Appendix — U. S. v. LOUISIANA, et al.

Supreme Court brief1974

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Text

No. 9, Original

Inu the

Supreme Court of the United States

OCTOBER TERM, 1974

UNITED STATES OF AMERICA,

Plaintiff,

STATE OF LOUISIANA, ET AL.,

Defendants.

APPENDICES II AND III TO THE EXCEPTIONS

OF THE STATE OF LOUISIANA TO THE REPORT

OF THE SPECIAL MASTER FILED JULY 31,

1974, AND BRIEF IN SUPPORT OF EXCEPTIONS

WILLIAM J. GUSTE, JR.

Attorney General.

P. O. Box 44005

State Capitol

Baton Rouge, Louisiana

70804.

PAUL M. HEBERT,

VICTOR A. SACHSE,

OLIVER P. STOCKWELL,

FREDERICK W. ELLIS,

_ WILLIAM E. SHADDOCK,

Special Assistant a

General,

NORA K. DUNCAN,

Staff Attorney,

Department of Justice,

State of Louisiana.

APPENDIX Il

Part 1

Index to transcript references and to de-

positions in the proceeding before Walter

P. Armstrong, Jr., Special Master ........ 1

Part 2

Index to the evidence introduced by the

State of Louisiana in the proceeding be-

fore Walter P. Armstrong, Jr., Special

SII ssitsaiieslaiitasiicpuiaiaalicteas ileal ina beeeiadip naling 7

Part 3

Index to the evidence introduced by the

United States in the proceeding before

Walter P. Armstrong, Jr., Special Master..159

APPENDIX Ill

Closing Line contentions of the State of

Louisiana including point to point de-

SID snstaprlnsdccsainicrlaseatinncisiniesiiianntiandisamadiiaianal 215

No. 9, Original

in the

Supreme Court of the United States

OCTOBER TERM 1974

UNITED STATES OF AMERICA,

Plaintiff,

STATE OF LOUISIANA, ET AL.,

Defendants.

APPENDIX Il, Part 1

INDEX TO TRANSCRIPT REFERENCES AND

TO DEPOSITIONS IN THE PROCEEDING

BEFORE WALTER P. ARMSTRONG, JR.,

SPECIAL MASTER

TRANSCRIPT

INDEX OF APPEARANCE OF WITNESSES

IN NEW ORLEANS

Witness Volume No. Pages No.

Dr. James P. Morgan I 34-149"

II 150-283'

III 287-425'

IV 426-446"

; 447-559?

V 561-639?

1 Direct

2 Cross

Dr. George H. Lowery, Jr.

Mr. Allan Ensminger

Mr. Joseph Lawrence Billiot

Dr. Leo Bouchez

Mr. J. Y. Christmas

Mr. John Lay

Mr. Richard Yancey

Mr. Jack Hood

Mr. Ory Poret

Mr. Hatley Harrison, Jr.

Dr. Lyle S. St. Amant

8 Redirect

* Recross

VII

Vill

640-647°

648-652*

653-699"

701-711'

712-740?

740-744?

744-746*

756-802"

803-811?

812-817°

817-831’

832-841? |

864-0787

979-995"

996-1103?

1109-1122"

1124-1142'

1143-1160?

1161-1219’

1211-1242?

1244-1260*

1261-1263?

1269-1284"

1476-1492"

1496-1529"

1530-1571?

1578-1604"

1611-1633"

1633-1704?

1707-1725?

1729-1742"

1742-1746?

1746-1747

Dr. John Loos

Mr. Curtis L. Buttorff

Mr. Leo W. Hough

Dr. James P. Morgan

Dr. Alexander Melamid

Mr. Philip Larimore

Mr. David Morgan

Mr. Philip L. Whitaker

5 Traverse

XIII

XIV

XVI

XVII

XVI

XVIII

XXI

XXII

XXIII

XXIV

XXV

XXVI

XXVII

XXVIII

XIX

XXX

1748-1812!

1816-1845"

1845-1855?

1855-1859"

1871-1950"

1977-2034!

260-2081!

2081-2178?

2185-2274?

2275-2289"

2289-2298"

2040-2050"

2325-2441?

2646-2770"

2775-2904"

2907-2960"

2961-3034?

3038-3165"

3169-3209"

3217-3224"

3224-3237°

3237-3283"

3292-3337"

3337-3413"

3414-3420"

3424-3558!

3586-3629"

3629-3694?

3715-3814"

3833-3877"

3880-3926"

3929-3938"

3945-4047"

4047-4064?

, 4

Mr. Lindsay P. Peperone

Mr. Francis Zimmerman

Mr. John L. Rankin

IN WASHINGTON, D.C.

Mr. Arthur I. Cooperman

XXX

XXXI

XXXII

Comm. R. Lawrence Swanson XXXII

Mr. Bennett G. Jones

Mr. Harland R. Cravat

Mr. Joseph K. Wilson

Dr. Charles R. Kolb

Dr. Roger T. Saucier

Mr. Buford K. Meade

* Further redirect

7 Further recross

~ 3-5

XXXII

XXXIIT

XXXV

XXXVI

XXXVII

4081-4091

4091-4094?

4094-4095°

4132-4179"

4179-4183?

4184-4212

4212-4217°

4265-4287"

4287-4330

4330-4351?

4351-4353"

4353-4365"

4413-4449!

4449-4476?

4476-4484"

4485-4521?

4556-4623?

4624-4650?

4650-4655"

4655-4656"

4657"

4665-4676

4676-4677"

4678-4692!

4698-4759"

4759-4811"

4812-4843?

4853-4867"

4867-4879?

4879-4881!

Dr. Louis Henkin

Mr. Donald J. Simon

Mr. James F. Richardson

Mr. Rupert B. Southard

Dr. Robert D. Hodgson

XXXVII

XXXVIII

XXXIX

XLI

IN BATON ROUGE

Mr. Philip B. Larimore

Mr. Curtis Buttorff

Mr. David J. Morgan

Dr. James P. Morgan

XLII

XLIV

XLV

XLVI

4882-4884*

4884°

4887-4927"

4927-4939?

4939-4943"

4943-4947?

4947-5004"

5035-5037°

5037-5114?

§114-5121°

5122-5131"

5140-5219"

5219-5251?

5251-5285"

5300-5451"

5454-5516?

5516-5551°

5572-5722"

5731-5824?

5828-58357

5836-5887"

5887-5908?

5918-5952?

5954-6080

6081-6128?

6132-6204?

6206-6364"

6365-6399?

DEPOSITIONS

Mr. James F. Richardson La. Exh. 123

Dr. A. Joseph Wraicht La. Exh. 123

Mr. Samuel J. Nunez

Mr. Chin Dy Hoy

Mr. Abraham Schouest

Capt. Emanuel Von Lubbe

Mr. Landry Cheramie

Mr. Bennett G. Jones

Mr. Gordon Atwater

Mr. Newton Beauvais

Cmdr. R. Lawrence Swanson

La. Exh. 145, also in-

troduced as La. Exh.

55, tab 195

La. Exh. 146, also in-

troduced as La. Exh.

55, tab 197

La. Exh. 147, also in-

troduced as La. Exh.

55, tab 198

La. Exh. 148, also in-

troduced as La. Exh.

55, tab 194

La. Exh. 149, also in-

troduced as La. Exh.

55, tab 196

U.S. Exhs. 268A and

268B

U.S. Exh. 269

U.S. Exh. 270

U.S. Exh. 417

APPENDIX II, Part 2

INDEX TO THE EVIDENCE INTRODUCED

BY THE STATE OF LOUISIANA IN THE

PROCEEDING BEFORE WALTER P.

ARMSTRONG, JR., SPECIAL MASTER

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

‘Exhibit 6

Exhibit 7

Vita of Dr. James P. Morgan

LPI 837. Official map of Louisiana, 1969

edition showing geological areas.

LPI 1141. Charles G. Holle, Sedimenta-

tion at the Mouth of the Mississippi Riv-

er, in PROCEEDINGS OF SECOND CONFER-

ENCE ON COASTAL ENGINEERING, p. 111

(J. W. Johnson ed. 1951).

J. P. Morgan, Ephemeral Estuaries of the

Deltaic Environment, in ESTUARIES, p. 115

(G. H. Lauff ed. 1967).

J. P. Morgan, “Deltas—A Résumé,” Jour-

nal of Geological Education, Vol. XVIII,

No. 3, pp. 107-117 (May, 1970).

J. P. Morgan, J. M. Coleman and §. M.

Gagliano, Mudlumps at the Mouth of

South Pass, Mississippi River; Sedimen-

tology, Paleontology, Structure, Origin

and Relation to Deltaic Processes, LOU-

ISIANA STATE UNIVERSITY STUDIES; COAST-

AL STUDIES SERIES, No. 10 (1963).

J. P. Morgan, Transparencies, Vol. 1, GP-

1 through GP-31, inclusive, as follows:

LIST OF OVERHEAD TRANSPARENCY ILLUS-

TRATIONS TO ACCOMPANY TESTIMONY OF

JAMES P. MORGAN CONCERNING

GENERAL

GEOLOGY,. GEOLOGIC PROCESSES AND RE-

SULTING MORPHOLOGY OF

Sivan feaira THE MISSISSIPPI

ago transparencies were made by James P. Morgan

or teaching purposes and for illustrating scientific

publications. Where taken from other

aan. sources, refer-

Louisiana

Chrono- Preliminary

logic Identifying

smnwer of Number or

Illustration Citation Description of Illustration

GP-1 604 Drainage basin of the Missis-

sippi River.

GP-2 596 Diagrammatic illustration of the

longitudinal stream profile.

GP-3 1201 Geologic time scale of the Quatev-

nary Period.

GP-4 = 1200 Longitudinal profile of the Mis-

sissippi River comparing present

a level with glacial stage Gulf

evel.

GP-5 | 591 Generalized geologic map of Lou-

isiana in relation to glacial stage

entrenched Mississippi River.

GP-6 601 Movement of stream load, sus-

pended and bed load.

GP-7 1199 Conventional depositional sedi-

mentary sequence in a wate

body. ;

GP-8

GP-9

GP-10

GP-11

GP-12

GP-13

GP-14

GP-15

GP-16

GP-17

GP-18

600

598

605

594

595

599

602

597

590

592

603

Diagrammatic illustration of a

“Gilbert-type” delta. After G. K.

Gilbert, “Lake Bonneville”, 1890.

Idealized concept of delta forma-

tion. Stages A-D.

Hydrography at the mouth of an

idealized distributary.

Longitudinal profiles along an

idealized distributary.

Transverse profiles across an

idealized distributary.

Idealized concept of delta forma-

tion. Stages E-F.

Idealized concept of delta forma-

tion. Stage G.

Idealized representation of de-

positional environments and sedi-

ment types at a distributary

mouth.

Historical sequences of Missis-

sippi Delta lobes from 4600 years

(before present) to present time.

Modified from Kolb and Van

Lopik, 1958.

Modern Mississippi River sub-

deltas compared with maps of

1838 and 1960.

Three-dimensional illustration of

the Birdfoot Delta of the Missis-

sippi River. Modified from H. N.

Fisk, 1961.

GP-19

GP-20

GP-21

GP-22

GP-23

GP-24

GP-25

GP-26

GP-27

GP-28

GP-29

593 Schematic diagram showing del-

taic progradation in a subsiding

delta.

589 Stages in the development of in-

terdistributary bays in an aban-

doned distributary system. From

J. P. Morgan, 1967.

Fig. 3 West Bay in 1816. From J. P.

“Estuaries” Morgan, 1967.

Fig. 4 West Bay in 1922. From J. P.

“Estuaries” Morgan, 1967.

Fig. 5 West Bay in 1958. From J. P.

“Estuaries” Morgan, 1967.

Fig. 8 Cubit’s Crevasse into Bay Rondo

“Deltas” in 1873. From J. P. Morgan,

1970.

Fig. 8 Cubit’s Crevasse into Bay Rondo

“Deltas” in 1901. From J. P. Morgan,

1970.

Fig. 8 Cubit’s Crevasse into Bay Rondo

“Deltas” in 1911. From J. P. Morgan,

1970.

Fig. 8 Cubit’s Crevasse into Bay Rondo

“Deltas” in 1925. From J. P. Morgan,

1970.

Fig. 8 Cubit’s Crevasse into Bay Rondo

“Deltas” in 1933. From J. P. Morgan,

1970.

Fig. 8 Cubit’s Crevasse into Bay Rondo

“Deltas” in 1968. From J. P. Morgan,

1970.

GP-30 Fig. 10 Isopach map showing sedimen-

“Deltas” tary mass in Bay Rondo result-

ing from Cubit’s Crevasse. From

J. P. Morgan, 1970.

GP-31 Fig. 7 Interdeltaic estuarine basin, Mis-

“Estuaries” sissippi Delta. From J. P. Mor-

gan, 1967.

REFERENCES TO SOURCES CITED

Fish, H. N., Bar-finger Sands of the Mississippi Delta.

in GEOMETRY OF SANDSTONE BODIES - A SYMPO-

sium. Tulsa: Am. Assoc. Petroleum Geologists

(1961), pp. 29-52.

Gilbert, G. K., Lake Bonneville: United States Geo-

logical Survey (1890), Monograph No. 1.

Kolb, C. R., and Van Lopic, J. R., Geology of the Mis-

sissippi River Deltaic Plain, Southeastern Lou-

isiana. U. S. ARMY CORPS OF ENGINEERS, WATER-

WAYS EXPT. STA. TECH. REPT. Vicksburg (1958),

pp. 3-483 and 3-484.

Morgan, J. P., Ephemeral Estuaries of the Deltaic

, atl ay in ESTUARIES, G. H. Lauff ed. :

American Assoc. for Advancement of Science

(1967), pp. 115-120.

Morgan, J. P., “Deltas—a Résumé,” Journal of Geo-

p wer he Education. Vol. XVIII, No. 3 (May, 1979),

pp. 107-117.

**#**

Exhibit 8 U.S.C. & G.S. Chart No. 1272 - 22nd edi-

tion, December 2, 1968.

Exhibit 9 Photographs of Dr. J. P. Morgan - Vol-

ume 2, 1 through 41, inclusive, as follows:

LIST OF PHOTOGRAPHS TO ACCOMPANY TES-

TIMONY OF JAMES P. MORGAN CONCERNING

GENERAL GEOLOGY AND MORPHOLOGY OF

THE MISSISSIPPI RIVER DELTA

(All photographs taken by James P. Morgan)

Louisiana

Prelimi-

Chronologic nary Date of

Number of Identifying Photo-

Illustration Number graph Description of Photograph

1 100 6-26-69 Cubit’s Crevasse opening

from Mississippi River

(background )

2 99 6-26-69 Cubit’s Crevasse opening

from Mississippi River

(background) into Bay

Rondo area to the east of

the Mississippi Delta.

3 127 8-27-69 Cubit’s Crevasse area.

Mouth of Bienvenue Pass

in right foreground, Mis-

sissippi Delta.

4 128 8-27-69 Mouth of Dead Wom-

an’s Pass (middle back-

ground), Cubit’s Crevasse

area, Mississippi Delta.

129 8-27-69 Mouth of Dead Woman’s

Pass (middle ground)

Mississippi Delta.

6 102 8-27-69 Town of Venice, La. and

the Jump (background)

leading into West Bay.

Inundation and property

a |

137

136

135

131

134

132

133

damage resulting from

Hurricane Camille.

9-83-69 View northeast of mouth

of Pass Du Bois, Missis-

sippi Delta. West Bay

area in background.

9-3-69 View southeast of mouth

of Pass Du Bois, Missis-

sippi Delta. Aerial view

of area shown on TL-185

through 189.

9-3-69 View north at mouth of

Pass Du Bois, Mississippi

Delta. Ground photograph

showing exhumed marsh

and shell piled up by wave

action resulting from

Hurricane Camille.

9-3-69 Ground photo. View north

at mouth of Pass Du Bois,

Mississippi Delta.

9-3-69 View northwest at mouth

of Pass Du Bois, Missis-

sippi Deita. Ground photo

of exhumed marsh and

scattered shell resulting

from Hurricane Camille.

9-3-69 View north at mouth of

Pass Du Bois, Mississip-

pi Delta. Ground photo-

graph.

9-3-69 View northeast at mouth

120

167

119

118

117

160

8-27-69

9-3-69

8-27-69

6-26-69

9-3-69

of Pass Du Bois, Missis-

sippi Delta. Ground photo-

graph of exhumed marsh.

View downstream along

South Pass, Mississippi

Delta. Note sedimentation

in East Bay (right)

through breaks in the

West Bank of South Pass.

View of west bank, South

Pass, Mississippi Delta.

East Bay in foreground.

Sedimentation in East

Bay, Mississippi Delta,

through breaks in the

West bank of South pass.

West bank of South Pass,

Mississippi Delta (fore-

ground). The Crevasse in-

to Garden Island Bay in

background.

West bank of South Pass,

Mississippi Delta (fore-

ground). Note lighthouse

on the levee at right of

photo.

Sediment-laden water

flowing across Southwest

Pass levees into West Bay,

Mississippi Delta.

West bank of South Pass,

Mississippi Delta. East

Bay to right.

158

163

170

105

145

144

143

104

9-3-69

8-27-69

9-3-69

8-27-69

Crevasse opening into

East Bay from South

Pass, Mississippi Delta.

Midway between Upper

Cave Light and Old Grand

Bayou Light.

Mud flats and marsh ex-

tending into East Bay

from west bank of South

pass, Mississippi Delta.

View looking east-north-

east across shoal in East

Bay, Mississippi Delta.

South Pass and fresh

water reservoir in dis-

tance.

Mouth of Southwest Pass

(right background) and

sand spit extending into

East Bay, Mississippi Del-

ta.

East Bay sand spit. South-

west Pass and levees in

background.

East Bay sand pit. South-

west Pass and levees in

background.

East Bay sand spit. South-

west Pass and levees in

background.

View south along sand

spit in East Bay. South-

140

146

112

150

152

149

west Pass, Mississippi

River in right of photo.

6-26-69 View West toward Mouth

of Southwest Pass show-

ing sand spit extending

northward into East Bay,

Mississippi Delta.

9-3-69 East bank of Southwest

Pass, Mississippi Delta in

foreground. Note sand

spit extending into East

Bay (middle ground).

9-3-69 North end of sand spit in

East Bay. Southwest Pass

in background. Double

Bayou in distance.

8-27-69 View northwest across

Joseph Bayou area. South-

west Pass in background,

Mississippi Delta.

9-3-69 Joseph Bayou area. Up-

per end of East Bay, Mis-

sissippi Delta. Head of

Passes in background, Jo-

seph Bayou in foreground.

9-3-69 View south down Joseph

Bayou into East Bay,

Mississippi Delta.

9-3-69 View east across mouth

of Joseph Bayou, Missis-

sippi Delta. South Pass in

background.

Exhibit 10

Exhibit 10-A

151

154

116

113

147

148

9-3-69 Joseph Bayou area. Up-

per end of East Bay, Mis-

sissippi Delta. Head of

Passes in background,

Joseph Bayou in fore-

ground.

9-3-69 Upper (northern) end of

East Bay, Mississippi Del-

ta. Head of Passes in

background.

8-27-69 View northwest across

Joseph Bayou area, Mis-

Sissippi Delta.

8-27-69 View west across south

end of Joseph Bayou area,

Mississippi Delta.

9-3-69 View southeast across

East Bay. Mouth of Jo-

seph Bayou in center of

photograph. South Pass in

distance.

9-3-69 View southeast across

East Bay. Mouth of Jo-

seph Bayou in left middle

ground. South Pass in

distance.

\ eee

J. P. Morgan, Genesis and Paleonto-

logy of the Mississippi River Mud-

lumps, Louisiana Geological Survey

Bulletin No. 35 (1961). ;

Exhibits to James P. Morgan, Gene-

Exhibit 11

Exhibit 12

sis and Paleontology of the M ississip-

pi River Mudlumps, Louisiana Geo-

logical Survey, Bulletin No. 35

(1961).

J. P. Morgan, J. R. Coleman and S.

M. Gagliano, Mudlumps: Diapiric

Structures in Mississippi Delta Sedi-

ments, in DIAPIRISM AND DIAPIRS,

Am. Assoc. Petroleum Geologists,

Memoir No. 8, pp. 145-161 (1968).

Photographs by Dr. J. P. Morgan of

Mudlumps, Vol. 3, 1 through 52, in-

clusive, as follows:

RATIONS

LIST OF PHOTOGRAPHS AND ILLUST

TO ACCOMPANY TESTIMONY OF JAMES P.

MORGAN CONCERNING MUDLUMPS AT

THE MOUTHS OF THE MISSISSIPPI RIVER

(all illustrations or photographs by James P.

Morgan unless otherwise annotated )

Louisiana

Prelimi-

nary Date of

Chronologic Identifying Photo-

Number of Number or graph or

Illustration Citation Publication

Fig. 1, 1968 Areas of mudlump de-

Mem. 8 velopment at major dis-

Description of Photograph

or Illustration

tributary mouths, Mis-

sissippi River Delta.

98 6-26-69 Mudlump islands seaward

from Pass A _ Loutre-

North Pass, Mississippi

Delta (background).

3 97 6-26-69 Mudlump island seaward

from mouth of Pass A

Loutre, Mississippi Delta.

4 95 6-26-69 Mudlump islands seaward

from mouth of Pass A

Loutre, Mississippi Delta.

5 96 6-26-69 Detail of largest mudlump

island off mouth of Pass

A Loutre, Mississippi Del-

ta. Island is also shown on

photos TL-54 and TL-56.

6 Fig. 6, Sept. 61 Schematic cross section of

Bull. 35 typical mudlump, indicat-

ing stratigraphic and

structural characteristics.

7 Fig. 4, Sept. 61 Furrowed surface appear-

Bull. 35 ance of mudlump island.

Aerial photograph of NP-

3 taken April 1948 (H.

N. Fisk) *.

8 93 6-26-69 Mudlump seaward from

mouth of Northeast Pass,

Mississippi Delta. See pho-

to TL-51 for relationsh i>

to land.

9 92 6-26-69 Ground photograph show-

ing details of mudlump is-

land at mouth of North-

east Pass, Mississippi Del-

ta. See photo TL-51 for re-

lationship to land.

10 125 8-27-69 Southeast Pass mudlump

? Photograph taken April 1948 by H. N. Fisk.

124

islands with the mouth of

the pass in background.

See TL-132.

6-26-69 Mouth of Southeast Pass,

Mississippi Delta (back-

ground) and some of the

mudlump islands.

8-27-69 Southeast Pass mudlump

islands. View taken look-

ing seaward. See TL-134.

6-26-69 Mudlump seaward from

the mouth of Southeast

Pass, Mississippi Delta.

Old Balize Bayou in left

background.

6-26-69 Detail of mudlump island

nearest mouth of South-

east Pass, Mississippi Del-

ta. (See photo TL-40, TL-

45 and TL-46 also of same

island. )

6-26-69 Same as TL-43. Detail of

mudlump island nearest

mouth of Southeast Pass,

Mississippi Delta (See

photo TL-40).

6-26-69 Same as TL-43. Detail of

mudlump island nearest

mouth of Southeast Pass,

Mississippi Delta (See

photo TL-40).

6-26-69 Group of three mudlump

121

122

123

Fig. 44, Sept. 61 Aerial

Bull. 35

islands seaward from the

mouth of Old _ Balize

Bayou, Mississippi Delta.

6-26-69 South Pass jetties, sand

spit and mudlumps. Fresh

water-marine water boun-

dary in left foreground.

6-26-69 Detail of central mudlump

shown on photo TL-37.

Mudlumps No. 89-90 and

South Pass sand spit and

jetties in distance.

8-27-69 East Jetty South Pass,

Mississippi Delta (fore-

ground). Coast Guard

Station and Bar Pilot Sta-

tion on west bank. Mud-

lump islands in back-

ground.

8-27-69 Shoal area waves over

South Pass sand spit

which was breached by

Hurricane Camille. South

Pass mudlump islands in

left middle ground.

8-27-69 South Pass mudlump is-

lands. Waves breaking

(left middle ground)

show position of sand spit

which was breached by

Hurricane Camille.

photograph of

South Pass mudlumps.

Left to right, Sp-4, Sp-1,

Sp-2 and Sp-3.

82 6-26-69 Spit composed of organic

matter (coffee grounds)

extending westward from

mudlumps 89-90 at mouth

of South Pass into East

Bay, Mississippi Delta.

77 6-26-69 Ground photo showing

spit comprised of organic

material (coffee grounds)

extending East Bay from

Mudlump 89-90 at mouth

of South Pass, Mississippi

Delta.

168 9-3-69 Ground photograph look-

ing south of South Pass

mudlump 89-90. Note

wave cut bench and “ra-

massis” (plant debris)

from Hurricane Camille.

Fig. 16, Sept. 61 Raised terrace, left fore-

Bull. 35 ground, has resulted from

secondary uplift of island

SP-1. Tilting has caused

the cliff to increase from 2

feet (foreground to about

5 feet (background). Two

earlier terraces are shown

at left.

Fig. 7, 1968 Coring operations on mud-

Mem. 8 lump 89-90, South Pass.

977 8-63 View looking south of

989

1006

979

981

borehole casing in mud-

lump SP 89-90. Small

mudlump island in back-

ground is mudlump 92,

“the castle.”

6-63 View looking south at

mudlump 92, “the castle.”

1-69 View looking northeast

of South Pass sand spit

with mudlump No. 92 in

foreground.

6-26-69 Detail of central mud-

lump shown on photo TL-

27, mouth of South Pass,

Mississippi Delta.

6-26-69 Three mudlumps breaking

the water surface at

mouth of South Pass, Mis-

sissippi Delta. Note: Mud-

lumps are shown on the

seaward (right margin)

side of photo TL-37.

6-26-69 Detail of rear (eastern-

most) mudlump shown on

photo TL-27, South Pass,

Mississippi Delta.

11-64 Ground view on south side

of mudlump 94, South

Pass.

11-64 Ground view of mudlump

94 with geologists collect-

ing fossils.

967 11-64 Ground photograph look-

ing toward the northwest

of the west side of mud-

lump 93 at South Pass.

Photograph taken at low

tide.

Fig. 4, 1968 South Pass mudlump is-

Mem. 8 lands mapped during peri-

od from 1876 to 1961.

Fig. 5, 1968 Island and submarine

Mem. 8 mudlump distribution at

South Pass. Data from

123 maps dated between

1876 and 1961.

Fig. 42, Sept.61 Advance of the bar at

Bull. 35 South Pass, 1920 to 1950.

Fig. 43, Sept. 61 Map of the bar at South

Bull. 35 Pass. Submarine mud-

lumps indicated.

Fig. 10,1968 Sites of appearance of ini-

Mem. 8 tial mudlumps and their

progression, determined

from maps dated between

1867 and 1961.

Fig. 40, Sept.61 Advance of the bar at

Bull. 35 Southwest Pass, 1920 to

1950.

Fig. 41, Sept. 61 Map of the bar at South-

Bull. 35 west Pass. Submarine

mudlumps indicated.

Fig. 36, Sept. 61 Schematic diagram show-

Bull. 35 ing relationship between

47A

47B

47C

47D

47E

47F

47G

Fig. 6, 1968

Mem. 8

Fig. 22, 1968

Mem. 8

Fig. 22, 1968

Mem. 8

Fig. 22, 1968

Mem. 8

Fig. 22, 1968

Mem. 8

Fig. 23, 1968

Mem. 8

Fig. 23, 1968

Mem. 8

Fig. 23, 1968

Mem. 8

bar growth and mudlump

development.

Bore-hole locations and

profile line along South

Pass sand spit.

Diagrammatic represen-

. tation of South Pass mud-

lump origin and develop-

ment, Stage A.

Diagrammatic represen-

tation of South Pass mud-

lump origin and develop-

ment, Stage B.

Diagrammatic represen-

tation of South Pass mud-

lump origin and develop-

ment, Stage C.

Diagrammatic represen-

tation of South Pass mud-

lump origin and develop-

ment, Stage D.

Diagrammatic represen-

tation of South Pass mud-

lump origin and develop-

ment, Stage E.

Diagrammatic represen-

tation of South Pass mud-

lump origin and develop-

ment, Stage F.

Diagrammatic represen-

tation of South Pass mud-

lump origin and develop-

ment, Stage G.

Di tic represen PUBLICATIONS CITED

i ammati -

a a r = tation of South Pass mud- Morgan, James P., “Mudlumps at the Mouths of the

lump origin and develop- Mississippi River,” in Genesis and Paleontology

ment, Stage H. of the Mississippi River Mudlumps. Louisiana

Geological Survey, Bulletin No. 35 (1961), pp.

1-116.

Morgan, James P., Coleman, James M., and Gagliano,

Sherwood M., Mudlumps: Diapirie Structures in

Mississippi Delta Sediments, in DIAPIRISM AND

DIAPIRS. American Association of Petroleum Geo-

48 Fig. 9, 1968 Shallow subsurface stra-

Mem. 8 tigraphy and structure of

South Pass. Line of sec-

tion is shown in Fig. 6.

49 Fig. 18,1968 Multiple reverse faulting

Mem. 8 found on wave-planed sur- logists, Memoir No. 8 (1968), pp. 145-161.

face - Figae Pass mud- Morgan, James P., Coleman, James M., and Gagliano,

lump 94.

Sherwood M., Mudlumps at the Mouth of South

Pass, Mississippi River; Sedimentology, Paleonto-

50 Fig. 5, 1963 Comparison maps show-

C.S.1 ing South Fess — = Pan eens erase Gopmmnanry pom

me 0 a aha & COASTAL STUDIES SERIES, No. 10 (1963).

lands. Exhibit 13 LPI 1224)

51 LPI Dec. View looking southwest of Exhibit 14 LPI 1228)

No. 968 1969 cu tienen anae e Exhibit 15 LPI 1227) Photos of birds and peli-

foreground and mudlump Exhibit 16 LPI 1226) cans by Dr. Morgan

93 in left rear of photo- Exhibit 17 LPI 1225)

7. Exhibit 18 LPI 1060, “Areas in Dispute in Lou-

52 LPI Dec. Steamship aground in isiana Closing Line Contentions.”

No. 965 1969 ae —- Exhibit 19 LPI 618, Mudlumps photo, M-101-6

dated June 26, 1969, Mouth of South-

east Pass, Mississippi Delta, with

mudlump islands in foreground, view

toward the northwest.

Exhibit 20 LPI 617, Photograph by Dr. James

Exhibit 21

Exhibit 22

Exhibit 23

Exhibit 23-A

Exhibit 24

Exhibit 25

Exhibit 26

Exhibit 26-A

Exhibit 27

P. Morgan concerning distribution of

mudlumps at South Pass, M-101-5

dated June 26, 1969, South Pass

mudlumps and sand spit, Mississippi

Delta. Mudlump 93 on left of photo.

Mudlump 89-90 in the central part

of photo and new mudlumps offshore

in right central part of photo.

LPI 362 through 430—Louisiana

Original Brief Exhibit No. 21, 1

through 69 (includes Talcott’s 1839

map).

LPI 1202—copy of notes by Dr.

James P. Morgan and Mr. David

Morgan which reflect the published

nautical charts of the period of 1873

through 1969 for the Mississippi

Delta Region and East Bay changes

reflected thereby.

LPI 1054. Set of display materials

pertaining to historic changes and

semicircle data in East Bay. (1839-

1956)

LPI 1054 (same as above with the

overlays)

A list of scientific publications by

Dr. James P. Morgan.

Case of The Anna, 5 C. Rob. 373.

LPI 647—Bucket Bend Bay Exhibit.

Corrected sheet to Ex. 26.

LPI 1053—Opinion of the Solicitor

Exhibit 28

Cox, dated December 20, 1963, ap-

proved by the then Attorney General,

Robert Kennedy, addressed to the

General, the Honorable Archibald

Secretary of the Interior, at the re-

quest of the President concerning

lands originally formed as islands

in the marginal seas. Attached to the

opinion is a letter dated December

20, 1963, by the Attorney General to

the Secretary of the Interior expres-

sing his accord.

Matters relating to Tern Islands and

other Bird Reservations as follows:

Description Identifying Number

1. Executive Order of August 8,1907 199 & 217

2. “Bird Lore for 1907,” pp. 229 et

seq.

203

3. Map of the State of Louisiana com-

piled from the official records of

the General Land Office dated 1916

(See Exh. 258) 66

4, Map of the State of Louisiana com-

piled from the official records of

the General Land Office dated 1930 215

5. Map of Plaquemines Parish (South

Section), Louisiana, dated 1958 216

6. Quadrangle Map of East Delta,

Louisiana, 1959 edition 204

7. 31 F.R. 16024 dated December 15,

1966

10.

11.

12.

13.

14,

15.

16.

17.

31 F.R. 7686 dated May 24, 1968

31 F.R. 16027 dated December 15,

1966

31 F.R. 16027 dated December 15,

1966

Alaska Pacific Fisheries v. United

States, 39 S.C. 40, 248 U.S. 78

(1918)

United States of America v. State

of Alaska, et al. 423 F. 2d 764

(1970)

General correspondence regarding

Tern Islands Reservation

Bureau of Land Management Mis-

cellaneous File No. 1883786

Fish and Wildlife Service Files

LAEO—Louisiana, Tern Islands

and Gas and Oil LA—Louisiana,

Tern Islands

First Formal Request for Admis-

sions by State of Louisiana dated

April 29, 1970, and Response to

Louisiana’s First Formal Request

for Admissions by United States

State of Louisiana’s Interrogatories

dated February 3, 1970, and Re-

sponse of United States thereto

dated March 4, 1970

State of Louisiana’s Interrogatories

dated October 23, 1969, and An-

swers of United States with attach-

205

206

207

211 & 218

220

219

18.

19.

20.

21.

22.

23.

24,

25.

26.

ments thereto dated December 23,

1969

State of Louisiana’s Reyuest to the

Bureau of Sports Fishery dated De-

cember 8, 1969, and Response of

United States thereto dated Janu-

ary 20, 1970

Directory of National Wildlife Re-

fuges

Wildlife Sanctuaries in Louisiana

from First Biennial Report of the

Department of Wild Life and Fish-

eries Commission, 1944 and 1945

Memorandum dated September 25,

1952, addressed to the Bureau of

Land Management suggesting re-

vocation of Tern Islands Reserva-

tion

Public Land Order No. 892 of April

15, 1953, 18 Federal Register 2342,

dated April 22, 1953, which revoked

Tern Islands Reservation

Birds of Sabine National Wildlife

Refuge

Birds of Lacassine National Wild-

life Refuge

Lacassine National Wildlife Refuge

Executive Order of August 17,

1907, creating Shell Keys Reserva-

tion

209

210

201

202

819

820

821

822

27. General correspondence regarding

Shell Keys Reservation

98. Birds of the Delta National Wild-

life Refuge

29. National Wildlife Refuges in South-

east Region 4

80. General correspondence regarding

East Timbalier Island

831. Gulf Island National Wildlife Re-

fuges (Breton)

32. General correspondence regarding

Breton National Wildlife Refuge

33. Inspection Report of East Tim-

balier Bird Reservation dated April

7, 1947, by John Lynch, Biologist

84. Refer the Court to 18 U.S.C. 41

eee

Exhibit 29 LPI 215 - Map of the State of Louisi-

ana compiled from the Official Records

824

212

213

823

825

826

1162

of General Land Office - 1930

Exhibit 30 LPI 1007 - Picture of bird display at

Louisiana State University Museum

Exhibit 31 LPI 775)

Exhibit 32 LPI 776)

Exhibit 33 LPI 807)

Exhibit 34 LPI 812)

Exhibit 35 LPI 814) Photographs taken by Allan

Exhibit 36 LPI 816) Ensminger on flight over

Exhibit 37

Exhibit 38

Exhibit 39

Exhibit 40

Exhibit 41

Exhibit 42

Exhibit 43

Exhibit 44

Exhibit 45

Exhibit 46

Exhibit 47

Exhibit 48

LPI 800) Mississippi Delta area in

January, 1970

LPI 805)

LPI 815)

LPI 798)

LPI 1192 - View of fresh dredge spoil

jetties (Photograph by Mr. Allan En-

sminger )

LPI 787 - Photograph taken by Mr.

Allan Ensminger on flight over Mis-

sissippi Delta area January, 1970

LPI 783 - Photograph taken by Mr.

Allan Ensminger on flight over Mis-

sissippi Delta area, January, 1970

LPI 1191 - View of portion of spit

above water at mouth of Pass Tante

Phine (Photograph by Mr. Allan En-

sminger )

LPI 1187 - View of portion of spit at

Pass Tante Phine above water (Photo-

graph by Mr. Allan Ensminger)

LPI 1188 - View of islands breaking

up north of West Bay (Photograph by

Mr. Allan Ensminger)

LPI 1189 - View of island headland at

north side of West Bay (Photograph

by Mr. Allan Ensminger)

LPI 780 - Photograph taken by Mr.

Allan Ensminger on flight over Missis-

sippi Delta area in January, 1970

Exhibit 49 Index to Mr. Allan Ensminger’s photo-

graphs

Exhibit 50 U. S. C. & G. S. Chart No. 1275, Edi-

tion 10, June 27, 1970

Exhibit 51 A History of the Inland Water Line,

as follows:

A HISTORY OF THE INLAND WATER LINE

CONTENTS

Louisiana Preliminary

Description Identifying Number

1. Refer the Court to the Act of Au-

gust 19, 1890 (Rules for the pre-

vention of collisions on the high

seas )

2. Refer the Court to United States

Revised Statute 4233, Act of April

29, 1864, c. 69, 13 Stat. 58

8. Refer the Court to Act of February

19, 1895, and amendments

(28 Stat 672

32 Stat 829

37 Stat 736

60 Stat 1097

33 USC 151)

4. Refer the Court to Act of June 7,

1897 (30 Stat 96)

5. Department of Treasury Circular

No. 127 issued June 13, 1895 188

6. Treasury Department Circular No.

88 of 1897 1161

10.

11.

12.

13.

14,

15.

16.

17.

Refer the Court to 1895 Edition of

United States Coast & Geodetic Sur-

vey Coast Chart No. 194 (Exhibit

6 to Louisiana Brief of October,

1968)

Treasury Department Circular No.

107 of 1900

Department of Commerce and La-

bor Circular No. 61 of March 9,

1905

Department of Commerce and La-

bor Circular No. 88 of 1905

Department of Commerce and La-

bor Circular No. 158 of November

21, 1907

Refer the Court to 1907 Edition of

United States Coast & Geodetic Sur-

vey Coast Chart No. 194 (Exhibit

8 to Louisiana Brief of October,

1968)

Department of Commerce Circular

No. 230 of 1911

Refer the Court to Exhibit 10 to

Louisiana Brief

Department of Commerce Circular

No. 230 of June 8, 1917

Department of Commerce Circular

No. 230 of October 10, 1927

Department of Commerce Circular

No. 230 of December 26, 1928

367

189

190

191

192

369

193

194

195

196

18.

19.

20.

21.

22.

23.

24.

Exhibit 52

Department of Commerce Circular

No. 230 of December 8, 1932

Refer the Court to Federal regula-

tion of December, 1953

Refer the Court to Exhibits 12, 14,

16 and 18 of Louisiana Brief of

October, 1968 (prior editions of

United States Coast & Geodetic

Survey Charts No. 194 and super-

ceding Chart No. 1272)

Refer the Court to Exhibit 20 of

Louisiana Brief

Refer the Court to Maps and other

materials showing location of In-

land Water Lines designated and

defined under the Act of February

19, 1895

Copy of transcript of hearing on

the proposed ciange of the line of

Demarcation h ld at New Orleans,

Louisiana, August 7, 1967

Copy of transcript of public hearing

concerning the lines of demarca-

tion between Inland and Interna-

tional Rules of the Road, conducted

at Morgan City, Louisiana, on Au-

gust 3, 1967

197

373

375

377

379

381

1027

Census of the United States, as follows:

LOUISIANA EXHIBIT No. 52

CENSUS OF THE U.S.

CONTENTS

Louisiana Preliminary

Description Identifying Number

1. A published book entitled, Measure-

ment of Geographic Area by Mal-

colm J. Proudfoot, published by the

Bureau of the Census of the United

States Department of Commerce in

connection with the 1940 16th cen-

sus of the United States 72

2. Area Measurement reports pub-

lished by the Bureau of the Census

of the United States Department of

Commerce showing areas of Lou-

isiana: 1960, July, 1967, G. E. -

20, No. 20 1129

Exhibit 53 The Captain of the Port of New Or-

leans, as follows:

THE CAPTAIN OF THE PORT OF

NEW ORLEANS

CONTENTS

Louisiana Preliminary

Description Identifying Number

1. Refer the Court of CFR Subpart

67.50

2. Refer the Court to 33 CFR Part 6,

Parts 121, 122 and 124, 125, 126

10.

11.

12.

13.

14.

15.

Refer the Court to 46 CFR Parts

146, 147

Refer the Court to 33 CFR sub-

part 3.40-75

Coast Guard seizure of Przemyal

dated October 29, 1927

Coast Guard seizure of “Emilia G”

dated September 24, 1925

Coast Guard seizure No. 874 of

Fleur de Lis

Coast Guard seizure of Memthis

dated April 22, 1930

Coast Guard seizure of St. Francisco

United States Coast Guard Law

Enforcement at Sea Relative to

Smuggling

Refer the Court to the prohibition

case of Ford, et al. v. United States,

47 S.Ct. 531

Refer the Court to the prohibition

case of Cunard S. S. Co. v. Mellon,

43 S. Ct. 504

Refer the Court to the prohibition

case of Cook v. United States, 53

S.Ct. 305

State of Louisiana’s Second Formal

Requests for Admissions (with at-

tachments) and Response of United

States

State of Louisiana’s Interrogatories

221

222

223

224

225

226

16.

17.

Exhibit 54

PERMITS ISSUED BY UNITED STATES ARMY

of October 23, 1969, and Response

of United States

United States’ Interrogatories of

January 20, 1970, and Response of

State of Louisiana

Refer the Court to 33 CFR Sub-

part 37.50 and 33 CFR subpart

3.40 - 10 regarding New Orleans

Marine Inspection Zone

as follows:

Permits Issued by United States Army

Corps of Engineers for Dredging Ca-

nals and Other Operations in East Bay,

CORPS OF ENGINEERS FOR DREDGING

CANALS AND OTHER OPERATIONS IN

EAST BAY

CONTENTS

Louisiana Preliminary

Description Identifying Number

Permit file from records of New

Orleans District Corps of Engineers,

granting permit to Shell Oil Com-

pany to dredge in East Bay area

with identifying cover sheet marked

GM 276

A Department of the Army permit

from New Orleans District Office

of the Corps of Engineers to the

California Company, dated Septem-

ber 28, 1953, to dredge in tribu-

1152

40 41

taries of East Bay area with re- 4. Act 121 of 1896 26

lated files from New Orleans Dis-

trict Corps of Engineers 1153 5. Act 153 of 1902 =

3. Permit from New Orleans District 6. Act 52 of 1904 “A

of the Corps of Engineers, dated 7. Act 144 of 1908 23

correspondence including request, ;

dated 22 September 1950, from 9. Act 127 of 1912 21

Shell Oil Company the permittee, 10. Act 6 of 1917 20

with cover title sheet marked GM

192 from records of New Orleans 11. Act 139 of 1924 19

District, U. S. Corps of Engineers 1154 12. Act 258 of 1926 18

4. Request from Shell Oil Company to 13. Act 67 of 1932 17

Corps of Engineers, New Orleans

District, dated April 21, 1949, and 14. Act 227 of 1944 263 & 16

permit dated May 12, 1949, to Shell 15. R.S. 56:421 through 460

= Cage Sr Coy See 16. Louisiana Land & Fish Co. v. Gas-

records of New Orleans District ; t 45 La. Ann. 759

Corps of Engineers 1155 gee", ; ;

sane 17. Doucet v. Texas Co., 17 So. 2d 340,

205 La. 312

Exhibit 55 Fishing Regulations in Five Volumes 18. Opinion of Attorney General’s Of-

as follows: fice dated December 8, 1937 228

VOLUME I

VOLUME 2

FISHING R

. 6 AT 19. Oyster Lease No. 3405 dated No-

CONTENTS vember 17, 1914, to United Fish

& Oyster Co. 722

Louisi Prelimi

Description Identifying Number” 20 Oyster Lease No. 356 dated July

20, 1904, to Miss Henrietta Mc-

1. Act 18 of 1870 29 Laughlin 747

B Act 108 of 1000 = 21. Oyster Lease No. 355 dated July

8. Act 110 of 1892 27 20, 1904, to Mrs. F. McLaughlin 732

22.

23.

24,

25.

26.

35.

Oyster Lease No. 357 dated July

20, 1904, to Miss M. McLaughlin

Oyster Lease No. 299 dated May

18, 1904, to Mrs. F. J. Lobrano

Oyster Lease No. 642 dated Decem-

ber 21, 1904, to Julien Cadro

Oyster Lease No. 3402 dated No-

vember 17, 1914, to United Fish

& Oyster Co.

Oyster Lease No. 57 dated June

17, 1903, to Louis Diemell

. Oyster Lease No. 300 dated May

18, 1904, to Miss Bertha Diemel

. Oyster Lease No. 47 dated May

20, 1903, to Peter Spongia

. Oyster Lease No. 46 dated May

20, 1903, to Louis Spongia

. Oyster Lease No. 45 dated May

20, 1903, to Peter Spongia

. Oyster Lease No. 59 dated June

17, 1903, to John McLaughlin

. Oyster Lease No. 40 dated May

20, 1903, to John Conaway

Oyster Lease No. 643 dated De-

cember 21, 1904, to Frank Morgan

Oyster Lease No. 644 dated De-

cember 21, 1904, to Capt. Erick

Anderson

Oyster Lease No. 636 dated De-

727

740

749

754

717

693

738

723

716

715

720

750

733

36.

37.

38.

39.

40.

41.

42.

43.

44.

45.

46.

47.

48.

cember 21, 1904, to Thomas Jack-

son

Oyster Lease No. 308 dated July

20, 1904, to Edward W. Fitzgerald

Oyster Lease No. 307 dated July

20, 1904, to John W. Jackson

Oyster Lease No. 319 dated July

20, 1904, to Thomas Jackson

Oyster Lease No. 44 dated May

20, 1903, to Frank Miller

Oyster Lease No. 294 dated May

18, 1904, to Frank Richmond

Oyster Lease No. 297 dated May

18, 1904, to Hope Lamb & John

Thomas Burns

Oyster Lease No. 295 dated May

18, 1904, to Warrick Brown

Oyster Lease No. 292 dated May

18, 1904, to Steven F. Purgley

Oyster Lease No. 291 dated May

18, 1904, to Gilmore & Jackson

Oyster Lease No. 774 dated Feb-

ruary 15, 1905, to Joseph Cadro

Oyster Lease No. 775 dated Feb-

ruary 15, 1905, to Messrs. O’Brien

& Connaway

Oyster Lease No. 48 dated May

20, 1903, to Walter Miller

Oyster Lease No. 4168 dated No-

vember 22, 1918, to Erick Ander-

son

748

651

648

655

718

694

674

675

673

714

731

730

695

662

49.

50.

51.

52.

53.

54.

55.

56.

57.

58.

59.

60.

Oyster Lease No. 3400 dated No-

vember 17, 1914, to United Fish

& Oyster Co.

Oyster Lease No. 3401 dated No-

vember 17, 1914, to United Fish

& Oyster Co.

Oyster Lease No. 315 dated July

20, 1904, to A. E. Washburn

Oyster Lease No. 313 dated July

20, 1904, to Morgan Loar & Co.

Oyster Lease No. 317 dated July

20, 1904, to John Conaway

Oyster Lease No. 3420 dated De-

cember 5, 1914, to Mrs. Frank

McLaughlin

Oyster Lease No. 303 dated May

18, 1904, to William A. Loar

Oyster Lease No. 335 dated July

20, 1904, to Andrew Spongin

Oyster Lease No. 640 dated De-

cember 21, 1904, to John Repath

& Co.

Oyster Lease No. 3403 dated No-

vember 17, 1914, to United Fish &

Oyster Co.

Oyster Lease No. 3408 dated No-

vember 17, 1914, to United Fish

& Oyster Co.

Oyster Lease No. 3406 dated No-

vember 17, 1914, to United Fish

& Oyster Co.

653

686

689

652

741

682

692

688

687

685

683

684

61.

62.

63.

64.

65.

66.

67.

68.

69.

70.

71.

Oyster Lease No. 3422 dated De-

cember 5, 1914, to Mrs. Frank

McLaughlin

Oyster Lease No. 3398 dated No-

vember 17, 1914, to United Fish

& Oyster Co.

Oyster Lease No. 3416 dated De-

cember 5, 1914, to Mrs. Frank

McLaughlin

Oyster Lease No. 3404 dated No-

vember 17, 1914, to United Fish

& Oyster Co.

Oyster Lease No. 3275 dated Sep-

tember 11, 1914, to Zanenovich &

Spongia

Oyster Lease No. 4165 dated No-

vember 22, 1918, to Brick Ander-

son

Oyster Lease No. 4176 dated No-

vember 27, 1918, to Leonard F.

Edgecombe

Oyster Lease No. 3770 dated Sep-

tember 10, 1910, to Frank J.

Lobrano

Oyster Lease No. 3407 dated No-

vember 17, 1914, to United Fish

& Oyster Co.

Oyster Lease No. 337 dated July

20, 1904, to John Spongia

Oyster Lease No. 293 dated May

18, 1904, to E. D. Jones

680

681

725

734

753

755

756

757

758

760

765

72.

73.

74.

75.

76.

77.

78.

79.

80.

81.

82.

83.

Oyster Lease dated March 25,

1903, to Whale Bay Oyster Co.

Oyster Lease No. 3399 dated No-

vember 17, 1914, to United Fish

& Oyster Co.

Oyster Lease No. 1005 dated Au-

gust 16, 1905, to Lobrano & Mc-

Laughlin

Oyster Lease No. 2842 dated July

15, 1912, to United Fish & Oyster

Co.

Oyster Lease No. 298 dated May

18, 1904, to S. B. George & T.

Kelly

Oyster Lease No. 349 dated No-

vember 18, 1908, to Nebert Burns

Oyster Lease No. 353 dated No-

vember 18, 1908, to Octave Barrios

Oyster Lease No. 386 dated July

20, 1904, to Red Fish Bay Oyster

Co.

Oyster Lease No. 342 dated No-

vember 18, 1908, to Thomasin

Burrois

Oyster Lease No. 351 dated June

15, 1905, to Ambroise Ansardi

Oyster Lease No. 348 dated No-

vember 18, 1908, to Augustin

Burrois

Oyster Lease No. 350 dated No-

vember 18, 1908, to Lucies Buras

774

742

751

752

772

712

708

700

690

710

713

711

84,

85.

86.

87.

88.

89.

90.

91.

92.

93.

94.

95.

96.

97.

Oyster Lease No. 346 dated June

15, 1905, to P. V. Lacoste

Oyster Lease No. 383 dated July

20, 1904, to James Kiger

Oyster Lease No. 384 dated July

20, 1904, to Luke Johnson

Oyster Lease No. 387 dated July

20, 1904, to Delesdernier & Kiger

Oyster Lease No. 382 dated July

20, 1904, to Joseph P. Logn

Oyster Lease No. 385 dated July

20, 1904, to George W. Deles-

dernier

Oyster Lease No. 388 dated July

20, 1904, to J. T. Delesdernier

Oyster Lease No. 352 dated July

20, 1904, to John Ansel, Jr.

Oyster Lease No. 341 dated June

15, 1905, to E. J. Rodricquez

Oyster Lease No. 343 dated June

1, 1931, to Frank Musemeche

Oyster Lease No. 347 dated No-

vember 18, 1908, to Jeff C. Wenck

Oyster Lease No. 311 dated July

20, 1904, to Thomas Bulot & Louis

Baril

Oyster Lease No. 314 dated July

20, 1904, to M. Baril

Oyster Lease No. 320 dated July

20, 1904, to John Ricovard

696

706

701

699

707

697

698

709

702

704

691

668

661

664

98.

99.

100.

101.

102.

103.

104,

105.

106.

107.

108.

109.

Oyster Lease No. 321 dated July

20, 1904, to J. G. Davis

Oyster Lease No. 56 dated May

20, 1903, to W. P. Hingle

Oyster Lease No. 302 dated May

18, 1904, to Mrs. Alexander Con-

way

Oyster Lease No. 296 dated May

18, 1904, to Mrs. Charles Post

Oyster Lease No. 310 dated July

20, 1904, to Alexander Conway

Oyster Lease No. 42 dated May

20, 1903, to Gustave Gusdrof

Oyster Lease No. 49 dated May

20, 1903, to August Johnson

Oyster Lease No. 43 dated May

20, 1903, to J. J. Williams

Oyster Lease No. 50 dated May

20, 1903, to Erick Anderson

VOLUME 3

Oyster Lease No. 2737 dated De-

cember 1, 1911, to W. J. Arm-

strong

Oyster Lease No. 318 dated July

20, 1904, to Charles Post

Oyster Lease No. 344 dated No-

vember 18, 1908, to George Bur-

rois

656

663

658

659

660

650

649

657

676

677

654

705

110.

111.

112.

113.

114,

115.

116.

117.

118.

119.

120.

121.

Oyster Lease No. 309 dated July

20, 1904, to John Dugas

Oyster Lease No. 4194 dated De-

cember 12, 1918, to W. J. Arm-

strong

Oyster Lease No. 3636 dated Octo-

ber 18, 1915, to Nick Popich

Oyster Lease No. 1503 dated June

19, 1907, to W. J. Armstrong

Oyster Lease No. 340 dated July

20, 1904, to Chris Ansel

Oyster Lease No. 345 dated June

15, 1905, to Erick Anderson

Oyster Lease No. 336 dated July

20, 1904, to S. B. George & T.

Kelly

Oyster Lease No. 3788 dated Sep-

tember 19, 1917, to Gulf Pack-

ing Co.

Oyster Lease No. 41 dated May

20, 1900, to Anton Duhon

Oyster Lease No. 11639 dated July

20, 1948, to Golden Meadows Fish-

eries Co.

Oyster Lease No. 11638 dated July

20, 1948, to Golden Meadows Fish-

eries Co.

Oyster Lease No. 1 640 dated July

20, 1949, to Golden Meadows Fish-

eries

721

724

726

729

746

759

768

771

773

764

767

728

122.

123.

124,

125.

126.

127.

128.

129.

130.

131.

132.

133.

Oyster Lease No. 11641 dated July

20, 1948, to Golden Meadows Fish-

eries Co.

Oyster Lease No. 11637 dated July

20, 1948, to Golden Meadows Fish-

eries Co.

Oyster Lease No. 11642 dated July

20, 1948, to Golden Meadows Fish-

eries Co.

Oyster Lease No. 7061 dated July

15, 1929, to Constant Callahan

Oyster Lease No. 3855 dated No-

vember 8, 1917, to Foret, Pele-

grin & Bro.

Oyster Lease No. 9905 dated Sep-

tember 25, 1942, to A. St. Martin

& Co.

Oyster Lease No. 2506 dated May

23, 1918, to Thompson & Nini

Oyster Lease No. 5757 dated Feb-

ruary 17, 1925, to Alonzo Lee

Oyster Lease No. 7241 dated Jan-

uary 15, 1930, to Aelane Pitre

Oyster Lease No. 7053 dated July

13, 1929, to Matis Vidos

Oyster Lease No. 7039 dated July

5, 1929, to Louisiana Oyster &

Fish Co.

Oyster Lease No. 6032 dated Feb-

ruary 6, 1936, to Colsom & Re-

beld

761

766

762

719

735

736

737

739

744

665

666

671

134,

135.

136.

137.

138.

139.

140.

141.

142.

143.

144,

Oyster Lease No. 9337 dated Sep-

tember 29, 1939, to P. R. Norman

& N. H. Breaux

Oyster Lease No. 8252 dated Octo-

ber 10, 1934, to P. R. Norman

& N. H. Breaux

Oyster Lease No. 4061 dated Au-

gust 14, 1918, to Louis Robardi

Oyster Lease No. 8251 dated Octo-

ber 16, 1934, to P. R. Norman

& N. H. Breaux

Oyster Lease No. 8690 dated No-

vember 9, 1936, to P. R. Norman

& N. H. Breaux

Oyster Lease No. 9338 dated Sep-

tember 29, 1939, to P. R. Norman

& N. H. Breaux

Oyster Lease No. 7164 dated Octo-

ber 14, 1929, to Lester J. Bou-

dreaux

Oyster Lease No. 4042 dated July,

1918, to Alvin Chauvin

Oyster Lease No. 7641 dated Jan-

uary 25, 1905, to Emelien Buras

Oyster Lease No. 7175 dated No-

vember 2, 1929, to Oliver Terre-

bonne

Oyster Lease No. 11869 dated

April 20, 1949, to Frank & Vin-

cent Bacala

667

743

679

763

669

670

678

672

703

770

745

145.

146.

147.

148,

149.

150.

151.

Oyster Lease No. 7095 dated Octo-

ber 4, 1929, to Leo Pitre

Copy of certified copy of applica-

tion for survey for oyster purposes

and list dated October 9, 1914, by

United Fish and Oyster Company

affecting part of East Bay

Copy of certified copy of lease of

water bottoms for oyster purposes

from Louisiana Conservation Com-

mission to United Fish and Oys-

ter Company dated October 14,

1914, affecting acreage in East

Bay

Copy of certified copy of applica-

tion for survey and lease for oys-

ter purposes dated October 9, 1914,

by United Fish and Oyster Com-

pany to Louisiana Conservation

Commission affecting acreage in

East Bay

Copy of certified copy of lease of

water bottoms for oyster purposes

from Conservation Commissioner

of Louisiana to United Fish and

Oyster Company dated October 14,

1914, affecting coverage in East

Bay

Copy of Survey Map for portions

of East Bay for oyster bedding

purposes for United Fish and

Oyster Company

Copy of Survey Map for portions

769

152.

153.

154.

155.

156.

157.

of East Bay for oyster bedding

purposes for United Fish and Oys-

ter Company

Copy of certified copy of oyster

lease map of South Pass and East

Bay

Department of Conservation, State

of Louisiana Survey showing loca-

tion and area of Oyster Leases

between South Pass and South-

west Pass, Plaquemines Parish,

compiled under the direction of

Frank T. Payne, Engr. 1921

Part of map from records of Lou-

isiana Wild Life and Fisheries

Commission showing location of

Leases 48 ; 4,168; 249; 3400; 3257;

3401; 301; 315; 313; 317; 3420;

303; 335; 640; 3403; 3408; 3406;

3422; 3398

Part of map from records of Lou-

isiana Wild Life and Fisheries

Commission showing location of

Leases 349; 353; 386; 342; 334;

351; 348; 350; 346; 383; 384;

387; 382; 385; 388; 352; 341;

343; 347

Part of map from records of Lou-

isiana Wild Life and Fisheries

Commission showing location of

Leases 311; 314; 320

Part of map from records of Lou-

isiana Wild Life and Fisheries

1164

841

842

843

158.

159.

160.

161.

162.

163.

164.

Commission showing location of

Leases 321; 56; 321; 302; 296; 310

Part of map from records of Lou-

isiana Wild Life and Fisheries

Commission showing location of

Leases 42; 49; 43; 50; 2737

Part of map from records of Lou-

isiana Wild Life and Fisheries

Commission showing location of

Leases 11,639; 11,638; 11,640;

11,641; 11,637; 11,642; 14,461;

14,240

Part of map from records of Lou-

isiana Wild Life and Fisheries

Commission showing location of

Leases 7053; 7039; 6032; 9337;

8252; 4061; 8251; 8690; 9338A

Part of map from records of Lou-

isiana Wild Life and Fisheries

Commission showing location of

Leases 7164; 4042

Part of map from records of Lou-

isiana Wild Life and Fisheries

Commission showing location of

Leases 7641; 7175; 11,896; 7095;

7039; 7053

Part of map from records of Lou-

isiana Wild Life and Fisheries

Commission showing location of

Lease 18,330

Part of map from records of Lou-

isiana Wild Life and Fisheries

845

846

840

844

847

848

838

165.

166.

167.

168.

169.

170.

171.

172.

173.

174.

175.

176.

177.

178.

179.

180.

Commission showing location of

Leases 5,013 and 4,482

Report on Division of Oysters &

Water Bottoms by James N. Mc-

Connell, Director from Second

Biennial Report 1946 - 1947

Report of Division of Oysters &

Water Bottoms by James N. Mc-

Connell, Director from Fourth

Biennial Report 1950 - 1951

Report on Division of Oysters &

Water Bottoms by James N. Mc-

Connell, Chief, from Sixth Bienni-

al Report 1954-1955

VOLUME 4

Act 245 of 1910

Act 168 of 1912

Act 193 of 1916

Act 86 of 1918

Act 68 of 1920

Act 103 of 1926

Act 50 of 1932

Act 314 of 1940

Act 10 of Extra Session of 1940

Act 143 of 1942

Act 78 of 1946

Act 51 of 1948

Act 92 of 1956

839

229

230

231

181.

182.

183.

184,

185.

186.

187.

188.

189.

190.

191.

192.

193.

194.

195.

196.

197.

198.

Copy of portion of Map of Lou-

isiana attached to Act 452 of 1962

Act 53 of 1958

Act 452 of 1962

Louisiana Revised Statutes 56:

491 through 526

Gulf Coast Shrimp, Fish & Oyster

Data September, 1954, United

States Fish & Wildlife Service

Examples of records of trials and

arrest records from Louisiana

Wild Life and Fisheries Commis-

sion

Statement of W. S. Werlla

Statement of James N. McConnell

Statement of Julius L. Book dated

December, 1956

Statement of Julius L. Book dated

November, 1956

Statement of R. L. Eddy, Jr.

Statement of Louis R. Cabirac

Statement of J. C. DeArmas, Jr.

Deposition of Captain Emanual

Von Lubbe

Deposition of Samuel J. Nunez

Deposition of Landry Cheramie

Deposition of Chin Dy Hoy

Deposition of Abraham Schouest

227

828

829

830

831

832

833

834

835

1145

1146

1147

1148

1149

199.

200.

201.

202.

203.

204.

205.

206.

207.

208.

209.

210.

211.

212.

213.

214.

215.

VOLUME 5

Letter from W. S. Werlla dated

February 2, 1948

Enforcement Division from Sec-

ond Biennial Report of the De-

partment of Wild Life & Fisheries

—1946 & 1947

Division of Enforcement for 1954

& 1955 from Biennial Report of

the Department of Wild Life &

Fisheries

Airplane Activity Report from

Second Biennial Report of the De-

partment of Wild Life & Fisheries

—1946 & 1947

Act 117 of 1855

Act 13 of 1871

Act 24 of 1910

Act 132 of 1910

Act 172 of 1910

Act 196 of 1910

Act 254 of 1910

Act 183 of 1912

Act 258 of 1912

Act 42 of 1914

Act 271 of 1914

Act 30 of 1915

Act 10 of 1916

274

275

276

277

232

233

234

235

236

237

238

239

240

241

242

243

244

216.

217.

218.

219.

220.

221.

222.

223.

224.

225.

226.

227.

228.

229.

230.

231.

232.

233.

234.

235.

236.

237.

Act 20 of 1918

Act 105 of 1918

Act 106 of 1918

Act 268 of 1918

Act 250 of 1920

Act 252 of 1924

Act 253 of 1924

Act 68 of 1932

Act 206 of 1932

Act 93 of 1936

Act 210 of 1936

Act 131 of 1934

Act 225 of 1936

Act 80 of 1938

Act 77 of 1940

Act 311 of 1940

Act 153 of 1942

Act 329 of 1948

Act 227 of 1944

Louisiana Revised Statutes 56:

311 through 415

Distribution of Fishing Effort in

Waters Outside the Coast Line of

the Northern Gulf of Mexico with

Special Reference to Shrimp

Fishes Taken in the Menhaden

245

246

247

248

249

250

251

252

253

254

255

256

257

258

259

260

261

262

263

264

265

238.

239.

240.

241.

242.

243.

244.

245.

246.

Fishery of Alabama, Mississippi

and Eastern Louisiana

Tables of Statistics from 1885 to

1956

Report by Bureau of Commercial

Fisheries, ''nited States Depart-

ment of Interior, Fish & Wildlife

Service, New Orleans, Louisiana,

dated September 9, 1968

Report by H. Roger Hunter, Jr.,

dated December 13, 1956

United States Fish & Wildlife Ser-

vice Tabulation of Commercial

Landings of Fish and Shellfish at

ports in Plaquemines Parish, dat-

ed September 9, 1968

Tabulations of Hunting Licenses

Sold by Parishes

Herbert R. Padgett, “Some Phy-

sical and Biological Relationships

to the Fisheries of the Louisiana

Coast,” in The Professional Geo-

grapher (September, 1966), pp.

423-439

Act 210 of 1946

Louisiana Revised Statutes R.S.

56:551 through 561

Refer the Court to Louisiana Re-

vised Statutes 56:1-56:1623

9:1101

9:2791

266

267

268

269

270

827

271

272

273

247.

248.

14:217

15:48.1

30 :211-216

Act 11 of 1921

Refer the Court to Louisiana Ex-

hibit 40

249. Act 52 of 1921

Exhibit 56

STATE CONTROL OVER SEISMIC OPERATIONS

PPP.

as follows:

CONTENTS

Louisiana Preliminary

Identifying Number

Description

Act 77 of 1940

Act 152 of 1942

Act 175, Section 2 of 1954

Seismic Permit No. 2138 dated No-

vember 28, 1949

Seismic Permit No. 1193 dated

June 5, 1947

Seismic Permit not numbered dated

January 26, 1950

Seismic Permit No. 2213 dated

January 30, 1950

Seismic Permit No. 2214 dated

January 30, 1950

1127

278

401

200

State Control Over Seismic Operations,

281

282

283

1069

1070

1071

1072

1073

21.

22.

Seismic Permit No. 1229 dated

June 19, 1947

Seismic Permit No. 1051 dated

December 23, 1946

. Seismic Permit No. 2231 dated

April 4, 1950

Seismic Permit No. 2389 dated

June 19, 1950

Seismic Permit No. 17 dated Janu-

ary 30, 1941

Seismic Permit No. 2363 dated July

17, 1950

Seismic Permit No. 914 dated Au-

gust 23, 1946

Seismic Permit No. 900-R dated

October 25, 1946

Seismic Permit No. 1160 dated

April 29, 1947

Seismic Permit No. 1055 dated

January 7, 1947

Seismic Permit No. 1077 dated

February 3, 1947

. Seismic Permit No. 535-R dated

December 16, 1944

Seismic Permit No. 606-R dated

July 4, 1945

Seismic Permit No. 1454 dated

Jan. 13, 1948

1074

1075

1076

1077

1078

1079

1080

1081

1082

1083

1084

1085

1086

1087

23.

24.

25.

26.

27.

28.

29.

30.

31.

32.

33.

34.

35.

36.

37.

Seismic Permit No. 1372 dated No-

vember 21, 1947

Seismic Permit No. 1385 dated De-

cember 4, 1947

Seismic Permit No. 1421 dated De-

cember 29, 1947

Seismic Permit No. 1363 dated No-

vember 13, 1947

Seismic Permit No. 1365 dated No-

vember 13, 1947

Seismic Permit No. 1452 dated

January 13, 1948

Seismic Permit No. 1515 dated

February 27, 1948

Seismic Permit No. 1778 dated

November 8, 1948

Seismic Permit No. 1558 dated

April 6, 1948

Seismic Permit No. 1808 dated De-

cember 22, 1948

Seismic Permit No. 1809 dated De-

cember 22, 1948

Seismic Permit No. 1080-R dated

May 5, 1947

Seismic Permit No. 1557 dated

April 6, 1948

Seismic Permit No. 1571 dated

April 15, 1948

Seismic Permit No. 1878 dated

February 7, 1949

1088

1089

1090

1091

1092

1093

1094

1095

1096

1097

1098

1099

1100

1101

1102

45.

46.

47.

48.

49.

Seismic Permit No. 1814 dated De-

cember 22, 1948

. Seismic Permit No. 1209 dated

June 12, 1947

. Seismic Permit No. 1168 dated

May 9, 1947

. Seismic Permit No. 1896 dated

Pobruary 21, 1949

delsmic Permit No. 1639 dated

July 6, 1948

Seismic Permit No. 1881, approved

September 16, 1946, to the Califor-

nia Company

Seismic Permit No. 2512, approved

April 13, 1948, to Shell Oil Com-

pany, Inc.

Seismic Permit No. 2512-R, ap-

proved April 13, 1949, to Shell Oil

Company, Inc.

Seismic Permit No. 2512-R, ap-

proved April 13, 1949, to Shel! Oil

Company, Inc.

Seismic Permit No. 2090-R, ap-

proved July 28, 1947, to Shell Oil

Company, Inc.

Seismic Permit No. 1521, approved

November 13, 1945, to the Califor-

nia Company

Seismic Permit No. 2336, approved

November 3, 1947, to the Texas

Company

1103

1104

1105

1106

1107

919

920 |

921

922

923

924

925

64 65

50. Seismic Permit No. 2348, approved 8. The History and Regulation of the

November 24, 1947, to the Cali- : . “or

fosude Company 996 Shell Dredging Industry in Louisi-

p ana, Compiled by the Louisiana

51. Seismic Permit No. 4814, approved Wild Life and Fisheries Commis-

October 26, 1953, to Cities Service sion (1968). 71

Oil Company 927 Exhibit 58 State Control Over Mineral Resources,

52. Seismic Permit No. 4999, approved as follows:

March 23, 1954, to Cities Service

Oil Company 928 STATE CONTROL OVER MINERAL RESOURCES

53. Seismic Permit No. 2389, approved CONTENTS

December 22, 1947, to Shell Oil Louisiana Prelimé

Company, Inc. 929 Description Identifying Reaber’

54. Seismic Permit No. 3051, approved 1. State Lease Number 749 481

August 5, 1945, to Shell Oil Com- 2. State Lease Number 750 482

pany, Inc. 930 8. State Lease N

55. Seismic Permit No. 2430, approved a ane une vas <8

February 2, 1948, to General Geo- 4. State Lease Number 752 484

physical Company 931 5. State Lease Number 753 485

56. Seismic Permit No. 3046, approved 6. State Lease Number 754 486

August 3, 1949, to Shel! Oil Com-

pany, Ine. 932 7. State Lease Number 755 487

eee 8. State Lease Number 756 488

Exhibit 57 Oyster Shell Leases, as follows: 9. State Lease Number 1522 489

quasen eames. - 10. State Lease Number 1523 490

LEAS 11. State Lease Number 746 491

CONTENTS 12. State Lease Number 747 492

7 nee Louisiana Preliminary 13. State Lease Number 749 493

escription entifying Number 14. State Lease Number 757 494

1. Act 42 of 1914 289 15. State Lease Number 758 495

17.

18.

19.

20.

21.

22.

23.

24,

25.

26.

27.

28.

29.

30.

31.

32.

33.

34,

35.

36.

37.

38.

39.

40.

41.

State Lease Number 760

State Lease Number 1395

State Lease Number 1396

State Lease Number 1397

State Lease Number 1398

State Lease Number 1399

State Lease Number 1521

State Lease Number 1798

State Lease Number 1799

State Lease Number 1800

State Lease Number 1801

State Lease Number 2812

State Lease Number 2813

State Lease Number 2814

State Lease Number 2815

State Lease Number 2816

State Lease Number 2817

State Lease Number 2818

State Lease Number 998

State Lease Number 999

State Lease Number 1007

State Lease Number 1008

State Lease Number 1009

State Lease Number 1010

State Lease Number 1011

497

498

499

500

501

502

503

504

505

506

507

508

509

510

511

512

513

514

515

516

517

518

519

520

521

42.

43.

44,

45.

46.

47.

48.

49,

50.

51.

52.

53.

54.

55.

56.

57.

58.

59.

60.

State Lease Number 1012

State Lease Number 1388

State Lease Number 2474

State Lease Number 997

State Lease Number 1000

State Lease Number 1006

State Lease Number 1013

State Lease Number 1014

State Lease Number 1015

State Lease Number 2592

State Lease Number 2665

State Lease Number 2666

State Lease Number 2667

State Mineral Lease No. 335, 1936

State Mineral Lease No. 188, 1928

State Mineral Lease No. 192, 1928

State Mineral Lease No. 195, 1928

Refer the Court to a map which re-

flects information concerning areas

affected by mineral leases granted

by the State of Louisiana as reflect-

ed by the records of the Louisiana

State Mineral Board since the pe-

riod of the creation of that Board.

It pertains to East Bay.

Refer the Court to an exhibit which

reflects the same sort of informa-

tion as does the exhibit bearing La.

Preliminary Identifying Number

522

523

524

525

526

527

528

529

530

531

532

533

534

1203

1204

1205

1206

1064

61.

62.

63.

65.

66.

67.

68.

69.

70.

Exhibit 59

1064, except that it pertains to the

Caillou Bay Area.

Map showing lease block locations

in South Pass Area

U. S. Department of the Interior,

Geological Survey, Number, 1950,

Mid Continent Map No. 1603

Pertinent parts of Outer Continen-

tal Lease Maps of Louisiana, pub-

lished by U. S. Department of the

Interior, Bureau of Land Manage-

ment

A map published by the Depart-

ment of Conservation of the State

of Louisiana entitled, Oil and Gas

Map of Louisiana

Map showing lease block locations

in Ship Shoal Area

U. S. Department of the Interior

Geological Survey; October, 1950,

Mid Continent Map No. 1607, Ship

Shoal Area

Refer the Court to Louisiana Brief

Exhibit Number 38

Refer the Court to Louisiana Brief

Exhibit Number 39

List of well permits prior to 1956

Cumulative well Completions and

Footage Drilled

Pollution Control, as follows:

1065

898

899

1150

1151

900

901

399

400

279

280

POLLUTION CONTROL

CONTENTS

Louisiana Preliminary

Description Identifying Number

1. Act 68, Section 12 of 1932 284

2. Act 367 of 1940 287

3. Act 385, Section 12 of 1948 285

4. Act 386, Section 12 of 1948 286

5. Rules Governing Disposal of Waste

Oil, Oil Field Brine, etc. 288

6. Notes of Jack Hood and pollution

regulations 836

Exhibit 60 Vita of Dr. Leo J. Bouchez

Exhibit 61-A_ _—‘ First drawing or sketch by Dr. Leo

J. Bouchez.

Exhibit 61-B Second drawing or sketch by Dr. Leo

J. Bouchez.

Exhibit 62 Written opinion of Dr. Leo J. Bou-

chez, “The Changing Configuration

of the Coast and the Law.”

Exhibit 63 L. J. Bouchez, The Regime of Bays

in International Law, A. W. Sythoff-

Leyden (1964).

Exhibit 64 LPI 827-A—Data sheet compiled

from Gulf Coast Shrimp Data of the

U. S. Department of the Interior, on

shrimp boat trips

Exhibit 65 Vita of J. Y. Christmas

Exhibit 66

Exhibit..67

Exhibit 68

Exhibit 69

Exhibit 70

Exhibit 71

LPI—Yu. A. Torin, “Oceanographic

Conditions and Fishing in the Gulf of

Mexico During Autumn and Win-

ter,” (Okeonologicheskie usloviya i

promysel ryby v. Meksikanskom

zalive v. oseene-zimii period), in

Trudy Atlanticheskogo Nauchno-Is-

sledovatel’ skogo Instituta Rybnogo

Khozyaistva i Okeanografil Atlan-

NIRO), No. 11, p. 4-11 (1964)

LPI 841—Part of map from records

of Louisiana Wild Life and Fisheries

Commission showing location of

leases 48; 4,168; 249; 3400; 3257;

3401; 301; 315; 313; 317; 3420; 303;

335; 640; 3403; 3408; 3406; 3422;

3398.

LPI 46—Copy of certified copy of

oyster lease map of South Pass and

East Bay

LPI 846—Part of map from records

of Louisiana Wild Life and Fisher-

ies Commission showing location of

leases 52; 49; 43; 50; 2787

LPI 842—Part of map from records

of Louisiana Wild Life and Fisher-

ies Commission showing location of

leases 349; 353; 386; 342; 334; 351;

348; 350; 346; 383; 384; 387; 382;

385; 388; 352; 341; 343; 347

LPI 839—Part of map from records

of Louisiana Wild Life and Fisheries

Commission showing location of

leases 5013 and 4482.

Exhibit

LPI 843—Part of map from records

of Louisiana Wild Life and Fisheries

Commission showing location of

leases 311; 314; 320

LPI 845—Part of map from records

of Louisiana Wild Life and Fisheries

Commission showing location of

leases 321; 56; 321; 302; 296; 310

LPI 844—Part of map from records

of Louisiana Wild Life and Fisheries

Commission showing location of

leases 7053; 7039; 6032; 9337; 8252;

4061; 8251; 8690; 9338

LPI 847—Part of map from records

of Louisiana Wild Life and Fisheries

Commission showing location of

leases 7164; 4042

LPI 848—Part of map from records

of Louisiana Wild Life and Fisheries

Commission showing location of

leases 7641; 7175; 11,896; 7095;

7039; 7053

LPI 838—Part of map from records

of Louisiana Wild Life and Fisheries

Commission showing location of

lease 18,330

LPI 840—Part of map from records

of Louisiana Wild Life and Fisheries

Commission showing location of

leases 11,639; 11,638; 11,640; 11,-

641; 11,637; 11,642; 14,461; 14,240

Louisiana Oyster Lease No. 334

Exhibit 80

Exhibit 81

Exhibit 82

Exhibit 83

Exhibit 84

Exhibit 85

Exhibit 86

Exhibit 87

Exhibit 88

Exhibit 89

Exhibit 90

Exhibit 91

Exhibit 92

Louisiana Oyster Lease No. 18330

Louisiana Oyster Lease No. 301

Louisiana Oyster Lease No. 654

Louisiana Oyster Lease No. 5013

Louisiana Oyster Lease No. 4482

Louisiana Oyster Lease No. 3257

LPI 1222—Certified copies of parts

of the file of State Mineral Lease

579

LPI 1223—Certified copies of parts

of the file of State Mineral Lease

580

LPI 1221—Certified copies of parts

of the file from State Mineral Lease

335

LPI 1220—Certified copies of docu-

ments comprising parts or portions

of the file, State Mineral Lease 195

LPI 1219—Certified copies of docu-

ments comprising parts of the file,

State Land Lease 192

LPI 1218—Certified copies of docu-

ments comprising parts or portions

of the file of the State Mineral Lease

188

LPI 1217—Certified copies of ex-

cerpts from index book at the State

Land Office of Louisiana pertaining

to State Mineral Lease Nos. 188, 192,

195, 335, 579 and 580

Exhibit 93

Exhibit 94

Exhibit 95

Exhibit 96

LPI 1170 through 1176 as follows:

LPI 1170—Plat of T. 22 and 23 S.,

R. 32 E., Louisiana Meridian, ap-

proved Sept. 25, 1875

LPI 1171—Plat of T. 22 S., R. 32 E.

Louisiana Meridian, approved De-

cember 8, 1842

LPI 1172—Plat of T. 21 and 22 §S.,

R. 19 E. St. Helena meridian, ap-

proved July 16, 1832

LP 1173—Plat of T. 24 S., R. 32

and 33 E. Louisiana meridian, ap-

proved Sept. 25, 1875

LPI 1174—Plat of T. 22S., R. 31 E.,

Louisiana meridian, approved De-

cember 8, 1842

LPI 1175—Plat of T. 24 S., R. 30

and 31 E., Louisiana meridian, ap-

proved May 18, 1842

LPI 1176—Plat of T. 23 S., R. 31

and 32 E. Louisiana meridian, ap-

proved Dec. 8, 1842

LPI 1184—Copy of quadrangle map

entitled “South Pass Quadrangle”

LPI 1064—This is a map which re-

flects information concerning areas

affected by mineral leases granted by

the State of Louisiana as reflected by

the records of the Louisiana State

Mineral Board since the period of the

creation of that Board. It pertains to

East Bay.

LPI 1065—This exhibit reflects the

same sort of information as does the

Exhibit 97

Exhibit 98

Exhibit 99

Exhibit 100

Exhibit 101

Exhibit 102

Exhibit 103

Exhibit 104

exhibit bearing Louisiana Prelimi-

nary Identifying Number 1064, ex-

cept that it pertains to the Caillou

Bay area

LPI 1025—Map showing outer limit

of areas claimed as the minimum ex-

tent of inland waters Louisiana

would be entitled to under issues 1A

through E

LPI 1027—Maps and other materials

showing location of Inland Water

Lines designated and defined under

the Act of February 19, 1895

LPI 53—Copy of Chart No. 194,

Edition 8, date, September, 1901.

LPI 899—U. S. Department of the

Interior, Geological Survey, Novem-

ber, 1950, Mid Continent Map No.

1603

LPI 901—U. S. Department of the

Interior, Geological Survey; October,

1950, Mid Continent Map No. 1607,

Ship Shoal Area

LPI 900—Map showing lease block

locations in Ship Shoal Area

LPI 898—Map showing lease block

locations in South Pass area

LPI 1059—This exhibit contains a

collection of cartographic materials

relating to the Ascension-Barataria

Bay area 7 and 10 of the statement

of issues. It shows possible overlarge

Exhibit

105

106

107

108

109

110

111

112

closing lines and related contentions

of Louisiana, plus alternative con-

tentions of Louisiana within this

area; and related data

Page 2 of Biennial Report of State

Mineral Board dated June, 1950

LPI 336—Report of John Jay to the

President of Congress from Madrid,

May 26, 1780, letter dated May 11,

1780, pp. 722-725

LPI 337—Communications of the

Honorable the French Minister to a

Committee of Congress at a Second

Conference, February 2, 1780, pp.

488-490

LPI 335—Proceedings of Congress

as to conditions of pacification and

particularly as to the Mississippi and

Fisheries, February 23, 1779, pp.

58-61

LPI 338—Congress—Proceedings as

to the Conditions of Pacification and

particularly as to the Mississippi and

the Fisheries, September 17, 1779,

pp. 324-326

LPI 340—Vol. IV, John Jay to the

President of Congress, November 6,

1780, excerpt pp. 134-138

LPI 339—Vol. IV, Letter of Benja-

min Franklin to John Jay, October

2, 1780, pp. 74-76

LPI 341—Vol. IV, John Jay to the

Exhibit 113

Exhibit 114

Exhibit 115

President of Congress, October 3,

1781, excerpt pp. 742-745

LPI 348—The Debates and Proceed-

ings of the Congress of the United

States with an appendix containing

important state papers and public

documents and all the laws of a pub-

lic nature. 7th Congress, 2nd Ses-

sion from December 6, 1802, to

March 3, 1803, Vol. 12, Washington:

Gale & Seaton, 1851. Mr. Madison to

Charles Pinckney, November 27,

1802, pp. 1058-1059

LPI 351—The Debates and Proceed-

ings of the Congress of the United

States with an appendix containing

important state papers and public

documents and all the laws of a pub-

lic nature. 7th Congress, 2nd Session

from December 6, 1802, to March 3,

1803, Vol. 12, Washington: Gale &

Seaton, 1851. The Purchase of Lou-

isiana, January 1803, pp. 370-374

LPI 345—American State Papers,

Documents, Legislative and Execu-

tive, of the Congress of the United

States, from the 1st Session of the

Ist to the 3rd Session of the 13th

Congress, inclusive: commencing

March 3, 1789 and ending March 3,

1815. Walter Lowrie, & Matthew St.

Clair Clarke, eds., Foreign Relations,

Vol. II, Washington: Published by

Gale & Seaton, 1832, No. 18 France

Exhibit 116

Exhibit 117

Exhibit 118

Exhibit 119

and Spain—Louisiana 7th Congress,

2nd Session Robert R. Livingston to

the Secretary of State No. 3, Janu-

ary 7, 1802, pp. 536-537. Footnote

in book: “The date should, no doubt,

be 1803.”

LPI 355—H. A. Washington, The

Writings of Tiomas Jefferson, Vol-

ume IV, Taylor & Maury, (1854)

pp. 456-460. Letter to M. Dupont,

February 1, 1803.

LPI 354—Treaty for the Cession of

Louisiana, April 30, 1803, 8 Stat.

200-7.

LPI 352—The Debates and Proceed-

ings of the Congress of the United

States, Eleventh Congress, Third

Session, December 3, 1810 to March

3, 1811, Washington: Gales & Sea-

ton, 1853. “An act to enable the peo-

ple of the Territory of Orleans to

form a constitution and State Gov-

ernment, and for the admission of

such State into the Union, on an

equal footing with the original states

and for other purposes,” pp. 1326-8

LPI 353—The Debates and Proceed-

ings of the Congress of the United

States, Twelfth Congress, First Ses-

sion, November 4, 1811 to July 6,

1812, Washington: Gales & Seaton,

1853. “An act for the admission of

the State of Louisiana into the Union

and to extend the laws of the U. S.

to the said State,” pp. 2264-2266

Exhibit 120 Map 4 of 8 of the Set of 54 maps

Exhibit 120-A Map 5 of 8 of the Set of 54 maps

Exhibit 120-B Map 6 of 8 of the Set of 54 maps

Exhibit 121 Photograph album of Curtis L. But-

torff, containing the following series

of photographs:

Description of Louisiana Exhibit 121—Series of

Photographs

902-22; LPI 992; Corps of Engineers; 3 October

1929

902-68; LPI 994; Corps of Engineers; 3 Octo-

ber 1929

INO-1-157; Corps of Engineers; 14 October 1940

20V311RWM1063; United States Exhibit; 1

October 1946

M-17-88-3 ; Corps of Engineers; 5 June 1949

724-193; United States Exhibit; 1 July 1954

24-116; LPI 537; Corps of Engineers; 29 Febru-

ary 1956

L596; C. & G.S.; 23 October 1956

8. L6948; C. & G.S.; 11 October 1958

11.

12.

144; LPI 544; Corps of Engineers; 8 November

1959

L8728; C. & G.S.; 30 November 1959

L9121; C. & G.S.; 7 December 1959

0932; C. & G.S.; 23 October 1956

13. 61; LPI 546; Corps of Engineers; 13 October 1960

62; LPI 547; Corps of Engineers; 13 October 1960

14. 112; LPI 550; Corps of Engineers; 17 October

1961

15. 75; Corps of Engineers; 23 November 1962

16. 5-1032; Corps of Engineers; 18 September 1965

17. $8995; C. & G.S.; 8 October 1965

18. 6-12; Source unknown; 23 February 1967

19. 59-61; LPI 562; Corps of Engineers; 15 Novem-

ber 1969

20. E4977; C. & G.S.; 30 January 1970

21. 4873; C. &G.S.; 24 January 1970

22. 8181R;C.&G.S.; 24 January 1970

23. 8281R;C. &G.S.; 30 January 1970

Exhibit 121-A_ Dr. James P. Morgan overlay of

Figure 2 from Exhibit 6

Exhibit 121-B Photos—Stereo Partners, as follows:

Louisiana Exhibit 121B—Series of Photographs

INO-1-158; Corps of Engineers

24 January 1970; L8182R;C. &G.S.

30 January 1970; E4976; C.&G.S.

30 November 1959; L8727; C. & G.S.

7-59-145; Corps of Engineers; LPI 545

30 January 1970; L8280R; C. &G. S.

15 November 1969; 59-64; Corps of Engineers;

LPI 564

SF rrFreenr PP

8. 6-61-113; Corps of Engineers; LPI 551

9. 23 October 1956; L595; C. & G.S.

10. 9-60-61; Corps of Engineers; LPI 546

11. 1 October 1946; 21V311RWM1063 16PS 6P183

12. 18 September 1965; 5-1031; Corps of Engineers

13. 12-62-74; Corps of Engineers

14. 29 February 1956; 24-115 P-55; Corps of En-

gineers ; LPI 536

15. 1-7-54; 724-192; Corps of Engineers

16. 8 October 1965; S8996; C.&G.S.

17. 1-7-54; 724-192; Corps of Engineers

Exhibit 122

Exhibit 123

1895 Chart No. 194

LPI-1144, Depositions of Dr. A. Jo-

seph Wraight and Mr. James F.

Richardson

EXHIBITS

W-1 October 3, 1969, letter to Mr.

Frederick W. Ellis from

Wraight

RW-2 May 26, 1969, Chart No. 1272

(with markings)

R-1 October 29, 1935, Chart No.

1272, see Exh. 164

R R-2 H-6172

R R-3 H-6513

R R-4 H-6492 (copy of portion)

R R-5 H-6492 (film 1:30,000)

R R-6 T-5407

R R-7 May 26, 1969, Chart No. 1272

(clean)

Exhibit

124

125

126

127-A

127-B

127-C

128-A

128-B

129-A

129-B

129-C

129-D

130

December 6, 1969, edition of Chart

No. 1272

LPI 1010—Copy of letter and report

from Mr. Leo W. Hough, State of

Louisiana, Department of Conserva-

tion, Louisiana Geological Survey,

dated July 31, 1970

Drilling Activity in East Bay and

Caillou Bay before Interim Agree-

went of October 12, 1956

C. & G. S. Photo No. L-9090, 7 De-

cember 1959

C. & G. S. Photo No. L-9091, 7 De-

cember 1959

C. & G. S. Photo No. L-9092, 7 De-

cember 1959

C. & G. S. Photo No. L-8987, 3 De-

cember 1959

C. & G. S. Photo No. L-8988, 3 De-

cember 1959

C. & G. S. Photo No. L-9031, 3 De-

cember 1959

C. & G. S. Photo No. L-9032, 3 De-

cember 1959

C. & G. S. Photo No. L-9033, 3 De-

cember 1959

C. & G. S. Photo No. L-9034, 3 De-

cember 1959

Affidavit by Mr. Frank J. Williams

Exhibit

131

132

133

134

134-A

134-B

134-C

134-D

134-E

134-F

135

136

identifying Sheet 38 of Louisiana

Exhibit 21

Overlay of right inset on Chart No.

1272 introduced as Exhibit 8

Illustrative sketch of seasonal mud-

lump growth process

LPI 1057—Alternative methods of

planimetering area of an indentation

are graphically illustrated on this

exhibit

LPI 1198—Photo Mosaic—Copies

of documents in connection with

our answers and objections to the

First Formal Interrogatories of the

United States and the related Re-

quests for Admissions in globo

Mosaic 21

Mosaic 22

Mosaic 23

Mosaic 24

Mosaic 25

Mosaic 26

LPI 360—Samuel H. Lockett, Lou-

isiana As It Is. Baton Rouge: Lou-

isiana State University Press

(1969). The original manuscripts

of this geological survey were writ-

ten in 1876 and 1891.

LPI 1011-Copy of picture of

Southwest Pass on wall at Lou-

Exhibit 137

Exhibit 138

Exhibit 139

Exhibit 140

Exhibit 141

Exhibit 142

isiana State University School of

Geoscience

LPI 55 - Copy of a letter from the

Liddell (Moses St. John R. and

Family) Papers in the Department

of Archives and Manuscripts of

Louisiana State University

LPI 56-Copy of page from the

“Daily Picayune” of Thursday

morning, August 14, 1856, obtained

from Library of Louisiana State

University

LPI 57-Copy of page from the

“Daily Picayune” of Friday morn-

ing, August 15, 1856, obtained

from Library of Louisiana State

University

LPI 58-Copy of page from the

“Daily Picayune” of Saturday

morning, August 16, 1856, obtain-

ed from Library of Louisiana State

University

LPI 59-Copy of page from the

“Daily Picayune” of Saturday

morning, August 16, 1856, ob-

tained from Library of Louisiana

State University

LPI 60-Copy of page from the

“Daily Picayune” of Monday after-

noon, August 18, 1856, obtained

from Library of Louisiana State

University

Exhibit

143

144

145

146

147

148

149

150

151

152

LPI 61-Copy of page from the

“Daily Picayune” of Wednesday

morning, August 20, 1856, obtain-

ed from Library of Louisiana State

University

LPI 62-Copy of page from the

“Daily Picayune” of Wednesday

morning, August 20, 1856, obtain-

ed from Library of Louisiana State

University

LPI 1146 - Deposition of Mr. Sam-

uel J. Nunez

LPI 1148 - Deposition of Mr. Chin

D. Hoy

LPI 1149 - Deposition of Mr. Abra-

ham Schouest

LPI 1144 - Deposition of Mr. Sam-

uel Von Lubbe

LPI 1147 - Deposition of Mr. Lan-

dry Cheramie

All of Louisiana’s Requests for Ad-

missions and Interrogatories and

Answers thereto directed to the

United States.

LPI 903 - Pertinent parts of 1887

map of the Alluvial Valley of the

Mississippi River

LPI 358 - Sovereignty of the Sea,

U. S. Department of State, Geo-

graphic Bulletin No. 3 (April,

1965)

Exhibit

153

154

155

156

157

158

159

160

161

162

LPI 359 - Sovereignty of the Sea,

U. S. Department of State, Geo-

graphic Bulletin No. 3, rev. (Octo-

ber, 1969)

LPI 1132- Whiteman, Digest of

International Law, Vol. 4, U. S.

Dept. State No. 7825 (April, 1965)

LPI 1142-U. S. Coast & Geodetic

Survey Chart No. 1

LPI 1137 - Willard Bascom, WAVES

AND BEACHES: THE DYNAMICS OF

THE OCEAN SURFACE, Doubleday &

Co., Inc. (1964)

LPI 897-Map of Survey of the

United States Coast, Section VIII,

made in 1853 by F. H. Gerdes

LPI 1 - Nautical Chart No. 94, 3rd

Edition, Published June, 1877, by

U.S.C.&G.S.

LPI 2-Nautical Chart No. 194,

13th Edition, Published December

20, 1918, by U.S.C.&G.S.

LPI 3- Nautical Chart No. 194,

15th Edition, Published November

19, 1924, by U.S.C.&G.S.

LPI 4- Nautical Chart No. 1272,

Ist Edition, Published February

12, 1925, by U.S.C.&G.S.

LPI 5 - Nautical Chart No. 1272,

3rd Edition, Published January

11, 1933, by U.S.C.&G.S.

Exhibit

163

164

165

166

167

168

169

170

171

172

173

LPI 6- Nautical Chart No. 1272,

5th Edition, Published September

28, 1934, by U.S.C.&G.S.

LPI 7 - Nautical Chart No. 1272,

6th Edition, Published October 29,

1935, by U.S.C.&G.S.

LPI 8 - Nautical Chart No. 1272,

7th Edition, Published April 1,

1944, by U.S.C.&G.S.

LPI 9 - Nautical Chart No. 1272,

9th Edition, Published March 31,

1947, by U.S.C.&G.S.

LPI 10 - Nautical Chart No. 1272,

9th Edition, Published August 22,

1955, by U.S.C.&G.S.

LPI 11 - Nautical Chart No. 1272,

9th Edition, Published September

17, 1956, by U.S.C.&G.S.

LPI 52-Copy of Chart No. 94,

Edition 1, date, 1873

LPI 54-Copy of Chart No. 194,

Edition 10, dated July, 1910

LPI 291 - Photostatic copy of Con-

nelly Field Notes

LPI 292-Letter from Mr. Sey-

mour Lowman, Assistant Secre-

tary of the Treasury to the Secre-

tary of State, dated June 4, 1929

LPI 1214- Edward W. Orton, “A

Geological Study of Marsh Island,

Iberia Parish, Louisiana,” Techni-

Exhibit 173-A

Exhibit 174

cal Report of Louisiana Wild Life

and Fisheries Commission (1959)

Attachments to Exhibit 173 - LPI

1214

LPI 293 - 1940, Chart No. 2, p. 1

from charts of the U. S. Bureau

of the Census, Statistical Abstract

of the United States

LPI 294-1941, Chart No. 2, p. 1

from charts of the U. S. Bureau of

the Census, Statistical Abstract of

the United States

LPI 295 - 1942, Chart No. 2, p. 1

from charts of the U. S. Bureau of

the Census, Statistical Abstract of

the United States

LPI 296 - 1943, Chart No. 2, p. 1

from charts of the U. S. Bureau of

the Cens"s, Statistical Abstract of

the United States

LPI 297 - 1944-1945, Chart No. 2,

p. 3 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 298 - 1946, Chart No. 2, p. 3

from charts of the U. S. Bureau of

the Census, Statistical Abstract of

the United States

LPI 299 - 1947, Chart No. 2, p. 3

from charts of the U. S. Bureau of

the Census, Statistical Abstract of

the United States

LPI 300 - 1948, Chart No. 2, p. 3

from charts of the U. S. Bureau of

the Census, Statistical Abstract of

the United States

LPI 301 - 1949, Chart No. 2, p. 3

from charts of the U. S. Bureau of

the Census, Statistical Abstract of

the United States

LPI 302 - 1950, Chart No. 2, p. 5

from charts of the U. 8S. Bureau

of the Census, Statistical Abstract

of the United States

LPI 303 - 1951, Chart No. 2, p. 5

from charts of the U. S. Bureau

of the Census, Statistical Abstract

of the United States

LPI 304 - 1952, Chart No. 4, p. 7

from charts of the U. 8. Bureau

of the Census, Statistical Abstract

of the United States

LPI 305 - 1953, Chart No. 4, p. 10

from charts of the U. S. Bureau of

the Census, Statistical Abstract of

the United States

LPI 306 - 1954, Chart No. 4, p. 10

from charts of the U. 8. Bureau

of the Census, Statistical Abstract

of the United States

LPI 307 - 1955, Chart No. 4, p. 9

from charts of the U. S. Bureau of

the Census, Statistical Abstract of

the United States

LPI 308 - 1956, Chart No. 190, p.

158 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 309 - 1957, Chart No. 195, p.

158 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 310 - 1958, Chart No. 200, p.

160 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 311-1959, Chart No. 206, p.

160 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 312 - 1960, Chart No. 206, p.

160 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 313 - 1961, Chart No. 212, p.

161 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 314-1962, Chart No. 220,

p. 170 from charts of the U. S.

Bureau of the Census, Statistical

Abstract of the United States

LPI 315 - 1963, Chart No. 226, p.

173 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

Exhibit 175

LPI 316 - 1964, Chart No. 228, p.

169 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 317 - 1965, Chart No. 232, p.

168 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 318 - 1966, Chart No. 242, p.

171 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 319 - 1967, Chart No. 252, p.

174 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 320 - 1968, Chart No. 245, p.

167 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 321 - 1969, Chart No. 243, p.

163 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 322 - 1956, Chart No. 192, p.

159 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 323 - 1957, Chart No. 197, p.

159 from charts of the U. 8. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 324-1958, Chart No. 202, p.

161 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 325 - 1959, Chart No. 207, p.

161 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 326 - 1960, Chart No. 208, p.

161 from charts of the U. S. Bu-

reau of the Census, Statistical At-

stract of the United States

LPI 327 - 1961, Chart No. 214, p.

162 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 328 - 1962, Chart No. 222, p.

171 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 329 - 1963, Chart No. 228, p.

174 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 330 - 1964, Chart No. 230, p.

170 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 331 - 1965, Chart No. 234, p.

169 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

Exhibit 176

Exhibit 177

Exhibit 178

(Accession file)

Exhibit 178-A

Exhibit 179

Exhibit 180

LPI 332 - 1966, Chart No. 244, p.

172 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 333 - 1967, Chart No. 254, p.

175 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 334 - 1968, Chart No. 248, p.

169 from charts of the U. S. Bu-

reau of the Census, Statistical Ab-

stract of the United States

LPI 1212-G. Etzel Pearcy, “Mea-

surement of the United States Ter-

ritorial Sea,”’ Department of State

Bulletin, No. 1044 (June 29, 1959)

LPI 1131-E. L. Corthell, A His-

tory of the Jetties at the Mouths

of the Mississippi River, New

York: John Wiley and Sons, 2d

ed. (1881).

LPI 918 - File from records of

United States Coast & Geodetic

Survey treated in 1 Shalowitz

Shore & Sea Boundaries

Copies of correspondence re Acc.

File

Pages 503 through 507 of Hum-

phrey and Abbot, Appendix A

LPI 1055- This exhibit also per-

tains to East Bay and contains

data and measurement information

Exhibit

181-A

181-B

181-C

181-D

182-A

182-B

182-C

182-D

182-E

182-F

182-G

182-H

associated with various maps of

the period 1918 through the 1960’s.

The various components of the ex-

hibit also reflect alternative na-

tural entrance points and measure-

ment data related to certain land

forms not treated in the exhibit

identified by Louisiana Prelimi-

nary Identifying No. 1054

Chart 1272, 21st Edition

Chart 1273, 9th Edition

Chart 1274, 10th Edition

Chart 1275, 1970 Edition

LPI 73 - Color Photograph - Photo

No. TL-13 dated June 26, 1969

LPI 74 - Color Photograph - Photo

No. TL-14 dated June 26, 1969

LPI 83 - Color Photograph - Photo

No. T-36 dated June 26, 1969

LPI 86 - Color Photograph - Photo

No. TL-39 dated June 26, 1969

LPI 94 - Color Photograph - Photo

No. TL-51 dated June 26, 1969

LPI 101 - Color Photograph - Photo

No. TL-65 dated August 27, 1969

LPI 103 - Color Photograph - Photo

No. TL-83 dated August 27, 1969

LPI 106 - Color Photograph - Photo

No. TL-97 dated August 27, 1969

Exhibit

182-I

182-J

182-K

182-L

182-M

182-N

182-0

182-P

182-Q

182-R

182-S

182-T

182-U

LPI 107 - Color Photograph - Photo

No. TL-99 dated August 27, 1969

LPI 108 - Color Photograph - Photo

No. TL-100 dated August 27, 1969

LPI 109 - Color Photograph - Photo

No. TL-101 dated August 27, 1969

LPI 110 - Color Photograph - Photo

No. TL-102 dated August 27, 1969

LPI 111 - Color Photograph - Photo

No. TL-113 dated August 27, 1969

LPI 114 - Color Photograph - Photo

No. TL-116 dated August 27, 1969

LPI 115 - Color Photograph - Photo

No. TL-117 dated August 27, 1969

LPI 126 - Color Photograph - Photo

No. TL-136 dated August 27, 1969

LPI 130 - Color Photograph - Photo

No. TL-142 dated August 27, 1969

LPI 138 - Color Photograph - Photo

No. TL-193 dated September 3,

1969

LPI 139 - Color Photograph - Photo

No. TL-196 dated September 3,

1969

LPI 141 - Color Photograph - Photo

No. TL-202 dated September 3,

1969

LPI 142 - Color Photograph - Photo

No. TL-204 dated September 3,

1969

Exhibit

182-V

182-W

182-X

182-Y

182-Z

182-AB

182-AC

182-AD

182-AE

182-AF

LPI 153 - Color Photograph - Photo

No. TL-217 dated September 3,

1969

LPI 155 - Color Photograph - Photo

No. TL-219 dated September 3,

1969

LPI 156 - Color Photograph - Photo

No. TL-220 dated September 3,

1969

LPI 157 - Color Photograph - Photo

No. TL-213 dated September 3,

1969

LPI 159 - Color Photograph - Photo

No. TL-225 dated September 3,

1969

LPI 161 - Color Photograph - Photo

No. TL-227 dated September 3,

1969

LPI 162 - Color Photograph - Photo

No. TL-228 dated September 3,

1969

LPI 164 - Color Photograph - Photo

No. TL-230 dated September 3,

1969

LPI 165 - Color Photograph - Photo

No. TL-231 dated September 3,

1969

LPI 166 - Color Photograph - Photo

No. TL-232 dated September 3,

1969

LPI 169 - Color Photograph - Photo

Exhibit

182-AG

182-AH

182-Al

182-AJ

182-AK

182-AL

182-AM

182-AN

182-AO

No. TL-241 dated September 3,

1969

LPI 171 - Color Photograph - Photo

No. TL-244 dated September 3,

1969

LPI 172 - Color Photograph - Photo

No. TL-245 dated September 3,

1970 —

LPI 173 - Color Photograph - Photo

No. TL-246 dated September 3,

1969

LPI 174 - Color Photograph - Photo

No. TL-247 dated September 3,

1969

LPI 179 - Color Photograph - Photo

No. TL-264 dated October 2, 1969

LPI 181 - Color Photograph - Photo

No. TL-266 dated October 2, 1969

LPI 609 - Photograph - TL-0(32)

2 da.ed June 24, 1967, Jetties at

mouth of Belle Pass outlet of Bay-

ou LaF ourche

LPI 610 - Photograph - TL-0(34)

1 dated June 24, 1967, Ground

view showing exhumed marsh in

retreating beach area, Timbalier

Island, Louisiana

LPI 953 - Photograph by Dr. James

P. Morgan of different parts of the

Louisiana coastal area

Exhibit

182-AP

183

183-W

183-X

183-Y

183-Z

184-A

184-B

184-C

LPI 1005 - Photograph fro the

files of Dr. James P. Morgan

NOTE: EXHIBIT 183-A

THROUGH 183-V WERE WITH-

DRAWN. THEY APPEAR IN

LOUISIANA EXHIBIT 21.

LPI 959 - Photograph TL-284 dated

October 2, 1969. Different parts of

the Louisiana coastal area

LPI 973 - Photograph TL-299 dated

October 2, 1969. Different parts of

the Louisiana coastal area

LPI 988 - Photograph TL-283 dated

October 2, 1969. Different parts of

the Louisiana coastal area

LPI 991 - Photograph TL-287 dated

October 2, 1969. Different parts of

the Louisiana coastal area

LPI 611 - Photograph M-100-8

dated June 26, 1969, View South-

west showing mouth of Pass Tante

Phine |

LPI 612 - Photograph M-100-10

dated June 26, 1969, View west

showing peninsula extending south

toward mouth of Pass Du Bois

LPI 613 - Photograph M-100-12

dated June 26, 1969, View toward

the Northwest showing the west

end of Pass Du Bois and the penin-

sula to the north

Exhibit 184-D

Exhibit 184-E

Exhibit 184-F

Exhibit 184-G

Exhibit 184-H

LPI 614 - Photograph M-100-13

dated June 26, 1969, View looking

southwest along the sand spit on

the east side of Southwest Pass,

Mississippi Delta

LPI 615 - Photograph M-100-15

dated June 26, 1969, Mouth of

South Pass, Mississippi Delta. Sand

spit, mudlump islands No. 89-90

and new smaller lumps shown in

the foreground View toward the

north

LPI 616 - Photograph M-101-4

dated June 26, 1969, South Pass

mudlumps and sand spit, Missis-

sippi Delta. Mudlump 93 on left

of photo. Mudlump 89-90 in the

central part of photo and new mud-

lumps offshore in right central part

of photo. The distinct fresh water-

salt water boundary line shown in

the foreground

LPI 619 - Photograph M-101-7

dated June 26, 1969, Mouth of

Southeast Pass, Mississippi Delta,

and mudlump islands in right mid-

dle ground. View toward the north.

LPI 620 - Photograph M-101-8

dated June 26, 1969, Balize Penin-

sula in the background and Balize

Bayou mudlumps in the fore-

ground. View looking generally

north.

Exhibit

184-I

184-J

184-K

184-L

184-M

184-N

LPI 621 - Photograph M-101-12

dated June 26, 1969, View toward

the northwest showing the mouth

of Pass A Loutre in the background

and Pass A Loutre mudlumps in

the foreground

LPI 622 - Photograph M-101-16

dated June 26, 1969, View toward

the north, showing a crevasse or

splay extending into Blind Bay

from the south side of Pass A

Loutre, Mississippi Delta

LPI 623 - Photograph M-103-13

dated September 3, 1969, View west

showing breaches in the sand spit

on the east side of Southwest Pass,

Mississippi Delta

LPI 624 - Photograph M-103-16 ©

dated September 3, 1969, View

north showing the north end of the

sand spit on the east side of South-

west Pass, Mississippi Delta

LPI 625 - Photograph M-104-5

dated September 3, 1969, View to-

ward the northwest showing the

marsh on the west side of South

Pass, Mississippi Delta. See M-104-

6 for comparison.

LPI 626 - Photograph M-104-6

dated September 3, 1969, View

northwest showing marsh on the

west side of South Pass, Missis-

Exhibit 184-O

Exhibit 184-P

Exhibit 184-Q

Exhibit 184-R

Exhibit 184-S

100

sippi Delta. Compare with M-104-

LPI 627 - Photograph M-104-10

dated September 3, 1969, View

northeast showing the marsh and

natural levees on the west side of

South Pass. Note small residual

islands in foreground of photo-

graph

LPI 628 - Photograph M-104-11

dated September 3, 1969, Natural

levee and marsh along west bank

of South Pass, Mississippi Delta.

View toward the northeast show-

ing small residual islands in fore-

ground of photograph

LPI 629 - Photograph M-104-12

dated September 3, 1969, Natural

levee and marsh along west bank

of South Pass, Mississippi Delta.

View toward the northeast show-

ing small residual islands in fore-

ground of photograph

LPI 630 - Photograph M-104-15

dated September 3, 1969, View to-

ward the west showing the mouth

of Southwest Pass and sand spit

extending into East Bay, Missis-

sippi Delta

LPI 631 - Photograph M-104-16

dated September 3, 1969, View to-

ward the west showing the natural

levees of Southwest Pass near its

Exhibit 184-T

Exhibit 184-U

Exhibit 184-V

Exhibit 184-W

Exhibit 184-X

101

mouth and the sand spit extending

into East Bay, Mississippi Delta.

A photograph showing more detail

than M-104-15, including breaches

in sand spit caused by Hurricane

Camille

LPI 632 - Photograph M-105-1

dated October 2, 1969, View to-

ward the south of a portion of Isle

Derniere, Terrebonne Parish, Lou-

isiana. The inlei in Isle Derniere

shown in the center of the photo-

graph is Coupe Colin

LPI 639 - Photograph M-105-10

dated October 2, 1969, View to-

ward the south showing the marsh

and shore line of north shore of

Caillou Bay. Note shell material is

concentrated in small pockets along

the shore line

LPI 641 - Photograph M-105-12

dated October 2, 1969, View to-

ward the north of marsh land ex-

tending inland from Isle Derniere.

This view is in the opposite direc-

tion from M-105-11

LPI 643 - Photograph M-105-16

dated October 2, 1969, View to-

ward the east showing the junc-

tion of Bayou Grande Caillou and

Bayou du Lac, Terrebonne Parish

LPI 645 - M-53-36

Exhibit

184-Y

185-A

185-B

186

187

188-A

188-B

189

102

LPI 646 - M-94-2 dated July 26,

1961

LPI 1058-A This exhibit pertains

to shore line changes in the Isle

Derniere area for the period 1853

through 1959, as reflected by var-

ious maps or surveys of that period

LPI 1058-B - This exhibit pertains

to shore line changes in the Caillou

Bay-Lake Pelto area for the period

1853 through 1959, as reflected

by various maps or surveys of that

period

LPI 903 - Pertinent parts of 1887

map of the Alluvial Valley of the

Mississippi River in overlay form

Chart 1050 in overlay form

LPI 1066-A - This exhibit reflects

certain island measurement infor-

mation pertaining to islands and

low water elevations in the Dern-

iere area

LPI 1066-B - This exhibit reflects

certain island measurement infor-

mation pertaining to islands and

low water elevations in the Shell

Keys area.

LPI 1063 - This is a collection of

reduced scale nautical charts with

an index map. The nautical charts

included in the exhibit from which

the reduced scale copies were made

103

for convenience in handling are

charts 1268 through 1277, inclu-

sive.

Exhibit 190 Photograph Album No. 4 of Dr.

James P. Morgan, as follows:

LIST OF PHOTOGRAPHS TO ACCOMPANY TES-

TIMONY OF JAMES P. MORGAN CONCERNING

PHYSICAL CHARACTERISTICS OF ISLE DERN-

IER AND CAILLOU BAY.

(All of the photographs included here were taken by

James P. Morgan on the dates indicated).

PART I—COLOR PHOTOGRAPHS

Louisi-

Chrono- ana Pre-

logic liminary

Number Identify- Date of

of Photo- ing Photo- Description of

graph Number graphy Photograph

1 606 June View west down beach of

24,1967 Isle Derniere, Terrebonne

Parish, Louisiana.

2 175 October View north across Trinity

2,1969 Bay, eastern Isle Derniere,

Terrebonne Parish, Louisi-

ana.

3 176 October View north across central

2,1969 Isle Derniere, Caillou Boca

in middle ground.

4 177 October View northward across cen-

2,1969 tral Isle Derniere. Caillou

Boca in middle ground.

978

987

178

183

607

964

608

October

2, 1969

October

2, 1969

October

2, 1969

October

2, 1969

June

24, 1967

June

24, 1967

June

24, 1967

104

View looking southwest to-

ward western Isle Dernie-

re with Caillou Boca in

foreground marshland of old

Bayou MiSale extending out

toward island.

View looking toward the

south of western Isle Dern-

iere. The island is in back-

ground, Caillou Boca in

foreground.

View northwest across west-

ern Isle Derniere. Inlet

shown is Coupe Colin. Note

new sand spit in forground.

View northwest toward Rac-

coon Point western Isle

Derniere, showing position

of new sand spit.

View north toward Coupe

Colin opening in Isle Dern-

iere with new sand spit in

foreground.

View looking north of west-

ern Isle Derniere; new

sand spit in foreground;

Coupe Colin Inlet in back-

ground.

View east along Isle Dern-

iere, Terrebonne Parish,

showing new sand spit sea-

ward and west of Coupe

Colin beach.

180

182

957

954

972

975

958

October

2, 1969

October

2, 1969

October

2, 1969

October.

2, 1969

October

2, 1969

October

2, 1969

October

2, 1969

105

View northeast across west-

ern Isle Derniere. Coupe

Colin Inlet in right. rear of

photo. New sand spit in fore-

ground.

View northeast across west-

ern Isle Derniere and new

sand spit.

View looking southeast

showing water boundary

line and its relationship to

the north shore of Caillou

Bay.

View looking toward the

northeast showing water

boundary in Caillou Bay.

Position can be determined

from Bayou Goreau in cen-

tral background.

View looking northeast of

north shore of Caillou Bay.

Shrimp drying platforms in

center of photograph are lo-

cated near the mouth of Ba-

you Goreau.

View looking west of north

shore Caillou Bay. Shrimp

drying platforms on the

shore of Bayou Goreau in

background.

View looking to the east.

East Bay Junop in back-

950

974

187

186

185

184

955

October

2, 1969

October

2, 1969

October

2, 1969

October

2, 1969

October

2, 1969

October

2, 1969

October

2, 1969

106

ground, Bayou Du West in

middle background.

View looking northwest

across Pelican Island along

north shore of Caillou Bay.

East Bay Junop in back-

ground, Pelican Pass in

right foreground.

View looking north of north

shore of Caillou Bay. Stream

on left margin of photo is

Taylor’s Bayou. East Bay

Junop in left rear back-

ground of photo.

View of north shore of Cail-

lou Bay Terrebonne Parish.

Bayou Charbon in risnt

background.

View of north shore of Cail-

lou Bay, Terrebonne Parish.

Area west of outlet of Grand

Bayou du Large.

View north showing opening

of Grand Bayou du Large

into Caillou Bay, Terrebonne

Parish.

View looking northeast

showing northeast shore

line of Caillou Bay, Terre-

bonne Parish.

Another view of water

boundary extending out-

26 1000 October

2, 1969

27 952 October

2, 1969

28 969 October

2, 1969

107

ward into Caillou Bay from

north shore of Caillou Bay.

Water boundary line extend-

ing into Caillou Bay from

north shore.

Water boundary line extend-

ing into Caillou Bay from

north shore.

Water boundary line in Cail-

lou Bay extending almost

perpendicular to north shore

of Caillou Bay. Details of

this boundary are shown on

additional photos in this

series.

PART II—BLACK AND WHITE PHOTOGRAPHS

Louisi-

Chrono- ana Pre-

logic liminary

Number Identify- Date of

of Photo- ing Photo-

graph Number graphy

Description of

Photograph

B&W1 633 October View toward the west along

2,1969 Isle Derniere with Rac-

coon Point in the distance.

Coupe Colin Inlet in center

of photograph and new sand

spit on seaward (left) side

of island.

B&W2 640 October View toward the south with

2, 1969 Isle Derniere in the back-

ground. Foreground shows

B&EW3

B&W4

B&W5

B&W6

B&EWT7

B&EWS8

642

636

637

635

634

644

108

marsh land surrounding old

Bayou MiSale. Caillou Boca

separates Isle Derniere

from marsh land.

October View south showing the

2, 1969 marsh land of old Bayou Mi-

Sale. Caillou Boca in fore-

ground and Isle Derniere

in background.

October View toward the northwest

2, 1969 showing the north shore of

Caillou Bay and a foam line

indicating a water interface

in foreground.

October View toward the east show-

2, 1969 ing the north shore of Cail-

lou Bay. Note the abundant

shelly material comprising

the beach along the border

of the marsh land.

October View toward the east show-

2, 1969 ing the north shore of Cail-

lou Bay with a foam line

suggesting a water interface

in foreground.

October View toward the northeast

2, 1969 showing and the north shore

of Caillou Bay and a foam

line indicating a water in-

terface in Caillou Bay.

October View toward the east, show-

2, 1969 ing north shore of Caillou

B&EW9 638

Exhibit

190-A.

191-A

191-B

191-C

191-D

191-E

191-F

192

109

Bay. Note decrease in shell

towards the east.

October View east of the north shore

2,1969 of Caillou Bay, an area

slightly farther to the east

than shown on previous

photograph (B & W 8) Note

lesser amount of shell on

beach.

Photo area Index Sheets

LPI 993 - U. S. Army Corps of En-

gineers Photo No. 902-25 dated Octo-

ber 3, 1929

LPI 995 - U. S. Army Corps of En-

gineers Photo No. 902-550 dated

October, 1929

LPI 996 - U. S. Army Corps of En-

gineers Photo No. 902-551 dated

October, 1929

LPI 997 - U. S. Army Corps of En-

gineers Photo No. 902-552 dated

October, 1929

LPI 998 - U. S. Army Corps of En-

gineers Photo No. 902-553 dated

October, 1929

LPI 999 - U. S. Army Corps of En-

gineers Photo No. 902-554 dated

October, 1929

Photograph Album No. 5 of Dr.

James P. Morgan, as follows:

110

LIST OF PHOTOGRAPHS TO ACCOMPANY TES-

TIMONY OF JAMES P. MORGAN CONCERNING

NATURAL ENTRANCE POINTS AT ATCHAFA-

LAYA BAY.

(All of the accompanying photographs were taken on

June 6, 1968 by James P. Morgan and previously sub-

mitted as part of Exhibit 68, Appendix G, Map Ex-

hibits and Related Materials for Brief of the State

of Louisiana in Support of its Motion for Entry of

Supplemental Decree No. 2).

Chrono- Photo-

logic graph

Number Number

of Photo- and Page Description of

graph Photograph

1 No.4,Pagel Point au Fer with North Is-

land lying to its left and with

a pronounced oyster reef for-

mation in the foreground. The

oyster reef serves as the east-

ern natural entrance point of

Atchafalaya Bay.

2 No.5, Pagel Closer view of the oyster reef

formation off Point au Fer.

North Island can be seen in

the background.

3 No.6,Pagel Another view from a different

angle of the oyster reef off

Point au Fer that is the east-

ern natural entrance point of

Atchafalaya Bay.

4 No.7, Pagel Looking west at Point au Fer

and the reef structures beyond.

No.

8, Page 2

111

Close-up from the ground of

the reef formation off Point

au Fer that is the eastern na-

tural entrance point of Atcha-

falaya Bay.

10, Page 2 Additional ground photograph

9, Page 2

of reef formation off Point au

Fer.

Another grotirid photograph of

reef formation off Point au

Fer. Point au Fer and inter-

vening reef formations can-be

seen in the background.

12, Page 2 Reef formation off Point au

Fer with helicopter in the back-

ground to show size and extent

of reef.

13, Page 2 Same reef formation stretch-

ing out toward the Gulf of

Mexico.

15, Page 2 Same reef formation. Looking

toward east with Point au Fer

and intervening reef forma-

tions in the background.

11, Page 3 Close-up of oysters and shells

on eastern natural entrance

point of Atchafalaya Bay. Note

that some oysters are up-right

or in active growth position.

Camera lens case is in photo-

graph to show size.

14, Page 3 A part of the reef formation

112

off Point au Fer showing oys-

ters in active growth position.

No. 33, Page 3 Looking northward from just

above the western natural en-

trance point of Atchafalaya

Bay. Formations in foreground

and winding to right back-

ground are islands permanent-

ly above high water.

No. 31, Page 3 Shell Keys formation, looking

northeastward.

No. 32, Page 3 Shell Keys again, but looking

more nearly due north.

No. 34, Page 3 Ground photograph on a Shell

Keys island. High-tide line is

large ridge in right foreground.

Note extent of island to left

and rear of photograph.

No. 28, Page 4 Some of the reef formations

associated with the Shell Keys.

No. 25, Page 4 Looking south past Mound

Point on Marsh Island toward

numerous reef formations lead-

ing out to the Shell Keys.

No. 30, Page 4 Looking east at reef forma-

tions that form a natural bar-

rier blocking entrance into

Atchafalaya Bay in this vi-

cinity. Marsh Island is on the

left.

No. 29, Page 4 Looking west along the shore-

line of Marsh Island showing

113

reef formations extending to-

ward the Shell Keys.

21 No. 26, Page 4 Looking south from Marsh

Island down the reef forma-

tions and Shell Keys.

22 No. 24, Page 4 Looking south at the western

Exhibit 192-A

Exhibit 193-A

Exhibit 193-B

Exhibit 193-C

Exhibit 193-AB

headland Louisiana employs in

Atchafalaya Bay. Because the

Shell Keys are farther than

twenty-four miles from the

eastern natural entrance point,

Louisiana moves the closing

line in to this point. The line

Louisiana describes is not quite

twenty-four miles long be-

cause the shoreline of Marsh

Island turns slightly north-

ward just to the right of the

point to which Louisiana closes.

Index Map to Volume 5

LPI 535 - U. S. Corps of Engineers

Photograph dated February 29, 1956

- P-55, 24-114

LPI 538 - U. S. Corps of Engineers

Photograph dated October 29, 1957

- X-2, 550

LPI 539 - U. S. Corps of Engineers

Photograph dated October 29, 1957

- X-2, 551

LPI 572 - U. S. Corps of Engineers

Photograph dated November 15, 1969

- 59-111

114

Exhibit 193-AA LPI 571 - U. S. Corps of Engineers

Exhibit 193-Y

Exhibit 193-X

Exhibit 193-AN

Photograph uated November 15, 1969

- 59-109

LPI 569 - U. S. Corps of Engineers

Photograph dated November 15, 1969

- 59-107

LPI 568 - U. S. Corps of Engineers

Photograph dated November 15, 1969

- 59-105

LPI 584 - U. S. Corps of Engineers

Photograph dated November 20, 1969

- 60-4

Exhibit 193-AM LPI 583 - U. S. Corps of Engineers

Exhibit 194

(Evidence)

Exhibit 195

Exhibit 196

Exhibit 197

Exhibit 198

Photograph dated November 20, 1969

- 60-3

LPI 1062 - This exhibit pertains to

the Atchafalaya Bay complex. It

shows natural entrance point and

measurement information.

LPI 1163 - 24 pages of descriptive

notes by Dr. James P. Morgan per-

taining to various photographs

LPI 917 - Gerdes Map (two pages)

LPI 1056 - This display employs base

maps, at a reduced scale from the

Set of 54 maps, to reflect natural

entrance points analyses and mea-

surement data for various pro-

nounced land forms in East Bay

This collection of illustrative display

materials shows Louisiana closing

Exhibit 199

Exhibit 199-A

Exhibit 200

Exhibit 200-A

Exhibit 201

Exhibit 202

Exhibit 203

Exhibit 204

Exhibit 205

Exhibit 206

Exhibit 207

115

line contentions, primary and alter-

native, for the Caillou Bay area. It

also reflects measurement informa-

tion

LPI 1211 - Relevant portions of a

map prepared by G. Etzel Pearcy

using U.S.C. & G.S. Chart No. 1275

as a base map, at a reduced scale

with notes thereon showing color in-

formation not reflected by the ori-

ginals. This map was obtained by

Louisiana by the Department of State

through the United States Depart-

ment of Justice.

Same as Exhibit 199, showing colored

lines

LPI 1213 - Same description as Lou-

isiana Preliminary Identifying No.

1211, except the base map is U. S. C.

& G. S. Chart No. 1272

Same as Exhibit 200, showing colored

lines

Map 2 of 8 of the Set of 54 maps

LPI 1068 - U.S. C. & G. S. air photo

compilation No. T 5295

LPI 1067 - U.S.C. & G.S. air photo

compilation No. T5291

LPI 905 - U.S.C. & G.S. map H-6492

LPI 906 - U.S.C. & G.S. map H-6172

LPI 907 - U.S.C. & G.S. map No. 3630

LPI 908 - U.S.C. & G.S. map No. 2752

Exhibit 208

Exhibit 209

Exhibit 210

Exhibit 211

Exhibit 212

Exhibit 213

Exhibit 214

Exhibit 215

Exhibit 216

Exhibit 217

A-E

Exhibit 218

A-F

Exhibit 219

Exhibit 220

Exhibit 221

Exhibit 222

116

LPI 909 - U.S.C. & G.S. map No.

1762

LPI 910 - U.S.C. & G.S. map No.

1763

LPI 911 - U.S.C. & G.S. map No.

4038

LPI 912 - U.S.C. & G.S. map No.

4044

LPI 913 - U.S.C. & G.S. map No.

4050

LPI 914 - U.S.C. & G.S. map No. T-

5403

LPI 915 - U.S.C. & G.S. map T-5407

LPI 916 - U.S.C. & G.S. map 1691

LPI 904 - U.S.C. & G.S. map H-6513

U.S. Army Corps of Engineers maps,

in 5 sheets, entitled “Passes of the

Mississippi River, La.” from photos-

aerial surveys made in 1922 and

1929

La. Ex. 1-6; Photographs by Mr.

David Morgan of Isle Derniere

Overheads from Mr. David Morgan’s

presentation; figure 1

Figure 49; Shalowitz

Figure 50; Shalowitz

Monterey Bay - Depth of penetra-

tion methods and data

Exhibit 223

Exhibit 224

Exhibit 225

Exhibit 226

Exhibit 227

Exhibit 228

Exhibit 229

Exhibit 230

Exhibit 231

Exhibit 232

Exhibit 233

Exhibit 234

Exhibit 235

Exhibit 236-A

Exhibit 236-B

117

Monterey Bay - Depth of penetration

methods - construction of median

line for depth of penetration mea-

surement in Monterey Bay

Figure 3 of Mr. David Morgan’s

depth of penetration memo

Figure 4 of Mr. David Morgan’s

depth of penetration memo

Figure 5 of Mr. David Morgan’s

depth of penetration memo

Mr. David Morgan’s sketch of fjords

Monterey Bay - Method B

Mr. David Morgan’s Bay Penetration

data

LPI 1182, a study prepared by Mr.

David J. Morgan entitled, ‘“Measure-

ment of Penetration Ratio”

Mr. David Morgan’s Bucket Bend

Bay work map

Mr. David Morgan’s Caillou Bay

work map

Mr. David Morgan’s West Bay work

map

Mr. David Morgan’s East Bay work

map

Mr. David Morgan’s Norway fjord

work map

Chart 1276, 12th edition

Chart 1277, 13th edition

Exhibit 237-A

Exhibit

237-B

237-C

247

Exhibit 248

Exhibit 249-A

Exhibit 249-B

Exhibit 250-A

Exhibit 250-B

Exhibit 251

Exhibit 252

Exhibit 253

118

Chart 1274, 10th edition

Chart 1272, 1970 edition

Chart 1273 of attachment, 5th edi-

tion

Talcott map, 1839

1918 chart 194

1901 chart 194

1873 chart 194

9th edition, chart 1272 with addenda

January 1933, chart 1272

April, 1944, chart 1272

October 1935, chart 1272

February, 1925, chart 1272

LPI 1231 - Gauld map sketch

Map 2 of 8

Mr. Philip L. Whitaker’s field books

(1 of 2)

Mr. Philip L. Whitaker’s field books

(2 of 2)

1198, prel. plat

1012, signed plat, showing mudlumps

at South Pass

Geodimeter notes, 1198

1014-1023, copy of notes by Mr.

Philip L. Whitaker on back of photos

numbered 1014-1023

Tidal Bench Marks, South Pass

Exhibit 254

Exhibit 255

Exhibit 256-A

Exhibit 256-B

Exhibit 256-C

Exhibit 256-D

119

LPI 1013, Letter from Harland R.

Cravat, Chief, Technical Planning

and Operations Branch, Photogram-

metry Division, U. S. Department

of Commerce, Environmental Science

Services Administration, Coast and

Geodetic Survey, to Frederick W.

Ellis dated August 20, 1970 file

#C141

Methods of planimetering furnished

Mr. Philip L. Whitaker by Mr. David

Morgan

LPI 63 - Copy of portions of a 1911

map of the State of Louisiana issued

for the Railroad Commission of Lou-

isiana as a supplement to its twelfth

annual report

LPI 64 - Copy of portions of a map

entitled ““New Commercial and Cen-

sus Map of Louisiana” copyrighted

in 1917

LPI 65 - Copy of portions of a map

entitled “Post Route map of the State

of Louisiana”, filed in the map Di-

vision of the Library of Congress

June 18, 1903

LPI 66 - Copy of a portion of a map

of the State of Louisiana published

by the Department of the Interior

and compiled from the official re-

cords of the General Land Office

and other sources under the direction

of I. P. Berthong in 1916

Exhibit 257

Exhibit 258

Exhibit 259

Exhibit 260

Exhibit 261

Exhibit 262

Exhibit 263

120

Joint 1962 agreement

LPI 1165 - Map compiled under the

direction of I. P. Berthong in 1916,

from the official records of the Gen-

eral Land Office and other sources,

showing the State of Louisiana, and

being a published map from the re-

cords of the General Land Office of

the Department of the Interior

LPI 342 - Message of President Jef-

ferson, 9th Congress, 2nd Session,

No. 25, pp. 68-69 (December 2, 1806)

LPI 343 - Message of President Jef-

ferson, 8th Congress, 1st Session, No.

21 pp. 61-63 (October 17, 1803)

LPI 344 - Report of the Secretary of

State, Thomas Jefferson, 2nd Con-

gress, Ist Session, No. 59 (March

7, 1792)

LPI 346 - Journals of the Continen-

tal Congress, 1774-1789, edited from

the original records in the Library

of Congress by John C. Fitzpatrick,

Vol. IIII, 1786, August 1 - December

31 U.S.G.P.0., Washington, 1934.

Tuesday, August 29, 1786, pp. 574-

596

LPI 347 - The Debates and Proceed-

ings of the Congress of the United

States with an appendix containing

important state papers and public

documents and all the laws of a public

nature. 7th Congress, 2nd Session,

Exhibit 264

Exhibit 265

Exhibit 266

Exhibit 267

121

from December 6, 1802, to March

3, 1803, Vol. 12, Washington: Gale

& Seaton, 1851. James Madison, Sec-

retary of State to Robert R. Living-

ston, May 1, 1802, pp. 1027-1028

LPI 349 - The Debates and Proceed-

ings of the Congress of the United

States with an appendix containing

important state papers and public

documents and all the laws of a public

nature. 7th Congress, 2nd Session,

from December 6, 1802, to March 3,

1803, Vol. 12, Washington: Gale &

Seaton, 1851. Mississippi Question,

February 23, 1803, pp. 151-154

LPI 350 - The Debates and Proceed-

ings of the Congress of the United

States with an appendix containing

important state papers and public

documents and all the laws of a public

nature. 7th Congress, 2nd Session,

from December 6, 1802, to March 3,

1803, Vol. 12, Washington: Gale &

Seaton, 1851. Mississippi Question,

February 1803, pp 231-234

LPI 356 - Executive Documenis &

Reports Committees, 27th Congress,

Ist Session. Doc. #9, Ho. of Rep.,

March 6, 1841, Resolution, of the

State of La., for a steamship of war

to be built on the waters of the Miss-

issippi

LPI 357 - Executive Documents &

Exhibit 268

Exhibit 269

Exhibit 270

Exhibit 271

Exhibit 272

Exhibit 273

Exhibit 274

Exhibit 275

Exhibit 276

Exhibit 277

Exhibit 278

Exhibit 279

Exhibit 280

Exhibit 281

122

Reports Committees, 27th Congress,

lst Session. Doc #10, Ho. of Rep.,

June 12, 1840, Resolution of the Leg-

islature of La. asking that the fortifi-

cations at the mouths of the Missis-

sippi be completed and mounted.

December, 1932 edition of chart 198

October, 1925 edition of chart 1272

1937 edition of map of Louisiana -

Official Map of Louisiana, first edi-

tion

April, 1924 edition of chart 194

March 1916 edition, which is a re-

issue of June 1914 edition of chart

194

June, 1914 edition of chart 194

LPI 1169 - Hardee’s Official Map of

Louisiana dated 1895

October, 1911 edition of chart 194

Sketch of waves by F, W. Ellis

Chart No. 1272, 23rd Ed., May 1969

I.L.C. No. 8 lease, 1956

Outer Continental Shelf “Hearings

Before A Special Sub-Committee,”

December 17, 1969, Janaury 22,

March 4, pp. 202-208

Mr. Stevenson’s Speech

Dr. Alexander Melamid’s published

articles from the Professional Geo-

123

grapher, with letter to Mr. Jonathan

Charney

Exhibit 282 Dr. Alexander Melamid’s published

articles from the Oil Forum, with

letter to Mr. Strauss

Exhibit 283 General Documentary Materials, as

follows:

LOUISIANA EXHIBIT NO. 283

GENERAL DOCUMENTARY MATERIALS

INDEX

Tab L.P.I.

No. No. Description

1 1232 A letter from Robert D. Hodgson to Mr.

Jonathan Charney, dated February 2, 1971,

with enclosures consisting of letter from

Robert D. Hodgson to Commander P. B.

Beazley, dated March 31, 1970, and a letter

from Commander P. B. Beazley to Dr.

Robert D. Hodgson dated May 27, 1970.

2 1233 Part III of The Law of Territorial Waters

from the Harvard Studies of International

Law, Reporter, George Grafton Wilson.

3 1234 A letter from Mr. D. A. McDougal of the

office of the Legal Adviser of the Depart-

ment of State to Mr. Hackworth, dated

June 26, 1934, enclosing a memorandum

dated June 25, 1934 pertaining to the ex-

tent of control that a state may exercise

over its territorial waters.

124

4 1235 A letter from R. S. Patton, Director of the

United States Coast and Ueodetic Survey,

to Samuel W. Boggs of the State Depart-

ment dated March 3, 1930, enclosing sug-

gestions regarding the three-mile limit or

parts thereof pertaining to bays and is-

lands, together with copy of a letter dated

March 22, 1930, to Captain Patton from

S. W. Boggs, dateline at the Hague, The

Netherlands.

5 1237 A letter to Mr. Hackworth from S. W.

Boggs dated April 6, 1931, on the letter-

head of the Department of State of the of-

fice of the Historical Adviser with en-

closures pertaining to sundry charts which

were the subject of the letter and which

were published for the United States Tariff

Commission.

6 1238 A letter to Mr. Miller from the Acting Sec-

retary of the Department of State dated

February 27, 1930.

6-A 1238 Enclosure with a draft proposal for the

League of Nations Hague Conference dated

March 17, 1930, showing proposals pre-

sented by the Norwegian and Swedish dele-

gations.

7 1299 Copy of memorandum from the Solicitor

of the Department of the Interior to the

Secretary of the Interior dated Otcober 1,

1954, from records of the Department of

the Interior.

8 1300 A group of copies of documents from the

records of the American delegation to the

125

Conference for the Codification of Inter-

national Law held at the Hague in 1930

consisting of :

(a) A memorandum on the subject of

territorial wateis dated March 6, 1930 with

annotations of the record copy to the effect

that the memorandum was to be handed to

the Secretary in London, but instead, Mr.

Miller talked to the Secretary.

(b) Proposals presented by the Norwe-

gian and Swedish Delegations to Committee

II on Bases 3 and 4; 6, 7, and 8.

gation of the United States pertaining to

Bases of discussion 1, 3, 4, 5, and 6.

(d) A memorandum by 8S. W. Boggs

dated March 22, 1930, pertaining to an in-

terview with a Captain Luymes.

(e) Proposals presented by the Norwe-

gian and Swedish Delegations upon bases

of discussions 3 and 4, 6, 7, and 8. (Note,

this is apparently the same item described

under (b) above ex-ept for annotations or

marginalia appearing on (b).)

9 1301 A group of documents from records of the

Department of State in the National Ar-

chives described as follows:

Copies of a group of documents from:

(a) A memorandum from the Legal Ad-

viser of the Department of State to Mr. S.

W. Boggs dated March 6, 1935 with the im-

126

print of the Office to the Geographer of the

Department of State.

(b) A memorandum on stationery of the

Department of State from “SWB,” presum-

ably, S. W. Boggs, to a Mr. Vallance, dated

March 7, 1935.

initialed, “W.R.V.” from the office of the

Legal Adviser of the Department of State

stamped with the receipt stamp of the office

of the Geographer of the Department of

State addressed to Mr. Boggs.

(d) A memorandum from the office of

the Historical Adviser of the Department

of State dated March 14, 1935 to Mr. Val-

lance with annotation or marginalia init-

ialed “S.W.B.”

(e) A draft with marginalia on the origi-

nal of a letter to the Secretary of the In-

terior from the Secretary of State showing

initials of “S.W.B.” and others.

(f) Another draft of a letter proposed to

be sent to the Secretary of the Interior by

the Secretary of State bearing initials of

“S.W.B.” and other persons pertaining to

a response to a letter of February 27, 1936.

Similar in content to the next preceding

letter except that the hand-written additions

or annotations thereon (from the originals)

differ, this copy having crossed out five

lines on the first page, and the preceding

draft (item (f) above) having proposed

127

certain additional language now apparently

incorporated in this typed draft. )

(g) A copy of the letter dated March

22, 1935 which was forwarded to the Sec-

retary of the Interior by the Assistant Sec-

retary of State for the Secretary of State in

response to The Secretary of the Interior’s

letter of February 27, 1935.

1302 A copy of the North Atlantic Coast Fish-

eries Case between Great Britain and the

United States with related documents as

reported in the Hague Court Reports on

pages 142 through 225, inclusive. Hand-

written marginalia on the first sheet of the

copy are not from the original but are

merely file number designations.

1303 Copy of the Fisheries Case (United King-

dom v. Norway) from the records of the

International Court of Justice for the year

1951. (Note: the marginalia are from the

hand of an unknown past reader of the

report and are not submitted.)

1477 Bulletin Number Four, Coastal Studies In-

stitute of Louisiana State University. See

Technical Report 76: “Effects of Hurricane

Camille on the Landscape of the Breton-

Chandeleur Island Chain”

1482 Executive Order issued by Theodore Roose-

velt concerning the declaration of bird pre-

serves for certain islands including Breton

Island, dated November 11, 1905.

1483 Executive Order issued by Theodore Roose-

velt concerning the decalaration of bird pre-

128

serves for certain islands including Breton

Island, dated October 4, 1904.

1516 A copy of the transcript of the hearing be-

fore the Committee on Foreign Relations,

United States Senate, Eighty-Sixth Con-

gress, Second Session concerning Conven-

tions of the Law of the Sea.

1520 Decision, Post Office vs. Estuary Radio,

Ltd. Opinion, Regina vs. Kent Justices.

1549 (a) Letter from President John Quincy

a & b Adams to the House of Representatives of

the United States dated Washington, 15th

January, 1828.

(b) Letter from Henry Clay, Secretary

of State, dated January 14, 1828, referred

to by President Adams.

1008 Copy of letter from Gulf Oil Corporation

Law Department (Melvin Evans) dated

June 24, 1968, with documents referred to

therein.

Documents relating to Louisiana’s Motion

of April, 1970 for publication of documents,

together with Responses by the United

States.

1538 This is a group of documents pertaining

to methods of delimitation under the pro-

posal at the Hague Conference in 1930 and

other documents pertaining to Tariff Com-

mission Studies all attached to a certifica-

tion by one Jane F. Smith dated March 2,

1971

Exhibit 284

Exhibit 284-A

Exhibit 285

Exhibit 286

Exhibit 287-A-H

Exhibit 288

Exhibit 289

= ONAM OO Ww Pp

129

Deposition of Mr. Christopher Do-

bard.

Exhibits to Deposition of Mr. Chris-

topher Dobard.

LPI 1526, an exhibit showing

straight baselines designated by

the United States, its agencies or

responsible officials, around parts

of the Mississippi Delta area.

LPI 1525, an exhibit pertaining

to the Caillou Bay region showing

straight baselines designated by

the United States, its agencies or

responsible officials.

1:250,000 AMS Q 501 series maps

of Bristol Bay area:

4-1 (Goodnews)

4-3 (Dillingham)

4-4 (Hagemeister Island)

4-5 (Nushagak)

4-6 (Naknek)

4-8 (Bristol Bay)

4-9 (Ugashik)

4-11 (Chignik)

LPI 1274, map labeled Bristol

Bay, reference number 3, 4 series

1301, edition 1-AMS, scale 1:1,-

000,000.

LPi 1273, overlay of Delta por-

Exhibit 290

Exhibit 290-A

Exhibit 291

Exhibit 292

Exhibit 293

Exhibit 294

Exhibit 295

Exhibit 295-A

Exhibit 296

Exhibit 297

130

tion of map labeled Mobile, refer-

ence number NH 16, series 1301,

edition 1-AMS, scale 1:1,000,000.

Johnston’s Readyfold Coloured

Touring Map.

Film overlay of portion of this map.

Sheet 12, map of England S.E.

and London - Thames Estuary.

Map - East Anglia.

Larimore’s work map, chart 1272,

August 15, 1970 ed., showing

planimetry areas within the Mis-

sissippi River, South Pass and

Southwest Pass. Also markings by

James P. Morgan.

LPI 1273, map labeled Mobile, re-

ference number NH 16, series 1301,

ed. 1-AMS scale 1:1,000,000.

LPI 1283, portion of delta area of

map labeled Breton Sound, sheet

numbered NH 16-7, 1:250,000.

Overlay of above map, exhibit 295.

East Bay planimetry information

on 24th edition (December 6, 1969)

and 25th edition (August 15, 1970)

U.S. C. & G. S. nautical chart No.

1272.

LPI 1521, an exhibit showing ap-

plication of the Boggs Reduced

Area formula to Monterey Bay and

Atchafalaya Bay showing that the

Exhibit 298

Exhibit 299

Exhibit 300

Exhibit 301

Exhibit 302

Exhibit 303

Exhibit 304

131

formula was never recognized by

law since these bays were adjudi-

cated to be bays acquired by the

states in the 19th century.

LPI 1298, Enlargement of “Figure

6.—Semicircular rule applied to

San Diego Bay, using reduced area

method.” from 1 Shalowitz 39

(1962).

LPI 1517, East Bay Shoreline,

January 24, 1970 from Coast and

Geodetic Survey Color Photogra-

phy Curtis Buttorff interpretation.

LPI 1524, an exhibit showing in-

terpretation of 1954 aerial photo-

graphy by Mr. Curtis Buttorff,

former United States closing lines

and modified water gap informa-

tion, all pertaining to additional

low water line inivrmation in the

vicinity of Isle Derniere.

Overlay of the South Pass sheet.

(Map 4 of 8 coverage at scale of

1:20,000 and on which Buttorff

interpreted East Bay shore line.)

LPI 1271, photograph, Ammann

identifying No. 727-124, dated

1/7/54.

LPI 1270, photograph, Ammann

identifying No. 727-123, dated

1/7/54.

LPI 1269, photograph, Ammann

Exhibit 305

Exhibit 306

Exhibit 307

Exhibit 308

Exhibit 309

Exhibit 310

Exhibit 311

Exhibit 312

Exhibit 313

Exhibit 314

132

identifying No. 727-122, dated

1/7/54.

LPI 1268, photograph, Ammann

identifying No.. 727-121, dated

1/7/54.

LPI 1267, photograph, Ammann

identifying No. 727-120, dated

1/7/54.

LPI 1266, photograph Ammann

identifying No. 727-119, dated

1/7/54.

LPI 1265, photograph, Ammann

identifying No. 727-118, dated

1/7/54.

LPI 1264, photograph, Ammann

identifying No. 1727-38, dated

1/7/54.

LPI 1263, photograph, Ammann

identifying No. 726-96, dated

1/8/54.

LPI 1293, photograph, Ammann

identifying No. 727-197, dated

1/8/54.

LPI 1292, photograph, Ammann

identifying No. 727-177, dated

1/8/54.

LPI 1291, photograph, Ammann

identifying No. 727-176, dated

1/8/54.

LPI 1290, photograph, Ammann

Exhibit 315

Exhibit 316

Exhibit 317

Exhibit 318

Exhibit 319

Exhibit 320

Exhibit 321

Exhibit 322

133

identifying No. 727-175, dated

1/8/54.

LPI 1289, photograph, Ammann

identifying No. 727-144, dated

1/7/54.

LPI 1288, photograph, Ammann

identifying No. 727-135, dated 1/

7/54.

LPI 1287, photograph, Ammann

identifying No. 727-134, dated 1/

7/54.

LPI 1286, photograph, Ammann

identifying No. 727-133, dated 1/

7/54,

LPI 1285, photograph, Ammann

identifying No. 727-126, dated 1/

7/54.

LPI 1284, photograph, Ammann

identifying No. 727-125, dated 1/

7/54.

LPI 1304, photo mosaic obtained

from Ammann International Corp.

compiled from photos of Jack Am-

mann Photogrammetric Engineers,

Inc. based upon 1954 aerial photo-

graphy employed in preparation

of the Set of 54 maps, sheet L 39.

LPI 1305, photo mosaic obtained

from Ammann International Corp,

compiled from photos of Jack Am-

mann Photogrammetric Engineers,

Inc., based upon 1954 aerial photo-

Exhibit 323

Exhibit 324

Exhibit 325

Exhibit 326

Exhibit 327-A

Exhibit 327-B

134

graph employed in preparation of

the Set of 54 maps, sheet L 40.

Natural Entrance point alterna-

tive at South Pass at various tide

stages. Location 1, overlay, made

by Curtis Buttorff at National

Ocean Survey.

George H. Lauff, ed., Estuaries,

American Association for the Ad-

vancement of Science, No. 83

(1967).

LPI 1478, map of Yarmouth-Wind-

sor area of Nova Scotia, published

by Canadian government showing

bay of Fundy and St. Mary’s Bay

area LPI 1479, map labeled Church

Point N. S., 21 B/8 West half,

first edition;

LPI 1480, map labeled Church

Point, N. S., 21 B/8 East Half,

first edition;

LPI 1481, map labeled Digby,

N. S., 21 A/12 West Half, second

edition, all dealing with St. Mary’s

Bay.

1886 Chart of Breton Island Sound

Map 20 of 41, Buttorff work sheet

of Isle Derniere, analyzing Am-

mann photos.

Map 19 of 41, Buttorff work sheet

of Isle Derniere, analyzing Am-

mann photos.

135

Exhibit 328 LPI 1463, David Morgan’s index

to photos taken along South Pass

and showing artificial mainte-

nance of openings by Corps of En-

gineers (sheet 4 of 8).

Exhibit 329 Photograph Album Vol. 3 of Dr.

James P. Morgan, concerning arti-

ficial maintenance of openings be-

tween South Pass and East Bay

(for rebuttal).

LIST OF PHOTOGRAPHS TO ACCOMPANY

REBUTTAL TESTIMONY OF JAMES P.

MORGAN CONCERNING ARTIFICIAL

MAINTENANCE OF OPENINGS BE-

TWEEN SOUTH PASS, MISSIS-

SIPPI RIVER, AND EAST BAY

(The following photographs illustrate artificially

maintained openings from South Pass of the Missis-

sippi River into East Bay. The photographs depict

openings on the west bank of South Pass consecutively

from south to north. Figure 1, pages 1 through 5

(LPI #1463) accompanying the photographs, indi-

cates the position of each photographed opening. All

photographs were taken by David J. Morgan unless

otherwise indicated. )

Chrono- Louisi-

logic ana Pre-

Num- liminary

ber of Identify- Date of

Photo- ing Photo- Description of

graph Number graphy Photographs

1 1420 February View west of opening shown

23,1971 on Fig. 1, page 1.

1414

1406

1405

1425

1418

1417

1416

1396

1415

1397

1365

1419

1404

1362

February

23, 1971

February

23, 1971

February

23,1971

February

23,1971

February

23,1971

February

23, 1971

February

23,1971

February

23,1971

February

23,1971

February

23,1971

February

23, 1971

February

23, 1971

February

23,1971

February

23,1971

136

View west of opening shown

on Fig. 1, page 1.

View west of opening shown

on Fig. 1, page 1.

View west of opening shown

on Fig. 1, page 1.

View west of U.S. Coast

Guard Light Station. (Fig.

1, pages 1 and 2)

View west of opening shown

on Fig. 1, page 2.

View west of opening shown

on Fig. 1, page 2.

View west of opening shown

on Fig. 1, page 2.

View west of opening shown

on Fig. 1, page 2.

View west of opening shown

on Fig. 1, page 2.

View west of opening shown

on Fig. 1, pages 2 and 3.

View west of opening shown

on Fig. 1, pages 2 and 3.

View west of opening shown

on Fig. 1, pages 2 and 3.

View west of opening shown

on Fig. 1, pages 2 and 3.

View west of opening shown

on Fig. 1, pages 2 and 3.

1361

1351

1350

1375

1360

1376

1359

1366

1403

February

23, 1971

February

23, 1971

February

23, 1971

February

23, 1971

February

23, 1971

February

23, 1971

February

23, 1971

February

23, 1971

February

23, 1971

137

Photograph by James P.

Morgan

View west of opening shown

on Fig. 1, pages 2 and 3.

Photograph by James P.

Morgan

View west of opening shown

on Fig. 1, pages 2 and 3.

View west of Oysterville

Light and opening to west

shown on Fig. 1, page 3.

Photograph by James P.

Morgan

View west of opening im-

mediately north of Oyster-

ville Light shown on Fig. 1

page 3.

View west of opening shown

on Fig. 1, page 3.

View west of opening shown

on Fig. 1, page 3.

View west of opening shown

on Fig. 1, page 3. Photo-

graph by James P. Morgan

View northwest of opening

shown on Fig. 1, pages 3

and 4. Photograph by

James P. Morgan

View northwest of opening

shown on Fig. 1, pages 3

and 4.

ane

25 1422

26 «61421

27 1423

28 1373

29 13872

30 861871

31 1401

32 1402

Exhibit 330

February

23,1971

February

23,1971

February

23,1971

February

23,1971

February

23,1971

February

23, 1971

February

23, 1971

February

23,1971

138

View west of opening shown

on Fig. 1, pages 4 and 5.

View northwest of opening

shown on Fig. 1, pages 4

and 5.

Detail of rip-rap at opening

shown on Fig. 1, pages 4

and 5.

View west of rip-rap con-

trolled opening shown on

Fig. 1, pages 4 and 5.

View west of rip-rap con-

trolled opening shown on

Fig. 1, pages 4 and 5.

View west of rip-rap con-

trolled opening shown on

Fig. 1, pages 4 and 5.

View west of rip-rap block-

ing opening shown on Fig.

1, page 5.

View west of rip-rap con-

trolled opening shown on

Fig. 1, page 5.

Photograph album of Mr. David J.

Morgan of Isle Derniere area.

139

DESCRIPTION OF PHOTOGRAPHS AND

RELATED LOCATION MAPS CONCERNING

THE ISLE DERNIERE AREA

(All photographs taken by David J. Morgan unless

otherwise annotated )

Chrono- Louisi-

logic ana Pre-

Num- liminary Date of

ber of Identify- Photo-

Ilustra- ing graph or

tion Number Publication

3 1256 September

5, 1970

4 1261 September

5, 1970

5 1632

6 1239 September

5, 1970

Descriptic .. of

Photograph or

Illustration

Index map of Isle Derniere

area showing location of

Figures 1-5.

Figure 1 - portion of Coco-

drie Quadrangle, 7.5 minute

series showing approximate

locations of photographs

taken in that vicinity.

View NNW of marsh vege-

tation in vicinity of Pass La

Poule in Lake Pelto.

View NE of marsh vegeta-

tion in vicinity of Pass La

Poule in Lake Pelto.

Figure 2 - Portion of sheet

18 of 41 of the Set of 54

Maps showing approximate

locations of photographs

taken in that vicinity.

Wave action in Lake Pelto -

view northward.

1245

1242

1262

1243

1260

1259

1232

1252

1248

September

5, 1970

September

5, 1970

September

5, 1970

September

5, 1970

September

5, 1970

September

5, 1970

September

5, 1970

September

5, 1970

140

Wave action in Lake Pelto -

view northward.

Remnant of Bobwin Point,

former distributary in Lake

Pelto. View N

View southward down west

side of pinnacle of land ex-

tending northward to the

west of Old Camp Pass.

Pinnacle of land extending

northward west of Old Camp

Pass, looking NE.

Detail of organic clay com-

posing land in rear of is-

land; exhumed vegetation in

background.

View facing south down pin-

nacle of land at rear of is-

land to the west of Old Camp

Pass.

Figure 3 - portion of sheet

19 of 41 of the Set of 54

Maps showing the approxi-

mate position of photographs

taken in that vicinity.

View looking south at vege-

tation characteristics at rear

of island.

View looking south at boat

traffic in Caillou Bay. Isle

Derniere in background.

1544

1545

1546

1547

1532

1244

1532

1251

March

13, 1971

March

13, 1971

March

13, 1971

March

13, 1971

September

5, 1970

141

View looking west at penin-

sula in Bay Round vicinity,

north of Isle Derniere.

(James P. Morgan)

Vegetation characteristics

on peninsula in Bay Round

vicinity. (James P. Morgan)

Vegetation characteristics

on peninsula in Bay Round

vicinity. (James P. Morgan)

Vegetation characteristics

on peninsula in Bay Round

vicinity. (James P. Morgan)

Figure 4 - portion of sheet

19 of 41 of the Set of 54

Maps showing the approxi-

mate positions of photo-

graphs taken in that vi-

cinity.

View of north shore of Cail-

lou Bay showing vegetation

characteristics. View east-

ward.

Figure 5 - portion of sheet

' 20 of 41 of the Set of 54

September

5, 1970

Maps showing the approxi-

mate position of photographs

taken in that vicinity.

View looking north at ex-

humed island vegetation

mud flat to the west of

Coupe Colin.

1249

1253

1247

1250

1246

1255

1258

1240

September

5, 1970

September

5, 1970

September

5, 1970

September

5, 1970

September

5, 1970

September

5, 1970

September

5, 1970

142

View NE across Coupe Colin

at fishing camp on second

island.

View NE across Coupe Colin

at fishing camp on second

island.

View loking ESE at back

of westernmost island of Isle

Derniere.

View southward of western-

most island of Isle Derniere

showing mangrove and other

vegetation. (With D. J. Mor-

gan)

View southward of western-

most island of Isle Derniere

showing mangrove and other

vegetation. (With F. W.

Ellis)

View SW down rear of west-

ernment island of Isle Dern-

iere.

Bateau on beach at rear of

westernmost island ap-

proaching Raccoon Point.

Exhumed marsh in fore-

ground. View looking east.

September View looking east down

5, 1970

westernmost island showing

general characteristics of

the island. Gulf of Mexico is

to the extreme right.

Exhibit 331

A through E__—i port of David Morgan concerning

Exhibit 332

A and B

143

82 1254 September View looking northward

5,1970 showing vegetation char-

acteristics-Caillou Bay in

background.

83 1255 September View looking west down

5,1970 westernmost island showing

vegetation and general char-

acteristics. Caillou Bay to

right and Gulf to left.

34 1241 September View looking west down

5,1970 beach of westernmost island

of Isle Derniere. Gulf of

Mexico to left.

LPI 1548, hand-written summary re-

comparison of the shapes and areas

of water gap and island configura-

tions in the Isle Derniere area plus

annexed Xerox copies of map infor-

mation.

LPI 1484, record of the United States

Coast and Geodetic Survey of the

Department of Commerce showing

hourly heights of tides at Eugene

Island, Louisiana, dated February

5, 1954 for the period January 1

through January 14, referenced to

a datum of 1.6 feet below mean low

water.

Exhibit 333-A LPI 1294, statement by E. T. Oliver,

Jr., dated February 18, 1971, con-

cerning the records of Ammann In-

Exhibit 333-B

Exhibit 333-C

Exhibit 333-D

Exhibit 334

Exhibit 334-A

Exhibit 335

Exhibit 336

Exhibit 337

144

ternational Corporation and prede-

cessor firms being in his custody.

LPI 1295, film record card of Jack

Ammann Photogrammetric Engi-

neers, numbered 726, referred to in

LPI No. 1294.

LPI 1296, film record card of Jack

Ammann Photogrammetric Engi-

neers, numbered 727, referred to in

LPI No. 1294.

LPI 1297, statement from E. T. Oli-

ver, Jr. of information obtained from

original file record cards, statement

dated February 18, 1971, and ori-

ginally attached to LPI No. 1294.

LPI 1485, a document entitled, ‘““Sum-

mary of Tide Information pertaining

to 1954 Ammann Photography in the

Isle Derniere Area.”

Drawing by David Morgan regarding

tide information derived from the

Eugene Island gauge.

LPI 1518, a sketch prepared to gra-

phically reflect wind direction infor-

mation presented in testimony of Mr.

Arthur I. Cooperman.

Mylar overlay of 24th edition of chart

1272, December 1969, delimiting

areas for planimetry.

Myler overlay of 25th edition of chart

1272, August, 1970, delimiting areas

for planimetry.

145

Exhibit 338 Sketch by David Morgan illustrating

scale problems on maps.

Work sheets showing data for 45-

degree test in the Caillou Bay area

(in comparison with United States

Exhibit 355).

Photograph Album Vol. 1 of Dr.

James P. Morgan, concerning mud-

lumps, South Pass sand spit, and

Bucket Bend Bay area.

Exhibit 339

Exhibit 340

LIST OF PHOTOGRAPHS TO ACCOMPANY

THE REBUTTAL TESTIMONY OF JAMES

P. MORGAN CONCERNING PHYSICAL

CHARACTERISTICS OF MISSISSIPPI DELTA

MUDLUMPS, SOUTH PASS SAND SPIT AND

BUCKET BEND BAY AREA

(All of the Photographs included here were taken by

James P. Morgan unless otherwise indicated. )

PART I—COLOR PHOTOGRAPHS

Chrono- Louisi-

logic ana Pre-

Num- liminary

ber of Identify- Date of

Photo- _ing Photo-

graph Number’ graphy

Description of

Photographs

1 1434 February River silt and “mainland”

21,1971 vegetation on mudlump at

Southeast Pass. View north-

west.

2 1452 FebruaryBuck brush and _ isolated

21,1971 clumps of Roseau on South-

1429

1450

1445

1345

1369

1367

1379

1380

146

east Pass mudlump. View

north.

February Vegetation including Roseau

21, 1971 on west (bayside) of South-

east Pass mudlump. View

north.

February Rangia clams (indicative of

21,1971 marshland lakes) on South-

east Pass mudlump.

February Feces of coypu (nutria) in

21, 1971 Bermuda grass on Southeast

Pass mudlump.

February Very shallow water between

21,1971 Southeast Pass mudlumps

indicated by significant

waves generated over short

fetch between islands. View

north.

February Flock of terns disturbed on

22,1971 Pass a Loutre mudlumps.

View north.

February Mudlumps off mouth of Pass

22,1971 a Loutre. View west.

February Mudlump islands off mouth

22,1971 of South Pass. View north-

east. Photo by David J. Mor-

gan.

February Mudlump islands off mouth

22,1971 of South Pass. View north-

east. Photo by David J. Mor-

gan.

1378

1377

1431

1441

1432

1476

1473

1470

147

February Mudlump islands off mouth

22,1971 of South Pass. View north

Photo by David J. Morgan.

February Dr. Morgan collecting fos-

22,1971 sils from South Pass mud-

lump 89-90; being watched

by Mr. Ellis. Photo by David

J. Morgan.

February Fire ant mount on South

22,1971 Pass mudlump 89-90. Photo

by David J. Morgan.

February Feces of coypu (nutria) on

23,1971 mud-cracked surface of

South Pass mudlump 93.

February Feces of coypu (nutria)

23,1971 around mud puddle on mud-

lump 89-90. Photo taken by

David J. Morgan.

February Telephoto view of South

23,1971 Pass Coast Guard Station

and sand spit. View north-

east. (No. 1 of a 7-photo

panorama. )

February Telephoto view of South

23,1971 Pass Coast Guard Station

and sand spit. View north.

(No. 2 of a 7-photo pano-

rama. )

February Telephoto view of South

23,1971 Pass Coast Guard Station

and sand spit. View north.

(No. 3 of a 7-photo pano-

rama.)

1474

1471

1472

1475

1512

1510

1509

148

February Telephoto view of South

23,1971 Pass Coast Guard Station

and sand spit. View north.

(No. 4 of a 7-photo pano-

rama. )

February Telephoto view of South

23,1971 Pass Coast Guard Station

and sand spit. View north.

(No. 5 of a 7-photo pano-

rama. )

February Telephoto view of South

23,1971 Pass Coast Guard Station

and sand spit. View north-

west (No. 6 of a 7-photo

panorama. )

February Telephoto view of South

23,1971 Pass Coast Guard Station

and sand spit. View north-

west. (No. 7 of 7-photo pano-

rama.)

March Mouth of South Pass show-

6,1971 ing sand spit which has re-

formed since Hurricane Ca-

mille and mudlumps in dis-

tance. View southwest.

March Mouth of South Pass show-

6,1971 ing sand spit which has re-

formed since Hurricane Ca-

mille. Mudlumps in distance.

View north.

March Mouth of South Pass show-

6,1971 ing sand spit which has re-

formed since Hurricane Ca-

1437

1382

1438

1496

1495

1497

1493

1491

1499

149

mille. Mudlumps in distance.

View east.

February Vegetation surrounding

23,1971 pond on South Pass mud-

lump 93. View southwest.

February Mud vent discharging brine

23,1971 into pond on South Pass

mudlump 93. View south-

east.

February Vegetation surrounding

23,1971 pond on South Pass mud-

lump 93. View northwest.

March View west toward the inte-

6,1971 rior of Cubits Crevasse area

north of Bucket Bend Bay.

March View west toward the inter-

6,1971 ior of Cubits Crevasse area

north of Bucket Bend Bay.

Area immediately south of

Photo No. 29.

March View toward southwest of

6,1971 Bucket Bend Bay.

March View toward southwest of

6,1971 Bucket Bend Bay.

March View toward southwest of

6,1971 Bucket Bend Bay. Pass a

Loutre in the background.

March View west of Bull Bay

6,1971 (inner part of Bucket Bend

Bay) and Paddy Bay. Pass

a Loutre to left of photo.

150

35 1487 March View north of Paddy Bay at

6,1971 upper end of Bucket Bend

Bay. Pass a Loutre in left

foreground.

36 1486 March View to the northeast of

6,1971 Bucket Bend Bay and open-

ing into Gulf.

37 1515 March Marsh area south of Bucket

6,1971 Bend Bay. Mud flats reflect

tide stage.

38 1514 March Marsh area south of Bucket

6,1971 Bend Bay. Mud flats reflect

tide stage.

PART II—BLACK AND WHITE PHOTOGRAPHS

Louisi-

Chrono- ana Pre-

logic liminary

Number Identify- Date of

of Photo- ing Photo- Description of

graph Number’ graphy Photographs

B&W1 1307 March Aerial view to northeast

6,1971 of Paddy Bay (fore-

ground), Bull Bay (mid-

dle ground), and Gulf in

Bucket Bend Bay area.

B&W2 1465 March Aerial view to the south-

6,1971 west showing Bucket Bend

Bay area with Pass a Lou-

tre in distance.

B&W3 1468 March Aerial view to the south-

6, 1971 west showing Bucket Bend

Bay area with Pass a Lou-

tre in distance.

151

B&W4 1469 March View to the southwest

6,1971 showing ship entering

South Pass with sand spit

and mudlump islands in

distance.

Exhibit 341 Photograph album, Vol. 2 by Dr. James

P. Morgan, concerning Joseph Bayou

area.

LIST OF PHOTOGRAPHS TO ACCOMPANY THE

REBUTTAL TESTIMONY OF JAMES P. MOR-

GAN CONCERNING THE PHYSICAL CHAR-

ACTERISTICS OF THE JOSEPH BAYOU

AREA, EAST BAY MISSISSIPPI DELTA

(All of the photographs included here were taken by

James P. Morgan unless otherwise indicated.)

PART 1-COLOR PHOTOGRAPHS

Figure 1- Index Map showing photograph directions

and locations by LPI Number.

Chrono- Louisi-

logic ana Pre-

Num- liminary

ber of Identify- Date of

Photo- ing Photo- Description of

graph Number graphy Photographs

1 13857 February View north from Joseph

22,1971 Bayou showing levees in

foreground and dredged

spoil in distance.

2 1346 February View northeast from Joseph

22,1971 Bayou showing levees in

1347

1355

1356

1353

1354

1408

1407

1411

1410

February

22,1971

February

22, 1971

February

22,1971

February

22, 1971

February

22,1971

February

22,1971

February

22, 1971

February

22, 1971

February

22,1971

152

foreground and dredged

spoil in distnace.

View east from Joseph Bay-

ou across levee.

View east .across Joseph

Bayou levee.

View southeast down Joseph

Bayou and left bank na-

tural levee.

View northeast across Jo-

seph Bayou natural levee

(middle ground) showing

Roseau clumps in distance.

View north from canal in

Joseph Bayou area. See at-

tached map (Fig. 1) for lo-

cation.

Well location in Joseph Bay-

ou canal. See Fig. 1 for lo-

cation.

Well location in Joseph Bay-

ou canal. See Fig. 1 for loca-

tion.

View northwest from Joseph

Bayou canal showing crew

boat in another canal in dis-

tance. See Fig. 1 for loca-

tion.

Deteriorating marshland in

Joseph Bayou area. View

1409

1400

1413

1394

1398

1457

1459

1458

February

22,1971

February

22,1971

February

22, 1971

February

22, 1971

February

22,1971

February

22, 1971

February

22, 1971

February

22, 1971

153

north. See Fig. 1 for loca-

tion.

View northwest across de-

teriorating marshland in Jo-

seph Bayou area. See Fig-

ure 1 for location.

View southeast out mouth of

Joseph Bayou into East Bay.

See Fig. 1 for location.

View northwest of Roseau

marshland of Joseph Bayou

area. See Fig. 1 for location.

View north of Roseau marsh-

land near mouth of Joseph

Bayou. See Fig. 1 for loca-

tion.

View north of Roseau marsh-

land near mouth of Joseph

Bayou. See Fig. 1 for loca-

tion.

Mr. Ellis standing in Roseau

clump at mouth of Joseph

Bayou. See Fig. 1 for loca-

tion. Photo by David J. Mor-

gan.

Mr. Ellis standing in Roseau

clump at mouth of Joseph

Bayou. See Fig. 1 for loca-

tion. Photo by David J. Mor-

gan.

Mr. Ellis standing in Roseau

clump at mouth of Joseph

1456

1381

1539

1540

1541

1542

1543

February

22,1971

February

22,1971

March

6, 1971

March

6, 1971

March

6, 1971

March

6, 1971

March

6, 1971

154

Bayou. See Fig. 1 for loca-

tion. Photo by David J. Mor-

gan.

Mr. Ellis showing result of

standing in Roseau clump

at mouth of Joseph Bayou.

Photo by David J. Morgan.

Mr. Ellis showing result of

standing in Roseau clump at

mouth of Joseph Bayou.

Photo by David J. Morgan.

Aerial view toward south-

west of the Joseph Bayou

area. Southwest Pass in

background.

Aerial view toward south-

west of the Joseph Bayou

area. Southwest Pass in

background.

Aerial view toward south-

west of the Joseph Bayou

area. Southwest Pass in

background.

Aerial view toward south-

west of the Joseph Bayou

area. Southwest Pass in

background.

Aerial view toward south-

west of the Joseph Bayou

area. Southwest Pass in

background.

155

PART II- BLACK AND WHITE PHOTOGRAPHS

Chrono-

logic

Num-

ber of

Photo-

graph

B&W1

B&W2

B&EW3

B&W4

B&W5

Louisi-

ana Pre-

liminary

Identify-

ing

Number

1326

1327

1328

1329

1340

Date of

Photo- Description of

graphy Photograph

February Part of a 3-photo pano-

22,1971 rama(LPI #1523A)show-

ing Joseph Bayou area;

same region as shown on

Fig. 1.

February Part of a 3-photo pano-

22,1971 rama(LPI #1523A)show-

ing Joseph Bayou area;

same region as shown on

Fig. 1. ~

February Part of a 3-photo pano-

22,1971 rama(LPI #1523A)show-

ing Joseph Bayou area;

same region as shown on

Fig. 1.

February Detail of Roseau marsh-

22,1971 land at the mouth of Jo-

seph Bayou. View east

(same location as LPI

#1381, Fig. 1)

February Mr. Ellis standing in Ro-

22,1971 seau at the mouth of Jo-

seph Bayou. View east

(same location as LPI

#1381, Fig. 1).

Exhibit 342

Exhibit 343

Exhibit 344

Exhibit 345

Exhibit 346

Exhibit 347

Exhibit 348

Exhibit 349

Exhibit 350

Exhibit 351

Exhibit 352

156

LPI 1523-B, panorama of Dr. Morgan’s

photos of tombolo at South Pass.

LPI 1523-A, black and white panorama

of Joseph Bayou area.

LPI 1522, an exhibit reflecting hydro-

graphic information pertaining to the

Pass a Loutre area. (colored)

Mylar film of map 2 of 8, North Pass,

Pass a Loutre, to overlay exhibit 344.

Mylar film of map of Southeast Pass

mudlumps, map 3 of 8, at reduced scale

(approximately 1:30,000) to overlay

Louisiana Exhibit 216.

Mylar film of mouth of South Pass

from map 4 of 8 at reduced scale (ap-

proximately 1:30,000) to overlay Lou-

isiana Exhibit 216.

Memo of area in acres of Mississippi

River below Venice by Larimore.

Water Borne Commerce of the United

States, Corps of Engineers, pp. 179-

80 (1967)

Water Borne Commerce of the United

States, Corps of Engineers, pp. 181-82

(1968)

Water Borne Commerce of the United

States, Corps of Engineers, pp. 189-

90 (1969)

Brief Exhibit 70-118, appendix G. of

Louisiana Brief before the Supreme

Exhibit 353

157

Court. Harbor works to show channel

depths (Corps of Engineers).

Three-mile projection plotted on re-

duced scale Set of 54 Maps (w/docu-

ments from Louisiana Answers to Sec-

ond Interrogatories affixed to front

cover)

Exhibit 353-A Computer printout of three-mile pro-

Exhibit 354

B-G

Exhibit 355

Exhibit 356

jection (done by Louisiana State Uni-

versity) (w/one-page attachments).

Norwegian maps

The In Camera documents; Confiden-

tial documents; no copy allowed.

(a) Letter from Solicitor General

Perlman to Boliver E. Kemp, Jr., At-

torney General for the State of Lou-

isiana, dated March 16, 1951. This

letter has been introduced in evidence

as U.S. Exhibit No. 341.

(b) The copies of the United States

Coast and Geodetic Survey Charts Nos.

1115 and 116 upon which was delin-

eated the line showing the general loca-

tion of the landward boundary of the

offshore area claimed by the United

States, which were attached to the let-

ter by Mr. Philip B. Perlman, Solicitor

General, to the Honorable Boliver E.

Kemp, Jr., dated March 16, 1951.

Perlman to Boliver E. Kemp, Jr., At-

158

torney General of the State of Lou-

isiana, dated June 12, 1951

(d) Letter from Solicitor General

Perlman to Boliver E. Kemp, Jr., At-

torney General of the State of Lou-

isiana, dated June 26, 1951.

(e) Letter from Secretary of State

Seward to Gabriel Tassara, Spanish

Minister, dated August 10, 1863, which

appears in 1 Moore Digest of Interna-

tional Law, 1906, p. 711.

(f) Hall International Law 8th Edi-

tion, 1917, pages 126, 127.

(zg) Senate Document No. 162, 58th

Congress, 2d Session, pages 239-240;

page 221, pages 224 to 228 and pages

15 and 16, and Volume 4, Part I, Count-

er Case of the United States, pages

131-132; Volume 5, Part I, Argument

of the United States, pages 14-18; Vol-

ume 7, pages 605-611, pages 543-548.

159

APPENDIX II, Part 3

INDEX TO THE EVIDENCE INTRODUCED BY

THE UNITED STATES IN THE PROCEEDING

BEFORE WALTER P. ARMSTRONG, JR., SPEC-

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

CIAL MASTER

Descriptive Report, Planimetric and

Mean-Low Water Line Mapping Pro-

jects PH-5903 and 20,000-819 Part

I - Mississippi River Delta, T-10944

to T-10957

Compilation Report, Mississippi

Delta, Louisiana Map Numbers T-

10944 through 10957, Bureau of

Land Management Numbers 1

through 8

Reprint from the International Hy-

drographic Review, Vol. XX XVIII,

No. 1, January 1961, Mapping the

Low-Water Line of the Mississippi

Delta

Descriptive Report, Shoreline and

Mean-Low Water Line Mapping -

Project 20,000-819 Part II—T11993-

T-11997, Atchafalaya Bay

‘Hand held photographs taken during

1960-1961 Atchafalaya Bay Survey

and Descriptive Area Maps

Aerial Photographs Nos. :

L8606 - L8612, L9036, L9035,

L9034, L9033, L9032, L9031,

L9030, L9029, L8703, L8704,

L9003, L9002, L9001

Exhibit 7

Exhibit 8

Exhibit 9

Exhibit 10

Exhibit 11

Exhibit 12

Exhibit 13

160

Field Inspection Photographs Nos. :

L8606 - L8609, L8703

Aerial Photographs Nos. :

L8720 - L8729, L8984 - L8989,

08713, L8991

Field Inspection Photographs Nos.:

L8991, L8983, L8985, L8987,

L8989, L8727

Letter from Wesley A. D’Ewart, As-

sistant Secretary of the Interior, to

William G. Helis, Chairman, Louisi-

ana State Mineral Board, July 11,

1956

Letter from William G. Helis, Chair-

man, Louisiana State Mineral Board,

to Wesley A. D’Ewart, Assistant

Secretary of the Interior, July 23,

1956

Memorandum for the Record, by Earl

G. Harrington, Cadastral Engineer-

ing Staff Officer, and Donald B.

Clement, Cadastral Engineering Of-

ficer, for the Interior Department

Committee, August 27

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