That the several persons tendered by the pe titioner, sir J. N. at the said election, as persons entitled to their freedom, as of right, but who were not admitted to their freedom of the said city, and whose votes were rejected by the sheriffs of the said city, (the legal returning officers at the said election), were not entitled to their freedom of the said city, as of right, or had not performed the requisites, prescribed by the usage of the said corporation, to entitle them to their freedom, and were, therefore, rightly rejected by the said sheriffs at the said election.

That, at the said election, a great number of persons who were, of right, entitled to their freedom of the said city by birth, marriage, or apprenticehood, and who had duly petitioned to be admitted, and had previously offered to perform the said usual requisites, and to pay the usual fees on such admission, tendered their votes for the said W. C. A. at the said election, to the sheriffs of the said city, who illegally rejected their votes, to the prejudice of the said W. C. A.

That all persons who tendered their votes at the said election, for the petitioner, sir J. N. and who were rejected by the said sheriffs, were fairly and duly rejected, and were not qualified to vote at the said election.

That the said sheriffs unduly and illegally rejected the votes of several freemen of the said city, at the said election, who tendered their votes for the said W. C. A. and were entitled to vote at the said election.

That the said sheriffs unduly and illegally admitted the votes of several persons, in the k k

following predicaments, at the said election, for the said sir J. N.; some of whom claimed to be, but were not really freeholders of the said city; and others of whom claimed to be, but were not really freemen of the said city; and others of whom were freeholders of the said city, but had not duly registered their freeholds; and others of whom did not produce legal certificates of qualification, although they were Roman catholics; others of whom were freemen of the said city, but who were disqua lified from voting at the said election; some by reason of minority; others by being under undue influence; others by having accepted bribes, entertainment, or rewards, from the said sir J. N. or his agents; and others of whom were Roman catholics, and did not legally qualify, or produce legal certificates of qualification; and others of whom were admitted to their freedom as of right, though not legally entitled thereto; and others who had not taken the oaths of freemen, or paid their fees, or did not produce coquets of their admission to their freedom; and the said sheriffs did, at the said election, illegally admit the votes of others, who were not freemen of the said city, but who were procured by the said sir J. N. or his agents, to personate men who were, or had been, admitted freemen of the said city; and the said sheriffs admitted two persons to vote for the said sir J. N. at the said election, who were deranged in their understandings, and not capable of exercising the elective franchise; one other person, who was an alien, and did not produce let ters of denization; and one other person, who admitted, at the time of voting, that he had not taken the oaths of a freeman, and objected to

taking the said oatlıs, and declared that he would not take them.

That peers of parliament, and persons holding high offices under his majesty's government,. and agents in the employment of government, had illegally and unconstitutionally interfered, and used undue influence in procuring, and did thereby procure several freemen of the said city to vote at the said election for the said sir J. N.; which persons would have voted for the said W. C. A. if such influence had not been exerted; and did, by threats and menaces, induce and prevail, on several freemen of the said city, holding places of profit under government, who had promised to vote, and would have voted at the said election for the said W. C. A. to decline giving their votes for him at the said election.

That the said sir J. N. is a partner in a bank, established and carried on in the said city of Waterford, for many years past, under the firm of S. N. and sons; and the said sir J. N. by himself, and his copartners and clerks in the said bank, and by his agents, procured many of the freemen of the said city to give their votes for him at the said election, some in consideration of their being freed or discharged from the payment of sums of money due by them, or for which they became security to the said bank; and others by giving or advancing money to them out of the said bank, under pretence of discounting bills of securities for such persons, which the said bankers knew to be insufficient, and the payment of which they had secretly promised to such persons not to enforce, and the payment of which the said

bankers did afterwards actually dispense with; and the said sir J. N. and his said partners, and their clerks, at and previous to the said election, used and converted the said bank to electioneering purposes.

That the said sir J. N. by himself, his said copartners in the said bank, and by his clerks and agents, after the dissolution of the last parliament, and after the issuing the writ for the said election, and previous to, and during the poll at the said election, was guilty of bribery, corruption, and undue influence, in procuring votes for himself, and in prevailing on persons to forbear to give their votes for the said W. C. A. and in attempting to corrupt and bribe those who had a right to vote, in order to procure himself to be elected and returned as member of parliament for the said city of Waterford, and was thereby disqualified from being elected or returned to serve in the present parliament, as representative for the said city; and did, by threats, menaces, and promises, procure the votes of many persons, who otherwise would have voted at the said election for the said W. C. A.; and that the said sir J. N. by himself, his friends, and agents, and persons employed by them, and by other ways and means did, after the dissolution of the said last parliament, and after the teste and issuing of the writ for holding the said election, give, present, and allow to, and provide for, divers electors of the said city, and other persons, who had or claimed a right to vote at the said election, meat, drink, entertainment, reward, and provision, in order to procure him, the said sir J. N., to be elected for the said city, contrary

to the import and spirit of the statute enacted for preventing such practices.

And therefore the said IV. C. A. insists, that he did not obtain the majority of thirty-one votes in the said petition, mentioned at the said election, by any of the undue means in the said petition mentioned; and the said W. C. A. doth object to, as unfounded, the allegations in the said petition, importing that the majority of the council of the said city, with the mayor, who presides therein, have, for several months past, been under the influence and dominion of him the said W. C. A.; or that the said council, or any of them, were induced by such influence to. commit any illegal or unwarrantable acts, in order to procure the return of the said W. C. A. on the said election; or that the said council did any of the illegal or unwarrantable acts charged by the said petitioner, for any of the purposes, or with any of the views in the said petition alledged, or for any purpose whatsoever; or that the said sheriff did, on the said election, admit any illegal vote whatever for the said W. C. A. or rejected any legal vote tendered for the said sir J. N.; or that the said W. C. A., or his agents, at any time before, or during the said election, was guilty of bribery, corruption, entertainment, or undue influence; or that the said W. C. A. did pervert the powers or patronage of the said corporation for election purposes, in order to procure his return on the said election; but, on the contrary, the said W. C. A. relies, and humbly submits, that being elected by a majority of legal voters, duly qualified, he was legally entitled to be returned, and was duly elected and returned to serve as