334 ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 



We will now quote Mr. Morgan wlio was the agent in 1891 of tbe 

 Russian Sealskin Company, of !St. Petersburg. He was on the Pribilof 

 Islands in 18G8 and 1869, and from 1874 to 1887 as agent of the lessees. 

 His testimony is abstracted on page 235 of the same volume. He says : 



Jlie Alaslca fur-seal breeds, I am thoroughly convinced only upon the Frthilof Islands; 

 that I have been on the Ahiska coast and also along the Alentian I.slands; that at no 

 points have I ever observed seals haul out on land except at the Pribilof Islands, 

 nor have I been able to obtain any authentic information which causes me to believe 

 such is the case. 



The Alaska fur-seal is migratory, leaving the Pribiloff Islands in the early winter, 

 going southward into the Pacific and returning again in May, June, and July to said 

 islands. I have observed certain bull-seals return year after year to the same place 

 on the rookeries, and I have been informed by natives that have lived on the islands 

 that this is a well known fact, and has been observed by them so often that they 

 stated it as an absolute fact. 



I was on the Bering Island at the same time that Sir George Baden-Powell and Dr. 

 George M. Dawson, the British rejiresentatives of the Bering Sea Joint Commission, 

 were upon said island investigating the Russian sealeries upon the Komandorski 

 Islands; that I was present at an examination, which said Commissioners held, of 

 Sniegeroff. the chief of the natives on the Bering Island, who, prior to the cession 

 of the Pribiloff Islands by Russia to the United States, had resided on St. Paul, one 

 of the Pribiloff Islands, and that since that time had been a resident on said Bering 

 Island, and during the latter part of said residence had occupied the position of 

 native chief, and as such superintended the taking and killing of fur-seals on said 

 Bering Island; that during said examination the Commissioners through an inter- 

 preter, asked said Sniegeroff if there was any difference between the seals found on 

 the Pribiloff' Islands and the seals found on the Komandorski Islands ; that said Snie- 

 geroff at once replied that there was a difference, and on further questioning stated 

 that such difference consisted in the fact that the Komandorski Island seals were a 

 slimmer animal in the neck and flank than the Pribiloff Island seals; and further, 

 that both hair and fur of the Komandorski Island seal were longer than the Pribi- 

 loff Island seal; said Commissioners asked said Sniegeroff the further question 

 whether he believed that the Pribiloff' herd and the Komandorski herd ever mingled, 

 and he replied that he did not. 



Now Mr. Morgan is also engaged to a great extent and on a large 

 scale in business. He is engaged in dressing and dyeing the skins. 

 He says at page 236: 



The skins belonging to these several catches are catalogued separately, sold sepa- 

 rately, and are of different values and necessarily, tberefore, bring dilferent prices 

 in the market. 



There is no better test after all than this. The money value of the 

 skin in the open market is shown not by the sales made in this year, or 

 last year, but made year after year. 



Sir Charles Kussell. — He does not say that on page 236. 



Mr. CouDERT. — I am reading from the summary of the evidence. 

 Then he says: 



The differences between these several classes of skins are so marked as to enable 

 any person skilled in the business to readily distinguish one from the other. 



Mr. Justice Harlan. — You are not reading from the printed Argu- 

 ment, and we are unable to follow you, Mr. Coudert. 



Mr. CouDBRT. — I am reading from the summary of the evidence. It 

 is volume 2 of the appendix, page 569. 



I will now read from page 237 of the Argument quoting from Mr. 

 Poland, page 571 of the same book. Mr. Poland's qualiti(;ations were 

 of the best. He is a subject of Her Majesty and the head of the firm 

 of P. K. Poland and Sou doing business at 110 Queen Victoria Street 

 in the City of London. His firm had lasted over a 100 years, having 

 been founded by his great grandfather in the year 1785, and if there is 

 anything in heredity, he ought to understand all about seal skins. His 



