ARGUMENT OF SIR JAMES WINTER. 983 



THE PRESIDENT: If I understand you correctly, Sir James, you 

 mean that because there are two coasts of Labrador, they use the term 

 in the plural? 



SIR JAMES WINTER: Yes. 



THE PRESIDENT : But then would it not have been the consequence, 

 in the treaty of 1818 if you will have the kindness to look at the 

 Treaty, at p. 30 of the British Appendix that also they are speaking 

 of two coasts of Newfoundland, the western and northern coast of 

 Newfoundland ? 



SIR JAMES WINTER : No. With all respect, I take issue upon that. 

 I say that the western and northern coast of Newfoundland is one 

 coast, and is intended by the parties to mean one coast. By looking 

 at the n%ap it will be seen that, being all within one limit, from Cape 

 Kay to Quirpon, it is described as one coast, with the two adjectives, 

 western and northern, prefixed to it. It is one coast, described as 

 " western and northern." 



SIR CHARLES FITZPATRICK: You see, unfortunately, on p. 89, they 

 speak of the southern and eastern coasts of Labrador. 



SIR JAMES WINTER : That is what I call attention to. 



SIR CHARLES FITZPATRICK: Then why not have used the word 

 " coast " there on the southern and eastern coast of Labrador ? 



SIR JAMES WINTER: Because they are understood as two distinct 

 coasts, being referred to as the southern coast, the eastern coast and 

 the northern coast. The three taken together are described as the 

 coasts. And that would further appear from the description that is 

 given of the southern coast, namely, from Mount Joli to Esquimaux 

 Bay, which clearly corresponds with the idea, or fits in with the idea 

 of the southern coast. Then there is an eastern coast and a northern 

 coast. 



The first cross which I have made on the map that has been handed 

 up to the arbitrators shows Esquimaux Bay. 



THE PRESIDENT : And the second is Huntingdon Island, further up ? 



SIR JAMES WINTER : And the second is Huntingdon. That is the 

 one referred to in article A, on p. 89 : 



" the southern and eastern coasts of Labrador, which extends from 

 Mount Joli to Huntingdon Island." 



So that, by that offer, they got these two coasts, the southern and 

 eastern coasts of Labrador, as far as Huntingdon Island. 



Then, having proceeded so far with the negotiations, and the offer 



having been made by the British Plenipotentiaries down to 



591 Huntingdon Island, and no further, the next step to which I 



will call the attention of the Tribunal is to be found on p. 91, 



dated the 7th October, 1818 : 



"Mr. Gallatin and Mr. Rush present their compliments to Mr. 

 Robinson and Mr. Goulburn, and beg leave to send them the enclosed 



