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Document 66, p 12

142 (12)
be too near the Surface of the Water, but as this Pier was in fact founded
upon Piles, the depth of the Gravel being here sufficient for that
purpose, this Alteration cannot in the Opinion of this Deponent be
considered as an Alteration for the worse, but for the better: but
all the rest of the other five Piers, are expressly shewn to be
founded upon the upper Surface of the Bed of the River, and were
so intended to be, whether the River’s depth might happen to be in
the very place where each Pier was to be sunk, a few Inches deeper
or shallower than the Measure of the depth of the Water according
to the Scale of the Plan: these were therefore founded according to
the directions and Intentions of this Deponent; though as to depth
they might a little differ from the Ground Lines of the Plan.
In short, this Deponent takes upon himself to declare, that he
does not think himself justified, for the sake of shifting any Blame,
that in this Matter may appear to rest upon him, to another; but to say
that the whole was performed as near to his Intentions, and Directions
(so far as has to this day come to his Knowledge and Belief) that
the Cause of the failure thereof, he cannot in any degree impute to
either his directions not being pursued; or to any want, or sparing
of proper Materials, Workmanship, or otherwise, on the part of the
Complainant, or his Agents; and that the whole was performed
according to this Deponent’s Knowledge and Belief, as nearly
conformable to the Agreement as the Nature of the Work would
admit of. And furthermore this Deponent had great reason to
12 believe

Note: Mr Smeaton's Replies to Interrogatories p12

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Transcribed by CTW and RMS