CROSS EXAMINATION OF
CHARLES W. GARSIDE
FEBRUARY 18, 1898
C. W. Garside was then sworn and cross-examined as follows:
Q. When did you know: of Mr. Moore conducting a trading post or manufacturing site of your own knowledge?
A. At the time the application for survey was made or about that time.
Q. You made your official survey in July, 1896?
Q. Did you find Mr. Moore conducting any business there at that time?
A. He had some goods there in the log house. I went up there and purchased some goods from him. Some little stuff, a matter of miscellaneous stuff that we needed on the survey, it would amount to probably $4 or $5. Maybe a little less than that. The goods were in boxes and we had to knock the covers off to get at them.
Q. What was the value of the stuff that was there?
A. I really don’t know they had it piled up there all one side of the house. There was lots of stuff there, I don't know how much.
Q. Do you know whether Mr. Moore had that stuff there for his own use primarily or for general purposes of trade?
A. I heard that people could get stuff there, but whether he was conducting a regular merchandise store I hardly think he was ready yet, he was just starting in.
Q. The stuff there consisted of supplies and provisions which it would be necessary for a man to have if he intended to live in a place of that kind?
A. Yes, a man would have to have most everything he was away from any place of supply. He had miscellaneous lot of goods.
Q. Mr. Moore and his men were using the stock for their general use, were they not?
A. I don’t know but I suppose they were. They would naturally draw from it if they wanted to.
Q. Did you see any conveniences for the purposes of carrying on trade, counters, etc.?
A. No, the boxes were piled on one side, the goods were all on one side of the room.
Q. What were the dimensions of the cabin?
A. It was a log house one and one-half story high, about 18 x 20 feet with 10 ft. ceiling.
Q. Did you regard the house at that time as a store or a dwelling house?
A. I don't know. They had one side of the house filled with these boxes and things, and they used the house for a dwelling house.
Q. How much ground was then cleared about the log house?
A. I should suppose about 8 acres, might possibly be over that but not less than 8 acres.
Q. Did Mr. Billinghurst accompany you when you made this survey?
A. Yes, he was on the trip.
Q. Were you not somewhat under his direction and supervision in making this survey?
A. No sir, I was not.
Q. Did he accompany you at your request?
A. No sir.
Q. Do you know what his object was in going with you at all?
A. He wanted to look over the ground to see what it looked 1ike.
Q. Did he offer any suggestions to you in reference to the survey?
A. No sir.
Q. With whom did you have a talk with first about making the survey?
A. I met Bernard Moore in my office and he asked me to go up and make a survey for him.
Q. Was he not accompanied by Mr. Billinghurst?
A. No not at first. He came first, and I afterwards met Mr. Billinghurst.
Q. Have you not had frequent talks and conversations with Mr. Billinghurst about this claim?
A. Yes sir, I have.
Q. In these conversations has he not taken a deep interest in the claim of Bernard Moore?
A. I really don't know. He has asked me about it some. I don't know how deep an interest he has taken in the claim.
Q. Did Mr. Billinghurst leave Alaska soon after the survey was made?
Q. Who engaged you on this additional survey? Plat of which is attached to your affidavit?
A. Mr. Moore.
Q. Do you know of your own knowledge who paid for the labor and material in building the saw mill on the claim?
A. Yes. The mill was built by Mr. Moore.
Q. What is the source of your knowledge?
A. I always heard that Mr. Moore built it and didn't suppose anyone would raise any further question about it. I never asked any questions or made any further investigations.
Q. Do you know of a company by the name of the Alaskan and North Western Territories Trading Company?
A. No, never heard of it.
Q. Do you know who is conducting the saw mill now of your own knowledge?
A. I believe a Mr. Hill is looking after the mill under Mr. Moore.
Q. How do you know Mr. Hill is under Mr. Moore?
A. Well he was around the office there and Mr. Moore told him to do certain things and he done them, and I supposed that he was head manager.
Q. Do you know who wakes contracts for the lumber turned out by the mill and receives the money therefore?
A. Mr. Hill has the management of the mill and he acts under Mr. Moore's orders. That’s the way I understand it.
Q. Does not Mr. Hill exercise general supervision and control over the mill?
A. Well I should suppose that he did acting under those orders.
Q. How often have you seen Mr. Moore giving orders to Mr. Hill?
A. I haven't been around Skaguay very much, but when I was at the office making that map Mr. Hill was around there and Mr. Moore
was giving him orders about the mill and he went out with those orders and I suppose executed them with dispatch.
Q. Did you notice any stationery or bill heads about the mill office?
A. No sir.
Q. Did you ever see a bill head with the name of the Alaskan and North Western Territories Trading Co., on it?
A. No sir, I never did.
Q. When did you see a store claimed by Mr. Moore with counters and shelves upon this claim of Mr. Moore?
A. I believe the first was last August.
Q. How recently have you been in the store?
A. I was there this month.
Q. About what was the value of the stock?
A. I really don't know. They had warehouse connected with the store. I don't the value. They had goods stored in the office and outside.
Q. Do you know of your own personal knowledge whether they had any goods stored in the warehouses or not?
A. They had goods outside the store. They had goods in the office. Whether they had warehouses specially constructed and marked “WAREHOUSES”, I am not positive.
Q. What was the value of the goods in the store?
A. They had lots of miscellaneous goods, I don't know the value.
Q. Do you know what the value of the business of that store is now?
A. No I don't know.
Q. How did you arrive at the value of the trade and business as being $5,000?
A. I supposed it was about that.
Q. What portion of the wharf is embraced in Moore’s claim?
A. About 100 ft. more or less.
Q. Do you include in your approximation of the business conducted on this tract the business of the wharf?
Q. Do you know of your own personal knowledge whether all the improvements on his tract were placed there by him, and at his expense?
A. That's what I suppose that Mr. Moore put those improvements there. That's what I always understood.
Q. Heard it from Mr. Moore?
A. Yes, also others.
Q. Your source of knowledge then is from what you have heard?
A. Yes sir.
Q. Have you indicated on this map prepared as an exhibit in connection with your affidavit, what time, these improvements were placed upon the tract, each and every one?
A. I have. They were placed on there after the official survey was made. Except what had been made at the time survey was made.
Q. Were not some of those placed after the application had been made? After the application for patent?
Q. Do you know of your own knowledge who constructed the wagon road mentioned in your affidavit across this claim?
[Signed] Chas. W. Garside
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 18th day of February, 1898.