On the 23rd of the same month, O'Neill made a counter statement to the following effect: O'Cahan had no estate in the territory that was by a corruption of speech called O'Cahan's country; nor did he or any of his ancestors ever hold the said lands but as tenants at sufferance, servants and followers to the defendant and his ancestors. His grandfather Con O'Neill was seised in fee of those lands before he surrendered to Henry VIII., 'and received yearly, and had thereout, as much rents, cutting, spending and all other duties as of any other lands which he had in demesne,' within the province of Ulster and territory of Tyrone, and that after Con's surrender the territories were all re-granted with the rents, customs, duties, &c. as before. He was ready to prove that the ancestors of O'Cahan never enjoyed the premises at any time, but at the will and sufferance of O'Neill and his ancestors. A few days after, he despatched a memorial to the king setting forth his grievances, in which he stated that there were so many that sought to deprive him of the greatest part of the residue of his territory that without his majesty's special consideration he should in the end have nothing to support his 'estate' or rank. For the Lord Bishop of Derry, not content with the great living the king had bestowed upon him, sought to have the greater part of the earl's lands, to which none of his predecessors had ever laid claim. And he also set on others to question his titles which had never before before doubted. He therefore humbly besought the king to direct that new letters patent should be made out re-conveying to him and his heirs the lands in dispute, being, he said, 'such a favour as is appointed by your majesty to be extended to such of your subjects of this kingdom as should be suitors for the same, amongst whom I will during my life endeavour to deserve to be in the number of the most faithful, whereunto not only duty, but also your majesty's great bounty, hath ever obliged me.'