And that Charles Random de Berenger, Sir Thomas Cochrane, commonly called Lord Cochrane, Andrew Cochrane Johnstone, Richard Gathorne Butt, Ralph Sandom, Alexander M'Rae, John Peter Holloway, and Henry Lyte, supposing and believing, that false reports and rumours of the death of said Napoleon Bonaparte, and of disasters and losses having recently occurred and happened to the said people of France, would induce the subjects of our said Lord the King to suppose and believe, that a peace between our said Lord the King and his subjects, and the said people of France would soon be made, and that an increase and rise in the Government Funds and Government Securities of this Kingdom, would be occasioned thereby. And unlawfully, &c. intending to injure and aggrieve the subjects of our said Lord the King, who should make purchases of and in said Funds, &c. on the 19th February, in Fifty-fourth year of the Reign of our said Lord the King, at the parish of St. Bartholomew, by the Exchange, in the Ward of Broad-street, in London aforesaid, unlawfully, &c. did conspire, &c. to make and propagate, and to cause, &c. to be made and propagated, a false report and rumour, that the French had been then lately beaten in battle, and that said Napoleon Bonaparte was killed, and that the Allies of our said Lord the King were in Paris.
And that they, the Defendants, would thereby induce the subjects of our said Lord the King to suppose and believe, that a peace would soon be made between our said Lord the King and the said people of France, and occasion an increase, &c. of the prices of the Government Funds, &c.
And that Defendants, Sir Thomas Cochrane Johnstone, Richard Gathorne Butt, and John Peter Holloway, respectively, should then sell, and cause, &c. to be sold for them, to divers liege subjects, &c. divers large parts, and shares in said Funds, &c. at higher and greater prices than said parts and shares of and in said Funds, &c. would otherwise sell for, with a wicked and fraudulent intention to thereby cheat, &c. the said subjects, &c. of divers large sums of money.
And that afterwards, to wit, on the 21st February, in the year aforesaid, at the parish and ward aforesaid, in London aforesaid, to wit, at Dover, in the county of Kent, the said Charles Random de Berenger, in pursuance, &c. of said conspiracy, did unlawfully, &c. write a certain false and counterfeit letter, containing divers false matters, which said false and counterfeit letter is directed as follows:
"To the Honorable J. Foley, Port Admiral, Deal, &c. &c. &c.
Dover, One o'Clock, A. M. February 21, 1814.
And did then and there send, and cause and procure to be sent, the said false and counterfeit letter to Thomas Foley, Esquire, at Deal; he, the said Thomas Foley, then being the Commander in Chief of His Majesty's Ships &c. employed on the Downs Station, with intention that the said T. Foley, should, by Telegraph, communicate the false matters in the said false letter, to the Commissioners of our said Lord the King, for executing the office of Lord High Admiral, &c. and that such false matters should be promulgated &c. to the liege subjects of our said Lord the King.
And that said Charles Random De Berenger, did also then and there unlawfully &c. assert and report to Timothy Wright, and other persons, that he, the said Charles Random De Berenger, had just then landed and arrived from France, and that the French were beaten, and that said Napoleon Bonaparte was killed, and that the Allies of our said Lord the King, were then in Paris; and the said Charles Random De Berenger, on same day &c. did travel from Dover towards London, and did unlawfully &c. falsely assert and report at Dartford in the County of Kent, and at other places on his way between Dover and London, the several false matters and things last mentioned, to divers other of the liege subjects of our said Lord the King with intention that the said last mentioned false matters &c. should be believed to be true, and should be generally reported, &c. by the said liege subjects, &c. to whom he asserted the same to divers other of the liege subjects, &c.
And more especially, with intention that the said false assertions &c. should reach London, to be reported and rumoured and believed there. And that on the said 21st February, at the parish &c. aforesaid, at London aforesaid, to wit, at Dartford aforesaid, the said Ralph Sandom, Alexander M'Rae and Henry Lyte, in pursuance &c. of the aforesaid conspiracy did unlawfully &c. hire and take a post chaise to go from Dartford, and did go from thence, the said Alexander M'Rae and Henry Lyte, then and there having white cockades in certain cocked hats, which they wore; and the horses drawing the said post-chaise then and there being decorated with branches of laurel, to and over London Bridge, and through the City of London, unto and over Blackfriars Bridge, and unto a certain place called the Marsh Gate, in the Parish of St. Mary Lambeth, in the County of Surry, with intention thereby to induce the liege subjects, &c. whom they should pass, and who should see them in their route and way from Dartford to near the Marsh Gate, to suppose and believe, and to report and rumour to divers other of the liege subjects, that they the said Ralph Sandom, Alexander M'Rae, and Henry Lyte, were the bearers to the Government of this kingdom, of great and important foreign news, highly favorable to the interests of our said Lord the King, and his subjects, and thereby to occasion an increase and rise in the prices of the said public Government Funds, &c. in order and for the purpose that the said Sir Thomas Cochrane, Andrew Cochrane Johnstone, Richard Gathorne Butt, and John Peter Holloway, respectively should then sell and cause and procure to be sold for them respectively to divers subjects, &c. divers large parts and shares of and in the said public Government Funds &c. at higher and greater prices than they would otherwise sell for, with a wicked and fraudulent intention, to thereby cheat and defraud the said last mentioned liege subjects, of divers large sums of money.
And that the said Defendants, in pursuance and further prosecution of said conspiracy, afterwards, to wit, on the said 21st February, did, by means of the premises aforesaid, unlawfully &c. cause and occasion a temporary increase and rise in the prices of said Funds, &c.
And the said Sir Thomas Cochrane, Andrew Cochrane Johnstone, Richard Gathorne Butt and John Peter Holloway, in pursuance and further prosecution of the aforesaid conspiracy, did on the said 21st of February, unlawfully, &c. respectively sell, and cause and procure to be sold for them respectively, unto divers subjects, &c. divers great parts and shares of and in the said public Government Funds and other Government Securities, (that is to say,) the said
Sir Thomas Cochrane L139,000 Omnium. Andrew Cochrane Johnstone L141,000 Omnium, and L100,000 Consols Richard Gathorne Butt L224,000 Omnium, and L168,000 Consols John Peter Holloway L20,000 Omnium, and L34,000 Consols
at and for greater and larger prices than such parts and shares of and in the said public and Government Funds, &c. would otherwise have sold for, with a wicked and fraudulent intention, then and there to cheat and defraud the said subjects respectively, of divers large sums of money, of the respective monies of the said last mentioned liege subjects, to the damage of the said last mentioned liege subjects, to the evil example &c. in contempt of our said Lord the King and his Laws, and against the peace of our said Lord the King, his crown and dignity.
[_Second Count._]--That the Defendants on the said 19th February, unlawfully &c. to induce the subjects &c. to believe that a peace between our said Lord the King and his Subjects and the people of France, would soon be made, and thereby to occasion an increase and rise in the prices of the public Government Funds, and other Government Securities, and to greatly injure and aggrieve the subjects of our said Lord the King, who should on the 21st February, purchase and buy a part or parts and share or shares of and in the said public Government Funds, &c. on said 19th February, with force and arms, &c. unlawfully &c. did conspire &c. together to make and propagate, and to cause and procure to be made and propagated, a false report and rumour, that the French had then lately been beaten in battle, and that said Napoleon Bonaparte was killed, and that the Allies of our said Lord the King were then in Paris.
And that they, the Defendants, would by such last mentioned false report and rumour induce the subjects, &c. to suppose and believe that a peace would soon be made, and occasion an increase and rise in the prices of the public government funds, &c.
And that Sir Thomas Cochrane, Andrew Cochrane Johnstone, Richard Gathorne Butt, and John Peter Holloway, respectively, should then sell and cause, &c. to be sold for them respectively, to divers of the liege subjects of our said Lord the King, divers other large parts and shares of and in the said government funds, &c. at higher and greater prices than said parts and shares would otherwise sell for, with a wicked and fraudulent intention to thereby cheat and defraud the said liege subjects, &c. of divers large sums of money.
And that on the said 21st of February the Defendants, in pursuance of said conspiracy, &c. unlawfully, &c. did cause and procure divers false reports and rumours to be made, spread, and circulated unto and amongst many of the liege subjects, &c. in certain parts of the counties of Kent and Surry, to wit at Dover in the said county of Kent, and in and along and near unto the King's common highway leading from Dover aforesaid to the said City of London, and also in the said City of London and parts adjacent thereto, that the French had then lately been beaten in battle, and that the said Napoleon Bonaparte was killed, and that the Allies of our said Lord the King were then in Paris. And that a peace between our said Lord the King and his subjects, and the said people of France would soon be made, with intention thereby to occasion an increase and rise in the said funds, &c. in order and for the purpose that the said Sir Thomas Cochrane, Andrew Cochrane Johnstone, Richard Gathorne Butt, and John Peter Holloway, respectively, should then sell and cause and procure to be sold for them respectively to divers liege subjects, &c. divers other large parts and shares of and in the said public government funds, &c. at higher and greater prices than they would otherwise sell for, with a wicked and fraudulent intention to thereby cheat and defraud the said subjects of divers large sum of money, &c.
[_Third Count._]--That the Defendants on the said 19th of February unlawfully, &c. by false reports, rumors, arts and contrivances to induce the subjects of our said Lord the King to believe that a peace would soon be made between our said Lord the King and his subjects, and the said people of France, and thereby to occasion without any just or true cause a great increase and rise of the public government funds, &c. and to injure, &c. the subjects of our said Lord the King who should on the said 21st of February purchase and buy any part or parts and share or shares of and in the said public government funds, &c. then and there, to wit, on the said 21st of February, unlawfully, &c. did conspire, &c. to make and propagate, and cause and procure to be made and propagated unto and amongst divers of the liege subjects, &c. in the county of Kent, to wit at Dover, Deal, and Dartford, and other places in that county, and also unto and amongst divers of the liege subjects, &c. at London aforesaid, and places adjacent thereto divers false reports and rumours that the said Napoleon Bonaparte was killed, and that a peace would soon be made between our said Lord the King and his subjects and the people of France.