To the third árticle hee saith hee this de … To the third árticle hee saith hee this deponent hath severall times seene<br />
the servants and lighter of the said Prior at worke upon the said shelve or banck<br />
and hath seene and observed then to worke fairly and orderly, as others use to<br />
doe, and have helped to ab[?a]te the said shelfe, to the better passage of<br />
shipps and boates and benefit of navigation.
To the fourth and 5th articles hee saith and deposeth that within the time arlate<br />
the arlate Mr Ewen late husband of the said Mris Ewen kept lighters of<br />
his owne, which hee imployed by his servants or lighter men oftentimes upon<br />
the said shelfe opposite this wharfe or banke, and taken up ballast at<br />
an hundred and sixteene foote distance from his wharfe or banke of this<br />
deponents sight and knowledge, who hath alsoe measured the distance;<br />
And saith the said Mr Ewen in his lifetime raised greate quantities<br />
of ballast (soe taken up by his servants and lighters) to be cast on greate<br />
heapes upon the aforesaid wharfe, where the same lay drying in readines<br />
for shipps to take the same thense, and saith the said wharfe was then<br />
old and decayed, all which hee knoweth, because hee sawe and tooke notice<br />
thereof. And hee conceiveth and beleeveth that the said weight of ballast<br />
soe lying on the said wharfe which was old and decayed, much endammaged<br />
and furthered the decay of the wharfe aforesaid. And otherwise hee cannot<br />
depose, saving that the ground was and is firme for 93 foote betweene the place where his<br />
lighters used to worke, and the place where Priors lighters used to worke<br />
Upon the sixth not exámined by direction of the producent
To the Interrogatories. CENTRE HEADING]
To the first hee saith hee hath noe relation to Priors lighters,<br />
or any of them, but is a lowe water man, and use to take<br />
up ballast as aforesaid in the said river in his owne lighter, but<br />
never in Priors lighter or lighters,<br />
Prior, nor hath any share therein, And otherwise hee cannot answer<br />
saving as aforesaid.
To the second negatively to every part.<br />
Repeated before doctor Godolphin.
the marke of TI [MARKE] To: Jones [MARKE, RH SIDE]
The first of June 1657.
Ewen con Prior.}
Exámined upon the foresaid libell.
'''William Ballow''' of Greenwich ferriman, aged 30 yeeres or<br />
thereabouts sworne and exámined.
To the first hee saith hee well knoweth mris Ewen the producent<br />
and alsoe the wharfe and banke where of hee saith shee hath bin and is commonly<br />
accounted the lawfull owner.
To the second and third árticles hee saith hee also well knoweth the arlate Richard Prior<br />
who professeth him selfe a low water man, and saith hee is commonly accounted owner<br />
of three of four lighters. And saith that<br />
in or about the moneth of October last (as hee remembreth the time) hee sawe severall<br />
lighters at worke neare the bancke and wharfe of the said Mris Ewen in taking<br />
up ballast or gravell, in which working they made severall greate pitts and holes, betwixt<br />
which pitts and holes (being some foure foote and a halfe deep other five foote, some<br />
more and some lesse) there have risen severall hillocks or hills, to the endangering<br />
of shipps and vessells in their passage that way, and the said digging and<br />
taking up ballast neere the said wharfe and bancke being to the greate endangering of<br />
the same, the said Mris Ewen caused one of the said lighters to be stopt or<br />
staid, which being soe stayed, hee saith the said Prior came and claimed and<br />
carryedr came and claimed and<br />