HCA 13/70 f.314r Annotate

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and free from damage by any wett soe longe as they had continued in the
same for that hee knoweth as aforesayd shee was a very tight stanch
lyter And hee alsoe saith that if the plugg of the sayd open Lyter had
bin struck or scooped out shee could not choose but have sunke and bin
covered and buried with water within lesse then fower howers space
And further to these articles hee cannot depose for that hee
was not any person imployed to goe in the sayd liter and therefore
knoweth not what passages or speeches happened betwixt the sayd
shipps company and the lytermen of the sayd lyter./

To the last hee saith his foregoeing deposition is true/

To the Interrogatories / [CENTRE HEADING]

To the first hee saith hee hath knowne the Interrogated Bolton and Mills
for these ten yeares last or thereabouts and that the said Mills is this
rendents Master and hyreth him for weekly wages to worke in his
lighters and further hee cannot answere not knowing or having heard
any such thing as is Interrogate/

To the 2 Interrogatorie hee saith hee knoweth not what agreement
was made betwixt the Interrogated Bolton and Hudson, but saith there were sent by
the sayd Mills, or the sayd Bolton in his behalfe, only one Cloase lyter belonging
to the sayd Mills which this deponent went with and laded fine goods as silkes
and the like from on board the Smirna ffactor and returned therewith to Galley key,
and an open lyter which brought Cottons therewith to Galley Key and discharged them
there, and then the lyter in which the damage Controverted happened,
before the sayd Pomeries Cloase lyter went for fyne goods, and further
hee cannot answere saving hee saith it is not the use soe farr as hee hath
observed if there bee fine goods and course goods stowed together to lade the fine
goods away in cloase lyters, before the course goods, if they be in hand
with lading coarse goods, but rather to have the fine betweene decks and make
an end of the course lading they are about And further hee cannot
depose./

To the third hee cannot answere not being one of those that was imployed
to goe with the sayd lyter and soe knoweth nothing what passages happened betweene
the sayd shipps Company and the Lytermen of the sayd lyter

To the 4th hee saith hee is noe way concerned in the lyter in question nor
the damage therein happened nor was a person intrusted with her and therefore
cannot be blamed thereabouts . and saith as before that hee is the sayd John Mills his
servant for weekly wages and further cannot answere

To