STAC 5/F9/17

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Court of Star Chamber:

Randall Fenwycke v Rauffe Lawson of Brough, Yorks Esquyre, Isaacke Witherington, Robt Dent, George Dent, Wm Dent, John Dent, John Strangwishe, Robt Spore, Edmonnd Whyte, Robt Barnes, Henrie Brigges, Gerrerd Richardson, John Smarte, John Arkell, Robt Anderson, Robt Atkinson, Andrew Tompson, Willm Lawson and Nicholas Fetherstone

Transcript: Dave King


Bill of Complaint of Randall Fenwycke, dated [tbc]:

To the Queenes moste excellent Ma[jestie]


In .... humble wise complayninge sheweth unto your moste excellent Ma[jestie] your highnes faithfull and obedient subiect Randall Fenwycke of NeweCastle uppon Tyne That whereas Robt Mitforde of Sighill in the Countie of Northumberland Esquyer and Henry Mitford of Newe[castle] afforesaid m[er]chant or thone of them were Lawfullie seised in there or thone of there demesne as of Fee of and In the Lordshipp and Mannor of Heaton w[i]th thapp[ur]tenances in the said Countie of Northumberland and of all the dem.... Lands Wastes mores & Common ... Lyinge w[i]thin the said Mannor & Lordshipp of Heaton afforesaid And alsoe of and in one greate waste more or Common ground Commonlie Called or knowne by the name of Heaton Banckes Lyinge w[i]thin a[nd] beinge p[ar]cell of the said Mannor & Lordshipp of Heaton & soe by all the tyme whereof the memorie of Man ys not to the Contrarie hath beene accepted Reputed & taken. And they the said Robt Mitford and Henrye Mitford or thone of them soe beinge of the said Mannor Lordshipp demesne Lands wastes moores & Commons and alsoe of the said greate more Common or waste groundes called Heaton Banckes w[hi]ch are p[ar]cell of the said Moore called Heaton More seised of suche estaite as afforesaid & beinge Resolved & p[er]sw[ad]ed that there was a myne of Cole to be found w[i]thin the saide ground w[hi]ch might be verie profitable and beneficiall for the Common welthe of the Countrie thereaboutes yf the same coulde be found out did p[ar]telie in consideracon that your saide subiecte shoulde s.... for and fynde out the said Cole Myne & p[ar]telie for and uppon other greate consideracons them thereunto movinge by there Indenture of demise Lease & grante bearinge date In or about the firste daye of Auguste Laste paste did sufficientlie and L[aw]fullie demyse & grante unto your said subiect aswell all the Cole Myne and Vayne of Coles Lyinge w[i]thin the saide more or Common called Heaton Banckes afforesaide & alsoe free Lib[er]tie to sincke Pyttes or Shaftes for the gettinge of C[o]les and alsoe Lib[er]tie to digge myne and gett Coles there & in ev[er]ie or anie p[ar]te & p[ar]cell of the same And alsoe sufficient waye Leaves and stayleaves in all or anie p[ar]te of the saide more or Common afforesaide To have and to holde unto your said subiect for a certeyne Ter[me] of Yeares yet endureinge By force whereof your saide subiecte into the saide more Common or waste grounde called Heaton Banckes afforesaide entred by himeself & his workemen s[er]vantes & helpers have digged & suncke Colepyttes And gotten Coles there to the greate [be]nefytte & p[ro]fett of the Common welthe aswell neare thereaboutes as alsoe in other places w[i]thin this your Ma[jesties] Realme of Englande unto w[hi]ch the saide Coles there gotten are Carryed and transported by Water daylie in greate plentie And whereas alsoe your sa[id] subiecte Together w[i]th dyv[er]s .... workemen s[er]vantes and factors in that behalf aswell in and uppon the Eighteenth daye of december Laste paste as alsoe uppon the seacond daye of Januarie and uppon the Twelffe daye of Januarie Laste paste did In there usuall & accustomed manner Repayre them selves unto or neare suche Colepyttes and places w[i]thin the saide mores or groundes called Heaton Banckes as where they were soe sinckinge digginge for or digginge of Coles and where they all beinge then in gods peace & your highnes, were workinge or Aydinge assistinge or helpinge the workeme[n] to worke in Rulinge or Removinge of greate stones wyndinge of Coles earthe and water and other necessarie busines to be doone about the same worke suche as was needefull and that in verie quyet and frenndlie manner and w[i]thout anie intent unlawfullie to hurte p[re]iudice or hinder anie p[er]son or p[er]sons whatsoever and w[i]thout anie force or violence by them or anie of them used or p[re]tended Nowe soe yt ys if it may please your moste excellent Ma[jestie] That one Rauffe Lawson of Brough w[i]thin the Countie of Yorke Esquyre envyinge & malycinge the good & p[ro]sperous estaite of your saide subiecte and the benefytte w[hi]ch by meanes of the said Coles thereby your said subiecte [?founde?] & gotten Came not onelie unto your said subiecte but alsoe unto the whole common welth & meaninge maliciouslie to overthrowe the same did most unlawfullie and undutifullie Combyne compacte and confederate hime self together w[i]th one Iseacke Witherington Robt Dent George Dent Wm Dent John Dent John Strangwishe Robt Spore Edmonnd Whyte Robt Barnes Henrie Brigges Gerrerd Richardson John Smerte John Arkell Robt Anderson Robt Atkinson Andrew Tompson Willm Lawson and Nicholas Fetherstone Conspyringe Complottinge devysinge practysinge and purposinge w[i]th them and by there meanes by force and stronge hande and in verie outragious desperate and Barbarous manner to murder kill or mayhen your said subiect and his said workemen s[er]vantes factors & Frennds w[hi]ch whould soe Labor or goe about to digge or gett Coles there and consequentlie by meanes thereof and by suche Terror and extremitie to enforce your said subiect to gyve over his said workes there Thereby meaninge to intytle hime the saide Rauffe Lawsonn by some p[re]tence or pretended tytle in & to the said more or more groundes called Heaton Banckes and to the Colemynes soe by your said subiecte firste founde there And in p[er]formance of suche there unlawfull Conspiracie complott devyse practyse & purpose They the saide Isaacke Witherington Robt Dent George Dent Willm Dent John Dent John Strangwishe Robt Spore Edmonnd Whyte Robt Barnes Henrie Brigges Gerard Richardson Andrewe Tompson John Smarte John Arkell Robt Anderson Robt Atkinson Willm Lawson and Nicholas Fetherston and dyv[er]s other Lewde outragious and evill disposed people dwellinge in Northumberland In or neare the Border of England againste Scotteland and alsoe dyv[er]s Scottishemen dwellinge within the borders of Scottland whose names are yet unknowne unto your saide subiecte To the number of Fortie p[er]sons and above the w[hi]ch hee the saide Rauffe Lawson at and by his speciall meanes and procurem[en]t hadd assotiated and joyned in assistance of the reste of the p[er]sons before named at and by the speciall Instigacon and p[ro]curem[en]t of hime the said Rauffe Lawson and by his speciall appointm[en]t concent privitie and Comanndm[en]t beinge all of them Armed and Arrayed in warlike manner That ys to saye w[i]th swordes daggers Billes halbertes Bowes and Arrowes pistolls and other Gunnes then readie Charged and bent Longe Pyked Staves and dyv[er]s other weapons aswell invasive as defensyve not havinge the feare of god before theire Eyes nor wayinge nor Regardinge your Ma[jesties] good and wholesome Lawes and Statutes of this your highnes Realme moste prudentlie and Carefullie provyded & maide againste Routes Ryottes and other unlawfull assemblies and the Ayders & p[ro]curers thereof but Wittinglie and Willfullie Incurringe into the breache and transgression of the same of there owne p[erv]erse and evill nature did In & uppon or neare about the xiiijth daye of december Laste paste and sithence your ma[jesties] moste gracous Laste generall p[ar]don moste Ryotouslie forcibly unlawfullie & in Warlike manner assemble them selves together in manner of an Insurrection aggregatinge and gatheringe into there Companie all suche Lewde p[er]sons as hee the saide Rawffe Lawson Coulde by anie sinister meanes by hime used p[ro]cure att in & uppon the saide more called Heaton Banckes afforesaid or neare unto the Colemyne afforesaide And they soe beinge then and there assembled armed and Arrayed and knowinge before hand that your said subiect his workemen were then in Laboringe and digginge for & gettinge of Coles did then and there in Like Ryotous outragious warlike manner marche as though yt hadd beene in Battell array towards and unto the place where your said subiect his saide s[e]rvantes and workemen then beinge in the peace of god & of your ma[jestie] and not meaninge or purposinge anie hurte or violence to .... neyther fearinge anie to be donne unto them were then in digginge for & gettinge of Cole And thereuppon fyndinge your said subiecte his s[e]rvantes and workemen at there Labor and worke & altogether unprovyded eyther to make anie Resistance un[to] the saide Ryotors or defence for the safetie of there owne p[er]sons the saide Isaacke Wytherington George Dent Willm Dent John Dent John Strangwishe Robt Spore Edmonnd Whyte Robt Barnes Henrie Brigges Gerrerd Richardson Andrew Tompson John Smart John Arkell Robt Anderson Robt Atkinson Willm Lawson Nicholas Fetherstone and other there saide conf[ed]erates & assotiates the Ryotors afforesaid uppon a like ma...ious meaninge Towards your said subiect & by and accordinge to theffe.. of suche there saide Compacte conf[ed]eracie practise and conspiracie afforesaid & at & by the speciall comanndm[en]t concent & p[ro]curem[en]t of hime the said Rauffe Lawson & by his privitie did then and there in & uppon or neare aboute the same daye ......... your ma[jesties] said Laste gen[er]all p[ar]don in moste Ryotous Rowtous outragious Barbarous and desp[er]ate manner havinge there bowes & Arrowes pistolls & gunnes alreadie aforehand Bent & ...vyded againste your said subiecte his saide s[e]rvantes and workemen sett uppon assalte & beate wounde & evell intreate your said subiecte his said s[e]rvantes & workemen and ... shoote Arrowes at them and discharge there pistolls and gunnes against theme and therew[i]th and w[i]th other there weapons did gyve unto your subiecte his saide s[e]rvantes and workemen manie and dyv[er]s greevous and deadlie woundes And therew[i]th did .. descorage & discomfor.. them that they did greatelie despaire of there Lyves and yet doe Langwish of suche hurtes as they then Receyved And the further to shewe their desp.... C..we... intent did moste Barbarouslie d........ the tyme of the ...rage or fight ....... as afforesaid Encourage ... another And p[ro]teste & confidentlie vowe & swere one to another to kill and not to suffer anie to escape w[i]th Liffe w[hi]ch the........ or thereafter should .. the ...te to gett Coles there by or ................. your said subiecte to the greate descurragem[en]t of your said subiecte and the manifeste Breach and Contempte of your highnes Lawes And yet not soe contented w[i]th such outrage soe by them Comitted as afforesaide although your said subiecte hadd well p[er]suaded himeself that hee the said Rauffe Lawson and the saide Ryotors afforenamed whom hee hadd soe Chosen or his Champyons woulde have beene [?sorie?] (uppon better consideracon thereof taken) for suche Fowle outrage soe by them Comitted and thesforth have quyetlie suffered your said said subiecte to have digged and gotten Coles there accordinge to his said Righte & uppon that p[er]suasion did afterwardes send suche workemen as hee could p[ro]cure to gett Coles there for the necessarie servinge of the Countrie hee the saide Rauffe Lawson and others his saide confederates afforesaid not contentinge them selves w[i]th there form[er] outrage but p[er]ceyvinge that your said subiecte uppon a willinge mynde to have Imbraced peace did seme to oversee suche there misdemeaner & by meanes thereof mistakinge the good meaninge of your said subiect therein and thereby growinge insolent they the said Wytherington George Dent John Dent Henrie Brigges & other the saide Ryotors & evill disposed p[er]sons affore named beinge all of them Armed & arrayed w[i]th such Like weapons & in suche Warlike manner as afforesaide In & uppon or neare aboutes the seacond day of Januarie nowe Laste paste and sithence your highnes Laste generall p[ar]don at w[hi]ch tyme your said subiecte hadd sent his servantes & workemen unto the said Cole mynes to digge & gett Coles there accordinge to his good & iuste tytle thereof & therein did seacondlie in Like moste forcible undutifull warlike outragious & unlawfull manner & at & by the unlawfull [?Causage?] Comanndm[en]t concent & p[ro]curem[en]t of the said Rauffe Lawson or by his privitie assemble them selves together in manner of an Insurrection at In & uppon the saide more or more growdes called Heaton Banckes afforesaide or neare unto the Colemynes afforesaide And th...... beinge then and there assembled armed and Arrayed as afforesaide and knowinge beforehand that your said subiect his workemen were then in Laboringe .. digginge for & gettinge of Coles did then & there in like Ryotous outragious warlike & forcible manner march as thoughe yt were in Battell arraye towardes and unto the place where your said subiecte his said servantes and workemen then beinge in godes peace [&] your ma[jesties] and not meaninge or purposinge anie hurte or violence to anie nether fearinge anie to be doone unto them were then in digginge for & gettinge of Cole And there fyndinge your said subiecte his saide servantes & workemen at there Labor in for[m]e afforesaide They the saide Isaacke Witherington George Dent John Dent Henrie Brigges and other there confederates & assotiates the Ryotors afforesaide uppon a Like malicous meaninge [to]wardes your said subiect by & accordinge to theffecte of the saide foreintended practise & confederacie & at & by the speciall comanndm[en]t consent & p[ro]curem[en]t of hime the saide Rauffe Lawson and by his privatie did then and there vid in or neare about the same daye and since your Ma[jesties] said Laste generall p[ar]don in like Ryotous outragious forcible and desp[er]ate manner havinge there bowes & Arrowes [pistolls] & gunnes then alreadie beforehand bent & p[ro]vyded againste your said subiect his saide servantes & w[or]kemen Sett uppon assault beate wound and evill intreate your said subiect his saide servantes & workemen and did shoote Arrowes at them and disch[arge] there pistols and gunnes againste them & therew[i]th and w[i]th other there weopons did gyve unto [your] said subiecte his saide servantes & workemen manye and dyv[er]s greevous & deadlie woundes & did soe discurrage & discomforth them there[by] that they did greatel.. dispaire of there Lyves & yet doe Languish of suche hurtes & woundes as they then receyved Addinge further threatninges & vowes that woulde [ki]ll [?mahen?] or wounde whosoev[er] shoulde gett anie Coles there for your said subiect & did alsoe at the same tyme vyolentlie and wrongefullie take from your said subiecte his servantes & breake in sunder all ...he weopons & engynes as wherew[i]th your saide subiecte his saide workemen did Labor for the gettinge of Coles And yet not therew... contented but p[er]ceyvinge that your said subiect did likewise quietlie tolerate & woulde have tollerated the same in hope that .. quietnes hee might have woone there malicious myndes to peace & uppon that purpose Continewinge in verie quyett & peaceable manner [g]ett Coles & by ....... of suche tolleracon growinge ... exceedinge greate insolencie They the saide Isaacke Witherin[gton] George Dent John Dent Henrie Brigges & other the saide Ryotors & evill disposed p[er]sons afforenamed beinge all of them armed & .......ed w[i]th suche Like weopons & in suche warlike manner as afforesaide In & uppon or neare aboutes the xijth [da]ye of Januarie nowe laste paste at w[hi]ch tyme your said subiect hadd sent his servantes & workemen unto the saide Colemynes to digge and .... Coles the.. did seacondlie in like moste forceblye undutifull warlike outragious & unlawfull manner & at & by the unlawfull causinge comanndm[en]t consent & p[ro]curem[en]t of the saide Rauffe Lawson or by his privitie assemble them selves together in manner of .. [In]surrection at In & uppon the saide more or more groundes called Heaton Banckes afforesaide or neare unto the Colemynes a[ff]oresaide And they soe beinge then & there assembled armed & arrayed as afforesaid & knowinge before hannd that your said subiect his work[emen] were then likewise in Laboringe & digginge for & gettinge of Coles did then and there in like Ryotous outragious War[li]ke & forcible manner march as though yt were in Battell Arraye Towardes & unto the place where your said subiect his said servantes [w]orkemen then being in gods peace & your Ma[jesties] were then in digginge for & gettinge of Cole & there fyndinge them at [th]ere Labor The saide Ryotors & evill disposed p[er]sons uppon a like malicious meaninge towardes your said subiect by & accordinge to theffecte of the said fore intended practyse and confederacie & at & by the speciall comanndment concent & p[ro]curem[en]t of hime the saide Ra[uffe] Lawson & by his privitie did then and there vid in or neare about the said xijth daye of Januarie Last past & sithence your Ma[jesties] sa[id] [la]st gen[er]all p[ar]don in like Ryotous outragous forcible & desp[er]ate manner havinge there bowes & Arrowes pist[ols] & gunnes then alreadie beforehand bent & p[ro]vyded againste your said subiect his saide servantes & workemen sett uppon assault beat [wou]nde & evill intreat your said subiect his saide servantes & workemen & did shoote Arrowes at them and discharge [the]re pistols & gunnes againste them & therew[i]th & w[i]th other there said weopons did gyve unto your said subiect his saide servantes & [worke]men manye and dyv[er]s greevous & deadlie wounds & did soe discurrage and discomforth them thereby that [th]ey did then greatlie dispaire of there Lyves & did Likewyse breake in sunder all suche worke..omes & Engynes as where w[i]th ... ..de subiect ...... were then workinge And yet not so contented but still p[er]sistinge in there like malicious mean... againste your said subiect They the saide John Smarte John Arkell Robt Anderson Robt Atkinson Willm Lawson Nicholas Fe.....ton Isaacke Witherington Robt Dent George Dent Willm Dente John Dent John Strangwish Ro.. Spore Edmonnd Whyte Robt Barnes Henrie Brigges Gerrard Richardson Andrewe Tompson & other the saide Ryotors & ....... p[er]sons afforesaid beinge all of them armed & arrayed w[i]th suche like weopons & in suche like warlike manner [as] afforesaide In & uppon the xiijth & xiiijth dayes of Januarie Laste paste & at dyv[er]s & sundrie other dayes & tymes sithence In the month of Ja....... laste paste at & uppon w[hi]ch said sev[er]all dayes your said subiecte hadd sente his servantes & workemen unto [the] saide Colemynes to digge & gett Coles there did in like most forcible undutifull warlike & outr[agiou]s manner & at & by ........ caus[ing] ........................... p[ro]curem[en]t of the [said] [Rau]ffe Lawson or by his priv[itie] [ass]emble them selves tog[ether] in .......... an insurrection at or ne[are] .... the Colemynes in Heaton [Banc]kes afforesaid And ............... beinge then & there .............................................. uppon a like ....... ...ninge towardes your saide ..................... & accordinge to the ..................... affore intended prac.... ....... [conf]ederacie & at & by ......................... comanndm[en]t ............................................ of hime the ......................................................... dayes laste before men[coned] ............................ your Ma[jesties] said Laste .......................... ...otous outra[gious] ................. desp[er]ate m....... ............................ bowes & .............................................. gunnes ....................................................... & workemen sett ............................................ wounde & evill ................................... [subiec]te his said ..................... [work]emen then ..................................... & your m....... ............................................................................. there weop[ons] ............................ subiect his ........................................................................................................................... [remainder lost or destroyed]


Answers of Robert Dent, George Dent, John Dent & John Stranguishe, dated 19 May 38 Eliz:

Jur: 19 May Ao 38 Elizabeth Regne Willm Mill

The Joynt and sev[er]all Annsweres of Roberte Dent George Dent John Dent and John Stranguishe defts to the false and slannderous Bill of Complt of Randall Fenwicke Complt


The said Defts savinge to themselves at all tymes hereafter all advantages of Exception to the Insufficiencie of the said Bill aswell for that the same bill as they by there Counsell ar informed ys uncerteyne in the materiall p[ar]tes therof & title claimed by the Complt as for that the effectuall matters therin conteyned as the same ar sett forthe in the same bill ar not punishable & determinable in this honorable court & for yt alsoe that aswell the said Complt as thes defts ar comorant and doe Inhabit and dwell w[i]thin the p[re]cynct of the Commission established in the North p[ar]tes where the same arr most aptlie determinable sayethe yt the said bill of Complt & the materiall matters & thinges therin conteined w[hi]ch doe conc[ern] these defts or the most p[ar]te thereof ar uniust & untrue devised and set forthe of mallice & purpose to put the[m] & others in the bill named to uniust chardges and expences & to the intent to Crosse and staye the said Raphe Lawson in his p[ro]cedinges against the Complt & others for manye great & outragious Ryotes & misdemeanures wherof the said Raphe hath compleyned in this honorable Court against the said nowe Complt & his Complices w[hi]ch suyt dependethe in this honorable court at & before the tyme of the said bill exhebited wherof thes defts hope yt this honorable court will have dewe consideracon neverthelesse for full annswere to ye materiall contentes of the said bill thes defts sayen and ev[er]ye one for himselfe sev[er]allie sayethe as to the Ryotes Rowtes unlawfull assembles Ryoteous assaulting batt... and other the misdemeanures in ye bill of Complt named & alledged to have bene done by thes defts that they these defts arr thereof not guiltye in such sorte manner and forme as in the said bill ys most untruelie & falslie surmised & alledged and yet for more full and better ...ifestation of ye truthe towcheinge the same thes defts sayen yt one Edmonde Lawson father to ye said Raphe Lawson in the bill named was lawfullie seized in his demeasne as of fee or fee taile of & in the manor of Byker in the countye of Northumberlande wherof one great moore common.. called Byker Moore w[i]thin the said countye of Northumb[erland] in w[hi]che the said Raphe Lawson hath caused certeine cole pyttes to bee sunck & digged & in w[hi]ch he hath gotten Coles ys p[ar]cell and soe hathe bene accompted reputed & taken & w[hi]ch these defts thinke ys the same wast moore of common grounde p[re]tended by the Complts to be called Heaton Banckes in the bill menconed and that he the said Edmonde Lawson soe beinge therof seized dyed therof soe seized by and after whose deathe the said mannor and p[re]misses discended & came as ye same of Right ought to discend & come to James Lawson .. sonne & heire of the said Edmonde by force wherof the said James was therof lawfullie seized & dyed therof soe seized by and after whose deathe the said mannor & p[re]misses discended and came as of right the same ought to discende and come unto the said Raphe Lawson as brother and heire of the said James, by force wherof the said Raphe entred into the said mannor and p[re]misses & was therof lawfullie seized in his demeane as of fee or fee taile accordinglie And he being therof soe seized hath by diverse & manye yeares together peaciablie & quietlie occupyed & enioyed the same and taken Re[cei]ved and enioyed ye Rents ysuues and profyttes therof and the said Raphe hath caused to be digged suncke and wrought Cole mynes and Cole pittes in the same moore & therin gotten and obteyned coles a good tyme before the Complt or those by whome he claimethe did p[re]tend anye title therunto and these defts further sayethe that they will [?aur?] and hope they shalbe well able to p[ro]ve that the said moore and grownd wherin the said Ryotes by the said bill ar supposed to have bene maide ys commonlie called and knowen by the name of Byker Moore and ys p[ar]cell of the said mannor [of] Byker & soe hath bene accompted reputed and taken tyme wherof the memorye of man ys not to the contrarye and not Heaton Banckes nor anye p[ar]cell of the p[re]tended mannor of Heaton in the Bill named & as concerninge the Ryotes and other the misdemeanures supposed and alledged have bene Committed by these defts the eightenthe daye of December in the bill named these defts doe saye yt at the said daye & at diverse tymes before the said Complt and dyverse others Ryoteous p[er]sons have unlawfullie & forcyblie entred into the said moore called Byker Moore p[ar]cell of the mannor of Byker & had then and theire committed outragious Ryotes & other misdemeanures [?contynuyng?] there forcyble Ryotes and outrages w[i]th such violence as Informacon was gyven therof to the Right honorable the Lo[rd] Ewrye Lo[rd] Warden of the Middle Marches of Englande for and against Scotlande and his Lo[rdship] beynge therof Informed thinkinge good to p[re]vent suche mischeife as by the same was like to Insewe did wryt his l[etter] to the said Complt and other Ryoteous p[er]sons as thes defts doe take yt & thinke they shalbe able to p[ro]ve to leave there force and to Repaire to his Lo[rdship] yt he might take order therein and w[i]thall did wryt one other l[etter] to Robte Dallavel and Henrye Anderson Esquires Justices of peace in the said Countye dwellinge as thes defts take yt next to the same place where the said Ryotes were Committed to remove the said force & did for quietnes sake adv... the said Robte Dent one of these defts first to trye if the said Complt and other Ryoteous p[er]sons would obey his warrant or Request to leave there force & if not then to deliv[er] his other l[etter] to the said Justices wherupon these defts and some others in ther companie repaired to the said More [c]alled Byker Moore and there fyndinge the said Complt and manie other Ryoteous p[er]sons in the said moore weaponed & armed in forcyble and warlike manner to the number of 13 or 14 the l[etter] or warrant from the said Lo[rd] Warden was deliv[er]ed to the Complt, but he seamed [?at the first?] to make some accompte therof makinge shewe yt he would notw[i]thstandinge the same continewe his forcable and outragious Ryotes & misdemeanures but the said Robert Dent deliv[er]ed the said l[etter] directlie to the said Justices to be deliv[er]ed unto them wheruppon the said Complt and his Ryoteous associates dep.... noe hurte then done to them or anye of them to thes defts knowledge althoughe by dyverse meanes the[y] [d]id seeke to co[m]pell thes defts to breake the peace w[hi]ch they al...aes hadd a speciall regarde to p[re]serve And as concerninge the other Ryotes and misdemeanures in the Bill menconed wherw[i]th these defts ar chardged this deft Robte Dent for himselfe sayethe tha[t] [th]e said Complt did at dyverse tymes and daies after the saide the said 18th daie of December p[ro]cure diverse p[er]sons to make Ryoteous and forcyable entryes into the said Byker Moore he himselfe and others beinge Redye at or neare to the said moore to assist them in the Ryoteous attemptes this deft Robte Dent in Right of the saide Raphe Lawson and by his Consent he then dwellinge farr distant from the Countye of Northumberlande did at diverse tymes and namelie the sayde 12 13 and 14 of Januarye last when the said Complt and dyverse other ..otorious Ryoteous p[er]sons or diverse other p[er]sons by the Complts ......m[en]t and p[ri]vytie he the said Complt and dyverse other Ryoteous p[er]sons beinge at or neare to assist them in there unlawfull and Ryoteous entryes and outraiges committed in Byker Moore did sende two of his servantes to u..dge suche woorkmen as the Complt had wrongfullie set on worke in the said Byker Moore and to will them to dissist and leave of there unlawfull attemptes and outraiges but the said p[er]sons w[hi]ch was so sent by this deft Robte Dent beynge Resisted threatned and at dyverse of the said daies evile intreated by this Complt or his Ryoteous Confiderates they dep[ar]ted as this deft verilie takethe yt w[i]thout doinge anie the hurtes or outrages in the Bill menconed in suche manner and forme as in the said bill ys alledged, w[i]thout that, that the [said] Complt & his woorkmen s[er]vantes and helpers have digged and suncke Colepites and gotten Coles in Heaton Banckes to the benifitt and p[ro]fytt of the Common Wealthe as in the Bill ys alledged, Or that the said Complt w[i]th diverse his workmen s[er]vantes and factors upon the eightenthe day of December last past and alsoe upon the seconde daye of Januarie and upon the Twelvthe daye of Januarye last past did in there usuall and accustomed manner lawfullie repaire themselves unto or neare suche Cole pyttes and places w[i]thin the said moores and growndes called Heaton Banckes as they were soe sinckinge digginge for or gettinge of Coles and were there workeinge aideinge helpeinge or assistinge there workmen to woorke in Rolinge or removeinge of great stonnes wyndinge of Coles earthe and water and other necessarie busines .... done about the same woorke suche as was needfull and that in freindlie manner and w[i]thout Intent unlawfullie to hurt p[re]iudice or hinder anye p[er]son or p[er]sons whatsoev[er] and w[i]thout anye force or violence by them or anie of them used or p[re]tended as in the said Bill of Complt [is] surmised & untrulie alledged Or that the said Raphe Lawson of Broughe in the Countye of Yorke Esquire envyinge and malycinge the good and p[ro]sperous estaite of the said Complt and the benifitt w[hi]ch by meanes of the Coles there by the Complt p[re]tended to bee founde and gotten and .... not onelie unto the said Complt but alsoe to the Common Wealthe meaninge to ov[er]throwe the same did malitiouslie and unlawfullie Combyne compact and confederate himselfe togeather w[i]th Isaack Witherington and w[i]th Robte Dent George Dent Willm Dent John Dente John Stranguishe the[se] defts and Robt Spore Edmund Whyte Robte Barnes Henrye Brigges Gerrarde Richardson John Smert John Arkell Robert Anderson Robte Atkinson Andrewe Thompson Willm Lawson and Nicholas Featherston Conspiringe Complotinge devisinge pra[cti]singe and purposinge w[i]th them and by there meanes by force and strong hande & in verie owtragious manner to murther kyll or maime the said Complt his said workmen s[er]vantes factors and freindes w[hi]ch should soe laboure or goe about to digge or gett Coles in Heaton Bankes in the bill mentioned and by meanes therof and [?terrors?] to Inforce the said Complt to gyve ov[er] his said woorkes thereby meaninge to entitle himselfe by some p[re]tence or p[re]tended tytle in and to the said moore or moore growndes called Heaton Banckes and to the Colemynes so by the said Complt p[re]tended to bee fy... ..ounde there as in the said Bill ys most falslie and slannderouslie surmysed and and p[re]tended Or that the said Raphe Lawson unlawfullie Comploted Conspired devised practised or purposed w[i]th these defts and w[i]th the said p[er]sons in the Bill named or anye other evile dispos[ed] people dwellinge [in] Northumberland in or neare the Borders of Scotland and alsoe w[i]th div[er]se Scotishe men dwellinge w[i]thin the borders of Scotlande to the number of fortye p[er]sons and above w[hi]ch he the said Raphe Lawson and by his specyall meanes and p[ro]curement had assocyated and ....ed in assistance .. the Rest of the p[er]sons in the Bill before named at and by the specyall Instigacon and p[ro]curem[en]t of him the said Raphe Lawson and by his speciall p[ro]curem[en]t Consent p[ri]vitye and Commanndment beyinge all of them armed and arrayed in warlike manner viz ... swoordes Dagger Billes and suche unlawfull weapons as in the said Bill ys sett forthe and falselie alledged ................................... aboute the xviijth daye of December last past and sythence your Ma[jesties] most gratious gen[er]all p[ar]donne most Ryoteouslie forciablie unlawfullie and in warlike manner assembled themselves togeather in manner of an Insurrection aggregatinge & gatheringe in to there Companies all such lewde p[er]sons as he the said Raphe Lawson by .... sinister meanes by him used .... at in and upon the said moore called [Heaton] Banckes neare unto the Colemynes aforesaid and yt they soe being then & there assembled armed and arrayed and knowinge beforehand that the Complt his workmen were then in laboringe and digginge for and gettinge of Coles did then and there in like Ryoteous & unlawfull manner [ma]rche as thoughe yt [h]ad bene in battle arraye towardes and unto the place where the Complt his s[er]vantes and workmen were then in digginge for and gettinge of Coles in the grownde in the Bill menconed and therupon findinge the Complt s[er]vantes and workmen at ther laboure and worke and altogeather [un]provided eyther to make anye Resistance unto the said Ryotes or defence for the saiftie of there owne p[er]sons did then and there in and upon or neare about the same daye in most Ryoteous outragious barbarous and desperat manner haveinge there bowes and arrowes pistolls and gunnes all redye beforehande bent and p[ro]vided againste the said Complt and workmen did set upon assault beat or wounde the Complt his said s[er]vantes and workmen or did shoote arrowes at them and dischardged there pistolls and gunnes against them and w[i]th other ther weapons did gyve unto the Complt his s[er]vantes workmen manie grevous and deadlie [?woundes?] and therew[i]th soe discorage and discomforte them that they did greatlie dispaire of there lyves and yet doe languishe of suche hurtes as they then Received in suche manner and forme as in the said Bill ys most falslie Slannderouslie and malitiouslie surmised Or yt they did p[ro]test vowe and weare one to another to kyll & not to suffer anye to escape w[i]th lyfe w[hi]ch then did or should attempte to gett Coles there by or under the tytle of the said Complt to the great discoraigment of the said Complt or that thes defts contente... suche outraige soe by them committed as aforesaid p[er]ceivinge yt the said Complt upon a willinge minde to have imbraced peace did seame to ov[er]see suche ther misdemeanures & by meanes therof mistakinge the good meaninge of the Complt therein and therby growinge insolent beynge armed and [arr]ayed w[i]th suche like weapons and in suche warlike manner as in the bill ys alledged in and upon or neare about the second daie of Januarie nowe last past at w[hi]ch tyme the said Complt had sent his s[er]vantes and workmen unto the said Colemynes to digg and gett Cole there accordinge to ... good and Just tytle therof and therin did secondlie in like most forcible undutifull warlike outragious and unlawfull manner & at and by the unlawfull causinge & commanndment Consent and p[ro]curement of ye said Raphe Lawson and by his p[ri]vitye or otherwise assemble themselves togather in manner of an In[surr]ection at in and upon ye said moore & groundes called Heaton Banckes or neare unto the Colemynes there and so beinge then and ther assembled armed and arrayed and knowinge beforehande yt the said Complt his s[er]vantes & workmen were then in laboringe & digginge for and gettinge of Coles did then and ther in like ...teous warlike and forcible manner in such sort as though it were in battle array m[ar]che towardes the place where the said Complt s[er]vantes and workmen were then in digginge for and gettinge of Cole and ther findinge the Complt s[er]vantes and workmen at ther laboure upon a malitious meanin[ge] towardes the said Complt by & accordinge to the effect of there foresaid intended practise & confideracie and at and by the said speciall Commanndment consent & p[ro]curement of the said Raphe Lawson and by his p[ri]vitye or otherwise did then and there viz in or neare about the same daye in like R[yot]ous & forcyble manner haveinge there weapons p[ro]vided against the said Complt his s[er]vantes & workmen did beat or wounde the said Complt his s[er]vantes or workmen and did gyve unto the Complt his servantes and workmen manye & dyverse grievous woundes and did discorage and discomforte them there.. [th]at they did greatlie dispaire of ther lives and yet doe languishe of such hurtes and woundes as they then Received or addinge threatninges & vowes yt they would kill or wounde them whosoev[er] should gett anie Coles there for the said Complt in suche sorte manner and forme as in the said bill ys most f[alsli]e & slannderouslie surmysed and alledged Or yt these defts at the same tyme did violentlie and wrongfullie take from ye said Complt his servantes & break in sunder all such weapons and Ingynes wherew[i]th the said Complt his said workmen did laboure for the gettinge of Coles Or yt thes defts therew[i]th contented but p[er]ceivinge yt the Complt did and would quietlie tollerate the same togeather w[i]th Henrye Brigges and other the said p[er]sons in the Bill named beynge arrayed and armed w[i]th suche like weapons & in suche like unlawfull manner as ys surmised upon or neare about the xijth daye of Jan[uari]e now last past at w[hi]ch tyme ye said Complt had sent his s[er]vantes and workmen to digge for and gett Coles there did in most warlike and outragious manner & at and by the unlawfull causinge commanndment consent & p[ro]curement of the said Raphe Lawson by his p[ri]vity or otherwise assemble [the]mselves togeather neare unto the Colemynes and they soe beinge then & ther assembled armed and arrayed & knowinge beforehande yt the said Complt his workmen were them likewise in laboringe and diginge for and gettinge of Coles did then and there in like Ryoteous outragious warlike and forcyble manner m[ar]che as thoughe yt were in battle array towardes and unto the place where the Complt said s[er]vantes & workmen were diginge for & gettinge of Coles & ther findinge them at ther laboure by and accordinge to the effect of ther p[re]tended practise [con]fideracie & at & by the speciall commanndment Consent and p[ro]curement of the said Raphe Lawson & by his p[ri]vitye did then and there in or neare about the said xijth daye of Januarye last past in like Ryoteous and outragious manner haveing ther bowes & arrowes pistolls & Gunnes then allreadye beforeh... bent & provided against the said Complt his said s[er]vantes and workmen & did sett upon assault beat & wounde ye said Complt his s[er]vantes & workmen & did shote arrowes at them & dischardged ther pistolls & gunnes against them and therw[i]th and w[i]th other ther said weapons did gyve unto ye Complt his s[er]vantes & [wor]kmen manie & diverse [greiv]ous & greate woundes & did soe discorage & discomfort them therby yt they did then greatlie dispaire of ther lyves & did likewise [break] in sunder all suche woork..... [En]gynes as where[with] the ..................................... workinge as ................. bill ys most mali[tious]lie suggested & su[rmised] ......... that the ....... defts & thother Ryote.... .............. the Bill menconed beinge [armed] and arrayed w[i]th suche like wea[pons] ........... suche warlike manner as ............... alledged ........................................................ sundry [oth]er daies .............................................. of Januarie last past ........................ said sev[er]all daies ye said C..... ................... his s[er]vantes & workmen .................... [Co]lemyne to digge.... ............ did in ........................................................ by the ...lawfu[ll] .......................................... and p[ro]curement of [the said Raphe La]wson and by his .......................... [them]selves togeather ........................ ....ction at or ................................................................................................... meaninge tow...... .................................... and fore inten[ded] .............................. & at & .................................................................. [remainder lost or destroyed]