The reasons and considerations inducing the sayd Peter Bland, to make the sayd assurances of the said Mannors and premisses, and disposall of specialties for the said 1150. l'. to the said Lawrence Lownes.

• 1. 340 l'. in hand payd by the sayd Lawrence Lownes, to the sayd Peter Bland.
• 2. 310 l'. per annum, to be payd vnto the sayd Bland during his life, by the sayd Lawrence Lownes, the sayd land being worth, and let for 216 l'. per annum, and no more.
• 3. 50 l'. to be payd after the sayd Peter Blands death yearely, by the sayd Lawrence Lownes, to M^rs. Ioane Langhorne, one of the sayd Blands Daughters during her life, she being a healthy woman, not yet exceeding forty yeares of age.
• 4. The sayd Lawrence Lownes, is by appointment of the sayd Peter Bland to pay at seuerall dayes after the sayd Blands death 2509 l' 3 s'. 4d'. to seuerall persons, being children, grand-children, and others neere of kin, vnto the sayd Peter Bland.

Note that

• 1. For these Executory payments, the sayd Lawrence Lownes gaue security by Indenture of couenants, and bonds of 4000 l'.
• 2. The Lands not worth aboue 3000 l'. to be sold.

• 1. For that the sayd Lawrence Lownes had formerly at the instance of the said Peter Bland, married his the said Blands neece, whom the sayd Bland had brought vp from her infancy, and was also esteemed by him as his daughter.
• 2. For that the sayd Lawrence Lownes had beene for a long time a carefull and faithfull dealer, and preseruer of and for the said Blands estate, which was very trouble-some and perplexed.
• 3. That the sayd Peter Bland loued the sayd Lawrence Lownes very tenderly, had an especiall opinion of him grounded vppon suffi­cient trials, and desired therefore some way to ingage him the more, not for himselfe onely during his life, but afterwards with the care and managing of the estates of his grand-children.

It is fully and directly prooued by many Witnesses of credit without all manner of exception, that at and during the making and perfecting of those conueyances and assurances, (being almost eight moneths in doing) as also before and after the sayd Peter Bland was of an able dispo­sing memory, and vnderstanding, and that at sundry times, and before persons of great credit, he voluntarily expressed his hearty loue to the sayd Lawrence Lownes, with wishes that the before bargained premisses had beene more worth, and that he the sayd Peter Bland had beene of better abilitie, to doe him, the sayd Lawrence Lownes more good in requitall of his great loue and paines.

This bargaine was ratified and allowed of by the sayd Peter Bland, by subsequent Acts during all his life after.

• 1. In his the sayd Peter Bland receiuing the sayd 310 l'. per annum during his life, being about two yeares after according to the said bargaine by quarterly payments, as appeareth by eight seuerall acquittances, vnder his hand and seale proued.
• 2 Besides the before mentioned Acts and conueyances) the sayd Peter Bland by his last Will and Testament in Writing, made and Published the 27. of Iune, 1. Reg. Caroli, made a principall relation vnto the sayd bargaine, and made thereof the sayd Lawrence Lownes, and his brother Iohn Bland his Executors, and liued a yeare and a halfe after, still continuing his the sayd Lawrence Lownes, Executorship, in signe also of his constant loue and opinion of him, and approbation of the sayd bargaine.

The premisses con­sidered the said Lawrence Lownes hopes that it appeares that

• 1. This was no great benefit vnto the sayd Lawrence Lownes.
• 2. No preiudice but aduantage to the sayd Peter Bland in his owne particular.
• 3. The sayd Peter Bland might the better doe thus, hauing no Sonnes.
• 4. Little or no preiudice came hereby to his Children, grand-children, and other kindred, among whom besides his former chargeable preferments of his Daughters in marriage; and the sayd 50 l'. per annum to his Daughter Langhorne, he did by and vpon the sayd bargayne dispose the sayd whole 2509 l', 3 s'. 4 d'. besides the rest of his estate, to and among them also being about 6000 l'. albeit amongst them there were not wanting some iust causes of Peter Blands displeasure towards them.

The sole obiections agaynst the sayd bargayne and assurances are, that all the benefits thereby redounding vnto the sayd Lawrence Lownes was corruptly, by circumuention, and without iust consideration drawne by the sayd Lawrence Lownes, from the sayd Peter Bland in his weake­nesse; and therefore in the Court of Chancery, decreed agaynst him the sayd Lawrence Lownes onely, albeit the sayd Court would not declare, that the sayd Peter Bland was at the making of the assurances, or of the sayd Will De non sane memory, or that he was not of a dis­posing memory, nor would make voyd the sayd Conueyances, or Will, or disaduantage any whom they concerned, but the sayd Law­rence Lownes onely, as by the decree of the sayd Court made Septimo die Februarij Anno Regni Regis Caroli, tertio: Inter Arnoldum Harbert mil. & al. querend, Lawrencium Lownes & al. defend. whereto for more truth and certayne relation bee had, it may appeare.⟨The post script is to come in at this place.⟩

To this as concerning all matter of supposed corrupt dealing, circumuention, or want of iust consideration, being matters which trench vpon the sayd Lownes his reputation aswell as profit, hee with all due reuerence Humbly offers the contrary; and that as hee hopeth vpon most iust grounds and reasons, humbly desiring the proofes may be considered, and the cause examined.

⟨Lawrence Lownes hath been in prison in the Fleet close prisoner 3 yeares for nonꝑformanc [...]of the sayd decree, and without any good ground sentenced▪ fyned v s in the starchamber for the obteining of the sayd Conveiances from Peeter Bland & not freed of the sayd imprisonment vntill he his wife and two Children being Infants by fine and recouery made assuraunce of the sayd Mannor and lands vnto vs according to the compulsion of y^e sayd decree in Chauncerye⟩