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John Grenesword of Stanhope in the County of Durham Yeoman aged thirty seven years or thereabouts Sworne & examined Saith as followeth 8: To the eighth Interrogatory this Depon[en]t Saith That the Defend[an]ts Lead=Mines in the parish of Stanhope Some of them are distant from Some of his Smelt Mills fourteen Miles & Some More & Some lesse distant, And this Depon[en]t Saith that he very well knows that the Said Defend[an]t by severall of his Agents or Servants by him imployed to that purpose since February in the year One thousand Six [interlined above at this point: hundred], Seventy & Six Severall times in Severall years bought great quantities of Lead Oar In Westmorland Cumberland Yorkshire, the Countys of Durham & Northumberland which were carried to the Defend[an]ts Smelting Mills & there mixt with the Defend[an]ts own Lead:Oar gotten in the Said parish of Stanhope to make his own Oar run & smelt the better: And this Depon[en]t hath both carryd Such bought Lead=Oar to the Defend[an]ts Smelting Mills at Stanhope hope Mill & Darwen Mill & at the Said Severall Mills hath seen the Said bought Lead=Oar mixt & Smelted with the Said Defend[an]ts Lead Oar gott at his Mines in the Said parish of Stanhope, Which said Oar Soe bought by the Said Defend[an]t to mix with his own Lead=Oar as aforesaid and was soe bought at Severall Mines in the Counties aforesaid where the Said Comp[lainan]t was interested in or entitled unto [interlined above at this point : ‘that this Depon[en]t’] knows of hath heard or believes, And this Depon[en]t Saith That for above twenty years last past this Depon[en]t hath been concerned as a Lead=Oar Carryer both for the Defend[en]t & Severall other owners of Lead Mines And he knows that during all his time of Such imploym[en]t it hath been used & accustomed by Owners of Lead Mines to buy Severall great quantities of Lead Oar at other Mines to mix with the Lead Oar gott att their own Lead Mines the same was look[e]d upon to be an advantageous & p[ro]fitable course to make their own Lead=Oar Smelt to better & greater advantage & p[ro]duce greater quantities of Lead; And this Depon[en]t hath Severall times been imployed to carry Such bought Lead Oar by Severall p[er]sons as well as the Defend[an]t to mix with their own Lead =Oar for the purposes & use aforesaid 11: To the Eleventh Interrogatory this Depon[en]t Saith That he hath known it the practice & Custome for twenty years last past & upwards both by the Defend[an]t & severall other Lead Mine Owners That they have reckoned & accounted with the Miners and Oar Carryers by Tally: And a day hath been always appointed for Stateing Accounts & reckoning betwixt the Said Lead Mine Owners & their Miners & Oar=Carriers & upon Such meeting & stating their Accounts for their Severall wages, the Miners P[ro]duced their Severall Stocks of what quantities of Lead Oar were wrought & sent from each Lead Mine to the Smelting Mill & the Oar:Carryers kept the Swatch of Such quantities & upon Such Accounts Stateing they fitted and compared the Stock & Swatch of the Tally together & if they agreed then both Stock & Swatch were broken, And this Defend[an]t hath heard his father who was an ancient Oar Carryer Say that that was the ancient Custome betwixt the Miners & Oar Carriers And the reason why Such Tallies upon Such reckonings were broke was because the p[ar]ties were thereupon paid of what wages were to them respectively due from the Owners; And that being their ancient & onely Method of keeping their reckonings & accounts if the Same Should be altered & changed the Same in this Depon[en]ts Judgem[en]t would be very wrongful & mischievous & occasion many differences betwixt the Said Owners Miners & Oar:Carriers, the Miners & Oar=Carriers being usually unlearned & can neither write nor read. 13:20: To the thirteenth & twentieth Interrogatories this Depon[en]t Saith That he this Depon[en]t hath carried to all the Said three Smelting Mills belonging to the Said Defend[an]t twice or thrice each week to Some of the Same Mills or to Newcastle Severall quantities of Lead=Oar And this Depon[en]t hath observed in his carrying of Lead=Oar to the Said Scotcheal Mill that the Compl[ainan]ts Agents were sett & placed at Wolsingham & Frosterley the one place three Miles & the other one Mile distant from the same Mill to take an account of what Lead Oar the Defend[an]ts Carriers carried to the Same Mill, And this Defend[an]t Saith That Frosterley is two miles distant from the nearest of the Said Defend[an]ts Said Mines & ten Miles off the furthest Mines; And the usuall place for his Agents to take an account of what lead=Oar was brought from the Said Mines to the Said Stanhope hope Mills was about a Mile or half a Mile Sometimes from the Same Mill & distant from the nearest of the Said Lead=Mines about four Miles & from the other Mines about eight Miles, And the usuall place for taking such accounts of the Oar that was carried to Darwen Mill was Sometimes a Mile other times halfe a Mile sometimes lesse from the Same Mill, & from the nearest of the Defend[an]ts Said Mines about five or Six Miles & from the furthest fourteen Miles or thereabouts. And this Depon[en]t saith That the Said Agents very rarely asked this Depon[en]t or the Oar-Carriers with him, What they were carrying Lead Oar or Chop wood? Nor to what place they were going, Nor from what place they came: And this Depon[en]t Saith That he & Severall others, about forty or fifty horses at a time Severall times went to Newcastle with Lead=Oar from Severall Mines not belonging to the Defend[an]t And in their returnes usually went by that place where the Pl[ain]t[iff]s Agent Stood to take an account of what Lead=Oar went to Darwen=Mill & Such Agent asked this Depon[en]t & his Company if they had been at Darwen Mill & went in the night, but they returned noe answer And Such Agent usually had penn Ink & paper, & this Depon[en]t verily believes Sett down Such Carriages as if they had gone from the Defend[an]ts Said Mines to the Said Mill; And this Depon[en]t saith that he hath heard that Thomas Mowbray one of the Pl[ain]t[iff]s Agents Severall times imployed Severall p[er]sons to take an account of what number of Lead=Oar Horses went through Wolsingham And this Depon[en]t Saith That he this Depon[en]t & severall others often went through Wolsingham with their Lead=Oar to Newcastle when they carried from Mines belonging to other persons & not to the Defend[an]t And this Depon[en]t saith that the places where Such of the Pl[ain]t[iff]s Agents stood as aforesaid were Common & publick ways by which Lead=Oar was carried from other Mines besides the Defend[an]ts. And this Depon[en]t further Saith That he hath been imployed as an Oar Carrier by the Defend[en]t both of his own Oar & of Such Oar as he bought as aforesaid & p[ar]ticularly within ten years last past & in that time hath been severall times imployed to carry Lead=Oar for Severall other p[er]sons from their severall Mines on the same road or highway that the Defend[an]ts Lead=Oar was carried in to his Severall Smelt Mills And this Depon[en]t Saith in his Judgem[en]t it was not possible that the Said Compl[ainan]ts Said Agents could know which was the Defend[an]ts own Oar, which his bought Oar & which other men’s Oar which did not belong to the Said Defend[an]t, And Such Agents very seldom ask’t this Depon[en]t or his Company what they carried or from whence they brought or whither they carried their Load, Whether it was Lead Oar or not, And this Depon[en]t doth not know what other account Such Agents took of Such Carriages than by numbering Such Carriage horses Signed John J Grenesword [possibly made mark with the ‘J’]
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.