C1/ 957/1, 2

Nicholas Ballard c. Thomas Harlakenden and Margaret, his wife

957/1

Bill of Complaint of Nicholas Ballard,

No date

[Document is damaged down the right hand side]

Property in the manor of Combe and Spytell in the Parish of East Greenwich in Kent, to the yearly value of 20 pounds had been in the possession of the Ballard family since the time of Henry VII. Firstly Robert Ballard, after his death, his wife Elizabeth and after her death, William Ballard, son and heir of Robert, and then to the heirs of William Ballard, but in default of William’s issue, then to Clement Ballard, the brother of William and father of Nicholas. The land came down to Nicholas by these means[1]. But the most part of all the evidence and writings concerning the lands have come into the hands of Margaret Draper, the widow and executrix of William Draper who has since married Thomas Harlakenden. Your complainant does not know the content of these evidences and writings. Ask that the Harlakendens be subpoenaed to appear before the court to answer his complaints.

 957/2

Answers of Thomas and Margaret Harlakenden,

No date,

Clement Ballard had three sons Nicholas, the complainant, Robert and Thomas, all living. Thomas is only 14 years of age[2] and is in the custody of William Culpepper and Mary, his wife, the mother of Thomas, who are his guardians[3]. The Harlakendens suppose that the premises mentioned in the bill are in Gavelkind in the County of Kent and from time ‘out of mind’ such lands in the county have come down through the heirs male. Margaret said that they have in their custody divers evidences concerning the premises, which they suppose; do belong of right to Robert and Thomas Ballard and to Nicholas himself. They do not themselves claim any title to the premises nor to the evidences relating to the same and they are prepared to make delivery of the evidences in such form as desired by the court. They ask that Robert and Thomas be called before the court to [meet with] Nicholas.

 [See also C1/1231/12-14]