Court of Requests: Edward Bowes v. John Digges and John Gape

Item 2 single membrane (Interrogatories on behalf of Edward Bowes)

Interrogatoryes to be mynistred on the parte and behalf of Edwarde Bowes Esquier Complaynaunte agaynste
Iohn Digges and Iohn Gape defendants as followethe./ (blank) viz:

ffirste whether doe you knowe the saide Edwarde Bowes, Iohn Digges, Iohn Gape or any of them, and howe longe haue you knowen them or any of them.

Item whether doe you knowe that the Conueyance of the grounde and thinges nowe in controuersie pretended to be made by Iohn Napton Grocer to the saide Digges and Gape was sealed and delyuered at the tyme of the Date thereof, or att what other tyme was the same Conueyance made sealed and delyuered, and to what intente and purpose was the same Conueyance so made, as you knowe, or haue harde, and for what cause or Consideracion. °and what speche was vsed by william Napton grocer or any other when the saide Conueyance was firste putt to making touching expedicon to be made of the same and for what cause the same expedicion sholde be or was vsed°

Item whether doe you knowe that the saide Conueyance was delyuered by the saide Iohn Napton as his acte and deede to thandes of the saide Digges and Gape, or to anye other persone or persones to thuse of them the saide Digges and Gape or either of them, and when and to whome, was the same Conueyance delyuered, and whether did the saide Digges and Gape, accepte of the same assurance to them made, and did agree therevnto, at the tyme of the delyuerye of the saide Deede or Conueyance, or afterwardes, and howe longe after that, the foresaide Deede or conueyance was sealed, had they notice thereof.

Item whether had the saide Iohn Napton the saide Conueyance in his owne handes and custodie after the date of an Indenture of Lease bearinge date the three and twentith daye of December 1579. and in the two and twentith yere of the Quenes maiestes Reigne that nowe is, made by the saide Iohn Napton to Morgan Pope Goldsmithe and howe longe did the saide Iohn Napton kepe the saide Conueyance in his owne custodye after the date of the saide Lease made to the saide Morgan Pope as is aforesaide:/

Item whether had the saide Iohn Napton any true Counterpayne of the saide pretended Conueyance made by hym to the saide Digges and Gape, and whether was the same Counterpayne made sealed and delyuered, to the saide Iohn Napton at the tyme of thensealinge and deliuerye of the saide pretended Conueyance or afterwardes and when was the saide Counterpayne delyuered to the saide Iohn Napton./

Item whether was the saide Conueyance or any other assuraunce of the premysses or any parcell thereof made or delyuered to the saide Digges and Gape or either of them, vpon truste or confidence for the vse comodytie profite releife benefit or aduauntage of the saide Iohn Napton, and of one willyam Napton Grocer or of either of them, or of any other the Credytour or Credytours of the saide Iohn Napton to your knowledge or as you haue harde tell and howe you knowe this to be true../ <...>

Item whether did the saide Digges and Gape or either of them take possession of the thinges conteyned in the saide Conueyance or of any and of howe muche thereof did they or either of them take possession and whether was the same possession taken by them at the tyme of the makinge of the saide Conueyance to them or afterwardes, and howe longe after, and who did in the meane tyme enioye and occupie the same and vpon what occacion did they then take possession thereof and whie did they not take possession thereof ymedyatlie after thensealinge and delyuerie of the said dede or Conueyance./

Item whether was the saide Iohn Napton indebted to the said Digges and Gape, or to either of them to the value of MCx^li before thensealinge of the saide Conueyance yea or no, or howe muche did he owe to them or either of them, and howe you knowe it to be trewe./

Item whether did the saide Digges and Gape or either of them before the date of the saide Conueyance vndertake to paie to the saide willyam Napton for the debte of the saide Iohn Napton any some or somes of money and howe muche and howe doe you knowe the same./

Item whether did the saide Digges and Gape or either of them enter into bonde to the saide willyam Napton, or did make any promyse to hym for the payment of the saide some or sommes of money yea or no, and for howe muche, and at what tyme did they or either of them become bounde, or any otherwise chargeable to the saide willyam Napton for or concernynge the same./

Item whether did the saide Digges and Gape or either of them vndertake to paie to the saide willyam Napton the saide some or somes of money, or any of them, at or before thensealinge and delyuerie of the saide Conueyance yea or no./

Item whether did the saide Digges and Gape or either of them become bounde or vndertake to paie to the saide willyam Napton the saide some or somes of money absolutelye, (bona fide) and without any fraude collusion or other secreate intente or purpose and howe doe you knowe the same./

Item what and howe muche ready money did the saide Gape lende to the saide Iohn Napton (bona fide) to thonelye vse of the saide Iohn Napton before thensealinge of the saide Conueyance, and whether was the same or any parcell thereof unpayed at thensealinge of the saide Conueyance and howe doe you knowe the same./

Item what and howe muche redye money doe you knowe that the saide Digges did lende to the saide Iohn Napton, (bona fide) to thonelye vse of the same Iohn Napton before thensealinge of the saide Conueyance and whether was the same or any parcell thereof vnpaied at thensealinge of the saide Conueyance, and yf there were, then whether doe you knowe that the saide Digges and Gape or either of them had any other assurance from the saide Iohn Napton, for paymente thereof, or of any parcell thereof, before the makinge of the saide Conueyance and what was the same other assurance to your knowledge and what other thinge doe you knowe concernynge the premysses./

Item whether did the saide Digges and Gape or either of them become bounde or charged to paie to the saide Iohn Napton or any other for his debte or to his vse any some or somes after the makinge sealinge and delyuerie of the saide conueyance. And ‸⸢yf⸣ yea then for what cause or consideracion and in or by what bonde or bondes or other assurance specyaltie or specyaltyes became they or either of them so bounde or charged and to whome and whether were the same made and delyuered, (bona fide) or not, what was the cause that he or they became not bounde or charged for the same before thensealinge and delyuerie of the saide assurance./

Item howe muche or what some or somes of money hath ben paid by the saide Iohn Napton or his assignes to the saide Iohn Digges and Gape or either of them as in parte of payment of the saide MCx li. mencioned in the saide Conueyance, and when or att what tyme was the same paied, and howe doe you knowe the same./

Item whether had the saide Iohn Napton the possession of the saide howse grounde and premisses att the tyme of thensealinge of the ensealinge of the Lease thereof by him made to the saide Morgan Pope and did take the proffites thereof yea or no./

Item whether was the saide Iohn Napton at or aboute the tyme of thensealinge of the saide Lease to the saide Morgan Pope demaunded or charged to vtter whether he had made any other conueyance or incombrance thereof, and vpon what occasyon, and what answer did he make thereunto, and howe doe you knowe the same./

Item whether did you or any of you sithence the controuersie betwene the saide mr Bowes Digges and Gape, at any tyme see the saide Iohn Napton shewe forthe at a windowe of his nowe dwellinge house, or ells where any Indenture or other conueyance touchinge the premisses and whether did you heare the saide Iohn Napton vtter theis wordes or the like in effecte./ Lett not Pope be so lustie for here is that which will cutt his nose, and I made it for that purpose./

(signed) Pagytt