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Collins Dec 12th 1751
December 1751 before
Both sworn at the publick office The Joint and several answers of John Marchant Gentleman and Robert Walker Defendants to the Bill of
Complaint of Jacob Tonson Richard Tonson Somerset Draper James Hodges Samuel Bert Thomas Longman
Lyncolnes Inn the twelfth day of Benjamin Dodd Edward Wasted Charles Hitch Charles Corbet John Brindley John Ward and John Oswald

The said defendants saving and reserving to themselves now and at all times hereafter all Benefit and Advantage of Exception to the
Manifold uncertainties Insufficiencies and other Imperfections in the Complainants said Bill of Complaint contained
for answer thereunto or unto so much thereof as these Defendants are advised materially concern them to make answer unto they severally
answer and say that they believe it to be true That John Milton of London Gentleman Deceased in the Complainants said
Bill of Complaint named did compose and write a Poem Intitled Paradise Lost and that he might for ought these Defendants know to the
Contrary by Indenture of such Date purport and Effect as in the said Complainants Bill is for that Purpose Mentioned Give
grant and assign to Samuel Symonds in the Complainants said Bill also Named his Executors and Assignes all that the Copy Book or
Manuscript of the said Poem Intitled Paradise Lost together with the full Benefit Scope and Advantage thereof or which should or might
Arise thereby And these Defendants further severally say that the said Samuel Symonds was for ought they Know to the contrary Intitled
unto the said Copy Book or Manuscript of the said Poem and to the sole Right of Printing and Vending the Same and they Also
severally Believe That he did between the year One thousand six hundred and Sixty Seven and the Year One thousand Six hundred and
Eighty at his own Costs Print and Publish the said Poem in Twelve Books in Octavo without any attempt to invade his Right
and these Defendants further Severally Say That they do not know or can set forth that the said Samuel Symonds did afterwards on or about
the Twenty seventh day of October which was in the Year of our Lord One thousand Six hundred and Eighty Agree to Sell the same unto
Brabazon Aylmer since Deceased in the said Bill also Named for a certain sum of money or that he Did thereupon by his Deed Poll of
Assignment bearing such Date as in the Complainants said Bill is mentioned for the considerations in the said Deed Poll Mentioned
Grant Bargain sell assign and sett over to the said Brabazon Aylmer his Executor Administrators and Assigns his Copy or Book Intitled
Paradise Lost to hold to him the said Brabazon Aylmer his Executor Administrators and Assignes to his and their own proper use
and Behoof for ever or that he Did by the said Deed Poll for himself his Executors and Administrators Covenant and Grant to and with the
said Brabazon Aylmer his Executors and absolute Authority to Grant Bargain Sell assign and Sett over the said Copy Book or Manuscript as
Aforesaid Or that he the said Samuel Symonds did in and by the said Deed Poll desire and Authorize the Master and Wardens of the
Company of Stationers London to permit and suffer the said Book or Copy to be Entred in their Register to him the said Brabazon Aylmer
as his own proper Book and Copy But these Defendants Severally Crave the Complainants to make such proof thereof as they shall think fit
and these Defendants further Severally Say that they do not Know or can set forth that the said Brabazon Aylmer by virtue of the said Deed
Poll or Assignment was possessed of or Intitled unto the said Book Copy or Manuscript of the said Poem and to the Sole right of Printing
and Selling the same or whether he did on or about the Seventeenth day of August which was in the Year of our Lord One thousand Six
hundred and Eighty Three Agree to sell one Moiety or Equal half part or Share of his right in and to the said Book Copy or Manuscript to
Jacob Tonson the Elder in the Complainants said Bill Named and Uncle to the Complainants Jacob Tonson and Richard Tonson for a
Certain Sum of Money Neither do these Defendants Know that the said Brabazon Aylmer by his Deed Poll of Such Date purport and Effect
as in the Complainants said Bill is Mentioned did for the Consideration therein mentioned Grant Bargain Sell assign Transfer and Sett Over
unto the said Jacob Tonson the Elder One Equal Moiety or half Part of his the said Brabazon Aylmers right of and in the said Book Copy of
Manuscript to hold to him the said Jacob Tonson the Elder his Executors Administrators and Assigns To his and their own proper Use and
Behoof for Ever But these Defendants severally Crave the Complainants to make such proofs thereof as they shall think fit and these
Defendants further severally say that they do not Know or can set forth that the said Brabazon Aylmer afterwards did agree to sell the
remaining Moiety or half part of his said Right ^in^ and to the said Book Copy or Manuscript of the said poem to the said Jacob Tonson the
Elder for a Certain Sum of Money or that thereupon he did by his deed Poll of such Date purport and Effect as in the Complainants said Bill
is mentioned and for the Consideration in the said Deed poll Bargain sell assign Transferr and Sett over unto the said Jacob Tonson the
Elder all that his remaining hald part or Moiety of the said Copy Book or Manuscript Intitled Paradise Lost a Poem in Twelve Books by
John Milton      [blank]      of London ^Gentleman^ Deceased To hold the said last Mentioned half part or Moiety to the said Jacob
Tonson the Elder his Executors Administrators and assignes to his and their own proper use and Behoof for ever but these Defendants
severally Crave the said Complainants to make such proof thereof as they shall think fit and these Defendants further answering say that
they of their own Knowledge do not Know or can set forth that the said Jacob Tonson the Elder was by Vertue of the said two last
Mentioned Deed Polls or Assignment Possessed of and Intitled unto the whole copy Book or Books of the said Poem Intitled Paradise Lost
and to the sole right of Printing and Publishing the same but these Defendants further Severally Say that the said Jacob Tonson the Elder for
ought these Defendants Know to the Contrary might between the Year One Thousand Six hundred and Ninety and the Year One Thousand
seven hundred and four at his own Expence and Charge Print Reprint and Publish Several Editions of the said Poem in Folio Quarto Octavo
and Duodecimo without any Lett or Interruption of or by any person whatsoever as in and by the Complainants said Bill is for that purpose
Mentioned And these defendants further Answering Say that they of their own Knowledge do not Know nor can they set forth whether the
said Jacob Tonson the Elder did in and about the time in the Complainants said Bill for that purpose mentioned agree to Sell and assign One
Equal fourth part of his Right in and to the said Copy Book or Manuscript to Richard Wellington in the Complainants said Bill named or
that thereupon the said Jacob Tonson the Elder by Deed poll of such purport Date and Effect as in the Complainants said Bill is Mentioned
and for the consideration in the said Deed Poll Mentioned did Grant Bargain sell and assign unto the said Richard Wellington since deceased
all that one fourth part The whole into four Equal parts to be divided in the said Copy Book or Manuscript Intitled Paradise Lost in Twelve
Books to hold unto him the said Richard Wellington his Executors Administrators and Assigns to his and their own proper use and Benefit
for ever But these Defendants severally leave the Complainants to Make such proof thereof as they shall think fit And these Defendants
further answering say that they of their own Knowledge do not Know or can set forth whether the said Jacob Tonson the Elder Continuing
Possessed of the Remaining three fourths parts of and in the said Book Copy Manuscript or Poem did on or about the Seventh Day of
September in the Year of our Lord One thousand Seven hundred and Eighteen Agree to Sell and assign the same amongst other things to
Jacob Tonson the Younger in the Complainants Bill also Named and Citizen and Stationer of London since Deceased late Father of the said
Complainants Jacob Tonson and Richard Tonson Or that thereupon the said Jacob Tonson the Elder did by Deed Poll of such purport Date
and Effect as in the Complainants said Bill is for that purpose Mentioned and for the Consideration in the said Deed poll Mentioned Grant
Bargain sell assign and Sett over unto the said Jacob Tonson the Younger all that the Right Title property Trust Claim and Demand of him
the said Jacob Tonson the Elder of in and to (Amongst several other Copies of Books Shares and parts of Copies of Books therein
Mentioned) all these three remaining fourth parts in in the said Copy Book Poem or Manuscript Intitled Paradise Lost in Twelve Books to
hold unto him the said Jacob Tonson the Younger his Executors Administrators and Assigns to his and their own proper use and Benefit for
ever But these Defendants Severally leave the Complainants to make such proof thereof as they shall think fit And these Defendants further
severally answering Say That for ought they know to the Contrary The said Richard Wellington might on or about the Twenty fifth Day of
April which was in the Year of our Lord One thousand Seven hundred and fourteen Depart this Life Intestate but whether by virtue of the
Custom of the City of London and Statute of Distributions ^ - ^ Wellington his Widow became Intitled to and Interested in four equal Ninth
parts or Shares the whole into Nine equal parts or Shares to be Divided of and in all such Copies of Books or Shares of Copies of Books as
the said Richard Wellington possessed of or Intitled unto at the time of his Decease Or Whether the Remaining five equal Ninth parts or
shares of such Copies of Books did by virtue of the said Custom and Statute became Vested in his three only Surviving Children Richard
Wellington Bethel Wellington and James Wellington (in the Complainants said Bill named) in equal third partes or Shares as in the
Complainants Said Bill of Complaint is for that purpose set forth these Defendants or Either of them to the knowledge of the other of them
know not nor can set forth Neither do they these Defendants Know or can set forth whether the said James Wellington being in possession
of and Intitled to one third part of the said ^five^ equal Ninth parts or Shares did afterwards on or about the twenty Eigth day of May one
thousand seven hundred and thirty seven Agree to sell the same to the said Complainant Charles Corbett or that thereupon the said James
Wellington by Deed poll of such Date purport and Effect as in the Complainants said Bill is Mentioned As for the Considerations in the said
Deed poll Mentioned did give Grant Bargain Sell and assign to the said Complainant Charles Corbett all that his one equal third part of the
said five equal Ninth parts or Shares of the said fourth part or Share that is to say five equal one hundred and Eighth parts of and in the said
Copy Book Poem or Manuscript Intitled Paradise Lost to hold to the said Complainant Charles Corbett his Executors Administrators and
assignes to his and their own proper use and Benefit for ever But these Defendants Severally leave the said Complainants to make such
proof thereof as they shall think fit And these Defendants further Answering say that they of their own Knowledge Do not know or can set
forth whether the same Complainant Charles Corbett was by Virtue of the said last Mentioned Assignment possessed of and Intitled to the
said five equal one hundred and Eighte parts or Shares being ten equal Two hundred and sixteenth parts or shares of and in the said Copy
Book Poem or Manuscript as in the Complainants Bill is for that purpose set forth or that about the ninth day of September one thousand
seven hundred and thirty seven He did agree to sell one Moiety of his Share or Interest in the said Copy Book or Manuscript to the said
Complainant Brindley Or that thereupon by Deed Poll of such Date purport and effect as in the Complainants said Bill is also mentioned the
said Complainant Charles Corbett for the consideration in such Deed Poll did give grant Bargain sell and assign to the said Complainant
John Brindley all that one equal half part or Moiety of his Right Title Interest share and Proporcion That is to say Five Equal two hundred
and sixteenth parts or Shares of and in the said whole Copy Book Poem or Manuscript Intitled Paradise Lost to hold to the said Complainant
John Brindley his Executors Administrators and assigns to his and their own proper use and behoof for ever that these Defendants severally
Crave the said Complainants to make such proof thereof as they shall think fit And these Defendants further say that they of their own
Knowledge do not Know or can set forth whether the said Complainant Charles Corbett Continueing possessed or Intitled unto five equal
two hundred and sixteenth parts of shares of and in the said Book Copy Manuscript or Poem Intitled Paradise Lost Did on or about the
twelfth Day of October in the Year of our Lord one thousand seven hundred and thirty seven agree to sell the same to Aaron Ward late
Citizen and Stationer of London since Deceased in the Complainants said Bill Named and to the said Complainants John Oswald Or that
thereupon by two several Deeds Poll of such Date purport and Effect as in the Complainants said Bill is for that purpose set forth The said
Complainant Charles Corbett for the Considerations in the said Deeds Poll respectively mentioned Did Give Grant Bargain Sell and Assign
to each of them the said Aaron Ward and the said Complainant John Oswald respectively one equal half part or Moiety of the said
Complainants Charles Corbet then remaining Interest and share that is to say to each of them five equal four hundred and two thirtieth parts
of and in the said Copy Book Manuscript or Poem Intitled Paradise Lost to them the said Aaron Ward and the said Complainant John
Oswald severally and to their Respective Executors Administrators and Assigns to and for his and their own proper Use and Behoof for Ever
But these Defendants Severally leave the said Complainant is to make such proof thereof as they shall think fit And these Defendants further
Answering Say That they of their own Knowledge do not Know that the said Widow Wellington being Intitled to such part or Share of the
said Book Copy Manuscript or Poem as aforesaid Did on or about the twenty first Day of February one thousand seven hundred and
Eighteen Intermarry with John Poulson of Hatton Garden in the County of Middlesex Esquire in the Complainants Said Bill Named But that
afterwards she might for Ought these Defendants know about the time in the said Complainants Bill Mentioned Died without having made
any Disposition of or Concerning any of her Copies of Books or Shares of Copies of Books But whether thereupon the said John Poulson
became Duly possessed of and Intitled to the said four Equal Ninth parts of Shares of the said fourth part of the said Richard Wellington
being four equal thirty sixth parts of Shares of and in the said Book Copy Poem or Manuscript Intitled Paradise Lost as in the Complainants
said Bill is Mentioned These Defendants or either of them to the Knowledge of the other of them Know not Neither Do they these
Defendants Know that the said John Poulson being so possessed and Intitled did on or about the Nineteenth Day of September in the Year of
our Lord one thousand seven hundred and Thirty four agree to Sell amongst other Copies of Books and Parts of Copies of Book the said last
Mentioned four equal Ninth parts to William Feales of London Bookseller as in the Complainants said Bill is Mentioned Or that thereupon
the said John Poulson by Deed Poll of such Date Purport and Effect as in the said Complainants Said Bill is set forth and for the
Considerations in the said Deed Poll Mentioned did Grant Bargain Sell Assign and Sett over unto the said William Feales amongst other
things all those his four equal parts of one equal fourth part of the said Book Copy Manuscript or Poem Intitled Paradise Lost in Twelve
Books To hold to him the said William Feales his Executors Administrators and assignes to his and their own Proper Use and behoof for
Ever. But these Defendants Severally Crave the said Complainants to make such proof thereof as they think Proper. And these Defendants
further answering Say That they of their Own Knowledge Do not know nor can they set forth whether the said William Feales being by
Virtue of the said Deed Poll or Assignment last Mentioned possessed of and Intitled to the said four Equal thorty Sixth parts or shares of and
in the said Book Copy Manuscript of Poem Did on or about the tenth day of July which was in the Year of our Lord one thousand seven
hundred and thirty five Borrow and Receive a Sum of Money of John New of London Gentleman as in the said Complainants Bill is
Mentioned or That thereupon for Securing the Repayment thereof with Interest He the said William Feales by his Deed Poll of such Date
Purport and Effect as in the Complainants said Bill is Mentioned did Grant Bargain Sell assign and Sett over to the said John New amongst
other things one equal thirty sixth part or share of and in the said Book Copy Manuscript or Poem Intitled Paradise Lost to hold to the said
John New his Executors Administrators and Assignes for Ever Or whether the same was Subject to a Proviso of Redemption as in the
Complainants said Bill is Mentioned. These Defendants or Either of them to the knowledge of the other of them know not Neither Do these
Defendants Know that the said William Feales afterwards on or about the twenty Eighth Day of March one thousand seven hundred and
thirty seven having Occasion for a further Sum of Money Applied to and Borrowed the same of the Complainant Charles Corbett or that
thereupon for Securing the Repayment thereof with Interest He the said William Feales by his Deed Poll of such Date purport and Effect as
in the Complainants said Bill is Mentioned And for the Considerations in the said Deed Poll Grant Bargain Sell and Assign to the said
Complainant Charles Corbett one other thirty Sixth part or share of and in the said Copy Book Manuscript or Poem Intitled Paradise Lost to
hold to the said Complainant Charles Corbett his Executors Administrators and Assigns for Ever Or Whether the same was Subject to a
Proviso of Redemption as in the said Complainants said Bill is Mentioned these Defendants or Either of them to the Knowledge of the other
of them Know not nor can set forth. And these Defendants further Answering say they do not know nor can set forth whether the said last
mentioned Thirty Sixth part or share of and in the said Copy Book Manuscript or Poem became forfeited for Default of Redemption
According to the Proviso in the said last Mentioned Deed Poll Contained or that the said Complainant Charles Corbett became thereby
Absolutely Possessed of and Intitled to the same or that he did about the seventeenth day of April which was in the Year of our Lord one
thousand seven hundred and thirty Eight agree to sell his said part or share to the said Complainants Samuel Birt and Edward Wicsted as
in the Complainants said Bill is for that purpose Mentioned Or whether thereupon by Deed Poll of such date purport and Effect as in the said
Complainants said Bill is Mentioned the said Complainants Charles Corbett for the Consideration in Such Deed Poll did Grant Bargain
Sell assign and sett over to the said Complainants Samuel Birt and Edward Wicsted all that his said Thirty Sixth part or Share of and in the
said Book Copy Manuscript or Poem Intitled Paradise Lost To hold to the said Complainants Samuel Birt and Edward Wicsted their
Executors Administrators and assigns for Ever These Defendants or Either of them to the Knowledge of the other of them know not but
Severally leave the Complainants to Make Such proof as they shall think fit And these Defendants further Answering say that they Do not
know nor can they set forth whether the said William Feales on or about the Eleventh day of June in the year of our Lord one thousand
Seven hundred and thirty seven Continuing to be possessed of and Intitled unto two Thirty Sixth Parts or Shares of and in the said Book
Copy Manuscript or Poem Intitled Paradise Lost Or that having an Occasion for a further Sum of Money did Borrow and Receive the same
of Henry Woodfall Citizen and Stationer of London as in the said Complainants said Bill is set forth Neither do these Defendants Know
That thereupon for Securing the Repayment thereof with Interest He the said William Feales by his Deed Poll of such Date Purport and
Effect as in the said Complainants said Bill is Mentioned and for the Considerations in the said Deed Poll did Grant Bargain Sell and
assign to the said Henry Woodfall all those his two Remaining Thirty Sixth parts or Shares of and in the said Book Copy Manuscript or
Poem Intitled Paradise Lost to hold to him the said Henry Woodfall his Executors Administrators and assigns for Ever or whether
the same was Subject to a Proviso of Redemption at a Day Long Since past as in the said Complainants said Bill is set forth these
Defendants or Either of them to the Knowledge of the other of them know not nor can set forth And these Defendants further say That the
said William Feales might some time in the year one thousand seven hundred and thirty seven for ought these Defendants know to the
contrary Became a Bankrupt within the Intent and Meaning of the Several Statutes Relating to Bankrupts and thereupon a Commission of
Bankrupcy about the time in the Complainants said Bill Mentioned may have issued out of this honourable Court against the said William
Feales Directed to the Commissioners therein Named as in the said Complainants said Bill is Mentioned and these Defendants further say
that they of their own knowledge Do not know neither can they set forth That the said Complainant Jacob Tonson and John Watts Henry
Woodfall and Joseph Stiles in the said Complainants said Bill named ^or any^ the assignees of the Estate and Effects of the said William
Feales under the said Commission did on or about the Sixteenth Day of October in the said year one thousand seven hundred and thirty
seven Redeem the said two Thirty Sixth parts or shares so made a Security to him the said Henry Woodfall as in the said Complainants said
Bill is Mentioned but whether thereupon the said Henry Woodfall by his Deed Poll of such Date purport and Effect as in the Complainants
said Bill is for that purpose set forth and in Consideration of the Money by them received out of the Estate and Effects of the said Bankrupt
in full of the Principal and Interest due to him on the Security Did Declare that he Stood Possessed of the said two Thirty Sixth parts or
Shares of and in the said Copy Book Manuscript or Poem Intitled Paradise Lost to the use of the said assigness their Executors
administrators and assignes for ever in trust for themselves and the rest of the Creditors of the said William Feales these Defendants or either
of them to the knowledge of the other of them know or neither Do these Defendants know or can set forth whether the said assignees of the
said William Feales did on the twelfth day of December in the year one thousand seven hundred and thirty eight put up to publick Auction
the said two thirty sixth parts or shares of and in the said Book Copy Manuscript or Poem in two separate Parcells or that the said Aaron
Ward and Richard Chandler in the said Bill Named were allowed to be the best Bidders for one and James Hutton in the said Bill also
Named for the other of the said two Thirty Sixth parts or shares as in the said Complainants said Bill is set forth Or whether thereupon the
said assignees by two several Deeds Poll of such Date Purport and Effect as in the said Complainants said Bill is Mentioned and for the
Considerations in the said