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BAIJER OTTO-BAIJER - BILL OF COMPLAINT 1853

Transcription of the document ANDREWS V. TINDAL - a Bill of Complaint detailing the eventual outcomes of legacies contained in the will of
Baijer Otto-Baijer


1853. A. No. 43 Filed 9th May 1853

In Chancery.

MASTER OF THE ROLLS.



PLAINTIFF:-
  • WILLIAM ANDREWS.
DEFENDANTS:-
  • THOMAS TINDAL,
  • ANN LOVELL,
  • HENRY WILLIAM MASON,
  • ANNE his Wife,
  • ELIZA EELES,
  • ELIZA ANN EELES,
  • WILLIAM SMITH and
    FRANCES SABINA his Wife,
  • JOSEPH BERRY EDWARDS,
  • JOHN HENRY COOPER,
  • WILLIAM ROE and
    FRANCES his Wife,
  • MARY ANN ARCHER,
  • ANN SERCOMBE, a Person of unsound Mind,
  • ISAAC HENRY SERCOMBE, Committee of the
    Person and Estate of the said Ann Sercombe,
  • WILLIAM SMITH and
    CAROLINE his Wife,
  • EDMUND BAIJER GIFFARD SERCOMBE, and
    ALICE LEES ELIZA SERCOMBE, respectively
    Infants under the age of twenty-one years,
  • HONOR PATCH,
  • WILLIAM OTTO PATCH,
  • THE REVEREND JOHN MARTYN COLLYNS, and
    SOPHIA his Wife,
  • GEORGE BIGNELL and
    CHARLOTTE his Wife,
    and
  • LOUISA PATCH.


BILL OF COMPLAINT.

To the Right Honourable ROBERT MONSEY BARON CRANWORTH OF Cranworth in the County of Norfolk Lord High Chancellor of Great Britain

HUMBLY COMPLAINING sheweth unto his Lordship William Andrews of No. 14 New City Chambers Bishopgate Street in the City of London Merchant the above-named plaintiff as follows :-

1. Baijer Otto Baijer late of Bentinck Street Manchester square in the county of Middlesex Esquire duly made and published his last will and testament in writing bearing date the seventh day of October one thousand eight hundred and twenty-six and four several codicils thereto bearing date respectively the seventeenth day of March one thousand eight hundred and twenty-eight the first day of March one thousand eight hundred and thirty the fifteenth day of December one thousand eight hundred and thirty-seven and the twenty-seventh day of April one thousand eight hundred and thirty-eight and which said will and codicils were all duly executed and attested so as to pass freehold estates by devise and by his said will and codicils the said testator directed the residue of his personal estate in England to be divided into four equal parts and disposed of the same in manner following (that is to say) he gave one of such fourth parts to the said defendants Henry William Mason Eliza the wife of Isaac Eeles and the said Anne the wife of the said defendant William Merry (the surviving children of Mrs. Eliza Mason deceased) equally to be divided between them and he gave another of such fourth parts to Langford Lovell And he gave one-third of the remaining two equal fourth parts of the residue of his personal estate in England to the said defendant John Henry Cooper in the said will called Henry Cooper Joseph Baijer Cooper (in the said will called Baijer Otto Cooper) and the said defendant Frances the wife of the said William Roe and the said defendant Mary Ann Archer then the wife of Thomas Archer since deceased (being the children of his the said testator’s deceased sister Mary Cooper) equally to be divided among them And he gave one other third part of such remaining two-fourth parts of the residue of his personal estate in England unto the said Langford Lovell and the said defendant Thomas Tindal their executors administrators and assigns Upon trust to pay the dividends and interest thereof to the said testator’s sister Elizabeth Sercombe for her separate use for her life and after her decease In trust as to the principal thereof for John Sercombe Isaac Henry Sercombe (in the said will called Isaac Sercombe) Baijer Sercombe (in the said will called Baijer Otto Sercombe) Ann Sercombe and William Sercombe (being the surviving children of the said Elizabeth Sercombe) and the children or such of them as should survive the said testator of Edward Sercombe deceased (another of the children of Elizabeth Sercombe) in equal shares but the children of the said Edward Sercombe to take only one of such shares among them as representing their father And the said testator gave the remaining third part of such two equal fourth parts of the residue of his personal estate in England unto Robert Baijer Patch (in the said will called Robert Patch) John Patch the said defendant William Otto Patch the said defendant Sophia the wife of the said defendant John Martyn Collyns the said defendant Charlotte the wife of the said defendant George Bignell the said defendant Louisa Patch and Amelia Patch and Ann Patch (the surviving children of his the said testator’s sister Barbara Patch deceased) equally to be divided among them And as to the share of the said defendant Eliza Eeles the said testator directed that the same should not be paid to her but should be invested by his trustees in their names in any of the parliamentary stocks or public funds of Great Britain and held by them Upon trust for the separate use of the said Eliza Eeles for her life subject to a restriction on anticipation and after her decease In trust for all her children who being sons should attain the age of twenty-one years or being daughters should attain that age or marry to be divided among such children if more than one in equal shares and in default of children then upon the trusts therein expressed And as to the share of the said defendant Mary Ann Archer the said testator directed that the same should not be paid to her but should be paid out by his trustees in their names in the parliamentary stocks or funds of Great Britain and should be held by them Upon trust for the said defendant Mary Ann Archer for her separate use for her life and after her decease in case she should leave any child or children her surviving Upon trust for all such children if more than one in equal shares and if by one for such only child and in case there should be not child or children who should survive her then in trust for the said Langford Lovell absolutely And the said testator gave devised and bequeathed all his real and personal estate in the island of Antigua in the West Indies unto and to the use of the said Langford Lovell and Thomas Tindal their heirs executors administrators and assigns according to the respective tenures natures and qualities of the same respectively Upon trust that they or the survivor of them or the trustees or trustee for the time being of his said will and codicils should when and as he or they should judge most eligible within the period of two years from his the said testator’s decease call in and convert into money all such part of his personal estate in Antigua as should not consist of money and sell and dispose of all his real estate in Antigua either altogether or in lots or parcels and by public auction or private contract or partly in each such mode as he or they might think proper and with full liberty unto or for the said trustee or trustees for the time being to buy in or rescind the contract or contracts for sale of all or any part or parts of the same real and personal estates respectively and to resell the same in or by all or any of the modes or means aforesaid and without being answerable for any loss or expense to be occasioned thereby And the said testator authorized and directed the trustees for the time being of his real and personal estates in Antigua for the purpose of effecting and completing such sales to enter into make and execute all such contracts covenants agreements conveyances assignments assurances acts deeds matters and things whatsoever as to them should seem meet Also to deduct and retain the costs of conversion and otherwise of executing the trusts and to pay all debts in Antigua and from and after deducting retaining satisfying and paying the costs charges expenses and debts aforesaid then he directed that the clear surplus of the monies to arise from the sale and conversion of his said real and personal estates in Antigua should be divided and subdivided into the same of the like shares and proportions as thereinbefore declared concerning his residuary personal estate in England And he gave the same clear surplus unto and for the benefit of the same persons and for the like shares ownerships and interests and subject to the like trusts and contingencies as he had given such residuary personal estate in England or the produce thereof or the investments therefrom And the said testator authorized and empowered the said trustee or trustees to lay out and invest any such portion or portions of the said surplus monies arising from the sale of his real and personal estates in Antigua as he or they might consider advisable for the performance of the trusts thereinbefore by way of reference declared concerning the same surplus at interest in his or their name or names in or upon all or any such stocks funds and securities as aforesaid and to alter and vary the same stocks funds and securities from time to time as he or they might think fit And he further authorized and empowered the said trustee or trustees to manage order and direct his real and personal estates in the island of Antigua until the same respectively shall be sold in such manner as he or they thought proper and after in the first place retaining deducting and satisfying unto and for himself and themselves out of the rents issues and profits of the said real and personal estates in Antigua all such costs charges and expenses as he or they might expend or be put unto in or about the management of the same estates the said testator directed that the clear surplus of the said rents issues and profits should be divided and subdivided unto the like shares and proportions as thereinbefore by reference declared concerning the clear produce of the sale of his said real and personal estate in Antigua and should according to such proportions be paid to and divided between the persons who for the time being would be entitled to the clear produce of the sale of the same estate or to the dividends and interest of the investments therefrom And by one of the codicils to his said will dated the seventeenth day of March one thousand eight hundred and twenty-eight the said testator after reciting that in his will he had directed his executors to sell his real and personal estate in the island of Antigua within two years after his decease thereby declared his will to be that his said executors should not be compelled to sell his said real and personal estate in the island of Antigua within any particular time and he thereby authorized and empowered them to dispose of the same then only when they should think most fit And the said testator appointed the said Langford Lovell and Thomas Tindal executors of his said will and codicils as by the said will and codicils or the probate copy thereof will appear.

2. The said testator Baijer Otto Baijer died on the twenty-fifth day of February one thousand eight hundred and thirty-nine without having revoked or altered his said will save so far as the same was revoked or altered by his said codicils and without having revoked or altered his said codicils save so far as the form of them was revoked or altered by any of the subsequent ones and the said will and codicils were on the ninth day of March one thousand eight hundred and thirty nine proved in the Prerogative Court of the Archbishop of Canterbury by the said Langford Lovell alone power being reserved for the said Thomas Tindal to prove the same.

3. The said testator left the several residuary legatees named in his said will him surviving (that is to say) the said Henry William Mason Anne the wife of the said William Merry and Eliza then the wife and now the widow of Isaac Eeles (the surviving children of the said Eliza Mason) the said John Henry Cooper Joseph Baijer Cooper Frances the wife of the said William Roe then Frances Cooper spinster and Mary Ann then the wife and now the widow of the said Thomas Archer (the surviving children of the said testator’s sister Mary Cooper) the said Elizabeth Sercombe and the said John Sercombe Isaac Henry Sercombe Baijer Sercombe Ann Sercombe William Sercombe (the surviving children of the said Elizabeth Sercombe) and the said Edmund Baijer Giffard Sercombe and Alice Lees Eliza Sercombe and Emma Mary Sercombe (the only children living at the said testator’s death of the said Edward Sercombe the other of the children of the said Elizabeth Sercombe) and Robert Baijer Patch William Otto Patch John Patch Sophia the wife of the said John Martyn Collyns and Charlotte the wife of the said George Bignell Louisa Patch Amelia Patch and Ann Patch (the surviving children of the testator’s sister Barbara Patch).

4. The personal estate and effects of the said testator in England were soon after his death duly got in and paid to or secured for the benefit of the several persons entitled thereto under the will of the said testator and the share of the said Eliza Eeles was invested in the names of the said Langford Lovell and Thomas Tindal in the funds of Great Britain for the benefit of the said Eliza Eeles and her children and the share of the said Mary Ann Archer was invested in the names of the said Langford Lovell and Thomas Tindal in the funds of Great Britain for the benefit of the said Mary Ann Archer and her children and the share of the said Edmund Baijer Giffard Sercombe Alice Lees Eliza Sercombe and Emma Mary Sercombe was after the death of the said Elizabeth Sercombe hereinafter mentioned transferred by the said Langford Lovell and Thomas Tindal into the name of the Accountant-General of this Court under the provisions of and Act of Parliament made and passed in the tenth and eleventh years of the reign of her present Majesty Queen Victoria intituled “An Act for better securing Trust Funds and for the Relief of Trustees.”

5. The said testator Baijer Otto Baijer was at his death seised of some real estates in the island of Antigua but was not possessed of any personal estate there and the said Langford Lovell and Thomas Tindal in exercise of the discretion given to them by the said will and codicils of the said testator never sold and disposed of the real estate of the said testator in the island of Antigua in the West Indies but managed the same under the provisions of the said will and codicils and have paid the clear rents and income which have from time to time accrued due in respect of such real estates unto and among the several persons entitled thereto under the said will and codicils of the said testator.

6. The said Langford Lovell died on the eleventh day of March one thousand eight hundred and fifty-two leaving the said Thomas Tindal his co-trustee him surviving and having first duly signed and published his last will and testament in writing dated the sixth day of March one thousand eight hundred and forty eight and thereby gave the residue of his personal estate and all his freehold estates to his daughter and only child Ann Lovell her heirs executors administrators and assigns absolutely And the said Langford Lovell appointed his wife Harriet Hersent Lovell and his daughter the said Ann Lovell the executrixes of his said will as by the said will or the probate copy thereof will appear.

7. The said Harriet Hersent Lovell died in the lifetime of the said Langford Lovell and the will of the said Langford Lovell was on the nineteenth day of April one thousand eight hundred and fifty-two duly proved in the Prerogative Court of the Archbishop of Canterbury by the said Ann Lovell.

8. The said Ann Lovell is entitled to one fourth part of the real estates of the said testator Baijer Otto Baijer in Antigua.

9. The said Henry William Mason is entitled to one third part of one fourth part of the real estates of the said testator Baijer Otto Baijer in Antigua And the said William Merry and Anne his wife are entitled in right of the said Anne Merry to one other third of the fourth part of the real estates of the said testator Baijer Otto Baijer in Antigua.

10. The said Isaac Eeles died on the sixteenth day of April one thousand eight hundred and forty-one and there was issue of the said Isaac Eeles and Eliza his wife three children and no more (that is to say) the said defendant Eliza Ann Eeles and Frances Sabina Smith the wife of the said defendant William Smith and ---------- Eeles who died an infant under the age of twenty-one years and unmarried And the said defendant Eliza Ann Eeles has attained the age of twenty-one years And in the year one thousand eight hundred and forty-two the said defendant Frances Sabina Smith intermarried with the said defendant William Smith previous to her attaining her age of twenty-one years.

11. By an Indenture or Articles of Settlement bearing the date the thirty-first day of May one thousand eight hundred and forty-two and made and duly executed between and by the said William Smith of the first part the said Frances Sabina Smith then Frances Sabina Eeles spinster of the second part the said Eliza Eeles of the third part and the said defendant Joseph Berry Edwards and Joseph Shrimpton since deceased of the fourth part (being the articles of settlement made previously to and in consideration of the marriage between the said William Smith and Frances Sabina his wife) It was witnessed that in consideration of the said then intended marriage It was declared and agreed that the said William Smith and the said Frances Sabina Eeles and all other necessary parties would as soon as the case would admit by such assignments and assurances in the law as by the trustees should be advised convey assign and transfer the moiety or half part or share or any other the part or share of or to which the said Frances Sabina Eeles or the said William Smith in her right then was or might thereafter become entitled of and in the said third part or share of the said one fourth part or share of the residue of the personal estate of the said Baijer Otto Baijer deceased unto the said Joseph Berry Edwards and Joseph Shrimpton their executors administrators and assigns And it was agreed and declared that the trustees should stand possessed of the said moieties and all other the share or interest thereinbefore agreed to be assigned or to be procured to be assigned of and in the said estates monies stocks funds and securities Upon trust to receive the said moieties part or share parts or shares of and in the premises thereby put in settlement when and as the same should become payable and either to permit the said moieties parts or shares to remain in their actual state of investment or at any time or times with such consent as therein mentioned to call in and compel payment of sell transfer and dispose of the said trust funds and to invest the money to arise therefrom in their names in the funds or on real security and stand possessed thereof upon the trusts therein mentioned for the benefit of the said William Smith and Frances Sabina his wife and their children as by the said indenture will appear.

12. The said Joseph Shrimpton died in the month of January in the year one thousand eight hundred and forty-seven And the said Eliza Eeles is entitled for her life to one other third of one fourth part of the real estates of the said testator Baijer Otto Baijer in Antigua And the said Eliza Ann Eeles is entitled to on moiety of one third of one fourth part of such real estates of the said testator Baijer Otto Baijer in Antigua expectant on the decease of the said Eliza Eeles And the surviving trustee of the marriage settlement of the said William Smith and Frances Sabina his wife is entitled to the remaining moiety of one third of one fourth part of the real estates of the said testator Baijer Otto Baijer in Antigua expectant on the decease of the said Eliza Eeles upon the trusts declared thereof by the said indenture of settlement of the thirty-first day of May one thousand eight hundred and forty-two.

13. By and Indenture dated the twenty-sixth day of August one thousand eight hundred and thirty-nine and made and duly executed between and by the said Joseph Baijer Cooper of the one part and the said defendant William Roe of the other part the said Joseph Baijer Cooper assigned to the said William Roe his executors administrators and assigns but in trust nevertheless for the said Joseph Baijer Cooper his executors administrators and assigns the part share or interest to which the said Joseph Baijer Cooper was under and by virtue of the said will and codicils of the said testator Baijer Otto Baijer entitled of and in the real and personal estate of the said testator in Antigua and the monies to arise from the sale and conversion thereof together with full power and authority to demand sue for and recover and give effectual receipts and discharges for the same premises in the name or names of the said Joseph Baijer Cooper his executors administrators or assigns as by the said indenture will appear.

14. Joseph Baijer Cooper died on the twenty-seventh day of April one thousand eight hundred and forty-two intestate leaving his brother the said John Henry Cooper and his sisters the said Frances the wife of William Roe and the said Mary Ann then the wife and now the widow of the said Thomas Archer his only next of kin him surviving And administration of the estate and effects of the said Joseph Baijer Cooper was granted by the superior Court of Judication at Fort William in Bengal to the registrar of the said Court but no letters of administration of the estate and effects of the said Joseph Baijer Cooper have been taken out in England.

15. By an Indenture dated the ninth day of December one thousand eight hundred and forty-five and made and duly executed between the said John Henry Cooper of the one part and the said William Roe of the other part the said John Henry Cooper assigned to the said William Roe his executors administrators and assigns but in trust nevertheless for the said John Henry Cooper his executors administrators and assigns the part share or interest to which the said John Henry Cooper was under and by virtue of the said will and codicil of the said testator Baijer Otto Baijer entitled of and in the real and personal estates of the said testator in Antigua and the monies to arise by the sale and conversion thereof together with full power to demand sue for and receive and give effectual receipts and discharges for the same premises in the name or names of the said John Henry Cooper his executors administrators or assigns as by the said indenture will appear.

16. The said Thomas Archer died in the month of May one thousand eight hundred and forty-eight And the said John Henry Cooper or the said William Roe as his trustee is entitled to one fourth part of one third of a moiety of the real estates of the said testator Baijer Otto Baijer in Antigua and the said William Roe and Frances his wife in right of the said Frances Roe are entitled to one fourth part of one third of a moiety of the said real estates of the said testator Baijer Otto Baijer in Antigua and the said Mary Ann Archer the wife of the said Thomas Archer is entitled for her life for her separate use to one other fourth part of one third of a moiety of the real estates of the said testator Baijer Otto Baijer in Antigua with remainder to her children in default of children of the said Ann Lovell And the said MaryAnn Archer had never had any children.

17. The said William Roe as the trustee of the said Joseph Baijer Cooper and by virtue of the said indenture of the twenty-sixth day of August one thousand eight hundred and thirty nine is entitled to the one other fourth part formerly belonging to the said Joseph Baijer Cooper of one third of a moiety of the said real estates of the said testator Baijer Otto Baijer in Antigua In trust nevertheless as to one third part thereof for the said John Henry Cooper and as to the one other third part thereof for the said William Roe and Frances his wife in the right of the said Frances Roe and as to the remaining third part thereof for the said Mary Ann Archer.

18. The said Elizabeth Sercombe died on the first day of January one thousand eight hundred and forty-eight.

19. By an indenture bearing the date the tenth day of September one thousand eight hundred and forty-two and made and duly executed between and by the said John Sercombe of the one part and the plaintiff of the other part And also by an Indenture bearing date the eighteenth day of November one thousand eight hundred and forty-five and made and duly executed between and by the said Isaac Henry Sercombe of the one part and the plaintiff of the other part And also by an Indenture bearing date the first day of August one thousand eight hundred and forty and made and duly executed between and by the said Baijer Sercombe of the one part and the plaintiff of the other part And also by an Indenture bearing date the sixteenth day of July one thousand eight hundred and forty-nine and made and duly executed between and by the said William Sercombe of the one part and the plaintiff of the other part The said John Sercombe Isaac Henry Sercombe and William Sercombe respectively did for the valuable considerations in the said indentures respectively mentioned assign their respective shares of and in the real and personal estates of the said testator Baijer Otto Baijer in Antigua unto the plaintiff his executors administrators and assigns absolutely as by the said respective indentures will appear.

20. By an Inquisition taken on the twenty-fifth day of June one thousand eight hundred and forty-nine under and by virtue of a commission for that purpose issued the said Ann Sercombe was found to be a person of unsound mind And by an Order of the Lord Chancellor bearing date the fourteenth day of November one thousand eight hundred and forty-nine the said Isaac Henry Sercombe was appointed to be the committee of the person and estate of the said Ann Sercombe.

21. The said Emma Mary Sercombe one of the children of the said Edward Sercombe deceased died in the month of December one thousand eight hundred and Forty-five an infant and intestate leaving her mother the said defendant Caroline Smith the wife of the said William Smith then Caroline Sercombe and the said defendants Edmund Baijer Giffard Sercombe and Alice Lees Eliza Sercombe her only next of kin her surviving and letters of administration of the estate and effects of the said Emma Mary Sercombe were on the twenty-first day of March one thousand eight hundred and forty-nine granted to the said defendant Caroline Smith then Caroline Sercombe by the Prerogative Court of the Archbishop of Canterbury And the said Caroline Sercombe hath since intermarried with and is now the wife of the defendant William Smith.

22. The plaintiff is by virtue of the four several indentures hereinbefore in that behalf respectively mentioned entitled to four sixth parts of one third of a moiety of the real estates of the said testator Baijer Otto Baijer in Antigua And the said Ann Sercombe is entitled to one other sixth part of one third of a moiety of such real estates And the said defendants Edmund Baijer Giffard Sercombe and Alice Lees Eliza Sercombe are entitled to two third parts of the remaining sixth part of one third of a moiety of such real estates And the said Caroline Smith as the administrator of the said Emma Mary Sercombe or the said William Smith in her right is entitled to the remaining one third part of one sixth part of one third of a moiety of such real estates In trust nevertheless for the said defendants Edmund Baijer Giffard Sercombe and Alice Lees Eliza Sercombe and the said Caroline Smith or the said William Smith in her right in equal shares as the next of kin of the said Emma Mary Sercombe.

23.The said Robert Patch died on the eighteenth day of March one thousand eight hundred and forty having first duly made and published his last will and testament in writing bearing date the twenty-third day of March one thousand eight hundred and thirty-nine and thereby bequeathed the
whole of his property to his wife the said defendant Honor Patch and letters of administration with the said will annexed of the estate and effects of the said Robert Baijer Patch were on the thirteenth day of July one thousand eight hundred and forty duly granted by the Prerogative Court of the Archbishop of Canterbury to the said defendant Honor Patch.

24. By an Indenture bearing date the third day of May one thousand eight hundred and forty-three and made and duly executed between and by the said John Patch of the one part and the plaintiff of the other part for the valuable consideration therein mentioned the said John Patch assigned unto the plaintiff his executors administrators and assigns the share of the said John Patch of and in the real and personal estates of the said testator Baijer Otto Baijer in the island of Antigua and the money to arise by the sale and conversion thereof.

25. By an Indenture bearing date the twenty-eighth day of November one thousand eight hundred and forty-six and made and duly executed between and by the said Ann Patch of the first part and the said Louisa Patch of the second part and the said John Martyn Collyns of the third part the said Ann Patch assigned unto the said John Martyn Collyns his executors administrators and assigns the share of the said Ann Patch of and in all the estate and effects of the said testator Baijer Otto Baijer In trust for the sole and separate and absolute use and benefit of the said Amelia Patch her executors administrators and assigns as by the said indenture will appear.

26. The said Amelia Patch died on the fifth day of November one thousand eight hundred and forty-nine having first duly made and published her last will and testament in writing bearing date the eleventh day of March one thousand eight hundred and thirty-seven and thereby gave all her personal estate and effects whatsoever unto her two unmarried sisters Louisa Patch and Ann Patch or the survivor of them.

27. Letters of administration with the said will annexed of the estate and effects of the said Amelia Patch were on the twenty-ninth day of October one thousand eight hundred and fifty duly granted by the Prerogative Court of the Archbishop of Canterbury to the said Louisa Patch.

[Page missing]

32. The defendant John Henry Cooper now resident in the East Indies out of the jurisdiction of this Court and the defendants William Roe and Frances his wife are now residing at Boulougne-sur-Mer in the French Empire out of the jurisdiction of this Court.


Prayer.

The plaintiff prays as follows:-

1. That an account may be taken of all and singular the real estates in Antigua of or to which the said testator Baijer Otto Baijer was seised or entitled at the time of his death.

2. That the real estates in Antigua of the said testator Baijer Otto Baijer may be sold and disposed of in such manner as this Honorable Court shall direct and that all proper and necessary parties may be decreed to join in such sale.

3. That the purchase-money to arise from the sale of such real estates may after deducting the expenses of such sale be paid to or secured for the benefit of the several parties entitled thereto in the proportions hereinbefore mentioned in such manner as this Honorable Court shall direct.

4. That the plaintiff may have such further or other relief as the nature of the case may require.
  • Names of the Defendants.

    The Defendants to this Bill of Complaint are -

    Thomas Tindal

    Ann Lovell

    Henry William Mason

    William Merry and Anne his Wife

    Eliza Eeles

    Eliza Ann Eeles

    William Smith and Frances Sabina his Wife

    Joseph Berry Edwards

    John Henry Cooper

    William Roe and Frances his Wife

    Mary Ann Archer

    Ann Sercombe a person of unsound mind

    Isaac Henry Sercombe
    Committee of the person and estate of the said Ann Sercombe

    William Smith and Caroline his Wife

    Edmund Baijer Giffard Sercombe and
    Alice Lees Eliza Sercombe
    respectively Infants under the age of twenty-one years

    Honor Patch

    William Otto Patch

    The Reverend John Martyn Collyns and Sophia his Wife

    George Bignell and Charlotte his Wife

    and

    Louisa Patch



    • G.S. LAW.

      NOTE. - This Bill is filed by George Law, Thomas Tindal, and Henry Skrine Law Hussey, No. 10, New-square, Lincoln’s Inn, in the County of Middlesex, Solicitors for the above-named plaintiff.


      [Transcribed by Jane Sercombe Lewis]