THat the Inhabitants of the Territory of the Birnes Countrey in the County of Wickloe, and those under whom they derive their Estates, were for above 300. years seized thereof, as of their Freehold and Inheritance, doing the service of Freeholders; Yet for further confirmation of their Estates, King James 26 Junii, 1611. by his Letters under the Privie Signet, directed to the then Deputy of Ireland to accept Surrenders from the said Inhabitants, and to agree with them at such Rent as they would give. In pursuance whereof they compounded for two hundred pounds yearly rent during the lives of Sir Henry and Sir William Harrington, and after their deceases for one hundred and fifty pounds per annum, to be paid for ever, which hath beene duly paid ever since: And Surrenders were to be accepted, and Patents granted accordingly, As by an Act of Coun­cell in Ireland dated the 11 of November 1611. may appeare, which Act of Councell was approved of by King James, as by his Letters may appeare. And most of them did surrender and accept of Letters Patents.

That the late King Charles taking into his consideration the Intention of King James for setling the Estates of all the Inhabitants, by his Letters of the 24 Maii 1628. directed that effectuall grants should be made to the Inhabitants and their heirs, and declared his expresse Will, that by occasion of no new doubts that might be raysed, the said Inhabitants be not againe molested or disquieted; And in the same yeare the said late King in consideration of 120000. li. did grant certaine graces to the people of Ireland; Of which one was, that at the next Parliament there to be holden, there should passe the like Act for limitation of the Kings Title as passed here 21 Jacob.

The Inhabitants of the Birnes Countrey, paid their share of the 120000. li. but the late Earle of Strafford in the next Parliament, being in the tenth year of the late King, would not suffer any such Act to passe.

That your Petitioners father upon the many engagements aforesaid, sold five hundered pounds land per annum in England, and seated himself in the County of Wickloe, where he laid out near 10000. li.

That about April 1638. by the power and procurement of Thomas late Earle of Strafford then Deputy of Ireland, and others of his Adherents, a Commission issued to persons of their nomination, and unindifferent to enquire what title the late King had to the said Territory: And the said Earle being present, none daring to oppose him without pregnant Evidence, It was found that King Richard the second was seized in Fee of the said Terri­tory, and that it immediately descended to the late King.

And whereas upon former Commissions of intituling only a fourth part was seized, and that planted with English Protestants, yet was your Pe­titioners father being of English extraction, and a Protestant, by direction of the said Earle and his Councell dated the 9th of July 1639. by the Sheriffe of the County of Wickloe dispossest of all his Estate in the Birnes Countrey (viz.) Tyne Parke, Kilne Parke, Galligoure, Garriduff, and two Ballihorses, and a faire stone built house. a Moety of the towne of Leybegge, two third parts of Ballinehone, and his certaine share in the townes of Gur­ten, le moore, Ballinotin, Killorter, Garricho, and Rodonaghmoore, worth above three hundred pounds per annum, whilest he was offered in liew there­of Lands not worth above sixty or eighty pounds per annum.

All which premisses (except two parts of Ballinehone granted to Sir William Parsons, and one other part granted to Master John Ʋsher) were by the late Kings Letters of the fifth of Iune 1639. granted to Sir Adam Loftus, Sir Robert Meredith, and Sir Philip Percival Knights, at such rents as the De­puty should think fit, and a Patent passed accordingly at the yearly rent of 212 li. 8 s. 3 d. ob. q. So that though many were ruined by this Plantation, the late King gained but 62 li. 8 s. 3 d. ob. q.

That the said Deputy, and other his Complices, knowing the weaknesse of the Title, a Bill was certified hither to be passed in Parliament there, wherein the premisses amongst divers old Plantations of that Countrey were inserted, and other lands called Towerboy and Shelelagh, which were no Plantation lands, nor contained in the said Inquisition (as your Petitioner is informed) were for the private ends of the said Earle of Strafford incerted in the said Bill; And the said Bill passed the houses of Parliament in that Country, not understanding of the engagements, either of the late King Iames or King Charles, or of the weaknesse of the grounds whereupon the Office was found, or of the extreme inequality of the several distributions; And was an Act only intended for securing the Estates of the Freeholders and reputed Inheritors.

That upon your Petitioners Fathers Petition to the Parliament of England, the said late Earle of Strafford knowing the said proceedings, must needs come to light, and how small an increase of rent came to the late King by this plantation; It was devised that all the said lands should be passed to George Carre, William Billingsly, and others in trust for the Earle of Strafford, and to be passed upon the Commission of Grace for remedy of defective Titles at the rent of two thousand pounds, which was accordingly passed by the late Kings Letters of the nineteenth of Ianuary 16 Car. Although your Petitioners Father did exhibit his Complaint against the proceedings in Ireland: And his Cause then depended in the Parliament of England.

That your Petitioners Father was denied the Copie of the Inquisition, though he petitioned for it, intending to Traverse it.

That the Commissioners for Plantation demanded sight of his Writings, and kept them from him, till your Petitioners Father petitioned to the Parliament of England for them, and then they were delivered.

That the like Inquisition to several Counties in Conaught and Munster were vacated by the late Kings Order, dated 3. Apr. 17. Car.

Your Petitioners Father in November 1640. petitioned the late Parliament for relief, who referred the same to a Committee, where his Cause was heard in February following. And upon Master Pyms Report the 19. of March following. It was resolved the Cause should be transmitted to the Lords; yet Master Speaker by direction of the House by his Letter of the ninth of September 1641. recommended the Case to the Commons in Ire­land to be righted, But before any thing done therein, the Rebellion broke out.

Your Petitioner therefore humbly prayeth, That out of your love to Justice and Zeale to Equity, you would vouchsafe to look upon the oppres­sion your Petitioners Father suffered by being wrested out of his Estate by the Potency of the late Earle of Strafford, It being the fitter Object of your Care in regard of the former Applications to Parliaments. And that no other Court of Iustice can do your Petiti­oner right; And that injustice may not prevaile above one Age together: And that your Petitioner may be restored unto that which his Father was so unjustly deprived of, with damages and costs.

And your Petitioner shall ever pray.