The expression <em>pie recordationis</em> suggests that Earl David of Hastings was already dead. His last known attestation is in August 1244, a treaty between Alexander II and Henry III at Newcastle (<em>CDS</em> I, no. 1654). This charter is confirmed by King Alexander, 3 July 1247 (<em>C.A. Chrs.</em>, no. 53; _Handlist_, no. 284).