# Appendix — U. S. v. LOUISIANA, et al.

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385003_0001%3A5

## Record

- **Collection:** Supreme Court brief
- **Document type:** Appendix
- **Published:** January 1, 1974
- **Citation:** 419 U.S. 969

## Text

No. 9, Original

Inu the
Supreme Court of the United States

OCTOBER TERM, 1974

oF

UNITED STATES OF AMERICA,
Plaintiff,
V.
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,

V.

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

VI

VII
Vill

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

XIV
XV
XVI

XVII

XVI
XVIII
XX
XXI
XXII

XXIII
XXIV
XXIV
XXV
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

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

XXXIIT
XXXV

XXXV

XXXV
XXXVI
XXXVI

XXXVII
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"
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
XXXVII
XXXVII
XXXVIII
XXXVIII
XXXIX
XXXIX

XL
XLI

IN BATON ROUGE

Mr. Philip B. Larimore

Mr. Curtis Buttorff

Mr. David J. Morgan

Dr. James P. Morgan

XLII
XLII

XLII

XLIV
XLIV

XLV
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?

6

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

7
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

8

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

9

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

10

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.

11

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:

12

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 |

10

11

12

13

137

136

135

131

134

132

133

13

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

14

15

16

17

18

19

120

167

119

118

117

75

160

14

8-27-69

9-3-69

8-27-69

8-27-69

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.

21

22

23

24

25

26

27

28

158

163

170

105

145

144

143

104

15

9-3-69

9-3-69

9-3-69

8-27-69

9-3-69

9-3-69

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-

29

30

31

32

33

34

35

76

140

146

112

150

152

149

16

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.

36

37

38

39

40

41

Exhibit 10

Exhibit 10-A

151

154

116

113

147

148

17

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

18

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

1

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).

19

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.

11

12

13

14

15

16

17

87

124

85

89

91

20

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

18

19

20

21

22

23

84

81

121

122

123

Fig. 44, Sept. 61 Aerial

Bull. 35

21

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.

24

25

26

27

28

29

22

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

30

31

32

33

34

35

36

989

1006

79

78

80

979

981

23

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.

37

38

39

40

41

42

43

44

45

24

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

46

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

25

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.

27

26
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

28

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

29

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.

30

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.

31

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

32

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

33

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

34

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.

35

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

36

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

49

50

Census of the United States, as follows:

37

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.

38

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

39

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

1,

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.

42

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.

43

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.

44

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.

45

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.

46

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.

47

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.

48

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.

49

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.

50

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,

51

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.

52

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

12

13

14

15

47

152.

153.

154.

155.

156.

157.

53

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

51

46

1164

841

842

843

158.

159.

160.

161.

162.

163.

164.

54

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.

55
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

45
44
43
42
41
40
39
38
37
36
35
34
33

181.

182.
183.
184,

185.

186.

187.

188.

189.
190.

191.
192.
193.
194.

195.
196.
197.

198.

56
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

48
32
31

30

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.

57

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.

58

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.

59

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.

60

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.

61

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.

62
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.

63

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.

66

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.

67

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

68

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

69

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

70

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

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

73

74

75

76

77

78

71

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

72

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

73

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

74

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

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

105

106

107

108

109

110

111

112

75

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

76

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

77

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

78

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

1,

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

79
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

80

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

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

124

125

126

127-A
127-B
127-C
128-A
128-B
129-A
129-B
129-C
129-D

130

81

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

Exhibit

Exhibit

Exhibit

Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit

Exhibit

131

132

133

134

134-A
134-B
134-C
134-D
134-E
134-F
135

136

82

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

83

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

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

143

144

145

146

147

148

149

150

151

152

84

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

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

153

154

155

156

157

158

159

160

161

162

85

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

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

163

164

165

166

167

168

169

170

171

172

173

86

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

87

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

88

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

89

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

90

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

91

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

92

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
Exhibit
Exhibit
Exhibit
Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

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

93

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

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

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

94

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

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

182-V

182-W

182-X

182-Y

182-Z

182-AB

182-AC

182-AD

182-AE

182-AF

95

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

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

182-AG

182-AH

182-Al

182-AJ

182-AK

182-AL

182-AM

182-AN

182-AO

96

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

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

182-AP

183

183-W

183-X

183-Y

183-Z

184-A

184-B

184-C

97

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

98

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

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

184-I

184-J

184-K

184-L

184-M

184-N

99

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-
5

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

Exhibit

Exhibit

Exhibit

Exhibit
Exhibit

Exhibit

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.

10

11

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.

12

13

14

15

16

17

18

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-

19

20

21

22

23

24

25

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
Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

Exhibit

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.

10

11

12

No.

No.

No.

No.

No.

No.

No.

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

13

14

15

16

17

18

19

20

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
Exhibit

Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
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 Codi

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385003_0001%3A5. Public record. Not legal advice.
