THE CASE OF William Eyre's Esq.  
Concerning his Estate in Ireland, truly stated, and Humbly Presented to the Kings most excellent Majesty, and both Houses of Parliament.  
CAlcot Chambre Esq being seized in Fee of the half Barony of Shelelah with the Castle of Carnow, and Appurtenances thereunto belonging, in the County of Wicklow in the Kingdom of Ireland; containing of Arable, Pasture, Meadows, and Wood-lands, about sixty thousand Acres. Fearing the profuseness of his Son, made a Lease of the same, Anno. 1629. To James Fines, Nathaniel Fines, and John Crew, Esq for two hundred years without Impeachment of waist, 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 Testament; and for default of such Declaration to the use of his own right Heirs.  
The said Calcot Chambre Anno. 1635. Made his last Will, and gave all his said Lands to his only Son Calcot Chambre; as also all his Goods and Chattels: and made his said Son Sole Executor, and died.  
After whose death, the said trusties possessed themselves of the Premises, and would have let a Lease thereof to one Sandford for three years, for payment of the Deceased's Debts and Legacies; and to allow Young Chambre 300 ll. per Annum for those three years, and then to account and deliver up the Estate to him: For this Sandford Marrying Old Chambre's Daughter did manage the Estate in his time, and therefore the trusties thought him the fit to manage it now for the Young Man. The rather for that the greater part of the said Debts and Legacies was due to him and his Brother in Law the Lord Brobson, since Earl of Meeth, who Married Old Chambre's other Daughter.  
That Thomas late Earl of Strafford then 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 at last got the same into his own hands, or in trust for him, by the means and Practices following.  
The aforesaid Young Chambre being come to Dublin with his Wife to take Shipping for England to live with his Father in Law Esq Leicester in Cheshire, and there abide till the aforesaid three years were expired, was by the subtlety of the Earl of Straffora's Agents persuaded not to go Aboard that night, but use means to get his Brother Sandford out of the Estate, or else he would be undone: And that he should Arrest his Brother Sandford for seven thousand Pounds, which he was to give an account for in his Father's time: But the morning following Chambre himself was made a Prisoner for the mourning for his Father's Funeral; and Sandford hearing of it, Posted to Dublin to pay the Debt: But the before mentioned Agents met him as soon as he came, and told him if he went to his Brother he would be Arrested for seven thousand Pounds. Upon which Sandford, being much troubled, went back and took counsel 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 thousand pounds' Legacy that his Father gave him. When this was done, the Earl caused Sir Philip Persival, 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 per Annum; and the third Penny profit of the Wood And in order to this, the said Agents persuaded Chambre to Petition the Earl of Strafford, that the Lease the trusties would make to Sandford might not go on; but that this 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 ever the Earl of Strafford received the Petition, he transmitted it to England to the late King and Counsel; and enclosed it in a Letter to Secretary Nickolas, seeming to commiserate the condition of the Prisoner, and troubled that they being out of his reach, he could not redeem the poor Man; and therefore desired that the trusties might be Summoned before the King and Counsel, to answer the Petition; or else to be sent over into Ireland, that he might take a course with them, and the Defendant Sandford, that the Prisoner might be released.  
Hereupon the trusties were immediately sent for to Counsel-Board to yield to the Lease propounded to Persival; who alleging that they were letting a Lease to Sandford, Brother in Law to the Petitioner, that was much more advantageous to the Petitioner, than that propounded by Persival.  
The King and Counsel 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, as did afterwards appear:) Or make any other better Bargain for the good of the Petitioner; declaring the Earl of Strafford 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 twenty two years. And farther, 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 made a power in the Lease to revoke it, but never did it; so that it is the general Judgement of Counsel, that the Lease is still in being, and distinct from the Inheritance.)  
Calcot Chambre being informed what order the Earl of Strafford had received Petitions again to him and the Counsel, that the Lease propounded by Persivall might not be made good, for he could have a great deal better bargain. At the Reading of which, his Brother in Law the Lord Brobson being one of the Counsel, 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; The most of his Father's Debts being due to him who there offered to have the Lease of 22 years, and give his Brother 5000 l. Fine, and 600 ll. per An. And half the Profits of the Wood: whereas Persivall would give but 4000 ll. fine and 500 ll. per An. and the third penny profit of the Woods: so that here was above ten thousand pounds profit, better than that of Persivalls; For there was above two thousand pounds a year made of the Woods, besides a thousand pounds a year of an Iron work upon the Ground: Yet, notwithstand Strafford had the King's Order to make the best Bargain for the Petitioner, he refused this of the Lord Brobsons, and causeth that of Persivals to be perfected by a special Order of him and his Counsel: Then Sandford was turned out, and the Earl of strafford's Agents got possession of the Premises: Yet still Chambre was detained a Prisoner, though Sandford and others Released him; but many came against him with Paper Petitions to the Earl of Strafford, insomuch Mr. Chambre could scarce get Victuals, and often Petitioned to the Earl of Strafford that the 4000 ll. Fine might be paid, that he might be able to pay his Debts and go out of Prison; upon which, the Earl causes an Agent to go to him, and tell him the 4000 ll. would not pay his Debts, and persuaded him to sell the Reversion of the Estate, and he should have 13 thousand 200 pounds for it: that is to say, 1200 pounds in hand to help to pay his Debts, and with the other twelve thousand pounds the Earl would Purchase him a better Estate than his was: But Chambre alleging he could not sell it because of the Lease of two hundred years, was kept closer Prisoner than before, and forced to Petition to the Earl, that the Cook might be paid that he might have Victuals.  
And some of the Earls Agents came often unto him in Prison to make him merry and cheerful; and then when they found him a little yielding to the Earls desires, he should be sent for to Dine with him at the Castle, and sometimes let him out of Prison, and then one pretended Debt or other clapped him up again; insomuch that he was brought into such misery that he was willing to yield to the Earls desire, If his Wife would: Then the Earl sent a Messenger to his Wife, desiring her that she would pass a Fine and Recovery, that her Husband might sell his Estate and come out of Prison; but she refusing, was threatened, and her Husband kept close Prisoner, that she, nor any else should come at him, though she six times Petitioned to see him, but could not be admitted, till he falling often into Convulsion Fits, the Keeper thinking he would have died, went to the Earl of Strafford, and told him that Mr. Chambre had a desire to see his Wife, and if she did not see him speedily, she would never see him alive; upon which he sent his Gentleman to go along with her, and three other men went into his Chamber with her, which are all sworn to what followeth, That he lay upon the Table on his belly as good as dead, and they setting him upon his Breech, pouring some Spirits, and rubbing his Temples, 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 pass a Fine of Recovery: but rather than I will be an Instrument to thy death, I will Sign it.  
Upon which words the Gentleman returned to the Earl, and told him he must strike whilst the Irons were hot, for now she was willing: So a Fine was perfected upon these words only, and a Deed Sealed by Chambres for the Reversion only to four persons, Carpenter, Car, Little, and Billingsly, for 13 thousand two hundred pounds, when the Estate was worth above Six score thousand; for the Lands would be worth, within 4 or 5 years' time, when the old Leases expired, 5 or six thousand pounds per Ann. and at that time the Wood upon the Estate was worth a hundred thousand pounds, the Earl of Cork having proffered (but a year before Old Chambre's death) Threescore thousand pounds for the Timber Trees upon the Land.  
But how Wood, and Land, and all must go for Thirteen thousand two hundred pounds, and even of that Money, none was ever yet paid, except one Five hundred pounds, which I think was to Chambres of Minmore, for to relinquish all his Right in the Premises, so much being given him by Old Mr. Chambres Will, to Relinquish all Rights, and Claims in the Premises. And the Earl of Strafford made above 30 thousand pounds out of the Profits of the Estate in four years' time, before the Rebellion broke forth in Ireland, as hath been proved by many Witnesses. Whereby appears how well the King's Order before mentionod was observed, that the best Bargain should be made to preserve the Estate, etc.  
This being done, the said Chambre was set at Liberty, but coming into the fresh Air, and a full Diet, he lived not long after, leaving two Children, a Son, (that died soon after him) and a Daughter.  
But before his Death, viz. the 7th of Aug. 1638. he makes his last Will and Testament, bequeathing all his Lands to Mary his Wife, for 12 years, the Remainder one Moiety to his said Wife, during her life, the other Moiety 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 ll. to his Daughter: And makes his Wife sole Executrix, and expressly gave her all his Goods and Chattels: By which she became Entitled to the Lease of 200 years, and the 13200 ll. agreed to be given for the Reversion of the Premises.  
But Chambre thus dying, without having Signed any Deed to lead the uses of the said Fine, the Lord Deputy, apprehending he had not yet made the Estate secure, by his Agents sets up a Nuncupative Will of the said Chambre, and a Deed of Uses thereupon, bearing Date the 3d of Novemb. with Feoffees joining with the said Chambre: that is to say, Ralph Leicester, Job Ward, Calcot Chambre of Minmore, Esq pretended to be made his Feoffees by a Deed in his Life time, and a Lease, and Release dated the same day under Chambre of Carnow's hand only, of all the Lands and Appurtinences absolutely, whereas the said Chambre in truth did perfect in his Life time only one Deed Dated the 2d of Novemb. which was only of the Reversion, and without any Feoffees joining: And these After-deeds were set up only to make the business plausible on the Earls side.  
For the same 3d of Novemb. Carpenter, Car, Little, and Billingsly made a Deed back to Calcot Chambre of Carnow, and to Leicester, Ward and Chambre of Linmore and their Heirs of all their Right and Title, till the Deed of Uses, or Articles of Agreement were made good by Carpenter, Car, Little, and Billingsly, but all to the uses of the Nuncupative Will: so that if we own these Deeds, we must own that (which is false) and if we Sue Carpenter, etc. who Purchased of Chambre, they Answer, they Reconveyed all the Right they Purchased, and we may seize the Lands for not making good the Articles, and renounce all Title.  
In which lies the grand Intrigue of the Fraud.  
But to the end if one Device would not serve, another might, the Earl about Trinity Term 13 Car. Prim. caused a Case, commonly called the Case of Tenors upon defective Titles to be made, without Jury or Trial, or consent of Parties, or other legal process, and procured the opinion of the Judges of England, and Letters Patents: wherein (amongst others) this Estate of Shalelaw is mentioned, as a defective Title (though it never were so; as by inquisition upon Record appears) and upon that he obtained an Act of Parliament in Ireland in 1640. (As is pretended by the now Earl of Strafford) for confirmation of Estates on defective Titles; amongst which this was again inserted: But this Act was never Recorded; for before he obtained the Royal Assent he was put to Death.  
But before that, the trusties in the Lease of 200 years by vexation and practice were prevailed upon to Assign the said Lease (contrary to their trust, and without Chambre's Widow joining with them) to two Persons for the use of Carpenter, Carr, and others: But it was upon condition that the 13200 l. should be paid, or laid out for purchasing Land of Inheritance according to the aforesaid Articles.  
Which Articles were to be performed in 1645. but were never made good, nor can be. True it is in the time of the Suits with the trusties, the Earl of Strafford pretended for to purchase a place, called the Rannalaws of Sir Adam Loftus, which was Plantation Land, taken from the Irish in Ireland, and given to several men, upon commission of Grace, and no real Inheritance, according to the Articles: and the Purchase was but a Lease of five hundred years, to the use of Mr. Chambre, and the aforesaid trusties, which was mentioned in the said Articles, for such damages as they should sustain, till the Articles of agreement was made good, on Carpenter and Cars part.  
And also the Lease of five hundred years, was for the use of Carpenter and Car till the other should be made good the Articles on their part.  
The Earl of Strafford's Agents pretend they have laid out ten thousand Pounds for it, but they laid it out without our assent; for the Land was never worth five thousand Pounds, as it appeared by many Witnesses: and the said Mary Chambre the Relict (then Married to Job Ward) was put into Possession of it, not knowing where else to go; and enjoyed it one year, before the Rebellion broke out, as part of security of the twelve thousand Pounds, which should be laid out for Land of Inheritance.  
It is to be noted, that all this while, the real Will in Writing of Chambre was not discovered, he having entrusted it with Mr. Guttridge then Minister of Carnow; who in the year 1640. proved the said Will, and Mary the Relict came in Person and Administered to it; and than though Nuncupative Will was thrown out of Court, although she was forced to Administer to it a year before: And the Earl of Strafford had spent above 500 l. in the maintaining of it in Law; but when this was done, the Earl of Strafford, and his Agents, was at a stand, because all the false Deeds and the Articles of agreement upon which the trusties signed away their trust; and whatsoever was done upon the nuncupidie Will, was void and out of doors: And Job Ward and his Wife had all the Deeds and Writings and the Lease of 200 years (that was resigned up by Mr. Crew) in their own hands, and none were delivered to the Earl of Strafford or his Agents; because the proving of the real Will had hindered any farther proceed at present.  
And in the time of the Rebellion Job Ward and his Wife was turned out of the Ranalows by the rebels, and came into England and lived some years. and Job Ward died.  
And in the year 1647. William Eyres Marries the Widow; by which Marriage all the Writing and proceed in the cause abovesaid, came to his hands; and also the Lease of 200 years, and the Estate therein: 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,  
By the means of the said Eyres often Imprisonment opposing Oliver Cromwell in his Arbittrary power, and the death of the late King of blessed Memory, the said Eyre's being a close Prisoner in Warwick Castle in the year 1649. Judge Advocate Whale, being a Servant to Mrs. Chambre in Ireland (which was become William Eyres his Wife) he persuaded her to make Colonel James Temple his Daughter's Guardian; for Cromwell would sequester her Estate, because of her Husband's Actions: whose pernicious advice she took, and also 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 Eyres and his Wife in the year 1650. demanded the Daughter, and Writings, which he refused to deliver; and contrary to his promises Inveigles the Daughter to marry with his youngest Son Alexander: and the said Eyres, the latter end of the year 1650. went into Ireland to look after his Estate, in the right of his Wife; and the than Lord jerton, being informed by most of the Nobility and Gentry, of the wrong done to Mr. Chambre, the said Eyres, his predicessor by the late Earl of Strafford, did, by the advice of the than Counsel put the said Eyres in possession of the said Chambre's Estate with the Castle of Carnow, which the said Eyres held several years; but being made Prisoner again, by 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 half Barony of Shelela, of which he was in possession, and entertained one Mr. Joseph Avery to prosecute both their Suits against him; and trusted him with the Writings, which Old Temple had betrayed Eyres of. And also delivered the Lease of 200 years in to my Lord Crews hands (who was one of the trusties) who hath sworn he hath the Lease still by him; and shall deliver it, to whom a Court shall command.  
The first Suit the said Avery, and the Earl of Strafford his Agents commenced, was in the behalf of the Countess of Carlisle for the Lease aforesaid for 22 years; yet had not paid a Penny Rent, nor any profit of the Wood, according to the tenor of the Lease; upon which the Lease was forfeited: yet they commenced many Suits several years, to weary out the said Eyres, as he was a Prisoner: and also commenced a Suit against the said Eyres, and Calcot Chambre of Minmore, who did pretend to be Heir Male to the Estate, according to the tenor of Young Chambre's Will of Carnow: And in the year 1657. all the Suits of the Earl of Strafford, and his Agents, came to a full hearing: and after five days debate, from morning to night, before Chancellor (Steel) who did then Judge, that the Inheritance might belong to the Earl of Strafford; because of the fine and recovery past, although it were surreptitiously gained; and the Heir Male went forth of the Court, and refused to make out his Title; but the Court Judged that the Lease of 200 years did belong to William Eyre, in the right of his Wife; and therefore did dismiss the Countess of Carlisle, and the Earl of Strafford, and all his Agents, with their Suits, that had been four or five years standing in several Courts; and did declare, that the said Eyres should be kept still in Possession, in the right of his Wife (the Lease of 200 years belonging unto him.)  
Whereupon the Earl of Strafford's Agents produced the  Act of Parliament, for the strengthening of defective Titles, upon his Majesty's Commission of Grace of 400 and odd Manors (amongst which) Shelelah, and Chambres Estate, was foisted in, with a defective Title; upon which Chancellor Steel deferred his Jubgement, till the next Term, expecting the said Eyres, and his Wife's Cross-Bill, would come to a hearing.  
By the next Term the Earl of Strafford, and all his Agents put in a Plea to the said Eyres, and his Wife's Bill, renouncing all Titles, and Claims whatsoever, declared by the said Bill. And did challenge the Estate, by the Act of Parliament for strengthening defective Titles; upon which, though it never had the Royal Assent, nor was Recorded Judge Steel made a Decree, that the Earl of Strafford should enjoy the Possession of the Estate, not upon any Title, but only by that Act; and declares in his Decree, there is nothing to be considered but that: That is, whether it be a defective Title or not, and gave the Earl of Strafford Possession, till he was outed by due course of Law, or farther order of the Court: And did publicly blame Eyres' Counsel, for not bringing his Cross-Bill to hearing, with the Earl of Strafford's Suits; and told them that there was speaking of a Will, and an Inquisition, to prove that the Estate was no defective Title; and he did believe there were such things: but they had not appeared Judicially before him, and advised the said Eyres to Appeal to a Parliament, who would undoubtedly do him right in the thing, which he being of an Inferior Court, had not power to do.  
But the said Eyre's being, at that time, a Prisoner by Cromwel's order, for opposing the death of the late King aforesaid, could not look after his business: And was not released, until Richard Cromwell was turned out, and Ludlow sent over by the Long-parliament into Ireland: And within half a year afterwards was made Prisoner again for this occasion (as followeth) His Majesty being to be Proclaimed in Ireland in the year 1660. on the 18th. of May, the aforesaid Eyres' Wife, desired that she might rejoice with her Tenants for the Restauration of His Majesty on the day aforesaid; and invited six or seven hundred People to Feast, and ordered the said Eyres' Servants to carry ten Wain-load of Wood to a Hill, to make a great Bonfire.  
But the subtlety of his Adversaries who were in Possession of his Estate prevented it, that they might the more craftily prevent the said Eyres for Appealing to the Parliament in Ireland for recovering the Lease of 200 years abovesaid: And to that purpose, employing a particular Agent, one Floid a Welshman, to pry into the said Eyres' Actions; he brought feigned complaints against him (whereof one was that if they did not fetch the said Eyres away before the 18th day, he would be the head of a great Army to oppose the coming in of the King; whereupon immediately the Counsel of State sent five Troops of Horse and took the said Eyres out of his Bed, and carried him Prisoner to Dublin Castle, where he was most cruelly handled for sometime: afterwards hurried (from Prison to Prison) above Ten years' space, and sometimes neither Meat nor Drink suffered to come at him, but what was given in by stealth at a hole made under the door for the Cat to go in and out: And the Marshal being demanded by the Prisoners and others, the reason of so great Cruelty afflicted upon the said Eyres, his Answer was, that his Command was so strike that he did not dare to do otherwise; And did declare often that he had an Order to Starve the said Eyre's: At which time, all persons whatsoever were prohibited for coming at him. And his Wife was not suffered to come to him, yet at the same time some were admitted to serve him with Subpena's, to answer a Bill in Chancery, through the Combination of Alixander Temple, and the now Earl of strafford's Agents: And for Contempt to the Court, Chancellor Hustes grants an Injunction, and turns the said Eyre's Wife and his Family out of doors of the Rannalaws too, and they had utterly Perished if good people had not Relieved them, although the said Eyre's his Counsel did proffer his Oath that the said Eyres did not make any Contempt, neither was he in any Capacity so to do: Upon which Injunction the said Eyres and his Family hath been ever since kept out of the Possession of the said Rannalows, which was pretended to be Purchased for the use of Mr. Chambre aforesaid, which Purchase was but a Lease of 500 years, and belongs really to the said Eyres in the Right of his Wife.  
But by Reason of the abovesaid Combination, The aforesaid Eyres, nor any one of his Family hath not since Received one penny profit thereof to this day, that he knows of: For his Wife Fainted in the Streets of Dublin (for Want and Died) Crying out her Daughter had broke her Heart since Eyre's Releasement out of Prison; And the said Temple & his Wife have the Benefit of all that the Earl of Strafford was to give for the Inheritance of Shelala, except one Five hundred pounds paid to Chambre of Minmore; although in truth the whole 13 thousand two hundred pounds which was to be given for Shelela, did belong to William Eyre in Right of his Wife as a Chattel (as i'th' hath been often declared by all the Judges in Ireland, for that there was no Land Purchased in Mr. Chambre's Life time: And the Judges did farther Declare, That what ever they Pay of the Purchased Money to any other, than to the said Eyres, they paid it in their own wrong) which caused the now Earl of Strafford to take a Bond of the said Temple, of twenty thousand pounds to save him harmless from the said Eyres, which that will not, nor cannot do (if Justice may be had) For Mr. Chambre's Daughter had a Seelected Portion of two thousand pounds, given her by her Father's Will, though now they would make her Heir of All.  
Oserve Mr. Chambers gave all his Lands to his Heirs Male, after the Death of his Wife, and to Calcot Chambers of Minmore, and his Heirs-Male; And that the Earl of Strafford at the hearing of Cause, Renounced all his Titles to Mr. Chambers Estate upon which the Inheritance Remains in the said Eyre's Wife, as well as the Lease of two hundred years, he having one only Child by her.  
For Calcot Chambre of Minmore sells to the said Eyre's his Wife and her then Husband for five hundred pounds by a Deed perfected under his hand and Seal, near a year after the death of Chambre of Carnow: Whatever was given in that Will, or by any other Grant whatsoever to the said Chambre of Minmore; And therefore that Chambre of Minmore hath no Right to the Premises.  
The said Eyre's seeing the Cruelty used to him and his Wife, and Family in his Imprisonment, brought himself to a Trial sometime since in Ireland by a Habe as Corpus, and was cleared by public Proclamation by the Judges of the Kings-Bench: But immediately, before he was clear of the Prison, there came an Order to another Marshal, more cruel than the other was, to take him into his Custody, and also an Order of High Treason: And foe four years and upwards he was brought to the Bar twice a Term, that he might know what this High Treason was; but the Attorney General put it off from time to time, insomuch that the Judges declared in open Court, It would light heavy somewhere at last, in keeping a man so long in Prison after he was cleared by Law. But His Majesty and Counsel being Informed of the Cruelty used to the said Eyres, granted an Order, That he should have the Benefit of the Law: Upon which Order the Judges brought him upon Trial; and finding nothing come against him, Cleared him the Second time by Proclamation. Which Troubles (he fears purposely occasioned) have been the only Cause why he had not sooner made his Address for Relief.  
Upon the Whole Matter Observe;  
1. That Calcot Chambre the Younger being Entitled not only to the Inheritance, but also distinctly to the Lease of 200 years (which could not be drowned by the Descent, because it was to operate to other Intents afterwards, as Payment of Debts, Legacies, etc.) And he by his Will having expressly given all his Chattels (wherein such Lease is included to his Wife, whom also he made Executrix) Eyres, by Intermarrying with her, become, and is Lawfully Entitled thereunto: Nor could the trusties Legally Assign it to any, without she and her Husband had Consented and Joined therein.  
2. That there appears only 500 ll. paid by the Earl, or his Agents, for this Vast Estate: out of which the present Earl, (though Ordered to the Contrary in the year 1661. till the Title were cleared) has made 3000 ll. per Annum ever since, merely of Wood growing thereupon.  
3. That the Earl, his trusties, or Agents can pretend no Title but by the Act of Parliament, because they have disclaimed all others on Record.  
4. That such pretended Act never had the Royal Assent: And was obtained on a most false Suggestion; the Premises being never any Defective Title, as by Inquisition upon Record doth appear.  
5. How tortiously, and by what Practices all the Pretences of Right and Possession were obtained; and that there is no Declaration of Uses on the said Fine and Recovery by young Chambre.  
Lastly, How long the said William Eyre's has been kept out of such his Right; What severe Imprisonments and Hardships, (chief, as he has good grounds to believe, on this occasion) he has suffered, and to what Extremities he is Reduced; with many other sad Circumstances, which will appear to the Judicious, in Reading this his Foregoing Case: The Truth whereof he 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 Respect) he should not have thus Exposed the same, lest he should seem to swoon the Memory of the Dead, or the Honour of the Living; Both which are much contrary to the Innocence of his Intentions, whose Design herein is only to set forth matter of Fact; without Aggravations, or unbeseeming Reflections: And he humbly hopes, since His Majesty in his late Gracious Speech to both Houses has given the World fresh Assurances of his great Zeal for the Preservation of Property; It may not be unseasonable for this poor Complainant to make his Addresses to His Majesty; and that most High and Honourable Court, in whose Power only it lies to Relieve him, For the Restitution of his Just Rights, so long detained from him.  
William Eyres.  
FINIS.