WILLIAM Ellis Esq; afterwards Sir William Ellis Kt. Borrowed of the said Mr. Smith Five Hundred Pounds, and for the Security thereof, Entred into a Bond Da­ted 12. January, 1686/7. of the Penalty of 1000 l. for the Payment of the said 500 l. on 16. October then next Ensuing, with a Warrant of Attorney to Confess Judgment thereupon.

Which Judgment not being Entred, and the Troubles coming on in that Kingdom, that Mr. Smith was forced to come into England, he did apply himself to Sir William Ellis for the said Money, or further Security for the same, who thereupon did by his Deed, Dated, 21 February 1688. Mortgage and Assign to the said Mr. Smith, Two Hou­ses in St. Georges-Lane, two Houses in Dames-Street, and One on Arran's-Key, which, with the Bond aforesaid, was all the Security he had for the said Money.

Soon after the Rout at the Boyne, there being a Commission of En­quiry for finding the Estates of several Persons concerned in that Acti­on, the said Deed of Mortgage was produced to the Court, and the same, being made out and Proved, was found by the Jury, and Return­ed so on the Inquisition, and thereupon, and pursuant to a Clause in the said Deed, Mrs. Smith did Enter into the said Houses, for securing as well the said Five Hundred Pounds, as for Satisfaction of the Arrears of Interest, which are considerable.

That several Sums have been expended in Repairing the said Hou­ses, whereof some lay Waste, and those that were Inhabited, were so much Ruined, and the Tenants Impoverished in the Troubles, that very little Rent could be received thereout; And when the Tenants came to be in a Condition to Pay something, several Judgments, Prior to the Mortgage, were Executed thereon, so that of the Rent of the said Houses, only Fifteen Pounds per Annum hath been received, and for these Two Years past the Tenants have refused to Pay any part of the Rent.

That Mrs. Smith Exhibited her Claim before the Honourable Trustees for Forfeited Estates, who were sensible of the Justice and Equity of her Case, and the Hardships she was under, having not any thing else left her for her Support and Maintenance; but could not Relieve her, by reason that the Act of Parliament for the Forfeitures took Place Eight Days before the Date of the Deed of Mortgage; The said Act Commencing the 13. of February, 1688. And the said Deed Eight Days after, viz. the 21. of the same Month, although the Money was really Lent, and Bond given near Two Years before.

Wherefore, It is humbly hoped, That the Honourable House of Commons will take this hard Case into their favourable Consideration, and Grant such Relief therein, as to their Great Wisdoms shall seem Meet.