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



N" 5. The Seal Islands of Alaska. (Washingtou Government Printing Oflice, 



1881.) 

 N" 6. Report on the Seal Islands of Alaska. (Washington Government Printing 



Office, 18X4.) 

 N° 7. Our Arctic Province. 



This Gentleman has a right, I think, to be heard, and to be treated 

 witli respect when heard. 



Now I have this volnme before me, and before I call attention in a 

 very cursory way to it, because I endeavour to follow the lines I have 

 laid down for myself at the beginning-, namely, to treat this question 

 in the broad outline, putting upon my learned friends the res])onsibility 

 of dealing with it, as it must be dealt with in detail — before I call atten- 

 tion to that report there are one or two dates in connection with it which 

 I think it is exceedingly important you should have in your minds. 

 You will recollect that Mr. Elliott was appointed by a Statute of Con- 

 gress for the purpose of making the report which is before you. He 

 makes tliat report in Washington on the 17th November, 1890. It lies 

 in the Government Office. It is not published. It is not printed. One 

 does not need to conjecture the reason. 



The reason is obvious: it did not suit the purposes of the United 

 States in the contention in which they were engaged; but on the 4th of 

 ]\lay 1891 there appeared an extract from this Keport in the Cleveland 

 Lender. It is so long ago since we had the discussion about the admis- 

 sibility of this Keport, that you. Sir, will no doubt have forgotten the.<e 

 fads though they were then mentioned, but the dates are very signiti- 

 cant. On the 4th May 1891 the extract appeared in the public press. 

 If it had not appeared in the public press, it would have lain perdue, 

 and we wouhl have known no more about it. 



At that time a resjiectable gentleman, Mr. Stanley-Brown, was at 

 Washington, and on that very 4th of May Mr. Stanley Brown goes to 

 San Francisco and later in the month of May leaves for the Islands. 

 In fact he leaves for the Islands on the tilth May and arrives at 

 St. George's on the 9th June. He left on his return on the liTth 

 September 1891 and reached San Francisco on the 2nd October 1891. 

 I pause for a moment. We have him back safe and sound in San 

 Francisco on the 2nd October 1891. First of all is it an unfair assump- 

 tion that Mr. Stanley-Brown had Mr. Elliott's report, was told of it, 

 if not furnished with a copy of it, was told its pur]iort, was sent 

 out with the view if he honestly could of counteracting its effect, 

 and, if he honestly could, of arriving at different results from those 

 arrived at by Mr. Elliott. He gets bflck on the 2n(l O'^tober 1891, 

 but from that day to this we have no report from Mr. Stanley-Brown — 

 none whatever. We have indeed two affidavits, one dated the 28th 

 March 1892, and the second the lOth December 1892. I will not go 

 into those two affidavits, but I will ask you when my learned friend is 

 dealing with the precise definite clear statement of fact advanced by 

 Mr. Elliott to ask yourselves, if I may resi ectfully so suggest, as you 

 go along whether Mr. Stanley-Brown, as he indulges in a good deal, I 

 admit, of oi)inion which points in a direction different from that of Mr. 

 Elliott, — whether he challenges any of Mr. Elliott's facts, and gives any 

 circumstances or particulars to support him in contradiction to the 

 views of fact advanced by Mr. Elliott. 



Now bearing in mind, Sir, that though we are now told there was a 

 marked decrease observed in 1884, some as I have said say earlier, in 

 1877 and 1879, yet that up till the year 1889, the reports from the islands 

 had been of the most glowing character. I will not stop to refer to 

 them. As late as 1889 there is a report of Mr. Tingle giving a most 



