HCA 13/70 f.196v Annotate

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To the first article of the sayd allegation hee saith that hee this deponent was
and is Masters Mate of the shipp the Smirna ffactor arlate, (the arlate Captaine
hudson Master) and knoweth that the goods damnified and now in Controversie
at the tyme of their delivery out of the sayd shipp into the lighter wherein they
were damnified were drye and well conditioned and soe farr as this deponent
could and did see and observe they were all free from any damage by wett and further
hee cannot to this article depose not knowing whether the arlate Mills or Bolton
or either of them or whoelse were Owners of the sayd lighter
wherewith the damage in question happened but saith hee hath heard the sayd Captaine
hudson saye that hee hired the lighters which hee used about the unladeing ofg
his sayd shipp of the arlate Boulton./

To the 2 and 3 article hee saith that after the goods controverted were
laden from on board the sayd shipp in the sayd lighter the boatswaines mate
of the sayd shipp did in thsi deponents presence and hearing tell those who had
the care and manageing of the sayd lighter that the shipps company could put noe more
goods into her by reason that divers goods laye in the way soe that noe more
could bee made ready for them at present, and willed them to goe away with
what they had if they pleased or to the like effect, but those who had the care
and charge of the sayd lighter stayed in her till towards evening and then scooped
out such water as shee had receaved and soe went ashoare and left her lying
by the sayd shipps side with the goods controverd in her, And
hee alsoe saith that in all probability by the working of the persons
belonging to the sayd lighter with their scoope in the evening the plug
in the bottome of the lighter which goeth through the same was struck out or at
least soe loosened that the water in the night tyme forced it out by
which meanes the goods controverted were wett and damnified, for this
deponent and others of the sayd shipps Company early in the morning sawe
and found that the sayd lighter was almost full of water to the great damage
of the goods in her which being perceived the sayd shipps Company did heave [?out]
the water that was in her and there found that her plugg hole was open, by
reason of which (as this deponent verily beleeveth and is perswaded in his
conscience the damage Controverted happened, And further hee cannot
depose./

To the 4th article hee saith hee cannot depose saving what he hath [?XX]
deposed to the first article of this allegation

To the 5th article hee saith hee this deponent being Masters mate as aforesayd of
the sayd shipp Smirna ffactor and on board her when the damage controverted
happened, well knoweth that after the goods controverted were unladen out of the
sayd shipp into the lighter aforesayd, hee this deponent for his part did noe
preiudice and beleeveth abd is perswaded in his conscience none Else of the sayd
shipps company did doe any preiudice to the sayd lighter or were any cause or
meanes of the dammage which happened to her and her ladeing, and well lnoweth
as afores is deposed that the persons intrusted with the mannagement of the sayd lighter
were required to goe away with the goods they had receaved, which had they done
the damage controverted had not happened as this deponent verily beleeveth And further
cannot depose./

Thomas Holgrave [SIGNATURE, RH SIDE]