HCA 13/72 f.175r Annotate

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a waterman for that time, and thereby well knoweth that there hath bin
formerly a faire sandy ground betweene the staires and dock of Saint
Catherines, upon which a man might have gonne drie foote at a low
water, which was very commodious for their imployment, and for the
whole neighbourhood, but continuall riding of many vessells
there upon the said Ellis his intertenniement, being sometimes fourteene
or fifteene at a time, the ground is now sunck and filled up with mudd
and soile, (above knee deep in some places) to their greate preiudice
and hinderance, And otherwise hee cannot depose.

To the 6th hee saith that hee heard that one mr [XX]artfall and mr
Stokes seized goods at the said Ellis his house that were conveyed
thereunto out of some vessells or vessell that lay at his house wharfe
And otherwise hee cannot depose.

To the 7th hee saith that by reason of such lying of many vessells
at a time at and neare the said Jenkin Ellis his said wharf, betweene
Saint Catherines Staires and the dock, the currant of the Thames
being hindered thereby and strength of the tide broken, a greate deale
of ooze and dirt is thereby setled and contracted there, and the river
wilbe much choaked and hurt thereby in processe of time, if not
timely prevented; All which premisses hee knoweth being a
Waterman that hath for all the said time used to plie and doth plie
at the said Staires of Saint Catherines: And saith the said place where
the said vessells soe use to lie and commit the foresaid annoyances
is within the ebbing and flowing of the sea, and Jurisdiction of this
Court. And further hee deposeth not:

Morris Brigges [SIGNATURE, RH SIDE]

To the Interrogatories. [CENTRE HEADING]

To the first hee saith hee cometh to be a
witnes in this cause at the instance of Mr Russell and Mr Gdwin
(two of the producents) and that hee hath not received or bin promised
ought for his deposition, nor hath hee contributed, or is to contribute
ought towards the charges of this suite, nor hath subscribed any
petition or information against the said Ellis concerning this busines, nor
set his hand thereto.

To the second hee answereth that hee doth not conceive that about
the twentieth part of the ground betweene the said staires and dock of
Saint Catherins belongeth to the said Ellis in his wharfe or rangeth
with the same, And saith hee never saw him receive any money for
any of the said vessells their lying there, And otherwise hee cannot
answer saving as aforesaid, and saving the masters and companies
of the said billanders and vessells, soe lying at the said Ellis
his wharfe and neare thereunto have their free way and passage
to and from the streete through the said Ellis his house, they that
lie adioyning to those that lie on his immediate wharfe going over
one another to passe and repasse through his said house, which hee
would probably never suffer, unlesse they paid him for their lying
there.

Morris Briggs ]SIGNATURE, RH SIDE]