Have you not seen Roger Walthew in the months and years set forth in the articles exhibited into this court against him, or in fame, one or more of the said months or years, much overtaken and disordered with drinking of strong drink, and do you not know or have you but heard it reported that the said Roger Walthew is and hath been for the time aforesaid or a great part thereof a frequenter of alehouses and an excessive drinker of strong drink?
This deponent being curate of the [illegible] and chapelry of Rainford for a year and a half in the year 1702 and [1703?] arlate, and observing that the arlate Roger Walthers neither brought his scholars to the chapel nor came thither himself on Sundays or Holydays, took occasion to speak to him of it; informed of the canon arlate and advised him to do his duty in pursuing the directions of it in bringing his scholars to the chapel and instructing them in the church catechisms, but Roger did still forbear to bring his scholars to the chapel or come thither himself. As as for the catechism, he told this deponent that if the parents of his scholars would have them learn the church catechism, he would teach it them; and he acquainted this deponent that he ordinarily or commonly taught his scholars the assembly's catechism and not the other… This deponent within the time predeposed hath frequently seen Roger Matthew overtaken or overcome with strong drink, insomuch that he has been at such times scarce able to go or stand and though this deponent hath sometimes admonished him of the crime and scandal of such his drinking to excess, yet hath he seen him relapsed into the said crime after such this deponent's admonition… This deponent doth not remember that he ever saw Roger Walther in the chapel at divine service on Sunday or Holy day, though this deponent had been instant with him to frequent the same.
This deponent hath known Roger Walthew for all the time arlate, viz. ever since he became schoolmaster of Rainford. For the later years of the time, viz. three or four years last past more particularly, he has been observed to be very negligent of his school and the neighbours who had children to send to him have very much complained... The deponent hath known Roger to absent himself for several days in the week together sometimes two sometimes three and other times four or 5 days in the same week together. Those persons who are well affected to the Church of England complain of Roger his grounding or educating the youth of the place in catechisms and principles different from those of the Church of England... At such times Roger Walthew hath addicted himself to keeping company and drinking strong drink in so much that he hath frequently seen him overcome by it and as a person stupified and besotted… In his drinking fits or times this deponent hath frequently heard him use rash vows imprecations and curses, dreadfully using God's name in vain. This deponent hath observed that the vows he so rashly made relating to himself, he generally slightly broke, neglected, or forgot so that little or no credit was given to such his imprecations… This deponent though he himself hopes he frequently went to divine service had in the chapel of Rainford since it was of late years recovered from the dissenters to the church, he never above once to the best of his memory saw Mr Walthew at divine service there. When this deponent was for years together Churchwarden of Prescot ending about 3 years ago, he does not remember (though this deponent frequented then his said parish church) that in the time he saw Roger above twice at divine service in the said church.
Roger Walthew has of late years been reputed to be much addicted to excessive drinking and to put or press into company where strong drink is to be had at an easy rate to him. This deponent hath seen him frequently overtaken with strong drink of late years and particularly remembers that about 4 years ago this deponent being constable and having occasion in the execution of his office to go to Prescot to bring his presentment to the High Constable, Roger followed this deponent and came into company where the constables were, where drinking freely he became very much overcome with strong drink and meeting with opposition or contradiction in words he fell into a passion and to profane swearing in so much that the Head Constable made him deposit 4d for swearing, and further he not depositing more money he threatened to put him in the stocks, but this deponent (he being their schoolmaster) prevailed with them to remit both the money and the punishment, but Roger persisted there in extravagant drinking and talking and though this deponent was earnest with him, he though without his hat which several times threw into the [fire?] went to several houses in the town and this deponent bringing his hat home with him left him in Prescot that night.
Within the space of 2 or years [sic], this deponent hath seen Roger Walthew within Rainford two or three several times at the least very much overcharged with strong drink as this deponent verily believes, he being [illegible] much altered in appearance from which [illegible] and talking simply and impertinently, and showing other signs [illegible] which this deponent takes to be the effects of excessive or too much drinking of strong drink. Roger is reputed to be much addicted to strong drink and for some late years of the time arlate has been so reputed in the neighbourhood.'
She hath known Roger Walthew from her childhood and saith that by some persons he is reported to be given to drink and this deponent hath seen him several times concerned so much in drink as to be hearty and the like, but she can't say that she ever saw him drunk.
She hath known Roger Walthew for several years of the time arlate and saith that he is accounted to be a man much given to drink and is much complained of for neglecting the charge of his school. She particularly remembers that the last year in Hay harvest he came one day to her master Edward Rainford's house in Rainford before noon and continued drinking ale there till night, at which time he was much overtaken with and full of drink.
He hath known Roger Walthew for all the time arlate. For about three of the last years of that time there has been great complaint against him for his neglect of the school. And this deponent hath heard and verily believes he has much neglected the school to the great prejudice of the neighbourhood. Roger is also said to be a man subject to drink and apt and easy to be drawn away from his business to drinking or good fellowship and this deponent hath seen him concerned in drink within the said time and particularly once at the house of Edward Rainford in Rainford when though this deponent cannot say that he was drunk. Yet he was so altered by drink as this deponent apprehended that he did then say and do such things as did not become him.
This deponent hath supplied or served the office of curate at Rainford since the beginning of September last, and saith that in that time he hath seen Roger Walthew several times much overtaken and overcome by strong drink. He never in the said time saw Roger at divine service or sacrament in the chapel, that by reason of Rogers absenting himself from chapel and not bringing his scholars thither as by the canon he is required, this deponent apprehends it to have been a hindrance to the propagation of religion as it is professed and promoted in the Church of England...
He hath known Roger Walthew for all the time arlate, and for about four years of that time, this deponent living in a house next to the school arlate hath had a more particular knowledge of him. For the said four years' time he hath been accounted a person much addicted to tippling and drinking, and a great and constant drinker of strong drink. This deponent hath seen him frequently in Rainford and other places much overcome with strong drink. Upon a Sunday particularly about a year and a half ago, he saw him in an alehouse in Rainford much overcome with drink as he appeared to this deponent (for he this deponent had not been of his company) he being as this deponent believes, not able to stand and scarce able to sit in the chair he was in his head and body woating or moving first one way and then another and sometimes near woating or falling out of it. This deponent was then told by some person then with him that he had been drinking either in that house or another in Rainford since Saturday (the day before) in the afternoon, and it was about two of the clock afternoon, as this deponent remembers for the time of day when he saw him.
Her husband and this deponent came to live and keep ale in Rainford since May day last and in that time she hath heard several persons complain of Roger Walthew, his great neglect of the school. He is reported to be a person much addicted to strong drink. This deponent hath seen him several times much overtaken with strong drink. She well remembers that twice the last year, both times before Christmas, he came full of drink to this deponent's husband's house and became there so overcome with strong drink that he has fallen asleep or so indisposed from strong drink that he stayed there twice all night, they leaving him overnight in his seat and finding him in the same room the next morning, from which reason, she concludes he was not well able to go to his own lodging… This deponent who frequents the chapel and the prayers and sermons there never saw Roger there at divine service. She believes he has not been so since the chapel was restored to the Church of England. She remembers that Roger once discoursing in her husband's house with a neighbour, who frequents the chapel, Roger did say and declare that he would never go again to Rainford chapel, but he would go to the parish church.
This deponent being an inhabitant in Rainford has known Roger Walthew ever since he came to be schoolmaster of Rainford. He doth not know or believe that he in all that time ever brought his scholars to the church or chapel to hear divine service and sermons... For three years last of the time arlate, Roger in this deponent's opinion has in a more than ordinary manner neglected his charge and duty in this school, absenting himself for several days together from it, for this deponent well knowing there was in the neighbourhood a common complaint against him for his negligence, and that the school was left in a miserable and scandalous disorder the boys being rude with and abusing the girls. He has often within the said three years called at the school several days together and has found him absent and the scholars in it making a noise and in great confusion. At another time in the said three years, this deponent called at the school, found Roger much overcome with strong drink, stupified and besotted in his seat, and the scholars in disorder playing on and mocking at the disorder of the Master, by which means the school which might be if governed according to the canon of greatest good advantage to the neighbourhood is fallen into a mean and scandalous condition, to the great hazard of the youth and discomfort of their parents… In the three years time, the elder of this deponent's daughters going to the school has when this deponent has enquired of her after the Master's care of it, told this deponent that she must not tell school tales, by which answer this deponent apprehends that Roger had charged the children not to acquaint their parents of his behaviour or frequent absence from the school… Roger Walthew is commonly taken to be a man much addicted to drinking of strong drink and that to excess and scandal. The deponent has frequently in the time arlate seen him drunk or overcome with strong drink and particularly for the last three years he [Roger] has been more scandalously addicted to and overcome by that crime than formerly. This deponent remembers more particularly one Sunday morning, when Mr Shardley was then in the chapel at divine service, this deponent going into an alehouse near the chapel, found Roger very much overcome with drink and in disorder from it. He offered to call for drink to give this deponent and treat him with it, but this deponent refused to drink told him he was going to the chapel and asked him if he would go with him. He answered, no, he would not go to the chapel, but he would go with this deponent to the Barn (meaning as this deponent apprehend a separate congregation, then as now in Rainford dissenting from the Church of England) if he pleased, upon which this deponent left him… This deponent never saw Roger Walthew at divine service on Sundays or holy days in the chapel since Mr Bradshaw the dissenting Minister's death and divine service had there according to the Church of England, he in this deponent's opinion not being conformable to the Church of England.
This deponent hath known Roger Walthew for all the time arlate. He saith that of late viz. about 3 years there has been great and common complaint against him in the neighbourhood... This deponent within the said later years sent three of his children to the school to him, but understanding that they made very little improvement under him, and enquiring of his children, how he managed the school, and being informed by them that he was very frequently from the school 3 or 4 days in a week and that sometimes he came to the school so much concerned in drink that he would sleep and doze after a drinking fit in the school and scarce hear them a lesson at such times, this deponent took his children from him and sent them to another Master… Roger is accounted a person much given to drinking strong drink, especially within the space of three years arlate, and this deponent hath seen him several times overtaken with drink and particularly about 2 years ago at the house of Edward Rainford in Rainford this deponent saw him in drink to a scandalous degree. This deponent saith that some of his children have told him that he sometimes come so dozed and besotted into the school, that he has not rightly understood his scholars when they said their lessons to him but has approved them sometimes when they said false, and corrected them when they have read right.
Before the time arlate when this deponent was young he went to the school of Rainford whereof Roger Walthew was schoolmaster and remembers that he did not bring his scholars to the parish church, or teach the catechism in pursuance of the canon. Yet he is not able to depose how he has discharged that his duty in the time arlate… This deponent hath seen Roger Walthew within the time arlate several times overtaken in drink and particularly the last summer in [Upholland] this deponent saw him very much overtaken or overcome with drink and drunk, at which time, he was very troublesome to the company then with him… This deponent hath been several times in Roger Walthew's company and hath at such times heard him offer to speak or repeat Latin, wherein this deponent observed that he made palpable mistakes, as to the truth of the Latin or grammar, and this deponent from thence and his former acquaintance with him believes he is meanly qualified to teach the school and that the same school is now in a very low condition as to the learning or instruction there.
This deponent hath known Roger Walthew twenty years last past, in all which time he has been accounted a careful and diligent person in the charge of his school and has given good satisfaction to the major part of the inhabitants for any thing this deponent knows to the contrary. If it happened that he was absent from the school, as this deponent believes he sometimes was so, yet he believes it was generally when he was upon the town's business or on the business of writing for some neighbours, and not only on a drinking account. This deponent believes the defendant to be of the Church of England having not seen him at one of the separate meetings except many years ago at a funeral. He is a good subject to her Majesty and sufficiently qualified to teach the school in Rainford, the salary whereof amounting only to about 6£.
This deponent hath known the defendant ever since he came to the school of Rainford and saith that several of his (this deponent's) children have been and one of them still is scholar to him. For ought this deponent knows to the contrary he has been for the time arlate and is yet well approved of by the generality of the chapelry and behaves himself as a careful master to his scholars. This deponent believes if Walthew has neglected the school or the due hours there, it has been when he has been employed about the town business or on account of doing some business for his neighbours, he having been always ready to serve them; and not for the sake of idleness or drinking. This deponent believes him to be conformable to the Church of England and good subject to her Majesty and of civil and sober conversation, sufficiently qualified for the school, and that he teaches his scholars (having particularly taught two of this deponent's sons and one daughter) the church catechism… He believes the prosecution of the defendant is chiefly occasioned by the displeasure and spite of Richard Wood, and that the majority of inhabitants and feoffees are against it… He [Robert Lyons] hath several times seen the defendant at the alehouse in the time interrogate about the town's business and at other times, but he never saw him overcome of ale so much but he understood his business.
This deponent has been acquainted with the defendant ever since he came to the school and as a scholar to him when he came first thither. This deponent saith that he has been generally for his time accounted a diligent and careful Master and has taught to the good content of the townspeople. If he sometimes omitted the hours of the school as this deponent believes he did, he believes it was generally on account of the town's business, he being much employed therein upon this deponent's more particular knowledge, he having been twice constable and once overseer of the poor in which matters he was very ready and officious. This deponent believes the defendant to be conformable to the Church of England, for that he does not join with this deponent and others in the separate congregation in Rainford. Likewise that he is a good subject to her Majesty, sufficiently qualified to teach the school at Rainford, and that he teaches good books and particularly the church catechism, this deponent having learned it of him and lately having been present when he has taught it to some of his scholars.
He well knows the defendant and was his scholar about twenty years ago. He has been for all the time esteemed in the neighbourhood a careful master in his school and has given good content to the parents of his scholars. That in case he has neglected the school and not been there at the ordinary hours (as 'tis probable he has not) this deponent believes such his absences have generally been on account of the business of the town or assisting his neighbours in his writing he being willing and ready on such occasions. This deponent believes the defendant is conformable to the Church of England, that he is a good subject to the Queen and of civil and sober conversation amongst his neighbours. He believes he is well qualified to teach the school at Rainford and that he teaches his scholars the church catechism. And this deponent says that when he was formerly his scholar he taught it this deponent… This respondent hath seen the defendant interrogate several times in the alehouse, in company, and so that this respondent could well perceive he had been drinking, but never much disordered or so that he did not understand himself and business.
This deponent hath known the defendant fifteen years and he has lived under the same roof above 2 years with this deponent. For all the former time, the defendant has been generally accounted a good and careful Master and has taught his scholars to the great satisfaction of their parents and particularly three of this deponent's children to his satisfaction. The defendant has all along been much employed in the town business and this deponent believes that if he neglected his hours at the school, it was upon account of the public business or writing for some neighbours and not for love of drinking or idleness. This deponent never saw him at the dissenting meeting nor indeed at the chapel of Rainford, but this deponent hath been with him at Billing chapel and at Prescot church and believes him to be of the Church of England and conformable to it, likewise a good subject of her Majesty, a man of civil and sober conversation, well qualified in this deponent's judgment to teach the school arlate and teaches his scholars and particularly two of this deponent's children the Church Catechism… That he believes this prosecution is chiefly occasioned from the displeasure and malice of the arlate Richard Wood... This respondent hath many times in the time arlate been with the defendant in the alehouse, and sometimes well sharpened in drink but he never saw him incapable of business or unable to go his way, but has often observed him in company to save himself by [lessening?] or missing the cup or glass in the round.
He has known Mr Walthew above twenty years and saith that he (this deponent) learned to write of him so long ago that for all that time he has been taken and accounted of as a diligent and careful master and is generally approved of by those who send their children to him. If he has neglected or omitted the school hours, this deponent believes it has for the most part been on account of the town business, he having been much employed in it, and not purely out of idleness or dispossession to drinking… This deponent believes the defendant to be a conformable person to the Church of England, for he hath seen him at Upholland, Billing and Prescot chapels and Church, but never at the separate meeting on a Lord's day. He believes he is a good subject to her Majesty and a person of sober life and conversation, and sufficiently qualified to teach the school at Rainford, and that he teaches the scholars or some of them and particularly a son of this deponent the church catechism… Upon account of a difference and law suit betwixt Richard Wood and the defendant, this deponent believes that Richard was the cause of this prosecution against the defendant, the greater number of the inhabitants of the chapelry are against the prosecution.
This deponent has known the defendant ever since he came to the school arlate and for sometime went to school to him to learn to write. For any thing he knows to the contrary, Walthew has all along carried himself in his place as a careful and diligent Master. He has been much concerned in the town business and this deponent believes he may have sometimes neglected the school hours on that account and not for the sake of drinking only. This deponent hath seen him at Holland and Billing and in Mr Sherdley's time at Rainford chapel's at divine service (but never saw him save once at a funeral at the separate meeting). That he believes him to be a good subject to her Majesty, and of civil conversation among his neighbours. He is sufficiently qualified to teach the school arlate (the salary of which amounts only to about 6£ per annum) and that he teaches his scholars and particularly 2 children a son and daughter (of this deponent) the church catechism… He believes the prosecution of the defendant proceeds from the spite and unkindness of Richard Wood, and is confident that 4 of the 5 feoffees of the school as well as the great number of the inhabitants of the chapelry are against it… This respondent not much frequenting company in alehouses has seldom seen the defendant there, except on business and then he never saw him overcome or in any incapacity of business by it. This respondent hath heard that he has too much frequented the alehouse and drinking but can't say that he did so.
He hath known the arlate Mr Walthew twenty years. He went to him so long ago to learn to write and cast accounts of him. For all that time he has behaved himself carefully in his school and has instructed his scholars well and to the satisfaction of the chapelry for any thing this deponent knows to the contrary. If he has neglected his time in the school, this deponent believes it was occasioned by the town's business, or upon account to serve the neighbours, he being ready and willing to do so upon occasion, and not for the sake of idleness and drink. This deponent believes him to be conformable to the Church of England, a loyal subject to her Majesty, and a civil and sober person, sufficiently able and qualified to teach the school there. He teaches (and particularly has taught this deponent's brother) the church catechism… There having been some difference and law suits betwixt Richard Wood and the defendant, he believes that difference has given occasion to this prosecution...
He well knows the defendant, this deponent having lived in Rainsford all his time. About twelve years ago, he went to the school arlate to the defendant, and according to this deponent's judgment, he behaved himself very carefully and diligently in his charge and has done so ever since for anything this deponent hath heard to the contrary. The inhabitants of Rainsford who send their children to him are well pleased with him. The defendant was commonly much employed in the town business and frequently called upon that account. If he was absent from the school, this deponent believes it was generally upon the affairs of the town, or upon account of serving some neighbours in their business and not of his own inclination and idleness. This deponent believes the deponent to be conformable to the Church of England and a good subject to her Majesty and a person of civil and sober life and conversation, that he is fitly qualified to teach that school, it being in a place where the inhabitants are not able to bring their children up to any considerable height in learning. In this deponent's time, the defendant taught this deponent the church catechism and believes he does so still… This deponent believes Richard Wood hath some particular disrespect and unkindness against the defendant and is the chief cause of this prosecution against him. All of the feoffees (except Richard) and also the majority of the inhabitants are against the prosecution… Though this respondent doth not much frequent company keeping in alehouses, he has seen the defendant sometimes in alehouses and then mostly upon business, viz. at townsmeetings or the like. Though he has seen him merry and cheerful yet he never saw him drunk at such times… He does not know that Mr Walthew frequents the chapel of Rainford, but hath heard and believes that he goes to divine service and sermons at other chapels or to the church of Prescot, but saith he never saw him in the Barn or separate meeting in Rainford, since it was set up.
He hath very well known Mr Walthew for fifteen years last past, in which time this deponent hath made use of him in matters of considerable moment writing of leases of tenements under this deponent's master, Robert Molyneux, Esq. and the like, in which matters Mr Walthew behaved himself very faithfully and honestly. This deponent is not personally acquainted with his behaviour in or ordering his school, but saith for anything he knows or hath heard to the contrary he has been careful and diligent in his place to the content of the neighbourhood. If he has neglected his time in or the hours at the school, it has generally been upon and of the town business or serving or writing for some neighbour or such like reasonable occasion of absence as this deponent believes… This deponent hath heard and believes that the majority of school feoffees are against the prosecution of this business against the defendant and also many of the township. Richard Wood, upon some differences about accounts and an action that was brought by the defendant against him, is the principle occasion of this prosecution against the defendant… This respondent hath indeed been much in the defendant's company upon business he employed him in and hath seen him often in the alehouse and sometimes pretty well advanced in drink. Yet not at any time so overcome with it but he was capable of understanding himself and carrying himself sensibly in company.
Above twenty years ago, this deponent being then one of the feoffees, the defendant was chosen by the majority of feoffees and inhabitants to be the schoolmaster of Rainford. The choice of him was certified to the then Bishop of Chester who thereupon granted to him a license to teach school accordingly… For anything this deponent knows to the contrary, the defendant hath all along carried himself carefully and diligently in his place as schoolmaster, and to good satisfaction as far as he could teach that being as far, in this deponent's opinion, as any of the inhabitants bring up their children. If he has neglected the school by not going to it in schooltimes or the like, this deponent believes it has been upon account of the town business, or writing for some of the neighbours, he being very kind and willing to serve his neighbours in their business when writing was concerned or useful… He well remembers there was a prosecution about the time arlate promoted by Mr Barns against the defendant in which this deponent was produced as a witness, and that the defendant was dismissed by sentence of this court… This deponent hath heard all or most of the feoffees save Richard Wood say they are for the defendant and against the prosecution of him. This deponent takes it to be the private spite or unkindness of Richard Wood that has occasioned this business against the defendant… He hath often seen the defendant in the alehouse and that pretty merry and advanced in drink, yet not so far but he understood business and was sensible of what he said and did… This respondent hath not seen the defendant at the chapel of Rainford for some years. He (this respondent) himself goes to the Barn there but he hath been credibly informed that he (Walthew) goes to Upholland, Billing, and Prescot to the Church and to divine service there.
This deponent hath known Mr Walthew about 24 years. In that time, this deponent hath sent several of his children to him, and they have improved under his instruction both in reading and writing to this deponent's satisfaction. This deponent hath heard several others of the chapelry who had children with him declare themselves also well satisfied with his teaching. For anything this deponent knows to the contrary, he has taught his scholars diligently and carefully. If he has sometimes not observed his times at school, this deponent believes it has been for the most part occasioned by his being employed in the public business of the town or sometimes in writing for or serving some neighbour. He believes Mr Walthew is conformable to the Church of England, and he hath heard that he goes to other chapels or churches though he hath heard he comes not to Rainford Chapel. This deponent believes he is and has been a good subject to her present Majesty and her late predecessors and is and has been of civil and sober conversation. This deponent believes he is competently qualified to teach school there, the endowment being but small (viz. but 6£ per annum or thereabout). Of late, though two persons who had the reputation of being better or higher scholars than the defendant set up to teach children in Rainford, yet in a short time they went off, which makes this deponent believe that such children did not improve more or as much under their direction as under the defendant's. This deponent hath heard and believes that he teaches some of his scholars (and particularly this deponent's children) the church catechism.
[7] 'He is very apt and confident to believe that Richard Wood if not the sole, is the principal cause of the present prosecution against this defendant. 4 of the 5 feoffees now living of which this deponent is one and as he verily believes the much greater majority of the inhabitants of the chapelry of Rainford are against it and for, or well...'
This deponent hath known the defendant from his youth. He lived some time formerly in Rainford and after he had lived in the chapelries of Upholland and Billington he returned to Rainford where he now lives. He, for the most part, sent his children, which were nine in all, to the defendant, who still taught and instructed them in the reading to his good satisfaction. Upon occasion of his removal to other townships, this deponent has sent some or all of his children to persons who taught children in that neighbourhood and this deponent hath observed that such children did not improve under such masters but got bad habits in their reading. Upon which he has applied himself to the defendant prevailed with him to receive his children again, and thereupon this deponent has sent them to him and he has recovered them in their learning and improved them to the great satisfaction and obligation of this deponent. And he is generally esteemed in the neighbourhood to be a careful and good master. This deponent really believes that if the defendant (as probable he might) has often neglected his school hours in teaching his scholars, it was generally at such times when he was employed about the town concerns. And not out of an idle inclination… This deponent hath seen the defendant at Holland chapel and hath heard that he frequents the chapel of Billing and the parish church of Prescot but he never saw him at the separate meeting in Rainford and is therefore of opinion that he is conformable to the Church of England. He believes him to be a good subject to her Majesty, of civil and sober conversation, sufficiently qualified to teach the youth of the place and that he has all along taught his scholars (and particularly this deponent's children) the church catechism.
This deponent was born in Rainford, near the school, has lived in Rainford ever since, and about twenty eight years ago he was a scholar to and therefore very well knows the defendant. He has been all along accounted of in the neighbourhood, a careful and diligent person in his charge, and one that had a very good way of bringing up young persons in the English tongue especially. This deponent hath known of young persons who have come from other townships and parishes to him to be fitted or improved up in that language and to learn to write, so that he generally gave good satisfaction to the parents. This deponent verily believes that if the defendant sometimes or oftener omitted his school hours, and neglected to teach the scholars, such his absences were for the most part occasioned by his attending on the town business, wherein he was often employed, or on account of serving or writing for some neighbour, wherein he was very ready and willing… This deponent believes the defendant is conformable to the Church of England having never seen him at the separate meeting in Rainford, but once or twice at a funeral, never on a sabbath day, and he has heard and believes that he frequents the chapels of Upholland and Billing and the church of Prescot, though not the chapel of Rainford. He takes him to be a good subject to her Majesty, and of a civil and sober life among his neighbours, not addicted to sottish drinking or drinking at all, but in company sufficiently qualified to teach the youth of the place (the stated salary of the school not amounting as he hath heard to 7£ per annum). He taught or heard this deponent the Church Catechism when he went to school to him as abovesaid. He believes he continues still to teach it his scholars, having been credibly informed he does so… This deponent believes this prosecution against the defendant was occasioned by some difference that happened betwixt him and Richard Woods, and that the rest of the feoffees and major party of the chapelry are against it.
This deponent hath lived above twenty years in Rainford and very well knows the defendant. Living near to some persons who sent their children to him (and this deponent having gone to several schools, some of 'em considerable within the country) he has several times taken upon him to examine some of the children, and try at distant times what improvement they made under him. This deponent, in his judgement, thought the improvement he found, on such experiments, very considerable and commendable. The defendant had been very careful in teaching them, and bringing them, not only to read the English tongue, distinctly and perfectly, but to understand, very competently, the rudiments or English rules of the Latin tongue. Walthew is generally esteemed to be a good and careful master, as far as he pretends to teach, and the neighbours seem generally to be well pleased and satisfied with his teaching… In case the defendant has sometimes neglected his school hours and to teach his scholars, this defendant believes it has been generally, on the account and for one of the town, and not upon an idle inclination to drink or neglect his school… This deponent hath heard and believes that the defendant is conformable to the Church of England, and that he frequents other chapels and the church of Prescot (but this deponent never saw him save at a funeral, and in the week days, at the separate congregation). He takes him to be a good subject to the Queen, a person of civil and sober conversation, and sufficiently qualified to teach the youth of the chapelry. This deponent hat not only been informed that he teaches his scholars the church catechism, but he hath been present in the school when the defendant has taught it or heard his scholars repeat it… This deponent believes the prosecution proceeds from the spite and malice of Richard Woods for Richard discoursing some time since, of the defendant, took occasion to say to this deponent that if he could not out the defendant from the school, he would lay him in gaol. This deponent verily believes that as well the majority of the chapelry, as the rest of the feoffees (beside Richard Wood) are against it… This respondent hath several times seen the defendant in the alehouse, but never at such a degree of drink but that he was capable of business, and was able then to walk two miles and a half in the space of an hour, as this deponent verily believes.
This deponent being of the township of Rainford hath known the defendant twenty years or thereabouts. About three years ago, one Mr Richardson, formerly the schoolmaster of Upholland being encouraged and particularly by the plaintiff Richard Woods to teaching some children privately in the chapelry of Rainford near this deponent's dwelling, this deponent sent his son to the said Richardson, and he continued to go to him about two years, other children going also; but it being observed that the children did not much improve, and that Mr Richardson did not much succeed in that way, he left the business and went off, after about 2 years' trial. Upon which, this deponent sent his son to the defendant to school, and saith that, in his opinion, he has much more improved in about 3 quarters of a year under him than in 2 years under Richardson… The defendant is much approved of in the neighbourhood and is reckoned a careful and diligent person in his charge, and able to teach children very fully and plainly in the English (and as far as he can go in the Latin) tongue… Though it be very much talked on and of in the neighbourhood by many that there was formerly a great friendship and familiarity betwixt Richard Woods and the defendant, and that the defendant had done him much service and business both at home and in Ireland (having been there on his account) yet upon some reckonings and accounts 'tis commonly believed that a difference has happened betwixt them and that that difference gave occasion of this prosecution against the said defendant. This deponent doth verily believe that not only the major part of the feoffees but of the inhabitants of the chapelry arlate are against it.
This deponent well remembers that betwixt 20 and 30 years ago as he believes for the time. Roger Walthew was upon a public meeting of feoffees of the school and inhabitants of Rainford, chosen for their schoolmaster there. His election was certified to then Bishop of Chester who granted to him his licence accordingly… For all or most of the time that the defendant has been the schoolmaster of Rainford, the children or grandchildren of this deponent have been his scholars at the said school. For any thing this deponent knows to the contrary, the defendant carried himself carefully and diligently in his place and to the content of the inhabitants, particularly to this deponent. This deponent verily believes that for the most part when the defendant neglected his hours and business at the school he was employed in the public business of the town, or on the behalf of some inhabitant at the sessions or the like… This deponent believes that all or most part of the time the defendant has been schoolmaster at Rainford he has been a person conformable to the Church of England and he the rather is of the opinion because Mr Bradshaw, who was a dissenter from the church and preached many years at Rainford Chapel, and Roger differed so much near twenty years ago, that he came not to hear him, but went to Upholland, Billing and Prescot to Church as this deponent doth verily believe, though the true and main cause of their first difference was not upon [a] point of religion but a private concern. He thinks the defendant has [been all] along a good subject to their Majesties for the time being, sufficiently qualified [to teach at] that school which is endowed only with 6 or 7£ per annum. And this [deponent hath heard] and believes that he taught and does teach the church catechism… He remembers there was such a prosecution against the defendant, wherein this deponent was a witness, and that he was dismissed by sentence of this court… This respondent hath several times seen the defendant at the alehouse, and hath seen him indeed in drink yet not so much concerned or overcome by it but he could do business. He (the deponent) lives some distance from the town and school of Rainford therefore knows not much personally of it, but hath heard the defendant hath been too much addicted to fuddling and drinking in alehouses… This respondent not frequenting the chapel of Rainford himself, but the separate meeting there, cannot depose or answer to what church or place of worship the defendant resorts.