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Being drinking a pot of ale at William Marrell's house in Dalham in company with Thomas Cornwall a witness produced sworn and examined on the part and behalf of Mr Thomas Poulter in this cause some short time after Thomas Cornwall returned from Norwich in September 1721 where he had been examined as a witness there for Mr Poulter against Mr Affleck, amongst some discourse which passed between this deponent, William Marrell and Thomas Cornwall about the witnesses who went up to Norwich upon Mr Affleck's and Mr Poulter's cause, Thomas Cornwall said all the witnesses who went up at this time were forsworn, to which William Marrell replied, was you? And Thomas Cornwall said again, he had not if they had not taken his paper from him, and therefore this deponent thinks no credit ought to be given to his deposition... Mr Tison, Thomas Sleep, William Malyn, Edward Plummer, Widow Eladen, and John Graves all lived in and occupied small tenements in Dalham, when the rate libellate was made, but doth not know the yearly value of any of them nor whither they were rated since... He has heard John Graves has had money out at ale. He says he has heard that the Widow Seely had money at ale in the house.
Upon a Sunday in the evening between 7 and 8 years ago, he did see Mr William Clark, Rector of Dalham, a witness produced by Mr Poulter in this cause, with Mr York... and Mr Thomas Poulter all sitting together in Mr Poulter's hall drinking together and all three singing a very lewd and debauched song, and that he believes he is so much in Mr Poulter's interest, that he would either affirm or deny anything that should be for the interest of Mr Poulter... John Plummer, maltster, a witness produced by Mr Poulter was at the time of his production, a common swearer and a person of no veracity, and always went by the name of Tyburn Jack, and had always a dependence upon and was in the interest of Mr Poulter, was so poor, that he is since gone off and absconds for debt.
He has known the Reverend Mr William Clark, Rector of Dalham, John Plummer, maltster late churchwarden there, William Hare parish clerk and sexton, Thomas Garner Miller and Thomas Cornwall witnesses produced on the behalf of Mr Poulter for many years last past and believes them to be persons of sober lives and conversations, and of good credit and reputation, and who would not depose an untruth upon oath, upon any occasion whatsoever, but that full credit in law ought to be given to their sayings and depositions, and as such persons are commonly reputed and known by sober and grave persons, and such as are acquainted with them... He has formerly known Mr William Clark Rector of Dalham, a witness in this cause, overseen in drink, but not of late years, he doth not remember the times when or how often. He having an impediment in his speech which makes him appear to be in drink, when he has drunk very little, and can bear very little drink or strong liquor without appearing disguised, and hath as great a guard upon himself least he should drink as any person he is acquainted with.
John Plummer, maltster, a witness for Mr Poulter at and since his production and examination was a vile profligate swearing fellow, no credit being to be given to what he said or did, and was always called by the name of Tyburn Jack, very poor and had a dependence upon Mr Poulter, and is lately gone off for debt... William Hare and Thomas Cornwall, two of Mr Poulter's wintesses, are profane, swearing fellows and spend all the money they get and can spare in drinking, and Thomas Turner another of Mr Poulter's witnesses has the character of thieving and cheating in his business of a miller, by which he has lost most of his custom. He [Turner] was tithe gatherer to John Plummer, maltster, and this deponent has heard that he encroached upon the parishioners some part of their crops, that several of them forewarned him coming on to their ground. William Hare was formerly servant to Mr Poacher, and Thomas Turner was a day servant to him, and they and Thomas Cornwall are very much in the interest of Mr Poulter, and believes they would say anything that would be for the service of Mr Poulter.
He knew John Plummer, maltster, a witness produced on the behalf of Mr Poulter for many years, and lived 3 years as a tenant to him, and saith he is a wicked profane swearing person, and so little regard what he swore or said, that this deponent has heard him bid the devil take him and other curses and imprecations if he did not immediately do such and such things and in a very little while after would laugh and make a jest of what he had sworn to do, and never perform the same. He commonly went by the name of Tyburn Jack, and is lately gone off for debt and absconds from his creditors... William Hare and Thomas Cornwall two witnesses produced on the behalf of Mr Poulter are drunken profane swearing fellows, and Thomas Turner another of Mr Poulter's witnesses by his evil practices as a miller in taking unreasonable toll and changing people's corn as he has heard, hath lost most of his customers. William Hare and Thomas Turner were formerly servants to Thomas Poulter and they and Thomas Cornwall are so much devoted to Mr Poulter that he believes they would not stick to say anything which might be for his service and advantage.
He has known the Reverend Mr William Clark, Rector of Dalton, John Plummer, maltster, William Hare, Thomas Turner and Thomas Cornwall all witnesses produced on behalf of Mr Poulter in this cause for at least 16 years, and believes they are and were at the time of their several examinations as witnesses persons of sober lives and conversations, and such as would not on any account take false oaths, and that full faith and credit in law ought to be given to their depositions on oath... He was not cited but came as a witness at the request of Mr Poulter, but expects no reward or advantage by giving his testimony herein... A great many years ago he hath seen Mr Clark, Rector of Dalham, a little disguised in liquor, but can't say how long since, but for many years last past he has not seen him once fuddled. No man he knows has a greater guard upon himself against drinking, and he hath an impediment in his speech which makes him appear concerned in drink when he is not being a very small drinker of strong liquors of any kind.