July 1584 D7 a The replicacon of Richard Dale complaynante to the D14 and Dayl de

Ti*pid Answer of John Maddock Deffend[ant] and

The said complaymant for replicacon doth Acrrr and mayntene his saed bill & all & every article matter close sentenced

& thinge them conteyned to be good Inste and trewe and very sufficente in the lawe to be answered unto in suche

saede manners and forme as the same byen in his saud bill expressed & declared w[i]thout that that the matters in

the saied bill conteyned are alledged for Arill will & with malicious policy setforth & practized to the Intente

wrongefully to vex the saied defend[ant]s & to caus**e & Spoyle his money tyme & goodes in sutes & charges in the lawe

in suche manner & forme as in the saed Answer is untruly alledged And w[i]thout that that aswell the cattle of

the saed defend[ant]s ali[as] of his Ancestors owners of the saied landes & ten[an]tes w[hi]ch the saed defend[an]t nowe hath as

also of some other Inhabitantes of Osmaston aforesaid beinge put to pasture & feede in the said In bechome

in the som* Answer named have used tyme out of mynde of man to drink & take wo***st all of & in the

same and had not any water elsewhere belonginge to humber holme aforesaid Or that the said defend[ant]s

or any other Inhabitant in Osmaston aforesaid ought to take any comoditie with the[i]r cattle or otherwise in the comp[lainant]

saed copyhold lande there , or have be[e]ne informed so to do or that the saed defend[ant]s hath or ought to

have anye waie to drawe and bringe his cattle throughe the saed plott of grounde to humber home

aforesaid in suche maner & forme as in the saed Answer is untrue by alledged And w[i]thout that that

there is not any other place as convement, as through the sa[e]d plott of land to use and have A**** to

humberholme aforesaid or that the said compl[ainan]t letteth the said defend[an]tes cattle unlawfully to come to

humberholme aforesaid to take the[i]r com[m]on & depasture there in suche manner & forme as in the saed

Answer is alledged And withowt that that the saed complynant by him self[e] or his Servantes

at sundry tymes now of late hath not only wrongefully impownded Dayton and sericdon the

saed defend[ant]s Cattle upon and out of humberholme aforesaid or also have assemble***

wounded and Will intreated the saed defend[ant]s there againste her mat[gestie]s pead and work there

greate pell of his le[a]s[e] without Justice or lawfull cause so to doe in suche manner and forme

as in the saud Answer is untruly setforth and alledged And without that that any other matter

or thinge in the saud Answer contayned mateuall or effectuall to be answered *** in

not herein sufficiently confessed and aworded trodsed or deviede it t*** to the saed

complaynantes knowledge All whicht matters this saud compaynant is ready to *orr

and prove as this honorable Doutie shall a worde and pranothe as he before in his

saede Bill hath prayed and desced         171                                          Bgnolds