Reply of John Norman, to Bill of Complaint of Thomas Drax, Priest
John Norman saythe, that he is not therof guiltie of any riot, unlawful assemblie in harness, forceable entrie, shooting of arrowes, or any other things done contrarie to the Kings peace, as is falsely stated by the said Thomas Drax.
But for the declaration of truth in this behalf, he saythe that the place whereas the said cattle were taken is called Neyther Park, in Woodhall aforesaid, of which he and one Jane his wife, were seized of the right of the said Jane in their domain as of freehold, given by the demise of Sir Thomas Wortley, Knight, and Roger Wombewell, Esquire.
So by reason whereof, he in peaceable manner with his two servants with him, and having such weapons as they be usual to ride with, came to the said place called Neyther Park, and found certain cattle feeding and defouling his grass, and took and drove them to Wombewell, adjoining to the said house, and there intended to have enpounded them, as lawful was him to do.
At which time, many of the servants and adherents of the said Thomas Drax, to the number of 24 persons, came and repelled the said beasts, and John Norman seeing that they were of so great a number, that he took the said beasts in a place called Stack Yard, within the said Manor, and denies that he shot arrowes at the servants of Thomas Drax in the said pasture, or that he struck any man or woman down with any spear in the towne of Wombewell, as is also verilie surmised by the said Thomas.
And as to the said Bill, sueing Thomas Drax, the said John Norman saythe that true it is that he, and according to the Kings Laws, commenced an action of trespass against the said Thomas Drax, Clerk, for occupying his said grounds, with others.
John Norman also saythe that Thomas Drax having knowledge of the said suit, and to delay judgement, craftily issued a Supersedeas against John Norman, who denies falsily and craftily procuring one John Calverd to suberseal the said Supersedeas, as is alleged in the said Bill by Thomas Drax.
Furthermore, all the aforesaid matters, the said John Norman is now ready to verify, whereas this honorable Court will award on judgement, his reasonable costs, for his wronful vexation on that behalf.