ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 395 



contained. To perform the examination I detailed John J. Phelan. This man has 

 been in the employ of my father or of myself since the year 1868. I regard him as 

 one of the most competent and trnstworthy men in our service. I have read an afti- 

 davit verified by him on the 18th of June. I agree entirely with what he says con- 

 cerning his experience in the handling and dressing of skins, and from what I know 

 of his character and ability I believe that everything stated by him in this affidavit 

 is correct. 

 I am 35 years of age, a citizen of the United States. 



Then we supplement tliis affidavit by that of Mr. Phelan. 



(Case of the U. S., Appendix, vol. II, p. 518.) 

 He says : 



As a result of the work I have performed for so many years I am able to distin- 

 guish, without difficulty, the skin of a female seal from that of a male seal. There 

 are generally several ways in which I can tell them apart. One of the surest ways 

 consists in seeiug whether any teats can be found. On a female skin above the age 

 of 2 years teats can practically always be discovered; when tbe animal is over 3 

 years old, even a person who is not an exjiert at handling skins can discover two 

 prominent ones on each side of almost every skin. This is because after the age of 

 3, aud often even alter 2, almost all I'emales have been in pup. . . 



I have been able to test all my observations as to the teats on salted fur-seal skins 

 by following these skins through the various processes which I have described. 

 During these processes the skins become thinner and thinner, and the teats more 

 and more noticeable, and at an early stage in the dressing they must be wholly 

 removed. There are other Avays of distinguishing the skins of the two sexes. . . 



I was sent to New York from Albany a few days ago by Mr. George H. Treadwell, 

 with instructions to go through a certain lot of seal skins, which I understand he 

 had recently bought in Victoria, and to tind out how many of these skins were taken 

 from female animals. I have spent four days in doing this, working about seven 

 hours a day. 



There were several men who unpacked the skins and laid them before me, so that 

 all of my time was spent in examining the individual skins. The lot contained 3,550 

 skins. I found that, with the possible exception of two dried ones, they were taken 

 from animals this year; they were a part of what is known as the spring catch. I 

 know this to be the case by the fresh appearance of the blubber and of the skin as a 

 whole. This affords a sure way of telling whether the skin has lain in salt all win- 

 ter or whether it has been recently salted. I personally inspected each one of these 

 skins by itself and kept an accurate record of the result. I divided the skins accord- 

 ing to the three following classes: Males, females, and pups. In the class of pups 

 I placed only the skins of animals less than two years of age, but without reference 

 to sex. 



I found in the lot 395 males, 2,167 females, and 988 pups. Leaving out of account 

 the pups, the percentage of females was therefore about 82. 



The great majority of what I classed as male skins were taken from animals less 

 than 3 years of age. There was not a single wig in the lot. On the other hand, 

 nearly all of the female skins were those of full-grown animals. On every skin 

 which I classed among the females I found teats, with bare spots about them on the 

 fur side. Such bare spots make it absolutely certain that these teats were those of 

 female skins. 



With regard to the pup skins, I will say that I did not undertake to determine 

 whether they were males or females, because they had a thick coat of blubber, which, 

 in the case of an animal less than 2 years old, makes it very hard to tell the sex. 



All of the skins that I examined were either shot or speared. I did not keep a close 

 count, but I am of the opinion that about 75 per cent of them were shot. 



The result of the examination is about what I had expected it would be. The 

 figures only confirm what I have always noticed in a general way, that nearly 

 nine-tenths of the skins in any shipmento'f North west coast skins are those of female 

 animals. 



This examination, in connection with one other of the same kind, is, 

 I think, of very great importance. There is notbing loose — there is no 

 estimate about it. It is mathematical, and agrees with the testimony of 

 all the men who can be referred to, practically — that is of all those who 

 deal with the Northwest catch, hence it is of great importance. Here is 

 a man who bought a lot of skins without any special object, and for the 

 sole purposes of his business; and when the United States discovered 

 the fact they asked, him to count these skins. He takes them one by 



