622 APPENDIX TO CASE OF GREAT BRITAIN. 
OL In the United States District Court in and for the Disttict of Alaska. 
United States v. Schooner *‘Sylvia Handy” and Cargo, and L. N. Handy, James Cartheut, 
J. N. Handy, and William Thomas, Owners. 
No. 93.—Appeal to the Supreme Court of the United States. In Admiralty. 
To the honourable Supreme Court of the United States of America. 
The appeal of the above-named appellants respectively showeth that, cr or about 
the 15th day of September, in the year 1887, the above-named libellants, tue United 
States of America, exhibited their libel in the District Court of the United States 
for the District of Alaska against the appellants for the reasons set forth in said 
libel, that these appellants might be condemned to pay the demands of said libellants 
and costs in said libel mentioned. 
That process issued out of said Court having been served on these appellants, they 
did, on or about the 19th day of September, in the year 1887, file their answer to said 
libel in the said District Court, praying that the said libel be dismissed with their 
costs in that behalf, as by reference to the said libel and the said answer may more 
fully appear. 
That the said cause came on to be heard before the Honourable La Fayette Dawson, 
Judge of the said District Court, on or about the 22nd day of September, in the year 
1887, upon the testimony and proofs adduced by the respective parties; and the 
said Judge, having advised thereon, did, on the 22nd day of September, in the year 
1887, make his decree in said cause, whereby it was, among other things, decreed 
that the libellants in said cause recover against these appellants a decree of forfei- 
ture against said vessel, her tackle, apparel, furniture, cargo, and 1,679 fur-seal skins, 
as by reference to the said decree may more fully appear; and these appellants are 
advised and insist that the said decree is erroneous, inasmuch as the honourable 
Court, at such sitting, did not declare the law or constitution by which such seizure 
and forfeiture of property was made. 
Wherefore these appellants appeal from the whole of said decree of said District 
Court of the United States, and respectfully pray that the decree of the said District 
Court and the bill, answer, pleadings, evidence, and proceedings in the said cause 
may be sent to the Supreme Court of the United States without delay, and that the 
said Supreme Court will proceed to hear the said clause anew, and that the said 
decree of the District Court and every part thereof may be reversed and a decree 
made dismissing said libel with costs, or such other decree as to the said Supreme 
Court shall seem just. 
(Signed) M. P. Berry, Solicitor for Appellants. 
Dated March 20, 1888. 
Endorsed: Copy. H. No. 93. 24. In the United States District Court in and for 
the District of Alaska. United States v. Schooner ‘‘ Sylvia Handy.” Appeal to the 
Supreme Court of the United States. In Admiralty. Filed the 25rd March, 1888. 
H. KE. Haydon, Clerk. M. P. Berry, solicitor for appellants. 
In the United States District Court in and for the District of Alaska. 
United States v. Schooner “ Sylvia Handy” and Cargo. 
No. 93.—Court in Error. Brief of Proctor. 
(Submitted without argument. ) 
Par. I. That the assumption of ownership by Russia of that portion of the Pacific 
Ocean generally known as the Behring’s Sea was a fallacy, and the transfer of the 
same to the United States of America was a fraudulent exercise of such ownership 
and supremacy, which did not exist at the certain time of the sale and transfer of 
Alaska and the Aleutian Islands to the said United States of America. 
2 » Par. II. That Russia had no control over such sea or waters from the year 
1825 until the claim of ownership when negotiating for the sale of the main- 
land of the Continent of North America and known and recognized as Alaska, and 
the chain of islands bearing the name of Aleutian, with other islands of the same 
group and certain islands within the Behring’s Sea and the strait opening and. 
leading into the North Arctic Ocean—1&66 and 1867; that the destruction of many 
American ships in the said Behring’s Sea and waters adjacent thereto by an unrec- 
ognized war-vessel as late as 1864 and 1865 met with no protest from the Russian 
authorities at that time within those seas (viz., the Kamschatka or Belring’s Seas), 
aS mae foe 
