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



of a dog upon the conclusions that could be drawn from sucb percent- 

 ages as these. It is obvious unless you have information with regard 

 to the actual condition of the seal itself and knew where it came from, 

 and if it had a i)up, or not or if the milk was drying np, you cannot. 



If I were to argue upon certain isolated cases I could prove to dem- 

 onstration they could within 20 miles get the food without going out, 

 and further that only a certain proi)ortion outside succeeded in obtain- 

 ing food. 



The whole argument is I submit untrustworthy, because you have not 

 and nobody can get from the fact of shooting a seal here and there what 

 1 may call quantitative or qualitative information upon the points 

 which the percentage are supposed to prove. 



Now I ask to go to the body of the testimony, and I will take it from 

 the United States abstract of evidence — the bodj^ of testimony sup- 

 posed to prove this killing of nursing cows; and 1 desire to rejieat and 

 substantiate to the best of my ability the statements by the Attorney 

 General which I believe are strictly true without exception, that there 

 is no single witness who proves time, i)lace or number of nursing 

 females killed in Behring Sea, so as to enable you to form a quantita- 

 tive estimate of what the amount of so-called destruction by that 

 operation is. Would the Tribunal kindly turn to page 45 of the 

 abstract of testimony. Of course I am not going to read the wliole, 

 though I am prepared to. I will read as many as are necessary, and I 

 will begin, if you please, at the top of page 453 where it is taken more 

 shortly. 



We entered the Behring Sea through the Mnckawa Pass about the 1st of July, 

 and commenced hunting seals wherever we could find them, among which were a 

 great many cows giving milk, which we killed from 30 to 150 miles from the Islands. 



I need not point out there again you do not have numbers given at 

 all, and the sole statement is, "Cows giving milk." You do not know 

 if it is drying up or not. I hear, General Foster laugh. All 1 can say 

 is that anybody who has any knowledge of this matter must know 

 that the milk takes some weeks to dry uj) iu these animals, and, there- 

 fore, there was no reason why the observation should be for the moment 

 treated with derision. 



A great many cows giving milk which we killed from 30 to 150 miles from the 



Islands. 



Then the next is. 



I have no exact information as to the proportion of male and female seals killed 

 by pelagic hunters. 



That does not carry it a bit further. Now. — 



And when in the Behring Sea, we take seals from 10 to 120 miles from the Seal 

 Islands. 



Then the the next man. — 



And the large proportion of the seals killed in Behring Sea are also cows. Have 

 killed cowseal with milk in tliem 65 miles from the Pribilof Islands. 



No statement when it was, or what number. If one were to judge 

 fairly, one would think that was an excei)tional case. 



We came out of the Behring Sea in the latter part of August, and had caught 

 about 1,700 seals between the Pribilof Islands and Uualaska. We caught them from 

 10 to 100 miles or more oli' St. (Jcorge Islands. 



