398 ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 



Sir Charles Russell. — Is it au affidavit? I do not understaud it 

 to be an affidavit. 



Mr. CouDERT. — I do; and we state here that " lie made the following 

 swoiii statement to the United States Government." 



Sir Charles Russell. — If you look at your own page 302, I do not 

 think you will liiid that that is so. 



Air. CouDERT. — AVhen Counsel says "it is unsupported by any details 

 of fact," I do not precisely know what it means. 



Sir Charles Russell. — I assure you it is not a sworn statement at 

 all. We make no comment upon it. It is, of course, a statement to be 

 received with respect; but it is not sworn to. 



Mr. CouDERT. — Then I Avill read from page 367 ; and it is best to refer 

 to the passage: 



I, J. M. Crawford, Consul-general of the United St.ate,s at St. Petersburgli, do 

 hereby certify that Nichola A. Grebuitzki, military chief of the Connnaiider Islands, 

 ap])eared before me this day au-i declared, under oath, that all the statemeuts con- 

 tained iu the foregoing article, etc. 



I am glad that my learned friends on the other side w hen they spoke 

 of aUrihuthui had not read this, and evidently were misled by think- 

 ing of some other paper; or they would not have said it was unsup- 

 ])orted by any details of fact because Mr. Grebnitsky gives these details 

 of counting two lots of skins. Nothing can be more detailed than that; 

 and if I were not anxious to save the time of the Tribunal, — it is only 

 my anxiety to save the time of this High Tribunal that i)revents my 

 reading the whole of it; but I would recommend its perusal to the mem- 

 bers of the Court, and I think they will be repaid. 



Messrs. C. W, Martin and Sons examined these same skins, or a por- 

 tion of them, after they reached London; and found them to consist of 

 the following: Females, 83.76 per cent; males, 1.66 per cent, and of sex 

 doubtful 14.58 per cent. You will see that they substantially agree if 

 you make a reasonable allowance for what he calls those skins that were 

 doubtful. 



We then have the testimony of Mr. Loud, the Assistant Treasury 

 Agent of the United States on the Pribilof Islands : 



In July, 1887, I captured the poaching schooner Angel Dolly while she was hover- 

 ing about the islands. I examined the sealskins she had on board, and about 80 per 

 cent were skins of females. In 1888 or 188!.', I examined something like 5,000 skins 

 at Unalaska which had been taken from schooners engaged iu pelagic sealing in 

 Behring Sea, and at least 80 to 85 per cent were skins of females. 



Then Mr. Malowansky, who is one of the men who has been cited by 

 both sides, or, at all events, commented upon by both sides, and whose 

 opportunities for acquiring knowledge were exceptional. 



He has resided on the Commander Islands nine years as agent of the lessees, and 

 is well acquainted with all matters pertaining to the sealing business. 



He says: 



{Case of the U. S. A}}}}., Vol. II, p. 197.) 



In 1891 the schooner J. H. Lewis was caught near the islands by the Rnssian gun- 

 boat Aleut and found to have 416 skins on board. I made a personal examination of 

 these skins, and found that from 90 to 95 per ceiit were those of female seals. I 

 called. the attention of the English Commissioners, Sir George Baden-Powell and 

 Dr. G. M. Dawson, to this fact when they visited the islands in 1891, showing them 

 the skins. I opened a few bnndles of the skins for their inspection and ottered to 

 show all of them, but tbey said that they were satisiied witliout looking at any more 

 than tliose already ojjeued. I remember that a schooner from Victoria was also 

 seized at the islands about tliree years ago by the Russian authorities with 33 skins 

 on board, which were nearly all taken from female seals. 



Then Mr. Morgan is the next witness, whose testimony we produce. 



