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Christopher Lun of Allisheehouse in the county of Durham Oar carrier aged sixty years or thereabouts Sworne & examined Saith as followeth 8: To the eighth Interrogatory this Depont. Saith that he knows the Pl[ain]t[iff’]s Mines & that some of them are distant from his Mills fourteen Miles & above, And this Depont. Saith that several years Since the twelfth day of February in the yr One thousand Six hundred seventy & Six the Def[endan]t hath bought several quantities of Lead=Oar in Westmorland, Cumberland & several other places & carried the Same to his Lead Mills at Darwen, Scotsheale & Stanhope hope, & there mixed & smelted the Same with his own Oar at his Said Mills, and this Depont. help’d to carry & mix the Same. And this Depont. Saith that without Such mixture the Def[endan]t’s Oar would not have p[ro]duced & afforded Such great quantities of Lead, And this Depont. Saith that he hath been an Oar carryer for thirty years. past & upwards. & he well knows it is the common system for Owners of Lead Mines to buy Oar at other Mines & mix with their own Lead=Oar. Which they always find to be very advantageous in making their own more fruitfull & p[ro]ductive. 11: To the eleventh Interrogatory this Depont. Saith that he hath been imployed for about thirty years last past generally in the Said Def[endan]t’s work & at other mines for other persons & the usuall method of working betwixt the Def[endan]t & other Owners of Lead Mines & their Miner & Oar=carryers hath been by Tally; And the Miners keep the Stock & the Oar=Carryers the Swatch. Upon their reckoning days they compare these, & if they agree then they break them, the Owners paying them of their wages thereupon, And this hath been always the method during this Depont.s remembrance & without Such method in his Judgem’t great differences & mistakes would arise betwixt the Miners & Oar=Carriers, they generally Neither being learned to write nor read. 13:20 To the thirteenth & twentieth Interrogatories this Depont. Saith that the Def[endan]t Keakers [sic] usually stood two Miles or one Mile, or at Such distance from the Def[endan]t’s Mills to take an account of what Oar was carried to the Same Mills in the public road where other Oar=horses as well as the Def[endan]t’s were driven & in which roads the Def[endan]ts Oar=horses with bought Oar as well as the Oar that was wrought at his own Mines & Oar of Severall other [persons?] are driven & Such Keakers [sic] or Agents did not ask this Depont. or his company, what they carried, where they came, nor whither they went and their onely method of taking account this Depont. believes was onely by remembering the horses where they came by them Chr: Lunn.
Witness on behalf of Humphrey Wharton in answer to Wharton's interrogatories. See 8 Oct 1686 'Questions to witnesses' Nathaniel Crewe, interrogatories, and notes given there for background to the case.