ARGUMENT OP CHARLES B. WARREN. 1145 



MR. WARREN : The words of the Act are as follows : 



"The use of trawls and bultows is prohibited on the fishing 

 grounds from the west point of Hillier's Harbor to Pyramid Point 

 near Cape Rogue, White Bay." 



That places Cape Rogue in White Bay. 



JUDGE GRAY : Where is Cape Rogue ? 



MR. WARREN: Does the Tribunal see Groais Island on the chart, 

 just off the coast? 



JUDGE GRAY: Yes. 



MR. WARREN : Right inside of it will be found Cape Rogue. 



JUDGE GRAY : Inside of it on the coast ? 



MR. WARREN : Yes, your Honour. 



THE PRESIDENT : Yes ; here it is. 



JUDGE GRAY : Yes. I see it now. 



SIR CHARLES FITZPATRICK: If you get Hillier's Harbour and get 

 Pyramid Point, and then draw a line across, it is clear what Mr. 

 Warren means. 



JUDGE GRAY: The language of the second paragraph of this sec- 

 tion 64 would seem to describe the coast south of Cape Rogue as 

 part of White Bay. 



MR. WARREN : That is my contention, if your Honour please. 



SIR CHARLES FITZPATRICK : On this map is there a line drawn from 

 the west point of Hillier's Harbour to Pyramid Point? 



MR. WARREN : From the west point of Hillier's Harbour ? 



SIR CHARLES FITZPATRICK : Yes ; to Pyramid Point ? 



MR. WARREN : Hillier's Harbour is opposite Belle Island. 



SIR CHARLES FITZPATRICK : I am asking you whether or not there is 

 a line drawn on this map that you submitted to us from the west 

 point of Hillier's Harbour to Pyramid Point, near Cape Rogue ? 



MR. WARREN : Well, Sir Charles, there could not be any line drawn 

 there between opposite shores, because the coast is almost straight. 



SIR CHARLES FITZPATRICK : Yes. What does the statute refer to ? 



MR. WARREN : The statute refers to Cape Rogue as being in White 

 Bay. 



SIR CHARLES FITZPATRICK: The statute refers to the "fishing 

 grounds from the west point of Hillier's Harbour, near Cape Rogue." 



MR. WARREN (reading) : " Cape Rogue, White Bay." 



SIR CHARLES FITZPATRICK : Well, that is a matter of construction 

 whether or not that is in White Bay at all, or not. 



MR. WARREN : I shall refer to but one more illustration of this sort 



from the statutes of Newfoundland; the first paragraph of 



691 the same section. I read the words of the first paragraph from 



the statute, section 64, on p. 209 of the Appendix to the Case 



of the United States : 



" The use of cod- traps is entirely prohibited in Port-au-Port Bay; 

 that is to say, in East and West Bay, and extending from Long Point 



