TO the first, for that by their Charter of incorporation, the importation of beaten Gold and Siluer is restrained: They answere, That the importa­tion of beaten gold and siluer, wrought in papers is expresly prohibited by the statute of 1. R. 3. cap. 12. And the same being base stuffe, and deceitfull, was only vsed by Painters and Bookebinders: and such beaten gold and siluer as Cutlers vse in their trade, was neuer imported from forraine parts, but made by the Goldbeaters of London. If the Cutlers should vse any of the imported gold or siluer, the same were against the intention of the said statute of 1. R. the 3. Cap. 12. and also the statute of 5. Eliz. Cap. 7. made for the maintenance of handicrafts and manuell trades, amongst which the trade of gold-beating is to be numbred, for that the said foliate gold and siluer is made only with the labor of the single hand, by continuall beating of forraine bullion with a hammer of 18. pound waight.

To the second, for that they being vnder the number of 30. persons, haue obtayned by the meanes of M ^r. Doctor Eglisham, one of his Maiesties Physitians, a Charter of incorporation vnto themselues, for the sole making of gold and siluer foliate, and a proclamation prohibiting the importation of any such gold into this kingdome: and that they haue entred into agreement to pay and allow vnto Doctor Eglisham, and S ^r Henry Bretton, sundry summes of mony yearly for procu­ring the said Charter: For answere thereunto they say, That the mystery of gold-beating hath beene an ancient and setled trade, within this king­dome many hundred yeares; as by ancient Records ready to be shewed forth may appeare. And the said trade is of such vse, as the same is not to be abolished, and therefore it was lawfull for them to procure a Charter of incorporation, for good order and gouernment of their trade, and to pre­uent fraudes and deceipts, as it hath beene done for other trades within the City of London. And for such rewards or gratuities as they haue giuen for procuring thereof, the same hath beene out of their owne estates, and no more then other trades vpon their incorporations haue done. And deny all combination and confederacy or the procuring of any proclamation.

To the third, wherein the Goldbeaters are charged to spend or consume of the proper coynes or bullion of this kingdome, in making of the said foliate three or fourethousand pound per annü: For answer therunto they say, That they spend only forraine bullion to the value of two thousand fiue hundred pound, and no more, wherewith, all England, Scotland, Ireland, and Wales, are serued and furnished: And that it is expresly prouided by the Charter, that no English coyne or bullion shall be by them spent in making of the said foliate. And it is also prouided by the said Charter, That no free man of the sayd trade shall beate any gold before he hath entred into bond of siue hundred pound, in the Exchequer, not to spend or consume any english coynes or bullion in the said trade.

To the fourth, that the complainants, since the incorporation of the Goldbeaters, are inforced to giue higher rates & prices, then before they wre wont to pay for the sayd foliate gold and siluer. For answere thereunto they say, That it is prouided by the said Charter, that the same shall be sold at such reasona­ble prices as the same was sold for 20. yeeres past, hauing regard to the raising of his Maiesties Standard, and the said complainants are serued with the same vnder the said rate. For then they paid for a hundred of gold, 13. shillings 4. pence, and for a hundred of Siluer, 3. shillings 4. pence: at which time the rate of the Standard, for gold was three pound the ounce, and siluer, fiue shillings two pence the ounce. And the rate of the Stan­dard being now for gold 3. pound 14. shillings 6. pence, and for Siluer six shillings. The complainants pay to the goldbeaters for gold, not a­boue the rate of 15. s. the hundred; and for siluer not aboue 3. s. the hundred. And since the said Incorporation the gold & siluer foliate is more sub­stantiall, larger, and in all points more sufficient, then is was in former times. And the said Goldbeaters neuer threatned the complainants to raise the prices.

To the fift, for that the Goldbeaters confine the sale of the said gold and siluer foliate to one place which they call their hall: For answere they say, That it is prouided by the said charter of incorporation, for the avoyding of all base and deceiptfull stuffe, that the same should be brought to the Hall of the Goldbeaters, to be viewed, and there sold by the Wardens of the company for the ease and benefit of his Majesties subiects, that haue occasion to vse the same, And the said Wardens do make no priuate gaine to themselues.

To the Sixth, that since the obtayning of the said incorporation, the said foliate gold and siluer is made more thinne and deceitfull then the same was before. For answere they say. That the gold and siluer foliate made since the said incorporation, is as large and thicke and as pure substantiall and workman­like as the same was at any time before, and for the purenesse and goodnesse thereof is without all exception.

To the seuenth: Touching a supposed wrong done vnto one Spencer, a Gold-Beater, for troubling and arresting him, and for exhibiting a bill into the Star-Chamber against him, and some of the Complainants, for vexation sake. For answer they say; That the sayd Spencer was the first, that drew the whole Company to prosecute the obtaining of the sayd Charter, and was named one of the Wardens in the sayd Charter, and tooke the Oath appoynted by the sayd Charter, and agreed to beare his ratable part of the charge of passing the same, and afterwards to bring in his ratable part for a generall stocke for the whole Company, and also to attend at the Hall, with the rest of the Wardens, to view such worke as should bee brought in by the Company, and to serue such as came to buy gold and siluer leafe: And according to his sayd agreement, he became bound in seuerall obligations, of fiue hundred pound a peece, to the other fiue Wardens; and likewise the fiue Wardens, in the like bonds to him, to performe the like agree­ments. Howbeit, when the Charter was passed, the sayd Spencer, by the practice of the Complainants, denyed to pay his ratable part of the charge, of passing the Charter; or to bring in his rate for stocke, according to his bonds; or to giue his attendance at the Hall, as the rest did, and priuately wrought base and deceitfull stuffe, mixt with copper, and would haue deliuered the same into the Hall, for pure gold, which the rest of the Wardens refusing, he thereupon (contrary to his sayd oath) brake from his Company, vowing (as he had beene the principall meanes to procure the Charter) he would doe his best to ouerthrow it. And the said Spencer, through the abetment and incouragement of some of the said Complainants, did dai­ly endeuour, to draw diuers others of the Gold-beaters from their Company to ioyne with him: For which wrongs the Gold-beaters did, in a legall course, arrest the said Spencer vpon his bonds: And did likewise prosecute the said Bill in the Star-Chamber, against the sayd Spencer, and two of the sayd Cutlers and their wiues, for vnlawfull maintenance, practice, and confederacie, to destroy their sayd trade: Wherunto the Defendants did put in a Demurrer, which depends in reference.

To the eighth: That the sayd Charter, for incorporating the Gold-Beaters, is in the nature of a Monopolie. For answer they say. That it cannot be denied, but that the trade of the Gold-Beaters is very ancient, and of great vse, and therefore to incorporate the same, is very lawfull and conuenient. For the generall forme of the Charter, the same is agreeable with the ordinary forme of Incorporations of other Trades in London, and euery one of them may aswell be charged, with sauouring of a Monopolie, as this. If any clause in this Charter be against the Law, or to the preiudice of the Sub­iect, the same is voyd, and doth not binde. And the same (if any such be) may bee reformed, by renewing of the sayd Charter, and omitting such clause. But to dissolue the Incorporation, and to leaue the Trade without order and gouernment, were vtterly to destroy the same.

Whereof the sayd Gold-Beaters doe most humbly pray, that due consideration may be had.

The ground of the Complainants griefe is, by reason the Gold-Beaters are incorporated, and not vpon any other cause. For before their Incor­poration, the sayd rates and prices of Foliate Gold and siluer, were vnknowne to his Maiesties subiects. And the Gold-Beaters being but few in number, and their dwelling vncertaine, the Complainants buying the sayd Foliate gold and siluer of the Gold-Beaters, at base and low rates, did vent and sell the same in their works, at double and treble the prices they payd, and thereby enriched themselues, and impouerished the sayd Gold-Beaters. But since the Incorporation, the prices of the sayd gold and siluer Foliate, and the place of the sale thereof being certaine and knowne, the sayd Complainants doe feare (as there is iust cause) that the Nobility and Gentry of the Kingdome, and such others, as shall vse Foliate gold and siluer, will make their owne prouision, and see the same wrought. And thereby the excessiue gaines of the Complainants bee abated and brought downe. All which shall be auerred vpon oath vnto this honourable Assembly: For whose prosperity and honour the said Company of Gold-beaters daily pray.