Frank H. Reid was then called for the protestant and after being duly sworn testified as follows:
Q. Are you the same Mr. Reid who testified in the protest of
John G. Price?
Q. Mr. Reid I wish you would take the blue print which is in evidence in this case and marked protestants Exhibit C in testimony, and indicate upon the same the Skaguay Wharf and Improvement Company? wharf and approach thereto?
A. It commences on First Ave and runs across lots 6, 8, and 9 in block 44 to deep water, the course is S. 12°30” W., into Skaguay Bay.
Q. You say it runs across lots 6, 8, and 9, block 44?
Q. Are those lots on tide land?
A. They are below the dike of gravel thrown up by the tide, they are below where the ordinary high tide line is.
Q. What kind of land as to whether tide land or upland is this company's wharf and approach built upon?
A. It is built upon tide land.
Q. You know where lots 7, 8, 9, 10, 11, and 12, in block 33, and also lot number 12, in block 37, are?
Q. What would you say as to those lots being necessary for this company to own to carry on its business?
A. They are necessary for a lumber yard.
Q. Do you know whether or not lot number 12, in block 37, is below ordinary high tide or upon the upland?
A. It is below ordinary high tide.
Q. Do you know where lot number 5 in block number 1 is and who
is in possession of it?
A. It is the lot claimed by Mr. Tanner. He has a stable there and is keeping his horses there.
Q. What do you know about this lot referred to as the Bloom lot?
A. Mr. A. Bloom had me survey off 26 x 50 feet of that lot for him and built a house on it, and is now occupying it.
Q. Just as you arrive off the approach of this wharf what land do you enter or what is it designated on this plat?
A. It is designated on the plat as State street, and it is below the line of ordinary high tide.
Q. I now hand you a plat that is attached to the protest of Emory Valentine and ask you if approximately the location of the wharf is correct upon that plat as to streets, alleys, etc.
A. It is practically correct.
Q. As I understand it the effect of your testimony is in getting on to the Valentine wharf you would have to pass through the water at ordinary high tide?
A. Yes sir. I have waded through there myself with gumboots on a number of times. The buildings in that vicinity are on piles from 4 to 6 feet high.
Q. The ground of the wharf or these other lots is covered or overlapped by the Price protest is it not?
A. Yes sir.
[signed] Frank H. Reid
I hereby certify that the foregoing testimony was read by me and corrected in the presence of the witness, and that it was then subscribed to by him at my office in Sitka, Alaska, this 6th day of April, 1898.
[signed] John W. Dudley