Limitation of Liability Hearings

Deposition of NEAL ROBERTSON


ss "Lusitania"


Southern District of New York.



as owner of the Steamship LUSITANIA, for limitation of its liability.



DEPOSITION of NEIL ROBERTSON taken before R.V. WYNNE, Esq. the Commissioner at the Law Institution, Chancery Lane, London, W.C.2. on Thursday, 14th June, 1917.

The Commissioner having duly administered the oath to SPENCER PHILIP HARRY as Shorthand Writer administered the usual oath of a witness to NEIL ROBERTSON.




Q. Were you serving as carpenter on the “Lusitania” at the time of her loss?

- I was.

Q. Had you previously been on the “Ivernia”?

- Yes.

Q. She is another Cunard vessel?

- Yes.

Q. You remember being in New York before you started on the voyage in question?

- Yes.

Q. During the time you were in New York was it part of your duty to do anything with regard to the boats as carpenter?

- Yes.

Q. What was it your duty to do with regard to the boats?

- It was my duty to overhaul all the boats and see that everything was in good working order and that the boats were in good condition.

Q. Did you obey your duty?

- I did.

Q. What was the result of your inspection of the boats? Were they good or bad?

- I found everything in perfect condition.

Q. Were any of the boats leaking?

- No.

Q. With regard to the collapsible boats which we know are under the lifeboats, did you take notice whether the gear which you have to use in order to release the boats was in order?

- Yes.

Q. Was the gear in good working order?

- Splendid working order.

Q. You left New York on May 1st we have been told, and all went well for some days. Could you give me any information with regard to the state of the portholes?

- All the portholes on the F. deck, that is the Orlop deck, closed because it is so near the water line that they have got to be closed or else the place would be awash all the time. They are only there for light, as it were.

Q. Is it within your knowledge that they were closed?

- They were.

Q. Do you know anything more about the closing of the portholes of your own knowledge?

- Just in the place where the cargo is stowed.

Q. And what deck is that?

- That would be in F deck.

Q. You know nothing more than F deck?

- No.

Q. I am wishful that you should only deal with the things that you know of your own knowledge. Where were you when the ship was struck?

- I was between 30 and 40 feet the other side of the saloon entrance, the first class entrance.

Q. On that deck?

- No, on the shelter deck.

Q. Where is that with regard to the deck on which the saloon is? Is the saloon on the shelter deck, or above it, or below it?

- One of the entrances into the saloon is on the shelter deck.

Q. It is on the shelter deck?

- Yes.

Q. When you were struck what did you do?

- I just remained steady for a couple of minutes, because I was not quite sure which way to go as it were, for the time being, and I thought it beet just to steady myself and see which was the best thing to do.

Q. You applied your mind to the situation for a short time?

- I did.

Q. What conclusion did you form after this deliberation?

- I came to the conclusion that it was best for me to go to my boat, because I could do more there than going anywhere else.

Q. Did you know the number of your boat?

- Yes.

Q. What was the number of your boat?

- 22. Of course I had charge of a group of boats.

Q. Your particular boat was 22 but you had charge of a group?

- Yes.

Q. 22 would be a boat on the port side according to what we have been told?

- Yes.

Q. Having got to your boat what was happening on the port side?

- On the way to get to my boat I had to come right aft to the after end of the ship to get up the ladder there from the shelter deck to the promenade deck, and then from that to the boat deck, but there were so many people on the ladder that I just remained steady because I did not want to rush my way past the passengers: That might cause a bit of a panic amongst them and I waited until they were all up.

Q. Then what did you do?

- Then I got to this 22 boat.

Q. Did you do your best to help save the lives of the passengers?

- I did.

Q. I do not want to go through the whole matter again in too much detail, but what happened to you yourself?

- There was quite a lot happened in a short time.

Q. How were you saved? Were you saved in a boat or did you go down with the ship?

- I went down with the ship; I was about the last on that deck.

Q. And you were picked up afterwards were you not?

- Yes.


Cross-examined by Mr. SCANLAN.


Q. Your position was aft as carpenter: Were you the senior carpenter?

- Yes.

Q. The particular port holes you have spoken to as having seen closed are merely the port holes on F. deck?

- Yes.

Q. On which side of that deck - the port or the starboard side?

- On both sides.

Q. But you can give no information of your own knowledge with reference to the rest of the port holes on board the ship?

- None whatever.

Q. So you do not know whether they were closed or not?

- No.

Q. Immediately after the ship struck when you went to the boat which you went to assist at, Number 22, you found something had happened to it?

- Yes.

Q. What had happened to it?

- When I came up on that deck I ordered one of the stewards to pick up a fall to lower 22A into the water. I noticed that 22 had gone by this time. I looked over the side. I intended to pick up the fall myself but when I went to pick up the fall I noticed what appeared to be wreckage clinging to the forward fall.

Q. Did you find that the after fall had gone altogether?

- Yes. It had gone altogether and left it practically useless.

Q. The block and everything else?

- Yes.

Q. So the appliances for lowering there were gone?

- Yes
Q. And you could do nothing with the davit without having a fall?

- No.

Q. In entering the danger zone the collapsible boats were not, I take it, free - released?

- Who said so. They were all free - all the collapsible boats.

Q. Had they been released or not?

- All released.

Q. The skids had not been removed, had they?

- It is not necessary to remove the skids.

Q. I just asked you a question of fact, and I wish you would direct your mind to it, and not answer anything else, because I may have to remind you of your evidence given in another place. The skids holding down the collapsible boats had not, in point of fact, been removed?

- The skids do not hold down the collapsible boats.

Q. Perhaps some time or other you will answer the question. The skids holding down the collapsible boats, were they or were they not removed?

- They were not removed. That is the skids I am talking about.

Q. Are the aft collapsible boats strapped?

- Yes.

Q. Number 22A to 22E?

- Yes.

Q. How are they strapped?

- With slip links.

Q. Those straps were not removed?

- No.

Q. In order to enable those boats to be of use it would be necessary to have the straps removed, would it not?

- To be of any use the straps would have to be removed, but if you removed the straps before the boats were required, then the boats would not be of any use.

Q. I put it to you thus, that rightly or wrongly these straps holding those five boats 22A to 22E, had not been removed?

- They had not been removed. I am in charge of that group of boats.

Q. Did you see many boats capsized?

- None.

Q. Was it possible to lower the open boats on the port side of the “Lusitania”?

- No, to lower the port boats would just be like drawing a crate of unpacked china along a dock road. What I mean is that if you started to lower the boats you would be dragging them down the rough side of the ship on rivets which are what we call snap headed rivets; they stand up about an inch from the shell of the ship, so you would be dragging the whole side of the boat away if you tried to lower the boats with a 15 degree list.

Q. One boat, number 22, had been lowered?

- I could not tell you whether it had been lowered or not.

Q. At all events, when you got to your station it is your evidence that that boat was gone?

- It was gone but I do not know whether it had been lowered or not. I do not know what had happened to the boat. I say I only saw wreckage there.

Q. Were you on deck that morning before the torpedoing took place?

- Yes.

Q. What time were you on deck?

- On deck all the time except at lunch.

Q. Were you on deck between 11 and 12?

- Yes, I was speaking to the chief engineer at 12 o'clock.

Q. Were you there when the haze, or whatever, it was cleared away?

- I daresay I was. I saw the chief engineer with his glasses on the look-out: I hid not take much notice of the weather all the same.

Q. The chief engineer was looking out?

- Well, he had his glasses. Of course that is a common thing with the chief or anyone else about the ship.

Q. He had nothing to do in the way of look out duty, had he?

- He was just watching for ships or anything like that in the water - passing ships.

Q. Do you know how many boats had been picked up altogether after the disaster to the "Lusitania"?

- No, I could not say.

Q. What boat were you saved in?

- I was saved in a collapsible boat. When I was plunged into the sea there were three collapsible boats, one on top of the other, and with the help of another man we pinched off the top boat. We broke an oar in the first effort to get the top boat released and that boat was badly damaged, and when we got the top boat off the other two boats seemed to float adrift. I was in the damaged boat.


Re-examined by Mr BUTLER ASPINALL.


Q. Questions have been directed to you on the assumption that the skids held the boats down. Do the skids hold the boats down?

- No.

Q. What is the object of skids?

- For resting the boat on.

Q. The boat merely rests upon the skids?

- It just rests on the skids.

Q. Just in order if we can, to picture these boats in our own minds, you have got your lifeboats hanging from your davits, and that have you got immediately below your lifeboats?

- A skid.

Q. Then below that what have you got?

- A wooden skid.

Q. And below that?

- The deck.

Q. Where do the collapsible boats come? Where are they stowed regard to the lifeboats?

- Immediately below the lifeboats.

Q. So you have your lifeboat, and immediately below that is what?

- The collapsible boat.

Q. Reference has been made from time to time to gripes. Of course it may sound silly to you as a sailor man, but I mean to ask you what the purpose of the gripe is?

- The gripe is for keeping the boat in position.

Q. How does it keep a boat in position? What is a gripe to begin with?

- The gripe is either a chain or a rope lashing with a link and a slip link attached. You put the slip through the link, and the slip turns up with a small link to come over the top. All you have to do is to touch the small link that binds the slip and let the thing slip.

Q. When you do that do you mean to convey to us that that releases a boat, and you are then able to place it in the water?

- Yes.

Q. If you do not have gripes and do not keep the boat secure by gripes, what may happen to the boat if the ship takes a list, or if there is a sea-way?

- If you do not have them secured in that way, they would come right inboard: They would fall to leeward all the time.

Q. In the circumstances of this particular case, having regard to the fact, that there was a list to starboard, if you had not got gripes keeping the boats in position, what would probably have happened to those boats. Where would they have gone to?

- We were doubly prepared for anything of that sort, even with the gripes free, which they were. To begin with the skid for the collapsible boat is 11 inch deal with a notch for the keel, and the keel of the collapsible boat sits into the notch. What we call a curtain plate, that is the plating on the ship's side, rises above the wooden deck about 2 inches high: The skid is placed against this plating and it is also placed up against the ring bolt for the gripes; therefore when the gripe is free, that skid is locked.

Q. And that prevents what happening?

- It prevents the collapsible boat from coming inboard even with the gripes free.

Q. To summarise it, if I may, the gripes are there for the purpose of keeping the boats in position: If you want to use your boat you have to free your gripes?

- Yes.

Q. Then if you do free your gripes there is a certain device which keeps the boat in place and prevents it taking charge and running free over the deck?

- That is so.

Q. That is what it comes to, is it?

- Yes. That applies to the boats on the boat deck, but not on the island.

Q. If you take off your lifeboats which are on the top and you cast adrift your gripes, when the "Lusitania" takes the water are the collapsible boats then free to float off?

- Yes.

Q. That is where their service comes in, is it not?

- Yes, they act as a raft.

Q. They are auxiliary, as it were to tie lifeboats, and so they are somewhat in the position of rafts?

- Yes.

Q. You have referred to the boats on the island: Where is the island?

- The island is a part of the second cabin part of the boat deck, but it is out off from the main boat deck by an alley. There is a break in the deck and there is a small bridge which we call the island which is part of the boat deck but is separated.

Q. The deck is not continuous?

- No.

Q. Why is not the deck continuous there, do you know? Is there some reason for it?

- There may be some reason.

Q. But you do not know it?

- I do not know it.

Q. The deck is not in fact continuous; there is a break in the continuity of the deck, and that space in between is the island?

- It is what we call the island.

Q. What was the difference between the fixing of the boats in the island and the fixing of the boats in the other part of the boat deck? I think you had present to your mind a difference?

- The boats on the island were double-banked: That is to say, the boats were one on top of the other. If you do not keep the collapsible boats in the island griped down and the ship takes a sudden list, it throws the top boat off on to the deck and damages the boat, and may hurt ever so many passengers.

Q. Because below this island that you are telling us of there is on the deck a promenade up and down which the passengers may be walking, is there not?

- That is so.

Q. And unless you carefully secure these boats, especially having regard to the weather which you may meet in the Atlantic, the top boat might topple of and break somebody's neck or head as the case may be?

- That is so. That is the idea.


The Witness withdrew.

Signed by the witness after the
deposition had been read to him
and the alterations had been
made and initialed.
Neil Robertson [sig.]
R. V. Wynne [sig.]