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



the best evidence tliey could to sni>port the view of stagey seals being 

 found at sea, when tliey are piei)ariiig their Counter Case, they iind 

 this catalogne, and put it in. My criticism is not that they are gnilty 

 of improper conduct, but that from the facts in regard to the matter, 

 there is warrant for my argument. They will have a chance to rebut 

 my argument when the times comes for them to reply. 



My strong point is this, which I have mentioned already: that dur- 

 ing the whole time the seals are stagey on land, they are being taken 

 at sea in ordinary condition, so far as we can tell. I have had put 

 together an abstract which I will hand to my friends and to the Court, 

 taken from the aflidavits, of exactly the same character as that Mr. 

 Coudert used in reference to one part of his case. I think it was about 

 the percentage of females. This v>'ill save the court a good deal of 

 trouble in looking up references. All the references are from volume 

 II of the Ai)i)endix to the British Counter Case. Tliis bears, Mr. 

 President, ui)on both points. Perhaps I had better state it once more. 

 It bears upon the point that during the time seals are upon the island, 

 both previous to the stagey time and at the stagey time, they are found 

 at sea, large distances from the island under circumstances which 

 would indicate that they have no immediate connection with the island. 



I will ask Mr. Macoun to indicate on the map, as I read, the various 

 places mentioned : 



Seals not frequenting the Breeding Islands. 



C. F. Dillon, p. 47. — In 1888 I cnme south from Behriiii;- Sea, about latitude 175 — 

 west, and caught seals there. This was in the latter part of August. In 1886, late 

 in August, we killed seals 30 or 40 miles south of 172nd Pass. Between Uuimak 

 Pass and Saanak Island, in 1887, I saw seals (]uite abundant in the latter part of 

 July. In 1889 we got seals about Kadiak, off and on, all summer. In 1890, late in 

 August, I killed a sleeping seal off the Shuma^in Islands, and saw others. 



Charles J. Harris, p. .51. — In August 1890 I saw seals about 300 miles from 

 Kadiak, and in August, 1891 I saw seals about 250 miles from Kadiak. I have seen 

 seals as far south as Queen Charlotte Islands in August. 



R. O. Lavender, p. .55. — Coming home from ISehring Sea this year I saw four 

 sleeping seals off Cape Flattery, the 21st July; one was shot. It was a barren 

 female. 



Abraham Billabd, p.56.— Last year the '^ Beatrice" crossed Behring Sea from 

 east, starting from a point 35 miles north of St. Paul Island. I saw seals all the 

 way over to the Co])per Island grounds, and got two seals on the line between the 

 Russian and American sides of the sea. 



W. T. Bragg, p. 57. — In August 1888 I saw sleeping seals in the water near the 

 Scott Islands, that is within 20 miles from the said islands, and have heard other 

 sealhunters nuike statements that they had also seen seals there. 



Alfred R. Bissett, ]>. 60. — From my experience and observation I believe that 

 immense numbers of the seals that go u]> this coast never enter Behring Sea. I 

 know that all through tlie summer and early fall seals are scattered over the North 

 Pacific, north of Vancouver Island, aiul as far as the 165th meridian east. 



William Dewitt, p. 62.— In 1891 the "Viva" crossed Behring Sea from about 20 

 miles north of Amuka Pass to the Copper Island grounds. I saw seals scattered all 

 the way over. This year the "Sea Lion" went over outside the Aleutian Islands. 

 I saw the seals in about the same way all the way over. 



George French, pp. GO, 67.— Last 'year, 1891, when the " City of San Diego" was 

 crossing Behring Sea from Amutka Pass to Copper Island, we passed small bands 

 and bunches of seals travelling rapidly north-easterly; this took place on three 

 different days. The last lot we met were about 150 miles from Copi)er Island. 

 These seals were the same kind of seals we got at Copper Islands, and I am fully 

 satisfied they were crossing Behring Sea to the Pribilof Islands. This was between 

 the 5th and ■l2tli July, 1891. 



Emile Ramlosk, p. 72. — Other years I have seen seals, — large seals, — in July out- 

 side of the 172ud Pass, and in August between llninuik Pass and the Saanak Islands. 



Ernest Lokenz, p. 73. — Last year I got temale seals in milk off Queen Charlotte 

 Islands in July. — I know from my own experience that seals remain off the coast of 

 Vancouver Island all the year round, as well as off Queen Charlotte Islands and 

 Southern Alaska. 



