Cross-examined by Mr. Purves: The Ozone is a very fast boat, and we often have heavy weather going down the Bay. Sometimes we have a lot of water on the deck. Our bunker lids have something that fastens them down when they are turned round a bit. The Ozone could not jump them off, because they fit in a socket. I should think the Alert was a sea-worthy ship if she had been further at sea. It is often the case that a captain has to bring the head of his steamer to the wind and lay to; when that is done, we steam easy ahead just to keep steerage way on her. I presume the Alert was sea-worthy when the Board of Trade gave her her certificate.
Re-examined by Mr. Smyth: I would not say the Alert was an ocean going vessel. I would call her a coasting steamer.
Occasionally there is worse weather near the land than out on the ocean. I did say there are means by which a man could batten down the window in the poop.
Q.—How would a man batten down on the iron frame-work? A.—In the iron I should put some small holes and put a plate over it. I would make the holes with a hammer and chisel. It would take half an hour.
Q.—Where would you get the iron plate? A.—It is a queer ship if there is not a bit of iron on board. Of course it would be better to have an iron door outside fastened on hinges.
Andrew Brown McKenzie, examined by Mr. Box, said: I am a shipwright, and have been about thirty-six years, more or less, in that business. I have been on board the Alert several times, and have known the vessel for a long time. She had very fine lines, and was very sharp foreward and aft. She had no bearings under her counter. Any time I saw her, she never had more than about eighteen inches of freeboard. To look at the vessel, she was like a snake in the grass. If the engines had been more amidships, she would have been a better vessel. The pantry window should not have been where it was; but being there, it should have been protected. I knew the engine room and stoke-hole. There ought to have been a tarpaulin on top of the grating. The Alert was very long and narrow, and should have had another mast placed aft with sail on it to help if the engines got disabled. A wooden awning covered the ship’s poop, and, in my opinion, it should have been made of canvas, so that it could be taken in when blowing. The bunker lids should have been fastened in with a turn screw, the same as the lid of an iron tank.
Cross-examined by Mr. Mitchell: I have been eight years at sea. I am the plaintiff’s father, and was on board the Alert seeing my son-in-law just before the fatal voyage. I have built all sorts of ships in the old country, and have built vessels here for the Melbourne Shipping and Coal Company.
Q.—Do you seriously say that this ship, the Alert, was like a snake in the grass?. A.—Yes. That was my opinion of her. She was so long and low. I did not take particular notice of the pantry window, but if the brass bolts dropped out, the aperture could not be properly secured. I saw the grating on the stoke-hole. I say that a seaman could not with his hands have secured anything on that grating to prevent the water from coming in. In times of storm it is too late to think of these things. They ought to be provided for before a vessel leaves a port. As a rule it is the ship’s carpenter, who, under the instruction of the captain, sees to these matters, but the Alert had no carpenter.
William Malone, examined by Mr. Box, stated: I am a seaman, and belong to the steamer Dawn at present. I was engaged on the Alert last November twelve months. That was four weeks before she foundered. I have been off and on at sea during the past twenty years, and was on the Alert when she went outside the Heads to Bairnsdale. I never thought her a trustworthy boat for going outside. I did not see any very bad weather in her. On one trip there was a stiff breeze, and she did not act very well. With a beam sea she shipped a lot of water. She took the most of the water on board amidships, and about the alleyways. This was between Cape Schanck and Port Phillip Heads, with a fresh, but not a heavy, breeze blowing. The Alert had no mast aft. A boat going outside should have an after mast in case they want to keep her head to wind in a heavy sea. There is no means of getting her head to wind without that. Her coal and engines were in the after part of the ship, and during my time she carried no carpenter. I was not discharged from the Alert. I had a word or two with the Captain, and luckily left her the voyage before she was lost.
Cross-examined by Mr. Mitchell; Q.—Did the Captain accuse you of being drunk while in the performance of your duty? A.—No, nothing of that kind. He could not do that, because I did not have any drink. Some ships will ship more water than others, but in an ordinary strong breeze a vessel should not take water on board. The water taken in by the Alert on the occasion I speak of ran out aft.