University of Virginia Library

XVI. Virginia Company vs. Sir Edmond Boyd, Sir John Sammes, and
Others. The Answer of Sir John Sammes to the Bill of
of Complaint
November 1, 1613

The Seu9all answere of Sr John Sammes Knt one of the defendtℯ to the bill
of complainte of the Tresurer and companie of adventurers and
planters of the Citie of London for the first colonie in virginia Compltℯ

Thaduantages of exceptions to the incerteinties and insufficiencie of the
said bill of complainte to this defendt now and at all tymes hereafter
saued for answere vnto so much thereof as concerneth this defendat, he
this defendt saith that he taketh it to be true that after the discouerie of
that p̱te of America now caled and knowne by the name of virginia there
was an honorable purpose and attempt made by dyuers worthie p̱sonnes

for the plantac̃on thereof and reducinge the same to ciuilitie, and chris-
tianitie, ffor the furtherance of wch honorable intent and purpose, it
pleased his Matie (as this defendat taketh it) to incorporate the Compltℯ
as in the said bill of Complaint is menc̃oned, and this defendt further
taketh it to be true, that after some mony adventured and spent in the
said buisines, the Compltℯ found it to be a matter of greater difficultie
and charge then they before Imagined and thought it would haue beene,
for they were (as this defendt taketh it) informed by Sr Thomas Gates knt
menconed in the said bill, beinge imployed in the said buisines of and for
virginia a greater supply of men and mony was requisite for the accom-
plishmt of that honoble acc̃on then formerly had beene imployed and gath-
ered, wherevpon the foresaid companie the Compltℯ and others entred
into a new councell or consultac̃on concerninge the afforesaid buisines of
virginia, And as this defendt taketh it resolued and concluded that wth out
a new aid and supply of mony and men for virginia such as was then
formerly propounded and required by the said Sr Thomas Gates, the
foresaid honoble acc̃on and intenc̃on of plantac̃on of virginia would faile,
and not take that effect as was desired, and therevpon some three yeares
since or thereaboutℯ as this defendt now remembreth, vpon the new con-
sultac̃on afforesaid had amongest the Compltℯ and companie for the good
of virginia concerninge what further charge in money would be requisite
for the furtheringe and accomplishinge of the foresaid intended plantac̃on
and acc̃on of virginia, it was concluded and agreed amongest them the
said Compltℯ that Eyghteene thousand poundℯ at the least to be gathered
in three yeares then next followinge would be but a sufficient some of
money for the accomplishinge and effectinge of the foresaid p̃nte service
for virginia, and that it was also necessarie to haue sixe hundred men
furnished sent thither before may then next followinge the consultac̃on
spoken of beinge about Michaelmas 1610 and that vnles the said 18m ɫi
and 600. men might forthwth in certeyntee be prouided the said service
would not at all be effected or p̱formed Therefore for the gatheringe of
the foresaid 18m ɫi and for the prouidinge of the said 600. men in the three
yeares afforesaid at the tyme of the Consultac̃on spoken of it was agreed
by the foresaid Compɫte and companie that a booke concerninge the
service afforesaid should by the Compɫtℯ be made and published wth a
condic̃on in the beginninge of the said booke to this or the lyke effect
vizt The names of such as vndertake to adventure to virginia so as the
som̄e of 18m ɫi may be made vp before some certein daie therein expressed
beinge about Christmas. 1610. as this defendt taketh it and so as the said
600. men might be prouided and sent in Januarie. 1610. to and for the
purpose afforesaid as this defendt also taketh it, the said mony to be
adventured in three yeares then next followinge as by the said booke
wherevnto this defendat for the more certeintie of and in the premisses
referreth himselfe will appeare wch said booke this defendant seeinge
and at that tyme thinkinge it to be a very worthie worke of plan-
tac̃on this defendt amongst others vpon the condicons and agreemtℯ in
the said booke menconed and on the Compltℯ p̱ts to be p̱formed and not
otherwyse did subscribe the name of this defendt to be contented to giue
a CLɫi towardℯ the plantac̃on afforesaid (as by the said booke wherevnto
this defendt doth solely refer himselfe appeareth and this defendt then
thinkinge the Compltℯ would haue p̱formed there p̱ts and condic̃ons
afforesaid paid fiftie poundℯ p̱cell of the foresaid CLɫi about Christmas
1610. But this defendt further saith that it was neuer his this defendtℯ
intent nor meaninge to disburse or laie out the foresaid CLɫi vnles the
said 18m ɫi might be gathered and the said 600. men prouided furnished
and sent accordinge to the condic̃on and purporte of the said booke so as
the foresaid service for virginia might indeede be p̱formed, And this
defendt further saith that he thinketh it to be true that the condic̃on and
purporte of the said booke is not nor hath not bene p̱formed aswell for
that the said 18m ɫi was not made vp as alsoe that the said 600 men were
not furnished and sent for the said purpose accordinge to the said con-
dic̃on (as this defendt verely thinketh) by meanes whereof (as this defend
hath beene informed and verely thinketh it to be true) the said intended
plantacon hath not succeeded accordinge to the purpose and intenc̃on of
this defendt and the said other adventurers, And this defendt further
saith that he this defendt hath beene informed that the Compltℯ or other
the managers of the buisines for virginia haue not pursued the courses
propounded whereby this deft and some others were invyted to contribute
so liberally as they did but beinge vpon condic̃ons and these not p̱formed
And this defendt further saith that he taketh it the greate som̄es of mony
amountinge to 8000ɫi or theraboutℯ wch haue bene gotten by the lottarie
and intended to haue bene vsed and disbursed in and about the buisines
and plantac̃on of virginia haue not beene imployed nor bestowed accord-
ingly besydes the Ilandℯ caled the Bermudas haue beene as this defendt
is informed sould by ye Compltℯ for 2000ɫi And this defendt is further
informed that the Completℯ haue also lately sould awaie for 6 or 8Cɫi or
thereaboutℯ the Shippe caled the De la War wch shipp was wont to be
imployed for or about the buisines of virginia, besydes also this defendt
hath and doth obserue that the Compltℯ respect not to giue satisfacc̃on to
this defendt nor to some other Kntℯ and gent̃ that haue adventured for
and concerninge the foresaid buisines of virginia but haue deteyned and
doe deteyne all the benefit made by the seu9all voyages to virginia affore-
said and all the seu9all somes afforesaid wth out yeeldinge any account to
the adventurers to this defendtℯ knowlege for all wch causes and many
others this defendt taketh it that neyther in lawe nor equitie he is to pay
or giue much lesse to be compelled for to pay or giue the foresaid CLɫi or any
p̱te thereof vnto the Compltℯ wth out that that this defendt in any other
maner then as afforesaid vndertooke or agreed to pay vnto the Completℯ
any som̄e or somes of mony whatsoeuer or that the foresaid acc̃on of virginia
be lykely to be relinquished or is vtterly relinquished or neglected for or
by reason of this deftℯ not painge of the foresaid Cɫi And vnles any other
thinge or matter in the Compltℯ bill menconed and hereby and herein not
sufficiently answered trau9sed confessed or denyed is true to the knowl-
ege of this defendt All wch matters this defendt is readie to proue and
auerr as this honble Court shall award And therefore this defendt doth
humblie praie to be dismissed out of this honble court wth his reason-
able costℯ and charges in this behalfe wrongfully and vniustly susteyned