Transcription of affidavit from William Ashbee (for "Morris v. Ashbee"), 22 May 1868, before George White. Source: Chancery files, 22 May 1868, ref: C 31/2233/1447; The National Archives of the UK (TNA), held off-site from Kew. Transcribed by Liz Evans, 29/10/2015, from photographic images held by Tony Proctor (images nos. 455-456) ================================================================ [page 1, image 455] In Chancery 1868 M 81 Between John Stuart Crosbee Morris ________________ Plaintiff ______ and ______ William Ashbee and Lewis Simonson _______ Defendants We William Ashbee of 190 Grays Inn Road in the county of Middlesex Publisher one of the above named Defendants Edward Alexander Kirby of ^Islington^ in the county of Middlesex Sorter in the General Post Office Philip Henry Hale of No. 190 Grays Inn Road in the county of Middlesex Clerk to the above named Defendants and Henry Charles Pereira of Alma Villas Dalston in the county of Middlesex sorter in the General Post Office severally make oath and say as follows 1 I the said William Ashbee say that in the month of March 1867 I had a conversation with the Plaintiff respecting the mode of compiling the Business Directory in the Plaintiff's Bill mentioned by making use of cuttings from the Post Office Directory and similar Publications when he stated in the presence and hearing of my fellow Deponents that the making use of the paid portions of any Directory was not illegal that advertisements paid for by the Public became public property and could be used by any person in the manner in which he was using them. I then enquired of the Plaintiff Do you mean to say that every one has the right to cut the capitals and lines from your book for the purpose of any new Directory? to which he answered yes, mine or any one's -This occurred after the Award of 10 Monday 22nd May 1868 (9) White No 1447 [page 2, image 456] the Injuction against the now Plaintiff in the Suit of Kelly v Morris. 2 I at that time had conceived the idea of publishing a Directory of my own as mentioned in my first Affidavit and I accordingly took particular notice of the Plaintiff's observations. 3 We the said Edward Alexander Kirby Philip Henry Hale and Henry Charles Periera say that we were present at and heard the conversation spoken of in the first Paragraph of this Affidavit and that the statement of it therein contained is true. 4 All this we say of our respective personal knowledge, the sources of which herein appear. William Ashbee Sworn by the Deponent William Ashbee at Record and Writ Clerk's Office Chancery Lane in the county of Middlesex this 19th day of May 1868 - Before me E Grubb Edward Alexander Kirby Sworn by the Deponent Edward Alexander Kirby at the General Post Office Saint Martins Grand in the city of London this 21st day of May 1868 - Before me Jno Letts a London Commissioner to administer oaths in Chancery Philip Henry Hale Sworn by the Deponent Philip Henry Hale at Record and Writ Clerk's Office Chancery Lane in the county of Middlesex this 19th day of May 1868 - Before me E Grubb Henry Charles Pereira Sworn by the Deponent Henry Charles Pereira at the General Post Office Saint Martins le Grand in the city of London this 21st day of May 1868 - Before me Jno Letts a London Commissioner to administer oaths in Chancery Filed for and on behalf of the abovenamed Defendants by George White 70 Russell Square [page 3, image ??] In Chancery Morris Further Affidavit v of William Ashbee Ashbee Copy by Monday George White 70 Russell Square