EXHIBIT 21.

Affidavit of Norman A. Ross.

I, Norman A. Ross, of Gloucester, County of Essex, and Commonwealth of Massachusetts, being duly sworn, hereby make affidavit and state as follows:

During the years 1900-1910 I was in the employ of various persons and concerns of Gloucester, Massachusetts, engaged in the business of producing and packing fish. Said persons and concerns owned fishing schooners which they sent to sea to engage in the herring, cod, halibut, mackerel and other fisheries. It was the practice to send a number of fishing schooners to the Treaty Coast of Newfoundland during the herring season of each year to engage in the herring fishery. This fishery usually commenced in October and lasted until the following January. The principal seat of the fishery was in the Bay of Islands on the west coast of Newfoundland.

During the above years I made herring trips to the Bay of Islands, as master of the schooners Golden Rod, Lottie G. Merchant and Veda Mc Kown as follows:

On each of these trips the vessel sailed from Gloucester with a crew of from seven to nine men. Upon the arrival of the schooner in the Bay of Islands additional men were added to the crew to enable her to take a cargo of herring. The vessel carried to Newfoundland simply the barrels, lumber, fishing gear, fishermen's outfit and supplies necessary for the use of the schooner and her crew in the successful prosecution of a herring trip.

Upon the arrival of the schooner in the Bay of Islands the customs officers required the master to report at the Customs House and enter the ship. The customs officers levied light dues on the vessel and customs duties on the barrels, lumber, fishing gear and fishermen's outfit on board the vessel. Duty was not levied on provisions. The customs officers included enough food in the ship's stores to feed not only the members of the crew shipped in Gloucester but also the additional men engaged in Newfoundland.

The fishing schooners owned and operated by Orlando Merchant were equipped with a special artificial device for freezing the herring.

Vessels thus equipped usually stopped at Boothbay, Maine, where ice was taken aboard for use in freezing the anticipated catch of herring.

The men engaged in Bay of Islands to complete the crew of the schooner rowed out to the ship in their boats, were taken aboard the vessel, and were housed and fed there during the continuance of their employment. The schooner anchored in various places and the men fished in their boats within a short distance of the vessel. The fishing was done with gill nets. The men were paid according to the amount of their catch, the usual rate being $1.25 per barrel. These men were treated in all respects the same as the men shipped in Gloucester. They understood that they were working for the vessel and that their catch belonged to the vessel. Fish caught by them were delivered to the schooner where they were salted or frozen and then placed in the hold of the vessel or in barrels on deck.

During this trip the vessel did not engage in trade. None of the articles taken to the Bay of Islands were intended to be sold or exchanged for other goods; nor were they in fact sold or exchanged for other goods. The cargo taken aboard consisted solely of herring taken from the Bay of Islands. This herring, upon the return of the vessel to Gloucester, was admitted free of duty as the product of an American fishery.

As above stated, the customs authorities of Newfoundland levied duty on barrels, which were used solely as receptacles for the fish and returned to Gloucester with the vessel; on lumber, which was used for building a scaffolding upon which to freeze the fish, the scaffolding being abandoned when the freezing was completed; on ice, which was taken to Newfoundland on ships equipped with the artificial freezing device referred to above and which was used solely in the process of freezing the fish; and frequently on salt, which was used solely for salting the fish on board the vessel. Duty was also levied upon fishing gear (nets, rope, anchors, etc.), fishermen's outfit (oiled suits, oiled hats, rubber boots, etc.), and tobacco. The crew were required to furnish their own gear and outfit. It frequently happened, however, that Newfoundlanders shipped at Bay of Islands were lacking in gear and outfit. Good gear and outfit were scarce in the region adjoining the Bay of Islands. In order to utilize the services of these men, it was necessary to supply them with the articles they needed. Furthermore, during the process of fishing much gear was lost and expended. Storms often destroyed nets, and anchors were frequently lost. The arms of the Bay in which the fishing was carried on frequently froze over and in that case the gear would often be taken away when the ice went out. Such gear had to be replaced immediately in order that the fishing might be continued. The fishing was usually carried on miles from a settlement

and the only source of supply was the vessel. The situation was such that fishing could not be carried on unless the vessel had at all times a supply of fishermen's gear and outfit. Gear and outfit supplied to the crew were charged against their accounts and deducted from their pay when settlement was made.

In witness whereof I hereunto set my hand on this 2d day of June, A. D. 1924.

NORMAN A. Ross.

Subscribed and sworn to before me on this 2d day of June, A. D.

I, Alf Thorp of Gloucester, County of Essex and Commonwealth of Massachusetts, being duly sworn, hereby make affidavit and state as follows:

During the years 1904, 1906 and 1907, I was in the employ of Carl C. Young, of Gloucester, Massachusetts, who at that time owned and operated the fishing schooners Dauntless, A. E. Whyland, and W. E. Morrissey. These vessels were engaged in the herring, cod, mackerel, halibut and other fisheries.

It was the practice of said Carl C. Young to send his fishing schooners to the Bay of Islands on the Treaty Coast of Newfoundland during the herring season of each year to engage in the herring fishery. This season commenced in October and ended in January or the early part of February. In the years 1904, 1906, and 1907, I made three herring trips to Newfoundland. In 1904, I sailed as mate on the schooner William E. Morrissey, leaving Gloucester on or about November 4, 1904, and returning to Gloucester on or about December 12, 1904. In 1906, I sailed from Gloucester as master of the schooner Dauntless, leaving Gloucester on or about October 8, 1906, and returning to Gloucester on or about January 26, 1907. In 1907, I left Gloucester on the same schooner on or about October 22, 1907, and returned to Gloucester on or about December 23, 1907.

On the 1904 and the 1907 trips, the vessel sailed from Gloucester with a crew of nine or ten men-enough men to sail the ship to Newfoundland and bring her back. Upon the arrival of the schooner in Bay of Islands, the crew was completed by the shipment of additional men.

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In the year 1906, the schooner Dauntless sailed from Gloucester with a full crew. On this voyage, no additional men were shipped in Newfoundland.

On these trips, the schooner carried no outward cargo. It carried simply the barrels, salt, fishing gear, fishermen's outfit and supplies necessary to enable the vessel and crew to obtain a cargo of herring.

Upon the arrival of the schooner in the Bay of Islands, the master had to enter his vessel at the customs house before he was permitted to fish. The customs officials levied duty on barrels, salt, fishing gear, and fishermen's outfit. Duty was not ordinarily levied on provisions as the customs officers usually included in the ship's stores a supply of food sufficiently large to feed not only the members of the crew shipped at Gloucester, but also the additional men shipped in Newfoundland.

Light dues were also levied against each vessel; these dues were payable annually.

Newfoundlanders shipped to complete the crew rowed out to the ship in their boats, were taken aboard the vessel, and were housed and fed there during the continuance of their employment. The schooner anchored in various places, and the men fished in their small boats within a short distance of the vessel. The fishing was done with gill nets. They were paid according to the amount of their catch; the usual rate was $1.25 per barrel. Their employment continued until a cargo was obtained. Sometimes, fish were plentiful and the ship was soon filled; at other times, it was necessary to wait four or five weeks for the herring to strike. When the fish were placed aboard the schooner, they were salted or frozen and then placed either in the hold of the vessel or in barrels on the deck of the schooner.

Men shipped in Newfoundland were treated in all respects the same as men shipped in Gloucester. All fish caught by them belonged to the vessel. They understood that they were working for the vessel and that their catch belonged to her.

During these trips, the vessel did not engage in trade. None of the articles taken to the Bay of Islands were intended to be sold or exchanged for other goods; nor were they in fact sold or exchanged for other goods. The cargo taken aboard consisted solely of herring taken from the Treaty Coast of Newfoundland in the manner herein described. This herring, upon the return of the vessel to Gloucester, was admitted free of duty as the product of an American fishery.

On each of the above mentioned trips, the customs officials of the Government of Newfoundland levied duties on articles on board the schooner. I did not personally pay these duties. In 1904, they were paid by Captain Williams and in 1906 and 1907 they were paid by Captain Young, who was in the Bay of Islands when the ship

arrived. Duty was paid on barrels and salt notwithstanding the fact that neither left the vessel. The barrels were used solely as receptacles for the fish and were returned to Gloucester with the vessel. The salt was used solely for salting the fish on the deck of the vessel.

On the 1907 voyage, duty was also paid on fishing gear and fishermen's outfit. Gear and outfit were taken to Newfoundland "for the benefit of the voyage.' ." The crew were required to furnish their own nets, anchors, buoy-lines, rubber suits, rubber boots, oiled caps, etc. It It frequently happened, however, that Newfoundlanders shipped at Bay of Islands were lacking in gear and outfit, and in order to utilize their services it was necessary to supply them with the needed articles. During the process of fishing much gear was lost and expended. Storms often destroyed nets, and anchors were frequently lost. The arms of the Bay frequently froze over and in that case the gear would often be taken away when the ice went out. Such gear had to be replaced immediately in order that the fishing might be continued. The only source of supply was the vessel, in view of the fact that the fishing was frequently carried on miles from a settlement. The situation was such that fishing could not be carried on unless the vessel had at all times a supply of gear and outfit. Gear and outfit supplied to the members of the crew were charged against their accounts and deducted from their pay when settlement was made.

Before the vessel was permitted to engage in fishing, the customs authorities at Bay of Islands frequently required the master to file a bond, the condition of the bond being that the fish caught would not be sold at St. Pierre or Miquelon. Two sureties were required on this bond and the charge of each surety was $5.00.

In witness whereof I hereunto set my hand this fourth day of April, A. D. 1924.

ALF THORP.

Subscribed and sworn to before me this fourth day of April, A. D.

I, Owen Whitten of Gloucester, County of Essex and Commonwealth of Massachusetts, being duly sworn, hereby make affidavit and state as follows:

During the years 1907, 1908 and 1910, I was in the employ of the Gorton-Pew Fisheries Company, a Gloucester concern engaged in the