WHILST some of those whom Sir Ro­bert King thought he had ob­lig'd [Page 4] to be his Friends, ex­prest their Unkindness to him in reproachful Discourses only, he judg'd it unnecessary to return any Formal Answer to them in Writing; believing his own Reputation so well Esta­blish'd in the World, as to be a sufficient Defence against the most violent Efforts of that nature: But seeing those se­vere Reflections that were past on him (tho' as unjustly rais'd, as industriously spread abroad) are lately form'd into a Libel, and publickly appear against him under the Specious Title of Materials, for a Bill of Dis­covery against Sir Robert King, &c. He thought himself ob­lig'd to vindicate his own [Page 5] Innocency, in the same manner in which it was aspersed, by returning a distinct Answer to each particular Article of his Accusation.

And tho' the Author of the Materials of that Bill of Dis­covery, or rather of Indictment, against Sir Robert King, has been very careful in observ­ing the known Maxim of mischievous Policy, by sup­plying the want of Truth in the Accusation, by the Boldness and Heinousness of the Charge: Yet I do not question, but that the Answer which is here return'd to that Scandalous Libel, is so full and convincing, that it will for ever silence the unrea­sonable Clamour of Sir Ro­bert's [Page 6] Adversaries, and effectu­ally acquit him in the Judg­ment of all candid and in­genuous Men.

The confus'd Materials of this pretended Bill of Disco­very may be reduc'd to these Four Heads. First, Those Matters that relate to Sir Ro­bert King's Guardianship, of the late and present Lord King­ston. Secondly, The Circum­stances of the present Lord's Marriage. Thirdly, The late Lord's Disinheriting the present Lord, and Settling his Estate on Sir Robert King and his Heirs. And, Fourthly, the Settlements, and other Deeds, relating to the late and present Lord King­ston's Estate.

[Page 7] The Complaints relating to the First Head, are these:

That John Lord Kingston, the Father of the late, and present Lord, having design'd his two Sons to be committed to the Tui­tion of the late Earl of Arran, by reason their Uncle, Sir Robert King, was too near related, and in Remainder, for want of Issue, of them, to the Estate of Boyle, Sir Robert King, by his Accom­plices, particularly Anthony Ray­mond, perswaded the late and present Lord to chuse him for their Guardian.—That by Contrivance of the said Raymond, Sir Robert got all the Patents, Rent-Rolls, &c. into his Hands, and pick'd out such Instruments out of his Brother's Agents, Stew­ards, [Page 8] &c. viz. Raymond, Gosling, Captain Caulfield, as enabled him to carry on his De­signs against his Nephews. That he Acted solely without the Concur­rence of the other Executors.—That Captain Blackwell, one of the Lord John's Trustees, and always an Opposer of the Designs of Sir Robert, was bought off from Acting; That Sir Robert never return'd an Inventory of the Goods and Chattels, nor any Ac­count of his management into the Prerogative Office.—That immediately after the late Lord John's Death, he remov'd the pre­sent Lord from Kilkenny-School, and for the space of a Year gave his Brother and him the liberty to follow their own Inclinations; which [Page 9] gave the Eldest an Opportunity of minding nothing but Hunting, and keeping mean Company: and the Youngest of Trifling away his Time very Idly also: and that when the late Lord was perswaded to go abroad, Sir Robert would not permit the present Lord to Travel into France with his Bro­ther, tho' earnestly desir'd with Tears; nor wou'd send him over to him, tho' his Brother writ fre­quently and pressingly for him, and sent Captain Pach to bring him: That the present Lord being placed at Charlevile-School, and com­mitted to Raymond's Care, he was wholly neglected there; his trusty Servant Roger Brennan, being turn'd off by Sir Robert's Orders, and a Boy preferr'd to [Page 10] wait on him, who was not capable of serving him, nor of seeing any ill designs that were form'd against him; That on Sr. William King's taking notice of, and expressing a concern for his ill usuage there, he was remov'd thence, on a pre­tence that Sir William King de­sign'd to Marry him to his Daug­ter; That being brought to Boyle and one Lightbourn appointed to be his Tutor, they both spent their whole time in Idleness; Sir Robert King in the mean while not vouch­safing to make the least Enquiry concerning his Studies, or any thing that tended to his good, though he lived within three Miles of Boyle. That being sent to the College, he was within some few Months after his Admission remov'd to Abby­boyle. [Page 11] That Sir Robert by neg­lecting to disburse three hundred Pounds for this present Lord's use, when he and Raymond had Fifteen hundred Pounds of his Money in their hands, lost him Captain Holcroft's Estate, which was worth Four Hundred Pounds per annum: That Sir Robert underhand encouraged his Father in Law Capt. Choppyne to buy it, in hopes of his Settling it after his Decease on Sir Robert and his Heirs; and in fine, that Sir Ro­bert King, to avoid giving an Account of his Trust, which he had broken in sundry particulars; shifted off the Guardian-ship of the present Lord, and plac'd it on the late Lord Robert, who was then but just Twenty one Years of Age.

[Page 12] To all which the following Answer is return'd: First, That Sir Robert King was so far from endeavouring to divert John Lord Kingston from appoint­ing the late Earl of Arran to be Guardian to his Sons, that he never knew or heard of his having form'd any such Design; and that after his Death (there being no Guardian nam'd in the Will) most of all the Tru­stees, and particularly that very Capt. Blackwell, whom the Au­thor of the Materials represents to have been always an Opposer of Sir Robert's designs, perswaded Sir Robert to take upon him the Guardianship of the late and pre­sent Lord, not mistrusting that the choice of such a Person [Page 13] wou'd (to speak the least) be any way prejudicial to their Affairs.

For though Sir Robert King was not appointed by his Brother to be Guardian to his Children, there is no reason to Believe that, what is suggested by the Author of the Materials, was the true Occasion of it: For his Brother having nomi­nated him in his Will, by the Name of his Dear Brother, to be one of his Executors, not­withstanding the nearness of his Relation, and his being in Re­mainder to the old Estate of Boyle, he did not, 'tis probable on those accounts, judge him un­qualified to be Guardian to his Sons, especially if it be consi­der'd, [Page 14] that John Lord Kingston was so far from entertaining any Jealous thoughts of his Brother, on Account of the nearness of his Relation, that he often earnestly intreated him to Travel with the late and present Lord, thinking that they wou'd be more safe under the care of Sir Robert, than of any other person: And as Sir Robert do's declare, that he never employ'd Mr. Raymond to perswade the late and pre­sent Lord Kingston to accept of him for their Guardian, (the truth of which Raymond has de­clar'd upon Oath) Vid. Ray­mond's De­position in the Appen­dix. No. 1. So neither were the Circumstances of Sir Robert's Fortune so inconsider­able, nor his Reputation in the [Page 15] World so bad, that he could reasonably be suspected to have had any self-interested design in the management of his Ne­phews Affairs; but on the con­trary, Sir Robert has good rea­son to Believe, that (besides the fatigue of frequent Winter Journeys from Conaught to Dublin, for the security or im­provement of their Fortunes, his long stays there, his trouble in following several of their Law-Suits, and the neglect of his own Business to attend theirs) he expended several hundred Pounds of his own Money, which, tho' laid out for their Advantage, was never placed to their Account, as ap­pears by Sir Robert's Answer [Page 16] upon Oath to a Bill in Chancery in Michaelmas Term 1697. And as the sole intention of his com­plying with the desires of his Nephews, as well as of the Trustees, in accepting the Office of Guardian to them, was to express his Gratitude to his Brother, by his care and good Management of the Persons and Concerns of his Children, so he thought he had discharg'd that Trust with so much faith­fulness as might, if not merit their acknowledgments, yet at least free him from their Cen­sures. And it is sufficiently known to the World, what great regard the late Lord Kingston had for him, and with what kindness and respect he [Page 17] always Treated him, which did abundantly testifie the due sense his Lordship had of his Unckles care in his Education, and of his just management of his Estate; and must needs render the contrary usuage Sir Robert has lately met with from the present Lord, the more un­easie and surprizing to him, he having always had an equal care of the concerns of both the Brothers, and no less af­fection for the Younger, than he had for the Elder, which will appear by the further Answers to the Materials for the pretended Bill of Discove­ries against him.

But amongst all the Libel­lers misrepresentations of Sir [Page 18] Robert's Actions, there is none more groundless and unreason­able than what relates to Capt. Caulfield, Dean Cope, Dr. Quail, Mr. Raymond, and Mr. Gosling; for it can't but appear strange that Sir Robert's intimacy with their Fathers faithful Friends, and imploying his most know­ing and trusty Servants in their business, (which in the opinion of all indifferent Men, wou'd be accounted a Mark of respect that Sir Robert paid to their Fathers Memory, and the best measures he cou'd take for the advancement of their Fortunes, and the surest proof he could give of the uprightness of his intentions) shou'd be objected to him as a Contrivance to carry [Page 19] on his own Designs against them; for certainly these persons might with much more shew of rea­son, be judg'd Spies on Sir Ro­bert's Actions, than (what is in­vidiously suggested) Accomplices of his ill Designs. Among these pretended Complotters with Sir Robert to Ruin the late and present Lord Kingston, Mr. Anthony Raymond is mentio­ned as the Chief; who was not only bred up from his Child­hood under the present Lord Kingston's Grandfather Sir Wil­liam Fenton, and constantly im­ploy'd by him in his business, but as a Mark of Sir William's more than ordinary regard for him, and his entire Confidence in him, was made a Trustee in [Page 20] several of his Deeds, and par­ticularly in a Deed for the Settlement of part of his E­state on this present Lord King­ston. And the present Lord Kingston's Father had so long Experience and so great an Esteem of the Faithfulness of Mr. Raymond's Service, and the Prudence of his Management, that he recommended him to his Trustees, as the fittest Per­son to manage the Estates of both his Children in Munster: So that it happens very un­luckily to the Libeller, That this very Raymond, who is re­presented by him as a mighty Grievance to the late, and pre­sent Lord Kingston, and the Employing of whom is ob­jected [Page 21] to Sir Robert King as a heinous Crime, shou'd not on­ly be constantly employ'd, and much approv'd of by their Father and Grandfather, during their Lives, but also Bequeath'd (as I may justly say) at their Deaths as a con­siderable Legacy to their Chil­dren.

And to make good that fa­vourable Opinion they had of him, and fully to Vindicate Sir Robert King in Employing him, he has (besides the many instances that might be given of his successful Industry in the late Lords affairs) considerably Improv'd the present Ld. King­ston's Estate: For, whereas it was not worth 400l. per an. at [Page 22] the time of his Fathers Death, it was rais'd by Mr. Raymond's Prudence and Care, to near 600l. per an. The Truth of which may appear by the Rent Rolls taken at his Fathers Death, compar'd with that which was given in to the present Lord Kingston, when his Lordship took the management of his Estate into his own hands.

And as by what has been said (and is ready to be prov'd) Sir Robert King's imploying Mr. Raymond in the concerns of both his Nephews, is abun­dantly justify'd, so what is ob­jected concerning his Acting without the Concurrence of the other two Executors, will be fully clear'd, if we consider that the [Page 23] late Lord Kingston, who was named First Executor in his Father's Will, was at the time of his Fathers Death, and for some Years after, in his Mino­rity; and on that Account was not so properly qualify'd to Act; and that the late Lord Chief Justice Povey, who was the other Executor, had not leasure, by reason of the Pub­lick Station he was in, to at­tend such Affairs; and that tho' by frequent Indispositions of Body, he was disabled to un­dergo the Fatigues of long Journeys into Munster and Conaught, yet he did give his Advice and Assistance to Sir Robert in the discharge of the Executorship, and approv'd of [Page 24] his management of Affairs as long as he continued in this Kingdom.

As touching Capt. Blackwell, he was a Creditor as well as a Trustee, and by his indeavour­ing to Impair rather than Improve the late Lord Kingston's For­tunes, he became indeed a con­stant Opposer of Sir Robert's de­signs, viz. of preserving the late Lord from being wrong'd by him; for he having claim'd a greater Debt than was really due to him, and Sir Robert re­fusing to pay it, the Contro­versie was referr'd to Sir John Temple's Determination, who awarded him 1000l. instead of 1500l. that he demanded, as appears by the Award in Mr. [Page 25] Sprig's hands, which as soon as he received, he quitted his Charge and went away to Eng­land. So that now the Reader may perceive that the Money paid to Capt. Blackwell, which is represented by the Libeller as a Bribe, was the Discharge of a Debt; and what is said con­cerning his being Bought off from acting as a Trustee, is to be understood of his being cut off 500l. of what he demanded as a Creditor.

Of this and all the other Debts and Credits, Goods and Chattels of John Lord Kingston, Sir Robert many Years ago re­turn'd a perfect Inventory and Account into the Prerogative Court, and there, if the Libeller [Page 26] be pleas'd to make a Search, he may better be Inform'd what reason he has Verily to believe that Sir Robert did never make any such return into that Office.

Nor is the Libeller less mi­staken in what he says concer­ning Sir Robert's getting into his hands all the Patents, Deeds, Rent-Rolls, &c. belonging to John Lord Kingston, for they never were in Sir Robert's hands, but were still lodg'd with Mr. Raymond, as with a Person who knew the matters contain'd in them more perfectly, and cou'd manage them more dexterously than any other for the Interest of the Orphans: Though if Sir Robert had kept them in his hands it could not reasonably [Page 27] be imputed to a Guardian, as a Crime to have the Writings relating to his Ward in his own Custody.

Nor can Sir Robert suffer in his reputation by those ground­less reflections that are pass'd upon him by the Libeller, in reference to the Education of the late and present Lord King­ston, there being many Persons of great Veracity and consider­able Character, in this King­dom, that can vouch for Sir Robert's Care of their Breed­ing, and Tenderness of their Persons; for it is sufficiently Notorious, That soon after the Death of John Lord King­ston, Sir Robert King having occasion to be in Dublin for [Page 28] some time to prove his Bro­thers Will, &c. his two Ne­phews were all the while in the same Lodgings with him, Eat at the same Table, and after about two Months stay, went together with him into the Country, and for the most part of that Year were with him in his House at Rockingham, where they were Treated with a respect suitable to their Qua­lity, and with a kindness equal to what he ever shew'd to his own Children; and were so far from being neglected in their Education, or permitted the liberty of following their own Inventions, that Doctor Quail. (a Person of known worth and Prudence, who had [Page 29] been Tutor to the late Lord Kingston in his Fathers Life­time, and was much Esteemed by him) did not only continue in the same Station, but had the present Lord also commit­ted to his care; and though the late Lord did for a while fol­low with too much fondness and application, the Divertise­ments of the Country, yet Sir Robert was not wanting in his Duty to him, but still imploy'd his whole Interest and Autho­rity to restrain his too eager Prosecution of them; and within a Year his Lordship was prevail'd upon, by his Unkle's Advice, (which was agreeable to his Father's De­signs) to quit all his Diver­sions [Page 30] at Home, to improve himself Abroad, being assisted by the Prudence and good Management of Dr. Quail, who was appointed by Sir Robert to be his Tutor and Compa­nion in his Travels.

And as the late Lord did not, at the time of his leaving this Kingdom, seem desirous of his Brother's Company a­broad, so notwithstanding what is suggested by the Libeller, Sir Robert never receiv'd any Letter from his Lordship, in­timating his Desire of having his Brother sent over to him into France, nor did Sir Robert ever know that Captain Pach was sent by the late Lord to bring his Brother thither, but [Page 31] to be his Tutor here. It may be true, that the present Lord did then, as the Libeller says, press his Unkle, and perhaps with Tears, to send him along with the late Lord Robert, but was deny'd; for Sir Robert did not judge it consistent with his Gratitude to his Brother's Memory, and the Interest of his own Reputation, (being, next to his Nephews, Heir in Remainder of the Estate in Conaught) to expose his Bro­ther's whole Family at once, and in their Nonage too, to the many and great Hazards of Travelling into Foreign Parts; and therefore thought it better to run the Risque of incurring the Censure of Un­kindness, [Page 32] from some indiscreet Persons, than too fondly to gratifie the imprudent, tho' earnest Desires of a Youth, who, in the Materials for a Bill of Discovery, is represented as being then but Thirteen Years Old; for certainly one of that Age, tho' well fitted for the Advantages of that sort of Education that is to be had at Schools in his Native Coun­try, is very little qualified for those Improvements that are to be acquir'd by Travelling into Foreign Kingdoms: and accordingly Sir Robert, instead of permitting the present Lord Kingston at that time to go for France, sent him to a then celebrated School at Charleville; [Page 33] and instead of his Trusty Ser­vant, Roger Brennan, as he is call'd in the Materials, (who had left the Family before John Lord Kingston's Death, and who afterwards declar'd him­self a Papist) Sir Robert ap­pointed an honest Protestant Youth to attend him; and or­dered Mr. Raymond, who liv'd near Charleville, to have a more than ordinary Care and Inspe­ction over him: And there being, some time after this Lord's going thither, a Report spread abroad in those Parts, of Sir William King's designing to Marry his Daughter to him, Mr. Raymond according to his Duty, gave Sir Robert King an Account of what was generally [Page 34] discours'd: And tho' the Libel­ler intimates that Raymond him­self was the Author of that Story, (being, as he alledges, provok'd thereto by Sir William King's kind reception of the present Lord at his House, and his resentment of his Lordships ill usage by Raymond at Char­leville) yet Sir Robert do's not think he has any reason to be­lieve that Mr. Raymond did raise that report, but that the dis­course in those parts concern­ing that matter, came first from others, and is fully satisfied that Mr. Raymond according to his order, furnish'd this present Lord Kingston during his stay at Charleville, with all necessaries and conveniences suitable to a [Page 35] Gentleman of his Age and con­dition, though not with Super­fluities to gratifie the Extrava­gancy of his Temper. And Tho' Sir Robert do's not question Sir William King's kind concern for, and obliging Treatment of the present Lord Kingston at his House, yet he do's not know of any Liberty he gave him of Courting his Daugh­ter, much less of his designs of Marrying her to him: How­ever Sir Robert do's acknow­ledge, that though the present Lord Kingston's Matching into so Worthy a Family, and with a Lady so excellently accom­plish'd, and of so considerable a Fortune, was a thing that wou'd have been very accept­able [Page 36] to him; yet, if there had been such a design, the con­sideration of the great dispa­rity of their Years, and the re­flections that might justly be past on him on that occasion, wou'd have made him unwil­ling to promote so unequal a Marriage; for that Lady who was judg'd no unfit Match for the Father, and was to have been Marry'd to him, if his unexpected Death had not in­terven'd, cou'd not reasonably be thought a proper Wife for the Son, who was then but 17 Years of Age; and therefore Sir Robert, on notice giv'n him of that Report (how ground­lesly soever rais'd) thought it Prudent to remove the present [Page 37] Lord Kingston from Charleville to Abby-Boyle, where he re­main'd till he was entered into the College at Dublin, from whence he was indeed much too soon remov'd, not, as is sug­gested, in order to the giving him opportunity to Prosecute his dishonourable Amour, but in compliance with his earnest desires of going into the Coun­try for the recovery of his Health; and to prevent any loss of his time there, Sir Ro­bert laid out for a Tutor for him in the House, and consul­ted the present Lord Bishop of Waterford (who had been Tutor to him and his Brother in the College) in the choice of one who recommended Mr. Light­burn [Page 38] to that Office, under whose Tuition he continued at Abby-Boyle, near Sir Robert's House, plentifully accommodated with all conveniencies without any Charge to him. The Author of the Materials is pleased to discover some Secret mis­spendings of my Lord's time with his Tutor, by playing at Cards, and keeping Idle Com­pany, on purpose to cast a Reproach on his Unkle; Yet as those that knew Mr. Light­burn, will be apt to judge that he was not so blameable as he is represented, so every Con­sidering man knows that this Suggestion, tho' true, can be no just Reflection on Sir Robert's care of his Nephew; for no [Page 39] Guardian is accountable for the secret irregularities of his Ward, they being of such a Nature, that no care can prevent 'em, no Guardian but a Guardian Angel can always discover them, and no Advices nor Ex­ample, without the Grace of God, can effectually restrain them.

To what is objected by the Libeller concerning the present Lord Kingston's losing Captain Holcroft's Estate of 400 l. per annum, by Sir Robert King's neglecting to expend 300 l. for securing it, when he and Ray­mond had 1500 l. of the present Lord's Money in their hands, and Captain Choppine's buying that Estate by Sir Robert's advice, Sir [Page 40] Robert returns this Answer, That he was so far from ad­vising Cap. Choppine to Purchase Holcroft's Estate, that he never knew of his having any designs that way, till he understood by Councel that the present Lord's Title to that Estate was Null; and tho' Holcroft's Estate might perhaps have been sometimes worth 400l. per an. yet before Choppine had any dealings with him, See Tho. Yeeden's Affidavit. Appendix. No. 19. he had sold all but 80 l. per an. which is the whole that Choppine ever Purchas'd from him: And further Sir Robert does declare, That neither he nor Raymond, as he verily be­lieves, had ever so much as four hundred Pounds, much less 1500l. at one time, of the [Page 41] present Lord's Money in their hands: The charge of his Education, and the Law-Suits, (by which his Estate was so considerably improv'd) toge­ther with his own Expences, which were very large, usually Exhausting the greatest part of the Yearly Income of his Estate, as is plain by Raymond's Ac­counts. See also Appendix. No. 21. An Account stated by the present Lord Kingston. And further says, That before the Deeds rela­ting to Holcroft's Estate were question'd, Sir Robert had giv'n up his Guardianship of the pre­sent Lord, and transfer'd it to his Brother, and never after­wards Intermedled with his Estate.

As to the only remaining objection relating to Sir Robert's [Page 42] Guardianship of the late and present Lord Kingston, which, in the Libellers Phrase is, Sir Robert's shifting off the Guardian­ship of the present Lord, to avoid giving an Account of his Trust, which he had broken in several par­ticulars, and placing it upon the late Lord Robert, who was then but just Twenty one Years of Age. The Answer in the behalf of Sir Robert is, That as the Re­signation of his Guardianship, and delivering it to the late Lord Kingston, did not in the least exempt him from being Accountable to the present Ld, for the former discharge of his Trust; so Sir Robert having nei­ther made nor design'd the least advantage to himself by the [Page 43] management of his Nephews Estate, he had no reason to fear the strictest Examination of his Accounts; but he must acknow­ledge that the successfulness of his care in the Education of the present Lord, made him willing to embrace so fit an opportunity of being quit of his Trouble; and he does de­clare, that as the sole design of his taking on him the Guar­dianship of this present Lord, was the promoting of his good; so the end of resigning it, was the preventing of his Ruin; for being advis'd that the Deeds relating to the present Lord's Estate were defective, and that the Title to them might pro­bably be vested in the late [Page 44] Lord Kingston, as Heir at law, he was fully perswaded that the best Measure he cou'd take for the Security of the present Lord's Fortune, was to place him under the care and Tui­tion of his Brother, being con­fident, that tho' the present Lord's misbehaviour might a­bate the late Lords affections to him, yet it cou'd not the Sence of his own Honour; and that he never wou'd have de­priv'd his Ward of that which perhaps he wou'd not have yielded to his Brother, but wou'd rather have quitted his legal Title to that Estate, than have done any thing mis­becoming the Character of a Guardian.

[Page 45] And now after all the fore-mention'd signal instances of Sir Robert King's care of the present Lord Kingston's Person, Education, and Fortune, let e­very indifferent person Judge what ground the Libeller had for casting that Scandalous Reflection on Sir Robert King, in saying, That for the space of five Years that this Lord Kingston remain'd at Boyle, under Sir Ro­bert's Eye, and under Mr. Light­burn's Care, he never made En­quiry after his Studies, or any thing that tended to his good.

I Proceed to the Second Part of the Libellers Materials for a Bill against Sir Robert King, &c. relating to the Circum­stances [Page 46] of the Present Lord Kingston's Marriage with his Lady.

The Author of these Mate­rials, being sensible of the many considerable disadvantages the present Lord Kingston may lie under on account of his having Married an Irish Woman, a Papist, and one of the meanest of the Servants in his Brothers House, is pleas'd, according to the forementioned instances of his Sincerity, to lay the whole blame of so disgraceful a Mis­fortune on Sir Robert King's connivance at it, and secret contrivance and encourage­ment of it; which he do's in these following words, viz.

That presently after Capt. Pach [Page 47] receiv'd the present Lord into his care, he discover'd his Lordships affection to the Lady he was after­wards Married to, and acquainted Sir Robert King with it, and press'd him to send the present Lord immediately to France, or to remove her out of the Family, to prevent his Marriage, or any other consequences that might attend such affection, which Sir Robert wholly slighted: That Sir Robert cou'd not deny his knowledge of the pre­sent Lord's affection to the Gentle­woman he afterwards Marry'd; for his Lordship having bought her a fine Scarlet Petticoat with a large Gold and Silver Lace to it, which was carried by Mistake to Sir Ro­bert's house, Sir Robert having view'd it, said, he knew it was his [Page 48] Nephews Present to his Mistress, meaning the now Lady Kingston, and ordered it to be sent to Boyle, to the present Lord, without taking any further notice. That after the late Lord Robert return'd from France to Ireland, Capt. Pach continued to caution the said Sir Robert, and the said Lord Ro­bert, who was then his Brother's Guardian, to prevent the growing Affection of the present Lord to the said Gentlewoman; yet not­withstanding this Caution from Capt. Pach, and others, they suf­fer'd the present Lord and his Lady to live under the same Roof, for above Two Years and an half; Capt. Pach still pressing to let him go with his Pupil for France; but was deny'd it. That when the [Page 49] late Lord sent this present Lord for France, Sir Robert knew that this Gentlewoman went with him. That notwithstanding the continual Information Sir Robert had out of France from Captain Pach, and others, of the Intrigues between the present Lord, and the Lady he Married, yet Sir Robert, in his Letter to Raymond, seems to charge the Fault on his Nephew; whereas he might have easily pre­vented the same, had he not been wanting in his Duty as Guardian, and neglected it out of Design.

Now seeing the Libeller thinks fit so freely and Pub­lickly to own the present Lord Kingston's Misfortune in Mar­rying a Person very much be­low him; the following Answer [Page 50] may without breach of the Rules of Civility, be return'd to this Unjust and Groundless Charge.

Sometime after the late Lord Kingston began his Travels, ob­servations were made, and Discourses rais'd, of a more than ordinary and suspicious familiarity between the present Lord Kingston and an Irish Pa­pist, a Servant in the House at Abby-Boyle, which as soon as Sir Robert was acquainted with, tho' he was not in the least mistrustful of his Nephews be­ing so mean spirited as to de­sign to Marry her, yet being Jealous of his Intentions to Debauch her, he not only ex­prest a Resentment suitable to [Page 51] the Character of a good Man, but also took such Measures in that Affair, as became the Pru­dence of a careful Guardian, by giving order to Mrs. Horsey the House-keeper, a Relation to the present Lord, immedi­ately to turn the Girl out of the Family, upon which the present Lord Kingston went to Mrs. Elenor Sankey, one that Sir Ro­bert had a more than ordinary respect for, as being a near Relation to his Lady, and then in his House at Boyle; and (as she has deposed upon Oath,) * told her, with his Eyes full of Vid. Appen. Mad. San­key's De­pos. No. 2. Tears, that he had a Complaint to make to her, which he express'd after this manner; There is a poor innocent Girl in the Castle, [Page 52] which was an Underling, and I saw her a quiet Creature, and I desir'd Mrs. Horsey to advance her to be my Chamber-Maid, and she did so, and immediately Mr. Gosling and some others said, she and I were too great, but I know the Reason why they are so Malitious, She is Honest, and wou'd not yield to them in any ill thing, and they (like unjust People) have told my Unkle, and he is so incensed against her, that he has fully resolved to turn her away, and has warn'd her to be gone; I know you have great In­terest with him, and I beg of you to use it now, that she may stay; And that he and all the World may see my Innocency, I will receive the Sacrament to Morrow on it, I wou'd not for any thing have the Girl [Page 53] turn'd off, and lose her Reputa­tion by me; Pray therefore inter­cede for her to my Unkle. Mrs. Sankey does further Depose, That on this so earnest an entreaty of the present Lord Kingston, she did, to the best of her Remem­brance, speak to Sir Robert King in the Girls behalf, but found him so angry, and so resolv'd to turn her off, that she wou'd not venture to say much to him. But his Lord­ship being very intent on keep­ing that Irish Girl in the Fami­ly, and mistrusting Mrs. San­key's Intercession not to be so prevailing with his Unkle in this affair as that of Dean Cope, the Minister of the Parish, he immediately made application to him, who has Deposed, [Page 54] Vid. Dean Cope's Af­fid. in the Appendix. No. 3. That Sir Robert King, having discharged that Person who is now Lady Kingston, of her Service in the Family, hearing there was too great a familiarity between her and the present Lord, his Lordship spoke to him to Intercede with Sir Ro­bert for her continuance in her Service, urging that the only way to prove the Report of her being with Child to be a Lye, was to let her stay in the Family, and that wou'd disprove it; but if she was sent away, the People at Boyle would conclude it true: Upon which the Dean went (as he declares) to Sir Robert, and press'd him to grant what the now Lord desir'd; and after some serious considera­tion, Sir Robert was pleas'd, out of a tender regard to the [Page 55] present Lord's Reputation, and on the House-keepers promise of a greater Watchfulness, and undertaking to prevent any such future Familiarities, to permit that Girl to continue in her Service.

And it further appears by the Deposition of Charles Gosling Esq Vide Appendix Charles Gosling's Affid. No. 4 that Sir Robert King was so far from conniving at the more than ordinary Intimacy, between the present Lord and Margaret Cahan, the present Lady Kingston, that on Mr. Gos­ling's acquainting Sir Robert with it, he immediately order'd the House-keeper to turn her out of the Family, who accordingly did so, and that it was by this Lords Means She was taken in again.

[Page 56] And from that time the In­trigues between the present Lord Kingston, and her that is now his Lady, were either so long interrupted, or so secretly Manag'd, that Sir Robert King heard nothing of their renewal till after the late Lord King­ston's return from his Travels; and being then acquainted that the former intimacies between them were renew'd, Sir Robert prevail'd with the late Lord Kingston, in order to prevent the bad consequences of his Brothers Imprudent and Dis­honourable fondness of this Girl, to promise a considerable Sum of Money, as a Portion with her, to a Servant in the House, with whom she was [Page 57] very intimate, to induce him to Marry her. See also William Team's Af­fid. Append. No. 16. The Truth of which last Clause, is particular­ly confirm'd by the said Mr. Gosling's Deposition in these words, That Sir Robert King being Guardian to the present Lord, and having a tender care of him, to prevent any occasion of Lewdness or Debauchery, between him and Margaret Cahan, a Servant in the House at Abby-Boyle, did endeavour to get one William Teams, then Under-Cook in the House to Marry her, offering him as Portion, Thirty Pounds Ster­ling, or thereabouts, to the best of this Deponents remembrance. And accordingly the Servant, having so great a Portion pro­mised with her, very thank­fully [Page 58] accepted the Proposal, not doubting the Success of his Wooing; but the Girl having far greater things in her Eye, could not by any Means be prevail'd on to accept of him for her Husband.

About this time, or soon after, that Laced Petticoat (which the Libeller mentions) was brought to Sir Robert King's House at Rockingham, being directed to Capt. King, (by which Name both the present Lord and Sir Robert were then commonly call'd) and Sir Robert perceiving the Mistake, sent it to Boyle to the present Lord Kingston; but was so far from saying (as the Li­beller very groundlesly al­ledges) that he knew it to be [Page 59] a Present from his Nephew to his present Lady, that he So­lemnly declares he did not in the least imagin it to be de­sign'd for her, but on the con­trary, Sr. Robert told Mr. Gosling that he believ'd it was a pre­sent from his Nephew to Mrs. Gosling. But soon after this, Margaret Cahan quitted her Ser­vice in the Family, and Sir Robert with great Joy receiv'd and believ'd the News of her being gone to live with her Friends in another part of the Kingdom; which, as appear'd afterwards, was given out on purpose by this present Lord Kingston's orders to amuse his Brother and his Uncle, and prevent their Suspicions of her [Page 60] then going with him, (as the Libeller says she did) or of her speedy following him to France. For after the late Lord's return from his Travels, Sir Robert King being desirous that his Brother also shou'd have the Advantage of Travelling, be­ing then of Years capable of it, requested the late Lord Kingston, who was then come to Age, and had taken on him the Guardianship of his Brother, to permit him to go abroad, and (notwithstanding what is suggested by the Li­beller to the contrary) it was not without great Difficulty, and after about a Years Im­portunity that his Lorship con­sented to it; and accordingly [Page 61] he sent his Brother to France, under the Tuition of Captain Pach: But soon after their Arrival at Paris, the late Lord Kingston and Sir Robert King, to their great Trouble and Sur­prize, received an account from the Captain, that Margaret Ca­han was not only come to Paris, to the present Lord, but also that the former Famili­arities between 'em, which in Ireland had been happily in­terrupted, were there more dan­gerously renewed than ever; upon which the late Lord King­ston was so highly incensed a­gainst his Brother, that then he first form'd his Design of Disinheriting him, and of mak­ing Sir Robert King his Heir; [Page 62] and accordingly the late Lord often sent to Sir Robert, to ac­cept of the Reversion of his Estate, and to permit a Settle­ment of it to be made on him and his Heirs; but Sir Robert was so far from complying with the late Lord Kingston's Desires, or from taking any Advantage of the Displeasure the late Lord had conceiv'd against his Brother, that he earnestly entreated, and at length prevail'd with his Lord­ship, to send Doctor Quail with all speed to France, to prevent, if possible, the great Mischief the present Lord might bring upon himself, and the Dishonour he might do his Family, by his indiscreet Fond­ness [Page 63] of Margaret Cahan; and accordingly the Doctor was dispatch'd away with Letters, and Advices from them both to this present Lord, then in Paris, to signifie their Resent­ments, and to disswade his Lord­ship from the Thoughts of the present Lady Kingston; and ac­cordingly the Doctor went with Letters, and Proposals of a con­siderable Advantage for the present Lord Kingston, and with great Promises, if he, the present Lord Kingston, obeyed; and Threat­nings of being disinherited if his Lordship would not be advis'd: All which the Doctor deliver'd to the present Lord Kingston; whose Answer was to this Effect, (viz.) That he the said present [Page 64] Lord Kingston had heard of the Doctor's Coming, and his Business, and that his Lordship was very sorry he had incurr'd his Brother's and Unkle's Displeasure, and to avoid it, his Lordship had sent her (meaning the present Lady Kingston) away; and did assure the Doctor, with great and solemn Asseverations, that his Lordship would not concern himself with her any more; yet notwithstanding all these solemn Professions and Asseverations, the Doctor was not only credibly inform'd of the Woman's being still in Paris, but within a while he found out her Lodging, and surpriz'd her in it; and at his next meeting with the present Lord, not only acquainted him [Page 65] with the Discovery he had made, but also assur'd him of the fatal consequences of so Dishonourable an Amour, at which the present Lord seem'd extreamly concern'd, and with­all told the Doctor, that his Passion for her was so great, that he cou'd not allay it. Soon after this, the Doctor having brought his Business to so unhappy an Issue, return'd to Ireland, and gave the late Lord Kingston an account of the whole Affair. Vide Dr. Quail's De­position in the Append. No. 5.

And now, since by the fore-mention'd Particulars it do's appear, that Sir Robert King, on the first intimation given him, of a more than ordinary Familiarity between the present Lord Kingston, and an Irish [Page 66] Servant Maid in his Brother's House, gave immediate Or­ders to have her turn'd out of the Family; and when after­wards he permitted her to be received in again, did it purely out of regard to the present Lord's Reputation, and in compliance with the Importu­nities of those whom his Lord­ship had imploy'd to inter­cede in her behalf, and on the Promise the House-keeper (who was his own Relation) made to prevent all dangerous Familiarity between them for the future; and since it does also appear, that on the second intimation of the Renewal of their Amours, Sir Robert en­deavour'd to persuade a Ser­vant [Page 67] in the House, on Promise of a considerable Portion, to Marry her: And further, that on Intelligence given by Capt. Pach, of her being with the Present Lord in Paris, he pre­vail'd with the late Lord King­ston, to send Doctor Quail on purpose to France, to persuade the present Lord to return to Ireland, with assurance of hav­ing a considerable part of the late Lord's Estate settled on him at present, and the rest in Reversion after his Decease without Issue: Since Sir Robert King, I say, has given so many signal Instances of his Care, to prevent the present Lord King­ston's Marriage with Margaret Cahan, every impartial Reader [Page 68] may not only perceive how groundlessly the Libeller ac­cuses Sir Robert of Conniving at the present Lord's Intrigues with that Irish Servant-Maid, and of designing to gain his own Ends, by his Nephew's unfor­tunate Marriage; but will also be fully convinced, that the most careful Guardian, and the most affectionate Friend, cou'd not have used more hearty En­deavours, nor taken more pru­dent Measures to prevent so lasting a Disgrace to a Noble-Man and his Family, than Sir Robert King has done.

And as these many Evi­dences already produc'd will be abundantly sufficient to e­very unprejudic'd Man, to [Page 69] vindicate Sir Robert King's Re­putation, in all Circumstances relating to the present Lord Kingston's Marriage; so I shall mention one more, which, if any thing, will convince even the Libeller himself of the Falshood of his Suggestions in this Matter: For in his Lord­ship's Address Vid. The Address in the Append. No. 6. to the late King James, (presented to Him by his Confessor) he was so far from Representing his Uncle as a Conniver at his Courting his present Lady, that he com­plain'd of the many Hardships that he suffered on account of Falling in Love with a Native Irish Woman: Nay more, in his printed Case that was then offer'd to the Consideration of [Page 70] the High Court of Parliament in England, tho' he was pleased to pass very severe and ill-grounded Reflections on Sir Robert King, as being Instru­mental in altering the Settlement of his Brother's Estate; yet he did not in the least accuse him of Promoting his Marriage with his Brother's Servant-Maid.

And when it was the present Lord Kingston's Interest to Tax his Uncle (who had been his Guardian) before a Protestant Parliament, with Conniving at his growing Affection to a mean Irish Girl, and a Papist, He had so much Honour as to acknow­ledge Vid. The Case in the Appendix, No. 7. That both He and his present Lady suffer'd many Diffi­culties and Hardships on that Ac­count, [Page 71] before his Affection to her (which, he said, grew up with his Years) could have produc'd a Mar­riage. By which we may per­ceive, that the Libeller has a far greater Zeal for the present Lord Kingston's Service, than Knowledge of his Affairs; or else he would have taken care that the Materials of his Bill in this Kingdom against Sir Robert King should have been more consistent with his Lordship's own Representation of his Case to the Parliament of England.

AND now I proceed to the Third Head of the Materials for the Bill against Sir Robert King; and they are these: That Sir Robert, with [Page 72] his Accomplices, prevail'd with the late Lord Kingston, by all the Artifices he could invent, to Dis­inherit the present Lord, and leave him nothing at all to support the Honour; which the Libeller endeavours to prove, First, by Gosling's Letter to Raymond, August 19. 1679. wherein he writes, That he was commanded to tell him, that the late Lord Ro­bert intended the Term following to cut off the Intail of Michels-town, and desir'd him to provide for it, but privately. From whence it is inferr'd, That there was an Intail on Michels-town, and a Design to cut it off, tho' they were afraid to do it pub­lickly: That Sir Robert King commanded Gosling privately to [Page 73] give Raymond notice of it, and consequently, that Sir Robert pro­jected the Disherison of the pre­sent Lord before Marriage, or any colourable Provocation given.

That several considerable Steps were made by the late Lord King­ston, and his Lawyers, and Capt. Choppine, in Trinity-Term 1682. to levy Fines and Reco­veries of the old Estate of Boyle, in order to Cut off the present Lord's Remainder, and to Settle it on Sir Robert King and his Children.

That Sir Robert came to Mr. Sprigg, in the Year 1683, or 1684, by the late Lord's pressing, as he said, to get a Settlement drawn for Excluding the present Lord, in case he was Married at [Page 74] the time of the Perfection of the said Settlement, but with a Re­mainder left to the Children of a second Wife, that he should Marry, with the Consent of the late Lord, and Sir Robert King, or such of his next Relations as should be then living; and on failure of his Issue Male by that second Wife, to Sir Robert King, and his Eldest Son, and his Heirs Males, with­out power of Revocation or Alte­ration of the Uses.

That according to this Settle­ment Sir Robert King sent a Paper to the Lady Wimbaldon, for the present Lord to sign, and employed Doctor Quail to persuade his Lordship to signifie his Con­sent to that Settlement, by signing the Paper; which the present [Page 75] Lord, as he was advised by his Friends and Counsel, refused to do: That Sir Robert's Design in this was, First, To exclude the second Brother, whom he then knew to be Married; and, Se­condly, To prevent the Eldest Brother's Marriage, by leaving him no Power to alter the Uses in this Deed.

That it was morally impossible that this should be done by any other but Sir Robert King, and his Accomplices; it being very un­likely that the Lord Kingston, who at that time was Young, Heal­thy, and likely to get Children, and to out-live his Uncle, should of himself propose such a Settlement of his Estate, by which he was only Tenant for Life, and no Power [Page 76] left him to make Jointures, or Provision for Younger Children, or Lease for Lives, and which hin­dred his own Marriage, and ex­cluded his Brother.

That Sir Robert left this Deed drawn in Captain Chop­pine's hands, in order to be per­fected, and then went for Eng­land.

That the present Lord King­ston having got from Dr. Quail the Deed of Settlement of the Mannor of Newcastle, (which was settled on him by his Grand­Father) gave Occasion to Sir Ro­bert and Raymond to incense the late Lord against him, tho' his Lordship had no colour of Right to it: That Sir Robert, in his Letter to Raymond, tells [Page 77] him, that since Jack's (meaning the present Lord Kingston's) Extravagancies were broke out in France, his Brother was resolv'd to settle the Estate he has from his two Grand-Fathers, so that it shall not be in his Brother's Power to set it from his Posterity.

That this Deed being dislik'd by Raymond, was never perfect­ed; but another Settlement was made in Decemb. 1684, wherein is a Power to settle Jointures, Por­tions on Younger Children, and to make Leases, with a Power of Re­vocation; but it utterly excluded the present Lord.

That Sir Robert, to give the better colour to what he had done, sent his Case of Conscience, drawn after his own way, to Raymond, [Page 78] (who was then in London) with Instructions to gain the Hands of such Divines as he named, to sign it.

That the late King having had the present Lord's Case laid before him, and reported to him, by the Earl of Rochester, express'd so high a Displeasure at the late Lord's ill Usage of his Brother, that his Lordship promised to do his Bro­ther Right, by leaving Matters as they were intended in the Original Settlement; but was diverted from doing it by the forementioned In­struments.

That on the late Lord's Mar­riage, a new Settlement was made by Sir Robert King's Directions, wherein he got himself and his Children Nam'd next in Remain­der [Page 79] after the late Lord Robert's, excluding the present Lord without Power of Revocation, the said Lord Robert having been plyed with Company, at the Tavern, for Eight Days together, and conti­nually incens'd against his Bro­ther, while the Deed was prepa­ring, till 'twas perfected.

That the late Lord declar'd to his Lady, that he was sorry he had settled the Estate on Sir Ro­bert King; that if he cou'd, he wou'd Revoke or Alter the Settle­ment, or get an Act of Parlia­ment for doing it; as appears by that Lady's Answer to a Bill of Sir Robert's, Filed against her in England in 1694.

That the late Lord Kingston made a Declaration, and Deed un­der [Page 80] his Hand and Seal, Revoking the Settlement made in 1685, on Sir Robert King, and Granting his Estate to his Brother, and his Heirs, if they shou'd come within the Law, and the Remainder to Sir Robert King, which was proved by three Witnesses.

That Sir Robert King Op­pos'd the present Lord's Passing his Pardon, and Reversing his Outlawry; and when his Endea­vours prov'd ineffectual in both, he got an Injunction to Quiet him in the Possession of the present Lord's Estate in Munster, which his Lordship had Entred on by his Servants.

That Sir Robert having Inti­mation given him by Dean Cope, and others, of some Papers being [Page 81] left by the late Lord, for his Bro­ther, us'd means to suppress them; but being Unsuccessful, he rak'd what Witnesses he cou'd, to prove them Supposititious, to bring the present Lord into Infamy, and to Ruine him for ever.

That Sir Robert wrought his Ends so with the late Lord King­ston, as to get him to perfect Deeds to him of 600 l. or 800 l. per Annum of the New Estate.

That from Sir Robert King's Buildings at Rockingham, (to Raise which he made use of the Rents of the present Lord King­ston's Estate, and which are so Sumptuous, as not to bear any proportion to his own Fortune) it may well be inferr'd, that he had his Designs all along on the [Page 82] Lordships of Boyle and Michels­town.

And that because the Deed of December 1684 was revokeable, Sir Robert, or Captain Chop­pine, to get an absolute Deed, pro­pos'd to buy the Town of Sligoe for the late Lord Kingston, and to put 2000 l. in his Pocket, provided he would give up the Possession of the whole Estate to Sir Robert, and settle it upon him, thinking the Estate kept too long from him; which shews his con­stant Endeavour to shake the Lord Robert off, as well as the present Lord Kingston.

Now, in Answer to all the forementioned Particulars, Sir Robert King does declare, first, [Page 83] That he never knew, or heard, that there was any Intail of Michelstown, much less that the late Lord Kingston had any Design of Docking it: And that he never gave Mr. Gosling Or­ders to write any such Letter (as the Libeller mentions) to Mr. Raymond.

Sir Robert King does also further declare, That tho' he heard of several Fines levied by the late Lord Kingston in 1682, of particular Parts of his Estate, for the Security of Creditors, yet of none to his, viz. Sir Robert's Advantage, or with Design of Prejudicing the present Lord.

And as touching what is alledg'd by the Libeller, con­cerning Sir Robert King's com­ing [Page 84] to Mr. Sprigg in 1683, or 1684, and of desiring him to Draw such a Settlement of the late Lord Kingston's Estate as might deprive his Lordship of Power to make Jointures, or Pro­vision for Younger Children, or Leases for Lives, or Years, &c. Sir Robert do's say, That he never spoke one Word to Mr. Sprigg to that intent.

And (as the Libeller him­self acknowledges) Mr. Ray­mond (whom he is pleased to stile Sir Robert's chief Accom­plice) did violently exclaim against the Unreasonableness of such a Settlement: And those very Letters from Mr. Raymond, produced by the Libeller, do plainly prove it to have been [Page 85] solely of Captain Choppine's preparing, and directly con­trary to Sir Robert's Sentiments, he having oppos'd the Making of any such Settlement of the late Lord Kingston's Estate as should be Irrevokeable; and having also often declar'd, as Raymond affirms in his Letter, Vid. Ap­pend. No. 8. The Sub­stance of Mr. Ray­mond's Let­ter, as in the Mate­rials, &c. dated the 20th of May 1684. That he thought it very reason­able that his Lordship should have Power to Alter the Uses, as he saw cause: And it was the Unac­ceptableness of such an Irre­vokeable Settlement to Sir Robert King (which Mr. Raymond very pressingly urg'd in his Letter to Captain Choppine) that pre­vailed with the late Lord to alter his Measures, and put a [Page 86] stop to his hasty Designs of levy­ing a Fine and Recovery upon his Estate.

And so far was Sir Robert from having left this Deed in Captain Choppine's hands, with Instructions to get it perfected, and from going then for England, on purpose that he might not be thought to have a hand in it, that he knew not of any such Deed being drawn, or di­rected to be prepared, when he went for England in February 1683, as he not only solemnly professes, but is also ready to depose upon Oath.

And as touching those Clauses in that Settlement that Captain Choppine prepared, and the late Lord Kingston made, [Page 87] which excluded the present Lord and his Issue from the Remainder of the said Estate; Sir Robert King does freely own, that he was then, and still is of Opinion, that they were such as well became the Honour of the late Lord Kingston to insert, and of the present Lord to have consented to; for (as Sir Robert himself declares, in his intercepted Letter to Dr. Quail, produc'd by the Libel­ler) the present Lord could not sure be against Excluding the Children of Pegg Cahan; to whom, if he be not Married, it cannot prejudice him; if he be, he cannot think her Children fit to Inherit Boyle, &c.

[Page 88] Now, to shew how suitably to his Uncle's Sentiments the present Lord Kingston expressed himself concerning this Affair, and how highly he resented the Injustice of his Friends in suspecting him Married to so mean a Woman, and how se­riously, in all appearance, he declar'd his Abhorrence of so disgraceful a Design, I shall produce some Passages out of his Lordship's Letter Vid. The present Lord Kingston's Letter in the Append. No. 9. to Mr. Gosling, dated from Paris May the 23d. (without mentioning the Year) wherein he severely Reprimands his Friends for their unworthy Reflections on his Veracity and known Wisdom, in believing him Guilty of such an Action as would ren­der [Page 89] him not only a Person of great Imprudence, but also of a profligate Reputation; the Wo­man whom they suppos'd him to have Married, being not only very much beneath him, but also one whom he had very solemnly disown'd by Oaths and Imprecations; for thus he expostulates with them on this Occasion in that Letter; Would that be the Effect of one who was counted Wise, to play the Fool to go Marry a Scullian, tho' he lov'd her never so well. And then complains of the hard Usage he had met with from his Friends, that tho' he damn'd himself to the Pit of Hell, he must never be believ'd; but that Bridget's and Will's Words must go before his Oaths: [Page 90] And threatens Mr. Gosling, that except they send him some Recom­pence for the Injury they had done him, by their unworthy and dirty Thoughts, he would never forgive them. By all which we may perceive, as far as Words are expressive of Mens Thoughts, that the present Lord King­ston, by his Letter to Mr. Gosling, did abundantly con­firm the Truth of what Sir Robert King writ to Doctor Quail, viz. That his Lordship could not think Pegg Cahan's Children fit to Inherit Boyle.

But his Lordship being sen­sible how little Credit Lovers generally gain to their most solemn Abjurations of their Mistresses, was pleased to make [Page 91] use of his Wit to support the Reputation of his Veracity; and therefore the more fully to convince his Friends of the Sincerity of his Protestations against so dishonourable an Amour, and the more effe­ctually to divert them from Entertaining any jealous Ap­prehensions of him for the future, he thought fit, besides the forementioned Letter to Mr. Gosling, to write one of another strain to Sir Robert King; the purport of which was, to acquaint him of the late Lady Donegall's being then in Paris; of his Intimacy with her; of the Marks of Favour he received from her; and of his full Assurance of Success, if he should [Page 92] make his Addresses to her Lady­ship: he alledg'd the greatness of her Estate as abundantly compen­sating for the disparity of their Years, which he did not think so considerable as might reasonably make him to despair of having Children by her; but withall, de­clar'd so great a Respect for his Uncle, and Deference to his Judg­ment and Advice, that he would not attempt a matter of that Con­sequence without his Privity and Consent. This Letter and o­ther Papers were by unwar­rantable means got, by the present Lord Kingston, out of the hands of Sir Robert's House­keeper at Boyle, in his Absence, in the time of the late Trou­bles. See Ap­pend. N. 14. Nola Mur­phey's Affidavit. The Effect of this Let­ter [Page 93] was what the present Lord Kingston wisht for, and intend­ed by it; for by this plausible but delusive Pretence, all his Friends in this Kingdom were drawn into a firm Persuasion of his having no Design of Disparaging his Family, by Marrying that Irish Servant-Maid, since he now seem'd with some earnestness to desire, and with impatience to wait for his Uncle's Consent to his Courting a Lady of consi­derable Quality and Fortune: Sir Robert King indeed could not approve of this Courtship, and therefore out of the re­gard he had to his Nephew's Advantage, and the Apprehen­sion of the World's just Cen­sure [Page 94] on himself, if he should promote so unequal a Match, which gave so little Prospect of Children, he did by his Let­ter to him declare his utter dislike of his Design, and us'd several Arguments to disswade him from it; but in the mean time, he had so entire a Con­fidence in the Sincerity of his Nephew's profess'd Intentions (with his Friends Allowance) to make his Addresses to her Ladyship, that Sir Robert de­clar'd to his Friends, and par­ticularly to his Grace the pre­sent Lord Primate, (not with­out some Transport of Joy) that now he was fully convinc'd that Jack (for so he was us'd familiarly to call the present [Page 95] Lord Kingston) was not Married to Peggy Cahan.

Yet notwithstanding Sir Ro­bert's stedfast Belief of the Truth of his Nephew's Pro­fessions, he thought it prudent, for the Vindication of his Ho­nour, and for the effectual pre­venting of his disgraceful Mar­riage, to send an Instrument to be sign'd by the present Lord, the purport of which was, a solemn Declaration of the Falseness of the Report of his being Married to Margaret Cahan, and of his free Consent to his Brother's Excluding him, and his Heirs by her, in the Settlement of his Estate, in Case he were then, or should afterwards be Married to her, &c. The Words were [Page 96] these, (as the Libeller him­self sets them down)

[Page 97] Now, as the Framing and Sending this Instrument was sincerely design'd by Sir Robert King, as an effectual Means to prevent the Disgrace of his Family; so he did not que­stion but that it would have been both kindly accepted, and freely sign'd by the pre­sent Lord Kingston: For Sir Robert being possess'd with a firm Belief of the Sincerity of his Nephew's Professions, could not imagine that he who had so earnestly desir'd his Consent to his Courting the Lady Donegall, and in the aforesaid Letter to Mr. Gosling, had so grievously complain'd of the unworthy and dirty Thoughts of his Friends, in suspecting him Married to so mean [Page 98] a Woman as Margaret Cahan, would decline so Prudent, and sure an Expedient, of preventing such dishonourable Sentiments of him for the time to come, much less, that he would ever represent it as a Grievance to give that under his Hand, by his Uncle's Advice, which he had so often and so freely Sworn to many others, and had (as he himself expresses it in that Letter) Damn'd himself to the Pit of Hell, for the Con­firmation of its Truth.

By all which it may appear, with what Justice the Libeller Taxes Sir Robert King with knowing that the present Lord Kingston was Married, when he sent him the Instrument to [Page 99] Sign; seeing he had then not only the Word and Honour of a Man of Quality, but also the Faith of a Christian, given in the most solemn manner, to engage him to believe the contrary.

And that which abundantly vindicates Sir Robert King from the Libeller's farther most scan­dalous Suggestions concerning this Instrument, is the Manner of his Transmitting it to the present Lord Kingston: For if Sir Robert had been conscious of the Unreasonableness of his Nephew's signing that Paper, or had intended, as the Libeller insinuates, to Wheedle him into a Consent of his Brother's making a new Settlement, and to the lay­ing [Page 100] aside the old Intails, (as the Libeller calls them) in Mun­ster and Connaught, wherein the present Lord had Remainders, im­mediately after the Death of his Elder Brother: If Sir Robert King, I say, had had any such fraudulent and circumventing Design, he would not surely have sent the Instrument inclos'd in a Letter into England, to the present Lord's Grand-Mother, the Lady Wimbaldon, in order to be shew'd to, and sign'd by her Grand-Son: And as the Libeller does freely own, that this Paper was shew'd to the present Lord Kingston by his Grand-Mother; so he does not so much as pretend, that her Ladyship, or any other of his [Page 101] English Relations, or Friends, did either reflect on Sir Robert King for sending it, or thought it improper for his Lordship to Sign it: For tho' he tells us that his Uncle, Sir Thomas Ber­nardiston, Fee'd a Lawyer, who was of Opinion, that it was dan­gerous for the present Lord to Sign it, whether he was Married or no; yet Sir Robert King having ne­ver heard of any such Advice being given his Lordship, nor ever receiv'd any such Intima­tion from the Lady Wimbaldon in her Answer to his Letter, has reason to believe it to be an Excuse, purposely fram'd by the Libeller, in order to con­ceal the true Reasons of the present Lord Kingston's Re­fusal [Page 102] to Sign the said Instru­ment.

It has indeed been some­times the Fate of some of the Nobility, both in England and Ireland, by reason of the Smal­ness of their Estates, and for the Support of their Honour, to Marry into Families much inferior to their own; but then the Largeness of their Ladies Fortunes had made some Com­pensation for the Meanness of their Descent; and the Pro­testants of Quality, even in Ireland, have had so due a Re­gard to the English Extraction, and so warm a Zeal for the Protestant Religion, that few can be found that have con­tracted Marriages with any [Page 103] Irish Papists, tho' of the greatest Families, and Estates; but no single instance, I believe, can be given of any Protestant Gen­tleman, of Noble Blood, and of English Descent, (except the present Lord Kingston) who, with great Deliberation, and against the repeated Advices and earnest Endeavours of all his Friends and Relations, for several Years together, Married an ordinary Servant Maid, and an Irish Papist.

And the late Lord Kingston was the more sensibly affected with this Calamity, and more provok'd with his Brother's Disgracing himself, by that ig­noble Marriage, because the Woman he had made Choice [Page 104] of for his Wife, was not only a Papist by Profession, and of mean Irish Parentage, and in a low Station amongst the Ser­vants of his own Family; but was also one who had neither Charms of Beauty, nor gen­tile Behaviour, nor Agreable­ness of Conversation, to engage his Affections; for tho' it may reasonably be hoped, that the present Lady Kingston is a well accomplish'd Lady, as having, for these several Years past, had all the Advantages that the Court of St. Germains could afford, for Improving her to a Degree answerable to her pre­sent Quality; yet certainly, all those that knew Margaret Cahan, when she liv'd a Servant-Maid [Page 105] in the late Lord Kingston's House at Abby-Boyle, must ac­knowledge that she was then very far from having any Ac­complishments, either of Body or Mind, to recommend her as a Wife to any Gentleman: And therefore, tho' the present Lord was so far carried away with an unaccountable Passion, as to Marry a despicable and homely Woman, as she then was; yet it might reasonably have been expected, that one who had been counted Wise, shou'd have demean'd himself to­wards his offended Brother, and the rest of his Relations, with so much Modesty and Respect, as might have testify'd a deep Concern, not only for [Page 106] his own Misfortune, but also for the Dishonour he had done his Family. But, on the con­trary, he was so far from taking such prudent Measures, as might possibly at last have recommended him to his Bro­ther's Favour, that immediately after the late King Jame's Ac­cession to the Throne, he did not only publickly expose his Brother's Honour, and his Un­cle's Justice, in a high reflecting Petition, which he preferr'd to the King, and in his Address to the House of Lords in England; but did also, within a while after, to the unspeakable Grief of the late Lord, and all his Relations, openly Renounce the Protestant Religion, and de­clar'd [Page 107] himself a Papist, and merited so highly of the Po­pish Party, and became so spee­dily famous for his bigotted Zeal, that he was advanc'd to the Dignity of being one of the Gentlemen of the Privy-Chamber to the late King James. All which disobliging, scan­dalous and dishonourable Actions of the present Lord, immoveably fix'd and con­firm'd the late Lord Kingston in the former Resolutions he had taken, of Disinheriting him, and Settling his Estate upon his Uncle, and the Heirs Males of his Body.

Now, because the Odium of the late Lord Kingston's Dis­pleasure against his Brother, is [Page 108] by the Libeller wholly cast on Sir Robert King, and the Dishe­rison of the present Lord is suppos'd by him (tho' with­out the least shew of Proof) to have been first fram'd at Sir Robert's Instigation, and brought about by his Contrivance, I shall, in order to a full Vindication of Sir Robert's Innocency in this whole Affair, produce the Testimony of such Gentlemen, as, by their personal Know­ledge of all Matters relating to the late Lord Kingston's Settle­ment of his Estate, are most fitly qualify'd to give their Evidence, and, by their esta­blisht Reputation for Integrity, are the most Credible Witnesses in what they do attest. The [Page 109] first Person that I shall men­tion, is the Reverend Doctor Francis Quail, who not only attended the late Lord King­ston in the Capacity of a Tu­tor, for about a Year before his Father's Death, but conti­nued in that Station for many Years after, and accompanied him in his Travels into France, and had also the present Lord Kingston committed to his Care, for some time, by Sir Robert King, Uncle and Guar­dian to them both. The said Doctor Quail does declare, and has depos'd upon Oath, Vide Dr. Quail's Af­fidavit in the Append. No. 10. That he always observ'd in Sir Robert King a great Care of, and Affe­ction for, the late Lord Robert, and present Lord John: And that [Page 110] the said Sir Robert, at the time of sending the late Lord King­ston abroad, being press'd by some Friends, to permit the present Lord to accompany his Brother in his Travels, refused to consent thereto, saying, It was not fit to expose them both together to the Hazard of the Seas, and Foreign Parts. And does further declare, That he always observ'd a Backward­ness in Sir Robert King touch­ing such a Settlement in Exclusion of the present Lord; and he ve­rily believes the said Sir Robert never did, either by himself, or any other Person or Persons whatso­ever, persuade or solicit the said late Lord to make such a Settlement; and that the said Sir Robert sent him to the said late Lord, to sig­nifie [Page 111] his, the said Sir Robert's dislike of it, and to dissuade him the said Lord Robert from mak­ing thereof; which Message the Doctor deliver'd to the said late Lord, at which the said late Lord seemed to be moved, and said he would proceed in it, or Words to that effect, and that Peggy Ca­han's Issue should never enjoy his Estate.

And to this purpose Charles Gosling, Esq (who was some­time Secretary to the late Lord Kingston) has depos'd, Vid. Mr. Gosling's Deposition in the Ap­pend. No. 4. That when the News came, of the pre­sent Lord Kingston's being Mar­ried to Margaret Cahan, the late Lord was so much troubled at it, and so much enrag'd at him, that he soon after resolv'd to Levy [Page 112] a Fine, and suffer a Recovery of his Estate, both in Connaught and Munster, and told his Un­cle, Sir Robert King, of his Re­solution, and that he would settle the same upon him, and his Chil­dren: And that Sir Robert there­upon advis'd him to the con­trary, telling him, That tho' his Brother had Married so far beneath himself, and his Fa­mily, yet she might make a good Wife, or Words to that effect; upon which the late Lord Kingston solemnly profess'd and swore, That in Case Sir Robert King would not accept of the Set­tlement, he would settle the Estate upon his Cousin, Captain Francis King, and his Children; which this Deponent, viz. Mr. Gosling, [Page 113] often heard the said Lord King­ston declare; and this Deponent does also verily believe, that he would so have done, in case the said Sir Robert had not accepted of the same.

Nor can the late Lord King­ston's Disinheriting his Brother be judg'd an Act of unreason­able Severity, if, besides what has been already said, it be but considered, that the present Lord's private Fortune, left him by his Grand-Father, Sir William Fenton, which he then enjoy'd, amounted to 600 l. per Annum, which, to any im­partial Judgment, will pass for more than a competent Inhe­ritance for the Children of such a Mother. And tho' the late [Page 114] Lord Kingston shew'd a just Displeasure at his Brother's dis­graceful Marriage, by Disin­heriting his Issue by the Irish Servant-Maid, yet he express'd a tender Regard to the Near­ness of the Relation, by order­ing such a Clause to be inserted in the Settlement, as might be a saving to such Sons as the pre­sent Lord Kingston should beget on the Body of such a Wife as he should Marry, with the Advice and Consent of his said Brother, and his Uncle Sir Robert King, or such of his next Relations as should be then living, &c. And surely the late Lord Kingston had no cause to believe that his Brother would think it unreasonable, that the Children of that Wo­man, [Page 115] whom, in his Letter to Mr. Gosling, he acknowledg'd to have been a Scullian, should be barr'd from Inheriting a Lord's Estate.

And as we may perceive, by Mr. Gosling's Deposition, that the late Lord Kingston did solemnly declare his Intention of Settling his Estate on Cap­tain Francis King, if his Uncle should obstinately persist in the Refusal of it; so the present Lord was so fully persuaded of the Stedfastness of those his Brother's Resolutions, that when he came to Age, he freely, and of his own Accord, de­clar'd his Consent to his Uncle's Acceptance of his Brother's E­state, which the late Lord King­ston [Page 116] had before very frequently offer'd, and earnestly press'd, and Sir Robert had as often, and obstinately refus'd: For when Sir Robert King was going for England, in February 1683/4. the present Lord Kingston was pleased to favour him with his Company to Rings-End, and on the way, the present Lord, without any Connexion with their former Discourse, addrest himself to his Uncle in these, or the like Words, Uncle, when I was under Age, you refus'd to accept of the Estate offer'd you by my Brother; but now I am come to Age, I freely consent to your Acceptance of it. The Truth of this Sir Robert is ready to depose, and has also the Te­stimony [Page 117] of Doctor Horneck to confirm it; for in his Vid. Ap­pend. No. 10. Dr. Horneck's Letter. Letter to Sir Robert, dated Sept. 22. in the Year in which he died, he declares, That the present Lord Kingston did acknowledge to him, that he had given his Con­sent to the passing his Brother's Estate to his Uncle.

Yet notwithstanding this so voluntary, and so seemingly a deliberate a Tender, which the present Lord Kingston made his Uncle, of his Title to, and Interest in his Brother's Estate, Sir Robert King was still scru­pulous in Accepting of it, un­til he had stated his Case to Four of the most Eminent Divines in England, (whom he consulted a-part, without Ac­quainting [Page 118] any one of them of his having had the Advice of any other) and had receiv'd their unanimous Agreement in their Opinions of the Lawful­ness of his Acceptance of such a Settlement.

And to convince the Rea­der that Sir Robert did not (as the Libeller most groundlessly suggests) State his Case after his own Way, but with all Faithful­ness and Truth, I here produce it in the very Words in which he propounded it to the English Divines, as may appear by the Original sign'd by them.

[Page 121] Nor is the Libeller less mi­staken in what he suggests con­cerning the Time, than in what he says of the Manner of Sir Robert's Stating his Case to the Divines; for tho' he inti­mates, that he had not ask'd their Opinions before he had actually accepted of the Estate, yet the Truth of the whole Matter is plainly this, which Sir Robert is ready to depose; Sir Robert going for England in February 1681/4. at his first Landing there, waited on Doctor Pearson, then Lord Bishop of Chester, and consul­ted him concerning the fore-mention'd State of his Case, who then writ, and sign'd his Opinion thereon; and when [Page 122] he came to London, he dis­cours'd the several other Di­vines above-mention'd, (who all concurr'd in their Judg­ments with the Bishop of Chester) before he consented to the late Lord Kingston's leaving him next in Remainder to his Estate. But afterwards, in his Return for Ireland, conceiving it fit to have all their Opinions in Writing, he sent the Original Case, with the Bishop of Che­ster's Hand to it, to Mr. Ray­mond, who was then in London, to get the rest to Sign what before they had declar'd, which accordingly they freely did.

But, besides the great and undeniable Evidences I have already produc'd, to prove the [Page 123] Falseness of the Libeller's Sug­gestion, That Sir Robert King endeavour'd, by all the Artifices he could invent, to procure the Dis­herison of the present Lord, I shall mention two, which I may reasonably presume are beyond Exception: The first is, The Testimony of the late Lord Kingston, who, in his Directi­ons to draw an Answer to his Brother's Case presented to the House of Lords in England, declares, in a Paper Vid. Appendix No. 11. The late Lord Kingston's Paper. under his own Hand, ready to be produc'd, That the first Rise of his Brother's Wife (the present Lady Kingston) was, to be his Poultry Woman's Servant, and her greatest, to be his Dairy-Maid, till she became his, viz. his Bro­ther's [Page 124] Spouse: And then follow these remarkable Words; That it was on this Occasion I settled my Estate from him, and his Heirs, into a Family of good Extraction, and not, as he most unjustly says, by the Advice and Desire of Sir Robert King, my Uncle, who was the only Man of all those that knew my Designs, that oppos'd so just a Settlement. To this may be added the late Lord's Vide Appendix No. 20. The late Lords Letter to Sir Robert King. Letter, dated June 29. 1688. in which he says, If I could more firmly settle what I have, I would, and rivet it, rather than it should be ever alter'd.

And if any Testimony in this Case may be imagin'd greater, than that of the late Lord Kingston's, it must be [Page 125] that of a profess'd Adversary to Sir Robert King, and even this I have to produce for Sir Ro­bert's further Vindication: For the present Lord Kingston him­self, after his publickly known and avow'd Marriage, and even after his having the certain knowledge of his own Exclusion out of his Brother's Settlement, writ a Letter Vide Appendix No. 14. The present Lord Kingston's Letter without date, but some time in Summer 1684, to Sir Robert, who was then in England, wherein he was so far from Accusing Sir Robert of Promoting his unfor­tunate Marriage, or of having done him ill Offices with his Brother, or of being an Instru­ment of his Disherison, that he professes a great Respect to [Page 126] him, stiles him his dear Uncle, and declares, It was not want of Duty, that he had not waited upon him; acknowledges the Kindnesses of his Relations, and confesses that bitter Reproaches were due to him from them; and that he was re­solv'd to live private, and retir'd from the Sight of all his Rela­tions and Friends; and ends that Letter with seemingly sincere and hearty Promises of perpe­tual Dutifulness to his Uncle, in these words; And tho' per­haps you may never see me, yet as far as my Power shall ever reach, you shall ever find me your Du­tiful and Obedient Nephew.

And now having, as I hope, very fully answer'd the Libel­ler's main Objections against [Page 127] Sir Robert King, relating to the Discharge of his Office of Guar­dian to his Nephews, and to the Circumstances of the pre­sent Lord Kingston's Marriage, and the late Lord's Settlement of his Estate, the remaining Objections will be more easily dispatch'd. For, first, to what the Libeller suggests against Sir Robert King, That he so wrought his Ends with the late Lord Kingston, as to get him to settle 600 l. or 800 l. per An. of the New Estate upon him; the Answer is plain and easie; for 'tis very notorious, that the Estate, which the Libeller means, was not settled on Sir Robert King by the late Lord Kingston, but by his Father, Sir Robert King's Brother.

[Page 128] And here Sir Robert takes Occasion, with all Gratitude, to acknowledge his Brother's extraordinary Kindness to him; for whereas his own Patrimony was but small, his Brother, the late John Lord Kingston, was pleased to settle on him, and his Heirs, by a Rentcharge, 400 l. per Annum, in order to his Marrying an Heiress of an equivalent Fortune; and Sir Robert does freely own, that after his Brother's Decease, his Executors and Trustees did accordingly set out Lands out of the New Estate, to the Va­lue of 400 l. per Annum, in lieu of the Rentcharge for that Sum on the whole Estate: By which the Reader may perceive the [Page 129] Ingenuity of the Libeller, not only in Advancing 400 l. into 600 l. or 800 l. per Annum, but also in Representing that as the Effect of Sir Robert's Artifice, and Influence over his Nephew, the late Lord King­ston, which was purely the Re­sult of his Brother, the late Lord John's Generosity.

And as to the Objection concerning Sir Robert's and Mr. Raymond's Incensing the late Lord Kingston against his Bro­ther, on Account of his not Re­turning the Papers relating to the Mannor of Newcastle, which he had got from Dr. Quail; the true State of that Matter is plainly this; Mr. Raymond be­ing appointed a Trustee by the [Page 130] present Lord Kingston's Grand-Father, Sir William Fenton, in several Deeds made by him of his Estate in Munster, (of which Newcastle was a part) and having deposited the Writings relating to that Interest in the Hands of his Son in Law, Dr. Quail, the present Lord pre­vail'd with the Doctor to send him the Writings that concern'd New-Castle, on Promise of Re­storing them when requir'd, which his Lordship afterwards refusing to do, Sir Robert King, knowing that the late Lord had a Remainder in that Estate, advis'd Mr. Raymond to ac­quaint his Lordship with the Damage he might suffer by those Papers being detain'd by [Page 131] his Brother, and not lodg'd (as they ought to be) in the hands of the Trustee: And this being the plain and whole Truth of that Case, the Libeller surely had no reason to represent Sir Robert's Justice to the late Lord Kingston as an ill Office to the present Lord.

Nor has the Libeller more reason to reproach Sir Robert King for Advising the late Lord Kingston, immediately after the late Revolution, to settle and ap­ply Newcastle to pious Uses; for tho' that Mannor was left to the present Lord, by his Grand-Father, Sir William Fen­ton; yet his Lordship being at that time a Forfeiting Person, on account of his adherence [Page 132] to, and continuance with the late King in France, and con­sequently, in no Capacity of Enjoying it, and his Brother, the late Lord Kingston, having Pretensions to that Estate, (as being in Remainder in the Set­tlement, as well as Heir at Law) Sir Robert's Advising the late Lord to dispose of it to the Poor, cannot reasonably be in­terpreted as an Injustice or Dis­service to the present Lord Kingston.

Nor is Sir Robert King so­licitous to make any Defence for his Opposing the Reversal of the present Lord's Outlawry; for his Lordship having, not only some Years before the late Revolution, publickly renounc'd [Page 133] the Protestant Religion, but also for some time since profest himself a Papist, and having left his Lady and Children in France, as Hostages of his firm Adherence and Fidelity to the late King, Sir Robert thought himself oblig'd to lay this Mat­ter before the Government: The Consideration of which being referr'd to the then So­licitor General Sir Richard Le­ving, he declar'd it as his Opi­nion, That it was not safe for the Lord Kingston to Reverse his Outlawry, until he had brought over his Lady and Children into His Majesty's Dominions, in Order to their being Educated Protestants: On which the Lord Capell, the [Page 134] then Lord-Deputy of this Kingdom, (judging it a Bu­siness of Consequence) thought fit to transmit it into England; whereupon the Reversal of the present Lord Kingston's Out­lawry was stopt, till his Lord­ship's Eldest Son came to Lon­don, and he had sent into France for the rest of his Family. And here we may take an Esti­mate of the Libeller's Loyalty to His Majesty, and of his Regard to the publick Good, by his blaming Sir Robert King for not preferring his Nephew's private Advantage to the Safety of the Kingdom, and Security of the Protestant Religion.

Nor is that more fairly re­presented by the Libeller, which [Page 135] he writes concerning the late Lord Kingston's Promise to the late King, to leave the Matters in Controversie between him and his Brother, as they were in the Ori­ginal Settlement: For that which the late Lord Kingston pro­mis'd the late King James, was not, as the Libeller insinuates, to make him Heir to his Lord­ship's Estate, but only to con­tinue him in the peaceable Possession of the Mannor of Newcastle, to which, as being Heir at Law, the late Lord had fair Pretensions; all which Sir Robert King is ready to de­pose.

And as to what is objected concerning Sir Robert King's being inform'd by Dean Cope of [Page 136] some Papers left by the late Lord Kingston for the Use of his Brother, and Sir Robert's endea­vouring to suppress them; the Occasion of that unjust Re­proach was only this: Dean Cope having acquainted Sir Robert King that there was a Report in the Country of some Papers being left by the late Lord Kingston at his Death, not for the Use of his Brother, (as the Libeller suggests) but of his Lady, Sir Robert writ to the Dean from Dublin, to take all possible Care to have them transmitted to the present At­torney-General, Trustee for the Lady Kingston; but the Dean, after the strictest Enquiry he could make, could find no [Page 137] such Papers, and discover'd the Report relating to 'em to be altogether false and ground­less.

As to what is offer'd from the late Lady Dowager King­ston's Answer to a Bill fil'd a­gainst her by Sir Robert King, namely, That her Lord declar'd to her, that he was sorry he had made such a Settlement, and that he had designs to alter it; It is answer'd, That Sir Robert, out of Respect to her Memory, being willing to suppose the Truth of what her Ladyship has averr'd, has nevertheless good reason to believe, that tho' his Lordship might per­haps, in some sudden heat, express himself to that purpose, [Page 138] on occasion of Sir Robert's plain dealing with him in other Matters, yet his Lordship ne­ver did, upon serious Thoughts, shew any dislike of that Settle­ment; for as it is observable, that her Ladyship does not, in her Answer to Sir Robert's Bill, give the least hint of her Lord's designing to settle any part of his Estate on his Bro­ther; so it is generally known, and has been publickly atte­sted by Persons Vid. Mr. Connelly's Deposition in the Ap­pend. No. 13 of good Cre­dit, who were most conver­sant with him, that in his Lordship's constant Discourse he declar'd himself highly pleas'd with the Settlement he had made, and did also in his last Sick­ness declare his Fears, that his [Page 139] Uncle's easie Temper would incline him to act contrary to his Lord­ship's full Design, and the pur­port of the Deed which he had made.

And as touching the pre­tended Declaration and Deed of the late Lord Kingston's Re­voking the Settlement made in the Year 1689, and granting his Estate to his Brother, &c. Sir Robert King does not in the least doubt but that he shall be able, when there is Occa­sion, to make good his Title against all pretended Declara­tions, Deeds, and Revocations, that have been set up since the late Lord's Death, and against all other Pretensions whatso­ever.

[Page 140] But that the Reader may the better judge of the Credi­bility of these Pretences, it will not be improper to inform him, that it appears by an Affidavit, ready to be produc'd, That considerable Rewards were promis'd to a Clerk belonging to the Common-Pleas, to imbezil or raze two Writs of Cove­nant which belonged to two Fines levied of the Boyle Estate by Robert the late Lord King­ston, and that these Proposals were made by Daniel Sullevane, a Person who was then in the Interests of the present Lord Kingston.

And it has been also fully and publickly prov'd, that in the Year 1695, when Mr. Ray­mond [Page 141] was in Dublin, and was suppos'd to have Sir Robert King's Papers with him there, several profligate Persons, of the Name of Sullevane, (one of which then waited on the present Lord Kingston) cor­rupted Mr. Raymond's Servant, to steal away his Master's Pa­pers, which he accordingly did; and the whole Matter being plainly detected, one of the Person's concern'd being taken, was Pillory'd, and the rest fled: And it was remark­able on the Tryal, that it was prov'd that they gave the Ser­vant a strict Charge to search for a Paper, containing a Dis­charge, or general Release, given by the present Lord [Page 142] Kingston to Sir Robert King, for his Guardianship.

And to this purpose it is observable, That in the time of the late War, when Sir Ro­bert King was in England, the present Lord came to a faithful old Servant, of Sir Robert King at Rockingham, and persuaded her to deliver him the Papers she had of Sir Robert's, and promis'd he would keep them safe for him, and on that Pre­tence got them into his Hands, and never would afterwards restore them; all which is fully depos'd upon Oath. Vid. Ap­pend. No. 14 Nola Mur­phey's Af­fidavit.

Now to what is objected concerning Sir Rober King's and Captain Choppine's offering to buy Sligoe, and to put 2000 l. [Page 143] in his Lordship's Pocket, on Con­dition he would make an absolute Deed, and put Sir Robert King into the actual Possession of his whole Estate; the Answer is ve­ry plain: For as Sir Robert was never known to be a Pur­chaser; so it cannot reasona­bly be imagin'd, that Captain Choppine, who bequeath'd Sir Robert King nothing at the time of his Death, would have made so great a Purchace for him in his Life time.

And it's hardly worth men­tioning what is objected con­cerning Sir Robert King's Build­ings at Rockingham, viz. That they were so Sumptuous, as to bear no Proportion to his Estate; and therefore, that it may be well in­ferr'd, [Page 144] That Sir Robert had Designs all along on Boyle and Michelstown: For supposing we should grant what the Li­beller suggests, concerning the Greatness of Sir Robert's House, (which none that have seen it will allow) yet the Inference he draws from thence is alto­gether groundless, and unrea­sonable: For tho' Mens Build­ing beyond their Fortune has been frequently esteem'd an Argument of their Impru­dence, yet scarcely ever of their Covetousness; it being often known, that many have Built themselves out of their own Estates, but seldom or never into those of other Men.

[Page 145] And as Sir Robert King gave many signal Proofs of his Affe­ction to the late Lord Kingston's Person, so also he plainly de­monstrated his sincere desire, that his Estate should descend to his Issue: For even after the perfection of that Settle­ment, by which Sir Robert and his Sons were Nam'd next in Remainder to the late Lord Kingston and his Issue, Sir Robert was so far from being tempted by the prospect of Advantage, to use any Artifice o divert his Lordship from the thoughts of Marriage, that the very consideration of his kindness in that Settlement did move Sir Robert to be more than ordinary Solicitous to [Page 146] provide his Lordship a good Wife, and accordingly, by the Advice and with the Assistance of the late Lord Arch-Bishop of Canterbury, Dr. Tillotson, he endeavoured to procure for him the Lord Hatton's Daugh­ter, who was his only Child, and had 10000 l. for her Por­tion, besides the expectation of her Father's Estate; but tho' the Lord Hatton himself gave some Encouragement to the Lord Kingston's Courting his Daughter, yet the young Lady's Relations by her Mother's side being unwilling she should leave England, the Match was broke off.

Some time after this, Sir Robert King advis'd the late [Page 147] Lord Kingston, to make his Addresses to the Lady Elizabeth Cromwell, of the Kingdom of Ireland, and with his Lordship's Approbation, had several Treaties with the young Ladies Relations, and had such En­couragement given him to con­tinue his Solicitations of this Match, that it was once thought to be very near a Conclusion, when on a sudden, the young Lady chang'd her Mind, and to Sir Robert's great surprize and concern, all his endea­vours to carry on that Design, prov'd ineffectual.

And not long after this, there being a Proposal made for the late Lord Kingston's Courting of Mr. Harbord's [Page 148] Daughter, Sir Robert King did not only give his free Consent to his Lordships making his Addresses to that Lady, but did also heartily Negotiate that Affair, and at length brought it to a happy Issue.

And lastly, to shew the groundlessness of the Libeller's Suggestion, that Sir Robert King, on the late Lord Kingston's Mar­riage, gave directions for the mak­ing a new Settlement of that Lord's Estate, plying him with Company at the Tavern for Eight days to­gether, and Incensing him all the while against his Brother, till that Settlement was perfected, and Sir Robert had got himself and his Children nam'd next in Re­mainder, after the late Lord and [Page 149] his Issue, excluding his Brother: I shall produce Mr. Raymond's Testimony on Oath, Vid. Ap­pend. Mr. Raymond's Deposition. No. 15. who declares that Sir Robert King, being inform'd that the late Lord Kingston had commanded Mr. Raymond to provide a new Deed of Settlement to be Drawn, in or­der to his Marriage, sent him to acquaint his Lordship, that by the former Deed of Settlement he had made, his Estate was, for want of Issue of his own Body, to go to Sir Robert King and his Sons, but that by a Proviso in that Settlement there was a Power reserv'd to his Lord­ship, some Months before and after his Marriage, to Revoke that Deed, and make such a Settlement of his Estate as he should think fit, and therefore desir'd his Lordship seri­ously [Page 150] to consider with himself, and also to consult some eminent Di­vines in the City of London, whether he was not oblig'd in Con­science to Settle his Estate on his Brother, when it was in his Power; because if there were a new Deed, and Settlement made upon his Mar­riage, with the like Uses and Limi­tations as in the former, it would not be in his Power to revoke it. This Message Mr. Raymond Swears, he faithfully deliver'd from Sir Robert King, to the late Lord Kingston, who commanded him to acquaint his Uncle, that he desir'd him not to trouble himself any more in that Matter, because he was fully resolv'd to continue the former Settlement as it was, or to Settle the Estate on Sir Robert's Sons, if he refus'd it.

[Page 151] And now I do not doubt but that every judicious and impartial Reader will be fully perswaded that no just Refle­ction can be made, either on the late Lord Kingston's Honor in Settling his Estate on his Uncle, or on Sir Robert King's Justice in accepting it; for tho' his Lordship was pleased to Exclude his Brother, yet 'tis very plain, that he did it on such weighty Considerations as would undoubtedly prevail with every Protestant Noble­man to Disinherit his only Son: And tho' Sir Robert King did permit himself to be Nam'd next in Remainder to the late Lord and his Issue in that Settlement that was Revokable, [Page 152] yet he did it not, (as has been plainly prov'd) till the present Lord had not only freely given his Consent to his Uncle's accep­tance of the Estate, but had also vilely prostituted his own, and his Families Honour by his Ignoble Marriage. But the grand Reasons that provok'd the late Lord Kingston to Exclude his Brother out of the final and irrevokable Settlement, perfect­ed some time before his Mar­riage, were the unworthy Asper­sions that he cast on him in his Petition to the late King, and in his Address to the House of Lords in England, and his open renouncing the Protestant Reli­gion, and his avow'd Adherence to the late King James's Inte­rests.

[Page 153] As touching the last Head of the Libeller's Materials for a Bill of Discovery against Sir Ro­bert King, &c. which con­cerns Matter of Title, and con­sists of a Recital of several Deeds of Settlement, and other Con­veyances, Sir Robert thinks it im­proper for him to make any particular Defence in this Pa­per, all those things being now referr'd, by Consent of Parties, to the Arbitrement of some of the Reverend Judges, and to the Umpirage of his Excellency the Lord Golloway.

And as I have good reason to hope, that their Determina­tion of that Controversie will be in Sir Robert King's favour, so I don't question but that, [Page 154] by the Answers that have been return'd to the Libeller's most invidious Suggestions, Sir Ro­bert's Innocency will be fully vindicated, and that it will ap­pear to every intelligent and ingenuous Reader, that no­thing could reasonably be ex­pected from an Affectionate Un­cle, from a Faithful Guardian, from a Grateful Brother, and from a Prudent and Good Man, which Sir Robert King has not done for his Brother's Sons, the late and present Lord King­ston.