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Class C. Containing the names of twentythree persons, who were admitted to their freedom shortly before the election, upon claims of right by birth, marriage, or servitude, which were false and colourable.

Class D. Containing the names of twentyfour persons, who were improperly admitted to vote at the said election, having obtained their freedom on false and colourable titles, or being in other respects legally incapacitated from exercising the elective franchise.

Class E. Containing the names of thirteen persons, who ought to be struck off the poll, as having been guilty of bribery, and corrupt practices.

The petitioner also means to give evidence of acts of bribery, corruption, and undue influence, committed by the said W. C. A. or by his agents under his direction, which disable him from sitting in parlian.ent.

The following is a list of the several persons who tendered their votes for the petitioner, sir J. N. at the election, and were improperly rejected by the returning officers, as stated in the petition, with a specification of the respective rights under which they claim to be admitted, and which are more particularly set forth in the several petitions presented by them, previous to the said election, to the mayor and council of Waterford, and which votes the said petitioner claims to establish, before the select committee, to be added to the poll as good votes on his behalf.

Class F. Containing the names of thirtytwo persons, who claimed their freedom in right of birth.

Class G. Containing the names of twelve persons, who claimed their freedom in right of marriage.

Class H. Containing the names of fortythree persons, who claimed their freedom in right of apprenticeship.

The said petitioner also claims to establish, before the select committee, the votes of the four following persons, who were freemen on the corporation books previous to the said election, and as such, tendered their votes for the petitioner, at the said election, which votes were improperly rejected by the returning officers.

Class 1. The said petitioner also claims to establish, before the select committee, the vote of W. M. a freeholder, who tendered his vote for the said petitioner at the said election, but which was improperly rejected by the returning officers.

The said petitioner also means to contend, that the right of voting at the election of a representative to serve in parliament for the city of Waterford is vested in the freemen and freeholders thereof, and that the resident sons and sons-in-law of freemen of the said city, and persons who have served a regular apprenticeship within the same to freemen thereof, are of right entitled to their freedom; but that by the letter, spirit, and object of the charters of the said city, by its ancient usages and customs, and by the several statutes relating to the cities and their franchises now of force in Ireland, no person, however in other respects entitled, (save and except persons who have served a regular apprenticeship within the said city to freemen thereof), ought to claim or to be admitted to the freedom of the said city, unless at the time of

such claim or admission he is residing and inhabiting within the said city, or the liberties thereof.

The said petitioner also intends to give evidence of the partial and illegal conduct of the mayor and corporation of Waterford, in admitting the friends of the said W. C. A. to their freedom, previous to the said election, and in neglecting the claims or petitions of those rightfully entitled; and he further intends to give evidence of the several proceedings stated in his petition, taken in 'his majesty's court of king's bench in Ireland in consequence thereof, and to establish the several other allegations particularly set forth in his said petition.

List and Statement, delivered by the Sitting Member to the Petitioner, on the first Meeting of the Select Committee (a).

STATEMENT of the matters, that IV. C. A. esq. sitting member for the city of Waterford, means to insist upon, contend for, or to object to, before the select committee appointed to try and determine the merits of the petition of sir J. N. bart. complaining of an undue election and return for the said city.

That the right of voting at an election, for a member to serve in parliament for the said

§ 4.

(a) 1 Peck. 243. See 42 Geo. 3. c. 106. 47 Geo. 3. c 14.

city, is vested in the freeholders and freemen of the said city, (whether resident therein or not), duly admitted to such freedom by the mayor and common council of the said city, as of right, or by special favour, and duly sworn ; and that sons of sons-in-law of, and persons who have served regular apprenticeships of seven years, to freemen of the said city, by indenture, executed by or in the presence of the town-clerk of the said city for the time being, and entered or registered by him in the corporation books, as well non-residents as residents, are entitled to, and have, on petitioning the mayor and common council of the said city, and on performing the other requisites prescribed by the orders of the said council, a right to be admitted to the freedom of the said city; and that it has been the usage of the said corporation, from the earliest period, to admit persons of the said descriptions to the freedom of the said city, whether inhabiting or residing within the said city, or the liberties thereof, at the time of such admission or not.

That although the said sir J. N. by his petition, insists, that none are entitled to the freedom of the said city, but those who, at the time of such admission, are residing or inhabiting within the said city, or the liberties thereof; yet the said sir J. N. and his agents, in his presence, and by his authority and directions, did, at the last election for the said city, tender the votes of a great number of persons, who were admitted to the freedom of the said city, and who had never been residents, or inhabiting within the said city or liberties; and which votes were admitted at the said election, and given for the said sir J. N.

That of the several persons admitted to the freedom of the said city, on the 23d day of July last, and in such petition mentioned, some were the friends of, and voted for the said W. C. A. at the last election for the said city, and some of them were the friends of, and voted for, the petitioner, sir J. N. at the said election; and that such of the said persons so admitted to the freedom of the said city, on the said 23d day of July last, as voted for the said W. C. A. as aforesaid, had petitioned the mayor and common council of the said city to be admitted to their freedom as of right, namely, by birth, marriage, or apprenticehood respectively, and were admitted in the said rights respectively, after an investigation of their respective claims; and, on finding that they were well founded, and that the said several persons so admitted, who voted for the said W. C. A. and whose claims were so found to be just, were well qualified to vote for a member to serve in parliament for the said city, at the last election, and were not occasional voters.

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That several of the persons so admitted to their freedom, on the said 23d day of July last, and on several other days previous thereto, as of right, and who were the friends of the petitioner, sir J. N. actually voted for him on the said election, although the claims under which they obtained their freedom, as aforesaid, were not founded in fact, and were misrepresented to the said mayor and common council; to the admissibility of whose votes the said W. C.A. means to object, for their want of the qualifications set forth in their respective petitions to the mayor and common council, for their freedoms.

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