DEPOSITION OF RIGHT HONORABLE ALEXANDER MONTGOMERY CARLISLE.
3rd April 1914.
The Right Hon. ALEXANDER MONTGOMERY CARLISLE, being duly Sworn, tertified as follows.
Examined by Mr. SCANLAN.
Q. You are a Member of the Privy Council, and your title and name are The Right Hon. Alexander Montgomery Carlisle?
Q. Where do you live?
- No. 12, Hyde Park Place, London, W.
Q. You were for some time General Manager and Chairman of the Managing Directors of the shipbuilding firm of Harland & Wolff?
- A. Yes.
Q. You retired from that position in the firm on the 30th June, 1910?
Q. I think you had been in that firm altogether for nearly forty years?
Q. You joined the firm, I think, in 1870?
Q. While you occupied the position of General Manager and Chairman of the Managing Directors, were the "Olympic" and "Titanic" in course of construction by the firm of Harland & Wolff in their shipbuilding yard at Belfast?
Q. In the course of your forty years in this shipbuilding firm, you had, I take it, practical acquaintance with shipbuilding in all its branches and details?
Q. Before you left the firm in June, 1910, had the work of construction, including the designing of those ships, been practically completed?
Q. Who was the designer of those ships?
- Lord Pirrie.
Q. What did the designing by him comprehend and include?
- The designing by the head of a firm is taking up with the owners what kind of ship they want, and arranging the length, breadth, depth, speed, and other general particulars.
Q. Which of you had to do with the working plans and drawings and the details of construction?
- I had the majority of them.
Q. Did all the working plans and drawings pass under your supervision?
Q. Had you control of all the minute work of the building of those ships in your time there?
Q. You are aware that the ships were constructed for and to the order of the petitioning Company, the Oceanic Steam Navigation Company, Limited?
Q. Had there been conferences between the heads of the shipbuilding firm and the heads of the Oceanic Company at various times in reference to the plans?
- Yes; that occurs in all ships: in that case the same as others.
Q. Had the conferences between the heads of the shipbuilding firm of Harland & Wolff and the heads of the Oceanic Company been with reference to construction of the ships and their plans and structure, decoration, fittings and equipment? Were all those things considered?
- Yes; that is the same in all cases.
Q. Was the work of construction as carried out, subject to the orders of the Oceanic Company?
- I do not think that can be answered by the word "Yes" or "No". A certain amount of it is, and a certain amount is not. Certain parts of the details they take up, but they could not take up all of them, because they were not in a position to do so.
Q. Were the plans for the ships submitted to the Directors of the Oceanic Company?
- Yes, they were submitted in all cases.
Q. Were the plans for the watertight compartments submitted to them?
- The drawings show everything. I could not positively say that the bulkheads were, any more than everything else, on the plan.
If we are going to have contents of plans, I think it is necessary that we should have the plans produced, and anything which is relied upon pointed out.
I have no plans.
I am on the general question of the privity and submission of the plans.
We must have proof.
I have no plans, and I have no power to get any plans.
I am going to submit some plans in a moment, given to us by the representatives of the petitioning Company in America, but just now I am on another matter. I take it all the plans were submitted?
- As far as I know.
Q. Did the plans which were submitted show the general construction of the ship?
I object that that must be shown by production of the plans.
I believe so.
And the bulkheads and watertight compartments?
Q. The arrangement of the decks?
Q. The position and number of lifeboats?
Q. The access from one deck to another, and from the various decks to the engine room and holds?
- All places where passengers go -- the regular ladderways; those are all shown; but there is no ladderway into the holds. To get into the hold is merely through a hole in the deck, and you go down a vertical stanchion or ladder.
Q. Have you in your control or possession the working plans of the "Titanic"?
Q. In whose possession are they at the present time?
Do you know?
- No, I could not say.
Is it consistent with your knowledge and experience ----
I object that this is a leading question.
When did you last see these plans?
- Before I left the yard in 1910.
Q. Where were the plans then?
- They were at Harland & Wolff's works.
Q. Have you any reason to doubt that they are still in the works?
I will say they are either there or with the White Star Company. They are either with the owners or with the builders, but I have no idea at which place they are. They were all in Lord Mersey's Court, and whether they went back or not, I do not know.
Q. You are prepared to produce any plans that you have?
- Yes. I have practically nothing.
Q. I think you have one plan?
Q. You were thoroughly acquainted with all the working plans?
Q. And you could identify them if they were submitted to you?
- I believe I could.
I call for the plans from Mr. Duke.
I have not got them.
You mean the Oceanic Company have not got them?
I believe not; but if you call for them, I can only say they are not produced. That is the formal answer.
To what scale were those plans made?
Can you tell the Commissioner to what scale those plans were made?
I object that until proper means have been taken to produce the plans, and their non-existence or some other reason for their non-production is shown, no evidence as to what appears on the plans is admissible.
Do you know the scale to which those plans were drawn?
- All working drawings are made to quarter scale.
Q. That is a quarter of an inch to the foot?
- Yes, one-forty-eighth of the real size.
Q. And the detail plans?
- They are different scales, according to the part of the ship and the amount to be shown. If you have a small thing like a fireplace to show, you can do it on a much larger scale than you can the whole side of a room, or anything of that sort.
Q. I want you to be good enough to look at these two plans which I hand to you. (Plans handed to the witness) Do those plans show the general details of the "Titanic"?
I object, for the reason I have already stated, and further for the reason that these do not purport to be the plans.
They are not marked "Harland & Wolff"; they are not stamped by us; therefore I could not say whether they are the right thing or not.
I submit those to you as plans furnished to us, the Respondents in America, by the Petitioners, the Oceanic Company.
I submit that that is an entirely irregular statement.
I submit those to you as plans which have been given to us and which purport to be scale plans of the "Titanic". I ask you, on looking at them, whether you can tell the learned Commissioner if those plans represent fairly and in a general way the details of the "Titanic", and show her subdivision into watertight compartments?
- I think so, but of course I do not know, seeing they have not been marked by Harland & Wolff's stamp, but I think they do; I know the four funnels and everything of that sort, but with ships in this state it is very difficult. I presume the White Star Company would not dream of giving you anything but the real thing, but could not swear unless I saw them stamped with Harland & Wolff's stamp. There is nothing on them to denote that we sent them to them.
Q. I direct your attention to this plan which is marked "No. 14", and to the sketch at the top of that plan. Of what is this a sketch?
- I believe that is a sketch of the "Olympic" and "Titanic".
Q. Does it show, in a general way, the division into watertight compartments?
(Two plans were marked respectively "A.M.C.1" and "A.M.C.2")
Q. You have already given us some information about the conferences which took place between the heads of Messrs. Harland & Wolff and the Oceanic Company. Who were present representing Messrs. Harland & Wolff at those conferences?
- In Belfast there would likely be about eight or ten present in the room, and the same number from the White Star, the principals in each case being Lord Pirrie and Mr. Bruce Ismay.
Q. Was Mr. Bruce Ismay present at all those conferences, so far as you are aware?
- I could only say in Belfast. Of course I could not, unless I had the dates and everything looked up, say whether he was there or not. I might know certain ones, but I could not tell which ones definitely.
Q. Did you meet Mr. Bruce Ismay at certain conferences in Belfast?
Q. Connected with the construction of the "Titanic" and "Olympic"?
Q. Did you meet him anywhere else at such conferences?
- In London - Cockspur Street.
Q. Was any other Director present representing the Oceanic Company at those conferences?
- Mr. Sanderson.
Q. Was any other Director of the Oceanic Company present?
- No. In London there were only four of us in the room.
Q. How many conferences took place in London at which you were present?
- I could really only swear to one. There may have been two or three, but I could not put dates or times on them.