ORAL ARGUMENT OF SIR CHARLES RUSSELL, Q. C. M. P. 115 



me, but wliich if done will enable the Tribunal to see at a glance bow 

 completely and absolutely the United States have changed front upon 

 this question since the discovery of these forgeries upon which they 

 had based their great case of derivative title from Russia. Oat oat 

 these forgeries, and you have uo reference to the fur-seals, no asser- 

 tions by Russia in respect to the waters of the Behring Sea, no acts of 

 interference asserted or suggested by Russia in that sea at all. 



Kow let me just justify this, although it may take a little time, I am 

 afraid. 



On page 41 you will see what purports to be a quotation from the 

 Board of Administration of the Russian-American Company, beginning 

 with the words: " Witli this precious Act in your hand." Every word 

 of that from those words: "With this precious Act", to the end of the 

 page, is a forgery, an interpolation ; and Mr. Ivan Petroff understood 

 very well what he was about, because he makes this Ukase of 1821 

 speak in this language — this is the concluding sentence: 



We can now stand upon our rights, and drive from our waters and ports the 

 intruders who threaten to neutralize the benefits and gifts most graciously bestowed 

 upon our Company by His Imperial Majesty. 



858 Turning to the next page you will find a letter from the Board 



to the Chief Managers of the Colonies beginning "As to fur- 

 seals", down to the word "future" at the end of that paragraph — it is 

 all a forgery : 



As to fur-seals, however, since our Gracious Sovereign has been pleased to strengthen 

 our claims of jurisdiction and exclusive rights in these waters with his strong hand, 

 we can well afford to reduce the number of seals killed aunually, and to ])atiently 

 await the natural increase resulting therefrom, which will yield us an abundant 

 harvest in the future. 



A complete interpolation; not a reference — I speak subject to correc- 

 tion, but I believe I am right — not a reference in any one document to 

 fur-seals at all. In point of fact we know from the Report of the Com- 

 mittee of the House of Representatives of the United States in 1876, 

 which I referred to before, that in the Russian time the existence of 

 the fur-seal was considered a matter of very little importance; and it 

 is stated in that Committee's Report that it had yielded no profit, or no 

 considerable profit at all, during the time of the Russian Government. 



Then again on the next ])age, 43, the Tribunal will observe about the 

 bottom of the page, the words, "and on the islands and waters situated 

 between them" — also a forgery; and a little further down the words, 

 "The coast of Kamchatka, the Kurile Islands and the intervening 

 waters" — also a forgery: an interpolation, for the purpose of building 

 up the case, which he thought was the case — and was justified in think- 

 ing was the case — which the United States were making. He lends 

 himself to the series of forgeries to build up that case. 



Then take the text, which is very remarkable, on page 44. You will 

 observe at the top of the page, the third line, the words, "And the 

 intervening waters (Behring Sea)". Every one of those words is a 

 forgery — interpolated. The original reads thus: 



The other ship, however, (sailing from Petropavlovsk), having examined the east- 

 ern coast of the Kamchatka peninsula up to 62° of northern latitude, and the west 

 coast of America from this latitude to the island of Uualaska, should proceed to 

 Ivadiak and from there to Sitka for the winter. 



But this ingenious gentleman makes it read: 



From this latitude to the Island of Ounalaska and the intervening waters (Behring 

 Sea) should proceed to Kodiak. 



