To the first [charge] I answer that Niall O'Neale was never my servant page and that I
never sent letter or letters by him to Monsieur Baldeschi [the Pope's secretary], or the
Bishop of Aix, or to Principle Colonna.
And I say, that the English translation of that pretended letter produced by the Friar
MacMoyer is a mere invention of his, and never penned by me, or its original, either in
English, Latin, Italian or any other language.
I affirm moreover that I never wrote letter or letters to Cardinal Bullion or any of the
French King's ministers; neither did any who was in that Court either speak to me, or write
to me either directly or indirectly, of any plot or conspiracy against my King or country.
Farther I vow that I never sent agent or agents to Rome, nor to write to Rome concerning
any civil or temporal affairs. And I do aver, that I never received letter or letters from
the Pope or from any other of his ministers making the least mention of any such matters:
so that the Friars MacMoyer and Duffy swore most falsely, as to such letter or letters,
agent or agents. To the second, I say that I never employed Capt. Con O'Neale to the
French King, or any of his ministers, and that I never wrote to him, or received letters
from him and that I never saw him but once, nor ever spoke to him, to the best of my
remembrance, ten words, and as for his being in Charlemont or Dungannon, I never saw him
in those towns or knew of him being in those places; so as to Con O'Neale Friar MacMoyer's
deposition are most false.
To the third I say that I never levied any money for a plot or conspiracy, for bringing the
Spaniards or French, neither did I ever receive any on that account, from Priests or Friars, as Priest MacClave and Friar Duffy most untruly asserted.
I assure you that I never received from any clergyman in Ireland but what was due to me by
ancient custom for my maintenance; and what my predecessors these hundred years past were
wont to receive; nay I received less than many of them.
And if all what the Catholic clergy of Ireland get in the year, were put in one purse, it
would signify little or nothing to introduce the French, or to raise an army of 70,000 men,
which I had enlisted and ready as Friar MacMoyer falsely deposed; neither is it less untrue
what Friar Duffy attested viz. that I directed him to make a list of 250 men in the parish
of Sogart in the County of Louth.
To the fifth I answer that I never surrounded all the forts or harbours of Ireland and that I was never at Cork, Kinsale, Bantry, Youghal, Dungarvan, or Knockfergus and these thirty-six years past I was not in Limerick, Duncanon or Wexford. As for Carlingford I was never in it but once, and stayed not in it above half hour; neither did I consider the fort or haven; neither had I it in my thoughts or imagination to fix upon it, or upon any other fort or haven, for landing of the French or Spaniards; and while I was at Carlingford (by mere chance passing the way) Friar Duffy was not in my company as he most falsely swore.
To the sixth I say that I was never at any meeting or counsel, where there was mention made
of alloting or collecting of monies, for a plot or conspiracy, and 'tis well-known, that
the Catholic clergy of Ireland, who have neither lands nor revenues, and are hardly able
to keep decent clothes upon their backs, and life and soul together, can raise no
considerable sum; nay cannot spare as much as would keep half a regiment.
To the seventh I answer that I was never at any meeting of 300 gentlemen in the County of
Monaghan, or of any gentlemen of the three counties of Monaghan, Armagh or Cavan, nor of
any one county, nor of one Barony: and that I never exhorted gentlemen either there, or in
any other part of Ireland to take arms for the recovering of their estates; and 'tis well
known that there are not even in all the province of Ulster 300 Irish Roman Catholics, who
had estates or lost estates by the late rebellion; and as 'tis well known, all my thoughts
and endeavours were for the quiet of my country; and especially of that province.
Now to be brief, as I hope for salvation I never sent letter or letters, agent or agents,
to Pope, King, Prince or prelate, concerning any plot or conspiracy against my King or
country; I never raised sums of money, great or small to maintain soldier or soldiers all
the days of my life; I never knew or heard that the French were to land at Carlingford; and
I believe there is none who saw Ireland even in a map, but will think it a mere romance;
I never knew of any plotters or conspirators in Ireland, but such as were notorious and
proclaimed (commonly called Tories) whom I did endeavour to suppress. And as I hope for
salvation, I always have been, and am intirely (sic) innocent of the treasons laid to my
charge, and of any other whatsoever.
And tho' I be not guilty of the crimes of which I am accused, yet I believe none came
ever to this place who is in such condition as I am; for if I should even acknowledge the
chief crimes laid to my charge, no wise man that knows Ireland would believe me. If I
should confess that I was able to raise 70,000 men in the districts of which I had care,
to wit, in Ulster; nay, even in all Ireland and to have levied and exacted moneys from the
Roman clergy for their maintenance, and to have prepared Carlingford for the French's
landing, all would but laugh at me; it being well-known, that all the revenues of Ireland,
both spiritual and temporal, professed by his Majesty's subjects are scarce able to raise
and maintain an army of 70,000 men.
If I will deny all those crimes (as I did and do) yet it may be that some, who are not
acquainted with the affairs of Ireland, will not believe that my denial is grounded upon
truth, tho' I assert it with my last breath.
I dare venture farther and affirm, that if these points of 70,000 men, etc had been swore
before any Protestant jury in Ireland, and had been even acknowledged by me at the Bar,
they would not believe me, no more than if it had been deposed, and confessed by me, that
I had flown in the air from Dublin to Holyhead.
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