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Document 71, Draft Interrogatories, undated, p 1

160 Interry for this Exam Of Witnesses to be produced sworn
and examined in a certain Cause now depending & at Issue
in the High Co of Chancery wherin Heny Errington Esqr is
Complt & Gawen Aynsley John Tweddle Bacon Wm Wastell
are the Defends on the part & behalf of the Plt
1st Interrs Do you know the parties Complt & Defts in the Title of these Interrs
named or any & which of &ym& & how long have you so known them or any
and which of them Declare the truth of the matter inquired after by this
interrogatory according To the best of your knowledge rememberance & Belief
2d Was you or not employed & when & by whom to make & form & Survey
Plan for the purpose of making & erecting a Bridge over the River Tyne
in the County of Northd & a Road thereto in the pleadings of this Cause mentd
And did you or not from form such Survey & Plan & was or not the sd Complt by
& under such Articles of Agreemts as in the sd Pleadings mentd to build
and make such Bridge & Road pursuant and agreeable to such Plan & under
your directions & Inspection If yea Wher or no did the sd Complt cause such
Bridge & Road there to be built erected & made persuant & in every respect
according to such Plan & survey & agreable to your directions & your Inspn
& conformable to ye sd Articles of Agreemt – Declare
3d Did the sd Complt as you know or bel or not, lay out & expend the Sums
of 5700L & 400L in the sd Articles of Agreemts before mentd or any further or
other Sums of money & to what amount as you know or why believe
in erecting & making the sd Bridge & road declare
4 Was or not the sd Bridge after & make? how long after the same had
been compleated, thrown down by a sudden & violent Flood. Wher was
such accident occasioned by any defect in the sd Bridge or from the
unusual Violence of the Flood & was there as you know or believe any
real Defect in the sd Bridge or the Construction there of And set forth
the particulars of the sd Accidt & the occasion there of as you know
or why bel Declare
5 Whether or know no woud it be necessary in Case anr sd Bridge was
to be built over the sd River of Tyne & in order to make & render the
same safe & secure from the like Accident as afd that the same
should be erected & built after some other Plan than that by which
the sd former Bridge made by the Complt was erected and built And if
yea what woud be the Expence of building A Bridge after such other
Plan And have you made or prepared any Plan & any & what estimate
of the Expence of fulfilling the same And Set Forth partrs thereof
6 Whether or no in case another Bridge was built over the sd River
according to the Plan upon which the sd Complt Bridge was built over
the sd River & erected it would not or might not reasonably be expected
to be thrown down in the Course of a few years Because of the sudden
& great Floods which do occasionally appear in the sd River Tyne
1 Do

Note: Draft Interrogatories, p 1

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Transcribed by KS and CTW