The term coney-catching had long been in use to define a species of fraud akin to our modern "confidence trick," or, as the French call it, the _vol à l'Americain_. Shakespeare, in the "Merry Wives of Windsor," makes Falstaff call Bardolph, Nym, and Pistol "coney-catching rascals." The fraud was then of but recent introduction. It is detailed at length by Robert Greene in his "Notable Discovery of Cozenage," published in 1591. He characterizes it as a new art. Three parties were needed to practise it, called respectively the "setter," the "verser," and the "barnacle;" their game, or victim, was the "coney." The first was the decoy, the second was a confederate who plied the coney with drink, the third came in by accident should the efforts of the others to beguile the coney into "a deceit at cards" have failed. In the end the countryman was completely despoiled. Later on there was a new nomenclature: the setter became the "beater," the tavern to which the rogues adjourned was the "bush," and the quarry was the "bird." The verser was the "retriever," the barnacle was the "pot-hunter," and the game was called "bat-fowling." Greene's exposure was supposed to have deprived the coney-catchers of a "collop of their living." But they still prospered at their nefarious practices, according to the author of the "Black Dogge." Plain symptoms of the approaching struggle between the king and the commons are to be met with in the prison records. Immediately after the meeting of the Long Parliament, orders were issued for the enlargement of many victims of Star Chamber oppression. Among them was the celebrated Prynne, author of the "Histriomatrix,"[83:1] who had lost his ears in the pillory; Burton, a clergyman, and Bastwick, a physician, who had suffered the same penalties—all came out of prison triumphant, wearing ivy and rosemary in their hats. Now Strafford was impeached and presently beheaded; Laud also was condemned. The active interference of Parliament in all affairs of State extended to the arrest of persons suspected of treasonable practices. There are many cases of imprisonment more or less arbitrary in these troubled times. Another petition may be quoted, that of Richard Overton, "a prisoner in the most contemptible gaol of Newgate," under an order of the House of Lords. Overton tells us how he was brought before that House "in a warlike manner, under pretence of a criminal fact, and called upon to answer interrogations concerning himself which he conceived to be illegal and contrary to the national rights, freedoms, and properties of the free commoners of England, confirmed to them by Magna Charta, the Petition of Right, and the Act for the Abolishment of the Star Chamber." Overton was therefore emboldened to refuse subjection to the said House. He was adjudged guilty of contempt, and committed to Newgate, where he was seemingly doomed to lie until their lordships' pleasure should be further signified, which "may be perpetual if they