tendentious. There were two parallel legal systems, one under the aegis of the church, the other under the crown, that continuously vied for jurisdiction and power. Bracton gave samples of writs that could be used in the case of a recalcitrant Bishop who refused to produce a witness for the common law or king's court. These indicate difficulties in defining jurisdiction, as well as recalcitrance on the part of Church officials to partake in civil and common law matters outside the Church court structure. Example 1: "Henry by the grace of God, etc. to the venerable Father in Christ "B", by the same grace bishop of London, greeting. We order you to cause to come before our justices etc. at such a day, such an archdeacon, to answer [the questions proposed in] "C", with respect to such a plea [as stated above], etc. And then let this clause be added: "as to whom our sheriff of Middlesex has sent word to our aforementioned justices that the aforementioned archdeacon (or such other clerk) has refused to find pledges and has no lay fee by which he can be destrained. And have this writ [brought with you]. Witnesses signed, etc. If the bishop does nothing with regard to the king's order, let the enrolment then be as follows: 'A' offered himself on the fourth day against 'B' with respect to such a plea, and 'B' did not come, and at another time the sheriff was ordered to attach him, and the sheriff sent word that he was a clerk, etc., whereupon such a bishop was ordered to cause him to come and to send the writ, who did nothing therein. Therefore let the bishop be summoned to appear on such a day and to have there the aforementioned 'B' to answer the aforementioned 'A' as to why etc. as described in the original writ, and offer an explanation why he ignored the original order to appear." Example 2: "The king to the sheriff, greeting. Summon 'F' bishop of London by good summoners to be before the aforesaid justices on such a day, etc. And show why he did not cause him to come forward [in accord with the order in the previous writ]." Example 3: "The king to the sheriff, greeting, We order you to distrain 'F', bishop of London, by the lands that he holds in barony in your county, to