THat having taken a Lease of a House in Pauls Church-yard upon the annual Rent 6 ^lb and two Capons, for which the said Higginson receiv'd the Rent, and gave Acquittances in his own name to your Petitioner, that after this, one Richard Hodgson Cosan to the said Higgison came out of Ireland and sealed a Lease of Ejectment upon the said House.

That then the Petitioner with some Witnesses, desired the said Higginson to defend the Ti­tle or produce his evidence, which he refused to do, but first said that he had nothing to do with the house nor this Petitioner, and at another time said that your Petitioner should enjoy his Right, and not be wronged of the said House;

That after this the matter was by consent put to Arbitration, but on his part, nothing was done in it: that there­upon your Petitioner exhibited a Bill in Chancery for relief against Higginson, Hodgson, and Steel. Steel then answered and declared that he had a Lease from Higginson, after this, Hodgson by his answer swore that he gave no autho­rity to Higginson, either by Letter of Attourney, nor any other way to let any Lease of the said House: but Higginson not answering stood out to a Proclamation of Rebellion untill Hodgsons departure (supposed back into Ireland) and then by his answer sweares that he had a Lease from Hodgson of the said House, upon payment of a 100 ^lb Fine, and a Pepper-corn yearly.

That then it came to a Hearing in Chancery, at which time Higginson feed Sergeants to arrest your Petitioner upon several feigned Actions, some of a 1000 ^lb and then by his Counsell pleaded that he would have defended his Title to the said House, but had no notice to defend it, and that it was a meer collusion between your Petitioner and one Iohn Elyas, and then thereupon it was ordered by the Court, that the Title should be tryed at Law for the main profits and dammages (& whose House it was) because Hodgson & Higginson had sworn point blanck one against the other.

That then your Petitioner and Higginson came again to Arbitration of the matter by friends, and were bound in 500 ^lb Bond to stand to the award of Mr. Richard Piggat Grocer, and another which also by Higginsons evil practi­ses came to nothing.

That thereupon your Petitioner gained the matter to be referred to Alder. Tichburn, & Alder. Vi [...] and others, but the said Higginson being summoned refused also to appear before them.

That then your Petitioner Indicted Higginson at Hixes-hall, for wilfull and corrupt Perjury, which Indictment was found by the Grand Iury, the Bench of Iustices thereupon issued forth a Warrant for Higginson, who was taken upon it and brought before Alder. Ireton, by whom he was bound over to the next Sessions upon his own Bond of 50 ^lb and his Security in 40 ^lb both which he forfeited on purpose to delay Iustice.

That thereupon the Bench granted another Warrant to your Petitioner, by which Higginson was also taken and brought before Alder. Tichburn by whom he was bound in a 100 ^lb Bond to answer at the next Sessions: Higginson thereupon by Certiorari removed the Indictment to the Crown-Office, where he and his Security was bound in two Bonds, the one of 80 ^lb and the other of 40 ^lb to bring the Cause to tryal next sitting after Michaelmas Term last past before the Lord Chief Iustic Glyn, which Bonds he in like manner also forfeited and where your Petitioner at­tending with 3 Counsell, and 14 Witnesses (upon promise the Cause should be tryed) the record not being brought by Higginson, the Cause was not tryed to your Petitioners very great dammage.

That the said Higginson being taken both by Sheriff Lawrence, & Sheriff Bateman upon severall amercements issued out of the Crown-Office, stood out and forfeited all to the Commonwealth, but at length made his appearance this last Midsummer Term, the Perjury by the Rules of Court would have been tryed, as in next Michaelmas Term; the Pre­misses honourably weigh'd, and for that by such potent unjust men, supported in their wickednesse by the corrupt practice of the Law) the just cause of the poor is destroyed, & the poor by them eaten up as they eat bread, and for that your Petioner by these impious practises is utterly ruined in his Estate, Credit and Calling, and his Wife and Chil­dren destroyed, and your Petitioner damnifyed above 500 ^lb.

In tender consideration whereof, and for that the said Higginson is now about the 27 ^th of Iuly last past deceased, having left a very great Estate.