1336 NORTH ATLANTIC COAST FISHERIES ARBITRATION. 



of it; that the territorial waters of the United States were to be 

 found somewhere south of the line and the British waters were to be 

 found somewhere north of it. But I humbly submit that the fixing 

 of a boundary-line is for the purpose of showing where the boundary- 

 line is not at all to indicate the place where there is no boundary- 

 line and to show that the limits of the territorial waters of the 

 parties are some place else. 



Mr. Warren seemed to be reduced to that position by the fact that 

 10 miles here (indicating on map) is too wide. The parties seemed 

 to be dividing that water between them; and that is what we say 

 they did. Mr. Warren thinks not. Very well, on this chart there is, 

 up in the corner here, an indication of a line which is said to separate 

 the sea from the inland waters; and that line commences from Dun- 

 geness Point here, curiously enough, it is an English name, and 

 sometimes used in England in this same connection from Dunge- 

 ness Point, here, over to Cattle Point, there (indicating on map). 

 The reason that the line is drawn there as separating the sea from 

 the inland waters, no doubt, is that that is the first place at which 

 they get two points of land both in United States territory. They 

 do not draw it out here (indicating the Straits) because only one end 

 of the line would be upon United States territory. The distance at 

 the place where the line is drawn serves my purpose much better, as 

 it happens, than between the two banks of Fuca Straits, because at 

 this place the distance is l\ miles, whereas in the Fuca Straits it is 

 only about 10 miles. 



The next item that I cite in that connection, and I only mention 

 it because Sir Robert Finlay referred to it, is the treaty between the 

 United States and Mexico. It is quite open to the observation that 

 Mr. Warren made about it, that it was only an arrangement between 

 two countries. So it was, but one of the countries was the United 

 States; and the United States and Mexico were agreeing that their 

 boundary ran 3 leagues from land out into the sea. 



Then I wish to deal with the Alaska matter. Mr. Warren rather 

 found fault with our statement that the United States were claiming, 

 or had claimed the outside edge of the archipelago there, and he read 

 from the United States Counter-Case in the Alaska proceedings. 



Now, may I ask the Tribunal to be kind enough to take our book 

 of maps for the purpose of following where, according to the United 

 States Counter-Case, they did claim that their line ran. I refer to 

 map No. 15. The tribunal will see the number of the maps, up in 

 the right-hand corner. 



I read from the United States Counter-Case in the Alaska pro- 

 ceedings, American reprint, volume iv, at p. 32, and ask the Tribunal 

 to look at map No. 15 in this connection: 



