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The proceedings of the Strabolgi case are summarized in Complete Peerage. The statement In consideration of his services to England, he was summoned to their Parliament from March 14, 1322 to December 3, 1326, directed to David de Strabolgi, comiti Athol, whereby he is held to have become Baron Strathbogie in the peerage of England. is false. The only writ he ever received was on 1322, and he is now held to have beome Baron Strabolgi in 1318, for which no writ exists. SeptentrionalisPMAnderson 06:30, 27 October 2011 (UTC)[reply]