changed his opinion as to George because he thought that George would be pleased to take the lands, and so he made for him a monthly allowance, as I understand, from 11 to 12 pounds, which he used to pay him monthly, and George used to come often to his uncle's and inspect the lands and thus a very strong friendship was born between the two.

This man Goubran Salem, who had possession of an estate of from thirty to seventy-five thousand dollars belonging to George Salem, was so small that he made George an allowance of but 11 or 12 pounds per month.

Mr. Salem's testimony before the investigator will be found at page 794 of the Reply of the United States, at the beginning of the third paragraph:

Q. Tell us the circumstances under which this deed was written?

George Salem answers:

I, after the negotiations which occurred, personally between myself and my uncle, in the month of January, 1917, and after he accepted to transfer to me the lands of Saft and Dar el Bakar, I spent a night here, and the next morning my uncle was upstairs in his private office and I was with him and he told me to go and call one of the clerks and I went down and I found Neguib Zeitoon in front of the office of the clerks and he was standing near the door of the office and because my uncle did not specify any special clerk, I told him. "Neguib, come to see my uncle" and he went up and he told him to "Sit, Neguib "—

The explanation of that, I understand, is that an employee never sits down until he is told by his employer to do so. (Continues reading :)

and gave him a paper from his desk and told him to sit down and write and my uncle sat at his private desk and the clerk sat at his desk and I sat on the sofa and it was my uncle himself who dictated to the clerk this deed and he gave him the date, but the clerk called attention about the date and he told him it was not his business and then my uncle ordered him to make another copy of the deed and he started writing it and then my uncle came and sat near me on the sofa and when he finished the writing of the second copy he handed them to my uncle and left and my uncle kept the two copies and then he said to me "George, you will bring in the afternoon some of our

relatives and friends to witness the deed." And then I went alone to Mr. Shafik Boulad and told him "Shafik, I have settled with my uncle. You will come in the afternoon to witness the deed." And I went to the coffee-house which was in front of the old post office and found Mr. Fadlallah Hanna and Wadi Hanna sitting together and I told them the story and begged them to come in the afternoon to witness the deed and to bring with them some of our friends also for that purpose. And this was about noon. Then I lunched with my uncle and his wife, the Dame Adele, and my uncle had a nap and I was reading in the private office of my uncle until he got up and took his coffee in the dining room and then entered his private office in which I was reading and we closed the door which communicated between the office and the rest of the residence of the family, and the other door overlooking the outside remained ajar. And after we sat for a little while, Mr. Fadlallah Hanna and Wadi Hanna came and brought with them Spiridon Fiani and after that Mr. Shafik Boulad came and I went down to call Hafez and I found Neguib Zeitoon, the writer of the deed, sitting on a bench and I asked him to come up and he came up and I went to Hafez and brought him up, and when we met he read the copy and then my uncle said to the witnesses-" You will please keep this quiet because this is a family matter"

That is an important point to bear in mind

and after signing, my uncle took one copy and I took the other and put it in my pocket and the witnesses congratulated us and some of them left and some of the others went down to Hafez Bandaly's. I the next day left and continued to come every once in a while as usual until my uncle became ill and then I kept with him most of the time during his illness, etc., as I have already stated in the investigation.

Spiridon Fiani's testimony on the same point-I hope this will not become monotonous to the Tribunal, but the purpose in reading this testimony, particularly at this point, is to show the exact way in which each of the witnesses to the deed explained the circumstances.

The testimony of Spiridon Fiani will be found on page 594 of the Counter Case of the United States. President SIMONS: What page, please? Mr. HUNT: Page 594.

President SIMONS: There is only one point in the testimony as to the discussion of the date, that is the only point that shows a difference.

Mr. HUNT: I have noted that, Mr. President. If you examine the testimony carefully, you will find that the testimony of one of the witnesses-I have forgotten which one-indicates that the circumstances were something like this: It was a small office room, and there were eight persons in it, and, as always happens, I presume, in cases of that kind, people gather into little groups to talk, two or three here and two or three there. At one point, perhaps, some question was made with respect to the date of the deed, and in another group nothing was said about it.

I notice on that point a slight difference; but, I should say, that with the seven witnesses, that is not material.

President SIMONS: I do not speak about it to hinder you, but I only wish to say that in the light of the testimony that has been referred to there has been that slight difference.

Mr. HUNT: Would the Tribunal prefer that I omit the reading of these other two witnesses? I had only intended to read two others.

Mr. NIELSEN: I should think the Tribunal had had enough on that point.

Mr. HUNT: Very well. I hope the Tribunal will not overlook that point, as it is very important, that an important document like this should be made in the presence of six witnesses, the maker of the deed and the grantee of the deed, and that those six persons should subsequently be called to give their testimony, and that their recollection was so almost perfectly uniform, sufficiently perfectly uniform to make it clear that there was no collusion between them, because if there had been collusion between them, the investigation to which they were individually subjected would most certainly have detected some point of weakness in that collusion.

This is the testimony, a part of which I have read and a part of which has been omitted, which was taken at the

beginning of 1918. The Tribunal will remember that four years later the case came before the American consular authorities, and a separate investigation was made. At that time Merzbach Bey called before him not only the same witnesses to the deed, but many other witnesses; and I should like, with the patience of the Tribunal to read the statements of, perhaps, two of those witnesses which were made four years later. On page 539 of the Counter Case of the United States, the very last paragraph, will be found the beginning of the statement of Spiridon Fiani.

Mr. Spiridon Fiani, 55 years old, merchant, born in Beyrouth, residing in Mehalla.

Called upon, he states that he is not a parent, nor a relative of Georges Salem, he is an Agent for the firm Peel, in Mehalla.

I might read the testimony of almost any one of these witnesses, but I choose Fiani because he is not a relative of the family; and I also choose Wadi Hanna because he is a member of the family and because I know him.

The witness states that at the beginning of February 1917, about 4 o'clock p.m., he was in his boat in Mehalla, when Messrs. Wadi Hanna and Fadlallah Hanna

Mr. NIELSEN: Where is that, now?

Mr. HUNT: At the beginning of page 540; at the bottom of page 539 is the beginning of the reading.

Shall I begin again?

Mr. Spiridon Fiani 55 years old, merchant, born in Beyrouth, residing in Mehalla.

Called upon, he states that he is not a parent, nor a relative of Georges Salem, he is an Agent for the firm Peel, in Mehalla.

The witness states that at the beginning of February 1917, about 4 o'clock p.m., he was in his boat in Mehalla, when Messrs. Wadi Hanna and Fadlallah Hanna were passing in the street and started to talk to him, saying that they were going to Goubran Salem's house, at the request of Georges Salem, to be present as witnesses at the signature of a deed. Being a friend of Goubran Salem, I accompanied them.

Upon arriving at the house of Goubran, we went up to his private office by his special staircase. Goubran was seated at his desk, Georges Salem at his side. Then, Mr. Shafik Boulad and Mr.

Zaitoon arrived. Then Georges went downstairs to look for Mr. Pandali.

Pandali, it says here, but the name is really Bandaly.

When everybody was present, Goubran took a paper from his desk, already drawn up in two copies, and told us that it was a sale to his phew, to which he had consented, of approximately three hundred feddans for approximately eighteen thousand pounds, that he had calculated the price with his nephew and that he asked us to sign as witnesses. Goubran signed first, then Georges, then the witnesses in an order which I do not recall. After the signature, the parties congratulated each other (Mabrouk) and Goubran asked us to keep this sale secret. We shook hands and left.

And to the same effect are the testimonies of all the other witnesses. On page 543, for example, is that of Wadi Hanna:

Mr. Wadi Hanna, 40 years old, residing in Mehalla, relative of Goubran.

Goubran Salem was a brother of my aunt (wife of my paternal uncle) and my sister is the wife of Youssef Salem, brother of Goubran.

So he was related in two directions.

It is my signature that is affixed on the deed that you are showing me. One day of February 1917, I was at the Cafe with my brother, when Georges came to ask us to be present as witnesses, in the afternoon, at his uncle's house for the signature of a deed. At about 4 o'clock, we came to this invitation and on our way, met Mr. Spiridon Fiani who was on the steps of his house, next to that of Goubran's. As Georges had told us to bring more witnesses, we requested Spiridon [Fiani] to accompany us. We came up to Mr. Goubran's [house or] office, the other witnesses arrived, Mr. Goubran read to us the deed which was in front of him, in summary, and signed it, then the witnesses signed. I left with Spiridon and my brother.

Called upon, he states that he had not been surprised to see Goubran give Georges a receipt for the eighteen thousand pounds that the latter was not paying h'm because this was not a real sale, but a family settlement, that Georges was his only nephew and that according to the witness, Goubran should have given to Georges, as the fortune that he had taken at the death of Joseph represented, at the death of Joseph, a value proportionally superior to the present value of the 300 feddans.