ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 369 



He then goes on to state that he has drawn a chart from memory, 

 which the court may look at. I am fully conscious that a chart drawn 

 from memory after many years is not as reliable as it might be, but it 

 simply expresses, in that form, the best recollection of a reliable witness 

 on the subject. 



The next passage is also from Mr. Mclntyre's evidence page 45. I 

 am reading from the same page of the Collated Testimony. 



That from the year 1870 there was au expansion of the areas of the breeding 

 grouuds, and that in the year 1882 they were as large as at any time during my 

 acquaintance with them. 



It was only subsequent to this period that the difficulty was found 

 with regard to getting the males. 



Now on page 267 of the Collated Testimony, Daniel Webster (and I, 

 may perhaps remind the Court again that Daniel Webster is conceded 

 to be a reliable, honest, and trustworthy witness), says: 



My observation has been that there was an expansion of the rookeries from 1870 

 up to at least, 1879, which fact I attribute to the careful management of the islands 

 by the United States Government. 



Twenty-four years of my life has been devoted to the sealing industry in all of its 

 details as it is pursued upon the Pribilof Islands, and it is but natural that I should 

 become deeply interested in the subject of seal lii'e. My experience has been prac- 

 tical rather than theoretical. I have seen the herds grow and multiply under care- 

 ful management until their numbers wore millions, as was the case in 1880. 



Now in connection with this, which is a very important subject not 

 only in a practical, but in what our friends the British Commissioners 

 call a transcendental jjoint of view, this assault upon the management 

 of the United States is one that we may well meet with abundant tes- 

 timony if we have it, and we have. 



In the Collated Testimony (the same book, page 257) there is the 

 evidence of Mr. Charles Bryant, one of the most experienced of them 

 all; he is constantly referred to, and constantly commented on, by the 

 other side. He says: 



I have examined the breeding areas of 1870, indicated by H. II. Mclntyre on 

 charts A. B. C. D. E. F. and G. of St. Paul Island, and they are, to the best of my 

 knowledge and belief correct. I have also examined the areas of increase shown 

 by him on the same charts as applicable to the breeding rookeries of 1882, and, they 

 are proportionately correct in 1877, the last year of my stay upon the islands, the 

 increase up to that time having been about half of that'shown by him. The above 

 statement is true also to the best of niy knowledge and belief, of the breeding areas 

 of 1870, and the increase of 1882, indicated by Thomas F, Morgan upon charts H. I. 

 J. and K. of St. George. 



We then have this on page 260 : 



From 1870 to about 1884 the seal rookeries were always filled ont to their limits 

 and sometimes beyond them. 



This witness is a priest of the Greek Church, General Foster reminds 

 me, and I may say in connection with the testimony of this reverend 

 gentleman that it is a matter about which he could not well be mis- 

 taken. It was not like counting. A man might say, " There are two 

 millions, or seven millions"; and it might be neither; but when he 

 says that certain places were covered this year that were not covered 

 last year, of course as to that he could not be mistaken. 



Now at page 263 we have the testimony of Mr. John M. Morton. He 

 says: 



I have already stated that my personal observation and investigation of the con- 

 dition at the islands from 1870 to 1878 inclusive, showed that during those years a 

 steady expansion of the breeding rookeries took jilace. I am also informed and 

 believe that such expansion continued up to the year 1882 or 1883. Daring this 

 period of general increase it is notable that the destruction of animals from pelagic 



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