avoided these problems. The result in difficult cases was almost always clear cut. Judges were spared tough decisions. 1215 was also the year of the Magna Carta. Among other things, it limited the Courts of Eyre. These were circuit riding courts of the King which were roundly feared and hated. They had a reputation for being imperious and angry. There was thought to be little mercy in the Courts of Eyre. Magna Carta limited the Courts of Eyre to visiting the same location once every seven years. Procedure on bills in Eyre and bills in Chancery The question inevitably arises: Did the writ subpoena develop in the Court of Eyre, or in the Court of Chancery? There were writs of a somewhat similar nature to be found in both courts. Bills (writs of complaints) were the method by which a litigant could make his story known in the courts of 13th and 14th century England. Because novel fact patterns frequently emerged, there was a tendency to become creative in the writing of bills of complaint and writs. Against this novelty, was a strong reaction, wanting to keep the number of writs to a minimum. An example is seen from the time of Edward II of England: in 1310–1311 John Soke, a litigant appearing in person before the Common Bench, exclaimed in great frustration, "For God's sake, can I have a writ to attaint this fraud?" Judge Stanton replied, "Make your bill and you shall have what the court can allow." This illustrates the great flexibility of the writing of writs to conform to the changing fact situations as they varied from case to case. At that time, a plaintiff who sued by bill was not liable to fail for defects in the form of a bill, provided the bill told an intelligible and consistent story. As a matter of procedure, the judge would question the plaintiff in order to bring out the cause of the complaint. Once this was accomplished, the subsequent proceeding under the bill would be carried out as if there was a legitimate writ. By the 15th century, the bill would typically pray that a subpoena should be issued to secure the appearance and examination of the defendant. At the bottom of the bill were the names of the pledges to prosecute. These were similar to the bills issued by the Court of Eyre. Those subpoenas issued