guments as these, which their Counsil urged. That the Precinct of the said Friers were in London; and therefore claimed the like Liberty in them, as in the rest of the City. And that divers Felons, for Felonies within the two Precincts, were in the Friers times Indicted, Arraigned and Tried in London. They claimed now to have from her Majesty all Waifes, Strays, Felons Goods, Amerciaments, Escheats, &c. the Execution of all Processes, the Expulsion of all Foreigners; the Assize of Bread, Beer, Ale and Wine; the Wardmote Quest, and such other Jurisdictions as they had within the rest of the City. But the Counsil against the City, answered these Allegations; and produced some other Proofs for the better Confirmation of the said Liberties. They denied not the Friers to be in London, but they affirmed them to be not of London; no more than St. Martins le Grand, Creechurch, St. Bartholomews, &c.

But to understand the Pretences on both Sides, as they were pleaded by the Counsil of each, take this authentick Abstract, drawn by the Council, on the behalf of the Liberties of the Friers.

"SOme Presidents they shewed, that the Precincts of the said Black and White Friers were in London; and therefore they claimed the like Liberties in them, as in the rest of the City."

"Wee denie not the Friers to be in London; but we do affirme they be not of London; no more than St. Martins le Grand, Cree Church, St. Bartholomews, St. Ellens, Paul's Churchyard, where the Preaching Place ys, Salisburie Court, the Great Wardrobe, Sir Thomas Heneage's House in Bevis Marks, and divers other Places in London. In all which Places, the Citizens of London, while the Houses of Religion were in being, nor since, had not, nor used, any such Liberties or Jurisdiction, as they do in the rest of the Citie."

" It was also shewed by some of their Precedents, that divers Felons, for Felonies within the said two Precincts, were, in the Friers Time, Indyted, Arrayned, and Tryed in London."

" It myght be, that they were apprehended in London, with the Things stolen abowte theim; (the contrarie whereof was not shewed) and then ought they to be Arraigned within the Citie. Besides, the same Felons were Arreigned by the King's special Commission, Ad inquirendum, &c. tam infra Libertates, quàm extra, infra Civitat. London. & Com. Middlesex. And so the Immunitie of the said Precincts thereby not impeached."

" The Citizens claim now to have from Her Majestie, all Waifes, Strayes, Felons Goods, Amerciaments, Escheats, &c. The Execution of all Processes, the Expulsion of all Foreiners, the Assize of Bread, Beere, Ale and Wyne, the Wardmote Quest, and such other Jurisdictions, as they have within the rest of the Citie."

" For these Matters there were no Precedents shewed, nor no sufficient Proof made. Wherefore we are humbly to beseech your Honours, that the Citizens of London may be enjoyned to shew auntient Precedents, to prove, that in the Friers Time they did execute the said pretenzed Jurisdiction, for the Execution of Processes; and had Waifes, Straies, Felons, Fugitives, and Out-lawed Mens Goods; and other Things claimed by them in generalitie. And that they may deliver unto your Honours, true Copies of the said Precedents. And that the Learned Counsell of the said Inhabitantes, may have a sight of the Records and the said Precedentes, with the Matters Precedent, and subsequent. Whereto they will aunswer sufficientlie in Writing, for preservation of Her Majesty's Title in, and to the Premisses; enjoyed by her Highness, and Her Majesty's Progenitors, by the space of Forty Years, and more, against the Citizens of London; by force of the Act of Parliament, made An. 31. H. VIII. Which gave to his Grace the same Precincts, in the same Plight, Manner and Forme, and as amplie and largelie, as the Friers enjoyed the same. Which then were exempt from the Jurisdiction of London. And being now invested in her Royal Majesty, cannot be taken away without Graunt from her Self. But allowing their chief Objection, which hath not been proved, that the Precincts aforesaid, were parcel of the Citie, before the Foundation of the same; yet after, and at the tyme of the standing of the same Howses, the said Precincts were exempt Places, from the Jurisdictions of the Citizens. And most of the Tenants within the Precints, were at that tyme inhabited by Foreigners, that kept open Shops in the same. And the said Precincts were, and be still nightelie shut with Gates from the Citie: So that the Watch of the Citie could not enter into the same. Which would not have been suffered, yf the Citizens of London had any such Jurisdiction, as they now pretend. Her Majesty may lose 10000l. in a Day, by Lands within the said Precincts, which may escheat to her. Which yf the Citie will have, it is Reason the Citie should give her Majesty a good Fyne for it. Beside, yf London should at any tyme rebell, her Majesty should loose two Places of Strength, to bestow her Force in their own Bosome, to annoy theim: which now by Walls ys shut from theim; and she hath, by keeping the Liberties. They pretend to wyn Favour to their Cawse, that they seek the Liberties onelie for Reformation of Disorders. where Gaine ys the Mark they shoot at."

" But the Black Friers, for good Order of Government, may be a Lanthorne to al the Citie, as shall be plainlie proved. And is now inhabited by Noblemen and Gentlemen."

" The Burthen ys great alreadie of the Government of the Citie, born by such as for the most part are unlearned; as their late hard dealing with Bedlam, and many other Examples, may declare. And therefore we pray most humblie your Lordhips, that they may not be further troubled with us. Submitting our selves most willinglie to be reformed and ordered by your Honours Discretion, as most upright Judges, free from Affection and Partialitie. And in respect, that when the Howses were dissolved, the Records of them were lost and imbesiled; which "