HCA 13/70 f.683v Annotate

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To the second article of the sayd libell hee saith hee this deponent hath bin one of the
Company of the Imployment for these sixe or eight moneths last past during which
tyme of this deponents knowledge the arlate John Bayly hath had the command of
her as Master of her and hath bin and is coomonly Accompted both Master of her and a part Owner of
a sixteenth and two and thirtith part of her And further to this article hee cannot depose./

To the 3 hee saith hee hath often heard that shipps rideing at Anchor
either in the Thames or other River ought to have a boy at their Anchor to the end that
other shipps may the better take notice wherabout the Anchor lyes and thereby avoid
the danger of setting upon them and hath observed ever since hee hath used to goe to sea
which hath bin for these 15 yeares last past or thereabouts that shipps doe usually ride
at Anchor in any river with a boye fastned thereto and beleeveth and hath heard that if they doe ride at
Anchor without a boy they are punishable for the same and liable to make good what dammage
happeneth for want thereof And further (referring him selfe to the lawes Customes
orders and rules of this Court) hee cannot to this article depose/

To the 4th article of the sayd libell hee saith that the shipp Imployment came
first to ride at Anchor neere Execution dock upon Michaelmas day last being Satterday and
receaved the damage in question on the Wednesday at evening next following which
was the third of November last And saith hee this deponent being one of the Company
of the Imployment well observed (and beleeveth others of the sayd shipps company
did soe alsoe) that the arlate shipp the James and Martin rode there alsoe at Anchor
during the sayd tyme and longer, and during that tyme before
the dammage in question happened and alsoe the next day after the damage in
question happened had noe boye fastned to her Anchor that hee this deponent could or did discover although hee looked [?XXXX] about to discover what boyes were neere the Imployment on every side
and did in the Imployments boate helpe to underrunne the cable
of the James and Martin the say after the samage in question happened at
which tyme alsoe hee knoweth shee had noe boy fastned to her Anchor to give
any notice where it lay And further hee cannot depose./

To the 5th and 6th articles hee saith that ever since hee hath bin a seaman which is
for these 15 yeares last hee hath observed that shipps doe usually in the River of
Thames ride with their Cables crosse the river and not alonge the streame and
hath heard and beleeveth they sought soe to doe, And saith hee well remembreth
that at such tyme as the Imployment receaved the damage in question by sitting upon
the Anchor of the James and Martin, the James and Martin did not ride with her
cables a thwart as shee ought to doe, but laye moored partly watershott
and with the current of the streane And further referring him selfe to
the rules and orders arlate hee cannot depose./

To the 7th 8th 9th 10th 11th and 12th articles of the sayd libell hee saith hee this
deponent being one of the Company of the Imployment well knoweth that
upon Satterday the 29th of September last (which was the tyme othe Imployment
came first to moore neere Execution dock) her Master and Company did moore
her there neere the middle of the River betweene two other shipps there lying
and the same appeared to them, and was in all likelyhood and appearance a
convenient place and free from danger and a place where shee had (for ought appeared)
a good