356 ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 



Mr. CouDERT. — I cannot locate tlieni, but I say that there is testi- 

 mony the feeding grounds are 60 miles and 100 miles oif. 



Senator MorCtAN. — I understaiul the testimony to show that the 

 feeding- grounds change, that the iishes congregate at one phxce one 

 year, and at another place anotlier year. 



Mr. CouDERT. — And that they are at great distances from the island, 

 the seals congregate for the purjwses of food and are found there in 

 great numbers, and it is the only way in which you can explain it. 

 There is nothing else. 



The President. — Do you think those feeding grounds might be 

 excepted by establishing a zone? 



Mr. Coudert. — Eo, they are* too variable. Of course, they change. 



The President. — That was the purport of the question of my learned 

 friend. 



Mr. Coudert. — They change, and it is stated in the case that there 

 are feeding grounds to which these animals resort at a great distance 

 from the islands and it is a mockery to talk of restricting the zone to 

 20 miles. 



The President. — I would like to ask if there is any evidence that 

 these seals met at such a distance from the Pril)ilof Islands are always 

 seals wandering from the islands or may they be seals swarming 

 towards the islands. 



Mr. Coudert. — Xo, they are onr seals. That is conceded in this 

 way: the British Commissioners themselves say (and, as I have said, 

 the value of a concession from them is great — I conceive it to be even 

 more valuable than one from my learned friend, Sir Charles liussell) — 

 they say, certain females in milic are caught «i (jreat dkianccs and there- 

 fore, presumahly, from the Fribilof IsIancLs. There is no pretence that 

 there are any others there, and it is a fact in the case (I am not talking 

 now of disputed facts) that all these seals at some time during the year 

 land and live and stay there; and when they leave, they always leave 

 with the animus reveriendi. The animus rercrtendi exists in their 

 minds and, I was going to say, in spirit, if they have any — but it 

 always exists when they go for a day or when they go for a season. 

 When the mother absents herself she stays away, sometimes a week, 

 and returns to feed her young; the vitality of this animal is so great 

 that the young pup can remain after a few days or weeks, when he has 

 acquired some strength, a considerable time without food. 



The President. — Will you be kind enough to remind me again what 

 is the distance from the Pribylof Islands to the Alaskan continent. 



Mr. Coudert. — A little over 200 miles and it is 400 or 500 to Eussia 

 the other side. 



Sir Charles Eussell. — The nearest land is between two and three 

 hundred miles away. 



Mr. Coudert. — To America that is the nearest land. 



Sir Charles Eussell. — The learned President was asking about 

 the nearest land. 



Mr. Coudert. — He asked the distance to Alaska. 



The President. — I meant to the continent. 



Mr. Coudert. — It is over 200 miles. Sir Charles Eussell says it is 

 between two and three hundred miles. 



The President. — With regard to these feeding grounds, is it known 

 whether they are more on one side than on the other side of the Pribi- 

 lof Islands? Are they towards Eussia or America — do you know about 

 that? 



Lord Hannen.— I think you will find that 182 miles is the distance 

 from the islands to the nearest part of the Aleutian chain. 



