He declared that for 3,000 years and upwards, he and his ancestors had been possessed of a country called 'O'Cahan's country,' lying between the river Bann and Lough Foyle, without paying any rent, or other acknowledgment thereof to O'Neill, saving that his ancestors were wont to aid O'Neill twice a year if he had need, with risings of 100 horse and 300 foot, for which O'Cahan had in return O'Neill's whole suit of apparel, the horse that he rode upon, and 100 cows in winter.

He also paid 21 cows every year in the name of _Cios'righ_, the king's rent, or the king's rent-cess.

He alleged that Queen Elizabeth had granted him his country to be held immediately from her majesty at the accustomed rent, by virtue of which he enjoyed it for one whole year without paying, or being craved payment, of any rent or duty, until the Earl of Tyrone, on his return from England, alleged that he had got O'Cahan's country by patent, from the king, who had made him vassal to Tyrone and his heirs for ever, imposing the annual payment of 100 cows, with the yearly rent of 200 l.

He had also claimed the fishing of the Bann; he preyed yearly upon other parts of his country, and drew from him his best tenants.

He therefore prayed for the protection of the lord deputy against these unjust demands and usurpations.
On the 23rd of the same month, O'Neill made a counter statement to the following effect: O'Cahan had no estate in the territory that was by a corruption of speech called O'Cahan's country; nor did he or any of his ancestors ever hold the said lands but as tenants at sufferance, servants and followers to the defendant and his ancestors.