The state of the Protestants of Ireland under the late King James's government in which their carriage towards him is justified, and the absolute necessity of their endeavouring to be freed from his government, and of submitting to their present Majesties is demonstrated.

John Plunkett Lessee of Christ. Lord Baron of Dunsany, Plantiff. Philip Tuite and John Rawlins, Defendants.

Sir Edward Tyrrell's Affi∣davit about packing of Juries.

WHereas there issued two several Venire Faciases, at the Plantiff's Suit, returnable to his Majesty's Court of Ex∣chequer, directed to Edward Tyrrell Esq then High She∣riff of the County of Meath, the first Year of his now Majesty's Reign. Now Sir Edward Tyrrell Baronet came this day before me, and made Oath, That one Mr. Plunket, Brother to the said Lord of Dunsany, came to Longwood to this Deponent's House; and desired this Deponent to stand the Lord Dunsany's Friend, and to give him a Jury that would do him Right; and withal said, this Deponent should have (after the said Lord of Dunsany should be restored to the Possession of his Estate) the sum of three or four hundred Pounds. To which this Deponent answered, He would do him Justice. The said Mr. Plunket desired this Depo∣nent to meet him at Mr. Nugent his Counsel's House, where he would further discourse the Matter. This Deponent did ac∣cordingly meet the said Thomas Plunket, where several Proposals and Overtures were made all to no purpose. This Deponent fur∣ther deposeth, That in some short time after, the said Lord of Dunsany came to this Deponent's said House, and after some Dis∣course, he the said Dunsany desired this Deponent to befriend him against those that wronged him, and kept him out of his Estate. Whereupon this Deponent told the said Lord of Dunsany what offer his Brother made him. The said Lord of Dunsany replying, said, His Brothers were all on the catch, and that he would do his own Business, and not trouble them, or any of them, or words to that purpose; and desired this Deponent to return him a good Jury, and that he, the said Dunsany, would give this Deponent twenty Guinnies in hand, and three or four hundred Pounds when he should be restored to the Possession of his Estate. To which this Deponent made answer, That he would impose no∣thing

on his Lordship▪ and that he would do him Right. Then the said Lord Dunsany swore, that this Deponent should not re∣pent what Kindness this Deponent would shew him in that Affair, and said, he would not fail paying the twenty Guinnies upon the return of the said Venires. This Deponent desired the said Lord of Dunsany to imploy his Brother Thomas Plunket in the prosecu∣tion of that Concern; which he promised he would do, and thereupon began to name such as he would have of the Jury: Which this Deponent desired he should forbear, telling him, if this Deponent should be examined to that, the Aray would be quash'd. The said Dunsany then said, he would put the Venires into this Deponent's Hands, and do what he thought fit, and said, this Deponent should hear from him within some short time, which he performed. And this Deponent deposeth, that he did receive the said two Venires, either from the said Lord Dunsany's Messenger, or from himself or one of his Servants. But this De∣ponent having recollected his Memory, is more apt to believe that it was the said Lord of Dunsany's Messenger or Servant, whom this Deponent hath seen before in the said Lord's Company, that came according to his the said Lord Dunsany's Promise, that de∣livered the said Venires to this Deponent; for he desired to know at his departure from this Deponent, where and when the said Mr. Thomas Plunket should meet this Deponent in order to return the said Writs, or words to that effect. That this Deponent ap∣pointed him to give the said Thomas Plunket notice to meet him at Trim, at one Mr. Eveys House, on such a day as this Depo∣nent cannot tax his Memory now with. That this Deponent having several Occasions to this City, waited on Mr. Daley this Deponent's Counsel, now Mr. Justice Daley, and advised with him about the Proposals, and said Overtures betwixt him this Deponent, and the said Lord of Dunsany; and thereupon resolved to serve the said Lord Dunsany gratis, and not to take or accept of any manner of Consideration from the said Lord of Dunsany, and that he this Deponent would be very just to him; which Reso∣lution was approved of by the said Mr. Justice Daley. This Depo∣nent further deposeth, That according to appointment, being met with punctually, had some Discourse with the said Thomas Plunket, who said, The said Lord of Dunsany his Brother was not prepa∣red

for a Trial, and that he would go on soon with all his Estate at once; and that them two Parcels were inconsiderable in respect of the Bulk of his Estate; and desired this Deponent to reserve the best Men, in order to return them on the Juries, when he should put other Venires for that purpose in this Deponent's hands, or words to that purpose. This Deponent desired him to consider what he had to do, and he should not blame him this Deponent hereafter. He the said Thomas Plunket then replied, That he would be satisfied with what Returns this Deponent should make on the said two Venires, and desired that the best Men might be reserv'd as aforesaid. Whereupon this Deponent soon after return'd the a∣foresaid Venires, with Pannels to them severally annexed. This De∣ponent further deposeth, That he having notice from the Lord Bp of Clogher, that he heard that the said Lord of Dunsany should re∣flect on this Deponent, saying, He would not return him a good Jury without a Consideration: and having met the said Thomas Plunket in the said Lord Bishop's Lodgings, in Michaelmass or Hil∣lary Term last, he desired the said Lord Bishop to acquaint the said Thomas Plunket with the Expressions he heard of the said Lord of Dunsany. Which he having done, the said Thomas Plunket said, That this Deponent desired no Consideration, and that the Lord Dunsany aforesaid was much obliged to him this Deponent; and that he was mighty kind to him, and would justify the same. This Deponent further deposeth, That the said Thomas Plunket having met this Deponent at Longwood, after some Discourse he had with this Deponent, the seventeenth day of March last past, shewed him a List of the Juries, and asked this Deponent if he returned them? To which this Deponent answered, That he had (as he believed): He the said Thomas Plunket thereupon said, most of them were Phanaticks, and that they would hang the said Lord of Dunsany if they could. This Deponent made answer then, That if they prov'd inconvenient, that it was the said Thomas Plunket's fault, for that he had desired this Deponent to return what he this Deponent pleased, and to reserve the best Men for the Bulk of the said Lord Dunsany's Estate, or words to that ef∣fect. The said Thomas Plunket said, He would never consent to the return of such Juries; and passionately said, If he had the twenty Guinnies to give this Deponent, that he would have bet∣ter

Juries. This Deponent asked the said Thomas Plunket, if this Deponent desired any such Sum, or any Sum of him when he met at Trim? he then replied, that he did not, but that the said Lord Dunsany did promise it. After a while he likewise said, That he told the said Lord of Dunsany, that this Deponent could not be supposed to have made that Return for Ill-will or Gain, for that none would give any Sum of Money where the Party could Nonsuit himself; as also that this Deponent had returned good Juries for several of his Country, naming Mr. Evers and others, and that it was his ill Luck that hindred him, or words to that effect. This Deponent further deposeth, That neither of the De∣fendants, directly or indirectly, desired this Deponent for to re∣turn the said Juries. Neither did this Deponent give them no∣tice that he had any Venires; neither did he know that there were any Venires ordered to be granted by this Court, until he recei∣ved the said Venires, either from the said Lord, or Tenants, or Messengers as aforesaid, and further saith not.