THE Earl of Exeter with divers other Lords and Gentlemen are Proprietors and Owners in possession, and Commoners by undoubted 
The Case and Title.  right and Title in the Law, by several and respective decents, and purchases of 36000 Acres of Fen and Meadow ground, lying between the Rivers of Glenn, and Kyme Eay, in the County of Lincoln, and of several Manors, and Lordships adjoining thereunto: And wherein the said Lords, and Owners, their Farmers and Tenants, have Common appendent to their Lands adjoining, and particularly the said Earl of Exeter is there seized of the Manors of Bourne, Morton, and Byker; and of the Soil and Royalty of Brovage, for about 14 miles together in the said Fen, and Meadow-ground.  
The Lords and Owners being estated and possessed as aforesaid, the now pretended Dreyners (Anno 1635) by colour of a Contract with certain 
The grievances committed by the Dreyners.  Commissioners of Sewers (themselves being the chief in Commission) entered into and upon the said Level, and without consent of the Owners, without Inquiry by Jury, against an express Verdict whereby the said Level was found not surrounded, and consequently not at the disposal of the Commissioners of Sewers: And also notwithstanding the Exceptions, Suits public and private, Complaints of the Owners and Commoners, endeavoured to possess themselves of 14000 Acres thereof, encompassed the same with Banks and new Dreyns, stopped the old ones, whereby at length such inundations fell upon the Neighbouring Towns, they were constrained (the Dreyners refusing to appear and justify their proceedings upon Actions of Law brought against them, for the preservation of their Lives and Goods, being authorized in that behalf by Commissioners of Sewers) to open the old Dreyns, since which the said Level hath been and now is peaceably enjoyed by the Lords, Owners and Commoners as the same hath been from time, whereof the Memory of man is not to the contrary.  
These Dreyners now desire to be Estated in the aforesaid 14000 Acres by Act of Parliament, upon pretence of their Improvement and former 
The present Question.  possession thereof.  
The Lords Owners and Commoners pray that they may not be stripped of their Estates upon such pretences, the Premises are a true state of the Case, Title, and Question in difference; and deny divers Pretences and Allegations, in the Proposals and Narrative of the Dreyners contained to be true; That is to say,  

Dreyners false Pretences.  

1. They deny, That the said Dreyners were ever in a just, lawful or quiet possession of 14000 Acres of the said Level, For 

The said Possession (such as the same was) was obtained illegally only by Colour of a Commission of Sewers, but without due proceedings thereupon, and not warrantable by Law, Statute or Precedent.    
2. The possession was interrupted by Clayms, Entryes, Distresses, and Actions brought by the Owners and Commoners, as appears by divers Records, and other Testimonies.  
2. They deny that a Contract was made with the Dreyners to give them 24000 Acres by approbation of many thousand Commoners, For 

No such thing was ever yet proved, and the ensuing Complaints, Suits, and Actions of the Owners and Commoners evidence the contrary.    
3. They deny that the undertaking to Dreyn the Level was ever performed, For, 

The Level in general (the 14000 Acres intended for the Dreyners themselves excepted) was not bettered by the pretended Dreyning, nor the new Dreyns so effectual and useful as the old Dreyns, which the Dreyns had stopped.    
4. They deny that the Dreyners by their dreyning improved the 14000 Acres to a Mark an Acre annual value, For 

The same was of as great yearly value and profit 40 and 50 years before, as we are ready to prove.    
5. They deny that the Title or Contract, under which these Dreyners claim, is the same with Lovels Levelly, Bedford Levelly, and other former undertake, For 

1. Lovels Dreyning was by general consent after the awarding of a Writ of ad quod damnum.  
2. Bedford Level was by verdict found to be surrounded ground and of no value, Lyndsey Level was by verdict found not surrounded, and proved of a good yearly Value.  
3. Bedford Level was contracted for with the Owners and Country at Lynn 6 Car. primi, and after Drained; Lyndsey Level never contracted for with the Owners and Country, but rested from them by Power and Force.  
The undertaking in Bedford Level was begun, and pursued legally, and finished, and continued to the Honour and Profit of the Undertakers and Country.  
The undertaking in Lyndsey Level was most illegally begun, violently and injuriously pursued, and never finished to this day, proving only vexatious and mischievous both to the undertakers and Country.    
6. They deny that the Lords and Owners (who continually offered and still offer to defend their Right by Law) either committed or abetted any Riot, or the pulling down the Dreyners Houses or Plantations, but what their oppressions constrained poor people to do, or may constrain them unto in the future, the said Lords and Owners know not: but have heard what ever Riot was, the same was occasioned by one Hull, Servant to the late Earl of Lindsey, who is supposed to be still living to give account thereof, and the said Lords, and Owners, are unjustly Scandaled therewith, not being concerned in Suit or in Law to excuse or answer it.  
7. They say the question is mis-stated to be now between the Riotters and Dreyners, but between the Dreyners and Owners, which shall be preferred to improve these Lands.    

Their Proposals Answered.  
The Dreyners Proposals, which are but three in number, are conceived by the said Lords and Owners unjust and unreasonable, being as followeth:  

1. Proposal. That the Dreyners should have 14000 Acres of the Level, with help to repair the Works by them erected. 

1. AnswerThese Owners conceive it unjust and unreasonable that 14000 Acres of Land should be demanded from the Owners thereof without Right and without Price for the same, and without Crime or pretence other than the scandal of a Riot.  
2. The Lords and Owners conceive it most unjust and unreasonable, the Dreyners should both divide and choose not only so much in quantity but the best Land in quality, their 14000 Acres being the heart and middle of the Level, secured by Banks and Dreyns from the Upland-waters, unto which the rest is left liable.  
3. They are ready to prove that 14000 Acres are more by some Thousands of Acres than the pretended Dreyners can claim by their own pretended contract made by and with themselves.  
4. The Lords and Owners conceive it most unjust and unreasonable that they should be required to contribute to the repairs of those Works, by which themselves and the Country sustained such mischief, and which were erected without leave to excuse them, or Law to justify them: And they conceive this Proposal designed purposely to prevent the demand of Satisfaction for the aforesaid injuries sustained by the Country.    
2. Proposal. That the Dreyners when estated by Act of Parliament in 14000 Acres will be contented to Sell them to the Country for their Money disbursed with Interest. 

Answer 1. This were to abuse the Justice and Authority of Parliament, to divest men of their Estates, to the end they may be put to buy them again.  
2. The Lords and Owners having undoubted right in the Premises by Purchases already made and paid for, 'twere unjust and unreasonable they should Re-purchase their own Lands.  
3. If these Dreyners (as probably it may be) by their projects in improving other men's Lands, have spent more than the Lands are worth, 'tis not reasonable they should be reimbursed out of their purses whom they have wronged.    
3. Proposal. That the Dreyners will accept of the Interest of the Lords and Owners, and be obliged to double every man's Profit in the Level. 

Answer 1. If this offer should Entitle the pretended Dreyners to this Level, they may in like manner Entitle themselves to all the Common and Wast-ground in England; not that they mean or can improve the Nature of the Soil by Dreyning, but by altering the manner of Enjoyment from Common to Enclosure, when they have the whole to themselves, the Commoners excluded: by which means, if the same were lawful for the Owners to do (as the same is not) but expressly against the Letter of divers Statutes, they could themselves treble every man's Profit.  
2. Commons are not to be valued according to the single profit made thereof, but as they Benefit and Maintain arable Land to which they belong, and which cannot consist without them: therefore,  
3. The Policy of this Proposal to get the whole Level under the specious pretence of doubling each man's profit, would (to compass the Dreyners design) destroy Forty Neighbouring Townships consisting in Tillage, which cannot be maintained without Common. Upon Consideration whereof,     
It is Humbly desired on the behalf of the Lords, Owners and Commoners, that they may be protected and defended in their Rights and Inheritances, according to the Laws and Statutes of this Realm, and quieted against such unreasonable Proposals as aforesaid, being but endeavours (under the specious pretence of Improvement) to get other men's Lands, without Title, Consideration, Consent, Verdict or Legal Eviction.