ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 355 



following statement, which corroborates the foregoing: Captain Donald McLean, one 

 of our most successful sealing captains, and one of the lirst to enter into the busi- 

 ness of tracking seals from California to Behriug Sea, informs me he has known 

 bands of seals to travel one hundred to two hundred miles a day, feeding and sleep- 

 ing during a portion of this time. Captain Bryant, with long experience as master 

 mariner of a whaling vessel, states that he is convinced that a seal can swim more 

 rapidly than any species of lish, and that a female could leave the islands, go to the 

 fishing grounds a hundred miles distant and easily return the same day. But in 

 case these excursions consumed a longer time, the peculiar physical economy of the 

 pup seal makes it possible for it to exist several days without nourishment. 



Now let me, before passing to any other subject, call the attention of 

 the Court to the enormous amount of valuable information contained 

 in those few brief extracts, and to assure the Conrt, as the Court may 

 readily satisfy itself, that every one of these statements is substanti- 

 ated not only on its face, as I have shown, but also by a large mass of 

 independent testimony which it is impossible to discredit; you there 

 have most important facts bearing on some of the vital questions in 

 the case. You will understand now how it is that these nursing 

 mothers are killed 150 miles from the land, or even more, as they are 

 full of milk, and how it is that the unfortunate pups at home are killed 

 by starvation. You will also understand that it is difticult for the 

 Counsel of the United States to speak with becoming patience of the 

 scheme proposed by the British Commissioners when they i)ropose to 

 establish a protective zone of 20 miles about the islands, when it is 

 manifest that this would be absolutely useless, for the destructive 

 process only begins beyond that line and it is simply the semblance of 

 granting something while really extending the privileges of pelagic 

 sealing. You will certainly lind that no pelagic sealer, however zeal- 

 ous in the practice of his so called industry will object to that scheme. 

 He does not come within the 20 miles nor catch any seals within that 

 zone. The facts stated here that there is this large number of seals 

 constantly upon the land, explains the scarcity of fish, and it is also 

 apparent that there are feeding grounds, that is, ])laces where enor- 

 mous masses of fish congregate and to Mdiicli the seals resort. When 

 I say seals, 1 mean, of course, only female seals, because the males, the 

 bulls, 7iever leave the islands. The young animals stay around the 

 islands, disporting themselves in the water and getting such food as 

 they may, but the mothers, under the strong impetus of nature's law 

 which tells them that they must feed their young by feeding them- 

 selves, first go with their enormous facilities of locomotion, — I inight 

 say unparalleled facilities of locomotion, — to these feeding grounds 

 which they know, and there they are pursued, they are slaughtered. 

 Hence the overwhelming preponderance of pelagic destruction is among 

 the females. 



The President. — Is there any evidence that those feeding grounds 

 are known — that they are located in some particular place? 



Mr. CouDERT. — There is this evidence, as stated in the book, that 

 there are feeding grounds and that the seals congregate there; they 

 are found there in great masses. 



The President. — Are they certain points which are known, and of 

 which the latitude and longitude may be described"? 



Mr. Coudert. — It is difticult to fix the locality exactly on the sea, 

 but they say, and the evidence is abundant, that there are feeding- 

 grounds 60 miles and 100 miles from the islands, to which these mother 

 seals resort in great numbers, and, of course, they are pursued there 

 and slaughtered. 



Sir Charles Russell. — Will my learned friend point to any evi- 

 dence that locates these feeding grounds"? 



