DEPOSITION OF RIGHT HONORABLE ALEXANDER MONTGOMERY CARLISLE - Continued.
Q. Can you tell us the date of the one which you do recollect?
- It was in the beginning of 1910.
Q. Where in London did it take place?
- At Harland & Wolff's office in Cockspur Street.
Q. Was Mr. Bruce Ismay present then?
- Yes.
Q. Was Mr. Sanderson present?
- Yes.
Q. Was Lord Pirrie present?
- Yes.
Q. And you?
- Yes.
Q. At those various conferences, whether they took place in Belfast or in London, can you say whether plans were submitted?
- I think there never was a conference without plans and notes, in my experience, in connection with every ship that is built.
Q. Did you, in your capacity of General Manager and Chairman of Managing Directors of Messrs. Harland & Wolff, prepare or give directions for the preparation of designs or plans in connection with the lifeboat accommodation?
- With the davits, I did.
Q. Did you prepare plans yourself, or give directions for the preparation?
- I gave directions.
Q. Can you say when those directions were given?
- No, I could not give you any date; 1909, I should say.
Q. Had you given consideration to the question of the lifeboat accommodation for the "Olympic" and "Titanic"?
- Yes.
Q. By whom were the plans prepared with reference to the davits and lifeboat accommodation?
- We did it in the yard.
Q. Were those plans submitted by you?
- Yes.
Q. To whom?
- To the White Star.
Q. Can you remember on what occasions they were submitted?
- No; I can only remember the davits being submitted. That was early in 1910.
Q. Were they submitted on one occasion, or on more than one occasion?
- On two occasions, once in Belfast and once in London.
Q. Have you in your possession the plan submitted, or a copy of it?
- I believe that this is it, but I really do not know. This is the only thing I had amongst my papers. The others were all left in the Court. (Plan produced) I presume that was submitted, as I see blue pencil on the corner: 1912.
Mr. Duke:
I object that there is no identification of the document produced as either the original or a copy of the plan.
Mr. Scanlan:
Of what plan or sketch is that a copy?
- The boat deck.
Q. What is it prepared from? What was the original of it?
- I could not really say what it was. It is not on a quarter scale, therefore it is not the working plan. It is more like this sketch plan that you have produced of your own. If you will let me look at the scale of that, I may be able to tell you.
Mr. Duke:
Is this a plan prepared by Messrs. Harland & Wolff at all?
- No; this is only a lithograph.
Mr. Scanlan:
In what form was the plan of the davits submitted by you drawn?
Mr. Duke:
It will be understood that my objection continues. I do not want to be perpetually interrupting with objections. You will understand there will not be any question raised that I am objecting to secondary evidence of the contents of documents not accounted for.
Mr. Scanlan:
It is right that I should state this. In the subpoenas served on Mr. Carlisle and Mr. Bruce Ismay, we have asked for all those plans. It will be for the Court to see that the plans are obtained afterwards.
Mr. Duke:
I merely take the necessary formal objection in order to have proper proof when the time comes.
Mr. Scanlan:
When did you last see the original plan of the davits to accommodate lifeboats on the "Titanic" and "Olympic"?
- I could not give you a date; the first half of 1910.
Q. Have you seen it at all since you left the employment of Messrs. Harland & Wolff?
- No.
Q. Was it then in the possession of the shipbuilding firm, Messrs. Harland & Wolff?
- It was either there or in Liverpool, I do not know which.
Q. When you say Liverpool, do you mean in the possession of the Oceanic Company?
- Yes, it might be sent over there; the plans went backward and forward.
Q. Can you tell us what lifeboat accommodation was provided by you in the plan submitted by you for the "Titanic": how many boats?
- Eight boats a side.
Q. How many boats were the davits which you had designed, capable of accommodating?
- You could have worked four boats on each pair of davits.
Q. How many sets of davits?
- Sixteen sets.
Q. Was the provision then for a possible 64 boats?
- If it was ever wanted.
Q. What size boats could be fitted to those davits?
- Without the information before me, think about 32 ft., but I have no particulars of what was fitted. I think 32 ft. is about the longest boat that we ever make, but from 26 to 32 ft. is the usual size of lifeboats. They are all standard things, to pass the Board of Trade.
It is really the Board of Trade who are the people that say the number of boats which are to be fitted.
Q. Were these davits, which you have spoken of, capable of accommodating lifeboats of the ordinary standard size?
- Yes.
Q. The boats which the "Titanic" actually did carry afterwards?
- Yes.
Q. Do you know for how many people 64 boats would have provided accommodation?
- I have no idea.
Q. Would 64 boats have provided for everybody on board?
- I could not say, without I made a calculation. I have no idea whether they would or not.
Q. Had you come to any conclusion yourself as to the number of boats which should be carried?
Mr. Duke:
I object to conclusions of the witness. He is not a representative of the Petitioners in this litigation.
Mr. Scanlan:
He held a most important position in the shipbuilding firm which built the boats.
Mr. Duke:
I still object that they are not servants of the Petitioners, and that only the conclusions of the Petitioners and their authorised agents can be evidence in this Inquiry. That objection does not extend to anything which the witness says to the Petitioners, but I suggest to my learned friend that the opinions in the mind of a witness who is not a party cannot be admissible.
Mr. Scanlan:
It is my submission that this question is relevant and competent. I cannot prevent Mr. Duke objecting to this and almost all my other questions, but I submit it is relevant, and that I am entitled to ask it.
Q. Had you come to any conclusion yourself as to the number of boats which should be carried?
- No.
Q. Did you submit the plan you had prepared to the Directors of the Oceanic Steam Navigation Company?
- Yes.
Q. Did the plan which you submitted show accommodation for or a possibility of accommodating 64 boats?
- No; it showed one pair of davits that you could work four boats on.
Q. And there were 16 sets of davits?
- Yes, I believe that is the number.
Q. How came you to work out a plan showing four lifeboats for each set of davits?
Mr. Duke:
I object to this, unless it is communicated to the Petitioners.
The Witness:
Because the Board of Trade had only Rules up to a 10,000 ton ship; and ships were gradually getting bigger and bigger, and I considered that either the Board of Trade or the owners would sooner or later fit more boats to their ships.
Mr. Scanlan:
In point of fact did the owners themselves order the lifeboats and decide how many there should be?
- I do not know. I had left the yard before that was settled.
Q. That was the ordinary course of practice?
- Yes. A ship like that takes so long to build. I could not even tell you whether I had started the lifeboats when I left the yard on the 30th June or not. You could build a lifeboat in two or three weeks.
Mr. Duke:
What were you saying was the ordinary course of practice? I ask in order that the note may be clear: what was the question you were answering.
Mr. Scanlan:
I will put another question to you. In regard to the providing of lifeboats, did it rest with the Oceanic Company to order as many lifeboats as they wanted?
- It is like a suit of clothes for yourself: you can order two or three, if you like to pay for them.
Q. Did those plans which you submitted to them, show that as many as 64 lifeboats could have been fitted on to the "Titanic"?
- No, there was no plan submitted showing 64 boats. It was only the set of davits that were shown.
Q. Did you convey to them by the plans or at a conference that each set of davits could carry four lifeboats?
- Yes.
Q. Could it be seen by them from your plans and from the explanation you gave them, that as many as 64 lifeboats could be put on to the "Titanic"?
- I suppose, if they had gone into it, they could have seen it, but the number was not gone into at the London or Belfast meetings. This is what was submitted -- this little plan showing a davit, merely showing three or four boats together. That was all that was submitted to them.
Mr. Duke:
I think it will be advisable to identify what the witness describes as the thing which was submitted.
The Witness:
Only one pair of davits.
Mr. Scanlan:
Will you mark the part which was submitted?
- Yes. (The witness marked the plan)
Mr. Duke:
It is the portion of the document produced which is enclosed in an irregular lozenge-shaped figure with initials against it.
(Plan marked "A.M.C.3")
Mr. Scanlan:
Can you recall whether those plans were submitted at a meeting in Belfast in October, 1909?
- I could not swear to that. The London one is the only one that I could swear to as being produced then. Whether it was produced in Belfast or not, I am not in a position to say. I might have done it, but I am not in a position to swear it.
Q. A plan, showing the capacity of each pair of davits, as marked on "A.M.C.3", was shown at the meeting in London in January, 1910?
- Yes.
Q. Was Mr. Ismay present at this meeting?
- Yes.
Q. Was his co-Director present at this meeting?
- Yes.
Q. In submitting this plan, did you explain it?
- I believe so.
Q. Did you allow the Directors, Messrs. Ismay and Sanderson, to understand perfectly how many lifeboats could be fitted?
- The plan showed how the pair of davits held them, but the number of boats was not gone into. The actual number of boats fitted in the ship was settled after I left the yard.