EXHIBIT Q.
[In the matter of the claim of Charles Lutgens against the Russian Government for the seizure of certain seal skins from the schooner Kate and Anna.]
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 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 George E. Dodge, personally known to me to be a credible witness, who, being first duly sworn, deposes and says:
My age is 38 years; I was born at San Francisco, Cal. My residence is now, and was at the time the events took place in regard to which I am testifying and deposing, at San Francisco, Cal. My occupation is now butcher; my occupation at the time the events took place in regard to which I am testifying and deposing was butcher; but I was then, and prior thereto, and subsequently thereafter, managing owner and part owner of sealing vessels and otherwise interested in the sealing business. I am not interested 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 whatever interested therein. I will not be entitled to receive any part of any sum which may be awarded under said claim to said claimant. I have been engaged in the sealing business as aforesaid since 1884, and am now interested in said business, and during that time I have been managing owner and part owner of the following-named vessels engaged in the sealing business, viz, City of San Diego, Vanderbilt, C. G. Wilson, Ellen, Bowhead, and Active. I know the probable number of seals which a well-equipped sealing vessel would have captured in 1892. I know the schooner Kate and Anna well, and knew said schooner in 1892. I knew Charles Lutgens was in every way well acquainted with the sealing business and fully competent for the purpose, and that the Kate and Anna was well equipped for the sealing business, and that the crew and hunters were skilled in said sealing business; and I know that during the years from 1890 to 1896, while the said Charles Lutgens was acting as master of said schooner Kate and Anna, the said vessel under his management captured fully as many seals in proportion to its size and equipment as any other vessel clearing from the port of San Francisco. I know that in the season of 1892 seals were plentiful from August 12, 1892, to the end of the season of 1892, and I know that during that season seal skins were worth in London as high as $14 each. I firmly believe and do depose and say that during the remainder of the sealing season of 1892, after August 12, 1892, the Kate and Anna would be reasonably expected to capture and catch at least 625 seals, and that the value of the seal skins so caught would have been $8,750; and I place the probable catch of seals by the Kate and Anna for the remainder of the season of 1892, after August 12, 1892, at 625, and the probable value thereof at $8,750.
Notary Public in and for the City and County of San Francisco, State of California.