in Chancery at the time of Henry VI of England were required to have a pledge attached. Statute at that time prohibited the issue of a writ of subpoena until the plaintiff had found sureties to satisfy the defendant's damages if he did not prevail in his case. When the defendant appeared, both the plaintiff and his witnesses, and the defendant and any witnesses which he might produce, were examined by the Chancellor. Production of documents could be demanded via subpoena duces tecum. It has been suggested that the writ subpoena was very similar to the bill of Eyre. However, in the opinions of Professor Adams, Sir Frederick Pollock, 3rd Baronet and Professor Powicke, it is erroneous to conclude that the writ subpoena came from the Bill of Eyre. It came from Chancery. The source of the word writ, or writ subpoena has been ambiguous. The Statute of Westminster II (1285) under the section in consimili casu (in similar case), attempted to limit the number of writs that could be issued. Development prior to the writ subpoena After the quick abolition of trial by ordeal, the novel approach was to call a jury to consider the case. Some situations were not difficult. As an example, from 1221 there is the case of Thomas de la Hethe. He had been presented by the grand jury with an indictment accusing him of being an associate of a notorious felon named Howe Golightly. Thomas refused to put himself on the country (accept a jury trial). Notwithstanding this refusal, the court declined to permit him any sort of trial by ordeal, but realizing the gravity of the situation they empanelled an impressive jury of twenty-four knights. These found Thomas guilty, and therefore he was hanged. At this time, even a villain who refused jury trial might have a panel of twenty-four knights. Such a large and distinguished trial by jury consisting of twenty-four knights shows the court's apprehension at depriving a man of his right to a trial by ordeal. Another example comes from the same year, 1221. An indictment indicated that the carcass of a stolen cow was discovered in William's shed. William did not express a claim to any particular sort of trial. He did state that the cow had been placed there by his lord, so that the latter could get his land as an escheat for felony. The serjeant who