ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 191 



Sir EiCHARD Webster. — If that was what General Foster meant I 

 will take it from him, but it is not material for my purpose. 



Now would you kindly look at the column of cows? This is what I 

 want to direct your attention to first, the landing- which takes place 180 

 or 190 miles from Unimak Pass is the 3rd June, the 8th June, May 

 24th, June 7th, June oth, May 25th, June 8th, June IGth, No record, 

 June 8th, No record. No record, and so on; June 10th, June Gth, and 

 June 11th. If you go over to St, George's Island, the next one in 

 the cows' column, you will se6 June 7th, June 9th, June 13th, June 8th, 

 June 9th, June 9th, June 9th, June Cth, June 7th, June 1st, June 8th, 

 May 31st and the 3rd June, Therefore, I point out that what I have 

 indicated is practically — I will not use the word admitted — I do not 

 suggest they would not say anything but what they believed to be a 

 matter of fact is practically the view taken by the United States Com- 

 missioners, namely, that the cows are landing on the Pribilof Islands 

 very often in the early part of June and sometimes at the end of May 

 which show^s they have passed Kadiak Island by the date I have men- 

 tioned, namely, the end of May. 



Now in that connexion I ought perhaps to read a passage from Mr, 

 Merriam's Circular Letter, page 414 of the 1st volume of the United 

 States Appendix to their Case, paragraphs 3 and 5: 



Returning the herds of females move northward along the coast of California, 

 Oregon, Washington, and British Columbia, in January, February, and March, 

 occurring at varying distances from shore. Following the Alaska coast northward 

 and westward they leave the North Pacific Ocean in June, traversing the passes in 

 the Aleutian chain, and proceed at once to the Pribilof Islands. 



Then paragraph 5 : 



The pregnant cows begin arriving early in June, and appear in large shoals or 

 droves, in)mense numberw taking their places on the rookeries each day bi'.tween 

 June lz!th and the end of the mouth, varying with the weather. 



I have at any rate adduced before the Tribunal evidence in support of 

 the statement I made yesterday from sources that my learned friend 

 will not be able to impeach. I only need, that I may give the informa- 

 tion to the Court, give the references to paragraphs 037, 039, 048 and 

 651 of the British Commissioners' Report, because there will be found 

 evidence giving the authority for their statement of identically the 

 same character, namely, showing the entry of the seals into Behring 

 Sea, and their passing along the parts of the Islands at the same time. 



Now, the last observation I have to make upon this part of the case 

 is as to whether the time that I suggest from the 1st of May is sufticient. 

 I was asked by a Member of the Court yesterday to make a suggestion 

 with regard to varying dates, if any, of leaving the four Ports men- 

 tioned. I propose to hand in on Tuesday the Regulations in writing; 

 and I will suggest then to the Tribunal dates getting the best informa- 

 tion that I can as to the actual distances and the difference of time that 

 ought to be applied. 1 do desire to say, with reference to the general 

 consideration, taking Victoria and Port Townsend, one a United States 

 and the other a British Port, they are about the same distance, 1,500 

 miles, direct in each Case, and 1,850 following the coast. The only sug- 

 gestion that could be made would be that the sealers would go straight 

 up to lie outside, (for they would not be allowed to go inside the Passes) 

 to avail themselves of the hunting in the last few^ days of May. Well, 

 from the best information I can obtain, and perhaps Members of the 

 Tribunal are quite competent to judge, under ordinary circumstances 

 the lowest average voyage, with ordinary winds, that you could allow 

 for a schooner to get over that 1,500 miles in ordinary circumstances 



