EXHIBIT D D.
George E. Dodge, 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 at one time owned and controlled a number of sailing vessels engaged in the sealing industry; that he is thoroughly acquainted with that class of craft, and is conversant with their sailing capabilities; that said vessels are heavily built, with a view to withstanding the severe storms prevailing in the waters where sealing is engaged in, but with no regard whatever to the attainment of speed; that he was entirely conversant with the general build and capabilities of the schooner James Hamilton Lewis prior to her seizure by the Russian Government in August, 1891, and that it is his opinion that the said vessel could never have attained more than the maximum speed of 8 knots per hour, and rarely made over 5 or 6 knots average per hour during her sealing voyages.
104 Stuart Street, San Francisco.
Notary Public in and for the City and County of San Francisco, State of California.