TO THE RIGHT HONOURABLE, The high Court of PARLIAMENT of the commonwealth of ENGLAND.  
The humble Petition of James Biddlecombe.  
HUMBLY showeth:  
THAT John Cifrewest, Gent. was lawfully seized in his Demesne, as of Fee, of, and in the manor of Moorechrichell, and of, and in the Advowson of the Parish Church of Moorechrichell aforesaid, in the County of Dorcet, and the Premises afterward descended, and lawfully came to Dorothy Morgan, wife of Gregory Morgan, Gent.  
That the said Dorothy and Gregory Morgan, by the advice of Sir Robert Napper, Knight, for the prevention of the sale thereof, the said Gregory being profuse, and an ill Husband, about Michaelmas term, in the four and thirtieth year of the reign of Queen Elizabeth did levy a Fine thereof to the said Sir Robert Knapper, John Fitzjames, and John Coward, Gent. in trust, to, and for the use of the Cognizers and their heirs.  
That the said Sir Robert Knapper having obtained the Fine aforesaid to be levied, did subtly advise and procure the said Gregory Morgan and Dorothy by Deed, to limit the use of the said Fine to the said Sir Robert Fitzjames, and Coward, and thei● Heirs, with a Proviso therein, that upon the tender of a pair of Gloves of six pence, to Sir Robert Napper by the said Dorothy, and declaring any new use, the Fine should be to the use of such persons, and in such manner, as should be so newly limited.  
That notwithstanding the said Sir Robert Napper did well know of the said Fine and Deed was levied, and made only in trust, yet intending thereby to obtain the premises to himself, upon the deaths of the said Gregory and Dorothy, refused to grant the premises to John Biddlecomb, your Petitioners Grandfather, who was next heir to the said Dorothy, but entered and possessed himself of the same, as though there had been no trust in him reposed by the said Cognizers, although there was never any consideration paid by the said Sir Robert Napper for the same, and although the said Dorothy was ever until her death reputed owner of the premises.  
That to entitle himself wholly in Law to the premises, the said Coward being dead for 700 l. given by him to Fitzjames, procures Fitzjames to release to him the said Sir Robert Napper all his right and claim in the premises.  
That he having now by subtlety obtained his ends, he still refused to grant the premises to your Petitioners Grandfather, and to be relieved in Equity, your Petitioners said Grandfather preferred his Bill in Chancery, and thereupon by the power and procurement of the said Sir Robert Napper, it was decreed in May, the first year of the late Majesty King James (although much equity is expressed in the Decree itself for your Petitioners Grandfather and although no sufficient ground is therein set forth to warrant a Dismission) that the Plaintiffs Bill should be dismissed, and that the plaintiff should have 200 l. only from Mr. Fitzjames out of the 700 l. which Mr. Fitzjames had received for his release aforesaid.  
That the said Sir Robert Napper being a powerful man, and your Petitioners Grandfather being much weakened in his Estate, by reason of the said Suit, and not longer able to strive with them in his life time, your Petitioners Grandfather never as yet received the 200 l. or had any consideration for the said premises, but shortly after died.  
That after his death, your poor Petitioners Father was disabled to prosecute his right yet occasioned your Petitioners Father through grief, to fall into a lunacy and distraction of mind, which he continued until his death, so that he was uncapable in his life time to prosecute his right, by means thereof, and having no friends that durst take upon them to question your Petitioners fathers right, being awed by the power of the said Sir Robert Napper, and Nathaniel Napper his son, and Sir Gerard Napper his Son, and Sir Gerard Napper hath successively kept, and enjoyed from your Petitioner the said manor and Premises, and the said Sir Gerard Napper doth most unconscionably keep and enjoy the same, and refuseth to grant the premises to your Petitioner, according to the trust in the said Sir Robert Napper reposed by the said Gregory Morgan, and Dorothy.  
Now forasmuch as the said Fine was levied, and the said Deed of uses made to the said Sir Robert Napper the said Fitzjames and Coward, but only in trust, and for that it appeareth by Sir Roberts own Answer in the said suit, that he never gave any consideration, as purchase money, for the premises, but that he only lent her, or laid out for her 400 l. which cannot be any valuable consideration, the Premises being at least 500 l. per annum. And for that some short time before the said Dorothy's death, when she would have tendered a pair of Gloves to the said Sir Robert Napper to revoke the said Deed of uses, the said Sir Robert Napper was in Ireland, and there continued till her death, and for that by the said Decree itself much equity doth appear for your Petitioners Grandfather, yet his Bill was unjustly dismissed, only allowing him 200 l. And forasmuch as the said Sir Gerard Napper hath gotten into his custody all the Evidences concerning the Premises, so that your Petitioner cannot evidence his right. And forasmuch as your Petitioners Grandfather was awed by the power of the said Sir Robert Napper, and weakened in his ability to resist them, or to seek further relief for his just right. And for that your poor Petitioners Father, by reason of his infirmity aforesaid, was disabled to seek relief in life, so that by occurrence of time, and by the potency of Sir Gerard Napper, and the Poverty of your Petitioner, your Petitioner is altogether hopeless to recover his right in any other way but by the Clemency of your Honours.  
Your poor Petitioner therefore humbly beseeches your Honours to take his miserable estate into consideration, and to call the said Sir Gerard Napper before your Honours, and to compel him to bring into this House all the Deeds and Evidences of the manor and premises, that thereby your Petitioner may have your honour's clear evidence of his right, and that your Honours would be pleased to take such speedy course for your Petitioners relief in all and singular the premises, as to your grave wisdoms shall seem most meet.  
And your poor Petitioner shall ever pray, &c.