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him Earl of Devon, and stating that he "should assume such title and style as his ancestors, Earls of Devon, had wont to do", by which he was confirmed as Earl of Devon. Although some sources consider this a new grant the wording of the grant arguably indicates a confirmation and that he became thereby 9th Earl. Historic sources thus variously refer to him as either 1st Earl or 9th Earl, and the position cannot be decided either way due to the uncertainty of the surviving evidence. For the last years of his life he thus held two titles, 1st/9th

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