❧ An Act for the settling and establishing of the Manor of Sundrish, alias Sundridge, with the appurtenances in the county of Kent, vpon Thomas Browker Esquire and his heires, against a Patent of concealment lately made and granted to George Fouch and Nicholas street and their heires.  
1o. MAriae, Sir Henry Isley Knight, seized in fee of the Manors of Sutton Valence, Brasted, and Sundrish in Kent, with diuers other Lands, was vpon his joining in Wyatts Commotion attainted of high Treason, and executed, and all the said Manors and Lands forfeited to the crown.  
1& 2 Phil.& Mar. all the said Manors and Lands were for 1000l. conveyed from the crown to William Isley his son in Fee under the fee farm rent of 22l. 12s. per annum.  
2 Eliz. William Isley( as surety for one Thomas bows) became indebted to the crown in 3644l. 18s. 4d. which was installed to be paid by 100l. per annum, half yearly.  
For security of this installed debt, William Isley, by fine and other assurances 3 Eliz. conveyed the said Manors to William marquis of Winchester( then Lord Treasurer of England) Sir Richard Sackuile Knight( under Treasurer) Sir Walter Mildmay Chancellor of the Exchequer, and diuers others( being of the queens learned counsel) and their heires, to the use of William Isley and his heires till default of payment were made of any part of the said installed debt contrary to the said installment, and vpon default, to the use of the crown till the said installed debt were levied out of the rents and profits, or otherwise satisfied; and then to the use of the said William Isley his heires and assigns.  
William Isley paid 1044l. 18s. 4d. of the installed debt( so as there remained onely unpaid 2600l.) but being then indebted to others in 10000l. and all his said lands being variously encumbered. And desirous to sell part of those lands for payment thereof, he by his dead dated 8. Febr. 14. Eliz. and enrolled in Chancery, absolutely released to the crown all his right, title, and demand to those Manors.  
The onely intention of this Release was to enable a freer fall for payment of his debts, by vesting the absolute fee in the crown, that so( the said 2600l. being secured to the crown) the purchaser might by an immediate conveyance from the crown haue a clear title discharged of all William Isleyes encumbrances( which were many) but was never intended for any further benefit to the crown then the payment of the said 2600l. as plainly appeareth by these reasons.  
First, the inheritance of those Manors so released, were then worth 8000l. at the least.  
Secondly, queen Eliz. 8. july next after( vpon a bargain between Willam Isley and sir Row. Hayward) by the aduise of the Lord Treasurer Burghley, and of the said Sir Walter Mildmay( a party to the said conveyance made 3 Eliz.) convyed all the said Manors to Sir Row. Hayward in fee, paying to the crown onely the said arrere( being 2600l. by 100l. per annum according to the installment; and after Isley and Sir Row. Hayward breaking off their bargain Sir roll. 11 Decemb. 15. Eliz. reconueied all the said Manors to the crown.  
Thirdly. 13. Decemb. 15. Eliz. being but two daies after the said reconueiance. queen Eliz. demised all the premises to Tho. guildford nominated and trusted for Isley. Habend. from Mich. before for so long as the same ought to remain in the crown for payment of the arrearage of the said installed debt, reserving 100l. per annum payable at the times in the installment limited. In which demise, guildford covenanteth to account yearly at the Exchequer for all the profits of the premises, and vpon every such account( the said Rent of 100l. per annum and his charges in collecting the rents and accounting allowed) to pay the residue to Isleyes creditors at the appointment of the Lord Treasurer and Chancellor of the Exchequer for the time being.  
Fourthly, William Isley being pressed with a debt to other persons of 10000l. and finding purchaser timorous to buy in regard of the many encumbrances, at the Parliament 18. Eliz. procured an Act whereby the said Lord Burghley, Sir Walter Mildmay, and diuers other persons of honour and eminency were authorised to sell so much of the premises as they should think fit, and with the money to pay Isleyes debts, wherein especial provision is made that no more of the said premises should be sold, but that there might still remain unsold lands of the clear yearly value of 100l. for payment of the arrere of the said installed debt. And there is one intent expressed in that Act, though not provided for in the body thereof, viz. that the overplus of the premises remaining, after the debts and duties paid, might remain to Isley and his heires. And by force of that Act, the said Manors of Brasted and Sutton valemce were sold, and are to this day under such sale enjoyed.  
William Isley enjoyed the residue left unsold, paid the said yearly rent of 100l. according to the said installment and the fee farm of 22l. 12s. per annum, and about 34 Eliz. died, and Henry Isley his son and heir entred into and enjoyed all the said Lands left unsold, duly paid both the said installed and fee farm Rent, till the whole installed debt of 3644l. 18s. 4d. was in Decemb. 39. Eliz. fully paid, and thereupon had his Quietus est under the Exchequer seal, reciting the said assurance of 3 Eliz. and that the said debt was then fully paid.  
Henry Isley 19 Eliz. was indicted for five Robberies committed 17 Eliz. and obtained his pardon 30 May 20 Eliz. of them and of all Outlawries then or after to be promulged for the same: and after his said fathers death, entred as his son and heir, enjoyed the Lands, and was during his life esteemed the true owner of them.  
25 Feb. 41 Eliz. Henry Isley made his last Will in writing, thereby devising the said Manor of Sundrish to jane his wife and her heires for payment of his debts, and for portions for Vrsula and Una his reputed daughters, and dyed in possession of the said Manor. jane entered thereinto and intermarried with William Meysey Esquire, and they for performance of the said Will, conveyed the said Manor to Williom Harlow in fee, who re-conueyed it to William Meysey and Robert Herle, and to the heires of Meysey, who for valuable consideration in money got assurances from Reginald Peckham( son and heir of Anne) and from Katherine Beeseley two of the sisters and coheirs of the said Henry Isley, of all their right in that Manor.  
Afterwards Hugh Browker the Petitioners Father for 2040l. purchased the same Manor of Meysey and Herle, not knowing of the said absolute release of 8 Febr. 14 Eliz. but being onely made acquainted with the other assurances of 3 Eliz. Guilfords Lease, and with the Act of 18. of Eliz. And was also acquainted onely with the said Pardon, and not with any the subsequent Outlawries. Hereupon, in confidence of the Title, the said Hugh Browker and the Petitioner haue bestowed above 2000l. more in building vpon the Manor. And the Petitioner then very young, was vpon the death and discent of the said Manor of and from his said Father many 〈…〉 his late majesty for the same Manor.  
That the Petitioner after his full age was enforced to compound with one Michael Blackwell another of Henry Isleys coheirs for his title to a ninth part of the said Manor, for which( in respect of the tenor) Henry Isleyes Will proved voided, and vpon that composition paid him 270l. and had from him a Fine, with other assurances with covenants for further assurance. Wherein one William Wise a councillor at Law was of council with Blackwell( as formerly he had been in his other svit against the Petitioner) and was privy to the composition and payment of the said 270l.  
That before this composition and payment, Wise( soliciting Blackwels said former svit against the Petitioner) had vpon search discovered the said absolute release of 8 Feb. 14 Eliz. and five several Outlawries of Henry Isley vpon the robberies aforesaid returned into the Kings Bench,& pronounced about 3 months after his pardon,& thereupon had drawn michael Oldsworth Esquire to procure a Patent of concealment dated 26 August. 22. Iat. whereby the said Manor of Sundrish with all the arrearages then incurred, were granted to George Fouch and Nicholas street and their heires in trust for Michael Oldsworth, which Patent Wise knew to be passed the great seal long before the Petitioners said Composition with Blackwell, but yet concealed it till the said 270l. was paid.  
Wise, presently after payment of the said 270l. advised Master Oldsworth to make entries vpon this Manor, and to bring an eiectione firm thereupon in the Exchequer, where, vpon the trial he produced the absolute Release( never before then heard of by the Petitioner) alleging the same to haue been made for the benefit of the crown onely, and not for any the ends or uses before mentioned, and thereupon had Verdict and Iudgement with a Cesset executie, till further examination of the cause.  
And Wise knowing the said Outlawries to haue been both subsequent to the Pardon, and in themselves apparently erroneous, and for those errors easily reuersable: for prevention thereof Master Oldsworth by his aduise hath procured Releases to the Patentees from Reginald Peckham( the foresaid Reginald Peckhams son and heir) contrary to his Fathers assurances and agreement, and from Michael Blackwell, contrary to his own composition and assurances aforesaid: and also Releases to his majesty from them, as heires to Henry Isley of all errors in the said Outlawries( the said Katherine Beeseley being dead without issue) and the said Blackwell since his said Composition, by the aduise of the said Wise, took letters of Administration of the goods of Henry Isley not administered by jane his Executrix deceased: and the said Blackwell as Administrator hath made other Releases of errors to his majesty, without any other consideration then to prejudice the Petitioner, the said Blackwell being a suitor to his majesty to accept those releases, whereby the Petitioner in point of privity is disabled to bring writs of Error either in the heires name, or as Administrator.  
That his majesty was graciously pleased to give way to the Petioners prosecution of writs of error as terretenant, who to his excessive charge sued out 5. several writs of error, and them prosecuted in the Kings Bench. But Master Oldsworth by aduise of Wise, hath brought 5. several writs under the great seal to command stay of further prosecution rege in consulto.  
That howsoever a pretence be made of his majesties profit by an increase of 20l. yearly rent in the said Patent, yet no part therof hath been ever paid, nor is it put in charge. But Wise for Master Oldsworth vpon tender of composition, hath offered to procure a discharge of that rent, so, as it is intended onely for their own private ends, not really for his majesties profit.  
That the Petitioner by the extreme charge of these suits is like to be impoverished, and by doubt in Law whether a Terretenant may maintain a Writ of Error, is in danger unjustly to be disherited.  
For prevention whereof, and discharge of the trust reposed in the Crown by Willi. Isley. It is humbly prayed, it may be declared, adiudged& enacted, that the said late queen by the true meaning of the said release, was to take no other benefit thereby then onely for satisfaction of the arrere of the said installed debt, being 2600l. and that after satisfaction of the said 2600l. then William Isley and his heires and assigns might haue and enjoy the said Manors, any thing in the said release to the contrary notwithstanding. And that the Outlawries shall be holden voided both in regard of the Pardon aforesaid, and for the apparent errors therein, and that the Petitioner and his heires may enjoy the said Manor of Sundrish against the Patentees, Reginald Peckham, Michael Blackwell, and Master Oldsworth, and every of them, and all claiming under them; and also against his majesty, his heires and successors claiming onely by the said absolute Release and attainders, and that no execution shall be had vpon the said Iudgement in the Exchequer. With a saving to his majesty of all right, except by the said absolute release and other assurances of William Isley, made for securing the said installed debt, and except by the attainders by the said Outlawries. And with a saving of right to all others except the Patentees, Peckam, Blackwell, and Oldsworth, and all claiming by or under them.