Kynnersley v. Tyxall et al

mb 1 (4 May) (Answer of Godfrey Tixall)

...

The said defendant saving and reservinge to himselfe all Advantage of excepcion to the incertaineties & insufficiencies of the said Bill of Complaint for answere vnto soe much therof as anie waie Concerneth or toucheth this defendant he sayth that the said Complainante ‸⸢as this defendant verily thinketh⸣ havinge within the space of three ‸⸢or fowre⸣ yeres now last paste ‸⸢or thereaboutes⸣ Conceiued A Causeles Malice and hatred againste William Tixall one other of the defendants & this defendants brother because the said William Tixall did refuse to lett the Complainante take his said Parke Called Loxley parke a parcell of ground beinge the inheritance of the said William Tixall hath devisde framde & Contrived this bill againste this defendant ‸⸢and his said brother William Tixall⸣ without anie Iust Cause of purpose to vexe & trouble this defendant and his said brother William Tixall & put them to needles expence & Chardges. And as to all & euerie the Ryottes Routes & vnlawfull assemblies puttinge throwinge downe & defacinge of anie house or barne, the riotous & vnlawfull Carryinge awaye of oates hey or Corne, huntinge, Coursinge, killinge or destroyinge of ⸢the Complainantes⸣ deere, the devisinge, Contryvinge, framenge and divulginge of false & slanderous lybells & Rymes ‸⸢against the said Complainant⸣ & all other the misdemeanours & offences in the said Byll of Complainte sett foorth & alledged and therby layd to this defendantes Chardge, he saith that he is not guiltie of them nor anie ‸⸢of them⸣ in such manner & forme as by the said bill of Complaint is vntruly sett downe & suggested without that that anie other matter or thinge on the said bill of Complaint Conteyned materiall & effectuall for this defendant to make ‸⸢any⸣ answere vnto is true to this defendants knowledge. All & euerie which matters and thinges this defendant is redie to averr & prove as this hoorable Courte shall award & humbley prayeth to be dismissed out of this honorable Court with his reasonable Costes and Chardges in the behalf wrongfully susteyned

(signed) Parker