in suite and how was it Ended And how much money was paid by the said Williams in dischardge of the said suite and bond and all Examin[ati]ons there upon, and to whome was the penalty of the said bond and Costs of suite paid the said Edward Morgan and how much or what sum[m]e of money was paid or delivered by the said Edward Morgan to the said Margarett in lien and full satisfaction of the said debtes and all Interrest due for the same from the said Williams did shee soe receave it in satisfaction for the said debte and interrest and what money had shee for[war]dly paid the said Edward Morgan towards his Charges in that suite, And what words were used or confessed by the said Morgan and deffendant Margarett at the tyme when shee receaved satisfaction ^as aforesaid^ did the said Morgan then or at any tyme after acknowledge that he had receaved from her and detayned in his hand as much of the money paid him by the said Williams as dis satisfie all Charges at Law due to the said Morgan from the said Margarett on and about what hee then paid her the said Margarett And did he then freely and willingly discharge the said Margarett from Charges at Law and of her debts due to him from her was hee the said Edward Morgan retayned or imployed by the said Margarett to p[ro]secute any of her suite or suits for her or in her name against any other p[er]son or p[er]sons whatsoever (or if shee had, was not the said Margarett then and ever since able to pay her owne debts declare what you know beleeve or have heard heerein with the reasons and Circumstances thereof at Lardge and the tymes of retayning and sevrall payments above said or Eyther of them as neere as you can remember
3) Item did you at any tyme or tymes where when and upon what amount or fee in the Complaynants or any other one, and whose hands or possession the Bill or writting obligation which the Compl[ainan]t doeth by his now Bill of Complaint or did by sevrall or any other suite or suits pretend that he had sealed for the debt of the said Margarett when she was sole and bore the name of Margarett William to the said Edward Morgan of twentie pounds or any other and what sum[m]e for the payment of Eight pounds to him the said Edward, whose hand writting was the said Bill obligatorie, was the name or marke of Margarett William subscribed to the same or if it were was ^it^ the name or marke of the now deffend[an]t Margarett was there any more than one seale to it, was it in the singular number of John Jones doe acknowleg my selfe to be indebted to Edward Morgen gent etc and soe all along and not in the plural wee, was it for his owne p[ro]per debt, was the name Margarett William [word crossed out] interlyned, was it the same hand writting as the rest of the said Bill or of any parte of it were you a wittnes to the same and did you see it sealed and delivered and by whome and did you subscribe your name or marke as a wittnes thereunto, where when and whoo was there in place besides your selfe declare
4) Item doe you know beleeve or have you heard that the said Edward Morgan in his life tyme and
before the said seaventeenth day of August 1655 (upon which day the said p[re]tended writting
obligatory was sealed) did often and frequently deale as an Attorney for the Compl[ainan]t was the said
Complaynant at that tyme or before indebted to the said Morgan And was hee the said Comp[lainan]t
after the decease of the said Edward Morgan sued by the said Morgans Executor and for what was
it for any debts of the deffend[an]t Margarett or Eyther of her husbands the said Mathew Prichard
or now deffendant Mathew was shee they or Eyther of them named in the said suite or had
shee or they any notice or knowledge of it, were they or one and which of them arrested
for the same or any way molested or sued for the same was there any acquittance or receipt
and by whom given the Compl[ainan]t upon payment of what hee owed the Executor aforesaid
was the name Margarett William inserted in the said receipt or acquittance and by whome
and upon whose request or p[er]swasions did the Compl[ainan]t desire it should be soe did the
debte that the Compl[ainan]t was sued for as aforesaid any way appe[ar] to be, or could it be thought
to Concerne the said Margarett or Eyther of her husbands by the Bill aforesaid or by any
other note or notes declare etc.
5) Item was there since the said seaventeenth day of August 1655 any account or accounts between theCompl[ainan]t and defend[an]t Margarett and Eyther or which of her said husbands And when and how long after appe[ar] upon such account that the Compl[ainan]t was indebted to the said Margarett and was he sued for the same, how much was the sum[m]e he owed her, and did hee pay how did the Compl[ainan]t upon any such account suite or payment menconed the said bill obligatorie or his being suertie for her or desier her to disingage him therefrom, and how long after was any suite secured toucheing the said obligatory now in acton or ment[i]on made of the same, did the said Compl[ainan]t since the said p[re]tended bill hath bine sett on foote and in action allwayes or often say that he was suerty for the said Margarett to the said Edward Morgan for the Chardges at Law remaineing due to him the said Edward in the said suite by the said Margarett against the said Thomas Williams Esq[uier] only and noe other
6) Item were you p[re]sent at any Comission or Comissions yssued foorth of the Court of his ma[jes]t[y]s Councell in the marches of Wales as Con[cillor] or Clerke was the Cause of acton upon the same p[re]tended bill obligatorie as now it is were one Edward Roberts gent and Joan William Thomas with or Eyther of them duely upon the holy Evangelists sworen as wittnesse upon the said Comission and duely and Carefully Examined to Interrogatories upon the defend[an]t Margaretts behalfe what did Each of them sevrally then and there depose toucheing the matter then and now in question, and are they both since deceased declare
7) Item were you at any tyme and when sum[m]oned by the shireefe of the County of Monmoth or his Bayliffe to appe[ar] before the said shiriffe to Enquire upon any writt or writts to him directed what damage the said then and now Complainant sustayned by reasone of his being bond for the deffendant Margarett to the said Edward Morgan, as hee then did by that acton and still doth p[re]tend, what Evidence did the then and now plaintiffe p[ro]duce at such Enquiry, was it sufficient to Convince you and your fellow jurors that he was any way dampnified or did it any way looke like a Combinat[i]on between the Compl[ainan]t and the Executor of the said Morgan, was there any Evidence p[ro]duced that might make you beleeve that he e[ithe]r was security or e[ithe]r paid any money for the deffendant Margarett declare
8) Item are the papers or writtings now showed you at the tyme of this your Examinay[tio]n
true Coppies of the record or records ^any - - - in^ any proceedings in the said Cause and upon the said
p[re]tended p[ro]mise or bill obligatorie now p[re]tended betweene the said parties or Eyther of them or betweene
the Complainant and the said Mathew Prichard former husband of the said Margarett Concerning
the said p[re]tended Bill
Will[iam] Price
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William Lewis of the towne of Bergavenny in the County of Monmoth gent aged Fiftie yeares or
thereabouts a wittnes p[ro]duced sworen and Examined on the deffend[an]ts behalfe deposeth as followeth
To the first Inter[rogatories] this deponent sayeth that hee knoweth the parties Comp[lainan]t and deffend[an]ts and did know the deffend[an]t Margarett when shee was sole and did alsoe knowe Mathew Prichard and Edward Morgan in that Interr[ogatory] named in their Lives tyme
To the second and all the rest of the Inter[rogatories] this dep[onen]t sayeth that Mr Edward Morgan was imployed as an attorney by the deffend[an]t Margarett when shee was sole and unmaried to sue one Mr Thomas Williams upon one bond of the penalty of twentie pounds for the paymen of tenn pounds with the Interrest And further sayeth that the said bond after it was put in suite was recorded in Com[m]on Lawe And this deponent further sayeth that the deffend[an]t Margarett together with her form[er] husband Mathew Prichard in his life tyme about thirteene yeares last past were sued by the playntiffe at Com[m]on Law and for want of putting in a declarat[i]on the said deffend[an]ts were dismissed And since that tyme the said deffend[an]ts was sued at the Counsell of Marches and after yssue joyned and sevrall witnesses Examined of both sides the plaintiffe was dissmissed there as this dep[onen]t doeth remember And this deponent sayeth that the plaintiffe com[m]enced his second suite at the same court against the said deffend[an]ts and verylie beleeveth of meere purpose to vex the said deffend[an]ts in putting them to greate chardge and Expenses and after witnesses were Examined of both sides the plaintiffe did not p[ro]ceede there but sayeth that since the matterial witnesses which were Examined upon the deffend[an]ts behalfe were dead and buried the pl[ain]t[iff] comenced this suite now depending And this deponent sayeth that at the sevrall comissions yssued out of the marches of Wales this deponent was a Clerke for the deffend[an]ts and one Mr Edward Roberts was in his life tyme sworen and Examined upon the deffend[an]ts behalfe And did depose upon the Evangelists that hee was an Attorney for the said Thomas Williams Esq[uie]r And further deposeth that the deffendant Margarett did obtayne a judgement against the said Williams of two and twentie pownds which was paid unto the said Mr Morgan the plaintiffs Attorney And further sayeth that one Joan William Thomas in her life tyme was likewise sworen and Examined upon the behalfe of the said deffend[an]ts And did depose that shee went with the deffend[an]t Margarett unto the dwelling house of the said Mr Morgan the Attorney for to see her receave the said money which he receaved from the said Williams to her use and that the said Mr Morgan did account and pay the said deffend[an]t Margarett of the said two and twentie pownds which hee did then acknowledge to have receaved to the use of her the said deffend[an]t but seaven pownds or there abouts and that the rest belonged unto him in satisfac[t]ion to his disbursments or Chardges at law or words to such Effecte And this dep[onen]t further sayeth that the pl[ain]t[iff] at the first Com[m]ission did p[ro]duce a finale scripe of paper in the nature of a penall bill and as farr as this dep[onen]t can well remember the said pl[ain]t[iff] John Jones was first named in the said bill and the worde Margarett William interlyned and one seale fixed to it but at the second Com[m]ission the said pl[ain]t[iff] would not p[ro]duce the same bill unto the said Court to be Indorsed And this deponent further sayeth that the said pl[ain]t[iff surruptitiosly got an Inquirie for this p[re]tended Bill and this deponent was sum[m]oned by the Shireeffs Bayliffe to be a Juror upon that Inquiry and hee together with his fellow Jurrors Could not have any Evidence to find that the said plaintiffe was in anywise dampnified and desired him to p[ro]duce the said Bill unto the Jury and then Impanelled but would not And this dep[onen]t further sayeth that hee heard that he was sued by one Mr Charles Morgan and that the said Mr Morgan obtayned a Judgement against the said pl[ain]t[iff] for want of a plea And sayeth that since this last suitenof law was Com[m]enced by the pl[ain]t[iff] against the said deffendants this deponent was desired by the deffend[an]t Mathew Price to aske the pl[ain]t[iff] that if hee Could p[ro]duce any honest p[er]sone to make it appe[ar] that hee at any tyme did give notice Eyther of the said deffendants that he was sued or molested for being a suertie for the said deffend[an]t Margarett as he alleadgeth that he the said Mathew was and is willing to subnitt to his mercie and the said pl[ain]t[iff] said in Answere that hee had no reasone to doe soe And this dep[onen]t further sayeth that at the tyme he the said pl[ain]t[iff] was sued by the said Mr Charles Morgan that the deffend[an]ts were able and [sic] to pay a greate deale of money more than was demanded by the said Mr Morgan from the said pl[ain]t[iff] And sayeth and doeth verylie beleeve that the deffend[an]t Margarett now did imploy the said Mr Morgan but in that busines against Mr William And further sayeth that the Coppies of pleadings and the depositions now showed unto him are true Coppies of the originall Records And the reasone of his knowledge is because they are his owne hand writting
Richard Prichard of the towne of Bergavenny in the County of Monmoth gent Aged sixtie five yeares or thereabouts a witness p[ro]duced sworen and Examined on the deffend[ant]s behalfe deposeth as followeth
To the first Inter[rogatory] this dep[onen]t sayeth that hee knoweth the p[ar]ties pl[aintif]f and deffend[an]t and did know the def[endan]t Margarett when shee was solo and did know Mathew Prichard the said Margaretts former husband in his life ^time and did know Edward Morgan in the Inter[rogatory] named in his life tyme
To the second Inter[rogatory] this dep[onen]t sayeth that the deffend[an]t Margarett when shee was sole and unmaried
desired this deponent to goo with her and Mathew Prichard (whoe not long after was intermaried
to the said Margarett) to the dwelling house of Mr Edward Morgan an Attorney Esq[uie]r then dealed
for the said Margarett in Com[m]on law against one Mr Thomas Williams of Caerlion for a debt
of twentie pounds by bond Condit[i]oned for the payment of tenn pounds and Interest And
upon the said Margaretts desier and request this dep[onen]t did goo with them to the said Mr Morgans
house and there the said Margarett demanded of the said Mr Morgan the money that he had
secured for her the said Margarett from the said Mr Williams And thereupon the said Mr
Morgan did offer or p[ro]duce to the deffend[an]t Margarett about five pounds which the said deffend[an] refused
askeing him was that all that shee should have from her bond whoe made Answere that all
the kost went in Chardges in Recordie thereof And thereupon the said Margarett then wished
him to keepe it all and there left them and demanded her bond, which was then delived to her, by
the said Mr Morgan And thenne departed without the rewaveing of any peny thereof at the
tyme And further sayeth that the said Margarett was then and is yet well able to pay her
debts
Anthony Jenkins of the parishe of Llanwen[ar]th in the County of Monmoth gent aged fiftie three yeares or thereabouts a witness p[ro]duced sworen and Examined on the deffend[an]ts behalfe deposeth as followeth
To the first Inter[rogatory] this dep[onen]t sayeth that he knowes and did know all the parties in that Inter[rogatory] named
To the seaventh Inter[rogatory] this dep[onen]t sayeth that he was aboute foure or five yeares last past sum[m]ned
by the then Shiriffes Bayliffe to appe[ar] in a Jury to Enquire for damages for the now Compl[ainan]t
against the deffend[an]ts whoe appe[are]d with others his then fellowe Jurors, and were sworen
and impanelled And sayeth alsoe that hee this dep[oen]t nor any his fellow Jurors
had any Evidence then given them at all soe that there was noething that C— — —
— — —