HCA 13/71 f.250r Annotate

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hee the better knoweth being carpenter of the sayd shipp and one
of these that hang out in roapes and workes in great perill about
fashioning the sayd Rudder and alsoe helped to work at the pumps
and sawe the Master and others of the sayd shipps company worke at the
sayd pumps And further to these articles hee cannot depose

To the 7th article the sayd allegation hee saith that the sayd first
storme being under the sayd shipp in her passage from Virginia
to London did about the 9th of the sayd moneth of ffebruary meete
with an other very violent storme which continued with great furies
till about the 12th of the same moneth and with some abatement
of the violence thereof from the sayd 12th till about the 16th of the
sayd moneth, by meanes whereof the sayd shipp being very dammified
by the former storme shee againe receaved much water into
her hold other parts of her and amongst her goods, her decks being
unavoidably seldom cleere of water not withstanding the master
and company of her afore all possible endeavour to prevent all damage
that might happen to her and her lading but the [?m]aste and timbers
of the sayd shipp were soe broken with the first stormes and the tyme soe
short betweene the sayd two stormes that what was mended after
the first storme was broken and spoiled againe by violence of
the second storme this hee deposeth for the reasons aforesayd

To the 8 and 9th articles of the sayd allegation hee saith hee being carpenter
as a foresayd well knoweth that the sayd shipp the
King of Poland was a strong staunch and sufficient shipp at the
severall tymes when shee laded the Tobacco predeposed of both
at the Bermudas and Virginia and well caulked and fitt to carrie
the sayd tobaccos or any other Merchandize of like nature and
knoweth that what dammage is happenes to sayd tobaccoe happened
not thereto by any neglect of the master and company of the sayd shipp
nor through any defect or in sufficiencies of the sayd shipp other
than what the stormes aforesayd made and occasioned, but happened
meerely by violence of the sayd stormes and by reason of the
sea water which ran over and brake into the sayd shipp and
ran amongst the sayd tobaccoe And further to these articles
hee cannot depose/

To the 10th hee saith hee knoweth that the sayd shipp did arrive with
her sayd lading of tobacco in the Port of London about the
two and twentieth day of March last and that the sayd tobacco were since unladen and
delivered out of the sayd shipp hee this deponent helping to unlade
then And further to this article he cannot depose./

To the 11th hee saith that the moneth of June 1655 and before videlicet
during the whole voyage in this shipp the arlate Thomas Allen Anthony Peniston and company
were