The CASE of William Eyre Esq; concerning his Right to the half Barony of Shelelah, and Castle of Carnow in Ireland, now in the possession of the Right Honourable William Earl of Strafford, truly stated, and humbly presented to the Kings most Excellent Majesty, and both Houses of Parliament.  
BY Inquisition upon commission granted, and Jury chosen, and legally executed at Bray, Anno 1636. which Commission was returned, with a Copy of a Lease of 200 years, and old Mr. Chambres' Will, verbatim upon Record; by which it doth appear, that Calcot Chambre Esq; being seized in Fee of the said half Barony of Shelelah, and Castle of Carnow, with the Appurtenances thereunto belonging, in the County of Wicklow in the Kingdom of Ireland, containing of Arable Land, Pasture, Meadow, and Wood Lands, about 60000 Acres, fearing the profuseness of the Son, did, 1629. make a Lease of the same to James Tines, Nathaniel Fines, and John Crew, Esquires, for 200 years, without Impeachment of Waste, in Trust, for payment of his Debts and Legacies, and afterwards to such uses as he should declare by any further Deed, or by his last Will, and in default of such Declaration, to the use of his own right Heirs, with power to revoke it, but never did, therefore the Lease remains still in force.  
That the said Calcot Chambre, Anno 1635. made his last Will, bequeathing several Legacies, and gave all his said Lands, and likewise all his Goods and Chattels to his Son Calcot Chambre, whom he also made his sole Executor, and died owing several sums of Money.  
After whose decease, the said trusties possessed themselves of the premises, and agreed to let a Lease thereof to one Sandford for three years, for payment of the deceaseds Debts and Legacies, and to allow young Chambre 300 l. per annum for those three years, and then to account and deliver up the Estate to him, the said Sandford being one of the principal Creditors and Legatees.  
But Thomas late Earl of Strafford, than Lord Deputy of Ireland, being by some ill persons put upon coveting this Estate, (which was and is as considerable as most in that Kingdom) prevented the trusties in these their honest intentions, and also got the same into his own hands (or in Trust for him) by the means and practices following.  
First, The aforesaid young Chambre being come to Dublin with his Wife to take Shipping for England, to live with his Father in Law Esquire Leicester in Cheshire, till the aforesaid three years were expired, was by the subtlety of the Earl of strafford's Agents, (as an introduction to their great design) persuaded not to go aboard that night as he intended, but use means to get his Brother Sandford out of the Estate, or else he would be undone; and that he should Arrest the said Sandford for 7000 l. which he was to account for in his Father's time, (he then having managed the Estate for the old Man) but the Morning following, Chambre himself was made a Prisoner by the Combination aforesaid, for the mourning for his Father's Funeral; and Sandford hearing of it, posted to Dublin to pay the Debt: but the beforementioned Agents met him as soon as he came, and told him, if he went to his Brother, he would Arrest him for 7000 l. at which Sandford, much troubled, went back and took Council of the Earl of Strafford, seeming his great Friend, whom he did not suspect to have any design upon the Estate, and he advised, instead of releasing his Brother, to clap another Arrest upon him for a 1000 l. pretendedly due to Sandford; which being done, and Chambre and Sandford thus set at variance, the Earl caused Sir Philip Percival and others, to make a proposal, that the said Sir Philip might have a Lease of 22 years of Chambres' Estate, for the use of the Countess of Carlisle, paying 4000 l. Fine, and 500 l. per annum, and the third penny profit of the Woods; and in order to this, the said Agents persuaded Chambre to petition to the Earl of Strafford, that the Lease from the trusties to Sandford might not go on, but that the Lease proffered by Sir Philip might be perfected, that he might receive the 4000 l. to pay his Father's Debts and Legacies, and get out of prison. As soon as the Earl received this Petition, he transmitted it to England to His late Majesty, and Council, seeming much to commiserate Chambre his Condition, and 〈…〉 Order to compel the trusties to consent to this Bargain, they living in this Kingdom of England.  
Hereupon the trusties were sent for before the Council Board to yield to this Lease propounded by percival, who alleged they were letting a Lease of the premises to Sandford, much more advantageous to the Petitioner, upon which the King and Council made an Order; that the business should be wholly remitted to the Earl of Strafford to perfect that Lease for the Countess of Carlisle, (which was in truth for himself) or make any other better bargain for the good of the Petitioner, declaring, that the Earl should by a Decree in Chancery, enforce the trusties to assent to what bargain he should make with the said Countess or others, so far as did concern their Trust for 22 years; but further, that the Earl should provide by such Decree, to preserve the Inheritance according to the intent of old Chambre, which was, that the Trust should continue in them 200 years; for he reserved a power in the Lease to revoke it, but never did, so that the same is still in being, and distinct from the Inheritance.  
Now Chambre being informed what Order the Earl of Strafford had received, Petitions again to him and the Council, that the Lease propounded by percival might not be made good, for he could have a much better bargain; at the reading of which, his Brother in Law, the Lord Brabason, being one of the Council, desired, seeing his Brother must be forced to Let his Estate to pay his Debts, that the King and Counsels Order might be fulfilled, and the best bargain accepted of; and for his own part, he was willing to take the Lease of 22 years, and give his Brother Chambre 5000 l. and 600 l. per annum, and half the profit of the Woods: Whereas percival would give but 4000 l. Fine, and 500 l. per annum, and the third penny profit of the Woods; so that here was above 10000 l. profit better than that of Percivalls, for there was above 2000 l. per annum, made Communibus Annis of the Woods.  
Yet the Earl of Strafford refused this offer, and caused the Lease with percival to be perfected by a special Order, forcing the trusties to consent by a Decree, but no care was taken therein to preserve the Inheritance, for that did not suit with the Earls avidous hope, so that His Majesty's Order of Council was doubly defeated and eluded; nor was the 500 l. per annum Rent, or third part of the profit of the Woods, mentioned in the said Lease ever paid, or one penny thereof.  
Secondly, Sandford being thus turned out, and the Earls Agents got in possession of the premises, Chambre was still detained a Prisoner, and being scarce able to get Victuals for his necessity, petitioned the Earl of Strafford that the 4000 l. Fine might be paid, that he might be able to discharge all his Debts, and that he might go out of Prison, upon which the Earl to drive his design on further, causes an Agent to tell him, that the 4000 l. Fine would not pay his Debts, and persuade him to sell the Reversion of the Estate, and he should have 13200 l. for it: That is to say, 1200 l. in hand to help pay his Debts, and with the other 12000 l. the Earl would purchase him a better Estate than this was: But Chambre refusing to sell, because e of the Lease of 200 years which he had right to as Executor of his Father, was kept more straight a Prisoner then before, and reduced to great want, yet often visited by several of the Earls Instruments, and when they got him merry, and at all inclinable to the Earls desires, he was sometimes sent for to Dine with him at the Castle, and sometimes let out of Prison; and then one pretended Debt or other, upon paper Petitions, clapped him up again, that being brought into such misery by continual vexations, and cruel duress, insomuch that he was willing to yield at last to the Earls proposal for the Reversion of the Estate, but not the Lease, if his Wife would consent.  
To make her willing, the Earl sends a messenger to her; and upon refusal, threatens her, and causes her Husband to be kept so close a prisoner, that neither she nor any of his Friends should come at him, though she petitioned six times but to see him, yet she could not be admitted, till the falling often into Convulsion Fits, the Keeper thinking he would die, went to the Earl of Strafford and told him, that Mr. Chambre had a desire to see his Wife, and if it were not speedily, she would never see him alive, upon which the Earl sent his Gentleman to go along with her, who found him lying upon the Table on his Belly, very near death; but raising him with some Spirits, and other help, he began to look up; and his Wife weeping said, Husband! how dost thou do? Wife, said he, I am kept here for a Bargain: Prithee Husband, replied she, pardon me, for it is my fault, I would not consent to a Fine, but I see they are resolved to have it, and rather than I will be an Instrument of thy death, I will agree to it, (all which discourse was proved by the Oaths of three persons then present.)  
Immediately the Earls Gentleman hasted back to his Lord and told him he must strike whilst the Iron was hot, for now she was willing: So a Fine was clapped up upon those words, and a Deed dated the 2d. of November 1639. Sealed by Chambre for the Reversion only to Josiah Carpenter, Henry Wentworth and others (intended, though not expressed to and for the use of the said Earl of Strafford and his Heirs) for the sum of 13200 l. mentioned therein as the Consideration. Whereas the Estate was then really worth above 120000 l. For the Lands would be worth within 4 or 5 years' time, when the Lease is expired, between 5 and 6000 l. per Annum: Besides Customs, which were worth as much more; and at that time the Woods were worth near a 100000 l. The Earl of Cork hearing, proffered (but a year before old Chambres death) 60000 l. for the Timber Trees only upon this Estate.  
But now by the practices aforesaid, Wood and Land and all the Appurtenances, are wrested from the said Chambre and his Wife, for the bare mentioning of 13200 l. For even of that Money none was ever yet paid, save only 500 l. said to be paid to one Chambre of Minmore for to relinquish all his pretensions to the Premises, so much being given him by Chambre the Father on that Condition.  
This Deed and Fine being executed (which were not only obtained by duress and without valuable consideration, but also tending to the destruction of the Inheritance) were directly contrary to the King and Counsels order at Whitehall the 17th. of January 1637 beforementioned; thereupon the said Chambre was set at Liberty, but coming into the Fresh Air an a Full Diet; within a few days after, viz. the latter end of November 1638. died, leaving two Children (a Son that died soon after him) and a Daughter.  
But before his death, or making of the said Conveyance, viz. the 17th. of August 1638. the said Chambre made his last Will and Testament in Writing, bequeathing all his Lands to Mary his Wife for 12 years; for the remainder, one Moiety to her during Life, the other to his Heirs Male, and for want of an Heir Male, to his Uncle Chambre of Minmore, and his Heirs Male for ever, and 2000 l. to his Daughter; and made his said Wife sole Executrix, and expressly gave her all his Goods and Chattels, by which she became Entitled to the Lease of 200 years for the remainder thereof to come, and also to the Inheritance notwithstanding the Conveyance aforesaid: But whatever was given to Chambre of Minmore by Will or otherwise, was Sold a year after Chambres death by Chambre of Minmore to the Deceased Chambres Wife; so that the Family of Minmore have no pretence of any right to it, as by Deed under his hand doth appear.  
That Chambre thus dying without having Signed any Deed to lead the uses of the aforesaid Fine; the Earls Agents apprehending they had not yet made the Estate secure, set up by false Suggestions a Nuncupative Will, supposed to be made by the said Chambre, and made Mary his Relict prove the same. And in pursuance of such pretended Will, set up likewise a Lease and Release dated the 3d. of November 1638. Supposed to be made under the said Chambre of Minmores' hand, only of all the Premises and Appurtenances absolutely and a Deed of uses or Covenants with the same Date. Between the aforesaid Carpenter Wentworth and others the Earls trusties, of the one part, and the said Chambre of Carnow, Esq; Leicester his Father in Law, Job Ward that Married Mary his Relict and his Uncle Chambre of Minmore pretended trusties for the said Chambre of Carnow of the other part; and it is apparent that all the Deeds to be Signed the 3d. of Novemb. were false, and hatched after Chambres death, and all suitable to the Nuncupative Will; for Chambre perfected no Deed in his Life-time, but that of the 2d. of November, by which he Sold the Reversion of his Estate for 13200 l. under his own hand, only without trusties; therefore it is apparent all the other Deeds are false; whereby the said Carpenter Wentworth, etc. Covenanted to lay out 12000 l. before the 1st. of Nou. 1645. in Land, to be conveyed to the said Leicester, Ward, and Chambre of Minmore, for several uses, and upon several Limitations therein expressed: Whereas in truth the said Chambre of Carnow did perfect in his Life-time only one Deed dated the 2d. of November, which was only of the Reversion, and Feoffees mentioned on his part, and these after Deeds were set up, and the said Esq; Leicester and Chambre of Minmore (who knew nothing of them) named therein only to colour the business.  
For Fourthly, this Nuncupative Will and several Deeds being set on foot, and the said Job Ward having Married Mary the Relict of Chambre of Carnow; and they desiring the Earl that the 13200 l. might be laid out in Land for Calcot Chambre, an Infant then living, Son of the said Chambre of Carnow and Mary, or else to be restored to Shelelah again his Honour made the said Job Ward his favourite, and caused him and the said infant to Petition that the said trusties James Fines, Nathaniel Fines, etc. might give up their Trust in the aforesaid Lease of 200 years; who induced by the said Suppositious Deeds, and a Decree grounded thereupon and obtained by the Earl's Potency in the Chancery of Ireland, were prevailed thereupon to Sell the said Lease (but without the said Job Ward or his Wife's Signing the same) to two persons, for the use of Carpenter, Wentworth, and others: But it was upon Condition that 13200 l. should be paid, or laid out for purchasing Land of Inheritance according to the aforesaid Articles.  
Which Articles were to be performed before November 1645. But were never made good, nor can be: The trusties Sold it Conditional for 13200 l. a year after Chambres death; which is an Argument their Trust was not void: True it is, in the time of the Suits with the said trusties of the Lease of 200 years, the late Earl of Strafford pretended to purchase a place called the Rannalaghs (or Knochrea) of Sir Adam Loftus, which was Plantation Lands taken from the Irish, and given to several men upon Commissions of Grace and no real Inheritance, for it was only a Lease for years, and with several Limitations, in Pursuance of some part of the aforesaid pretended Articles; and though the Earls Agents pretended they laid out 10000 l. for it; yet if they did it was in their own wrong, and not with our Consent, and the Land was not worth 5000 l. as appears by many Witnesses.  
Fifthly, That in the year 1640. The real Will in Writing of the said Chambre of Carnow (entrusted by him with Mr. Guttridge, than Minister of Carnow, was produced, which being proved and administered unto by the said Mary his Relict, and the Nuncupative Will (though she was forced to administer a year before) and the Earl of Strafford had spent above 500 l. in Law to maintain it) thrown out of Court: The said Earl and his Agents began to be at a stand, because all false Deeds and Articles of Agreement upon which the trusties assigned away their Trust, being all done upon that Nuncupative Will, seemed to signify very little. And therefore to the intent, that if one device would not serve, another might: The Earl (as it is said) having about Trinity Term 1637. 13 Car. I. caused a Case called, The Case of Tenors upon Defective Titles, to be made without Jury, Trial, Consent of Parties, or any Legal Process; and procured Letters Patents, wherein amongst others this Estate of Shelelah was Craftily mentioned as a Defective Title (though it never were so, as by Inquisition upon Record appears.) He obtained an Act to pass both Houses of Parliament in 1640. (as now pretended) to invest it in the Crown amongst 400 and odd Manors as a Defective Title.  
That the said Job Ward and his Wife upon setting aside the Nuncupative Will, had all the Deeds and Writings and the said Lease of 200 years (that was resigned up by the Right Honourable, the now Lord Crew) in their own hand, and the same were not then delivered to the Earl of Strafford, or his Agents: Because, the proving of the real Written Will had hindered any further proceed at present.  
And in the time of the Rebellion, Job Ward and the said Mary was turned out of the Rannalaghs, and came into England, and the said Job her Husband likewise Died.  
That in the year 1647. the now Suppliant William Eyre Intermarryed with the said Mary formerly Relict and Executrix of the said Calcot Chambre of Carnow, and thereby in Right, became Entitled unto, and aught to have had and enjoyed the use and benefit of the Premises, under, and according to the Trust aforesaid, for the than remainder of the aforesaid Term of 200 years: And accordingly most of the Writings aforesaid came to his hands, and also the said Lease of 200 years: But by Deceit and Subtlety he was deprived of them, and many of them came into the now Earl of strafford's hands and his Agents.  
For the said Eyre, by means of his opposing Oliv. Cromwell in his Arbitrary power, and the death of the late King of Blessed Memory, being a close Prisoner in Warwick Castle in the year 1649. Judge Advocate Whaley, formerly a servant to Mrs. Chambre in Ireland (than Eyre's Wife) persuaded her to make Colonel James Temple her Daughter's Guardian; lest Cromwell should Sequester their Estate because of her Husband's Actions, whose pernicious advice she took, and trusted the said Temple with most of the Writings concerning the Estate, upon his promise to restore her Daughter and Writings upon demand: But the said Eyre and his Wife, in the year 1650. demanding them, he refused to deliver them, and contrary to his promise inveigels the Daughter to Marry his youngest Son Alexander.  
That Eyre in the Latter end of the year 1650. went into Ireland to look after his Estate in Right of his Wife; and then the Lord Ireton being informed by most of the Nobility and Gentry of the wrong done to Mr. Chambre the said Eyre's Predecessor by the late Earl of Strafford: Did by the advice of the then Council, put the said Eyre in possession of the said Chambres Estate of Shelelah aforesaid, which the said Eyre held several years: But being made Prisoner again by Oliv. Cromwell for many years together; the Earl of Strafford and Colonel James Temple, and his Son Alexander and his Wife taking the opportunity of Eyre's Imprisonment, combined together, and commenced many Suits to out him of the said Premises of Shelelah of which he was in Possession, and made use of the said Writings which the said Colonel Temple had so unduly deprived the said Eyre of, and re-delivered the Lease of 200 years into the now Right Honourable the now Lord Crews hands (one of the trusties) who hath acknowledged that he hath the same by him, and would deliver it to whom a Court shall command.  
The first Suit the said Confederates commenced, was on the behalf of the Countess of Carlisle, for the aforesaid Lease of 22 years; yet had not paid a Penny Rent nor any Profit of the Woods according to the Tenor thereof, so that the same was long since void; yet they still brought vexatious Suits to weary out the said Eyre as he was a Prisoner, and also against Chambre of Minmore, as pretending to be Heir Male to the Estate according to the Tenor of young Chambres Will.  
And in the year 1657. all the Suits of the now Earl of Strafford and his Agents came to a hearing, and after 5 days Debate from Morning till Night before Chancellor Steel: He did then Judge that the Inheritance might belong to the Earl of Strafford, because of the Fine past, although surreptiously obtained: And the pretended Heir Male went forth out of the Court, and refused to make out his Title. But the Court was of opinion that the Lease of 200 years did belong to Eyre in Right of his Wife; and therefore did dismiss the said Earl of Strafford and the Countess of Carlisle with all their Suits that had been of 4 or 5 years standing in several Courts, and seemed resolved to continue the said Eyre in Possession, in Right of his Wife the Lease of 200 years belonging unto him.  
Which the Earl of strafford's Agents perceiving, betook them to their last refuge, and produced the beforementioned Act of Parliament for strengthening of Defective Titles; amongst which Chambres Estate of Shelelah was foisted in untruly as aforesaid: Upon which Chancellor Steel deferred his Judgement till the next Term, expecting the Cross-Bill of Eyre's and his Wife would then come to hearing.  
That before the next Term, the now Earl of Strafford and his Agents put in a Plea to such the said Eyre's Cross-Bill, waveing and renouncing all pretences of Titles and Claims whatsoever declared by the said Bill; and did Challenge the said Estate merely by the said Act for Corroborating Defective Titles, and Letters Patents thereupon granted under the great Seal of Ireland the 28th. of September Anno 1641. 17 Car. primi to George Carr and others, to and for the use of the said now Earl of Strafford.  
That Eyre being a Close Prisoner, and his Council neglecting to Argue the said Plea, or bring that Cause to hearing: Steel the next Term proceeded to pronounce his Decree in the said other Cause, wherein the Earls Agents were Plaintiffs, and merely upon the said Act (though it never had the Royal assent, nor was Recorded) gave away Eyre's Possession, not upon any other Title and Earl had to it, but merely by that pretended Act: Declaring in his Decree that the same is chief to be considered, viz. Whether it be a Defective Title or not; and therefore gave the now Earl of Strafford Possession only till he was outed by due Course of Law, or further order of the Court; and did publicly blame Eyre's Council for not bringing his Cross-Bill together to a hearing, and told them; there was speaking of a Will and an Inquisition, proving the Estate was no Defective Title. And he did believe there were such things, but they had not appeared Judicially before him; and therefore advised the said Eyre to Appeal to a Parliament, who would undoubtedly do him Right in the thing, by their Sovereign power, which he being of an Inferior Court had not power to do.  
But the said Eyre could not obtain his Liberty till after Richard Cromwell was turned out, and Ludlow sent over by the long Parliament into Ireland; and within half a year after was made Prisoner again on the occasion following (viz.) His Majesty our Sovereign that now is, being to be Proclaimed in Ireland on the 18th. of May 1660. The said Eyre's Wife desirous to rejoice with her Tenants for His Majesty's Restauration, had invited many of them to a Feast on that day, and ordered Servants to carry 10 Loads of Wood to a Hill to make a Bonfire; of this the subtlety of his Adversaries who were in Possession of his Estate, that they might prevent him from Appealing to the Parliament in Ireland for recovering the Lease and Estate aforesaid; took an advantage and brought feigned Complaints, suggesting to some Magistrates: That if they did not secure the said Eyre before the said day, he would be in the head of a great number of persons to oppose the coming in of the King, than which nothing could be more false, or remote from the said Eyre's Intentions.  
However upon this slander, the Council of State sent 5 Troops of Horse, halled the said Eyre out of his Bed, and carried him to Dublin Castle, where he was most cruelly handled for sometime, afterwards hurried from Prison to Prison above 10 years' space, without any known Crime; sometimes kept from all kind of Food for several Weeks, but what was given in by stealth, at a hole made under the door for the Cat to go in and out: And his Keeper being demanded by the Prisoners and others the reason of such extraordinary Rigour towards the said Eyre, would usually answer: That his Command was so strict he durst do no otherwise; often declaring he had an order to starve him.  
That whilst the said Eyre was thus in Durance, all persons were prohibited to come at him, and his Wife not suffered to visit him; at the same time some were admitted to serve him with Subpaenas in Chancery, through the Combination of the said Alexander Temple, and the now Earl of strafford's Agents, and for pretended contempt of the Court under that inevitable necessity, Chancellor Eaustace grants an Injunction, and turns the said Eyre's Wife and Family out of Doors of the Estate of Rannalaghs' too; and they had utterly perished, if good people had not relieved them: Although the said Eyre's his Council, did proffer his Oath that the said Eyres did not make any concempt, neither was he in any Capacity so to do: Upon which Injunction. the said Eyre and his Family have been ever since kept out of the Estate of Rannalaghs; which was pretended to be purchased for the use of Mr. Chambre aforesaid, with the Money that was to be given for the Reversion of Shelelah. And Steel did declare that if all the Money had been really paid for the Reversion, it could not have hindered Eyre of the Lease of 200 years; and if so, the Rannalaghs being but a Lease or 500 years, really belongs to the said Eyre in Right of his Wife.  
But by reason of such Combination and Cruelty against him, the said Eyre; not any one for him, as he knows of, hath not since received one penny profit thereof to this day. And his the said Eyre's Wife (a person well Descended, and who had lived formerly in great Splendour) Fainted in the Streets of Dublin (for want) and died about two hours after taking into a house; crying out her Daughter Temple had broke her heart. For by the Confederacy aforesaid, the said Temple and his Wife enjoy all that the Earl, or his Ancestors gave for Shelelah (except the 500 l. to Chambre of Minmore.) A in truth the whole 13200 (if the purchase were honest) did belong to William Eyre in Right of his Wife as a Chattel; as it hath often been declared by all the Judges in Ireland, no Land being purchased in Mr. Chambres Life-time. And the Judges did likewise further declare, that whatever they pay of the purchase Money to any other than the said Eyre, they pay it in their own wrong; which caused the now Earl of Strafford to take a Bond of the said Temple of 20000 l. (as he is informed) to save him harmless from the said Eyre, which that will not, nor cannot do; when Truth and Justice shall take place: For Mr. Chambres Daughter had a distinct Portion of 2000 l. given her by her Father's Will, though now they would make her Heir of all that they have been pleased to leave the Family.  
That the said Eyre to vindicate his innocency to the World, brought himself to a Trial sometime since in Ireland by a Habeas Corpus; and was cleared by public Proclamation in the Court of Kings-Bench there. But immediately before he was clear of the Prison, there came an Order to another Marshal more Cruel than the former, to take him into his Custody on a General Charge of High Treason; and four years and upwards he was brought to the Bar twice a Term to know what his Treason was: But the Attorney General put it off from time to time; insomuch that the Judges declared in open Court it would fall heavy somewhere at last for keeping a man so long in Prison after he was cleared by the Law. But his Majesty and Council being informed of the Cruel Injustice used to the Pisoner, was Graciously pleased to Command by a special Order, that he should have the benefit of Liberty according to Law; upon which Order the Judges brought him again to the Bar, and finding nothing against him, but only an Allegation that there was formerly a Charge of Treason preparing against him, but now the same was lost, they cleared him the second time by Proclamation, discharged; and then after 10 years' Hardship and vast Expense he was released not knowing of whom  
Which continual and most vexatious troubles he fears purposely contrived have been the only cause why he was no sooner released; whereupon he made his humble Address for relief and recovery of just Rights in the  Estate wrongfully (as he humbly conceives, and is by Council advised) withholden from him.  
Upon the whole matter be pleased to observe, First, That Calcot Chambre the younger, being entitled not only to the Inheritance, but also distinctly to the Lease of 200 years, (which would not be drowned by the descent, because it was to operate to other intents afterwards, as payment of Debts, Legacies, etc. and was acknowledged to be in force long afterwards by their attempts to sell and convey it) And he by his Will having expressly given all his Goods and Chattels (wherein that Lease is Entitled) to his Wife and Executrix; And the Conveyance executed afterwards in his life time, not pretending to affect such Estate for years, but only the Reversion; Eyre by intermarrying with the said Executrix, became, and is lawfully entitled thereunto for the Residual Term: And for the Assignment or Sale thereof by the trusties, the same was without consideration, and they were surprised into that Action by the pretended Deeds, set afoot as aforesaid; nor could such Assignment (as Council advise) give away the Executrixes Right, unless she, or her then Husband, had actually Sealed the same.  
2ly, That there appears only 500 l. paid by the late or present Earl of Strafford, or their Agents, for this vast Estate (their purchase of the Rannalaghs being without the consent of Chambre or his Wife, etc.) And 'tis proved by many Witnesses, that the late Earl of Strafford made above 30000 l. of the profits of this Estate in 4 years' time before the Rebellion broke out: And the present Earl, though ordered to the contrary in the year 1661. (till the Title should be cleared) has made at least 3000 l. per annum ever since only of the Wood growing thereupon.  
3ly, That the present Earl, his trusties or Agents, can pretend no Title, but by the pretended Act of Parliament for investing of it in the Crown, Anno 1638. and Letters Patents thereupon given to him upon Commission of Grace; and in the year 1640. or thereabouts, caused an Act of Parliament to be made by his Deputies for the confirmation of all the aforesaid Manors to him, which was granted him by Letters Patents as aforesaid, which Act was never Recorded; for 17 years after the date thereof, at the hearing of the Cause, they moved Chancellor Steel that it might be Recorded; and Council declared, it ought not to be Recorded, because it had not the Royal assent.  
4ly, All the Title that the Earl of Strafford has to challenge Right, is only by these two Acts of Parliament, and Letters Patents thereupon; The first Act, and the Letters Patents thereupon being void, because it is mentioned, if it be plantation Lands, and his Majesty abused in his Grant; and the last Act being void, having not the Royal assent; therefore it is apparent, that the said Earl of Strafford has no Title to it, the premises being never any defective Title, as by Inquisition upon Record doth appear; And the said half Barony of Shelelah was inserted there by practice: And when it passed neither Heir to the Inheritance, nor trusties to the Lease of 200 years, had never any notice of it to make them capable of defending their Title and Trust.  
5ly, That Chambre the Son, giving all his Lands to his Heirs Male, and to Calcot Chambre of Minmore, and his Heirs; and the present Earl of Strafford having disclaimed all his Titles by Deed or Purchase, and the said Calcot Chambre of Minmore, (having, after the death of the beforementioned Infant Heir Male) sold to the said Eyre's late Wife for 500 l. by Deed executed under his Hand and Seal, ready to be produced whatever was given him by that Will, or any other Grant whatsoever: It follows (as 'tis humbly conceived) that the Inheritance was invested in the said Eyre's Wife (by whom he had one Daughter) as well as the Lease of 200 years.  
6ly, How notoriously, and by what practices, all pretences of right and possession have continually been obtained on the part of the Earls Agents; and how long the said Eyre has been kept out of the same by unheard of cruelties; what severe Imprisonments, and unparallelled hardships (chief, as he has grounds to believe, on this occasion) he has suffered; and to what extremities he is reduced, with many other sad circumstances which will appear throughout the whole series of the Case.  
The truth whereof; the said William Eyre is ready to make appear in every particular; And yet (had he not been enforced by the unanswerable impulses of necessity, after all other overtures, were despised; though offered with the greatest moderation) he should not thus have exposed the same, lest he might seem to violate his due respects to the me●●● 〈…〉 〈◊〉 of his Intentions whose design is only to set forth a brief of the matter of Fact, without Aggravations of unbecoming Reflections.  
And hopes it may not be thought presumption in this ruinated Suppliant, humbly to make his Address to His Majesty, and the most High and Honourable Court of Parliament, in whose power only (he is advised) it lies to relieve him for the restitution of his just Rights (as he conceives) so long wrongfully detained from him.  
William Eyre.   

The Earl of Strafford and his Agents having renounced all his Titles to Shelelah, and challenged it only by an Act of Parliament, and Letters Patents from His Majesty, as by their Plea upon Oath doth appear. And it is clear, that Shelelah was never any plantation Land, as will appear by these Arguments following, viz.  
1. For two years before the Act of Parliament and Patent was granted, there was an Inquisition legally taken, that Mr. Chambre was possessed of Shelelah as an Estate in Fee, and that he had let a Lease for 200 years, because of the profuseness of his Son, to preserve the profits to the use of his Will.  
2. By an Order from His late Majesty and Council to the Earl of Strafford, That he should cause a Decree in Chancery in Ireland to be made for the preservation of the Estate according to the intent of old Chambre aforesaid.  
3. Which Order was a year before the Act of Parliament and Patent, and the Earl of Strafford, and his Council, made an Order upon the King and Counsels Order, that there should be a Decree in Chancery for the preservation of the Inheritance.  
4. But his avidous desire made him falsify both these Orders, and kept Chambre in Prison till he was almost starved to death, to force him to sell the Reversion of the Estate to him.  
5. That after Chambres' death they hatched a Nuncupative Will, and grounded many false Deeds thereupon, the better thereby to secure the Estate to the Earl of Strafford; which deceit they had no need to have used, if it had been plantation Lands.  
6. And they would have had no occasion to have forced the trusties to sell the right of the Lease upon the false Deeds aforesaid, to them for 13200 l. conditionally to be laid out in Lands for the use of Chambre aforesaid, which was never done; because shortly after the real Will was discovered, and the Nuncupative Will was thrown out of Court, and all the false Deeds grounded thereupon void.  
7. If it had been plantation Lands, (as the Earl of Strafford would have it by the Act) they had no need to appeal to the Court of Claims in Ireland since His Majesty's Restauration, to have had it settled upon the Earl of Strafford as Traitor's Land; but the Commissioners finding it was an Estate in Fee, and no forfeited Land by any former Rebellion; and Eyre's being then a Prisoner, and unconvicted, the Commissioners of the Court of Claims would not meddle with it.  
By these Arguments it is clearly seen, that Strafford has no right to it but by the Act of Parliament aforesaid, which Act is out of doors, as to Shelelah; for the Parliament when the Act was granted, fearing they might be misinformed, says in the Act, It shall be invested in the Crown if it be plantation Lands; and being none, His late Majesty was abused in His Grant, which is hoped His now Majesty, and Parliament, will rectify.  
And he further demonstrates to His Gracious Majesty, and the most Honourable Houses of Parliament, that there was an Act of Parliament made upon the late Earl of strafford's Attainder, in which there is salvo (that extenuates and takes away what right this present Earl can or may challenge by the former Acts of Parliament made in Ireland; for the Act saith, That no Lands should be invested in the King, but what was really the Earl of strafford's own Estate; and not any Lands that he had gained into his hand upon paper Petitions, and Imprisonment of Men; it being well known to many yet living, what cruelty and duress of Imprisonment was used by the instigation of the late Earl of Strafford to enjoin and enforce Chambres to grant the Reversion of the said Estate of Shelelah to him, your Suppliant hopes, and humbly expects, that His most Gracious Majesty, and the most Honourable Houses of Lords and Commons assembled in Parliament, well weighing, and duly considering the injustice and wrong by which the said Estate was obtained by the late Earl, and still is detained from your Suppliant, by the now Earl and his Agents, your Suppliant doubts not but your most Gracious Majesty, and the most Honourable Houses of Parliament, will in your most Sovereign Justice and Mercy, cause your Suppliant to be restored to his said Estate, after his so many years of oppression and