416 OKAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 



drawn a red line, and I liave put the names of the vessels, the "Caro- 

 line" and "Eliza;" and the place where that is to be found in the British 

 Case is page I'O. The year is 1799. The nationality, so far as it could 

 be ascertained, which is indicated by an initial, in that case happens to 

 be American. Tliat was a case in the year 1799, when the " Eliza" vis- 

 ited Sitka. The next in 1802 was a vessel called the "Jenny"; and 

 then if you will look at Behring Bay, you will find the "Jackal", a 

 British ship, 1792 to 1794. Then opposite Mount St. Elias, which was 

 mentioned in reference to it, you will find La Perouse went in a French 

 vessel in 1786, mentioned in the British Case at page 17. 



Now I desire to call attention to two localities well-known now. Cooks 

 Inlet and Prince William's Sound; and I call attention particularly to 

 this. Prince William's Sound is about 200 miles to the westward of the 

 line of boundary, or latitude 60^'; and Cooks' Inlet is considerably 

 further. 



Then, Mr. President, if you will observe with reference to Prince 

 William's Sound, there are several cases of vessels going there. The 

 "Phoenix", which was a British ship; ithe "Fidalgo", a Spanish ves- 

 sel, both in 1790. Portlock and Dixon were there in 1786 to 1789; and 

 Vancouver in 1794. Then, if you go to Cook's Inlet, Douglas was there 

 in the year 1791, the name of his vessel was, I think, the "Iphigenia"; 

 and Portlock and Dixon also and Vancouver. Then, the Spaniards vis- 

 ited Kadiak, in 1788; and in 1800 the "Enterprise" and in 1808 the 

 "Mercury", both being British ships. Then, if you will run your eye 

 along to ITnalaska, you will find that was visited by the Spaniards in 

 1788; and by a man whose voyages are well known, Meares; and the 

 Island of Atka was visited — also by Meares in the years 1785 and 1786. 



Then, on the coast of Kamschatka, you will find two voyages to a 

 place now known as Petropaulovsk — in 1792, the "Halcyon" and the 

 "Flavia" and, as you will be good enough to run your eye to the extreme 

 North, where you will find a mark put of Pigott's voyages (to which I 

 shall make reference later) as far as Kotzebue Sound; and I shall show 

 you, by the correspondence, he had been trading all along the coast 

 of Kamschatka as well as visiting parts of the coast of America in Beh- 

 ring Sea. 



Now I may be permitted to remind you that the whalers of 1842 were 

 in Behring Sea. I have merely indicated it and given the reference to 

 it. It is in the British Case, page 83, so that even from what we are 

 able to trace in respect of a district comparatively speaking, of course, 

 little opened up, there had been substantial trading, and this will be 

 found to have been the main ground of the attempted action by Russia — 

 there had been substantial trade to various places well to the north, 

 using the expression of my learned friend, Mr. Carter, of latitude 00°. 



Therefore, upon the face of this information, you would not expect to 

 find the North- West Coast was to have the limited meaning which my 

 learned friend, Mr. Carter, wishes to give to it. 



Mr. Justice Harlan. — Is this a copy of a map of any particular date 

 as to the names and spelling, and so on? 



Sir EiCHARD W^EBSTER. — It Is the Map N" 1 of the United States 

 Case — Behring Sea, North Pacific. I do not think they give the date. 

 I merely used it because it happened to be the most convenient to 

 put the names on. It has no value beyond being distinctly authentic 

 as coming from the United States — but upon that I wrote down those 

 names, taking them myself from the Case — the dates, boats, and the 

 voyages; and I desire, before I break off to point out that while I am 

 going to show you that complaints of trade along these coasts led to 

 the action of Eussia, it is idle to suppose that we know anything like 



