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Thomas Richardson of Crooked Oak in the County of Northumberland Yeoman aged fifty three years or thereabouts Sworne & examined Saith as followeth. 1: To the first Interrogatory the Depon[en]t Saith That he knows the parties Compl[ainan]t & Defend[en]t in this suit & the parishes of Stanhope & Wolsingham in this Interrogatory menconed & hath known them for Severall years last past. 2: To the Second Interrogatory this Depon[en]t Saith That Severall of the Defend[en]t’s Groves & Lead Mines Viz. Kilhope head & others Lye distant from Darwin & Scotcheale Mills which are the Defend[en]ts Smelting Mills of their Leade Oar about fifteen or Sixteen Miles. & Some of the same Mines are Eight or Nine Miles distant from the nearest of the Defend[en]ts Smelting Mills And this Depon[en]t Saith That the Said Defend[en]t Mr Wharton by his Agents betwixt February in the year of our Lord One thousand Six hundred Seventy & Six until within the two years last past, bought Severall quantities of Lead=Oar in Northumberland Cumberland & Yorkshire at Severall Leadmines in the Said Severall Counties none of which Lead-Mines are holden of the Said Compl[ainan]t; And this Depon[en]t Saith ~//~// that in that time he this Depon[en]t was imployed p[ar]ticularly to buy severall quantities of Lead Oar in Northumberland by & for the Said Defend[en]t within the time aforesaid and this Depon[en]t hath paid One hundred pounds at a time for Lead Oar which in that time he bought in Northumberland & at Severall times Severall other Summes All which great quantities of Oar was mixt with Lead Oar which was wrought & gotten in the Defend[en]ts Mines in the p[ar]ish of Stanhope, And this Depon[en]t alsoe bought severall great quantities of Cuttings or Sparr of Lead Oar which alsoe was mixt amongst the Said Defend[en]ts Lead Oar which was brought from Stanhope parish and were Smelted at the Defend[en]ts Mill called Darwin Mill to make the Defend[en]ts own Oar run the better & without which the Defend[en]ts own Lead Oar gotten in Stanhope parishwould not have smelted & run to that advantage: And this Depon[en]t Saith that for about fourteen years last past this Depon[en]t hath been imployed as Agent & Servant for the Said Defend[an]t Humphrey Wharton at the Said Darwin Mill to & where this Depon[en]t did take an Account of all Oar that was brought to the Same Mill to Smelt, as well what quantities were brought from the Defend[en]ts Mines & Groves in Stanhope parish as the quantities bought att & brought in that time from Cumberland Yorkshire and Northumberland to mix with the Said Defend[en]ts Stanhope parish Lead Oar And this Depon[en]t Saith that it is very usuall & customary with Owners of Lead Mines to buy Severall great quantities of Lead Oar at other Mines to mix with their own to make their own Smelt & run the better which hath been by experience found to be a very profitable & advantageous course. 9: To the Nineth Interrogatory this Depon[en]t Saith That the Defend[an]ts Oar in the parish of Stanhope Since the month of February In the Said year One thousand Six hundred Seventy & Six hath been usually worth betwixt Seventeen Shillings & Eighteen Shillings a Bing and each bing contains four horse Loads and the usuall weight is fourteen stone to each horse Load & oftentimes less weight & often times soe ill washed that the Agents of the Said Defend[en]t at his Mills are forced to wash the same over again; And the Defend[en]ts Oar brought to the Said Darwen Mill from the Said Stanhope parish betwixt the Said month of February of the year One thousand Six hundred Eighty & four was a very bad sort of Oar & p[ro]duced small quantities of Lead insomuch that the workmen or Miners that wrought & digged the Same at Soe much a Bing were forced to abate of their wages for bad washed Oar, And this Depon[en]t Saith that in that time he paid for Oar bought for the Defend[an]ts use at other Mines twenty four Shillings a Bing & two Shillings a Bing loading to the Said Darwen Mill which is three Shillings fourpence per Bing cheaper in carrying to the Said Darwen Mill, then some part of the Defend[an]ts own Stanhope parish Oar, & Sixteen pence less p[er] bing then the other got of the Same Stanhope parish Oar cost bringing to the Said Darwen Mill, And the said bought Oar was sixteen <Stone> & betwixt seven & ten pounds there to each horse Load. 11: To the Eleventh Interrogatory this Depon[en]t Saith That it is & hath been for fourteen or fifteen years last past to this Depon[en]ts knowledge the common practice & usage in Accounts stating & reckoning & marking betwixt the Defend[en]t or his Agents & the Miners & Oar Carriers as well for the bought Oar as for his own Oar on Tallies, And the Miners always keep the Stock or great part of the Tally and the Oar Carryers the other part; And the usuall way is upon Accounts Stating to have a day appointed betwixt them to that purpose & then they compare the Stock & Swatch of the the Tally together to See if they agree which if they doe then the Tally is broke after the Same was fitted & compared And the reason why the Same was broken was because both the Miners & Oare Carryers were paid upon Such Account the wages that were to them severrally due from the Said Defend[en]t, Which hath been the constant practice in that case since this Defend[en]t was concernedand he hath heard & been credibly informed that was always the common practice betwixt the said Miners & Oar Carriers Without which way or method of Tally keeping betwixt the Said Miners & Oar Carriers, this Depon[en]t believes many mistakes errors & differences & mis reckonings would arise betwixt them they being most of them unlearned either to write or read. 13: To the thirteenth Interrogatory this Depon[en]t Saith That the usuall place where the Compl[ainan]ts Agents stood to take an account of what Oar came from the Defend[ent]s Stanhope parish Mines to the Said Darwen Mills was about a Mile off the Same Mill & distant from Some of the Same Mines about fourteen or fifteen miles, And this Depon[en]t hath seen Garthorne, John Hopper & others of the Said C[omplainan]ts Agents Standing at the place aforesaid, who informed this Depon[en]t that they stood there to take Such accompt of aforesaid; And this Depon[en]t saith That Severall great quantities of bought Oar as well as the Defend[en]ts own Oar came by the same place where the Said Agents stood to the Said Darwen Mill And this Depon[en[t believes the Said C[omplainan]ts Said Agents took an Account of the Said bought Oar as the Defend[en]ts own Oar & not as bought Oar soe that by that Method noe Certain accounts could be given of what was due to the C[omplainan]t for his Said Lott Oar as this Depon[en]t conceived. Thomas Richardson.
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.