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Document 66, p 9

139 (9)
This Deponent formed his Design: which was, to lay the Bases of the Piers
upon the natural Bed of the River; be it deeper, or shallower, except the
two Piers which were respectively contiguous to the Abutments; which
being in shallow Water, these together with the Abutments themselves,
were to be founded on Piles at such depth as should appear eligible,
and necessary on Opening of the Ground: which was not done, nor in
Course could be done, till the Bargain between the Magistrates and
the Complainant Henry Errington could be ratified.
In Consequence of Proposals made by the Complainant to the
said Magistrates; the Complainant did, as this Deponent was informed,
and verily believes; enter into Articles of Agreement as in the
Pleadings mentioned; but he denies that he was ever consulted upon
the particular form, or Stipulations to be contained in the said Agreement.
On the contrary, he was very much surprized, when he was afterwards
informed, that the Complainant had become bound to the County in a
greater Sum of Money than he advised the Complainant, for the
building thereof; or than he was to receive from the County on Account
of the said Undertaking. For, though he had not then, nor ever had
any doubt of the Stability, and Permanency of the Bridge, previous
to its actual Demolition; yet it appeared to him so absurd and
unreasonable, that as the building of a Bridge appeared full as
desirable to the Magistrates, as it did to the Complainant; and from
what has been stated; must appear to every one that had a Knowledge
of the previous proceedings, as it did to this Deponent: that it was
Work of so much natural hazard, and difficulty, that it might be
considered in the Nature of a forlorn Hope this Deponent begs leave
9 to

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Note: Mr Smeaton's Replies to Interrogatories p 9

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