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Document 72, Perfected Interrogatories, undated

161
Interrogatories for the Examination of Witnesses to be produced sworn and examined
in a certain Cause now depending and at Issue in the High Court of Chancery wherein
Henry Errington Esqr is Complainant And Gawen Aynsley John Tweddell and Bacon
William Wastell are the Defendants on the part and behalf of the Plaintiff
First Interrogatory +5Do you know the parties Complainant and Defendants in the title of these Interogatories named or any
+5and which of them and how long have you so known them or any and which of them Declare the truth of
+5the matters enquired after by this Interogatory according to the best of your knowledge Rememberance and
belief
Second +5Was you or not employed and when and by whom to make and form a Survey and Plan for the purpose of
+5making and erecting a Bridge over the River Tyne in the County of Northumberland and a Road thereto in
+5the pleadings of this Cause mentioned And did you or not form such Survey and Plan and was or not the said
+5Complainant by and under such Articles of Agreement as in the said pleadings mentioned to Build and
+5make such Bridge and Road pursuant and Agreeable to such Plan and under your directions and inspection
+5If yea whether or no did the said Complainant cause such Bridge and Road thereto to be built erected and
+5made pursuant and in every respect according to such Plan and Survey and agreeable to your directions
and your inspection and conformable to the said Articles of Agreement – Declare
Third +5Did the sd Complainant as you know or believe or not lay out and expend the Sums of Five thousand seven hundred
+5pounds and Four hundred pounds in the said Articles of Agreement before mentioned or any further or other
+5Sums of Money and to what Amount as you know or why believe in erecting and making the said
Bridge and Road – Declare
Fourth +5Was or not the said bridge after and how long after the same had been compleated thrown down by a
+5sudden and Violent Flood whether was such Accident occasioned by any defect in the said Bridge or from
+5the unusual Violence of the Flood and was there as you know or believe any real defect in the said
+5Bridge or the construction thereof And set forth the particulars of the said Accident and the occasion thereof
as you know or why believe – Declare
Fifth +5Whether or no would it be necessary in Case another Bridge was to be Built over the said River Tyne and
+5in order to make and render the same safe and secure from the like Accident as aforesaid that the same
+5should be erected and built after some other Plan than that by which the said former Bridge made by
+5the Complainant was erected and built And if yea what would be the expence of building a Bridge after
+5such other Plan And have you made or prepared any Plan and any and what Estimate of the Expence of
fulfilling the same and set forth the particulars thereof – Declare
Sixth +5Whether or no in Case another Bridge was Built over the said River according to the Plan upon which the
+5said Complainants Bridge was Built and erected it would not or might not reasonably be expected to be
+5thrown down in the Course of a few years because of the sudden and great Floods which do occasionally
appear in the said River Tyne – Declare
Last Interrogatory +5Do you know of any other Matter or Thing besides what you have already deposed which may be
+5of any benefit or Advantage to the said Complainant in this Cause If yea set forth and Declare the same
fully and at large
E King

Note: Perfected Interrogatories

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Transcribed by KS and CTW