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To the 1st Interrogy - The first Interrog. requires no answer from Mr. Blackett To the 2nd Interrogy J.E. Blackett was the Agent of Sir Tho. Blackett and had the superintendence of his Mining Concerns and the control of the Accounts from the year 1777 untill his death in 1792 – JEB did not personally direct the working thereof, but took his information from the Agents who had the management of those Mines. Since the Death of Sir Thomas Blackett until the end of the year 1804 J.E.B. continued to act in the same capacity. To the 3rd Interrog: JEB saith that the Weardale Mines are held under the Bishop of Durham for the time being and that the Lessees thereof are liable to pay One Ninth part of the Ore raised or a Composition in lieu thereof to the said Bishop & in answer to the remaining part of the Interrog: begs leave to refer to his answer before given to Interrog. No. 7 – JEB does not recollect whether the Bishop of Durham enquired of him whether the Sum accepted by the late Bishop was the full value of such 1/9 th part of the Ore raised in Weardale or not. To the 4th: Interrog: JEB saith he waited upon the Bishop of Durham at the request of Sir T. Blackett to obtain a renewal of the Agreement for his 1/9 Lot Ore, but who introduced him to the said Bishop J.E.B does not recollect – J.E.B. could have informed himself of the quantity of the 1/9 Lot Ore from the Accounts for the years 1787, 1788, 1789 & 1790 but no estimate of the value thereof was ever made by J.E.B. as the quantities wrought in those years were in consequence of a favourable agreement with the late Bishop for his Lot Ore. J.E.B. did not draw any conclusion as to its value therefrom. To the 5th Interrogatory J.E.B. saith he could have informed himself of the quantity of the said 1/9th Lot Ore raised in each of the years 1787, 1788, 1789 & 1790 but as those were in consequence of the former Agreement JEB drew no conclusion therefrom; nor could he ascertain its value, inasmuch as he did not know the Price Lead Ore sold for at those times, not having ever either bought nor sold any, but begs leave to refer to his answer before given to the 11th Interrog. for the total quantity of Ore raised in each of those Years. J.E.B. did not know at the time of his interview with the Bishop what was the actual value of such 1/9 part for the reasons before given. To the 6: Interrog. JEB saith that the quantities of Ore raised from the Mines in question in this Cause since the Agreement in Sept. 1791 was entered into, are set forth in Schedule annexed to the Def[endan]ts answer. J.E.B. saith that with respect to the Profits arising from such Mines that from the Mode of carrying on the Defendants Lead Mining concerns an accurate account of the Profits arising from the Mines in question cannot be made because the Ore provided therefrom and the Ore provided from the Allendale Mines in North[umberlan]d (the private property of the Defendants) are smelted at the same Mills and no separate Accounts have been kept of the Lead produced from each. To the 7: Interrog. JEB saith that certain persons are appointed as superintendants or Managers of Agents at the Leadmines in question and that such persons have directions to report the state of the Mines quarterly, but they do not give any account of the quantities of ore raised until after the expiration of some Months in the succeeding year. The late Mr Emerson was principle [sic] Superintendent or Agent at the Waerdale Mines from the year 1786 to 1792 both inclusive, from whose reports only JEB received information as to the state of those leadmines. Lancelot Allgood was under Agent to Mr Emerson during that period. To the 8th Interrog - There were Agents & Clerks employed in keeping & adjusting the Accounts of the said Mines from the year 1787 up to the time of the interview with the Bishop – JEB saith that he doth not believe it was practicable from the mode in which the Mining Acc[oun]ts are kept for any of the Clerks or for the said JEB himself between the 17 June & 1 Sept. 1791 to have made out such an Account of the Ore raised from the said Mines & of the expenses of working the same as would have enabled him to have formed an accurate opinion of the quantity of Ore raised from the said Mines in the final Six Months of the said year 1791. JEB saith that he did not to the best of his recollection ever direct any Agent Clerk or Bookkeeper employed in or about the said Mines to make any such statement or valuation. To the 9th Interrog: JEB saith he knew very well that the Sum of £850 - // - was not the full value of the 1/9 Lot Ore during the time B[isho]p Thurlow held the See of Durham, but whether the said Bishop knew the full value of such 1/9th J.E.B. cannot set forth, but saith that it was in consequence of the favourable terms under which the late Sir T: Blackett held those Mines that he was induced to extend the workings in a greater degree than he otherwise would have done in case he had paid to the Bishop his 1/9th or Lot Ore in kind, and by which means a considerable additional quantity of Ore was produced. To the 10 Interry. J.E.B. in answer to this Interry. begs leave to refer to his answers already given to Interrogs. 12 & 13 which he conceives will fully answer it. [on reverse:] JEB’s Answers to Cross Interrogatories
Undated, but the annotation on the reverse of the final page, ‘JEB’s Answers to Cross Interrogatories’, suggest it might be dated to much the same date as the replies to the Interrogatories