Such acts as this, made in good faith, which required a young man of that age to offer to the government of his adoption his fortune, his life, are not usually connected with a naturalization obtained by fraud.

During this period of time, the Egyptian Government, on several occasions, recognized George Salem as an American citizen. He was summoned many times, several times, I should say, by the Egyptian Government to the American consular offices to testify in cases pending before Egyptian courts.

I will mention at this point the fact that Mr. Salem was constantly working to obtain settlement of his estate. If I may quote from pages 759-760 of the Reply of the United States-this again is the testimony of Selma Salem, the aged lady whose character we need not question. The questions are being asked by an official of the Egyptian Government.

Q. You stated that when you went in February to Mehalla you noticed that Goubran and his nephew were on the best terms together and happy. Were they on bad terms together before?

A. They were a little cold to each other because George was always asking for his father's estate and he would stall and would tell him that he is his nephew and that he is the only descendant of the family and the sole one, and that there was no difference between the two.

Goubran Salem, during all this time, was representing to George Salem that he [George], being the only male descendant of the Salem family, the only person who could perpetuate the Salem name, was to receive the Salem estate.

On page 606 of the Counter Case of the United States will be found another statement by one of the members of the family, Mr. Wadi Hanna-and may I say at this point that while in Egypt I had the pleasure of spending one whole day in the company of Wadi Hanna and that, to my mind, Wadi Hanna is an outstanding, straightforward, honest business man.

We brought Mr. Wadi Hanna and we asked him. He stated "My name, Wadi Dimitri Hanna; my profession, business man, and was inspector of agriculture at Lotfallah Pasha [sic] lately, and from the beginning of the month I resigned and went into business and during my service I was also doing some business; born and residing at Mehalla; my age forty-one years." Was sworn in.

Q. Do you know that Mr. Goubran and his nephew

Mr. NIELSEN: May I interrupt you a minute, before I forget the point you spoke of. You know the customary procedure in Egypt, whenever a foreigner is summoned, is to have him appear through application to a foreign diplomatic representative, whether he be called to testify in person, so to speak, or whether he be called upon to appear in court with papers. I am not sure as to the procedure.

Mr. HUNT: If I understand aright, it is this way: Capitulatory nationals in Egypt are not subject to the jurisdiction of the Egyptian courts in any respect, and when a case is pending before the Egyptian courts which requires the attendance of a capitulatory national, either as a principal or as a witness, or in any other capacity, he must of necessity, under the capitulatory regime, be summoned through the diplomatic or consular representative of the national concerned. That is my understanding of it.

The summonses in this case will be found on pages 132-134 of the Case of the United States, if the Tribunal is interested in seeing the form.

Mr. NIELSEN: I recall the form, but I wondered if that is a standard procedure.

Mr. HUNT: It is my understanding that it is, in all cases involving the appearance of capitulatory nationals in local or Egyptian court matters.

Continuing with the statement of Mr. Wadi Hanna before the Egyptian investigator (reading):

Q. Do you know that Mr. Goubran and his nephew George, had a difference relative to the estate of George's father?

A. Yes, there was a difference about four years ago and he used to ask for his father's estate and I was eighteen years of age when his father died and know a great deal about it because they have two houses at Mehalla and twelve feddans; and five feddans at Kafr el Zeblawi, and a business of coal and cattle with the peasants at Kafr el Zeblawi, and he had four pairs of carriages at Mehalla and claims not less than 2,000 pounds, and, in my opinion, a business man of that kind must have left cash not less than 200 pounds in his house; and there was no inventory made of the estate and his uncle took possession of it and, according to the statements of the deceased, who said he spent for his nephew during the twenty years 2,000 pounds, and he told me that on one occasion when I talked to him about giving back the estate to his nephew, and he used to say that he was safekeeping everything for his nephew and everything he had would go to him, but he did not give him much and lately one day they agreed together; and that was that I was one day with my brother

And then Mr. Wadi Hanna, one of the members of the family, begins to describe the circumstances under which this notorious deed of January 26, 1917, was made. He says:

and that was that I was one day with my brother, Fadlalah, at the coffee house, which is near the bridge, and George passed us a little before noon and told us that he agreed with his uncle and that we should come in the afternoon and witness the agreement and he told us that his uncle sold him some lands and that we should go in the afternoon to witness the deed, and he told us if we had a friend to bring him along with us, and we thought that anyone we would meet we would take along, and we met Spiridon Fiani in front of his house and we took him along, and we went up and found George and his uncle in the private office of his uncle, and after our arrival George left us and went down; and then came Shafik Boulad and Neguib Zeitoon, and after that came back George and with him Hafez Bandaly. And the deed was of two copies in front of Mr. Goubran and he read to us some of the

I hope that you gentlemen can picture this, the making of this deed, because it is an extremely important point in the

case

and then came Shafik Boulad and Neguib Zeitoon, and after that came back George and with him Hafez Bandaly.

There were seven-eight people in the room, including Goubran Salem, in a small room, gathered together at the request of Goubran Salem for the purpose of making this deed.

And the deed was of two copies in front of Mr. Goubran and he read to us some of the deed and some of it he was giving its résumé such as the boundaries, the localities—and he told us that the sale was for 18,000 pounds, which they accounted for together, and he signed the two copies, then George signed, then Neguib and Fadlalah and myself after them, and the others signed and I do not remember the order in which they did, but Spiridon Fiani is the one who signed the last and I left, I and my brother, and Spiridon left ahead of us, and Mr. Shafik and Hafez and George remained, and this is how the matter ended.

Mr. President, I should like it if the Tribunal would at this time look at this paper, please. This is the original deed which has been subjected to so much scrutiny, so much examination, so much photographing, so much criticism.

(Mr. Hunt exhibits the paper referred to.)

Mr. NIELSEN: I won't take the time to read it now, Mr. President.

Mr. HUNT: I am also submitting to the Tribunal and to counsel for the Egyptian Government the necessary magnifying glasses, so that each member may make any inspection of this deed he may care to make and be satisfied as to all the details.

Let me make this point perfectly clear at this time, Mr. President-there is not before this Tribunal any question for decision as to the validity of this deed, and I would not like to have any statement I make with respect to the signature or the validity of the deed misunderstood in that respect. This deed, so far as this case is concerned, is an absolutely valid, legitimate, unquestionable deed.

I have read to the Tribunal the testimony of one witness before the Egyptian investigator with respect to the circumstances of the making of this deed. If it were not that it took too much time, I should like to read the testimony

of each of the seven witnesses in order that the Tribunal might make comparison. However, I shall read only three. I have read one. I may read now the testimony of Mr. Salem on page 431 of the Counter Case of the United States-I should say, the testimony of Mr. Bandaly, at page 612 [613: see infra]:

Q. Is this signature yours? (We showed him the deed alleged to be forged.)

A. Yes.

Q. Do you remember this deed?

A. Yes, I remember it.

Q. When was this deed made?

A. It was made about ten or fifteen or twenty days before his illness, which occurred on the first of March.

Q. But the deed has the date of January 26, 1917.

A. When Mr. Goubran read the deed to us I noticed this point and Mr. Shafik was standing beside me and remarked that the deed has the date of January 26, 1917, and why should we sign today, and he answered that this has no importance.

Mr. Bandaly's testimony begins on the preceding page, 612, that is, with respect to the particular making of this deed, and perhaps it is better that I begin there:

Q. Did you know what George Salem has done with his uncle relative to the estate?

A. George used to speak to his uncle often relative to his rights in the estate and his uncle used to promise him, and I was one of those that talked with his uncle relative to that matter, and George wanted his uncle to give him the lands and submit an account, and when I talked to his uncle he said to me that he would give him 11 feddans and promised to give them to him.

President SIMONS: What page is that?

Mr. HUNT: On page 612-I have gone back to 612.

But as to the accounts, he refused and, in fact, I submitted this to George and he refused and told me that he would take all his rights in the lands or nothing, and it seems that there is some sort of arrangement between George and his uncle in the same way as his sister, Marie, but I don't know its subject. It seems to be a matter of sale and purchase, and the man used to hear that George was a spendthrift and when George refused to take the lands the man