724 APPENDIX TO COUNTER-CASE OF GREAT BRITAIN. 



tlie rest of our catcli no one could pick out one from tlie otber, tliou^sjli 

 we, of course, kuew them, having kept them apart and put them up by 

 themselves. 



I consider that the seals need protection, but it should apply to the 

 breeding-islands more than to the coast, for I cousider there is more 

 harm done to seal life by their manner of killiug there and by their prac- 

 tice of killing all bulls. 



We get very few old bulls. 



I have never picked up a dead seal or " stiuker," but have seen two 

 picked up that had not been long in the water, as they were quite fresh. 



I have not been paid nor promised anything in consideration of hav- 

 ing made the foregoing statement, which I have read over and found 

 correct. 



(Signed) Lee J. Thiers. 



Subscribed and sworn to before me, this 29th day of November, 1892. 

 [seal.] (Signed) Lincoln Sonntag, Notary Public. 



Deposition of Warren F. Upson. 



State of California, City and County of San Francisco. 



Warren F. Upson, of San Francisco, being duly sworn, deposes and 

 says: 



I will be 57 years of age on the 4tli January next, reside in San Fran- 

 cisco, and have lived here for over twenty years, and am an American 

 subject. 



I have been a hunter of fnr skins for the past twenty years, and com- 

 menced killing seals about thirteen years ago as a business; previous 

 to that time I was sea-otter hunting altogether, though would occasion- 

 ally kill a few seals. Was otter-huuting principally amongst the Kurile 

 group up to the time I commenced seal-hunting, and was as familiar 

 with all the islands of the group as I am with the streets of this city, 

 from Cape Nogshaf to Kamtchatka, and know that there were no rook- 

 eries at that time on those islands. I know Kakoke, Moo-shire, and 

 Shrenoi Kocks between Ushisir and Shiaskotan, and, to my knowledge, 

 there were no rookeries on them during my otter-hunting days, but I 

 learned since that Captain Miner has taken a large number of seals on 

 some of those rocks, and I account for the fact that they were driven 

 from liobben Island in the Okhotsk Sea, for liobben Island has been 

 raided till there are, comparatively, very few seals landing there. I 

 was on the first schooner that raided Robben Island, the " Matinee," 

 fitted out by H. Liebes, T. P. H. Whitelaw, and Isaac Leonard, of this 

 city. This Avas about twelve years ago. This was the first and only 

 raid ever I made on rookeries. 



As near as I can remember, I hunted in the following vessels: pilot- 

 boat "Fannj^," schooners "Matinee," "Alexander," "Undaunted," 

 "City of San Diego," " Yanderbilt," "Kate and Ann," and "Active." 

 In some of these 1 have been hunting several seasons. I have sealed 

 on the American coast, Beliring Sea, on the Russian coast, oft" the Com- 

 mander Islands, also on the Japan coast. 



In crossing over this year to the south of the Aleutian group, going to 

 the Commander Islands, during the month of July I noticed seals more 

 or less in tlie passage. On our return in August it was so rough we 

 could not see anything, but I have come along there as late as Septem- 

 ber and noticed plenty of seals to the southward of 172nd Pass. I 



