Record in Rhythme, Being an Essay towards the Reformation of the Law

Be it remembred now that formerly,
To wit, last Term o'th' holy Trinity,
Before the Keepers of the liberty
Of England , by the full authority
Of the long Parliament at Westminster ,
Priscilla Morecrave widow came, by her
Atturney M.B. and prefers,
I'th' Court of Upper Bench, a bill of hers,
Against one Roger Pricklove , who doth lye
A prisoner in the Marshalls Custody
Et caetera , and 'tis upon a plea
Of trespass on the Case, Pledges there be
To prosecute the suite, to wit, John Doe
And Richard Roe . And the said bill also
Doth follow in these very words, to wit
In legal manner, London, Scilicet .

Declaration

By M B

Priscilla Morecrave Widow, doth complain
Of Roger Pricklove , who doth now remain,
Prisoner to th'Marshal of the Marshalsie ,
Of the said Keepers of the Liberty
Of England , by authority and power
Of Parliament, i'th' Bench superiour,
Before the same Keepers themselves that be,
For that (to wit) whereas the aforesaid she
Priscilla Morecrave , is a person just,
Honest, and faithful, one that never durst
Give the least cause for to be thought unchast,
But hath liv'd ever modest, and was grac't,
With godly education, and demurely
Behav'd her self; and all her life most purely,
Hath with the zealous and precise consorted;
And free from all uncleanness was reported,
Who never was amongst the well affected,
Stain'd with a Crime, or in the least suspected;
But with the pious people of this Nation,
Hath had good fame, credit, and reputation;
By which good reputation, she hath gain'd
Not only love, and favour, but obtain'd
A plentiful estate, by which most freely
She manag'd her Affairs; And that Ralph Seely ,
One of the Assembly late at Westminster ,
A godly-Gospel-preaching-Minister,
Was earnest suiter in the way of Marriage,
To have her for his yoke-fellow; his carriage,
And his most Saint-like loving humble speeches,
Had her consent to all that he beseeches
And she agreed to give him all content,
To wed him by the Act of Parliament:
Three times the Contract publish't, then their trust is
That all shall be compleated by the Justice:
But this said Roger all aforesaid knowing,
Maliciously intending her undoing,
To blast her reputation, and dishonour
Her unstain'd Chastity; to cast upon Her
Infamous obloquy, to dis-repute Her;
And to deprive her of her foresaid Suiter;
By breaking of the marriage was intended;
To leave her to the world lost, and unfriended;
In month September, day of the same Eleven,
One thousand six hundred fifty and seven,
Of our Lords year, as by our computation,
Our Common-wealth reckons from th'incarnation,
At London in the parish of St Mary
Bow , in the ward of Cheap , he then contrary
To truth most falsly and maliciously
In hearing of right worthy Company,
And honourable persons, Noble Lords,
Did speak these false, and most reproachful words,
To and of her the Plaintiff; that's to say,
You are a Pockie Whore, and at this day
You have three Bastards living, which do dwell,
Two in Pick-hatch , and one in Clarkenwell :
By reason of which false malicious speaking
Of the said Roger , to her great heart-breaking;
The godly Gospel-Minister, her Suiter,
Forbears his former suit, and for the future,
Did make profession he would never take her
To be his Consort, but did quite forsake her;
And all her friends with whom he had repute,
Do now esteem her for a Prostitute;
Whereby she is the worse, and damnifi'd,
One thousand and five hundred pounds, beside;
And thereupon she doth her suit produce,
In th'Upper Bench, because of this abuse.

Imparlance

By A B

And now until this day, that is to say,
On Munday three weeks after Michaels day
In this same Term, which very day until
Roger had leave t'emparl unto that Bill,
And then to answer it; before the same
Keepers, as well the said Priscilla came,
I'th' Court of Upper Bench, at Westminster
By that Attourney nam'd before, for her,
As the aforesaid Roger , who doth come
By his Attourney A.B.
And doth defend the force and injurie,
When, where, et cetera . And said that she,
The said Priscilla , ought not maintain, nor
Have thereupon her Suit against him, for
Protesting, not acknowledging that she
Is half so honest as she'ld seem to be;
Nor is her body, or her life so clear,
Nor so unspotted, as she would appear;
Nor is she of so chaste a reputation,
As is pretended by her Declaration:
Protesting also that the said Ralph Seely
(Though oft together did both he and she lye)
Ne'r meant to Marry her, but all his power
Of love was quench'd in less then half an hour.
Besides he'ld quite undo her; if he had,
His learning was so small, his life so bad
For Plea he saith that at the time, wherein
She does suppose these slandrous words t'have bin
Spoke by th'aforesaid Roger , she the said
Priscilla was nor Widow, Wife, nor Maid;
And though she pass'd for an unbroken Virgin,
She catch'd th'aforesaid Presbyter in her gyn;
And with his wall-ey'd Saintship plaid the sinner,
Who b'ing inspir'd by a Thanksgiving dinner,
Did carnally her body know, to wit
The crime of Fornication did commit;
In the same Ward, and Parish, to his Honour,
He at one clap got three great Boyes upon her
All which for privacy were put to feeding
At Bridewell and Pick-hatch , to learn good breeding:
And she in recompence clap'd him so sore,
With Anglice French -POX, it made him rore;
And put his Genitals in such a pickle,
That all his Parish women did article,
And out him of his Benefices twain,
And into Scotland made him trot again:
Wherefore (as lawful 'twas) on this occasion,
He spake the words laid in the Declaration.
And this he Justifies, and judgement crave,
If she this suit ought to maintain or have.

Replication

By I H

And she the said Priscilla doth maintain her
Said Action, against all that's said to stain her;
And saith this Court nor will nor can forejudge her,
For ought that's pleaded by the foresaid Roger ;
But though by his said Plea, she's forc'd to tarry
Her suit against him, yet she ought to carry;
Protesting therefore she's not such a liver,
Nor of such Fame, as the said Plea doth give her
Out for to be, but that she hath not vary'd
One jot in life from what she hath declared:
And on the said Ralphs part protesting farther,
That of the Kirk he was a Godly Father;
And of as pure and chaste a conversation,
As any Presbyter within the Nation:
And free from any lustful act committing,
With her, or any other deed unfitting:
For Replication saith, she was not knowing
Of the said Ralph but three years last foregoing:
During which time, and till the said words spoke were
By the said Roger (that almost have broke her)
She liv'd a Matrons life, chaste, grave, and thrifty,
And came unto the Age of three and fifty;
And the said Ralph all the said time, by reason
Of his much preaching in and out of season;
And of his fasting long, and longer praying,
And from his peoples not their duties paying,
In the same Ward and Parish, grew so weakly,
That of his life he did despair weekly:
Which weakness had so very much out-worn him,
That in his bed he was not able turn him;
Till that a learned Doctor of the Colledge
Who of his sickness had full perfect knowledge,
For gaining of his health did much exhort him,
To wed an honest Matron to Comfort him:
Which the said Ralph well liking, and well knowing
The honour to the said Priscilla owing,
And thinking that delayes might greatly worse him,
With Zeal, did Court her for a wife to nurse him:
And she in pity to his weak Condition,
Did condescend to be his she Physician,
And for their joynt desires better carrying,
A day by both appointed was for marrying:
But on the sudden off the same was broken
By the said Roger's words aforesaid spoken;
By means whereof, he the said Ralph , endure
Could not the said Priscilla for a Cure,
But of relief his expectations failing,
And his long sickness more and more prevailing;
In Month October, day thereof that first is,
In the Lords year that formerly exprest is;
At the said Ward, the said Ralph much in trouble,
Did dye, to's loss, possess'd of living double:
And left the said Priscilla to bemoan her,
For that no other man would after own her;
And that she truly doth reply and don't lye,
She prays may be inquired by the Country.

Rejoynder

By A B.

And the aforesaid Roger saith the Plea
By her the said Priscilla formerly
Put in and pleaded by her Replication,
In the aforesaid manner, form, and fashion,
And the whole matter that's contained there,
Are not sufficient in the law, for her
The said Priscilla , to maintain her aforesaid
Suit against him, and there need be no more said:
Nor by the laws of England is it fit,
That he should make answer unto it;
This to averr he's ready. Whereupon
For want of better Replication
In this behalf, he doth a judgment pray,
And that she from having her action may
Be barr'd, for this against him; And for
The causes why he doth in Law demurr
Upon that Replication, he the said
Roger according to the Statute made,
And in such case provided, doth declare
And shew to th'Court of Upper Bench that's here,
These causes following, to wit, that this
Said Replication insufficient is,
Negative, pregnant, and uncertain, rude,
Double, wants form, and does not conclude
Rightly, according to the legal way.

Joyning in Demurrer

By A B.

And she the said Priscilla here doth say,
That the said Plea which by reply has been
Pleaded by her, and what's contain'd therein,
In point of Law, good, and sufficient be,
Her suit against him to maintain; And she
That Plea and marter, pleaded as above,
Is ready here both to maintain and prove,
As this Court shall consider, and think fit,
And 'cause he does not answer it, nor yet
Deny the Replication any way,
The said Priscilla (as before) doth pray
Judgement, and dammages to be judg'd to her,
For all this injury which he did do her:
But 'cause this Court here not advised is
Of giving judgment of the premises,
A day's giv'n to both parties to appear
I'th' Upper Bench, before the Keepers here
At Westminster , till Munday after eight
Dayes of St Hillary , for the receipt,
And hearing of their Judgment upon it,
For that the Court is not advis'd as yet.
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