390 ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 



We will begin by producing wliat may perhaps be the most satis- 

 factory evidence, starting', of course, with this idea — that it s a fact 

 in the case that more than half these animals are females; but I 

 ought to preface my reading with this remark, that we took the testi- 

 mony of a large number of British subjects, men who, certainly as far 

 as nationality is concerned, would not be prejudiced in our favor. We 

 went to the most respectable sources in England and in France; we 

 found the very best men — the best because they knew the most about, 

 and stood the highest in the business ; and our friendson the other side 

 had the opportunity to cross-examine them. Now in some cases they 

 did cross-examine — perhaps in all cases — but they have given us, in a 

 few cases, tlie result of that cross-examination; and wherever they 

 have done it we have stated it in these printed extracts. 



Sir Charles Eussell. — Yes, but not giving it in full in any of 

 them. 



Mr. CouDERT. — That may be. You can use this for what it is worth. 

 There is no misleading; because when we say that cross-examination 

 appears in the British Counter Case at a certain page, it is manifest 

 that we do not pretend to give what is there — we refer you to it. 



The tirst witness called is. 

 H. S. Bevington. — Head of tlie firm of Bevington and Morris, FiirrieTS, London. 



(Case of the U. S., Appendix, voL II, p. 551.) 



It appears ttiat the above firm was founded in the year 1726 and that deponent has 

 been in the business ever since 1873. He says: 



That the Copper and Ahislca slvins are almost exclusively the skins of the male ani- 

 mal, and the skins of the Northwest catch are at least 80 per cent of the skins of the 

 female animal. That prior to and in preparation for making this deposition depo- 

 nent says he carefully looked through two large lots of skins now in his warehouse 

 for the especial purpose of estiniating the percentage of female skins found among 

 the Northwest catch, and he believes tlie above estimate to be accurate. 



Mr. Bevington's cross-examination appears in the British Counter Case, Appen- 

 dix, vol. II, page 249; he has nothing to say upon the above subject. 



Now whether we state this correctly, or not, we certainly facilitate 

 the investigations of the Court, and our friends on the other side, by 

 giving them the references. 



Now the next is: 



Alfred Fraser, member of the firm of C. M. Lampson and Co., of London. 

 (Case of the U. S., Appendix, vol. II, p. 554.) 



Mr. Eraser is 52 years of age, and a British subject, residing in the United States. 



The great majority of the skins sold from the Nt)rthwest catch are the skins of 

 female seals. Deponent is not able to state exactly what proportion of skins are 

 the skins of females, but estimates it to be at least 85 per cent. 



The next is 

 Walter E. Martin, Head of the firm of C. W. Martin and Sons, Furriers, Loudon. 



{Case of the U. S., Appendix, vol. II, p. 569.) 



The above firm have for many years dressed and dyed over 110,000 skins per 

 annum. 



Deponent has made no computation or examination which would enable him to 

 say specifically what proportion of the Northwest catch are the skins of the female 

 seal, but it is the fact that the great majority, deponent would say 75 to 80 per cent, 

 of the skius of tbis catch are the skins of the female animal. 



Mr. Henry Moxen, furrier of London was then examined. This very 

 witness has a direct examination by the British Government; audit 

 is evident, from the language he uses, and by his phraseology, that he 



