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Margaret Shale and Mary Buckley now are and for all the time of their living and inhabiting in the several towns, places and parishes of Wrexham in the county of Denbigh, Nantwich within the county and diocese of Chester, and St Martin's within the city and diocese of Chester, have been persons of very ill and profligate lives and conversations of no credit and reputation whatever in the said several towns and parishes but on the contrary have all along been looked upon and esteemed in the neighbourhood where they lived to be very lewd and debauched women and have committed and been guilty and accordingly detected of a great many dishonest practices and unfair dealings. And are now and all along have been such as may be easily persuaded and prevailed with to swear an untruth in this or any other cause and for such Margaret Shale and Mary Buckley have been and still are commonly accounted, reputed and taken to be within the said several towns and parishes of Wrexham, Nantwich and St Martin's within the said City of Chester and other places adjacent… [Peter Shale was obliged to quit employer and lodgings on account of his wife's sexual advances to other men. In Wrexham, Margaret] picked up a stranger... and prevailed upon him to carry her to a country wakes in the neighbourhood where they stayed together two or three nights and days and passed as man and wife by calling each other so and lying in the same room together… She [Margaret] all along has been and now is a great actress and manager in the plot and contrivance carried on against this party proponent [Jane Hollyman] and has been very assiduous and solicitous in finding out, procuring and spiriting up witnesses to swear against her... and particularly sometime about the commencement of this cause, Margaret rode behind the plaintiff to one Edward Edwards of Poulton about three miles from Chester to procure one Ellen Thomas there a maidservant but who had before been a servant at a public house, one Mr Harvey's in Wrexham at the time mentioned in the articles in this cause exhibited, to swear against [Jane] and thereupon offered Ellen Thomas a guinea if she would swear that she saw Isaac Hasley the saddler upon the body of the said defendant but Ellen Thomas refused the same... Before and ever since the beginning of this suit, the plaintiff and Margaret Shale have lived and been together in very suspicious and disorderly manner and Margaret Shale almost constantly every week has been seen riding behind the plaintiff from fair to fair and from market town to market town to all public diversions and meetings and at such times the plaintiff has always entertained and treated her, and at several of the inn houses in the several market towns he so carried her to, and at several other places the plaintiff has been observed to be frequently teasing, pulling and kissing Margaret Shale and has been often or once at the least caught lying down on the bed with her in a very unseemly and indecent manner and posture... Sometime after Candlemas 1729 and before Lady day 1730 or thereabouts, Mary Buckley then lodged at the house of one Joseph Rowlands in Hope street in the town of Wrexham where Ann the wife of Joseph Rowlands several times saw and caught Mary Buckley in bed with soldiers and other men and particularly with one John Pattinson a soldier quartered in the town of Wrexham who afterwards owned and acknowledged before Ann Rowlands and Thomas Evans' wife that he had lain and been naught with Mary Buckley… In case Margaret Shale and Mary Buckley have sworn and deposed that they did see Isaac Hasley lying upon the body of the defendant they have therein sworn falsely and untruly. Neither Margaret Shale nor Mary Buckley went first into the parlour or room of the house where this party proponent and Isaac Hasley were by themselves in company together the said night. For that Ellen Thomas and one Thomas Gough were the first that entered the room or parlour where the defendant and Hasley then were, after the defendant had made a noise and cried out for help or assistance to get from Isaac Hasley. And when Ellen Thomas and Thomas Gough entered the room, they found Isaac Hasley only sitting upon the bedside and the defendant laid down with her head upon the pillow and entirely disengaged from Isaac Hasley and no otherwise were they then found together... She (Jane, the defendant) on the said day walking from Bangor to Wrexham did call at the house of William Harvey in Wrexham and being pretty much wearied with her walk did there desire and accordingly did lie down upon the bed in the parlour of the said house, and during the time she was so lying down, Isaac Hasley being there a mere stranger to her did break into the room upon her and began to ruffle and tease her upon the bed and as the truth is would have gladly been naught with her but she absolutely refused to suffer him and gave him a denial and repeated the same diverse and sundry times in the hearing of Ellen Thomas and several others and at last when Isaac Hasley began to be more and more importunate with her she cried out for assistance which readily came and prevented Isaac Hasley from obtaining his desire and from committing any further rudeness by or to the defendant...
She has known Mr Robert Hollyman the plaintiff in this cause but since a little before Christmas last, when he sent for her to a house in Wrexham to discourse with her about the affair upon which she now comes as a witness, and she never knew his wife the defendant in this cause nor saw her to her remembrance before Saturday the twenty eighth day of November last, when being a glover by her trade and working with one Thomas Collinge a glover then in Wrexham and being a lodger in the house of one William Harvey at the sign of the Shoulder of Mutton in the town of Wrexham and county of Denbigh (where one Mrs Margaret Shale, the wife of Peter Shale, also lodged, and quilted petticoats, her husband, a cabinetmaker then working in Chester) Margaret Shale about eight or nine o'clock in the morning being in the kitchen of the said house called this deponent from her chamber where they lodged together to come down there to see some prisoners, that Mr Pilson had sent to jail as incendiary letter droppers, and had called there for drink in their way, and this deponent going down into the kitchen saw there a strange woman whom she did not know sitting by the fire with a mug upon a boiler aside of her, whom this deponent observing to be very loose in her dress and taking her therefore not to be a very good person whispered the said Margaret Shale who leaned upon her shoulder and saying to her what she thought of her asked her who she was, to which Mrs Shale answered that she did not know, but soon after this deponent being going up to her chamber again the said Margaret Shale stayed below, and (as she understood afterwards by her) upon the strange woman's asking her to drink with her spent her penny with her, Mrs Harvey their landlady in the meantime having taken Margaret aside and told her, the woman was one Mrs Hollyman the wife of one Robert Hollyman a gentleman. Not long after that, Margaret Shale coming upstairs to this deponent where the woman soon followed her, Margaret Shale asked her whether she was married and she answered, yes, she was to one Mr Robert Hollyman, and had two children by him. And some time after she went down into the house again, where this deponent on the same day several times afterwards saw her and particularly in the evening again she came up to Mrs Shale's room where Isaac Hasley being told by this deponent in the kitchen who was with Mrs Shale followed them and stayed there some time with them, and after they were gone thence about seven of the clock in the same evening one Mr Thomas Cooper belonging to an iron forge and Richard Davies a blacksmith and his son Robert (with whom Margaret Shale and this deponent were acquainted) coming into the house to drink and desiring them to come into the kitchen to them Mrs Harvey their landlady coming for them they did accordingly go down and sit there with them by the kitchen fire till about eleven of the clock, where when they first came Mrs Hollyman was then also sitting by the said Thomas Cooper and Isaac Hasley soon after came in to them, and this deponent observed in the time of their being there together that Mrs Hollyman all along drank to the said Isaac which made him laugh and gave this deponent and others a suspicion of her. And this deponent saith that before they parted some time (she remembers) one Mrs Jones the said Isaac's mistress coming into the house to ask Isaac whether he would come home he answered, no he would lie at Mrs Harvey's all night and accordingly Mrs Harvey said he should and ordered her maid to make a bed for him in the back parlour under Mrs Shale and this deponent's room, where he used to lie (as she said) he having some time before also lodged in the same house. And about eleven of the clock, Mr Cooper and Richard Davies parting and going away, this deponent and Mrs Shale went into their room where they had not been long, but she heard Isaac's tongue under her and both she and Mrs Shale thereupon kneeling down and looking through a hole in the boards of their room (under which was no ceiling) and the hole as she believe being as broad as her hand, she for some time saw Isaac Hasley and Mrs Hollyman together, there being a candle in the room and a cake and ale before them. Isaac there pulled and hauled Mrs Hollyman to draw her to the bed in the room insomuch that this deponent observed her breast to be open, and her cap off her head, her handkerchief from about her neck and her apron from before her, and this deponent then heard Mrs Hollyman say if he would not let her alone she would call Mrs Harvey, to which he saying, God damn him if he cared who she called he would not let her alone. She desired him to be quiet a little bit and he should after which he got her to the bed, and then going to the door and making it fast with the sheath of his knife, he put the candle out and this deponent and Mrs Shale then got off their knees. Very soon after one James Macginnis and Thomas Goff coming to the house to speak with Mrs Shale and their landlady coming for her she was prevailed upon after some time (tho' late) to go down stairs to them with the deponent with her into the kitchen where (she believes) they stayed near two hours, in which time their landlady Mrs Harvey being very uneasy at Isaac and Mrs Hollyman's being together in the room aforesaid (as Mrs Shale afterwards told this deponent Mrs Harvey who whispered with her had told her) and soon after calling this deponent and telling her so also and desiring her to go softly to the door and hearken what they were doing this deponent did accordingly do so first without a candle and hearing nothing of them brought with her a piece of paper that was put into the latch hole and show'd it them and afterwards at Mrs Harvey's request again went with a candle but found the door was not to be opened, upon which returning to the company and telling them so and Mrs Shale thereupon acquainting James Macginnis with what Mrs Harvey was uneasy at, James at Mrs Shale's request went with her to the door, Mrs Shale having a candle in her hand and this deponent, the maidservant of the house and Thomas Goff following them, and James Macginnis forcing open the door and all of them thereupon rushing in after him one after another as fast as they could, this deponent there saw Mrs Hollyman lying upon the bed upon her back with her clothes up to her breast, and Isaac Hasley with his breeches hanging down to the calves of his legs, upon her and betwixt her legs, insomuch that this deponent saw his nakedness and also saw him draw his privy member out of her body, upon which immediately Mrs Hollyman asked what they wanted but had not power to put down her clothes and cover her nakedness but Mrs Shale did it for her and Isaac then sitting upon the side of the bed with his breeches down threatened, that if he had had but one other with him he would have shewed them a narrower way out than they came in, and after some time when they could prevail with her to dress her they went all into the kitchen again and the said Isaac and Jane Hollyman with them… She believes Isaac Hasley and the defendant Hollyman were not acquainted with one another before their meeting at Mrs Harvey's on the day abovesaid, because she recollects Mrs Harvey told her that Isaac Hasley after his dinner on the same day coming into the house from his master's, one Jones a saddler, in Wrexham (as usual) to drink a mug of ale and seeing the defendant in the kitchen there asked Mrs Harvey who she was, and Mrs Harvey told him who she was. After what she has predeposed and Hasley and the defendant were come from the room or parlour where they caught them, they stayed some time with the company in the kitchen, and after some time Isaac being sleepy and desirous to lie down somewhere was directed by Mrs Harvey to go to a bed in the nigh or nearer room which was over the kitchen. Some time after that the defendant Hollyman without asking leave (as this deponent apprehended) also stealing upstairs and Mrs Harvey perceiving it bid her maidservant one Ellen Thomas go up after her for that (as she said) she would not have more mischief done betwixt them in her house. Accordingly the servant did so and not long after a child of Mrs Harvey's (which lay in her own bed in a room, to which they were to go through the room where Isaac lay) crying for some drink and the maidservant coming down, this deponent thereupon (being well acquainted with the child from her lying with the mother and it in the same bed before she lay with Mrs Shale) went up to the child and found Isaac in bed in the nearer room, the defendant Hollyman lying on Mrs Harvey's bed in the further room where the child was, whereat this respondent taking the child in her arms and carrying it with her downstairs left Mrs Hollyman and saw her not after till daylight in the morning, when this respondent being called up from sleep out of her own chamber to go a few miles out of town with Mrs Shale and the maidservant to the house of the father of the servant in Gresford (where they were before invited) she saw Mrs Hollyman was sitting again in the kitchen. And further, she knows not saving that Mrs Harvey had another younger child which lay with the servant-maid in another part of the house… She never was by the plaintiff or any other ordered or directed how and in what manner to give her evidence in this cause nor has she ever received any money, reward or promise of reward from any person whatsoever for her giving any evidence at all against the defendant in this cause, nor does she know nor did she ever hear of any plot or contrivance carried on by the plaintiff or any body else to get the defendant into other men's company and endeavour to intoxicate her with strong liquor in order to lay a complaint against her to the end that the plaintiff might obtain a divorce from her.
This deponent has known and been well acquainted with Mr Robert Hollyman the plaintiff in this cause for about fourteen or fifteen years last past, and has known the defendant Jane Hollyman (who has been reputed to be his wife for about five or six years past) for nine years past or thereabouts he believes. About nine years ago as he believes, this deponent living with Mr Robert Hughes and attorney in Wrexham as his clerk, he well remembers Jane then living with one Mr Jones the curate of Wrexham as his servant and being commonly called and known by her maiden name Jane Waters, had by report a very ill character and was said to be much addicted to drinking and her neighbours at that time thought her to be a naughty person and to be given to whoring and keeping of bad company, and since that time and her being reputed the plaintiff's wife, this deponent has seen her several times or at least once in the High Road much in drink and has heard people say that if a man would go to Bradenheath in the parish of Hanmer (where she mostly was at a reputed bad house there) he might have as much c-nt as he pleased of Mrs Jane Hollyman for six pence a time, and it is commonly now reported and has been for some time past within the parish of Wrexham and other neighbour places and parishes that Jane Hollyman some time ago did commit the crime of adultery with a journeyman saddler within the town of Wrexham and for and as an adulteress and a woman of an incontinent life and conversation she is commonly taken, had and reputed to be within the town of Wrexham and other neighbouring places… He does not know, believe nor ever heard that any plot or contrivance has been for anytime carried on by the plaintiff or any other person to get the defendant into other men's company and to endeavour to intoxicate her with strong liquors in order for to lay complaint against her and that the plaintiff might obtain a divorce from her.
She very well knows Mr Robert Hollyman the plaintiff in this cause and also the defendant Jane his wife who some years ago lived a servant with his brother Mr John Hollyman in the parish of Worthenbury where she was got with child, as was the common report, by the said Robert and he afterwards married her… Her [Harvey's] husband keeping a public house at the sign of the Shoulder of Mutton within the town of Wrexham, Jane Hollyman came there about eight or nine of the clock in the morning upon Saturday the twenty eight of November last and called for a mug of ale which this deponent gave her, not recollecting just then who she was, for that she had not seen her of seven or eight years before, upon which Jane saying to this deponent, that she believed she did not remember her and this deponent thereupon recollecting her and asking whether she was not Jenny Waters which was her maiden name, she said her name was so but that she was then Mr Robert Hollyman's wife, after which she several times came in and went out again of the house on the same day and particularly on the evening coming in pretended she was to have gone a little further to a place called [Staneey?] but that then it was too late and that she would stay all night and thereupon sitting by the kitchen fire and some other company coming in and sitting there also and amongst them Isaac Hasley a saddler who then lived in Wrexham coming also in and sitting there this deponent observed Jane having a mug of ale by her to drink to the said Isaac and both of them to laugh and leer one at another insomuch that Isaac came to this deponent aside in the kitchen and asked her who she was which she told him, upon which he answered, she's a whore, I'll warrant you, I'll have something to say to her before she goes from hence. Which this deponent told him he should not have in her house. Afterwards about ten or betwixt ten and eleven of the clock at night, the company breaking up and some of them going away and one Mrs Shale and Mary Buckley (who both lodged in this deponent's house at that time and were with the company in the kitchen before) going up to their chamber this deponent calling for a candle went with her maid with an intention to make a bed for Jane Hollyman and showed her into her chamber being an out-parlour which was under the room where Mrs Shale lodged, where Isaac following of them, this deponent spoke to her maidservant and bid her not leave them together and that she should lie with her all night, but afterwards he, Isaac, calling for a mug of ale and a cake, her said maid brought them and there came out of the room from them contrary to this deponent's order and left them there together so that while this deponent was in the kitchen and before she was aware Isaac had made fast the door and refused this deponent, calling upon him, to open it and afterwards put out the candle upon which this deponent standing by the door and listening heard him very much troubling of her and say he must and would have to do with her, it was as good for her not to talk on't, and Jane then saying she would call Mrs Harvey if he would not let her alone, he answered, he did not care who the Devil she called for he would have to do with her, upon which she bid him be easy a bit and by her soul he should, at which this deponent being very uneasy, went and desired Mrs Shale and Mary Buckley who were not in bed to come down stairs to her which they did and at the same time one James Macginnis and Thomas Gough two joiners or carpenters (she knows not whether) who were acquainted with Mrs Shale coming in to the house to speak with her and this deponent telling them what made her uneasy, James at her request broke open the door where Isaac and Jane were and James thereupon and Mrs Shale with a candle in her hand and Mary Buckley rushing into the room upon them, and this deponent also with a candle in her hand soon after following them she came time enough to see Jane Hollyman sitting as it were upon the bed with her clothes or petticoats up or lying upon her belly so that this deponent saw her naked thighs, and Isaac was then sitting upon the side of the bed and buttoning up his breeches, upon which this deponent in a passion taking hold of her and shaking her and saying if she had known she had been such a woman she should not have stayed in her house, she impudently answered this deponent, why what harm was there or there is no harm, or to that purpose… Isaac Hasley came into this respondent's house upon the twenty-eighth of November last of his own accord as he used to do to drink a mug of ale, and believes he was not acquainted with the defendant Jane Hollyman before because he was a stranger in that country and had not lived long in Wrexham, and then as she has before deposed asked this respondent who she was. He left Wrexham in the beginning of March last and she has not heard where he was since. When the defendant came into this respondent's house about eight or nine of the clock in the morning on the day aforesaid, one Betty Keswick a bakerwoman from Bangor and a neighbour of the defendant and who leaves or lights her bread at this respondent's house whilst she sells it in the town came in with her and stayed a little but not long with her. After this respondent had seen her in the indecent posture as she has before deposed and Hasley and the company were gone, she came to this respondent into her kitchen where after this respondent had talked to her a good deal of her lewd or unhandsome behaviour, she asked her whether she would go into a bed and she saying that she would not, but that she would lie down, if she pleased for an hour, this respondent ordered her then maidservant, whose christian name was Ellen to show her up into the room over the kitchen, through which this respondent afterwards going to her own chambers saw her, Jane Hollyman, lying upon the bed there in her clothes no body else being then with her that she saw… This respondent had a child that she believes that night lay with her maid servant as it used to do in another bed belonging to her servant though she did not that night see them in bed… She believes Ann Bowdell who is aunt to the defendant and also Elizabeth Keswick have asked this respondent and well before as since the commencement of this suit concerning Isaac Hasley and the defendant being together at this respondent's house on the day aforesaid and saith particularly Anne Bowdell has been several times with her upon that occasion, but this respondent never told her or any other person that the defendant called upon her or any body else to open the door of the room they were in for that Isaac would not let her (the defendant) open it, nor did the defendant call upon this respondent or any body else upon that occasion that she knows of. She has been not only by Bowdell and Keswick and also Mr Robert Hollyman himself the defendant's husband but several other persons (she believes) asked whether she had seen any acts of incontinence or indecency by the defendant and she has told them what she has before deposed and believes she may have said to some or all that she could not say whether she was a whore or not for that it was a hard matter to prove a whore, but that she was sure she was guilty of whorish actions, having caught and seen her in the manner she has before deposed… She never heard of any plots or contrivance that has been at any time carried on by the plaintiff or any body else to get the defendant into other men's company and to endeavour to intoxicate her with strong liquors in order for to lay a complaint against to the end that he might obtain a separation or divorce from her.
Was not you brought fetched or carried from Chester upon last Saturday or Sunday fortnight or what other day to the house of widow Phydeons in Shocklach? Who was it that so fetched or carried you to the said place? Did you not at that time ride behind the plaintiff Hollyman or who else? How long did you and the plaintiff or either of you stay at Widow Phydeons? Where did you and the said plaintiff Hollyman go from the house of widow Phydeons? Did not you both or one and which of you go from thence the day to Threapwood to the house of one Morgan there? Did not the plaintiff carry you then behind him? How long did you and the plaintiff or either of you stay at Morgan's house? Where did you and the plaintiff go from thence? Did not you go into Shropshire? Did not you and the plaintiff call at a public house betwixt Lappington and Blackhouseford? Where did you travel from thence, and when did you return back to Chester? Did the plaintiff or who else carry you behind him, the remaining part of the journey, and who brought you home to Chester? Where and at what houses was it you and the plaintiff lay, at the time you were so out? What was the occasion or particular business you and the plaintiff or either of you had to take such a journey?'
Upon Saturday the twenty-eighth day of November last past this deponent and her husband being then lodgers at the house of one William Harvey at the sign of the Shoulder of Mutton within the town of Wrexham in the county of Denbigh and this deponent coming from her own chamber down into the kitchen about eight or nine of the clock in the morning, saw there a woman sitting at the fire who asked her to drink with her but before she did so she was called by her landlady, the wife of William Harvey, into a buttery and there told by her that the woman was one Jane Hollyman, wife to Mr Robert Hollyman a gentleman who lived not far off, and that she was a sad creature and destroyed all that she could get. Afterwards this deponent went into the kitchen again to her and spent her penny with her, and being yet more curious to know the truth from her self of her being such a person, asked her to go up into her own chamber with her and when she was there enquired of her whether she was married and she answered that she was, to one Mr Robert Hollyman, brother to one Mr John Hollyman with whom she lived as a servant, that she had two children by him but that they did not live together because they married without consent. Afterwards the said Jane Hollyman went down stairs from this deponent's chamber and stayed in the house all the day, and about nine of the clock at night, one Mr Cooper belonging to an iron forge and Richard Davies a blacksmith and his son coming into the house to drink together (with whom this deponent and her husband were acquainted) they sent for this deponent (her husband being then at Chester) to come down to them, which she accordingly did and sat with them by the kitchen fire where Jane Hollyman also sat and Isaac Hasley a saddler of Wrexham soon after coming in and sitting also there with them this deponent observed Isaac Hasley and Jane Hollyman laugh and leer one at another and after a while this deponent sitting next the said Isaac, he whispered in her ear and asked her whether she would lend him her bed for that night for that he believed he could get that woman to lie with him there, to which this deponent, thinking that he jested, only answered that she would lend her bed to nobody. Afterwards (to wit) about eleven of the clock at night her acquaintance Mr Cooper and Davies going away, this deponent went up into her own chamber with one Mary Buckley a glover who lodged in the same house and lay with this deponent in her husband's absence, and soon after they were come there, Mary Buckley through a hole in the floor full as broad as or broader than this deponent's hand, observing a light in the parlour under her room wherein was a bed and telling this deponent that she believed somebody was coming to lie there they both one after another looked through the said hole and saw Isaac Hasler and Jane Hollyman together there having ale and cakes before them, and soon after this deponent particularly saw Isaac Harley throw Jane Hollyman upon the bed after he had put his hands into her breast and loosened her stays as far as well he could and then going to the door pulled a knife and sheath out of his pocket and therewith fastened the door and then went and blew out the candle and afterwards immediately this deponent heard Jane Hollyman say that she would call out to Mrs Harvey if he would not let her alone upon which he saying God damn him but he would do it let him call who she would, she thereto replied, if he would let her rest a while he should do it quietly. This deponent afterwards heard a great bustle and rustling of the bed but no more, and then she and Mary Buckley lying down or being about to lie down upon their own bed in their clothes (more than which they did not design that night to do, because they were to go very early in the morning to Gresford where they were invited to dine that day) and thereupon one James Macginnis and Thomas Gough two carpenters knocking at the door to enquire something of her about her husband who was then at Chester, this deponent at first refused because it was so late to go down but afterwards at the pressing instance of Mrs Harvey desiring her for God's sake to come down, did accordingly go down apprehending something more than ordinary, William Harvey her husband being then from home, and thereupon Mrs Harvey before Macginnis and Gough, Ellen Thomas her servant-maid and Mary Buckley, told this deponent that that sorry jade, meaning the said Jane Hollyman, was got with Isaac Hasley in the parlour and that the door was made upon them and that she believed they were naught together and desired this deponent and Molly Buckley to take a candle and go into the room to them if they could, for she would not for anything have such a thing in her house, upon which the said Molly Buckley did accordingly take the candle and go to the door but finding it was not to be opened and returning back and telling that there was no getting in to them, James Macginnis and Thomas Gough at the request of this deponent went with her and Mary Buckley and the maidservant to the door and James Macginnis burst the door open which they all going into the room this deponent there found Jane Hollyman lying upon the bed upon her back with all her clothes up upon her breast and covering her so as that her face was not then to be seen and Isaac Hasley upon her with his breeches down as low as they well could be upon which Isaac got off Jane and this deponent saw him take his privy member out of her body and Jane Hollyman afterwards lay in the same posture with her naked body till this deponent and Mary Buckley pulled down her clothes, after which Jane impudently asked this deponent what she wanted and Isaac Hasley threatened what he would do to her and her company for coming into them if he had had but another with him… She heard her landlady Mrs Harvey say that a bread woman came in with the defendant Jane Hollyman into her house when the defendant first came there in the morning of Saturday the twenty eighth of November last before deposed to, which breadwoman this respondent saw there at that time in the kitchen, but saith, she did not stay there long but went away immediately after drinking of a pint of ale. And this respondent saw no more of her. The defendant did not lie in any bed in the house the night after what this respondent has deposed to happened, but afterward Isaac going into a bed over the kitchen where they were, to lie and soon after upon Mrs Harvey's child crying, which lay in Mrs Harvey's own room, which they were to go through the room where Isaac lay and Mrs Harvey calling her maid whose name was Ellen Thomas to go to the child, Mrs Hollyman thereupon said she would go to it, for that she had a mind to lie down by it to sleep and accordingly did go up but soon after Mrs Harvey hearing Mrs Hollyman from the room where Isaac lay, to call to the child to be quiet sent up her maidservant to take care that Isaac and Mrs Hollyman should not go near one another any more, and some time after this respondent at Mrs Harvey's request going up stairs with her through the room where Isaac lay into Mrs Harvey's chamber saw Mrs Hollyman and the maidservant lying upon the bed wherein the child was and after that Mrs Harvey going down again and sitting up the remainder of the night herself (as this deponent also did because she was to go early in the morning abroad) charged her maidservant to stay with Mrs Hollyman there all night. And further, referring herself to what she has before deposed, she knows not to answer… Some time since Christmas last, this respondent was sent for to the sign of the Plume of Feathers in Chester, to Mr Hollyman the plaintiff in this cause and Mr Parry his proctor, and asked there by them what she knew in relation to the defendant and Isaac Hasley's being together at Mrs Harvey's house on the twenty-eighth day of November last at night, but this respondent did not then make answer or say to them that the defendant called upon anybody in the house to open the door of the room aforesaid which they were in because Isaac would not let her open it, nor did she really hear her call upon anybody to do so, but Mr Hollyman and Mr Parry did ask her whether she had seen any acts of incontinency or indecency by the defendant and she confessed to them that she had caught and seen them in an indecent manner together, but never said so much as now she has upon her examination upon oath, nor referring herself to what she has before deposed knows further to answer to this interrogatory… She never was by the plaintiff or any other ordered or directed how or in what manner to give her evidence in this cause save by Mr Parry aforesaid and all that he said to her was, that as she was to be sworn or upon her oath she must speak the truth of what she knew, and she has not received any money or reward nor promise of reward from any person for giving evidence against the defendant in this cause… She does not know nor ever heard of any plot or contrivance carried on by the plaintiff or any other to get the defendant into other men's company and endeavour to intoxicate her with strong liquors in order for laying a complaint against her that the plaintiff might obtain a divorce from her… On Saturday last was fortnight, the plaintiff Mr Hollyman coming to Chester to this respondent's husband to desire of him as he was acquainted with James Macginnis before mentioned, who they then heard was working at his trade as a carpenter in Shrewsbury to prevail upon him to come to Chester to be an evidence for him in this cause, this respondent's husband, because he could not conveniently leave his work here, consented to this respondent's going with the plaintiff there because one horse might carry them both and this respondent could as well prevail upon the said Macginnis as he could to come to be a witness, wherefore on the Sunday morning after, this respondent did ride behind the plaintiff first to widow Phithian's in Shocklach where they dined and afterwards to Threapwood to the house of one John Morgan (as she remembers) where he left this respondent for some little time and went home about a mile off (as it was said) to get some clean linen, and returning this respondent rode behind him from thence to Elsmere where they lay that night at the sign of the Crown the Postmaster's (as she remembers) and from thence on Monday morning they went forward together to Shrewsbury where they lay also at one Mr Davie's the postmaster's, at the sign of the Red Lyon, where this deponent stayed from Monday till Thursday morning she not being well. And the plaintiff upon their not finding James Macginnis at Shrewsbury went himself home on Tuesday to enquire after him at Oswestry and returning back without hearing of him on Wednesday morning, on the same day went to Whitchurch (as he told this respondent) in search of him, where not finding him also, he came the same night back to Shrewsbury, from whence the respondent rode behind him back again the next day and because of a heavy rain that happened that day they were forced again to take up at the same house in Elsmere and the next day being Friday he brought this respondent home again to Chester.