ORAL ARGUMENT OF FREDERICK R. COUPERT, ESQ. 335 



judgment is entitled to great respect, and he says on page 571 of vol- 

 ume 2 of the Appendix to the case of the United States : 



That the three classes of skins are easily distiuguishable from each other by any 

 person skilled in the business or accustomed to handling skins in the raw state. 

 That deponent has personally handled the samples of the skins dealt in by this firm 

 and would himself have no difficulty in distinguishing the skins of the Copper Island 

 catch from the skins of the Alaska and north west catch, by reason of the fact that 

 in the raw state the Copper Island skins have a lighter colour and the fur is rather 

 shorter in pile and of an inferior quality. The skins of each of the three classes have 

 different values and command different prices in the market. 



Kow I shall read some of the evidence of Mr. George Eice on page 573 

 of volume 2 of the Appendix to tlie United States Case. Mr. Kice, I 

 may say, is another of that class of witnesses entitled to particular 

 respect. 



[The Tribunal then adjourned for a short time.] 



The President. — Mr. Coudert, if you are ready, we are. 



Mr. Coudert. — Thank you, Sir. I propose, may it please you, l^Ir. 

 President and the members of this High Tribunal, to close this exami- 

 nation and reading of extracts by two or three very brief passages on 

 the same subject, viz, the intermingling of herds. I shall read but 

 three or four lines (it will not be worth while to trouble the Court to 

 look at the book), from the second volume of the Appendix to the 

 United States Case, on page 438, the testimony of Alexander McLean. 

 He is asked : 



In your opinion, do the seals on the Russian side intermingle with those on the 

 Pacific side or are they a separate herd? 



That is a pointed question and deserves a categorical answer. He 

 says: 



They are a different herd of seals altogether. 



Then Daniel McLean is asked the same question on page 444 of the 

 same book : 



In your opinion do the seals on the Russian side intermingle with those on the 

 Pacific side? — (A). No, Sir, I do not think so. They are different seals in my 

 opinion. 



I may say with regard to both of these witnesses, that they are 

 vouched for by the Canadian Inspector of Fisheries in his Eeports of 

 188G, page 207, and mentioned by him in such a way that we have a 

 right to read their testimony with the confidence that it will be accepted 

 on these points. This is the testimony of these two men and I propose 

 (stating to the Court that what I have read is only a small part of the 

 testimony which we claim to be overwhelming on this subject), to read 

 from the evidence of Mr. Morris Moss. His testimony should be read 

 because of his high position in connection with this business. 



Mr. Morris Moss testifies at page 341 of the same book, volume 2, of 

 the United States Appendix. Mr. Moss, I should say, (and this is the 

 reason I have selected his testimony out of the great mass that I have 

 before me), is the vice-president of the Sealers' Association of Victoria, 

 presumably acquainted with the business, and testifying with knowl- 

 edge of the subject. He says: 



There are two great herds or armies of fur-seals that frequent the North Pacific 

 Ocean and Behring Sea. They are quite distinct from each other, and do not inter- 

 mingle. The one army appears oft' the coast of California, in the latter part of 

 December, and gradually work their way northward, and are joined by others coming, 

 apparently, from mid-ocean. 



They appear to travel in two columns, the outer column containing an army only 

 of bulls, and the inner one mostly cows and yearlings. These columns are not con- 



