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carried their cruelty to the respondent to the most infamous extremity. They stabbed her reputation, which had ever been unblemished; they traduced her as a thief; and even dared to deny her marriage with the appellant, weakly imagining to apologize to the world for the wanton cruelty exercised against her, and maliciously intending to deprive her of all resources from the friendship of her relations and friends, to enable her to seek for justice, or even to procure the means of necessary subsistence. But the respondent's character was too well established to suffer materially by this wicked device; and her friends, convinced of her innocence, and shocked at the treatment she had received, advised her to seek redress in a Court of Justice.

Accordingly, on the 2d of December 1763, the respondent, by her brother and next friend Francis Rolleston, esq. exhibited her bill in the Court of Chancery in Ireland against her said husband, the appellant, and also against Charles Lambert and Megg his wife, [21] John Lambert and Mary his wife, Thomas Lambert and Mary his wife, Mary Lambert widow of Peter Lambert, who were the sons of the appellant; and against Robert Hamilton, esq. brother-in-law to the appellant, and the said Cloran; stating several of the matters and acts of cruelty before mentioned, and also charging her marriage and cohabitation with the appellant for nineteen years, during which time, the appellant had frequently represented to his friends and relations, her care and tenderness of him: her being introduced by the appellant to, and visited by ladies of the first distinction in the country, as his wife. That she was always called mother by the appellant's sons and daughters-in-law, and was received as such by them; and that she stood sponsor to several of the appellant's grandchildren. That she, from time to time, received letters from his sons, addressed to her as their mother-in-law, and written in a dutiful manner. That the appellant joined the respondent in making two leases of her farm of Gortern, in each of which leases there was a proviso, that the respondent should take the profits to and for her sole use, notwithstanding her coverture. That the appellant executed several wills, which were all in his own handwriting; the first of which was dated the 3d of December 1751; another dated the 17th of March 1752; another dated the 15th of June 1756; another dated in March 1757; and another dated the 25th of November 1758; in each of which wills he made certain provisions for the respondent, and in every one of them called her his wife, and even willed to her her said farm of Gortern and Ballybrien. That the appellant, upon the marriage of his second son John Lambert, with the daughter of Sir Henry Burke, in the year 1756, having occasion to levy a fine of some part of his estate, which was to be settled on the marriage, applied to the respondent to join in levying such fine; and in order to induce her so to do, he signed the following writing: "I do hereby assure my wife Catherine Lambert, that she shall not suffer in any shape by her levying fines for my son John Lambert. Witness my hand, September 10th, 1756, Walter Lambert. Present William Nethercott." That she accordingly joined in the said fine, as the wife of the appellant. That the appellant had, notwithstanding his agreement with the respondent, received the issues and profits of her said farm, and converted the same to his own use for upwards of ten years, which amounted to £1500, and that the respondent had, by means of the waste which the appellant had committed thereon, lost her said farm; the lives for which the same was held having dropt, and Colonel French having refused to grant a renewal thereof, which the respondent charged would be well worth to her and her children, upwards of £3000 if the same had been renewed. That the appellant was possessed of a real estate of £1500 a year, and of a personal estate to the amount of £12,000 and upwards. And the bill prayed, that the deed of the 29th of November 1762, whereby the appellant agreed to give the respondent his wife, the sum of £20 a year, by way of a separate maintenance, might be set aside; and that the appellant might be compelled to give the respondent [22] such maintenance, from the time of her separation from him, as the Court should judge reasonable to support her as his wife, and to continue as long as she should live separate from him; and that her bill should be taken as a bill of discovery, against such of the defendants as it was improper to pray relief against; and that the respondent might have such other and further relief, as the nature of her case required.

To this bill the appellant put in two answers, and admitted his agreeing in the year 1740, to discharge the arrear due to Colonel French, and the execution of the deed of the 25th of November 1740. He admitted, that he frequently called upon