Uploaded image; transcribed on 28/04/2014
The 29th of May 1657. Ewen against prior} Examined upon the foresaid libell. '''Rp. 3us.''' '''William Barnes''' of Greenwich in the County of kent Labourer aged 56 yeares or thereabouts, sworne and examined. To the first article of the said libell hee saith and deposeth that hee well knoweth the producent Mary Ewen and the bancks and wharfe arlate, having often times wrought thereat, and saith the said Mary was and is commonly reputed owner and proprietor of the said wharfe and bancks. To the second and third articles hee saith that for severall yeares last this deponent hath at severall times seene severall lighters and lightermen or other persons in and with them take up gravell in the river of Thames neare the said wharfe and bancks, and make sundrie greate pitts or holes by such taking up gravell neare the said bancks and wharfe, some of the said pitts or holes being as hee saith foure foote deep, and other holes neare the mill wharfe some of five deep and some more and somelesse, by reason of which taking up of gravell, diverse hills have bin and are made betweene the said pitts and holes, by meanes of which said pitts, and hills, hee saith it hath bin and is dangerous for shipps, boates and other vessells to passe or come neere unto the said wharfe, all which hee knoweth having seene and taken notice thereof And saith the arlate Richard Prior hath bin said and reputed to have lighters amongst them that this deponent hath soe seene, and about Michaelmas last this deponent being at worke upon the said wharfe sawe the said Priors lighter at worke neere the same taking up ballast or gravell at the place where the said pitts and holes were made. the said lighter being then made stay of for the said dammage, and hee the said Prior coming to cleare the said lighter as his owne, and acknowledged it to be his. To the fourth and 5th hee saith that by reason of the foresaid digging and making holes and pitts by the said lighters and such as worked in or with them, the bancks of the said wharfe have broken and fallen or calved into the river, about the repaire whereof hee saith the said mris Ewens hath of late bin at much cost and charges for workemanshipp and materialls, this deponent having wrought there long about the said repaires, occasioned by the premisses, namely by the taking up gravell and making holes and pitts by lighters neare the said wharfes, and saith shee is at a continuall charge thereabouts, insoemuch that this deponent and three or foure labourers more have for their worke earned about twenty pounds a peece of her for their worke thereabout, besides what shee hath paid to other workemen and for materialls of wood and other things. To the Interrogatories. [CENTRE HEADING] To the first hee saith hee hath lived for theise thirtie yeares last at Greenwich, and hath and doth live by his labour, and favoureth the parties indifferently, and would give the victory accordingly. And otherwise hee referreth himselfe to his foregoeing deposition. To the second hee saith it hath bin usuall for lighters to take up ballast with shovells upon shelves in the River of Thames, but not allowable for them to worke with nets as of late they have used neere wharfes or bancks, as they have done as aforesaid neere the said bancks and wharfe of the producent. And otherwise hee cannot depose. To the third hee cannot answer saving as aforesaid. To the fourth and 5th hee saith that about tenn or eleaven yeeres since mris Ewens [?her GUTTER]
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