ORAL ARGUMENT OF SIR CHARLES RUSSELL, Q. C. M. P. 25 



there are numerous statements of persons who express as a matter of 

 opinion that the deaths are caused in this way and that way, but these 

 are persons who simply find themselves unable to liud auy definite 

 cause for this marked mortality. 



I therefore, come to the next point, if pelagic sealing is shown to be 

 utterly inadequate to account for this depletion for this attack upon the 

 sealeries we must look for the causes of that depletion and the results 

 of that attack in other directions. In what other direction? Well, I 

 say we find the case carelnlly and elaborately explained in the report 

 of Mr. Elliott. I do not forget that my learned friends have made 

 some etforts to discount the value of Mr. Elliott's testimony. I am 

 sure the Tribunal will ju<lge by the value of that report, by its intrinsic 

 merits, and by the view that they take of the contents of that report, 

 whether or not they are hasty opinions, or whether or not they are not 

 careful results of a conscientious man trying to accunuilate all the 

 information that he can on this subject. So far as that report is a 

 matter of Mr. Elliott's opinions let my learned friends criticise it as 

 they please; but they av ill not be heard, and they cannot be heard when 

 he is recording facts. They cannot suggest that their own ofldcial, a 

 highly trusted ofiicml, and ireqnently employed, is coming to invent 

 statements against the interests of the country to which he belongs 

 and against the United States Executive Government which employs 

 him. It is the case, as I said to-day, of a witness called for the plaiu- 

 titf, who turns out to be a most valnable witness in the suit for the 

 defendant. They are now saying to him as Balak said to Balaam, 



I called thee to curse miue enemies, and thou hast altogether blessed them. 



It is not correct to say lie has altogether blessed them, because it is 

 one of the facts which goes to show the bona fides of this gentleman 

 that he is as strong against pelagic sealing as anyone can be in the 

 interests of the United States, but having gone to the islands with the 

 preconceived idea that pelagic sealing was the root of the mischief, he 

 is met by circumstances and by facts which compel his judgment to 

 the coiu'lnsion that it is not pelagic sealing mainly or principally, but 

 that the causes have been the wasteful, improvident, uneconomic man- 

 ner in which the islands have been administered. I have told you who 

 Mr. Elliott was, and where he was employed already, and I find that 

 he is the author of a number of works upon this subject. 



He may theu well be described, as he was described by Mr. Goff the 

 Treasury Agent, and by Mr. Blaine in effect. Mr. Golf whose testi- 

 mony is the more important, because he was with Mr. Elliott on the 

 islands in 1890, and he makes no report, and makes no afHdavit which 

 is forthcoming to countervail the report of Mr. Elliott. I find on page 

 148 of our printed argument, and I will not trouble you to do more 

 than take a note of it, a list of the works published on this subject by 

 Mr. Elliott. They are nearly all, or a great many of them, published 

 by the Washington Government. 



N" 1. Report on the Prihilof group or Seal Islands of Alaska in 1873. (Washing- 

 ton Goveruuient Printing Office.) 



N" 2. Report of the Secretary of the Treasury concerning the waste of seal oil, 

 and the "natives" of the Pribilof Isl.inds, and the brewing of quass. (H. R. 44th 

 Congress, first session. Ex: Doc: n" 83 pp. 103 and 104.) 



N" 3. Kepnrt upon the condition of affairs in the Territory of Alaska. (Wash- 

 ington Government Printing Oltice, 1875.) 



N" 4. Ten years' acquaintance with Alaska, 1867 to 1877. (New York. Harper 

 Brothers.) 



