Shewing,
THat Sir Thomas Dale her husband being imployed (in the yeare 1617) by the East India Companie as chiefe Commander of their Fleete into the East Indies, Sir Tho. Dale im­ployed to the East-Indies by the Com­pany, dyeth, leauing a great estate there in his ship belonging to the petitioner as his Executrix. and there dying (in the yeare 1619) leauing a great estate there in money and other things (in his Ship called the Moone, then floating at Sea) to the value of 20000 pounds, all which after his death belonged to the Petitioner as sole Executrix of his last Will made be­fore his going in that Voyage.

Shortly after his death, one Thomas Iones a Factor for the Companie there, and Robert Owen a seruant of the said Sir Thomas, His estate there after his death spoi­led by the Cōpanies factors and his own seruant, and shared between thē & the Gouerners, Treasurers and Cōmittees of the Company, & his state-bookes taken and suppres­sed by them. by confederacie with George Ball, William Methald and Augustine Spaulding Factors likewise for the said Companie (according to the vsuall customes of those Factors in case of any mans death there, by a forehand pri­uate direction from the Gouerners, Treasurers and Committees of that Companie, to seize vpon all his goods for the vse of the Companie, and so to swal [...]ow vp all his estate) got aboord the said Ship in the absence both of the Master and Purser of the same, and there vnlawfully brake into Sir Thomas his Cabbin and store-roome, and tooke and carried from thence all his money, goods and estate there whatsoeuer, together with diuers written bookes and memorials of the particulars of his estate there, which bookes and memorials they haue suppressed and concealed, and haue shared all the said estate betweene themselues; and the said Gouerners, Treasurers and Com­mittees of the said Companie giuing no part thereof, nor the sight of the said bookes and memorials to the Pe­titioner euer sithence.

The said Gouerners, The Gouerners, Treasurers and Cō mittees practise further to defeate her of all her estate at home, lying in their hands. Treasurers and Committes not herewith content, haue since practised to defeate the Pe­titioner of all her estate at home (lying all in their hands) being a matter of 2000 poūds or neare thereabouts, ad­uentured by her said husband in both the ioynt stocks of that Companie, besides the profits thereof and some o­ther moneys owing by the Companie to her husband, causing an officer of theirs to charge her for that purpose with supposed debts of her husbands to the Companie, to the value of 2600 pounds, which vpon examination of another of their officers in her cause, hath been since confessed by him vpon oath to be an vniust charge, and ex­cused as a mistaken by the Companie.

That the Petitioner hath sought remedy for the former of these wrongs (done in the Indies) by a suite in the Admiraltie Court against the said Iones and Owen, She seeks remedy in the Court of Admiraltie for her wrongs beyond seas, but obtaines not iustice there according to her proofes. being the principall actors of the said wrongs and spoile there, where notwithstanding that good proofe was made, as well of their said vnlawfull fact, as of diuers particulars of the said estate (to a great value) so vnlawfully taken away by them, besides a much greater estate concealed by their taking and suppressing of the said bookes and memorials, yet through the greatnesse and potencie of the said Gouerners, Treasurers and Committes bearing those fellowes out in that suite against the Petitioner, she could not there obtaine recompence of the said wrongs, All she hath, thus detained from her, not able to main­taine suite, her wit­nesses not to be had at all times, their depositions already taken, not seruing in any other Court. according to her proofe made thereof.

So the said Gouerners, Treasurers and Committees, and those others before mentioned, detaining from the Pe­titioner all she hath; and the said Gouerners, Treasurers and Committees not onely denying to yeeld her any part of her meanes in their hands, either for the righting of her selfe by suite, or for her necessary maintenance, but re­fusing also very scornfully as much as to treate with her (or her friends for her) of iustice and equitie, especially be­cause the depositions already taken in her cause, will not auaile her in any other ordinary Court; and her wit­nesses (of the wrongs done her beyond Seas) being sea-faring men, are not to be produced at all times to serue her turne, some of them (who haue been examined already in her cause) being since gone againe to Sea. Praying this high Court to consider of her cause, to call the parties, to view the state-books and the proofes already made, and thereupō to take order for her reliefe.

Humbly therefore prayeth this honorable Court to take her cause into their considerations, to call the parties aboue mentioned (or such of them as are neare at hand) to appeare forthwith before them, comman­ding them to bring the said bookes and memorials into the Court, and vpon view thereof, together with such proofes as are already made in the cause, without further trouble or other examinations, to take such order for her reliefe and satisfaction for the said seuerall wrongs, as their wisedomes shall finde agreeable to iustice and equitie.