THE External happyneſſe of mankind, conſiſting in Society, of which the briole, or check, is the Law, which curbs and reſtrains the unruly exorbitances of unreaſonable men; what can be fall more miſerable in this life, than to have this remedy (by the Injuſtice of its Execution) made worſe than the diſeaſe? to find Judgement turn'd into Gall and Wormwood, as is evident in your poor Petitioners Caſe, who to the ruine of his Wife and Children, hath for ſeveral years found experimental proof thereof, which being his lot in thoſe times, when our Sun of Earthly happyneſs was eclipſed, and only the Screetchowles of Horror and Diſtraction were heard in our almoſt ruined Land; when Corruption and Villany was the natural milk to feed our Infant Monſter the Commonwealth; His hope and aſſurance is, that the return of our Sun of Majeſty, will be like unto that of him, who hath been, and is his true pattern, the Sun of Righteouſneſſe, with healing under his wings, to poor, oppreſſed, and otherwiſe deſpairing Priſoners, among whoſe number, your Petitioner humbly acknowledgeth himſelf.

Nor is he only prickt forward to this Addreſſe, by the ſharpneſſe and tediouſneſſe of his ſufferings, and preſent diſtreſs brought upon him thereby; but is alſo incouraged (nay more) aſſured of ſucceſſe, in confidence of your Honors true Gallantry, Juſtice and Wiſdom, who your ſelves in theſe late overturning times▪ have taſted of the ſame cup of affliction, many of you drunk thereof deeply.

Yea, His Moſt Sacred Majeſty, hath not eſcaped the ſame Lot; but (in imitation of our Saviour, his immediate Lord and pattern) hath ſuffered in the like kind, (though not in the ſame manner) and therefore my confident aſſurance is, that having in this Humble Addreſſe to deal with ſuch a King, the like of whom England never ſaw, nor brought forth, experimentally (by Gods inſcrutable providence) made ſenſible of the diſtreſſes and ſufferings of his meaneſt Subjects, ſuch Lords and Nobles, who themſelves have been tryed in the ſame Furnace of Affliction, and for many years laſt paſt, have (not through their Princes diſpleaſure; but for being Loyal to their Prince) by the meaneſt and worſt of Plebeians been plundered, and ſtript of all, and afterwards impriſoned, with as much reproa • h and contempt, as if they had been Chips of the ſame Block with the moſt Contemptible Commoner: Such Knights and Burgeſſes to Sit in Parliament, who if in theſe times of diſtraction, they lived in England, and are unacquainted with the miſeries of Impriſonment, it argues in them little Cordial Fidelity to their Soveraign Lord, or his Father of Bleſſed memory, whoſe real friends mildeſt Lot was reiterated, and ſevere Impriſonments, others being Baniſhed, not a few Murthered.

On which Conſiderations, your Humble Petitioner begs of, and Humbly beſeecheth you, who by the good hand of our moſt Gracious God, have been dragged, many of you out of the Dungeon, ſome recalled from Exile, to injoy your Antient Priviledges and Freedoms, and ſit (according to your true deſert and merits) at the Helm of State, to caſt back your Gracious Eyes upon ſuch who once were fellow Sufferers with you, and not (like Pharaohs Butler) being now your ſelves reſtored, to forget the languiſhing Eſtate of Joſeph, (viz.) your once fellow Priſoner.

This my Lords and Honorable Gentlemen, I ſpeak not as in the leaſt doubting or fearing any ſuch thing; but out of the meer ſenſe of my long, and moſt unjuſt ſuffering; pardon my boldneſſe that I am thus importunate (if poſſible) to find an effectual and ſpeedy remedy.

And not to trouble your Honours with a long Preamble, whoſe very weighty occaſions, cannot admit a tedious diſcourſe, I ſhall come Humbly to repreſent my Grievances, ſo illegal, ſo many, and carryed on with a high hand, on purpoſe to ruine your Petitioner, whom ſeveral perſons of note and power, have confederated to undoe and deſtroy, in ſo barbarous, and wickedly malicious a manner and way, as I queſtion not, but in the following particulars to make ſo plainly evident to your Honors and Wiſdoms, as will cauſe your hearts in reading of them to relent, and commiſerate your poor Petitioners Caſe, yea ſo to pity him, as effectually to relieve him.

In the year of our Lord 1648 Octob. 21. Richard Dawſon Gentleman, then reſiding in the County of Norfolk, and dealing in the Capacity of a Graſier, had at one time, forcibly taken from him 267 Oxen, which were all driven into the Caſtle of Pomfret, by ſome who pretended themſelves Souldiers of that place, and there came to the poſſeſſion of one Roger Portington, the Governour denying, that he had any thing to do with them, when Dawſon (owner of the Cattle,) demanded them of him; but ſent him to Portington, to treat with him concerning them, being (as he affirmed) wholly in his power, and withall required Portington to roſtore them to Dawſon, but he refuſed to return them, or any part of them, uſing this exaſperating expreſſion, to the owners face, That would he give 100 l. for ten of the worst, he ſhould not have them; with which most rugged anſwer, Dawſon being juſtly provoked, (as well as exaſperated by his great loſſe) in the year 1649, he brought his Action of Trover and Converſion againſt Portington, which being tryed by Niſi prius, at Guild Hall, in the year 1650. the Plantiff recovered againſt the Defendant Portington, (with coſts of Suit) 1297l. 13s. 4d. according to which verdict, Judgement was entred, and Dawſon had granted him a Writ of Execution thereupon.

A man would now have thought that the Plantiff had not been far from his mony, having able bail for bringing forth the Body of the Defendant, and him a man of ſufficient eſtate to ſatisfie a greater debt; But the ſequel of this diſcourſe will make it moſt evident, that as our Laws have been, and are in the Execution of them ſtill abuſed, there is no Caſe, ſo notoriouſly corrupt and injuſt; but meeting with a ſuitable Conſcience, joyned with ability of Purſe, he may be provided with Lawyers, who for the ſake of gain, will maintain and defend the ſame, in deſpight of Juſtice.

For this Portington to diſcharge his Bayl, rendred himſelf Priſoner to the Kings Bench, where Dawſon charged him in Execution, upon the ſore-recited Judgement, and there he to this time continues a Priſoner, although for many years he hath been, and ſtill is at large, dwelling at his own houſe in Yorkſhire, to the defrauding, and great dammage, of the injured Creditor, who can look upon ſuch actions, no otherwiſe than Cheats, however ſeemingly backt with Colour of Law; But of this I ſhall have cauſe given to ſpeak more fully hereafter in this diſcourſe: I will now come to ſhew by what vexatious troubles, the Condemned Defendant, hath for ten years moleſted the greatly ſuffering Plantiff, by which he hath been put to ſo much coſt, (beſides moleſtation,) that he had better have been himſelf Condemned in as much more money, and clearly loſt his debt, then recovered againſt the Defendant that Judgement, of 1297l. 13s. 4d. For to avoid payment thereof, the Defendant Portington hath not only himſelf endeavoured, but combined with others, to bring Dawſon to ruine, and hath effected it, ſo far as tedious Law-Suits, and Impriſonments could do the ſame, to the Expence and Dammage of him the forenamed Plantiff, more than 8000l. which he can make appear; and this by ſuch monſtrous courſes of Villany, as can ſcarce be believed, but that the Plantiff can by many Records make out the ſame.

His firſt vexatious Dog-trick was, when that invention of Salters-Hall was hatched, for the relief (as was pretended) of Creditors and Debtors: To theſe Commiſſioners Portington Addreſſed himſelf by Petition, which was granted, and Dawſon Summoned thereupon, to have the Caſe heard by them, who inſtead of relieving the Creditor, ordered only a rehearng of the Cauſe before themſelves, to which order (patience perforce) Dawſon ſubmitted; but the event proved neither relief to Creditor, or Debtor; for that Court after hearing the Cauſe, and with mature deliberation weighing the merits thereof on both ſides, diſmiſt Portingtons Petition, which cooled his hopes and expectation of relief; and for the Creditor Dawſon, all his relief was, that after the expence of 200l. in that ſecond hearing and Tryal, (ſeveral of his Witneſſes living 200 miles from London, beſides other ways of great charge and coſt) he had only his former Judgement confirmed, and yet as far from his mony as before.

This Dog-trick failing, Portington was ſoon provided with another, which was, to Petition the uſurper Oliver for relief againſt ſo due a debt doubly now confirmed by two Tryals; in which Petition (being on Record, and the Copy of it in Dawſons hands, to be ſhewed any that deſire ſatisfaction therein,) Portington (to his praiſe be it ſpoken) who would by all means be thought a Cordial Royaliſt, did baſely, and perfidiouſly acknowledge the Supreme Legiſlative Power to be in that bloody Rebel; betraying both his Conſcience, and the Cauſe he pretended to maintain, with deſign only to cheat his Creditor Dawſon of a juſt debt, ſo injuriouſly detained. The Uſurper, in anſwer to his Petition, ordered ſeveral references: In attendance upon which, the Creditor was put to a new charge of 100l. or thereabout, the Priſoner finding as little relief, as he before had at Salters-Hall (that is none at all) not do I believe he ever expected relief from either, only uſed theſe delatory means, if not to defraud, at leaſt to retard his Creditor from getting, what by Law he had recovered; and by multiplying expenſive proceedings (although illegal) to weary him out, and tire his patience, ſeeing more monies dayly thrown away after the former, of which he could now have but little hopes, to receive either Principal, Intereſt, or Coſts of Suit.

Yet for all theſe diſappointments, he is not weary; but ſince his Majeſties happy Reſtauration, preſented his Petition againſt Dawſon in the Upper Houſe of Parliament, where the Lords after ſeveral hearings, thought no relief fit to be granted in the Caſe, wherein the Law had no leſſe than twice had its full, and due courſe; however, his reſtleſſe ſpirit hath lately prompted to him another poor ſhift, and that is, to bring an Audita querela, in which he pretends an acquittance by the Act of Indempnity, although he hath been a Priſoner in Execution (therefore) now above ten years ſince he was firſt charged therewith.

Howbeit, although I call him a Priſoner, yet (thanks to good Sir John Lenthall) he is one at large▪ this Gentleman when great Rogues come to be Cannonized, ſhall paſſe for a pretious Saint, the rules of whoſe Priſon, where he meets with one like himſelf, that makes no more Conſcience of giving, than he of taking a bribe, reach as far as Conſtantinople, ſome ſay to the Eaſt-India's, by which means, thoſe who can diſpenſe with their Conſciences, va • ue the Execution of the Law not a ruſh; as particularly appears in Portington, who being ſuffered (though in Execution) to live at home, and ſometimes for nigh three years together, not to come ſo much as to Town, hath taken up a reſolution, never to pay his Credit or Dawſon a groat, yet boaſts, that he can, and will have his Liberty in ſpight of him, although the hopes of Dawſon are, that this Parliament will take ſuch effectual courſe againſt theſe kind of tricks, as may truly relieve the oppreſſed, and curb the inſolencies o • unconſcionable men.

And ſo at preſent I ſhall leave my firſt Cuſtomer of this kind, and proceed to new, and more prodigious Villanies, acted by others, but countenanced and fomented by this Portington, who to ſecure himſelf in his unjuſt proceedings, hath not been backward, in the moſt helliſh deſigns to act his part, to the ſhame of thoſe who have abetted him, and his Aſſociates, who were men of Rank and Repute.

In the year of our Lord 1656. Novemb. 11. Dawſon being then in Norfolk, had occaſion to make uſe of three hundred pounds for the manageing of his Trade, which he offered to repay in London by Exchange nine days after; which Sum, one Phillip Read, an Attorney in the Court of the Kings Bench, undertook to furniſh him with all, in two dayes time, provided Dawſon would give him a Warrant to an Attorney to confeſſe a Judgement to him for five hundred pounds, (with a Defeaſance, for nine dayes) for his better ſecurity of the payment of the ſaid 300l. which Dawſon conſented to, Signed and Sealed a Warrant, and Read alſo Signed and Sealed the foreſaid Defeaſance annexed thereto, which being delivered mutually by both parties; Dawſon came at the time appointed, (viz.) two dayes after, to receive the 300l. according to agreement, but could have no more paid him then 158l. which was repayed by Dawſon to Read, and his appointment in London by the time limited and allowed in the Defeaſance, (yea in truth two dayes before) with 15 pounds more, which was lent by him to Read, to be repaid upon demand; upon which payment Dawſon called for his Warrant of Attorney, which Read at that time put off with this excuſe, That he had forgot, and left it at his houſe in the Country, promiſing the delivery of it as ſoon as he returned to Norfolk; but not performing his word, Dawſon made ſeveral times other demands of the ſaid Warrant, but had for anſwer, It was loſt: Yet before ſeveral perſons of Repute and Credit, Read acknowledged himſelf fully ſatisfied by Dawſon, and nothing to remain due to him from the ſame. However, Sept. 12, 1657. Read having privately, without the leaſt knowledge or ſuſpition of Dawſon, entred that Judgement, took out Execution upon it, againſt the goods of Dawſon, and by virtue thereof did levy in the County of Norfolk to the value of 700l. and after ſent one Thomas Hide into Huntingtonſhire, who by his order, without Writ of Execution, or any other Authority but his direction, took away 47 fat Bullocks, worth 200l. and ſold them; nor content with this, he in the ſame year and month, in the County of Norfolk, at a place called Wallpool in Marſhland, did by Colour of the ſaid Execution, ſeize of the proper goods of the ſaid Dawſon, viz. Hay (in Stacks and Reecks) to the value of 500l. which though he had no power to condemn and diſpoſe of, yet he detained by colour of his own Execution, till he could, and did procure one Robert Dun by a pretended Execution to Levy the ſame, and ſell it.

Upon which illegal abuſe, Dawſon made complaint to the then judges of the Kings Bench, (in thoſe dayes called the Upper Bench) by whoſe order, Read was committed Priſoner in the Cuſtody of Sir John Lenthall; but by favour of ſome of his Fraternity, forthwith had his Liberty, which he imployed ſo well, that before the end of the ſame Term, he procured one Diſney to commit wilful perjury, with intent to overthrow Dawſon in his moſt juſt cauſe, he when Read firſt moved to him that he ſhould make ſuch an Oath, replyed, Maſter I know no ſuch thing, who then ſwore by his Maker, that unleſſe he would make that Oath, as he directed him, he was utterly undone; ſo partly by importunity, partly by promiſes, he procured the ſaid Diſney deſperately to ſwear againſt his own knowledge,; Whereupon Dawſon endicted Diſney for this perjury, and this Maſter for ſubornation thereto, ſince which Diſney's Conſcience accuſing him, he hath confeſt to ſeveral perſons of worth and repute, that his Maſter Read would never permit him to be at reſt, till he had perſwaded him, to make Oath of ſuch things, of which he had not the leaſt knowledge.

For which Cauſe in Eaſter Term 1658. Dawſon filed a Declaration in the Kings Bench againſt Read, (who did, and ſtill doth practiſe there as an Attorney) upon the Caſe, in a ſpecial Action, which the firſt of July he brought to a Tryal, and recovered 700l. dammage, beſides coſts of Suit, 18l. for which the following Michaelmas Term he had Judgement, and Execution granted thereupon, againſt the perſon of Read, which Writ being delivered to the Sheriff of Norfolk; the buſineſſe was ſo jugled between them, that although Read was often in the Sheriffs Company, yet he was not taken in Execution, nor would the Sheriff at the inſtance of Dawſon return the Writ, for ſeveral Terms, and at laſt returned a non eſt inventus thereupon, when Read during the time of detaining this Writ, without Execution or Return, had embroyled Dawſon in a tedious and chargeable Chancery Suit, which becauſe of its Exemplary Injuſtice, and Corruption, diſcovered in the manageing thereof, ſhall be particularly here ſet down.

Not long after, Dawſon had got againſt Read this Judgement, and Execution; the Defendant ſues for relief in Chancery, and ſerves Dawſon with a Subpaena to that purpoſe, and proceeds the Vacation following to examine witneſſes, and by favour with the Maſter of the Rolls (William Lenthall) procures the cauſe to be forthwith ſet down for a hearing in Eaſter Term (ſuddenly then following) 1659. which Term being adjourned, the Cauſe was again ſet down for hearing at the Rolls, the 9th. of June following, where as ſoon as it was opened by Reads Counſel, Lenthall (the Conſciencious Maſter of the Rolls) called for Dawſon, and in ſeeming familiar friendſhip told him, he would make a bargain with him, (viz.) that Read ſhould within two dayes pay him Four hundred pounds, and the differences between them made up, and fully ended thereupon, to whom Dawſon replyed, his debt was 718l. in recovery of which it had coſt him no leſſe then 500l. When Lenthall ſaw that this bait would not allure Dawſon to bite at it, who had ſufficient former experience of his corrupt baſeneſſe, and diſſembling villany, (as before the Cloſe of this diſcourſe ſhall be diſcovered in another caſe,) he then demanded of Reads Counſel, if they could produce any Preſidents, where relief in Equity, had been granted, in the like caſe after recovery, Judgement, and Writ for Execution, who replyed, there were ſeveral Preſidents, upon which anſwer, Lenthall put off the hearing till the 18th. following, of the ſame month, againſt which time he willed them to have thoſe preſidents in readineſſe, and then he would determine the Cauſe; but in the mean time tyed up Dawſon not to take Read in Execution: the appointed day for hearing being come, upon reading the firſt preſident, Lenthall told them plainly, it made not at all for, but againſt them; but he had ſince the laſt hearing, Conſidered of the Cauſe on his pillow, and ſo forthwith, without farther hearing Counſel on either ſide, ordered them to go to a new Tryal at Law, after which he would reſerve the Equity to himſelf; but in the mean time Read ſhould not be taken in Execution, with which orders Dawſon being much agrieved, Petitioned the then Lords Commiſſioners of the Great Seal (as they were called) complaining of the great injuſtice he ſuffred thereby; in anſwer to which Petition, they granted him a rehearing before them, upon which, Counſel having ſpoken on both ſides, they diſmiſt Reads Bill, and diſcharged the ſeveral orders made by the Maſter of the Rolls, with coſts to be taxt by a Maſter of Chancery, which were accordingly taxed at an hundred marks; Whereupon Sir John Lenthall (one of the Rebel Olivers mock Knights) Son to the Maſter of the Rolls, being at that time a Member of that thing, then called a Parliament, ſeeing Read thus left to the Law, (notwithſtanding his honeſt Fathers devices to obſtruct the ſame) gives him his protection during the ſitting of that Convention.

Read finding himſelf thus countenanced, by the Maſter of the Rolls and his Son, (for which as himſelf confeſſeth, it coſt him three hundred pounds thinks he is now armed Capape, for any villany, and having a prodigiouſly villanous wit, goes thorow ſtitch to the purpoſe, and thus performs it. Firſt he perſwades and prevails with one Robert Dun, that he might make uſe of his name, (at his own charge and coſts) to confeſſe, and enter a Judgement againſt Dawſon, for the Sum of 350l. upon which grant. Read as repreſenting the perſon, and taking upon him the name of Richard Dawſon, forged the foreſaid Warrant of Attorney, Subſcribes and Seals it, as if himſelf had been the perſon of Dawſon, and then delivers it to the uſe of Robert Dun, having witneſſes in readineſſe, (who upon examination affirm that they knew neither the perſons of Read or Dawſon) to ſubſcribe to the delivery thereof as the Act and Deed of Dawſon.

Upon which Warrant ſo given by himſelf, he procured a Judgement to be entred, and Execution taken out, and levyed on the Goods of Dawſon in the County of Norfolk, where by a Combination between him and the Sheriff, with his under Officers, (who knew very well the Judgement to be grounded upon a forged Warrant of Attorney before the Execution of the Writ,) 1000l. worth of Goods were ſeized and ſold, yet valued but at 150l. which Goods ſo under valued, were bought by one John Prat, whom Read procured to buy them upon a joynt account, between them both.

Which 1000l. being thus ſwallowed up between theſe two devourers, and the Execution ſtill unſatisfied more than one half; in the next place, Read ſues forth a Commiſſion of Bankruptſhip againſt Dawſon, in the name of Dun, for the unconſcionable remainder of the pretended Execution; to ſit upon which, he pickt up Commiſſioners of his own Confederates, who in a very ſhort time after the Commiſſion came to their hands, declared Dawſon a Bankrupt, and diſcharged Read from payment of any monyes to him, no other pretence of Debt, being brought before theſe Commiſſioners to prove this Statute againſt Dawſon, but only the forged Warrant for Judgement, as is before at large recited, and teſtified by thoſe very witneſſes who were preſent at the Sealing and Delivering that Warrant of Attorney, who depoſed that Read (whom then they had no perſonal knowledge of) Subſcribed, Sealed, and Delivered it, in the name and counterfeiting the Perſon of Dawſon.

Things being thus corruptly and unjuſtly carryed, Dawſon to prevent (if poſſible) the ruine, which he ſaw inevitably hanging over the heads of himſelf and Family, unleſſe ſuch villanies were redreſſed, in Michaelmas Term 1659. made his complaint before the Judges of the Kings Bench, of the fore-recited horrible Forgery of Read in his name, as alſo of falſe witneſſes, which were ſuborned by him, and in readineſſe to ſwear that Dawſon was the very perſon, who Signed and Sealed the Warrant of Attorney, to the uſe of Dun; upon which complaint the Court, referred, the matter of fact in the Caſe to the examination of Mr. Herne Secondary of the ſame Court, who upon examination of Dun, and ſeveral other witneſſes, found that no monyes were due from Dawſon to him; but on the contrary, Dun was indebted to Dawſon in the Sum of 400l. due upon Bond, who had a general releaſe from him under Hand and Seal, before the forging that Warrant of Attorney, (by Read, in his name) nor did ever Dawſon deal with him ſince, as he hath confeſſed in the hearing of ſeveral perſons; To make which more evident, Dawſon hath now from Dun a Judgement upon Record, acknowledged by himſelf, for that ſame debt of 400l. then due when this forgery was committed, Dun having moreover confeſſed on his Oath, that Read to acquit himſelf of the Judgement for 718l. and 100 Marks Coſts, did Sollicite him to conſent to, and own this forgery, and ſuing forth the Statute of Bankruptſhip againſt Dawſon thereupon.

Mr, Herne having carefully ſifted the whole truth of the Caſe, made thereof a juſt report to the Court, who thereupon ordered a Tryal at Law, and the rule was, that this Tryal ſhould be (according to the Election of Dawſon) at the next Aſſizes in Norfolk, or Suffolk, upon a feigned Action, whether the Warrant of Attorney were the Act and Deed of Dawſon or no, which if upon tryal, the Jurors ſhould find in the affirmative, then the monyes in the Sheriffs hand (made of the goods levied in Execution) to be delivered to Dun, but if they ſhould find in the Negative, then the Judgement to be vacated, and the moneys reſtored to Dawſon; Dawſon upon this order moved, that the Tryal might be either in London or Middleſex, where the Forgery was committed, becauſe at ſo great diſtance, Knights of the poſt might ſtand for ſubſtantial witneſſes.

Yet in this he was overborne by the Court, and the Tryal ordered in one of thoſe two Counties, who becauſe he could have it no better, choſe of two Evils the leaſt, and had his Tryal at Bury St. Edmonds, at the Aſſizes holden Sept. 10. 1660. for the County of Suffolk.

Read making Cock-ſure of the Tryal to goe on his ſide, being at ſuch a diſtance, carries down the Record, and with it Witneſſes that knew how to ſwear home; Dawſon alſo knowing the juſtice of his Cauſe, fearing the other ſhould neglect it, (though Defendant) he alſo carried the Record with him, to tryal, in caſe Read, and Dun ſhould not; So two Juryes were Impannelled, one on the Plaintiffes, another on the Defendants ſcore; And although Dawſon might have juſt cauſe to fear the packing of a Jury, on the behalf of Read and Dun, whom his former experience had taught him, to be notoriouſly villanous, yet truſting to the righteouſneſſe of his Cauſe, rather than contend, was content to loſe the benefit of his own Record, and proceed to tryal by their Jury.

Who being ſworn upon the Caſe between Dun and Dawſon, Read who was at the charge of that Tryal, and carrying the witneſſes out of London, as hath been ſince confeſſed upon Oath, by the Plaintiff Dun, and ſeveral other witneſſes, and may be concluded by this undenyable Circumſtance, that Read gave Ten thouſand pound ſecurity, to the Warden of the Fleet, to whom Dun was then a priſoner, to have him perſonally preſent at the Tryal to own the ſame, yet this Read appears as one witneſs in the behalf of Dun, and ſwore that Warrant of Attorney was a true Warrant, and Signed and Sealed by Dawſon to Dun, for 220l. which Dawſon owed him, although in truth Read did himſelf Forge, Sign, and Seal that Warrant, as hath been already ſaid, and alſo made appear by Oath upon Record.

Having thus led the Dance, he next produceth another witneſs like himſelf, to confirm his teſtimony, who went by the name of William Holmes (which name alſo, was ſo ſubſcribed to the Warrant of Attorney) but that perſon being dead, this Counterfeit ſwears poſitively, that he was the ſame William Holmes, who ſubſcribed his Hand to that Warrant of Attorney, which he upon Oath ſaid, was Signed, Sealed, and Delivered by that ſame Richard Dawſon, who was then Defendant in that Cauſe; But it was diſcovered in Court, that this pretended William Holmes, was indeed Iſaack Harding a Scrivener, now, and for thirty years laſt paſt dwelling in Swan-Alley near Holborn-Bridge, and was hired by Read for the Sum of 45s. paid him in hand by his appointment, beſides what was promiſed him afterward, to make that deſperate Oath, which he knew to be falſe in every Circumſtance of it.

Now how God was pleaſed to diſcover the falſhood and perjury of theſe Villains, whoſe feared Conſciences durſt atteſt his Divine Majeſty ſo ſolemnly, yet ſo falſely, it will not be amiſs to declare briefly.

In the time of the hatching, and proſecuting the afore-mentioned Villany againſt Dawſon, one Thomas Gunning, was by Robert Dun perſwaded to goe to a certain perſon, unknown (but only to the Procurers and Abbetters of the intended Cheat) to make demand of 220l. of him (as if he had been Richard Dawſon) which ſum he was to pay unto him upon Defeaſance of a Warrant of Attorney, to confeſſe a Judgement for 350l. which Dun told Gunning, Richard Dawſon had Signed and Sealed, and that Party to whom he ſent him, was the ſame perſon; Gunning (at that time not knowing Dawſon) made demand accordingly; That Counterfeit perſon owning the name of Richard Dawſon, promiſed payment of the Sum demanded in a Weeks time; Of which demand, and an anſwer thereto returned, by the ſuppoſed Richard Dawſon, Gunning (being perſwaded by Dun) made Affidavit: The true Dawſon hearing this news, ſo ſtrange to him, teſtified upon Oath, was alarum'd thereby to look about, and being Authorized by an Order, to bring in this Deponent Gunning, to ſee if he would make good his Depoſition the whole Plot was in part diſcovered, for ſeeing the true Richard Dawſon in preſence, he not only upon his Oath denied him to be the ſame, of whom he made the aforeſaid demand of 220l. (who then profeſſed himſelf to be the ſame Party) but alſo Depoſed, that Dun in the name of Read, had offered him 40l. to ſwear that Warrant of Atorney to be the Act and Deed of Dawſon, and bringing him to Read's Chamber in Davids-Inne, there Read himſelf proffered him (in Caſe he would ſo make Oath) to maintain him at his Country-Houſe, furniſh him with a good Horſe, and give him forty pounds in money, as is at large declared in the Depoſition of Thomas Gunning, before the Right Honourable Juſtice Mallet, taken July 27. 1660.

This firſt light in ſhort time (with Gods bleſſing) diſcovered the whole deſign; For afterward, Richard Ramſey one of the witneſſes to that Warrant of Attorney, being Subpaena'd by Read, four dayes before the Tryal at Bury Aſſizes, at his Chamber in Davids-Inne, to be witneſs in the Caſe between Dun and Dawſon, there Read proffer'd him five pound in hand, to ſwear that the Defendant Dawſon did Sign, Seal, and deliver that Warrant of Attorney, to the uſe of Dun, he when he came in Court ingeniouſly related the truth, viz. that he was preſent at ſigning, and ſealing that Warrant of Attorney, and ſubſcribed his Mark as a Witneſs thereto, but then knew not either Dun or Dawſon, but ſince knowing both, he on his Oath affirmed, Dawſon not to be preſent at that time, but Read was the very perſon who ſigned, ſealed, and delivered it in the name of Dawſon; he alſo upon Oath declared the proffer of five pound in hand, made him by Read, in caſe he would ſwear as was before related; alſo, that then, and ſeveral other times, he ſaw Read give Dun money to proſecute the ſaid Suit of Forgery, and that Jacob Wrag, Clerk to Read, told him after the Tryal, that had not he been at Bury Aſſizes, his Maſter Read and Dun, had overthrown Dawſon, by the evidence of Iſaac Harding, who there ſwore by the name of William Holmes.

Which William Holmes being then dead, on his death bed did declare, that he was ſollicited, but was not witneſs to the Warrant of Attorney againſt Dawſon, to Dun, yet his name was ſubſcribed, his perſon and hand counterfeited; and though at the Tryal he were dead, yet Harding, who as a Scrivener had atteſted ſeveral Leaſes, and Deeds, (for above thirty years ſpace) by the name of Iſaac Harding, for the ſum of forty five ſhillings, paid in hand, (beſides what was afterward promiſed) he deſperately ſwore what he knew to be falſe, under the counterfeit name of William Holmes, whoſe name and hand, was at firſt only forged, as before was ſaid.

Thus it pleaſed God to defeat the Devices of theſe two malicious deſperate Villains, and to diſcover their forgeries, ſo that the old perjured Wretch, that ſwore by a diſguiſed name, got nothing by his counterfeiting, and forſwearing himſelf, not thoſe who employed him, but a bare detection of their Villany, to the confuſion of themſelves, and the amazement of the hearers.

Dawſon having this ground to work upon, proceeds to the examination of Dun whoſe Conſcience beginning to relent, had compelled him to acknowledge what he had acted againſt him, to ſeveral of his acquaintance; which he hearing of, procured his examination before the Right Honourable Lord Chief Juſtice Foſter, Nov. 26, 1660. who there upon Oath confeſſed, that the Warrant for Judgement to an Atturney, and Commiſſion for Bankruptſhip, ſued forth thereupon, were both carried on in his name, by the inſtant importunity of Read, and at his Coſts and Charge, with deſign only to defraud Dawſon of the 718l. Judgement recovered by him againſt Read and the Coſts taxed in Chancery upon the diſmiſſion of his Bill, by the Lords Commiſſioners, and that he did verily believe, the Commiſſioners, who ſat upon the Statute taken out in his name, did declare Dawſon a Bankrupt, under their hands and ſeals, only at the requeſt, and importunate deſire of Read. He alſo confirmed upon his Oath, Reads ſuborning Iſaack Harding, to ſwear at Bury Aſſizes, under the falſe borrowed name of William Holmes, that he ſaw the Warrant of Attorney, which was made to Dun, for 350l. ſigned, and ſealed, by that very Dawſon who appeared Defendant in that Caſe in the Court, for which Oath ſo to be made, Read gave him forty five ſhillings in hand; Likewiſe, that by the Confeſſion of Read, as well as the information of divers credible perſons, he was aſſured, that Read was often in company with the Under-Sheriffe of Norfolk, during that very time, he had a Writ of Execution againſt him, (at the Suit of Dawſon) for a Judgement of 718l. recovered by law. And laſtly, that one Jacob Wrag (Servant to Read) came to him (the Deponent) in his Maſters name, to deſire him not to diſcover any of theſe things before mentioned, and for ſo doing, he would be careful for him, and not ſuffer him to want.

Thus, at length was made a compleat diſcovery of all the windings and turnings of theſe Serpentine Monſters in Villany, one of them, in whoſe name, and by whoſe induſtry (in great meaſure) things were thus corruply (or rather helliſhly) carried, upon his Oath diſcovering himſelf, and accuſing, and ſo branding his wicked partner, with a black note of infamy, not to be wiped off by all the cunning he, or his accurſed Tutor in theſe Forgeries, Perjuries, and ſubornation to perjury, can find out, or invent. To God the true Author of this diſcovery, be aſcribed the ſole praiſe, and glory thereof.

The ſeveral chief heads of the teſtimonies of theſe three Deponents, I thought fit here to ſet down with what perſpicuity and brevity I could, (not ſwerving in the leaſt from the true intent and meaning of the Affidavits themſelves) which are at large upon Record, taken before Honourable Perſons, as was before touched in each of them; the name of the Right Honourable the Judge, before whom taken, being particulary remembred, in giving their teſtimonies in brief, for the Readers fuller ſatisfaction, and further confirmation.

To which I might adde many more of the like Kind, thirty ſeveral at leaſt, but that I here account needleſſe, ſince in the mouth of two or three witneſſes, each thing in controverſy, is, and ought to be confirmed, and here we have not only witneſſes, but (ipſos fatentes reos) the perſons concerned in the forgery, (either ignorantly or knowingly, drawn in thereto,) upon Oath confeſſing againſt both themſelves, and one another, which is a teſtimony as firm as can be deſired or expected.

I ſhall now ſpeak a little more particularly to the Statute of Bankruptſhip, ſued forth by Read in the name of Dun againſt Dawſon, and firmed by Commiſſioners pickt, and packt for the ſame purpoſe, only to diſcharge Read from paying any monies to Dawſon, whoſe juſt debt, upon a legal recovery was upward of 800l.

For taking forth, and granting, or affirming the ſame, Dawſon brought his action againſt Read, and thoſe Commiſſioners, his Confederates; and upon Tryal in Jan. 1660. recovered againſt them 500l. notwithſtanding which, upon an Affidavit of Reads, read openly in the Court, at the Kings Bench Bar, a motion was made to have a ſecond hearing, which was had by the conſent of both Plantiff and Defendants the Hillary Term following; where Read (according to his old wont) procured in readineſſe four ſeveral witneſſes, to ſwear Dawſon a real Bankrupt, (viz.) Thomas Wigge, one of Honeſt Sir John Lenthalls Engineers, a villain ſo notorious in that kind, that if in any Caſe, (where he is well paid) his Evidence come ſhort, (that is) be not ſworn home enough, blame the Lawyer that gave him not better and larger inſtructions, and not him, who wants only to be informed, what manner of Oath will ſerve turn; then as for performance, let him alone for one. The ſecond Jacob Wragge, ſervant to Read, one who had learned ſo much of his Maſters qualities, that no wiſe man can truſt his Word, or believe his Oath; the third Robert Coghill, a neighbour to Read, who by this hopeful beginning, gives great aſſurance, what a compleat Knight of the Poſt he may prove in time, if he continue the acquaintance, and follow the direction of Read; the laſt, Thomas Adamſon formerly a Clerk to Read, who it ſeems ſtill wants his help at a dead lift, (knowing his abilities) though at preſent he hath left his Service: Theſe four, being pre-inſtructed, could (if occaſion had required) have ſworn any man of dealing, in England a Bankrupt; for to give them their due, in their depoſitions, there wanted nothing but Truth, Malice enough, and Formality ſufficient, with a home ſhot to reach the mark aimed at by Read, their Tutor, who put cruel words of falſehood into their mouths, and told them what manner of Oaths would ſerve his turn, and they accordingly ſwore as dangerouſly, deſperately, and reſolutely againſt the Credit and Reputation of their innocent Neighbour, whom ſome of them knew not, others very little; all of them, knew certainly that what they ſwore againſt him, was abſolutely falſe, and ſo God by his providence hath plainly ſince diſcover'd it to be, to the great ſhame of thoſe poor perjured wretches; but moſt eſpecially of that Monſter, who ſuborned them to doe it, as he had done others often before.

For which wilful perjury (palpably now detected) theſe four abovenamed, ſtand indicted at the Old Bayly in London, by Dawſon, who doubts not, but to have them brought to Condigne, and Exemplary puniſhment.

Thus have I in brief decyphred out to you, a great Monſter in villany, as in a Landskip, given you a large volume of Roguery contracted into an Epitome, a ſhort narrative of what to his coſt and trouble, Dawſon (who hath ſtill been the ſufferer hitherto) hath felt for theſe many years, to the ruine almoſt of his Wife, Children, and Family, and whoſe Caſe or Lot may it not be next? nay who can eſcape for future? if ſuch Villanies be countenanced, as they will be if not prohibited, and ſeverely puniſhed to the terror of others? It is reported of a Bravoe, that he would vauntingly boaſt, how he had at his beck ready an hundred to ſwear for him, an hundred to fight for him, and an hundred more to ſupply him with money.

The thing, (though▪ I cannot affirm the number) is moſt true of this Read; who as for ſwearers, hath made his boaſts, that he is ſo provided with a ſtock of them, as never to fail in any Caſe, and that his manner of dealing with ſuch Knights of the Poſt, is ſuitable to that of the Dutch before a Sea-fight, with their Marriners, viz. to give them 20 or 30 glaſſes of Sack, juſt before they come upon their Oaths, then (quoth he) they are fit to ſerve my turn, and ſwear reſolutely, bravely, and boldly, without making the leaſt ſcruple of any thing that is told them makes abſolutely for the good of the Cauſe depending, to have it ſworn either thus, or otherwiſe.

And for fighting (or rather maintaining his quarrel,) 'twould make a man bleſſe himſelf to ſee prodigious Villains ſo favoured, before one that mannageth a Cauſe as juſt as Juſtice it ſelf, (having been ſo often determined juſt, by the reiterated Sentences of Common-Law, Commiſſioners for Equity; &c.) How did the honeſt Maſter of the Rolls (Speaker to the reforming Rump) endeavour to entrap Dawſon in favour of Read? How was Read with great charge, brought into a Priſon, where he deſerved to lye till death, yet (Preſto be gone Sir) diſcharged forthwith? and Dawſon brought in upon a large Scroll of Fob'd Actions, to keep the other, and ſuch as he procured to commit Perjury wilfully and maliciouſly, from Condigne puniſhment? How ready was the Sheriff of Norfolk to Execute a Writ upon a forged Warrant for Judgement, againſt Dawſon, and yet knew it to be ſo, (uſing this expreſſion, He would Execute 1000 the like, if they were brought to him, and Goods of Dawſons to be found in his Balywick;) yet how loth, nay abſolutely unwilling to Execute a true Writ, upon a Judgement, juſtly recovered, in Court, (after the diſcovery of a pack of Roguery) againſt Read; though oft in his Company, nor would be perſwaded to make return of the ſame, till Reads Cockatriſe Eggs of Villany were hatched? How have the Gaolers, and their fetting dogs, complyed with this perjured Monſter and his Confederates, to ruine one in defence of the other? Portington a Condemned Debtor to Dawſon, and Priſoner to Sir John Lenthall in Execution, having liberty to chooſe whether he would live in reſtraint or no; and Read caſt into Priſon, for Perjury, and Subornation thereto, Forgery, perſonating other men, and taking upon him their names, not without great coſt and charge to the Plaintiff, yet he in ſhort time, let out, upon inconſiderable Bayl, though Dawſon wrongfully impriſoned upon feigned, falſe Actions, maliciouſly brought againſt him, to hinder his proſecuting theſe ſo abominable Villains, hath not liberty to remain in one priſon; but is toſt (like a Curr in a blanket) from Gaol to Gaol, to a vaſt expence of monyes, nor without danger to his perſon, being this preſent Term, removed from the Fleet (where he was ſo happy, as to be free from groſſe incivilities,) to the Kings Bench, where the Keeper Sir John Lenthall, for a baſe bribe, hath injuſtly (yet much like himſelf, and his Brother, the Quondam Ravenous Maſter of the Rolls) ſuffered Portington, a Priſoner in Execution, at his Suit, to have free liberty, theſe many years, to the defrauding his greatly oppreſſed Creditor, and his extraordinary dammage; and is now become a deadly Enemy to Dawſon, becauſe he Sues him for an Eſcape.

I might be large here, but that I ſtudy and muſt affect brevity; In a word then to cloſe this ſad diſcourſe concerning this bad Subject, I wiſh only that the effect and tendency of ſuch practiſes would be ſeriouſly weighed, which is no other than the total ſubverſion of all our Laws, and deſtruction of civil policy; for if all that is recovered by legal proceſſe, may be ſo evaded, and detained from the Plantiff, and Coſts multiplyed by vexatious after hearings, his Eſtate pluckt away violently, by forged Judgements, and theſe proved true and real by wilfull perjury, till the party thus wronged hath not monyes left him to proſecute ſuch injuries, or to make a motion in Court, yet when this is diſcovered, and openly made to appear, the parties doing the wrong, be not curbed, and diſcountenanced, what hopes can an honeſt man have for future in a juſt and righteous Cauſe, well then may we cry out with the Philoſopher, fiat Juſtitia, aut ruet Coelum.

Willingly could I now throw aſide my pen, but that more injuries compel me to a farther complaint: From relating the Villanies of an Attorney; I would next proceed to match him with a pair of as great Villains as himſelf, in his own profeſſion, viz. a Sollicitor and a Counſellor, which three, if the Devi • had a Cauſe to be proſecuted, he could not be better fitted with a leaſh of Lawyers.

But before I come to a ſurvey of their Villanous actings, I ſhall relate a ſhort particular Caſe, which for ought I know hath no relation to any of the reſt, but was carried on by the Conſcientious Maſter of the Rolles, and a Kinſman of his (as very an honeſt man as himſelf) to the Dammage of Dawſon at the leaſt 2000l.

About the year 1649. Dawſon Commenced a Suit with Mathew Binkes a Graſier, for a great ſumme of money, which he injuriouſly detained from him, and by Law recovered 805l. and had Judgment entered for the ſame, Binkes brings his Bill for relief in Chancery, whereupon after a tedious Suit, and great Expences (the Commiſſioners for examination of witneſſes, ſitting above a hundred and eighty miles from London,) at laſt the cauſe came to hearing, before the honeſt Speaker William Lenthal, at the Rolls, who perſwaded Dawſon to referre the matter to a perſon whom he ſhould name, promiſing to name an honeſt indifferent man, a ſtranger to both their perſons, and the Cauſe; but ſcorning to be as good as his word, nominated a Kinſman of his own, by name John Nabbs, whoſe Son was Sollicitor in that Cauſe againſt Dawſon for Binks, and pleaded it before his Father ſo effectually, that Nabbs gave away the Judgment of 805l. from Dawſon, and moreover, ordered him to pay 44l. 4s. 6d. coſts to Binks, a ſtrange order, which could not be expected otherwiſe, conſidering how it was brought forth, for neither Dawſon, or any friend of his for him, was preſent or heard, but only Binks and ſuch who ſpake on his ſide, the chief of whom was Nabbs Son, a Sollicitor retained by Binks.

Nor was the Judgment only given away, but Dawſon ordered to acknowledge ſatisfaction for the ſame upon Record, which he refuſing, appealed to the then Lords Commiſſioners, Liſle, &c. who without proofs or allegations, ordered Dawſon to be committed Priſoner to the Fleet, until he ſubmitted to perform the order of Nabbs, whom the Maſter of the Rolls had impowered to hear, and finally determine that Cauſe without appeal.

Nabbs underſtanding that Dawſon queſtioned his decretal order, in a moſt unjuſt revenge, further ordered 180l. more to be paid to Binks for coſts, which payment Dawſon refuſing, a Serjeant at Armes was commanded to ſeize and impriſon him, till he did acknowledge ſatisfaction on the Judgment for 805l. pay the firſt 44l. 4s. 6d. and the other 180l. awarded for Coſts, and give a general Releaſe, never more to queſtion Binks.

Now the injuſtice of Nabbs decree may eaſily be evinced, for that the Maſter of the Rolls, before Dawſon conſented to the reference, proffer'd to give him by decree, 380l. (taking the rule of thoſe Conſciencious Jurors, who at a venture hang half, and ſave half,) which Dawſon refuſing as unjuſt, and too much damnifying him, at laſt conſented to a reference, where ſuch a Referre was appointed by Lenthal, who gave not only the judgement away wholly, but above 200l. more, for imaginary coſts, refuſing to hear any teſtimony on Dawſons ſide, but perremptorily binding him up to his determination, upon pain of impriſonment, to avoid which, Dawſon was a long time hunted from County to County, by the Officers of the Fleet, and at laſt finding ſuch a fugitive life, to tend to his abſolute ruine, he was enforced to ſubmit to this monſtrous piece of injuſtice, not ſeeing then any hopes of remedy. Lenthal being a man ſo powerful, and Nabbs ſupported by him, that not to yield to them then, ſignified nothing elſe but preſent ruine, they being able to cruſh at their pleaſure whom they liſted.

He that knows the manner of dealing of the Maſter of the Rolls, may give a ſhrewd gueſſe at what it coſt Binkes to purchaſe this piece of injuſtice, who thriv'd ſo well upon it, that he who then was viſibly reſponſible for ſuch a debt trebled, is now as far from being maſter of a tithe of ſuch a ſumme, as he was then from honeſty; from whence may be concluded undeniably, that at the long runne, honeſt dealing will prove the beſt policy.

And now I am at leiſure to take notice of, and lay open the injuries wherewith I have been, and ſtill am oppreſſed, by the procurement of two Lawyers, a Counſellour, and a Sollicitor, Brothers in Profeſſion, Name, and Villainy, Francis Lutterel, and Edward Lutterel, who both write themſelves of Grayes-Inne, but their practiſes have been ſo baſely foul, and groſſely corrupt, as may juſtly be the ſhame of all the Innes of Court, which I hope will ſhortly ſpue out ſuch, (I will not ſay Villains, becauſe they are Lawyers) but who are the ſcorn and ſhame of the long Robe.

Edward Lutterel, who prectiſeth as a Sollicitor, was in that Capacity emp • oyed by Dawſon for ſeveral years, who was indeed the chief means o • his ſuſtenance for that time, he having not bread for either himſelf or children, but what was bought with the money wherewith Dawſon relieved him, who thought he had ſo engaged him by many kindneſſes▪ that he might boldly commit his very life into his hands, as he unadviſedly be-truſted him with his means of live • yhood, almoſt to his utter undoing, as ſhall be particularly related with as much brevity as I can.

He as I ſaid being employed by Dawſon as a Sollicitor, was acquainted with the forgery, and unjuſt devices of Read and Dun, in tended for the ruine of Dawſon, who, as ſoon as by his induſtry, and Gods bleſſing thereon, he could get together 500, or 1000l. worth of Goods, would immediately with Executions taken out upon forged Warrants ſweep all away.

Dawſon at that time having in the County of Norfolk at Walpool, Hay • o the value of about 1200l. being at leaſt ſix hundred Load, which at that time might have been ſold in the place for forty ſhillings the Load, or thereabout, and a ſhort time of ſome months intereſt in the Land on which it grew, and then ſtood made up in Stacks, in which time the graſs upon the Land, was (for feeding Cattle) worth at leaſt threeſcore pound or upwards. Edward Luttrel perſwaded Dawſon for avoiding the malicious miſchief intended againſt him by Read and Dun, to ſell and make over thoſe Goods and Leaſes to him, out of which he would diſcharge 402l. 10s. 2d. which Dawſon was ingaged to ſeveral perſons for, and bring him into his purſe 500l. more, and himſelf defray all incident charges.

Dawſon confiding in the honeſty of Edward Luttrel, conſents hereto, and gives him a Scedule particularly mentioning all his Debts, to whom due, and when payable,; ſummed up in the Total, as was above expreſt, in Conſideration of the payment of which, and the Sum of 500l. over and beſides to be paid to Dawſon by Luttrel, he conſents to the making of an Indenture of Sale, which was accordingly made by his Brother Francis Luttrel the Counſellor, with the Scedule of Dawſons Debts annexed to the Deed, which Edward Luttrel upon receipt of this Deed, undertook to diſcharge, and for ever to acquit Dawſon from, and every part of them, then and there aſſuming, and faithfully engaging his promiſe to pay to Dawſon 500l. over and above the Debts; This Deed was made July 25. 1659. as by it and the Scedule doth more at large appear. Edward having gotten this Eſtate in his hands, began to ſlight Dawſon, bidding him pay his Debts himſelf, nor did he either ſatisfie them as he had ingaged, nor pay to Dawſon one penny, according to his Aſſumption, and faithful promiſe.

Dawſon being thus deluded, and unworthily dealt with, addreſſeth himſelf to the Counſellor (Francis Luttrel) who had promiſed, and undertaken to him, that his Brother Edward ſhould fully perform and make good his promiſe, or he in default of him would himſelf make it good, but he was ſo far from performing what he promiſed, that he threatned Dawſon, that in caſe he ſued or moleſted him upon the ſcore of his promiſe, he would grind him to powder: his Brother Edward boaſting, that before he ſhould pay to Dawſon, or for him, one Groat, the Counſellor his Brother would furniſh him with a 1000l. to ſpend in Law.

From which time both the Luttrels, have moſt maliciouſly combined with Read, the old implacable Enemy of Dawſon, aud other of his aſſociated Confederates, to avoid whom was the firſt pretence uſed, and urged by Edward Luttrel, to induce and perſwade Dawſon to make over the Eſtate unto him.

Which by his own words and Confeſſion, as is teſtified upon Oath by one of his acquaintance, was worth more than 1000l. and made over to him upon that Conſideration, that he ſhould firſt of all pay Debts, to which he agreed, and promiſed the ſame, but ſaid he would neither do it, nor give Dawſon an account of his Eſtate, of which Intention, being demanded the reaſon, gave this, that he had got into his hands the whole by which Dawſon intended, or was able to pay his Debts, or live upon, and therefore was reſolved if he would keep himſelf but honeſt, he would keep him poor enough; Which word of his he hath kept to his ability, For when ever Dawſon brought his Action againſt one or both of them, at Common Law, they would ſue for relief in Chancery, as namely that the Goods were but only made over to Edward in truſt, for the uſe of Richard, and ſo that Condition of payment of Debts, &c. to be only pro formâ, and not intended to be interpreted to the prejudice of Edward; upon 〈1 page duplicate〉 〈1 page duplicate〉 which and the like falſe ſuggeſtions, Dawſon was tied up by Injunction and Orders not to proceed at Common Law, till the Cauſe were heard in the Court of Chancery, where when Dawſon preferred his Croſs-bill of Complaint, expecting to have the merits of his Cauſe heard by the Right Honourable the Lord Chancellor; In ſtead of Anſwer, he had an old Outlawry, long before reverſed, and ſuperſeded, pleaded in Bar to his Complaint, to diſprove which, coſt the ſaid Richard much money, beſides great trouble and delay of time; To adde to whoſe incumbrance, and if poſſible to make him for ever uncapable to proſecute thoſe oppreſſing betrayers of his peace, Edward hath cauſed to be ſued againſt him moſt of thoſe Debts which he had engaged to diſcharge and pay, yet keeps his Eſtate without ſatisfaction therefore, or account thereof given to Dawſon, pretending it was formally made over to him only in truſt, which truſt he hath made good with a vengance; But in truth the Goods were abſolutely ſold▪ and the Deed of bargain and ſale delivered to him (bonâ fide) upon which he received them, took them into his poſſeſſion, ſold as much of them as according to his own words would ſerve his turn, and then complied with Read to ſeize the reſt (as Dawſons goods) which he upon abſolute ſale, aud delivery, had enjoyed and poſſeſſed for many months together, with the Land which Dawſon made over to him, for the full time of his Leaſes therein, without moleſtation of Read, Dun, or any other, and had them alſo ſix months in poſſeſſion after the time was expired, which Dawſon made over to him by vertue of his Leaſes.

Yea when Dawſon after the Sale and Delivery (being with him in Norfolk) adviſed him to the ſelling of the Hay, in which he had more inſight then Luttrell; he bad him meddle with his own buſineſs, for he had nothing to do there with either the Goods or Ground, which were ſold and made over to him; And after that, when Dawſon perceived that he did not pay thoſe debts, he deſired of him, that he would either ſell the Goods, and make payment, or reſign them to ſome other, who would give ſecurity, to indemnifie him, (the ſaid Luttrell,) as to his ingagement of paying debts; but he replyed, the Goods were his own, which he would neither reſign, nor ſell, but when he ſaw his own time. Nor was he aſhamed to boaſt, that he had met with ſuch a bargain from Dawſon, that he would put 500l. into his own purſe thereby, which it were ſtrange if he could do any other way, than by cheating him of the whole, and that was the courſe he took, in which he was incouraged and ſupported by his Brother.

And ſuitable to the dealing of him, in this Caſe of Hay and Leaſes of Land, was another trick of knavery put upon Richard by Edward about the ſale of a Coach, which coſting Richard 40. l. he ſold it to Luttrell for 30l. by a Deed of Sale, which 30l. he the ſaid Richard ordred Edward to pay 5l. to his Brother Francis Luttrell, and 25l to Richard Norwich, which payments (ſo ordred) Edward Luttrell did aſſume and promiſe to make; upon which only conſideration, the Bill of Sale for the Coach was by Richard delivered to Edward.

Francis Luttrell who ordered the Deed to be made, accepted of this payment from his Brother Edward, and did thereupon diſcharge Dawſon of the Debt of five pounds, though ſince the Coach is ſold by Edward, and the money for it received, and ſpent, Francis makes new demand of the money from Dawſon, Edward refuſing to pay either his Brother Francis, or Richard Norwich, but when ſued for this Debt of thirty pounds by Dawſon, he firſt by Levata querela, removed it into the Mayors Court, where by his Bill, he pretended himſelf only a Truſtee for the Coach, as before he was for the Hay, though ſuch truſts ſo diſcharged, will ſhortly bring him to be truſted by none.

For theſe have been his continual Subterfuges, firſt to pretend only a truſt in Dawſons Goods, that he might have colour to ſue for relief in Chancery, and there in ſtead of making anſwer material to the Cauſe depending, to plead old reverſed Outlawryes in Bar, ſo that at once Dawſon is tied up from his legal courſe of proceeding (by Injunctions) and debarred in Chancery to proſecute thoſe his Bills, till he hath with great coſt and trouble diſproved the pretended Outlawryes to be in force, of which Luttrel hath made his brags to ſeveral of his Companions, as is by ſome of them teſtified upon Oath, and alſo upon Record.

Nor is this all▪ though it argue a mind as bad as bad may be, but by compliance with the Clerks of Chancery, this Luttrel hath not ſeldome penned his own Orders, which have been entred down according to his own words (as can be proved againſt him undeniably) upon which advantage it is not to be wondred at, that Dawſon is ſtill the ſufferer, when his Enemies profell, are in effect the Contrivers of their own Orders, which no doubt (having that liberty) they pen with the greateſt advantage for themſelves▪ To prove which Charge real, the laſt Order which was left for Richard at the Regiſters Office, was every word thereof, the hand-writing of Edward Luttrel, which he hath in readineſſe to ſhew, in caſe it be required of him.

Now how ſad the Caſe of Dawſon is, may be collected briefly, if we conſider his preſent Condition, and compare it with what he was formerly, one who dealt for at leaſt 20000 l. per annum. Rented in Land (for feeding of Cattle, and for Hay) 900 l. annually, and by Gods bleſſing upon his Endeavours, had by his Induſtry gotten ſuch an Eſtate, by which He and his Family lived comfortably and plentifully, whoſe Credit would have paſt without ſcruple for 3. or 4. thouſand pounds: now to find him a Priſoner, his Eſtate pluckt away from him by Knavery, Injuſtice, Perjury, and Subornation thereto, Forgery, and Counterfeiting his Name and Perſon, by which means he is damnified at the leaſt 8000 l. beſides what by his Induſtry in this time he might have got thereby, in his way of dealing, for want of which money (although he hath made legal recovery of the greateſt part of it) he hath Contracted ſome Debts, which he is unable to ſatisfie, unleſs he might have his due from others, one of which Debts due to him upon Judgement (if paid) would diſcharge every real Creditor that could juſtly make demand of moneys from him.

But in ſtead of payment, theſe honeſt Debtors to Dawſon, have all combined together in a mutual engagement never to diſcharge one Farthing, yet are men of able Eſtates, Portington a man reſponſible, detaining 1297 l. 13 s. 4 d. for above 12. years, and putting Dawſon to at leaſt 1000 l. charge firſt and laſt, in recovering and defending that Judgement againſt him: In Execution for which, although he hath been 10. years and upwards, one of Sr. John Lenthall • (faſt and looſe) priſoners, yet ſo he is reſolved rather to dye, than to pay a Farthing of this Debt; Read alſo, againſt whom Dawſon hath recovered 718l. for his deceitful ſeizing his Goods by vertue of a Warrant of Attorney (which was ſatisfied) and 500 l. againſt him, and other his Confederates, for Dammages ſuſtained by a Commiſſion of Bankruptſhip, ſued out againſt Dawſon, upon a forged Warrant to confeſſe a Judgement, as hath at large been declared, yet he boaſts that (rather than pay a Groat) he will rot in priſon, though he hath at command ſeveral thouſand pounds to maintain him, which with his Land he will ſo make over to Feoffees in truſt, that the Plaintiff ſhall never get penny, not know how to find his Eſtate: And although at another time he took away a thouſand pounds worth of the Goods of Dawſon, upon a forged Judgment; In diſproveing of which, and diſcovering the Forgery, Perjury, and Subornation to Perjury, committed therein, it coſt Dawſon ſeveral hundred pounds, and though the order of Court were, that upon diſproving that Warrant to be real, the Goods levied in Execution ſhould be returned to the Owner of the ſame, yet he hath not yet received nor can get the leaſt ſatisfaction therefore; Nor will the Sheriff of Norfolk make return of that Writ of Execution, upon which he took away the Goods of Dawſon, and ſold them almoſt two years ſince; To which oppreſſions may be added the giving away a Judgement of 805 l. recovered againſt Binks, by Nabbs, upon Commiſſion granted him by Lenthal, then Maſter of the Rolles, to hear and determine that Cauſe without appeal, which he determined without hearing Dawſon, or any Witneſſe, Counſellor, or Sollicitor in his behalf, giving away moreover, beſides the Debt, 200 l. and upwards for Coſts.

And laſtly Edward Luttrell upon pretence of ſecuring Dawſon from the like future plots of Read, and his complices, with promiſe (as hath been related) of paying Dawſons real Debts, and bringing an overplus into his purſe, for the maintenance of him, his Wife, and Family, hath cheated him of all he had left, his Brother and he now complying with Read and Portington not only to defraud, but to grind and ſqueeze Dawſon, and bring him to utter ruine, (a bad requital of the many years kindneſſes ſhewed by Richard to Edward, whom he kept from ſtarving) who now if it lay in his power would ſtarve him and his.

And that the falſehood and baſeneſſe of theſe two Brothers in iniquity may be made more evident, beſides the ingratitude of Edward, which according to the Aphoriſm in Ethicks (Ingratum ſi dixeris omnia dixiſti▪ ) includes all that can be ſpoken evil concerning any perſon; it will not be amiſs to hint in brief, the remarkable honeſty of the Counſellor Francis, who being ſummoned by Richard at the Tryal between him and his Brother Edward, concerning the Debt of thirty pounds, due upon Sale of a Coach, at which Deed of Sale, Francis was preſent, and ordred the making thereof, and thereupon accepted 5 l. from his Brother Edward, which was due to him from Dawſon, yet he againſt his own Conſcience and Knowledge, ſwore that the Deed was there made fraudulently, for the defrauding of ſome Creditors, which Edward upon a former Deed of Sale (of Hay and Leaſes of paſture ground) made to him by Richard, had a year before, undertaken to diſcharge, yet Francis upon Oath declared, that to Evade thoſe Debts, the Coach was only colourably made over to Edward in truſt, and no otherwiſe, to be redelivered upon demand at the pleaſure of Dawſon; At the time of making which Oath, all of the Long Robe preſent in Court, bleſſed themſelves to hear him ſo ſwear, the Judge telling him openly, that Oath could not be true, or if it were, it would argue himſelf to be a very Knave: not long after which Tryal the Coach was ſold, and the mony ſhar'd, but not a penny paid either to Dawſon or his Order. Now what Juſtice can be expected againſt ſuch perſons, that can, and dare ſo ſwear, let the World Judge▪

Nor was this only a failing at that preſent in the Counſellor Francis, but according to the relation of his Brother Edward, to Dawſon (in the hearing of ſeveral perſons,) Francis the Counſellor, made offer to him (the ſaid Edward) of 300 l. ſterling, conditionally, that he ſhould make Oath againſt Sir Allein Appeſly, that he was one in Sir George Booths deſign, in thoſe times to have brought both the life of that worthy perſon into danger, and confiſeated his Eſtate, which he in his conceit was juſt graſping, only wanted ſuch a deſperate ſwearer, fully to accompliſh this intended Villany; from whom, and ſuch as he is, God of his Mercy deliver each honeſt man.

For of late Edward Luttrell, hath gone from party to party, with whom Dawſon had formerly any dealing, to procure them to enter Actions againſt him, and ſeveral with whom he never had to do, nor doth know the perſons, have by his perſwaſion, and Reads, brought againſt Dawſon great Actions, upon which (to the number of 30 and upwards amounting to the Sum of about 1600 l.) he is now deteined Priſoner, of which there is not an hundred pounds due; but ſome of the parties dead two years ſince, in whoſe names Actions are now brought, others ſatisfied as long time agoe, nor know of the entring any ſuch Actions at their Suit; others never known to, or heard of by the Defendant Dawſon, yet have Actions againſt him, (viz.) 560 l. pretended to be due upon Bond, unto William Marriot and Thomas Bre • tford, of whom he never had knowledge, much leſſe dealing with them. Alſo 200 l. entred at the ſeveral Suits of Thomas Osborne, and John Bates, with whom likewiſe Dawſon never had dealing, beſides other Fob'd Actions, too tedious to name particularly.

The greater part of which were not charged upon Dawſon at his firſt impriſonment, although then the Luttrels, Read, and their Confederates boaſted, they had him faſt for his life time. To accompliſh which deſign (to their power) Sir John Lenthal (with whom Dawſon never had to do, more than to ſue him for the wilfull eſcape of Portington, whereby he is damnified at leaſt 1500 l.) this laſt Eaſter Term, 1661. by Habeas Corpus, fetch'd him over to his priſon, where he was loaded with fob'd Actions, to hinder his proſecution of that eſcape of Portington, and the ſeveral in • ictments of perjury, which are found againſt Read, and ſuch as were ſuborned by him, and his procurement, among whom one is an Enginee • to, and Servant of Sir John Lenthal, that keeps many ſuch Cattle, who it is to be feared, ſerve his turn in the like Caſes, oftner, than I hope will hereafter be ſuffered, or elſe woe to thoſe whom he and others of ſuch Conſcience deſign to ruine. From which priſon with very great coſts and charges (which were encreaſed by the number of feigned Actions) Dawſon was compelled to remove himſelf back to the Fleet, not accounting his perſon ſafe, in the Kings Bench Priſon, where the Keeper is ſo great a Confederate with his moſt malicious implacable Adverſaries.

HAving thus, with as much brevity as I could, related my great grievances, under which I have long groaned, and for remedy whereof I have tryed many wayes (for divers years) both in Law and Equity; But by reaſon of the Corruption of former times, the power, and number of my Adverſaries, and mine own inability (at length) to proſecute them in a Legal Courſe, being reduced by theſe long oppreſſures, to great ſtreights, and at preſent a Priſoner, loaded with many Malicious Forged Actions, to hinder my Liberty, upon reaſonable ſecurity ſuch as my preſent conditition will afford me to procure.

Some of my Creditors by the instigation of Read, Portington, and the Luttrells, having proſecuted me to Judgement, and charged me in Execution thereupon, only to hinder my going abroad without charge of an Habeas Corpus, or Day Writ, which (with the allowance for a keeper, Chamber-rent and Outgoing Fees) amounting to at leaſt 10 or 12 s. each day, is ſo great a burthen, that while I am ſo Confined, or have Liberty at ſuch rates, I can expect nothing but utter ruine to my ſelf, and all that are neerly related, and dear unto me.

Wherefore all other hopes failing me, the laſt remedy, left me, is to fly unto the ſhelter of the moſt Honourable, the Lords and Commons in Parliament now Aſſembled, to ſpread (moſt Humbly) my Cauſe before them, and with all poſſible Submiſſion to Beg and Implore their Gracious Help and Aſſiſtance.

My Caſe Right Honourable Lords, and Worthy Gentlemen, although private, is not of private Concernment, nor bounded within private limits, for as Read hath dealt by me, and mine, ſo hath he dealt by divers others, twenty Families at least I could name, whom by the like A • ts he hath ruined and deſtroyed, and ſeveral fellow-Priſoners I meet with daily, oppreſſed by the ſame courſes of injuſtice, falſe Oaths, counterfeit Warrants for confeſſing Judgments, falſe Actions, under which they are detained, &c. by which wayes of unjust vexation, together with the exceſſive, unreaſonable charges which (through the corruption of times) now accompany impriſonment, many are reduced to that extremity that they want for the conveniences of life, much more unable are they, by any means of addreſſe to ſeek for relief.

My Lords and Gentlemen; You are your ſelves the fathers of Children, whom God long preſerve and bleſſe; Howbeit none of you can promiſe to them a future immunity from the like miſeries, unleſſe this Cockatrice-Egge of corruption and injuſtice be cruſhed, which no foot, but ſuch a foot of Authority can do. Theſe unjust vexatious, Law Suits, or rather Law Cheats, bringing ſweet gain to very many, who though they will not openly defend, yet will connive at ſuch practiſes, ſo lucriferous and beneficial to themſelves, and their dependants.

But conſidering there is legal profit ſufficient, allowed to all honeſt Miniſters of Juſtice, and what comes in this way, is ſqueezed out of the heart blood of his Majesties most faithful Subjects, thouſands of whom have been ruined in their Eſtates, Credit, or both, by ſuch illegal proceedings. My caſe alſo being ſo groſſely and fouly exemplary, that it cauſeth amazement in all who hear it: I doubt not, but that your Honours and Wiſdomes will think of a way of relief, as for all the like oppreſſures in general, ſo for your moſt humble Supplicant in particular, that we may have cauſe (from our hearts) to bleſſe God for the happy change of times, when our bowels ſhall be refreſhed, our miſeries conſidered, and out unjuſt vexatious oppreſſures relieved, by your power, prudence, and justice.

I ſhall not dare to preſcribe any means to ſo grave, wiſe, and honourable a Council, but with all humble ſubmiſſion expect and wait for ſuch a remedy as ſhall appear meet to your judicious breaſts, praying the great God (who ſits in your Aſſembly,) ſo to aſſiſt you with his bleſſing from above, that you may your ſelves become a bleſſing to this Kingdome, a Sanctuary to the diſtreſſed, a defence againſt wrongs and injuſtice, and a refreſhment in particular, to