EXHIBIT Z.
Charles F. Rydell, being first duly sworn, deposes and says: That he is a resident of the city and county of San Francisco, State of California; that he is at present master of the schooner Frolic, now being fitted out at this port for a cruise to Alaskan [Page 206] waters; that he was thoroughly familiar with the schooner James Hamilton Lewis, which was seized by the Russian Government in the month of August, 1891; that he sailed in a number of vessels of the same class on sealing expeditions, notably the schooners Alexander, Herman, Jane Gray, Eppinger, serving during different seasons in the capacities of first mate, sailing master, and captain, respectively; that none of the vessels named ever attained a greater average speed during their cruises than 6 knots per hour; that he frequently met the schooner James Hamilton Lewis under full sail while on sealing voyages during the years 1889 and 1890, and that he knows of his own knowledge that the said schooner James Hamilton Lewis, whenever sailing alongside of any one of the vessels named, was invariably outsailed by them, and was probably the slowest of any of the sailing vessels comprising the fleet during the years named; and on one particular occasion, while he was mate of the schooner Alexander, during a sealing voyage, the said schooner started simultaneously with the schooner James Hamilton Lewis from the Cordell Banks bound for the harbor of Drakes Bay, and although both vessels encountered similar conditions on the way, the schooner Alexander arrived at Drakes Bay far ahead of the schooner James Hamilton Lewis; that he knows of his own knowledge that said schooner James Hamilton Lewis was not built with a view to the attainment of speed, but was composed of the heaviest kind of timber available for such craft, for the purpose of withstanding the rough weather usually encountered off the northwest coast and Alaskan waters during the sealing seasons.
Notary Public in and for the City and County of San Francisco, State of California.