358 ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 



This gives official information and it would take a great deal of 

 time for me to read tliem or to study them before the Court; but if the 

 Court has any doubt in its jnind about the truth of the statement in the 

 case which sums up the whole situation, it should be found iu those 

 charts — may I take the liberty of suggesting tluit the learned President 

 is not looking at one of the charts I call attention to — it is a valuable one, 

 but it is a table of vessels. Besides that we have the charts showing the 

 localities in which the vessels were seized. There are several between the 

 two pages that I mentioned. 



General Foster. — Page 574 is one of the most descriptive. 



Mr. CouDERT. — iSTo thing can be more conclusive than that because 

 the localities where the seals were taken are pointed out, fr(»m day to 

 day, from the logs. 



The President. — It seems mostly between the Pribilof Islands and 

 the Aleutian chain. 



Mr. Coudert. — Tow^ards the South and West. 



Sir Charles Kttssell. — The South and West, I think you mean? 



Mr. Coudert. — South, South-east, and South-west, are the principal 

 localities or directions in which these vessels are found. 



That of course only re])reseuts the few vessels that were actually 

 seized. Tlie Tribunal will understand that these nuips are made from 

 materials furnished by the sealing vessels themselves — that these data 

 are taken from the log books of these vessels. 



The President. — Mr. Coudert, you will observe that these maps are 

 not quite conclusive and complete as to the locality — the places — w^here 

 the seals have been taken, because as my learned colleague Mr. Justice 

 Harlan suggests the ])laces where the sealing vessels have been seized 

 upon or wiiere they have cruised is mostly indicated as lying between 

 the Pribilof Islands and the Aleutian chain, that is to say, in the very 

 route of the herds, as swimming towards tiui Pribilof Islands. 



Mr. Justice Harlan. — They might have been swimming away from 

 the islands. 



The President. — Yes. 



Mr. Coudert. — But they had all gone to the islands before that. 

 They run up in April, May and June. 



The President. — The seizures are more important than the jjlace 

 "where they are made. 



Mr. Justice Harlan. — Mr. Coudert means to say as I understand it, 

 that taking the date and the place together it proves that at a given 

 distance from the island, ascertained from these logs, seals were taken 

 in milk. 



Mr. Coudert. — Yes. 



Mr. Justice Harlan. — And therefore the seals had travelled that 

 long distance from the island wliile jiups w^ere on the land. 



Mr. Coudert. — Yes. 



Sir Charles IIussell. — Will my learned friend ])oint to any evi- 

 dence showing that, because these dates are all given and they are in 

 July and August. The herd, as my friend calls it, breaks up in July. 



Mr. Justice Harlan. — I did not so understand it. 



Sir Charles Kussell. — It begins to break up in July. 



The President. — The question is whether these seals are in process 

 of migration, or whether they are merely wandering with the spirit to 

 return again to the islands. That is what we want to make quite clear. 



Mr. Justice Harlan. — The question Mr. Coudert was discussing was 

 as to whether seals in milk were taken at a long distance from the 

 Islands. 



