ORAL ARGUMENT OF CHRISTOPHER R0T5INS0N, Q. C. 281 



The cliapter on ''Eaids" is to be found in tlie British Commissioners' 

 Eeport, parag-raphs 727 to 770. I do not propose to read from that at 

 all at any length; but you will find at paragraph 762 they say: 



The evils of raitlinaj are very great. It is by far the most destrnctivo form of seal- 

 ing, combiuing all the disadvantages and none of the advantages of the other forms. 

 The killing is chiefly of breeding females, as the raiders cannot penetrate far enough 

 inland to obtain the young bachelors or immature females. 



And so on. 



We ourselves noticed, tbe great ease with which, under present arrangements, raids 

 might be successfully carried out. 



— and they give particulars of that. 



For instance, we steamed into the anchorage of the settlement at St. Paul, close 

 past the Zapadnie and Tolstoi rookeries, one bright moonlight night (14th Septem- 

 ber), and moved early the next morning by daylight round the Garbotch and Reef 

 rookeries to the otherlanding, without our presence becoming known in any way at 

 the settlement. 



In short they say under present regulations and arrangements, there is no difficulty 

 or danger whatever to vessels raiding along shore any night, or in any of the fre- 

 quent fogs at several of the best rookeries, except when a revenue-crnizer chances 

 to be close by, an occasional occurrence well known to every marauding schooner. 



If you look at the British Counter Case, the Appendix Volume I, 

 pages 153 to 154, you will find Mr. Macoun's report on that subject, 

 which is very definite and specific. He says: 



During the months of July and August, 1892, no guard was stationed upon any 

 rookery on either island with the exception of North-east Point on St. Paul Island, 

 and Zapadnie on St. George. Polavina and Zapadnie Rookeries on the former island, 

 and Great East and Starry Arteel Rookeries on the latter, were left without a guard 

 of any kind, and three of these four rookeries are known to have been raided in recent 

 years. 



On the 16th of July I walked on St. George Island from the village to Zapadnie 

 Rookery with the two natives who were going to relieve the watchmen there. One 

 was a young man about 20 years of age, the other a boy of 12 or 13. When we 

 reached the guard-house, I found that the guards to be relieved were an elderly man 

 with but one arm, and a boy of about the same age as the one referred to above. I 

 was afterwards told by Dr. Noyes, the manager on St. George Island for the Com- 

 pany, that when the killing season was at its height this one armed man was the 

 only guard kept at Zapadnie. He was unable to assist in any way at the killings, 

 so was employed as a watchman. 



Two or three meii were kept at North-East Point, St. Paul Island, and this place 

 is connected with the village by a telephone line. Early in August, 1892, however, 

 the receiver or transmitter at one end of the line got out of order, and it was ren- 

 dered useless as a means of communication between these places. 



At the time of my departure from the island on the 12th of September it was still 

 in this condition, and there was apparently no prospect of its being rejiaired before 

 next spring. More than two hours would he required by the watchmen to reach the 

 village were a raid to be made at North-east Point, and the same time to return 

 with assistance. This, with the time consumed in rousing the people at the village, 

 would give any raiders ample opportunity to do their work, as I have been assured 

 by several men who have actually r<aided the islands that four hours is the time 

 usually required to make a successful raid, so that North-east Point was in 1892 

 practically without protection. 



Polavina rookery is 5 miles from either the village or North-east Point, and any 

 night the wind served, or even on foggy days, raids might be made there and nothing 

 be known of them at the village. Although Zapadnie rookery can be seen from the 

 village, and on this account is supposed to be safe, it was at this very place that the 

 skins taken by the crew of the " Borealis", late in 1891, were procured. I was told 

 by one of the men engaged in the raid that, at the time it was made, a revenue- 

 cutter was lying at anchor near the village, and less than 2 miles from the rookery, 

 that the night was clear, — so clear that they could see from the schooner not only 

 the lights of the cutter, but the vessel itself. They were desperate, however, and 

 sailed in close to the rookery, landed, and secured 400 skins without being seen or 

 heard. 



