[28]_Ibid._ [29]_Ibid._ [30]_Ibid._ [31]_Ibid._, V, 984. [32]_The Papers of Lewis Morris, Governor of the Province of New Jersey from 1738 to 1746_, ed. William A. Whitehead (New York, 1852), pp. 22-23. [33]_Ibid._, pp. 24-25. [34]_N.Y. Col. Docs._, VI, 21. [35]_Ibid._, VI, 34-35. [36]Rutherfurd, _op. cit._, pp. 127-128. Notes to the Text [1]William Hawkins was, during Zenger’s own period, probably the outstanding author of legal textbooks. Delancey’s quotations are from his _Treatise of the Pleas to the Crown_ (London, 1724), I, 192-193. [2]Henry Sacheverell, a Tory divine, attacked the Whig Ministry for not being Royalist or High Church enough. He was tried for seditious libel and found guilty (1710), but his case was instrumental in the decline of the Whigs and the rise of the Tories under Queen Anne. See G. N. Clark, _The Later Stuarts_ (Oxford, 1940), pp. 216-217. [3]Gilbert Burnet, Bishop of Salisbury, was the historian of his time as well as one of its most controversial ecclesiastico-politicians. His pastoral letter sounds innocuous enough now, but his enemies in Parliament impugned it as too Royalist and too favorable to the Dissenters (1693). See Macaulay’s _History of England_, “Fireside” ed. (Boston and New York, 1910), IV, 464-466. Bishop Burnet was the father of New York’s Governor William Burnet. [4]Thomas Brewster, one of the many printers prosecuted during the reign of Charles II, was convicted (1663) of violating the licensing laws when he published _The Phoenix, or the Solemn League and Covenant_, which defended the regicides who executed Charles I. For Chief Justice Robert Hyde’s excoriating summing up, see J. W. Willis-Bund, _A Selection of Cases from the State Trials_ (Cambridge, 1882), II, 415. [5]Sir John Holt, one of the great chief justices in the history of British law, handed down numerous important rulings on the subject of libel. See Fredrick Seaton Siebert, _Freedom of the Press in England, 1476-1776_ (Urbana, Ill., 1952), _passim_. [6]John Tutchin, publisher of the _Observator_, made broad charges of treason and corruption against the government, and was tried in a court presided over by Chief Justice Holt (1704). See Siebert, _op. cit._, p. 275. [7]William Fuller was one of the notorious impostors who abounded in England at the time of the Popish Plot. His grossly fictitious account of a sinister scheme to restore the Stuarts was exposed by the House of Commons (1692), and he was promptly arrested, prosecuted, and convicted. Macaulay has a good description of the Fuller incident, _op. cit._, pp. 280-289.