TIP | Limitation of Liability Hearings | Day [#] | Affidavit of [WITNESS]

Limitation of Liability Hearings

DEPOSITION OF EDWARD WILDING
13 and 14 May 1915

United States District Court
Southern District of New York

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In the Matter
of the
Petition of the Oceanic Steam
Navigation Company, for Limitation of its Liability, as
Owner of Steamship TITANIC.

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DEPOSITION OF EDWARD WILDING
May 13 and 14, 1915

DEPOSITION OF EDWARD WILDING, a witness for the petitioner, examined in open court by permission of his Honor, Judge Mayer, pursuant to notice under Section 863 of the Revised Statutes of the United States, in New York City, on the 13th and 14th days of May, 1915.

Appearances:

Messrs Burlingham Montgomery & Beecher (Mr. Burlingham and Mr. Wells) for petitioner;

Messrs Hurt Hill & Betts (Mr. Betts and Mr. Kinnicutt),
Messrs Barry Wainwright Thacher & Symmers (Mr. Symmers)
Messrs Everett Clarke & Benedict (Mr. Everett),
Messrs Spencer Ordway & Wierum (Mr. Smythe),
Messrs Harrington Bigham & Englar (Mr. Houston), Roger Poster Esq., A. Gordon Murray Esq., A. Leonard Brougham Esq., and Theodore M Taft Esq., for various claimants.

A. Gordon Murray, Esq:
I desire to state that I wish it understood that I am to conduct my own case, and that I do not wish to be bound by anything except by my own questions. There are a great many cases being tried here in one large case, and I want to keep my own case, my own position and my own objections separate and distinct from the other claims.

The Court:
It will be assumed that nobody adopts anybody else's line, unless he so states.

EDWARD WILDING, being duly sworn and examined as a witness for the petitioner, testifies:

BY MR. BURLINGHAM:

Q. You are one of the managing directors of Harland & Wolff, Ltd., of Belfast, are you not?

Mr. Murray:
Objected to unless counsel for the petitioner is prepared to admit that the English law applies to this case, and then I object as immaterial, incompetent and irrelevant. I should like to have decision on this reserved, so that at some future time I can seriously present it to your Honor.

The Court:
We will take the testimony now and I shall have to pass on all the questions at the end of the case.

- I am.

Q. And have been how long?
- For two years now, managing director for not quite two years.

Q. How long have you been associated with Harland & Wolff?
- Eleven years.

Q. Besides being a manager and director what position do you hold in the company?
- I am naval architect and adviser on technical questions.

Q. Are you the head of the designing department of Harland & Wolff?
- Yes.

Q. They are ship builders of long standing, and they not?
- Yes.

Q. How long?
- Over half a century.

Q. Their principal works and yards are in Belfast?
- In Belfast, Ireland.

Q. And they have other yards where?
- On the Clyde, at Govan, near Glasgow, and repairing works at Liverpool and at Southampton. They are also marine engineers as well as ship builders.

Q. And they have built a large number of vessels and are building them constantly, are they not?
- They have, and are building them constantly.

Q. Of the vessels of say 650 feet long, and over, how many have they built?
- Of ships over 650 feet long, about eight out of the seventeen in the world, in April, 1912.

Q. In the world there have been built about seventeen, and your firm has built eight of them?
- Our firm has built eight of them; practically half.

Q. Have they built all the White Star boats?
- They have built all the White Star boats.

Q. What other lines have they built?
- We have built large steamers for the Royal Mail Steam Packet Company, for the Union Castle Company, and for Elder Dempster & Co.

That is, for several of the largest ship owning organizations sailing under the British flag.

Q. Have they built foreign vessels too?
- To a limited extent.

Q. Any of the German boats?
- Yes.

Q. What?
- The three that I remember at the moment, since I went there, are the President Lincoln, the President Grant and the Amerika, for the Hamburg American Line.

Q. Any for the Holland America?
- Yes; the Nieuw Amsterdam and the Rotterdam.

Q. How many men have you in your employ?
- At present about 32,000.

Q. What was your experience prior to connecting yourself with Harland & Wolff?
- Do you wish me to begin from my apprenticeship?

Q. Yes. I want to qualify you as an expert.
- My training was that of the naval architects for the British Government. That training consists of joining the Navy as a cadet, or the equivalent of a cadet.

Q. How long were you a cadet?
- Five years.

Q. Beginning when you were 15, I suppose?
- Beginning when I was 15.

Q. And after you had finished your cadetship?
- I became what is known as a probationary assistant constructor for three years, and attended the course for such officers at the Royal Naval College at Greenwich, London.

Q. Did you have sea experience?
- To a moderate extent, being attached to one of the battleships of the then Channel Squadron in the British fleet for that purpose.

Q. What dock yard experience did you have?
- During one's apprenticeship about half the time, or rather more, is spent in the dock yards acquiring practical experience.

During the vacations of the three sessions of the Royal Naval College we were attached to the dock yards in a roving capacity, almost, to get further experience as far as possible.

Q. After you had finished your work at Greenwich, where were you stationed?
- I was stationed first of all for a short time in Portsmouth dock yard. I then had the sea experience that I have referred to. I was then for a short time at the Admiralty on some special calculations, and I was then attached to the Admiralty experimental works under Dr. R. E. Freud F. R. S. at Hasler.

Q. What are those experimental works?
- They are a department specially organized for the study of the scientific questions which arise in connection with war ships.

Q. You went to Harland & Wolff's when?
- In February 1904.

Q. Beginning as draftsman?
- Beginning as draftsman in their designing department, the scientific side.

Q. And now you are the chief of the designing department?
- Yes.

Q. What are your duties generally?
- The duties are of a very miscellaneous character; but the principal ones may be shortly put as this: to interview and consult with owners for the preparation of designs for proposed vessels, and, when they have designated their requirements, to prepare designs embodying these requirements for discussion with them; if necessary to discuss the designs with them and to modify these as required until an approved design is obtained. Then to prepare the necessary preliminary structural plans for the guidance of the draftsmen attached to the ship yard, whose duty it will be to develop them; and during the development, to act as the consultant and to advise and in a limited extent to supervise the development of such plans; and when the work is in progress on the slips, to go periodically over the ships to see that the requirements that I have formulated -- or that my assistants have put before me -- are being properly carried out; to advise on any special difficulties that may arise during construction; during the construction to periodically meet the owners and discuss with them any new points, or anything of that sort which may arise; and finally, when the ship is completed, to attend the trials and to see that everything has been carried out in accordance with the general requirements.

Q. Did you assist in designing the Olympic and the Titanic?
- I did.

Q. Who was the head of the designing department then?
- Thomas Andrews.

Q. Was he lost in the Titanic?
- He was.

Q. He came out on her maiden voyage?
- He did.

Q. How many more came from Harland & Wolff's at that time?
- Eight.

Q. What were their positions?
- There was one of the principal assistants of the electrical department in connection with electrical matters; there was one of the principal assistants of the engine works department to supervise engine work matters; there was the leading draftsman who had charge of all the preparation of the working plans of the Olympic and Titanic; there was a junior draftsman, principally to deal with questions of ventilation, which was complicated; and there were four of our best apprentices in their last year, who are usually sent out on these trips for experience.

Q. Were all these men lost?
- All these men were lost.

Q. Were the Olympic and Titanic planned for at the same time?
- They were planned at the same time.

Q. But the Olympic was launched a considerable time earlier than the Titanic?
- In the case of these ships the slips had to be specially prepared, and hers was ready first.

Q. Were they alike in construction?
- As nearly as possible.

Q. Were they built by specification in a contract, or were they built on commission terms?

Mr. Betts:
Objected to as immaterial.

The Court:
I will take it.

Mr. Brougham:
May our objection be reserved until after the deposition is finished?

The Court:
Yes; except objections that could be made to advise counsel present; so that any ambiguity or any further inquiry may be disposed of at this deposition, as this witness is here from abroad and must return home.

- Built on commission terms, under what is known as a contract letter; a sheet of quarto paper making a formal agreement to do it, and that is all.

Q. (Producing letter to witness) Is that a copy of it?
- That is a copy of the letter.

Q. Is it a true copy?
- It is a true copy.

The copy of letter is marked Petitioner's Exhibit 1, being dated July 31st 1908.

Q. When was the keel of the Titanic laid?
- (Referring to notes) On the 31st of March 1909.

Q. What was her number?
- Her number in our books was 401; that is, the four hundred and first ship that we had built.

Q. Contracts are made without a particular name, usually?
- There is no name for twelve months.

Q. When was she launched?
- The 31st of May, 1911.

Q. When was her trial trip?
- On the 2nd of April 1912, and on the 3rd of April 1912, on the way around to Southampton.

Q. Did you go on the trial trip?
- I did.

Q. Where was it?
- In Belfast Lough, in the Irish Sea, at the mouth of the Lough, for the general trial, and a further trial in the Irish Sea and in the English Channel on the way to Southampton.

Q. Was she built under Lloyds Survey?
- She was not.

Q. Under Board of Trade survey?
- Yes.

Q. Did the Board of Trade surveyors visit her during the process of building?
- Very frequently.

Q. How often?
- Including the surveys for the engines, over 2,000 times.

Q. Was there a passenger certificate issued by the Board of Trade?
- Yes.

Q. When is that ordinarily issued, in England?
- It is not issued to the builder, though the builder gives the information to the Board of Trade inspector; the Board of Trade inspector advises the builder that he has completed the survey; the builder advises the owner to pay the fees necessary, and then the owner gets from the Board of Trade the certificate that the ship has complied with the regulations made for the construction and equipment.

Q. Do you recall the date of the passenger certificate issued by the Board of Trade?
- I can't recall the exact date; it would be 2 or 3 days after the trial trip.

Mr. Foster:
I move to strike out all this testimony about passenger certificate as incompetent, and as hearsay, and not the best evidence.

Objection overruled.

Mr. Burlingham:
It appears in the Mersey Inquiry Appendix, pages 7 to 10. May we, subject to Mr. Foster's objection, and the objection of others, put this in, or do you wish us to obtain from England a copy of it?

Mr. Betts:
I am perfectly willing to use the copy in the Mersey testimony, although I do not admit its admissibility.

Mr. Foster:
I have no objection.

Mr. Burlingham:
I offer in evidence, subject to objection, pages XIII and XIV in the Appendix just prior to page 481 of the Mersey Commission; it is dated the 4th of April, 1912.

It is marked Petitioner's Exhibit 2 for Identification, of this date.

The Witness:
I happen to know about it, because I carried it down to the ship in its frame.

Mr. Houston:
I object to the testimony as to the passenger certificate on the ground that it is irrelevant and immaterial.

Taken subject to objection.

Mr. Burlingham:
I offer in evidence a certified copy of the transcript of the registry of the Titanic.

Same objection and ruling.

It is marked Petitioner's Exhibit 3 of this date.

Q. Did I understand you to say that the Titanic and the Olympic were alike?
- As far as possible.

Q. In what respects?
- In all respects, except in the matter of certain deck erections additional, which were put on the Titanic.

Q. That makes a difference in tonnage?
- It does.

Q. Does it in displacement make any difference?
- No, not materially.

Q. These dimensions stated in the registry I assume are correct?
- Yes, they are officially measured from the ship by the Board of trade surveyor.

Q. Was the Olympic substantially the same as the Titanic in length?
- Yes.

Q. In beam?
- Yes, sir.

Q. Shape of hull?
- Yes.

Q. Rudder, and rudder area?
- Yes.

Q. Engines?
- Yes.

Q. Steering and reversing gear?
- Yes.

Q. Displacement?
- Yes.

Q. But the passenger accommodations and the deck houses, etcetera were different in tonnage?
- They were slightly different in the upper parts.

Q. What was the tonnage of the Titanic?
- The gross tonnage was 46,329 to the nearest ton.

Q. What was the engineroom space?
- The deduction allowed for propelling power space, which is the legal allowance in tonnage for the tonnage of the engineroom and boiler room is 21,690 tons.

Q. What is the net tonnage?
- The net tonnage is 21,831 tons.

Q. At the time these vessels were built were there any other vessels of equal size?
- There were not.

Q. What was the nearest?
- The Lusitania and Mauretania.

Q. About what is their gross tonnage?
- 31,000 to 32,000 tons, speaking from memory.

Q. Was any ship as large as the Titanic or the Olympic under contemplation at that time, so far as you know?
- Not so far as I know.

Q. Just for lay convenience will you state what the percentage of increase in the size was?
- It is about 45%, over the Lusitania, in tonnage.

Q. Will you give me a general description of the construction of the ship; we have her dimensions. I want with a little particularity you to give a description of the ship, particularly with reference to her construction?
- She was a vessel with a very strong built steel hull, what is known as poop bridge and forecastle type; these being above a continuous shelter deck. She was a trible screw vessel driven by two sets of four cylinder triple expansion engines; the exhaust steam from these engines working a low pressure turbine, driving a third screw.

Q. What sort of a bottom had she?
- A. very strong double bottom construction.

Q. Cellular?
- Cellular, like most large ships.

Q. With how many compartments?
- 46 compartments, including tree peak tanks in the double bottom.

Q. What does that mean?
- That means that the double bottom space between the tank top and the outer shell was divided by thwart ship divisions at the main transverse bulkheads, and by longitudinal divisions on the center line, and also out at the wings; into 46 separate watertight boxes.

Q. (Producing plan to witness) What is this plan?
- A general arrangement plan of the ship, one-thirty-second of an inch scale to a foot.

Q. Is this second sheet a part of it?
- It is the lower part of the same design.

The two sheets are offered in evidence, and are marked respectively Petitioner's Exhibit 4 and 4A.

Q. Those plans represent briefly what?
- Briefly, the general arrangement of the accommodation in the vessel; also of the store room and of the cargo spaces, and machinery.

Q. Let us come first to the decks. What decks did she have?
- In all 10, whole or partial.

Q. But generally speaking for the purpose of ordinary human beings who are not experts, how many decks should you describe this boat as having; 5 or 6 or is she a 4 deck ship?
- She had 5 continuous decks.

Q. Give us the letters, or numbers?
- They w ere known, owing to the confusion of names, by letters; decks C, D, E, F and G.

Q. G being the lowest?
- G being the lowest, which was continuous fore and aft.

Q. Below that G deck, which was well below the waterline -
- Amidships, yes; towards the end, about at the waterline.

Q. Below that G deck there was an orlop and a lower orlop deck for a portion of the space?
- For a portion of the length

Q. Above the C deck were there partial decks B, A. and a boat deck on top?
- There were.

Q. Was there access to the boat deck from below?
- Yes.

Q. From all parts of the ship?
- From all parts of the ship.

Q. By stair cases and ladders?
- Yes.

Q. They are all indicated on the plan?
- They are all indicated on the plan, and in the case of the second class by an elevator to the boat deck.

Q. First and second class?
- First class elevator stopped at the deck below; you had to walk up the last deck.

Q. Tell us about the plating of the ship?
- The ship was heavily plated. The keel plate and the bilge strake; the top side plating and the bridge deck stringers being doubled.

Q. I forgot to ask you how high the double bottom came up?
- To the top of the curve of the bilge.

Q. And the upper part of the bottom; what space between the inner and the outer bottom?
- 5 feet 3 inches, generally; 6 feet 6 under the main engines.

Q. What about the water tight subdivisions of the vessel. Tell us about the water tight subdivisions of the ship; how many water tight bulkheads were there?
- 15.

Q. Describe, in a general way, these water tight subdivisions and the bulkheads. Are they indicated on these diagrams?
- They are.

Q. In what way? By a black line?
- By a broad black line, particularly on the lower sheet, but also on the first sheet; on the elevation for identification they are marked by the letters W.T.B.

Q. That means water tight bulkhead?
- That means watertight bulkhead.

Q. Are these bulkheads lettered from forward, A, B, C, D?
- Yes, for convenience in reference.

Q. What is the last letter?
- P.

Q. From the letter A to the letter P, omitting the letter I on that plan 4, by measuring the black line, we can tell the height of the bulkheads; is that right?
- Yes.

Q. Can you state generally what the height of the bulkheads was?
- Generally they extended in the after body to D deck; in the fore body to E deck; but the two foremost ones extended to C deck.

Q. What was the height of the foremost bulkhead, generally?
- To C deck; it was about 80 feet from the keel.

Q. How much would that be above the waterline?
- About 50 feet at the time of the accident.

Q. What do you consider the waterline, when she is loaded and leaving port?
- 34 feet 7 inches.

Q. You have calculated what it was at the time of the accident?
- Yes.

Q. What was that calculation, about?
- It was about 30 feet forward and 32 feet aft.

BY THE COURT.

Q. How do you make that calculation?
- By estimating the amount of coal and water and stores used. We know what the sailing draft was from Southampton, and can estimate how much she came up.

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