OKAL ARGUMENT OF SIR RICHARD WEBSTER, Q, C. M. P. 137 



sea while suckling the young, but not further than half-a-mile or a mile from tlie 

 shore. Most of the natives, he added, thouglit that tlie females did not feed during 

 this period, but in this he believed them to be mistaken. 



It is not an unfair comment to say that this is a striking instance of 

 liow little we really know accurately. I call attention to it in order 

 that the Tribniial may see tliat upon the evidence wliicli was there (col- 

 lected, of a number of witnesses of equal credit, a number of wit- 

 nesses of equal experience, all Treasury Agents, and therefore whose 

 interest it would be to tell the truth and not to suppress the matter, 

 some of them say they do not go more than 10 or 15 miles, others think 

 they go farther. But it is extremely important to notice we are dealing 

 for this purpose only with the period when from the wasteful i)oint 

 of view it may be suggested that you ought not to kill the female 

 because the life of her i)up depends upon it; for in so far as it referred 

 to the killing of females on whose life a pup's life did not at the moment 

 depend, I protest tliat there is not only no reason for interfering with 

 it, but it would be contrary to all the rules which have governed similar 

 matters to interfere with the killing of a female simply because it is a 

 female. 



It is not unimportant, and that is why, Mr. President, I postponed 

 the reference to Mr. Grebnitzky, to remember tbat Mr. Grebnitzky 

 made a further allidavit for the United States on the 26th of Novem- 

 ber — 8th December, 1S92, and that they sent that to St. Petersburg]! 

 from Washington in order to have certain corrections made in the affi- 

 davit that it might be an affidavit which would go as far as JMr. Greb- 

 nitzky could go in support of the United States Case; and I ask you 

 just to let me read what he says upon this at page 3G6 of the Counter 

 Case of the United States: 



Consequently when the mothers, who after the birth of their pups leave the rook- 

 eries in search of food (travelling sometimes considerable distances, I do not Icnow 

 exactly how far), and fail to return their pups must necessarily die. 



Those words "considerable distances" were inserted in the affidavit 

 after the affidavit had been sent to him, no doubt properly sent to him, 

 from Washington, that the further correction might be inserted. 



Mr. Foster, — It does not so appear. 



Sir KiCHARD Websteu. — Well, I think it does so appear. If it is 

 not the fact, by all means, if you say it is not the fact I Will accept that. 

 I think it does a])pear in the papers that it is so. 



Mr. Foster. — I -will state what I understand the fact to be, if you 

 desire it. 



Sir Richard W^EBSTER, — I was merely dealing with what appears 

 upon the face of the affidavit; but my point is that Mr. Grebnitzky, who 

 was previously stating that he did not think they w^ent larther than 

 half a mile or a mile says in the revised affidavit, "considerable dis- 

 tances" but he does not know how far. 



We know, Mr. President, that the result of the combined knowledge 

 on the Russian islands — and Mr. Grebnitzky comes from the Russian 

 Islands, — demonstrates that they are rarely to be found outside 10 miles 

 except in the particular case of a particular place which it is considered 

 some seals go to in connection with some island. 



Mr. Foster. — I have no idea that you wish to make any statement 

 that is not consistent with the facts. If you will observe the date of 

 the corrections, you will see they are of the same date as the original 

 affidavit, December 8th. The fact is that the errors in copying were 

 corrected by the Consul-Geueral at St. Petersburgh. 



