164 APPENDIX TO CASE OF GREAT BRITAIN. 
145 [Inclosure 7 in No, 90.] 
Declaration of James Douglas Warren. 
Ciry or Orrawa, Province of Ontario, Dominion of Canada. 
I, James Douglas Warren, of the city of Victoria, in the Province of British Colum- 
bia of the Dominion of Canada, master mariner and ship-owner, do solemnly and 
sincerely declare as follows: 
1. That I am the duly authorized agent, by power of attorney bearing date the 4th 
November, A. D. 1886, of Thomas H. Cooper, of the city of San Francisco, in the State 
of California, one of the United States of America, the managing owner of the herein- 
after mentioned schooner ‘‘ W. P. Sayward.” 
2. That the said Thomas H. Cooper is, as I am informed and do verily believe, a 
British subject by birth, and has never renounced his allegiauce to the Sovereign of 
Great Britain. 
3. That the said schooner ‘‘W. P. Sayward” is a British vessel, having been built at 
Victoria aforesaid in A. D. 1882, and duly registered at the port of Victoria aforesaid, 
and was at the time of her seizure, as hereinafter set out, so registered. The said 
“W. P. Sayward” is 1353 tons burden, by builder’s measurement, and is a well and 
strongly built vessel. 
4. That on the 16th day of May, A. D. 1887, after having duly cleared at Customs at 
the port of Victoria aforesaid for such purpose, the ‘‘W. P. Sayward” sailed from Vic- 
toria on and for a full hunting and fishing voyage in the North Pacific Ocean and 
Behring’s Sea. On said voyage George E. Ferey, of the said city of Victoria, was 
master; Andrew Laing, of the same place, mate; and the crew numbered, in addi- 
tion to the master and mate, twenty-two or twenty-three, with nine canoes and one 
boat for hunting and sealing purposes. 
5. On the 2nd day of July then next following the said ‘* W. P. Sayward ” entered 
Behrineg’s Sea, having then on board, as by the report of the master sent to me, 479 
seal-skins, all taken on the voyage from Victoria to Behring’s Sea prior to the said 
2nd day of July. After entering the said sea the weather was very thick, and no 
sealing was done by the ‘‘W. P. Sayward.” 
6. On the 9th day of said July, the ‘‘W.P.Sayward” then being in latitude 54° 
43/ north and longitude 167° 51’ west, and about 58 miles from Ounalaska Island, 
the nearest land, and lawfully pursuing the objects of her voyage, was seized by the 
United States steam-ship ‘‘ Richard Rush,” and taken to Illoolook Harbour, at 
Ounalaska Island, in the United States’ Territory of Alaska. At said harbour the 
seal-skins on board the ‘“‘W.P.Sayward” were taken out and stored on shore, and 
the “ W.P. Sayward” was, by order of the authorities of the United States, sent to 
Sitka, in the said Territory of Alaska, in charge of an officer from said ‘ Richard 
Rush,” together with all her crew. 
7. Upon arrival at Sitka the ‘‘W. P. Sayward” was handed over to United States 
Marshal Atkins, the master and mate of the ‘‘ W. P. Sayward,” the said George E. 
Ferey and Andrew Laing, were taken before a Judge and bound over to appear for 
trial on the 22nd day of August then instant, and from day to day thereafter, on a 
charge of having violated the laws of the United States relating to seal-fishing in 
the waters of Alaska. The said master and mate so appeared on the 22nd August 
and day by day thereafter, until the 9th day of September, when, without having 
been tried on said charge or any other charge whatever, they were unconditionally 
released. 
8. That hereto annexed, marked “(A),” is a statement of the value of the said 
schooner ‘‘ W. P. Sayward” at the time of her seizure by the “ Richard Rush,” also 
of the articles, and groups of articles, and the value thereof, comprising the outfit 
of the ‘‘W. P. Sayward” on and for said voyage, also of the amount of premiums 
paid for insurance of the hull, outfit, and cargo of said schooner during said voyage; 
also of the amount paid in wages to the crew and hunters on said voyage; also of 
the fares and expenses of the mate to and from Victoria for instructions, and of the 
master, mate, and part of the crew in returning to Victoria from Sitka; and also of 
the number and value of the seal-skins taken from the said schooner when seized. 
9. The value placed on the schooner ‘‘ W. P. Sayward” in said Exhibit (A), namely, 
6,000 dollars, is a fair and reasonable valuation of the said schooner, considering her 
origina] cost, which was about 7,000-dollars, the condition of repair she was in 
when seized, and the value of vessels of her class at Victoria aforesaid, for such 
purposes as the ‘‘W. P. Sayward” was designed and used. Immediately before going 
on said voyage she was thoroughly repaired and refitted, and, at the time of 
146 her seizure, was in first-class order and condition. Besides the outfit men- 
tioned in Exhibit (A), there was on board the ‘‘W. P. Sayward,” when seized, 
a considerable quantity of extra gear, tackling, and ship stores. The insurance 
