348 ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 



But lie had been prepared to giveliis testimony to minimize the force 

 of ours, and be did for tbe first time corroborate our testimony to tbe 

 extent tbnt it was at least 75 per cent. 



The President, — But in fact, you have not answered Lord ITannen's 

 question, you know. I suppose you cannot. Perhaps nobody can. 



Mr. CouDERT. — If nobody can, I am sure I cannot, Mr. President; 

 but I would not Hke to make such an admission, and I am sure you 

 would not expect me, even by my silence, to admit that you can put any 

 question on this subject tliat I cannot answer. 



I will say this: I propose to show by testimony, which I take to be 

 overwhelming, that witnesses in this case have in handling these skins, 

 physically, as Mr. Moxon says, considered the question of sex, and that 

 they are able to testify that a certain proportion in every consignment 

 consisted of female skins. Now, if you ask me whether in the inner- 

 most machinery of the business there is au individual whose offlce and 

 function it is to pass upon the sex of the animal. . . 



Lord Hannen. — Ko, no — anyone who, in the course of his business, 

 would find it necessary to decide the question of sex. 



Mr. CouDERT. — I would answer it in this way, even if it should be 

 an imjierfoct answer: These skins, of course are costly and valuable. 

 They are thoroughly examined. Their condition has to be examined, 

 and in many cases they have to be repaired — perhaps in almost every 

 case, to a greater or less extent; and in examining them, the question 

 of sex presents itself to the examiner. An experienced examiner will 

 tell you just how many of each sex there are; and perhaps — that is a 

 mere hypothesis — this has become more marked of late years for this 

 reason, that the number of female skins in the market is only a recent 

 product. Until recently there were no female skins. It was only about 

 1876, 1878, 1879, 1880 and 1881 that this business began and took its 

 progression, that the three ships grew into fifty, and the fifty into a hun- 

 dred; and naturally these men examining the skins would observe the 

 sex. They could not help it. Even if I am unable to give a definite 

 answer to the enquiry, may I not satisfy the conscience of the Court, 

 when I produce credible witnesses who say, '' We did examine and we 

 know" ; even if I cannot dive into their motive; if I cannot show that 

 it was a part of their particular function in the business; if I produce 

 men of standing and character who say, "I have examined one hun- 

 dred thousand skins, and there were only five thousand males" ; shall 

 I not satisfy the Court upon this question, assuming that I shall pro- 

 duce such testimony? 



The President. — I suppose those are mostly sealers'? 



Mr. CouDERT. — Furriers, sir. I dismiss the sealers. 



The President, — Will you just allow me to read an extract from 

 Revillon. Revillon says: 



That all the skins bought by the said firm of Rdvillon Friires are dyed in France, 

 and therefore the skins pass under our eyes in the following conditions: (1) in salt 

 when we buy them in London; (2) dressed; (3) dyed. That deponent believes that 

 the firm of Rt^villou Frt^res is by far the largest firm of furriers and fur-dealers in 

 Fr.ance; that the greater part of tlie skins l>ought by Revillon Fri-rea are made up 

 into garments, cloaks and mantles, but that some of the skins after having been 

 dj ed are sold to otlier numufacturers. 



That the sales of sealskins by the said firm of Revillon Fri^res have amounted for 

 the last twenty years to about 4,000,000 francs per year. 



He knows the skins as they are in these three conditions, — in the very 

 condition of salt when they come from London. He proceeds: 



That later on, from the year 1878, we have noticed in the London market seal- 

 skins called Victoria or Northwest coast skins, the quantity of which is variable, but 



