ARGUMENT OF CHARLES B. WARREN. 1147 



THE PRESIDENT : And that is 16 miles. That is wide enough ; but 

 it is not as wide as you suggested before. It is very difficult to read 

 these figures. 



JUDGE GRAY: You will observe that the short line from North 

 Point across to the mainland is only 6 miles. 



MR. WARREN : Yes, your Honour. I was about to comment on the 

 various lines which have been drawn across from shore to shore, or 

 from point to point, across that particular body of water. 



JUDGE GRAY : Every other line, it seems to me, upon looking at the 



chart, except that 6-mile line, encloses part of the open sea. 

 692 MR. WARREN : Your Honour, that statement practically sums 

 up my argument as to that particular body of water. 



If the Tribunal please, I shall not take up each of these charts 

 that have been submitted, and discuss in detail the various lines 

 drawn thereon. They are filed with the Tribunal ; and the lines show 

 various outside lines that might be drawn from shore to shore. The 

 lines drawn across these great bodies of water on these shores, if 

 drawn in accordance with actual constructions by the legislature of 

 Newfoundland, would be so indefinite, and so vague, that they could 

 not possibly furnish a basis upon which the Award of this Tribunal 

 could be founded. 



[Thereupon, at 12 o'clock, the Tribunal took a recess until 2 

 o'clock p. m.] 



AFTERNOON SESSION, MONDAY, JULY 11, 1910, 2 P. M. 



THE PRESIDENT: Will you please continue, Mr. Warren? 



MR. WARREN : Mr. President, resuming the discussion which was 

 engaging my attention just preceding the adjournment in connection 

 with the argument based upon the charts, showing lines of various 

 lengths drawn across all these so-called geographical bays, I refer 

 now to all the charts, not only to No. 2440, but the other charts 

 handed to the Tribunal, showing the lines across all the bays on the 

 non-treaty coasts, and in some instances on the treaty coasts for pur- 

 poses of illustration. 



I desire to refer to the fact that there is no evidence before this 

 Tribunal that there was any map before the negotiators of the treaty 

 of 1818. Without intending to attribute any unworthy motive to 

 counsel for Great Britain, I desire to state that the conclusion might 

 be drawn, from the manner in which the subject was presented, that 

 there was a map before the negotiators of this treaty. 



All of the protocols of the conferences in 1818 are found in the 

 Appendix to the Case of the United States on pp. 308 to 317. Ac- 

 cording to the protocol of the first conference the proceedings were 



