EXHIBIT W.
[In the matter of the seizure of the schooner C. H. White by the Russian Government.]
State of California, City and County of San Francisco, ss:
On this 19th day of November, 1900, before me, William T. Hess, a notary public in and for said city and county of San Francisco, State of California, duly commissioned [Page 249] and authorized by law to administer oaths in said city, county, and State, and not interested in anywise in said claim, and not being the agent or attorney of any person interested in said claim, personally appeared, Charles Lutgens, sometimes called Claus Lutgens, personally known to me to be a credible witness, who being first duly sworn, deposes and says:
I am not interested either directly or indirectly in the said claim, nor have I any contingent interest in the same. I am not the agent or attorney of the claimant making the above claim, nor of any person interested therein. I will not be entitled to receive any part of any sum which may be awarded under said claim to said claimant. My age is 59 years; my place of birth was North Germany. I arrived in the city and county of San Francisco in 1869, and I have been a duly naturalized citizen of the United States since about 1875. I have been a sailor or seaman for 38 years, and have been a master mariner since 1872. I am now a master mariner. At the time the events took place in regard to which I am now testifying and deposing I was a master mariner, and master and owner of the American schooner Kate and Anna, and am now the owner thereof. My residence is now at Alameda, Cal., and my residence at the time the events took place in relation to which I am testifying and deposing was San Francisco, Cal. During the season of 1892, I was sealing and hunting in the North Pacific Ocean as owner and master of said schooner Kate and Anna. I have been in the sealing business since 1886; I was master and owner of said schooner Kate and Anna until 1896, and since 1896 up to the present time, I am the owner of said schooner Kate and Anna and am engaged in the sealing business. I am well acquainted with the schooner C. H. White. I saw her in the year 1890, and I saw the said schooner in 1892 at the time it cleared for the voyage during which it was seized by the Russian cruiser Zabiaca. I was informed as to the date of the seizure of said schooner C. H. White on July 15, 1892. I know the master of said schooner, L. M. Furman, to have been a competent master, understanding the sealing business, and I know the equipment of the vessel to have been sufficient for the purpose of sealing and fishing. I was sealing in the North Pacific Ocean during the year 1892 as master and owner of the schooner Kate and Anna, and am fully able to judge as to the probable number of seals which ‘the said schooner C. H. White would reasonably be expected to catch during the season of 1892 after its seizure as aforesaid. I know the value of the seal skins in the London market during the year 1892 to have been $14 each, because I sold 1,252 seal skins that year at that price. I estimated that the probable catch of the schooner C. H. White for the season of 1892, subsequent to its seizure on July 15th, 1892, would have been at least 2,400 seal skins, worth as aforesaid $14 each, and the probable and reasonable value thereof would have been $33,600.
Notary Public in and for the City and County of San Francisco, State of California.
[Seal of notary.]