360 ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 



The President. — WhicL is that? 



Mr. Coudert. — It is chart No. 6 which Mr. Phelps has pointed out 

 to me, ill the Americau case. 



Sir Charles Eussell. — At what page is it referred to in the 

 Counter-Case? 



The President. — It is slightly more satisfactory than the other 

 maps, because it shows that some of the seals cannot be mistaken as 

 being on the migration route — that was tbei)oint of my question. Those 

 ou the south between St. Paul and the Aleutian chain being on the 

 right, they might be taken for migrating seals — either migrating 

 towards the islands or from the islands. 



Sir RiOHARD Webster. — Wiiich chart is it? 



Mr. Coudert.— ISTo. 6 of the Counter Case. What I want to call the 

 attention of the learned President to, is the dates. Now would you, 

 Mr. President, look up the extreme North-west there? 



The President. — Yes, that is more significant I think. 



Mr. Co LTDERT. — The dates are August llth August 21 st J uly 29th and 

 August 3d and so on, 



I would also ask the Tribunal, at its convenience, to study another 

 map that Mr. Phelps requests me to submit as being an iujportaut one. 

 It is the Track Chart of the United St;ites Naval Ofticers in Behring 

 Sea; and it will show how thoroughly the aftair has been gone into, 

 and how complete the investigation has been. 



Mr. Justice Harlan. — What is the number of the map? 



Mr. Coudert. — The Counter-Case, Chart No. 4. 



Senator Morgan. — How many vessels, do you recollect, were en- 

 gaged in that work there? 



Mr. Coudert. — Seven. 



Senator Morgan. — Under the command of a Naval Officer? 



Mr. Coudert. — Yes; under Commander Ev^ans, who commanded the 

 force. 



Lord Hannen. — Can you refer me to the evidence relating to this 

 map, Chart No. G of the Counter-Case? Is there any evidence relating 

 to it, do you know? 



Mr. Coudert. — To show its authenticity? 



Lord Hannen. — No; not to show its authenticity, but to see what it 

 is about*? 



Mr. Coudert. — I do not know that anything can be said about it 

 beyond what it shows for itself. 



Lord Hannen. — Then I must say that I cannot count these things, 

 which I suppose represent seals. 



Mr. Coudert. — No; this is intended to show the track pursued. 



Lord Hannen, — I am speaking of the first map. 



Mr. Coudert. — I was speaking of the other. 



Mr. Phelps. — There is evidence of that. Every fact is iierfectly 

 proved. 



Lord Hannen. — Quite so. I only want to be referred to it, so that I 

 may look at it. 



Mr. Coudert. — That evidence I will call attention to later on, if I 

 may; but I understood that Lord Hauneii's question was directed 

 simply to the Track Map. I understand it now. 



Sir Charles Russell. — No. 6 is Entitled " Seals observed " simply. 



The President. — How many seals were observed, and at what 

 season ? 



Mr. Coudert. — I shall give the Tribunal some testimony ou that; as 

 I say, I have to take it stej) by step. 



