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 Companies factors and his own seruant , and shared between them & the Gouerners , Treasurers and Committees 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 Committees 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 pounds 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 thereupon 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 .