112 ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 



300, and it is plainly indicated by the context, if you read the whole 

 page. It will show itself when you examine it with the Chart. 



Mr. TUPPER. — And I may say that you informed me, as I understood 

 you, that the error, whether it is an error or not, is in the original 

 Eeport signed by Captain Hooper. 



General Foster. — Yes, it is a type- written copy. 



Sir KiCHARD Webster.— Well, my learned friend, Mr. Phelps, hav- 

 ing said that it is a typographical error, I of course accept it at once; 

 but I attach so little importance to the actual question of distance, 

 having regard to what the maps themselves show, because the 1,008 

 seals in the 100,000 square miles include the seals observed by Captain 

 Hooper and all the other cruizers, and we know what he means by 

 numerous seals because every single set of seals he observed outside 

 the 20 mile radius was counted and put down. Therefore, whether it 

 be 200 or 300 for the purpose I am contending for is immaterial, but I 

 think I ought in justice to myself to say that, when I made the argu- 

 ment about the 300 miles the other day, I did not receive the slightest 

 notice from my learned friends of the mistake, nor did I hear of it till 

 some days afterwards, when I immediately made the enquiry to know 

 if it was in the original. 



Lord Hannen. — I think, if you look at the paragraph, General 

 Foster's observation is borne out, and I think he is correct, because it 

 speaks of a 200 mile zone " dividing that part of the sea over which the 

 "Corwin" cruised into zones" up to 200 miles, and he says, " I find the 

 percentage of seals", and so on. 



Sir Richard Webster. — I had not examined it from that point of 

 view, my Lord, I was only looking at the statement with reference to 

 the supposed absence of intermingling when I made my last reference 

 to it, 



i*^ow the main point of attack made on the British Commissioners is 

 because they have stated, as the result of their own observations, taken 

 during their own cruising, that the seals did extend sparsely, practically 

 speaking, all the way across Behring Sea. Now if I was entitled, and 

 if I desired simply to incorporate, as part of my argument, the mere 

 statement in the Commissioners' Supplemental Report, I should from 

 their own investigations prove that they did in fact see seals right 

 away across; but I prefer to take another course, and I will ask the 

 Tribunal kindly to turn to Volume 2 of the Appendix to the British 

 Counter Case, pages 23 to 27, where they will find a very convenient 

 abstract of the affidavits which bear upon this matter. I will only 

 pick out those (there are some 57 of them, and I will not trouble the 

 Tribunal with the whole of them) that bear directly on this question of 

 seals in Behring Sea. If you will look at the top of page 24, it is a 

 verbatim extract of Mr. Billard's afitidavit given later on in the book, 

 page 56: 



Last year the " Beatrice" crossed Behriug Sea from east to west, starting from 

 about 35 miles north of St. Paul Island. I saw seals all the way over to the Copper 

 Island jiTounds and got two seals on 27th July between American and Russian sides 

 of the Sea. 



Mr. Bragg, the next man, also on page ii6. 



In the year 1887 I went over to Copper Island on the schooner "Teresa" and I saw 

 seals in Behring Sea ail the way across. 



And if you go to the top of page 25, George French his affidavits are 

 at pages 44 and 46, but I read from the summary on page 25. 



