Delgamuukw Trial Transcripts

Cross-Examination on Affidavit of Abel Sampson British Columbia. Supreme Court Dec 14, 1988

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 <3n \\\z j&uprsxn* (Sourl of JUritisIj Columbia  Na  0843  Smithers  Registry  Smithers, B. C.  December 14, 1988  BETWEEN:  AND  DELGAMUUKW, also know as KEN MULDOE,  suing on his own behalf and on behalf  of all other members of the HOUSE OF  DELGAMUUKW, and others,  Plaintiffs;  HER MAJESTY THE QUEEN IN RIGHT OF THE  PROVINCE OF BRITISH COLUMBIA and  THE ATTORNEY-GENERAL FOR CANADA,  Defendants.  CROSS-EXAMINATION ON AFFIDAVIT  OF  ABEL SAMPSON <3!n ilj* jg>upr*m* Court of £3rttisl| Columbia  Na 0843  Smithers Registry  Smithers, B. C.  December 14, 1988  BETWEEN  AND:  DELGAMUUKW, also know as KEN MULDOE,  suing on his own behalf and on behalf  of all other members of the HOUSE OF  DELGAMUUKW, and others,  Plaintiffs;  HER MAJESTY THE QUEEN IN RIGHT OF THE  PROVINCE OF BRITISH COLUMBIA and  THE ATTORNEY-GENERAL FOR CANADA,  Defendants.  CROSS-EXAMINATION ON AFFIDAVIT  OF  ABEL SAMPSON  P.R. Grant, Esq.  CM. Mackenzie, Esq  M.W.W . Frey, Esq.  appearing for the Plaintiffs  appearing for Her Majesty the  Queen in Right of the Province  of British Columbia  appearing for the Attorney  General of Canada EXHIBITS  INDEX  NO.  DESCRIPTION  PAGE  Letter dated Oune 24, 1983 on  Gitanmaax Band Council Letterhead  Topographic Survey Data Sheet dated  December 20, 1982  19  29  WITNESS  SAMPSON, Arthur  Cross-examination by Mr  Cross-examination by Mr  Frey  Mackenzie  Re-examination by Mr. Grant  1  23  34 1  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1 SMITHERS, B.C.  2 December 14, 1988  3  4 ABEL SAMPSON, a witness herein  5 called on behalf of the  6 Plaintiffs, having been duly  7 sworn, testifies as follows:  8  9 S. HOWARD: Interpreter previously  10 sworn  11  12 MR. GRANT:  Before we proceed, I want to set out that I have  13 delivered to you without a transmittal letter an  14 eight page document entitled Maggie Louie's Funeral  15 Book on Feast, a photocopy of that as well as a  16 four-page document which is a record of the  17 contributions made at the smoke feast for David  18 Gunanoot, Nii Kyap.  Neither of these feast books  19 were in the possession of this witness, but they  20 were in the possession of his sister who informed me  21 that she was unable to locate any other feast book,  22 although another — there may be another feast book  23 with respect to David Gunanoot's feast.  It is not  24 in her possession, nor is it in the possession of  25 this witness.  26 I will send a confirmation letter to you in due  27 course, but I had to get these — I got these at the  2 8 last moment, so I wanted to give you copies of them.  29 I believe Mr. Sampson is being cross-examined with  3 0 respect to his affidavit which is exhibit number —  31 MR. FREY:  600.  32 MR. GRANT:  600?  33 MR. FREY:  That's right.  Did you have anything more, Mr. Grant?  34 MR. GRANT:  No.  35  36 CROSS-EXAMINATION  BY  MR.   FREY:  37 Q Mr.   Sampson,   when were you born?  3 8 A         August  2,   1934.  39 Q And where  do you live?  40 A Right  now?  41 Q Right  now.  42 A Hazelton.  43 Q And did you live  any place before you lived in  44 Hazelton?  45 A   Yes, at Bear Lake.  46 Q   Bear Lake.  And when did you move from Bear Lake to  47 Hazelton? A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1 A 1949.  2 MR.   FREY: All   right.     And what  do you  do  for  a  living?  3 MR. GRANT: Now?  4 MR. FREY:  5 Q    Now?  6 A Millwright.  7 Q And how long have you been a millwright?  8 A 15 years I guess.  9 Q I guess you're including the apprenticeship period  10 as well?  11 A Yes.  12 Q And have you worked as a millwright all those 15  13 years in Hazelton?  14 A Yes, in Hazelton.  15 Q And before you were a millwright, what did you do?  16 A I was at the sawmill ten years.  I've been at the  17 sawmill all my life.  18 Q Okay.  And the first job you had was at the sawmill?  19 A Right.  20 Q All right.  So before you became a millwright you  21 worked for ten years at the sawmill, is that about  22 right?  23 A Yeah,   about  that.  24 Q And which mill   are you at now?  25 A Westar.  26 Q Now, you hold a chief's name and I am going to try  27 and pronounce it.  Is it Haimadimtxw?  28 A Haimadimtxw.  29 Q And when did you acquire that name?  30 A I don't remember the year, but it's been about five,  31 six years now.  Oh, it's longer than that.  1976  32 when I — when the holder passed away, so it would  33 be 1976.  34 Q All right.  Now, your father was Arthur Sampson?  35 A Yes.  36 Q And he held a chief's name.  I'll try and pronounce  37 it again, Smaex?  3 8 A Smaex, yes.  39 Q And is that a chief's name in the house of Tsabux?  40 A Yes.  41 Q Is that pronunciation close?  42 A Yes.  43 Q And that's  in the Wolf  Clan?  44 A Mh'm.  45 Q And your mother was Mary  Patrick?  46 A Yes.  47 Q And which house was she in? A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1  A  2  Q  3  A  4  Q  5  A  6  Q  7  8  9  A  10  11  Q  12  13  A  14  Q  15  16  A  17  MR.  FREY:  18  19  MR.  GRANT  20  MR.  FREY:  21  Q  22  A  23  Q  24  A  25  Q  26  A  27  Q  28  A  29  Q  30  A  31  Q  32  A  33  Q  34  A  35  36  37  Q  38  A  39  Q  40  41  A  42  MR.  FREY:  43  44  MR.  GRANT  45  46  MR.  FREY:  47  Ni i Kyap.  Nii Kyap?  Yes.  And that's Wolf Clan as well; is that right?  Yes.  Now, is that acceptable under Gitksan law for two  members of the Wolf Clan to be married to each  other?  I guess it's not, but they have to put up a feast  when that happens.  So it's your understanding that when your mother and  father were married that they put up a feast?  Yes.  And was that feast specifically because they were  both in the same clan?  Yes.  But am I correct in saying that the law generally is  that two people in the same clan do not marry?  The Gitksan law?  The Gitksan law?  Yeah.  Now, do you know the name of your father's father?  My grandfather?  Yes, on your father's side?  Luke Sampson.  And do you know who your father's mother was?  My — what's that? Alice.  Do you know what her maiden name was?  Robinson.  And what house was she in?  She is in Tsabux.  Now, what did your father do for a living?  A little of everything I guess.  Trapping most of  his life.  When we came here he started working in  the sawmills.  And again that's 1949?  Yeah.  Before you moved to — before your family moved to  Hazelton, did he ever work logging before that?  No, it was all trapping up north at Bear Lake.  Now, can you tell me the traditional village from  which the house of Tsabux comes?  Can you clarify what you mean when you say "the  traditional village"?  Well, the way that it has been used in the  interrogatories and the genealogies.  The A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  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  42  43  44  45  46  47  traditional villages as I understand are Gitanmaax  and Kitwanga and Gitsegukla and Kisgagaas and Kuldo  and villages like that.  I haven't named them all,  but I am wondering if you know which of those  villages the house of Tsabux is from.  MR. GRANT:  I don't object to the question, I just want to be  clear.  From what you describe you are not talking  about necessarily a village of origin that is an  ancient village when you are saying your traditional  village, and I am referring to Gitangasxw and those  ancient villages?  MR. FREY:  No, I'm not.  MR.   GRANT:     I just wanted to be  clear on  that.     Maybe Madam  Interpreter would like  to repeat  that question.  MR.  FREY:  Q  A  Q  MR.  THE  MR.  MR.  MR.  THE  MR.  Well, I am wondering about the traditional village  that the house of Tsabux comes from.  Kisgagaas.  It's from Kisgagaas.  And is Smaex a separate house  from Tsabux?  Smaex?  Smaex?  :  No.  MR.  THE  MR.  A  GRANT:  WITNESS:  FREY:  Q   They are in the same house?  A   Yes.  FREY:  And another name Tsiiwas or Tsawas?  GRANT:  Tsiiwas.  WITNESS:  Tsiiwas.  FREY:  Q   Tsiiwas.  Is that a separate house from Tsabux or is  it the same house?  A   It's the same house.  Q   Now, I've already named — Tsiiwas and Tsabux are  both chiefs?  A   Yeah.  Q   Now, are there any other chief's names in the house  of Tsabux that you can tell me about, and I mean  chief's names?  A   There is To'ogwit.  I don't know, but somebody using  it.  And you mentioned Tsiiwas already.  FREY:  Could I get that name?  INTERPRETER:  I just put down T-0 Stop O-G-W-I-T, and I will  look up the correct spelling after.  FREY:  Q   So that makes four.  We have got To'ogwit, Smaex,  Tsiiwas and Tsabux.  Are there any others that you 5  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1 can remember today?  2 A   I'm afraid not.  3 Q All   right.     Now,   today  it  is Wilmer Johnson who  4 holds  the  name Tsabux?  5 A Yeah.  6 Q   And where does he reside? Where does he live?  7 A   In Hazelton.  8 Q   And do you know what his occupation is?  9 A   He works at the — in the reserve band office.  10 Q   You don't happen to know what he does there?  11 A   He's the planner.  12 Q   Now, you know of the house of Gwoimt?  13 A   Yes.  14 MR. FREY:  Now, is there a relationship between the house of  15 Tsabux and the house of Gwoimt that you know about?  16 THE INTERPRETER:  He can't remember who has the name Gwoimt.  17 MR. FREY:  18 Q   I believe it is Kathleen Wale today.  19 A   Yeah, they are in the same house.  20 Q   Do you mean the same clan?  21 A   Yeah, the same clan.  22 Q   They are Wolf as well?  23 A   Yeah.  24 Q   Is there any other connection between those two  25 houses that you know about other than the fact that  26 they are in the same clan?  27 A   What kind of — what kind of a connection is it?  28 Q   Well, I can tell you the reason that I am asking is  29 that the provincial government asked some questions  3 0              of Wilmer Johnson.  And one of the questions is  31 number 10.  I am simply reading now the answer that  32 Wilmer Johnson gave to one particular question.  And  33 the question is:  34  3 5 "When did you become head of the house of  36 Tsabux?"  37  3 8 And the answer that he gave is:  39  40 "In 1958 or 1959 when I received the name  41 Tsabux."  42  43 And then he went on to say:  44  45 "I share the house with Gwoimt."  46  47 Now, do you know what he meant by that? A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1  A  2  Q  3  A  4  Q  5  6  7  8  9  10  11  12  A  13  MR.  FREY:  14  15  16  THE  INTERP  17  THE  WITNES  18  19  MR.  FREY:  20  MR.  GRANT:  21  22  23  24  25  MR.  FREY:  26  Q  27  A  28  Q  29  A  30  Q  31  A  32  Q  33  34  35  A  36  Q  37  38  A  39  MR.  FREY:  40  41  42  MR.  GRANT:  43  MR.  FREY:  44  Q  45  46  A  47  Q  Yes, they are in the same house.  You mean clan?  Yes.  It's just that I'm not too sure what Wilmer means  here.  It is your understanding that when Wilmer  says:  "I share the house with Gwoimt"  what he is referring to is the fact that both Gwoimt  and Tsabux are both Wolf Clan?  Yes.  So a person who is a member of the house of Gwoimt is  not a member of the house of Tsabux, they are  separate?  IETER:  I'll explain to him.  3:  Yeah, they share the same house and they are the  same clan.  All right.  Was —  You haven't, and you are not obligated to, but maybe  to be clear as to who you are talking to — you  haven't asked this witness as to which house he is  in.  There may be an implication from the series of  questions that may not be correct.  You are in the house of Nii Kyap; is that correct?  Yes.  You are not in the house of Tsabux?  Yes.  Again it is the same clan, but a different house?  Yeah.  Now, have you ever heard that at some time in the  past the house of Gwoimt and the house of Tsabux  were the same house or were connected?  Yes, I have heard they were in the same house.  And do you know when that changed? Do you know when  they became separate chiefs?  No, I do not.  Now, we just went over this, you are in the house of  Nii Kyap.  Can you tell me the names of the chiefs  in the house of Nii Kyap?  Other than Nii Kyap?  Other than Nii Kyap and other than Haimadimtxw or —  say that one again so I get it right?  Which one?  Haimadimtxw? A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1 A   Haimadimtxw.  2 Q   Other than those two names, do you know any other  3 names that are chief's names in that house?  4 A   There is Nii Kyap, O'yee, Haimadimtxw.  Do you have  5 that?  6 Q   No, that's one I'm familiar with now.  7 A   I can't remember them.  8 Q   All right.  Now, the affidavit that you swore, I  9 believe you have a copy here.  Now, I take it from  10 your affidavit that your description of the Red  11 Creek territory is based on what you were told by  12 your father?  13 A   Yes.  14 Q   And your father was Arthur Sampson?  15 A   Yes.  16 Q   Now, when did your father pass away?  17 A   19 81.  18 Q   '81.  Now, how many times did you go to the Red  19 Creek territory with your father?  20 A   I only went there in my — when I was still pretty  21 young in my teens.  22 Q    And ~  23 A   And what's on the map is correct as far as I can  24 remember.  25 Q   All right.  So in terms of going there with your  26 father, you just went there once?  27 A   Well, I went there quite a few times before I came  2 8 here starting at the age of about 13 when I start —  29 started going out with him.  3 0 Q   At age 13.  And how old were you when you moved to  31 Hazelton?  32 A   About 15 I think.  33 Q   And after you moved to Hazelton, did you go out to  34 the Red Creek territory with him?  35 A   No.  36 Q   And I know this is a long time ago, but before you  37 moved to Hazelton can you remember how many times  3 8 you went up to the Red Creek territory with your  39 father?  40 A   About three times.  41 Q   All right.  Now, between when you moved to Hazelton  42 and when your father passed away in 19 81, did you go  43 up to the Red Creek territory during that period?  44 A   No.  45 Q   And since 1981 when your father passed away, how  46 many times have you been back?  47 A   Never. A. Sampson  Cross-exam  (for Plaintiffs)  by Mr. Frey  1  Q  2  A  3  Q  4  5  A  6  Q  7  8  9  10  11  12  13  14  15  16  17  18  A  19  MR. GRANT  20  MR. FREY:  21  MR. GRANT  22  MR. FREY:  23  Q  24  25  26  27  28  29  30  A  31  Q  32  33  A  34  Q  35  36  37  A  38  Q  39  A  40  41  Q  42  A  43  Q  44  45  A  46  Q  47  All   right.  Never went  there.  So the last  time you were  there was when you were  14  or 15 years  old?  Yeah.  Now, there is another statement in the answers that  Tsabux gave to the questions asked by the provincial  government.  Mr. Grant, that's number 73.  And I'll  just read the — well, the question deals with the  provincial government was asking Tsabux about the  use of the territory.  And in question number 73 the  answer that Tsabux gave was that:  "Art Sampson was the last to use our  territory.  This was in the late 1950's."  Do you agree with that statement?  Yeah.  You are asking Art Sampson being his father?  Oh, yes.  If it was his father who did that?  Well, what I'm asking is to your knowledge — I will  read this statement again, all right?  The  is:  statement  "Art Sampson was   the  last  to use  our  territory.     This was  in  the late 1950's."  Yes.  And to the best of your knowledge is that statement  correct?  Yeah.  Now, you mentioned that your father passed away in  19 81, and I'm wondering who — after his death who  took the name Smaex?  Don Milton.  And do you know when Don Milton took that name?  Right at the feast after my father died, the same  year, '7 6 — I mean '81.  '81?  Yeah.  To your understanding, he got it in  year?  Yeah.  Now, you received your name in 1976  1971 the same  I believe is  what you said.  Was there a feast when you received A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1  2  A  3  Q  4  A  5  Q  6  7  A  8  Q  9  A  10  11  12  Q  13  14  15  A  16  Q  17  18  A  19  Q  20  21  A  22  Q  23  24  A  25  Q  26  A  27  Q  28  A  29  MR.  FREY:  .  30  MR.  GRANT:  31  MR.  FREY:  32  MR.  GRANT:  33  THE  WITNESS  34  MR.  FREY:  35  36  MR.  GRANT:  37  38  MR.  FREY:  39  Q  40  A  41  Q  42  A  43  MR.  FREY:  44  45  46  47  your name?  Yes.  And where was that feast?  In Hazelton, Gitanmaax.  Now, can you remember how much you personally  contributed to get your name?  Approximately $1,500 to $2,000.  $1,500 to $2,000?  Yeah.  And the Wolf Clan had to put in for me too  for my house.  They all put in so it would come —  it was over 10,000 altogether.  Now, of the 1,500 to 10 — sorry, 1,500 to 2,000  that you put in, was that just cash or was that cash  and goods?  Cash and  goods.  Now,   Haimadimtxw  Peter Wilson held  that name before  you?  Yes.  And do you know who held the name before Peter  Wilson?  I  don't  remember his name really.  Do you know approximately when Peter Wilson received  the name Haimadimtxw?  No,   I  don't.  Was it before your time?  Way before my time.  All right.  Now, did you know Jacob Mowatt or Moat?  Yes.  And do you know whose house he was in?  How do you spell the last name?  M-O-w-A-T-T.  I would say Mowatt.  Mowatt.  :  He is in Tsabux.  And do you know — can you recall when he passed  away?  Are you asking him to give you the date or if he can  remember what happened?  Well, your best recollection.  I would say about four or five years ago.  All right.  And were you at his funeral feast?  Yes.  The feast? No, I wasn't at the feast.  Now, my understanding — and you may not know this  because you weren't there, but my understanding is  that it was a feast put on by both the house of  Tsabux and the house of Gwoimt.  Had you ever heard  that? i n  A. Sampson  Cross-exam  (for Plaintiffs)  by Mr. Frey  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  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  42  43  44  45  46  47  MR.  MR.  GRANT:  FREY:  Q  A  MR.   GRANT:  THE WITNESS  MR.   FREY:  MR.   FREY:  MR.  MR.  THE  MR.  FREY;  Q  A  Q  A  Q  A  Q  A  FREY:  Well,   that question —  I'm just asking.     He wasn't there,   so  I just wanted  to  see  if he was aware  of  it.  No.  It would require a hearsay answer.  :  I didn't hear about it.  All right.  Now, I want to ask you just a couple of  questions about the territory that you've described  in your affidavit.  Now, do you read maps?  (NO AUDIBLE RESPONSE)  And there is a particular part of the territory that  I want to ask you about.  Perhaps we can just go off  the record here for a moment, please.  (DISCUSSION OFF THE RECORD)  Now, there is a stretch of Bear River just north of  where Bear River meets Bear Lake.  Do you know where  I'm talking about? Do you know the north end of  Bear Lake?  Yes.  And that's where it meets Bear River?  The river that runs out of Bear Lake?  Yes.  Runs into Xsu Wii Ax.  It runs into the Sustut?  Yes.  And what I am referring to is Xsu Wii Ax.  I'm  probably not doing that well.  Mrs. Howard, I  understand that that's —  INTERPRETER:  FREY:  Xsu Wii Ax.  Q   That's the river I'm talking about.  A   Yes, that runs from Bear Lake.  Q   And it runs into the Sustut?  A   Yes.  GRANT:  Just if you're going to use the Gitksan names, I  think you should just in each occasion allow Miss  Howard to say the word because some of them —  FREY:  I'm not doing well at this.  GRANT:  Some of them are close and the witness may think it  is another word.  MR. FREY:  Madam Reporter, do you have that spelling?  MR.  MR.  MR. 11  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  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  42  43  44  45  46  47  THE  MR.  REPORTER:  FREY:  Q  Yes.  MR.  MR.  A  GRANT  FREY:  Q  Now, the land is on the north bank of what I will  call Bear River which is Xsi Tax.  The land that's  on the north bank and running back from the north  bank, is that within the Red Creek territory of  Tsabux or more accurately it would be northeast?  Going up to —  Is it — if you are going downstream, which side?  MR.  THE  MR.  A  Q  A  Q  A  FREY:  MR.  MR.  THE  MR.  If you are going downstream and you are looking  downstream it would be on the right?  On the right side.  So it is the land that goes up to the Connelly  Range?  Yes, that's part of the land.  That's part of the territory?  Yeah.  All right.  And there is another creek that the  spelling in the affidavit is S-A-B-A-N-A, new word,  G-E-E.  And, Mrs. Howard, if you could pronounce  that name?  INTERPRETER:  Sabana Gee.  FREY:  Now, you know the creek that I am talking about?  Mh'm.  Now, the land that's again if we were looking  downstream on that creek the land on the left would  be on the southeast — excuse me, the southwest  bank, all right?  Yeah.  Is that land on the left bank as you are looking  downstream?  Is that land within the Red Creek  territory?  You are going downstream?  You are looking downstream.  :  Going down Sabana Gee.  Going down Sabana Gee.  Left, right?  Q  A  Q  A  Q  A  FREY:  GRANT:  WITNESS  FREY:  Q  A  Q  A  Q  The land on your left?  Yeah, that's part of our land too.  All right.  Now, those two — I've asked you about  two creeks, and they bound a piece of land on the  south.  It is bounded by Xsi Tax, and on the north  it is bounded by Sabana Gee.  Yes, I know what you mean.  So you know the part of territory that I am talking 1 0  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  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  42  43  44  45  46  47  MR. FREY:  MR. GRANT:  MR. FREY:  Q  A  Q  A  Q  A  Q  A  MR. FREY;  THE INTERPRETER:  MR. FREY:  Q  about.  So your evidence is that that land is all  part of the territory of Tsabux?  Mh'm.  So if someone said that that was Miluulak's  territory they would be wrong?  Miluulak.  Miluulak's territory, that would be wrong to say  that?  Yeah.  And Miluulak is in the Frog Clan; is that correct?  Yes.  Now, do you know who held the name Smaex before your  father did?  Alec Brown.  And do you know who Alec Brown's wife was?  Her Indian name is Guu helangit.  I think her name  is Martha Brown.  Can I get that spelling, Mrs. Howard?  G-U-U, H-E-L-A-N-G-I-T.  I'll check it after.  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  MR. GRANT:  MR. FREY:  Now, was that Martha Brown, was she ever known as  Martha Gwoim?  I never heard that.  You were never aware of her being called that?  No.  And  the Martha Brown who held  the name Guu helangit,  do you  know what  clan  she was  in?  I would  say  that would be Frog.  Now,   I  am going to move  on  to another  area.     You've  told me   that  the person who held  the name  Haimadimtxw before you was  Peter Wilson?  Mh'm.  And the information that I have is that the person  who held the name before him was called Peter  Haimadimtxw.  Had you ever heard that?  Yeah.  Does that sound right?  Yeah, I think that is — I'm not quite sure.  He was  his father.  It was  Peter Wilson's  father?  Yeah.  But you're not certain if it was Peter Haimadimtxw  if that was his name?  No.  You're not certain?  If Peter Haimadimtxw was his name. A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1  MR.  GRANT:  2  MR.  FREY:  3  4  THE  INTERP  5  6  MR.  GRANT:  7  8  9  10  MR.  FREY:  11  Q  12  13  14  15  A  16  Q  17  18  19  A  20  Q  21  22  A  23  24  MR.  FREY:  25  MR.  GRANT:  26  27  MR.  FREY:  28  MR.  GRANT:  29  MR.  FREY:  30  Q  31  32  33  A  34  35  Q  36  37  38  39  40  A  41  Q  42  43  A  44  Q  45  46  47  A  Was his name?  Was the name of the gentleman who held the name of  Haimadimtxw prior to Wilson?  2TER:  He thinks it was Peter Wilson's father, but  he's not certain.  Can we go off the record a moment.  (DISCUSSION OFF THE RECORD)  I should clarify that.  I take it that number one  you're not certain if the previous Haimadimtxw was  Peter Wilson's father.  You are not certain about  that?  No, I don't know.  Now, are you aware that Peter Wilson had a trapline  registered at the — I'm going to use the English  name the Kluatantan River?  Say it again?  Kluatantan.  Kluatantan, have you ever heard of that  river?  Yeah, I've heard, but I've never been there.  It is  way up the Skeena Rier.  Had you ever heard that —  I think you asked if the previous Haimadimtxw held a  registered trapline; is that right?  That's right.  Are you talking about Peter Wilson?  I'm wondering if you ever heard that Peter Wilson  had a trapline registered up in the Kluatantan  River.  Had you ever heard that before?  Yeah, he has a trapline up there, up north  somewhere.  And it's my understanding that that trapline also  included, and I may not get this pronunciation  right, Kluayaz Lake.  That's again the name off the  English map.  Kluayaz Lake, have you ever heard of  that name?  No.  What about Jenkins Creek?  Have you ever heard of  Jenkins Creek?  No.  The area  that was  registered  to Peter Wilson up at  the  Kluatantan River,   that's  the area  I'm asking  about.  Mh'm. J.*  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1 Q   Now, had you ever heard that the previous  2 Haimadimtxw also had that same registered trapline  3 before Peter Wilson had it? Had anyone ever told  4 you that?  5 A   Yes, I have heard about it.  6 Q   Now, have you ever heard that Peter Wilson wanted to  7 transfer the registration of that trapline on the  8 Kluatantan River, that he wanted to transfer the  9 registration to his sons?  10 A   Yeah.  11 Q   You heard about that?  12 A   Yeah.  13 Q And  did you object  to  that  transfer?  14 A No,   I  didn't because  I  didn't —   they  didn't  come  to  15 see me  about   it.  16 Q   Were you aware that the —  17 A   Yes.  Excuse me —  18 Q   Sorry, go ahead.  19 A   His son — one of his sons came up and told me,  20 asked me about it.  I told him it had to be — it  21 had to stay on the Haimadimtxw's name territory and  22 the territory belongs to Haimadimtxw.  You can't go  23 into there.  24 Q   And do you remember which one of the sons it was  25 that came up and asked you?  26 A   Joe.  27 Q   Joe Wilson?  28 A   Yeah.  29 Q   And how long ago was that, that discussion that you  3 0 had with him?  31 A   I just told him last year.  32 Q   All right.  33 A   I didn't hear anymore about it.  34 Q   And is that — is that the first time that you had  35 ever heard that Peter Wilson's sons were trying to  36 get that trapline registration or had you ever heard  37 about it before then?  3 8 A   Well, I knew they were after it.  39 Q   And just so I have this right, when you spoke with  40 Joe Wilson last year —  41 A   Mh'm.  42 Q   — you said to him that's Haimadimtxw's territory?  43 A   Yeah.  44 Q   And I'm Haimadimtxw, and I am not going to let you  45 register there?  46 A   I told him he can go there as long as he comes and  47 sees me first. A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1  Q  2  A  3  Q  4  5  A  6  Q  7  A  8  Q  9  A  10  Q  11  12  13  14  A  15  Q  16  17  18  19  20  21  22  A  23  MR. FREY: <  24  MR. GRANT:  25  26  THE WITNESS  27  28  29  MR. FREY:  30  Q  31  32  33  34  35  A  36  Q  37  A  38  Q  39  40  41  42  43  44  45  46  47  He can go and use the territory?  Yeah.  But the actual registration has to stay in your  name?  Yes, under Haimadimtxw.  Under Haimadimtxw's name?  Yeah.  Or someone in Haimadimtxw's family?  Yeah.  Now, were you aware that three or four years ago  that the Gitanmaax Band Council objected to the  transfer of the trapline to Joe Wilson and his  brothers?  Had you ever heard about that?  No, I'm not aware of that.  All right.  Had you ever heard that the Gitanmaax  Band Council had taken the position that you were  Haimadimtxw and that therefore because it was  Haimadimtxw's traditional territory you should get  the trapline registration and not Joe Wilson and his  brothers.  Had you ever heard of the Band Council  taking that position or discussing that?  Well, we always — we have to go by the tradition.  Oh, I understand that.  What I'm —  Just a minute.  I think he may not be finished  answering.  :  For generations that's the way it has always been.  We have to go by the  stays on the name.  name to stay — the territory  All right.  And it's your position that the  territory where that Kluatantan — the Kluatantan  River area where that trapline is registered, it's  your position that that's the traditional territory  of Haimadimtxw?  Yes.  You're the traditional owner of that territory?  Yes.  And I guess what — I'm going to show you a letter  that is a letter from the Gitanmaax Band Council.  The only reason I am showing you this letter is I  simply want to find out if you are aware — it is a  letter written in 1983, and it is about this line.  Actually perhaps, Mr. Grant, what would be best is  if the witness could read the letter and if it was  necessary we could have any part translated into  Gitksan.  I would say it is from document number  4560.  It is the trapline file.  Have you had a 16  A.   Sampson   (for  Plaintiffs)  Cross-exam by Mr.   Frey  1 chance  to read  that letter?  2 A Mh'm.  3 Q   Now, you'll see that this letter is way back in  4 19 83.  My question to you is were you aware that  5 back then, back five years ago, that the Gitanmaax  6 Band Council was taking that position on your  7 behalf?  8 A   I don't remember.  I remember getting a letter like  9 this, but I don't remember.  10 Q   I guess what I am getting at is Joe Wilson came and  11 talked to you last year?  12 A   Yeah.  13 Q   Or within the last year or two?  14 A   Yeah.  15 Q   And you mentioned previously that no one had come  16 and asked you about this problem before?  17 A   Mh'm.  18 Q   And what I'm getting at is back in 19 83 did anyone  19 from the Band Council or on behalf of the Band  20 Council come and talk to you about this?  21 A   I got a letter like this.  It's about his sons  22 and —  23 Q   Well, there might be another letter.  Well, I only  24 have — well, there are two other letters right  25 about the same time which might be the letter that  26 you've got.  I will simply ask if you recognize  27 either of these as the letter that you received.  28 Now, just for the record the first letter that was  29 put to the witness is a letter from the Gitanmaax  3 0 Band Council re Steve Robinson dated June 24, 19 83.  31 It is addressed to the Gitksan Carrier Tribal  32 Council to the attention of Neil Sterritt.  Do you  33 recall receiving that specific letter?  34 A   Yeah, I think I did get a letter like this.  3 5 Q   All right.  Can you recall if it was this letter or  36 could it have been another letter?  37 A   I think I got two letters and one like this.  38 MR. FREY:   There is two other letters.  I don't believe that  3 9 you would have got either of these letters, but just  40 in case it turns out that these were one of the  41 other two letters, I'm showing to the witness  42 firstly a letter on the Ministry of Environment  43 letterhead dated May 9, 1983.  It's from Frank  44 Guillon, District Conservation Officer.  It is to  45 the attention of Indian Affairs to the attention of  46 Bob McLure.  Now, have you ever seen that letter  47 before? Mrs. Howard, you should make it clear to 17  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1 the witness that it is not addressed to him, and it  2 has not been circulated to him.  3 THE INTERPRETER:  That's what I just said.  4 MR. FREY:  5 Q   So it may be very well that you have never seen that  6 letter before?  7 A   No.  8 Q   And the next letter is on the Gitksan Carrier Tribal  9 Council letterhead, and it is dated November 24,  10 1983.  It is addressed to Neil Sterritt.  It is not  11 addressed to you and it has never been circulated.  12 Have you ever seen this letter before?  13 A   No, I haven't seen this.  14 Q   So of the three letters that you do recall seeing or  15 the only one you recall seeing is the June 24, 19 83  16 letter.  And when you say you received it, you  17 remember receiving it in the mail?  18 A   Yes.  19 Q   Now, I know this is a long time ago, but before you  20 got this letter had anyone ever talked to you about  21 Joe Wilson and his brothers wanting this trapline?  22 Had anyone ever talked to you before you got this  23 letter or is this the first you heard of it?  24 A   Yeah, it's the first I heard of it.  25 Q   All right.  And you don't recall anyone from either  26 the Tribal Council or the Gitanmaax Band office  27 contacting you about this before you got this letter  2 8 in the mail?  29 A   No.  3 0 Q   All right.  Now, it's your position that the  31 trapline or the area covered by the trapline  32 registration at Kluatantan River is part of the  33 traditional territories of Haimadimtxw; is that  34 correct?  35 A   Mh'm.  36 Q   So does that mean they are also part of the  37 traditional territories of the house of Nii Kyap?  38 A   Yes.  39 MR. FREY:  Now, are you aware that today these lands are no  40 longer claimed in this lawsuit?  And when I say  41 "these lands", I'm referring to the area up at  42 Kluatantan River.  Are you aware that today these  43 lands are no longer claimed in this action?  44 MR. GRANT: Well, just a moment.  I want to be clear.  You've  45 been talking here about a registered trapline.  I  46 want to be sure that the entirety of the lands in  47 that registered trapline are not included or that A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1  2  3  MR.  FREY:  4  MR.  GRANT:  5  6  MR.  FREY :  7  8  MR.  GRANT:  9  10  MR.  FREY:  11  Q  12  13  A  14  Q  15  16  A  17  Q  18  A  19  Q  20  A  21  22  Q  23  24  25  A  26  Q  27  A  28  Q  29  A  30  Q  31  A  32  Q  33  34  A  35  36  Q  37  38  A  39  Q  40  41  A  42  MR.  GRANT:  43  MR.  FREY:  44  Q  45  46  47  it's made clear to the witness which part of lands  in the registered traplines are not included.  Well, my understanding, Mr. Grant —  And the simplest way is with the overlays, the  famous Macaulay overlays.  I will come back and ask that question after the  break, that would be the easiest way to do it.  I just think it should be clear to the witness as to  what lands.  All right.  Now, your father Art Sampson, he had a  trapline registered on the Red Creek territory?  Mh'm.  And have you ever heard that your father had a  dispute with Bob Patrick regarding that trapline?  No.  Never heard of that before?  No.  Did you know a David Abraham?  David Abraham.  They are not talking about David  Patrick, are they?  The name I have is David Abraham, and I think it is  a different person.  Have you ever heard of a person  called David Abraham?  No.  Do you know of a person called Peter Abraham?  Yeah.  And is he from Takla Lake?  Yeah.  He is not a Gitksan person?  He lives in Burns Lake now.  All right.  But to your knowledge is he a Gitksan  person, and I am talking about Peter Abraham now?  Well, he is from Bear Lake.  He would be in with the  Babine band now.  All right.  Do you know if he is a member of a  Gitksan house?  No.  I mean it is your understanding he is a Babine  person?  Yeah.  Well —  Now, were you aware that Peter Abraham had a  trapline registered across that part of the  territory I was asking you before, and the part that  I'm referring to is the part that is between Sabana 19  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  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  42  43  44  45  46  47  Gee and Xsi Tax.  A   Mh'm.  Q   So I'm asking you about the same part of the  territory that we discussed before.  A   Mh'm.  Q   And my question is are you aware that Peter Abraham  has a trapline registered on that part?  A   Their trapline starts way, way up to Sustut River  past — way past Tsim Gehl Loop.  THE INTERPRETER:  Tsim Gehl Loop, it is on the affidavit.  MR.  MR.  MR.  GRANT:  FREY:  Q  A  Q  A  FREY:  MR.  MR.  MR.  GRANT;  FREY:  Q  A  Q  A  Q  A  Q  A  Q  A  FREY:  Maybe the witness can finish his answer.  Finish your answer.  Yeah, their trapline is way up the Sustut River.  All right.  Up above us.  Well, my understanding is that it is quite a large  trapline.  And the information that I have is that  it comes down and includes that southeastern part of  the territory that we were discussing before.  And  my question is have you ever heard that their  territory covered — excuse me, have you ever heard  that their trapline included that part of the Red  Creek territory?  The registered trapline?  Yes, the registered trapline.  This part here?  That's right.  Yeah, it includes that.  Now, what right does Peter Abraham have to register  a trapline there?  I don't know.  Did Peter Abraham — are you aware that Peter  Abraham ever asked your father for permission to  trap there?  No.  Do you know if Peter Abraham ever asked Wilmer  Johnson for permission to trap there?  No.  Perhaps this would be a convenient time to take the  break.  And perhaps we could mark this letter  Exhibit 1.  (EXHIBIT 1:  Letter dated June 24, 1983 on Gitanmaax  Band Council Letterhead) 20  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Frey  1  2  3  MR.  FREY:  4  Q  5  6  7  8  A  9  Q  10  11  A  12  Q  13  14  A  15  Q  16  17  A  18  Q  19  20  21  A  22  MR.  FREY:  23  24  25  26  MR.  GRANT  27  MR.  FREY:  28  Q  29  A  30  31  Q  32  A  33  Q  34  35  A  36  Q  37  A  38  Q  39  A  40  Q  41  42  A  43  MR.  FREY:  44  45  MR.  GRANT  46  MR.  FREY:  47  MR.  GRANT  boundaries of the  it is in  right?  the area  (BRIEF ADJOURNMENT)  All right.  Before we took the break I had been  asking you a couple of questions about a Haimadimtxw  territory up at Kluatantan River, do you remember  that?  Yes.  If I understand you have never had an opportunity to  go up to that territory yet?  No.  So you wouldn't  know  the precise  territory?  No, I wouldn't.  But it's your understanding that  of the Kluatantan River; is that  Yeah.  Now, talking about that territory generally as being  in the area of the Kluatantan River, were you aware  that that area is not being claimed in this action?  No, I wasn't aware of that.  All right.  Now, Mr. Grant this afternoon when he  arrived gave me a photocopy of what appears to be a  feast book for Maggie Louie.  Firstly, can you tell  me who Maggie Louie is?  Was.  Was, excuse me.  There is so many of them, I don't — that's the  sister of my grandmother.  All right.  Elsie Patrick, my grandmother.  All right.  And was Maggie Louie in the house of Nii  Kyap?  Yes.  All right.  And when was her funeral feast?  I don't remember.  Was it in the last ten years?  I think it is more than that.  Okay.  Were you at that funeral feast, the Maggie  Louie funeral feast?  I think I was.  Do you  know  if  Maggie Louie had a name,   a  chief's  name?  That's  two questions.  I was  clarifying.  So  the question  is  did  she have a chief's  name? •51  A. Sampson  Cross-exam  (for Plaintiffs)  by Mr. Frey  1  MR.  FREY:  2  Q  3  4  A  5  Q  6  7  8  A  9  Q  10  11  A  12  MR.  FREY:  13  14  15  MR.  GRANT:  16  MR.  FREY:  17  18  19  MR.  GRANT:  20  THE  WITNESS  21  MR.  FREY:  22  Q  23  24  A  25  Q  26  27  28  29  30  A  31  Q  32  33  A  34  Q  35  36  37  A  38  Q  39  A  40  Q  41  42  43  A  44  Q  45  46  A  47  Q  Did she have a chiefly name in the house of Nii  Kyap?  No, I don't remember her name.  I understand that you may not be able to remember  the particular name that she had, but do you know if  she did have a chief's name?  Yes, she did.  She did.  All right.  And was that chief's name  transferred to another person at this funeral feast?  I don't think so.  All right.  Do you know — and now I appreciate you  don't know what Maggie Louie's chief name was, but  do you know who has that name?  How can he answer that?  It could we well be that he doesn't know the  specific Gitksan name, but he knows who her  successor was.  All right.  :  No, I don't.  Do you know if Wilmer Johnson has ever been up to  the Red Creek territory?  No, he hasn't.  Now, in some of the material that I've read there  was a story about certain battles or a war between  the Kisgagaas people and the Fort Graham people who  I believe are called Ts'ets'aut.  Have you ever  heard that story?  Yes.  Now, my understanding is that it was a war over a  certain territory; is that right?  Mh'm.  And I may not have this right, but I also understand  that the territory included the Ingenika River; is  that right?  Yeah.  That's the area that they were fighting over?  Mh'm.  And I understand that the dispute was over who had  the right to trap groundhogs in that area; is that  correct?  Yeah.  Now, do you know when that war or this dispute took  place?  No, I don't.  It's way back, too far back.  All right.  Well — 22  A.   Sampson   (for  Plaintiffs)  Cross-exam by Mr.   Frey  1  A  2  Q  3  4  A  5  Q  6  7  A  8  Q  9  10  11  12  A  13  Q  14  15  16  A  17  Q  18  19  20  A  21  MR.  FREY:  22  23  24  MR.  GRANT:  25  26  MR.  FREY:  27  Q  28  29  30  A  31  MR.  FREY:  32  33  34  35  36  37  MR.  GRANT:  38  THE  WITNESS  39  MR.  FREY:  40  Q  41  42  A  43  Q  44  45  46  A  47  Q  But I heard of it.  Is it your understanding that it was say in the  180 0's or was it many hundreds of years ago?  I would say in the 1800's.  All right.  In the version of the story that you've  heard, did the Indians have rifles?  I don't think so.  Now, my understanding is that at one point in this  struggle that the Fort Graham people attacked and  killed a number of Kisgagaas people; is that  correct?  Yes.  And I also understand that it is part of the story  that a young Kisgagaas girl was taken prisoner by  the Fort Graham people?  Yes.  And that she later escaped and went back to the  Kisgagaas people.  What happens from that point on?  Can you tell me the story from that point on?  No, I can't.  Well, then, my -- well, let's put it this way.  I've  heard two versions and neither of them may be right,  but one version —  They both may be right because the war may have gone  on for hundreds of years ago.  That could be.  But one version that I have heard is  that the Kisgagaas people got together an armed  force and that they went —  Oh, from then on you mean?  And when I mean from then on, what I am interested  in is the end of the story.  Maybe we can go back  and cover this.  The end of the story after the  young Kisgagaas girl escaped from the Fort Graham  people and went back to the Kisgagaas people, do you  know what happens after that?  Maybe Miss Howard can translate the question?  :  They went back and avenged the Kisgagaas people.  So they went back and attacked and killed the Fort  Graham people?  Yes.  And as a result of their defeating the Fort Graham  people, did the Kisgagaas people acquire ownership  of the Ingenika River territory?  Yes, they took back what they owned.  All right.  And did they also get back the right to 23  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Mackenzie  1 trap groundhogs there?  2 A   Yes.  3 Q   All right.  Now, do you know who that territory  4 belongs to today? And I'm talking about the  5 Ingenika territory that they were fighting about?  6 A   I forgot the name now.  7 Q   Well, perhaps my question could be more specific.  8 Do you know what Indian nation or Indian group — in  9 your opinion, what Indian nation or Indian group  10 owns that Ingenika territory today?  11 A   Gitksan.  12 Q   And I take it Mrs. Howard's question as translated:  13 Is it owned by Gitksan, is it owned by Ts'ets'aut or  14 is it owned by another person.  Is that how she put  15 the question to you?  16 A   Yes.  17 Q   And you say that it is owned by the Gitksan?  18 A   Yes.  19 Q   Do you know which chief owns that territory, which  20 Gitksan chief?  21 A   No. '  22 MR. FREY:  Those are all the questions that I have.  Thank you.  23 Mr. Mackenzie will probably have some questions for  24 you.  25  26 CROSS-EXAMINATION BY MR. MACKENZIE:  27 Q   Mr. Sampson, you speak about the territory at Red  2 8 Creek in your affidavit, correct? Yes?  29 A   Yes.  3 0 Q   And the last time that you were up there was when  31 you were about 14 years old, about 194 8?  32 A   Mh'm.  33 Q   Did you — in those days were you living at Fort  34 Connelly?  35 A   Oh, yeah.  That's in Bear Lake.  36 Q   Yes.  Did you have a village?  37 A   Yeah.  3 8 Q   Was that the Bear Lake Band?  39 A   Yes.  40 Q   And where was your village located?  41 A   Right at the lake.  42 Q   At the north end of Bear Lake?  43 A   Yes, at Bear Lake.  44 Q   Xsi Tax?  45 A   Yes.  46 Q   And why did you move to Hazelton in 1949?  47 A   The only reason how we can stay up there is from A. Sampson (for Plaintiffs)  Cross-exam by Mr. Mackenzie  1 trapping.  The trapping got so poor that they had a  2 store up there, and pretty soon you can't afford to  3 get the airplane in to pay for stuff and we had to  4 move into town.  5 Q Who ran the store up there?  6 A It's a guy by the name of Carl.  7 Q Did some people also go down to Takla Landing?  8 A Not while I was there.  From Bear Lake?  9 Q Yes.  10 A Yes, some went to Burns Lake.  11 MR. MACKENZIE:  Do you know if anybody stayed there?  12 MR. GRANT: Where?  13 MR. MACKENZIE:  14 Q At Bear Lake.  15 A Yeah, there was two or three families stayed behind.  16 Q Are they still there?  17 A One family, yeah.  18 Q Who would that be?  19 A Patricks.  20 Q Is that Bob Patrick?  21 A Bob Patrick and the Abrahams, I believe.  22 Q Peter Abraham?  23 A Mh'm.  24 Q And up until the time that you were 14, did you stay  25 in the village or what did you do during those years  26 personally?  27 A During the —  28 Q Up to the years that you left, before you left?  29 A I would go out trapping, fishing.  Fishing and  3 0 trapping.  31 Q What did you do before you started going out on the  32 trapline?  33 A What do you mean?  34 MR. MACKENZIE:  How did you pass your time?  35 MR. GRANT: Before he went on the trapline?  36 MR. MACKENZIE:  37 Q Yes.  3 8 A Well,   all we do  is  fishing and trapping.     There was  39 no jobs there.  40 MR. MACKENZIE:  Is it fair to say that the Department of Indian  41 Affairs moved the members of the Bear Lake Band  42 to — away from Bear Lake to assist with medical  43 care and education and jobs?  44 MR. GRANT: I would object.  First of all there is a combination  45 here that the Department of Indian Affairs moved  46 them, something which we have not made a foundation.  47 And, secondly, that the motivation of the 25  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Mackenzie  1 department — I don't know how this is going to  2 determine that, although I think you may get to it.  3 MR. MACKENZIE:  4 Q Do you know if there was an official move by the  5 people?  6 A No, I don't know.  7 Q You were pretty young then?  8 A Yes.  9 Q And you say the first time you went out with your  10 father was when you were 13?  11 A Yeah.  12 Q And where did you  go at  that  time  trapping with your  13 father?  14 A Up the Xsu Wii Ax, the Sustut River.  15 Q And how did you get there?  16 A Snowshoes.  17 Q Do you have an idea generally of the route that you  18 might have taken?  19 A No, we just went through the valleys and mountains.  20 Q Did you go along the Xsi Tax Valley?  21 A Yes, up the right.  22 Q And when you got to Xsu Wii Ax, did you then go  23 right?  Do you remember?  24 A We went down to Bear River and went up the Sustut  25 River.  26 Q And then where did you go, which direction?  27 A We trapped right up the river.  2 8 Q Upstream?  2 9 A Yeah.  3 0 Q How far upstream would you go? Would you have an  31 idea of that?  32 A Oh, about 20 miles I guess.  33 Q Who was the next territory over?  34 A Up above the river?  35 Q Yes.  36 A The Abrahams.  37 Q Were the Abrahams on the north side of the river or  3 8 the south side of the river, the Xsu Wii Ax?  3 9 A I've never been through this.  4 0   MR. GRANT: I think in fairness given the witness in the  41 affidavit says that not all directions are given by  42 him, I think if you are trying to pinpoint that you  43 should make some reference as to facing downstream  44 and which river.  4 5    MR. MACKENZIE:  46 Q If you are on Xsu Wii Ax facing upstream, are the  47 Abrahams on the right bank or the left bank? 26  A. Sampson  Cross-exam  (for Plaintiffs)  by Mr. Mackenzie  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  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  42  43  44  45  46  47  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  Q  A  MR.   GRANT:  MR.  I  don't  know  really.  Where was your father's  territory  or  the  left bank facing upstream?  The left.  Did you ever go as far  No.  I've been through  Did you?  Yeah.  When was   that?  Gee,   I  don't remember,  as the  there.  on the right bank  Sustut Lake?  but I went through there.  Would it be after you moved to Hazelton?  No.  While you were still young?  Yeah.  Well, you are still young now, but before you left  Bear Lake?  Yeah.  Can you recall who you went with?  My dad.  Do you know who owned  It was supposed to be  Where  did —  Sustut Lake  then?  my  grandfather's.  Bob Patrick.  That's where we  went to —  to interrupt  Sustut.  come from?  you.  You went to —  Oh, yes.  Sorry  The head of the  Where did Bob Patrick  From Bear Lake.  Was he born there?  I think so.  Did Bob Patrick own any other territory up there?  Well, I don't know how far his line went to.  Did you ever go — sorry?  About this land Bob Patrick or my grandfather, I am  lake Dam Giist?  Lake, a couple  not sure if it is Bob Patrick's or my grandmother's.  I am not too sure of that.  Who is your grandmother?  Elsie Patrick.  Oh, yes. Did you ever go to the  Yes, that's just miles from Bear  miles.  Do you know who owned that lake?  That's —  You are talking about which house or  about — I just want you to be clear  is registered traplines.  MACKENZIE:  Q   I'm sorry, which person owned it?  are you  because  talking  there 07  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Mackenzie  1 A It is part of our trapline.  2 Q Dam Giist?  3 A Yeah, the creek.  4 Q Did you ever trap there?  5 A No.  6 Q Do you know if your father ever trapped there?  7 A Part ways.  Part of it.  Actually, our line starts  8 just below the lake.  We actually live on there all  9 the time.  10 Q Dam Giist?  11 A Yeah, part of the land on Bear River — part of Bear  12 River our line runs down the river there too.  13 Q So if one were to say that Peter Abraham owned Dam  14 Giist that would be wrong?  15 A Yes.  16 Q Did you know Thomas Abraham?  17 A Yes.  18 Q Is he related to Peter Abraham?  19 A He is uncle.  20 Q If someone were to say Thomas Abraham owned Dam  21 Giist he would be wrong?  22 A Yes.  23 Q Did you ever go to the lake Dam Luu Gidii Sitax?  24 A Oh, yeah, that's our trail to — that's a trail to  25 our trapline.  That's where the line runs up there.  26 Q Where would that be?  Is that up the Bear River  27 from —  2 8 A Yeah.  29 Q — your village?  3 0 A Right.  31 Q If you are going up — if you are going down the  32 Bear River, isn1t it?  33 A Yeah.  34 Q If you are going down the Bear River, which side of  35 the Bear River is it?  36 A The Xsi Tax?  37 Q Yeah, Xsi Tax.  3 8 A Going down would be the right side.  39 Q Did you know Paul Jack?  40 A Yes.  41 Q His name was Saa po'liyaa?  42 A Yes.  43 THE INTERPRETER:  Is that a Gitksan name?  44 MR. MACKENZIE:  Yes, apparently.  4 5   MR. GRANT: Will you say it again?  46 THE INTERPRETER:  Saa po'liyaa.  47 MR. MACKENZIE: A.   Sampson   (for   Plaintiffs)  Cross-exam by Mr.   Mackenzie  1 Q And where did he live?  2 A Now?  3 Q When you knew  him?  4 A He used to live  in Hazelton.  5 Q Did he  ever live  out  there at Bear Lake?  6 A Saa po'liyaa?  7 Q Yes.  8 A He lived there in the same year too in '49.  9 Q Did he have a cabin at Dam Luu Gidii Sitax?  10 A Yes, that's where they fish.  11 Q And a smokehouse?  12 A Yeah.  13 Q I guess everyone fished along the Bear River there?  14 A Yeah, there was about four places all the way down  15 the river there right down — we were the last one  16 close to Wii Naa Guuk.  17 Q Is that getting down towards Xsu Wii Ax?  18 A Yes.  19 MR. MACKENZIE:  Do you know who was the next person over  2 0 downstream from — downstream on the Xsu Wii Ax who  21 had the trapline.  22 MR. GRANT: The registered trapline?  23 MR. MACKENZIE:  24 Q Or the territory downstream from your father's  25 territory?  26 A I think it was Wii Kaax.  27 Q When you are facing downstream, which side is that  2 8 on?  29 A I don't know.  3 0 MR. GRANT: Facing downstream on which?  31 MR. MACKENZIE:  32 Q On Xsu Wii Ax?  33 A I don't really know the boundaries.  34 Q Do you recall meeting — do you recall having a  35 meeting with Neil Sterritt in December 19 82?  36 A About?  37 Q To talk about the territory?  3 8         A I don't remember.  39 MR. MACKENZIE:  Do you recall telling Neil Sterritt that your  40 dad's trapline started at where the Bear River flows  41 into Xsu Wii Ax and went 20 or 3 0 miles upstream on  42 Xsu Wii Ax?  43 MR.   GRANT: His  dad's  hunting  grounds?  44 MR.   MACKENZIE:  45 Q Your dad's hunting ground, sorry?  46 A Yes.  47 MR. MACKENZIE:  Mark that as the next exhibit.  I'm going to 29  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Mackenzie  1 describe it.  This will be Exhibit 1 on this  2 cross-examination.  3 MR. GRANT:  Exhibit 2.  4 MR. MACKENZIE:  I beg your pardon, Exhibit 2.  It is a  5 topographic survey data sheet recorded by Neil  6 Sterritt and the date is December 20, 19 82.  The  7 informant is Abel Sampson.  8  9 (EXHIBIT 2:  Topographic Survey Data Sheet dated  10 December 20, 19 82)  11  12 THE WITNESS:  I don't remember, but it didn't seem that long.  13 MR. MACKENZIE:  14 Q   Did you ever get a chance to go over to Xsu Wii Lax  15 Amaawx?  16 A   Have a chance to what?  17 Q   Did you ever have a chance to go over to that creek?  18 A   No.  19 Q   Did you ever know the English name for that?  2 0 A   The English name?  21 Q   Yes?  22 A   Well, the way that I remember is Xsu Wii Lax  23 Amaawx — I can't explain in English.  24 MR. MACKENZIE:  Well, go right ahead and —  25 THE INTERPRETER:  The name he knows is Xsu Wii Lax Amaawx.  26 MR. MACKENZIE:  27 Q   That's the name that you heard?  28 A   Yes.  29 Q   It is number one under special features Xsu Wii Lax  30 Amaawx.  Can you describe what that feature is that  31 you just mentioned?  Is it a mountain or a river or  32 a stream or something?  33 A   It is a big valley, meadow and creek.  The way I can  34 figure it out — the closest way I can explain what  35 it means by that is it is the valley of the winds,  36 hey.  It is always blowing and it's cold.  37 Q   Did your dad tell you that?  3 8 A   Yeah.  3 9 Q   Did you hear it from someone else?  40 A   Yeah, I heard it from — that's what they said.  It  41 is always blowing, just blowing and cold.  It is a  42 wide open field.  43 Q   Who would have mentioned that to you?  44 A   What do you mean?  4 5 MR. MACKENZIE:  Can you recall who you might have heard that  46 from?  47 MR. GRANT:  He just said. 3C  A. Sampson (for Plaintiffs)  Cross-exam by Mr. Mackenzie  1 THE WITNESS:  From my father.  2 MR. MACKENZIE:  3 Q   Anyone else, can you recall?  4 A   And my mother.  5 MR. MACKENZIE:  Do you recall your father telling you that that  6 was in Wii Kaax's territory?  7 MR. GRANT:  What Xsu Wii Lax Amaawx?  8 MR. MR. MACKENZIE:  9 Q    Yes?  10 A   Yeah.  11 Q   Now, Mr. Sampson, you said that you are a member of  12 Nii Kyap; is that correct? You are a member of the  13 house of Nii Kyap?  14 A   Yes.  15 Q   As a member of the house, do you have the right to  16 use Nii Kyap's territories?  17 A   I would have to ask permission.  18 Q   Who would you ask for permission?  19 A   Nii Kyap.  20 Q   And who would that be?  21 A   Jerry Gunanoot.  22 MR. MACKENZIE:  And can you say as a member of the house of Nii  23 Kyap you would have a claim to compensation for  24 other people using those territories?  25 MR. GRANT:  What other people?  26 MR. MACKENZIE:  White people, alienations, that's what I am  27 talking about.  Let me rephrase the question.  In  2 8 this lawsuit, among other things, the Gitksan people  29              are claiming compensation for alienations and damage  3 0 to their territories.  And my question was as a  31 member of the house of Nii Kyap would you share in  32 the compensation awarded for Nii Kyap's territories?  33 MR. GRANT:  Well, just a moment.  I think what you are asking is  34 ultimately a question of law as you framed it, and I  35 would object to it.  It is not up to this witness or  3 6 anyone to interpret questions of law as to what he  37 is entitled to as the outcome of his lawsuit.  There  3 8 may be a question in this lawsuit you can ask, but I  39 object to that question.  4 0 MR. MACKENZIE:  Okay.  I am going to try and reframe the  41 question because I think as you say we have asked  42 questions along these lines successfully.  As a  43 member of the house of Nii Kyap, do you claim an  44 interest in the Nii Kyap territories?  45 MR. GRANT:  In this lawsuit?  46 MR. MACKENZIE:  In this lawsuit?  47 MR. GRANT:  Maybe that question can be translated. •}1  A.   Sampson   (for  Plaintiffs)  Cross-exam by Mr.   Mackenzie  1 THE WITNESS:  Yes.  2 MR. MACKENZIE:  3 Q   As a member of the house of Nii Kyap, do you know  4 the location of the Nii Kyap territories?  5 A   Not really.  6 Q   Can you say whether you know the location of any of  7 the Nii Kyap territories?  8 A   No.  I haven't been through there.  9 Q   Okay.  Can you say who in the house of Nii Kyap  10 might know about the Nii Kyap territories?  11 A   I would say Jerry Gunanoot.  12 Q   Let me ask you this then.  It is fair to say that  13 talking about Tsabux territories now Wilmer Johnson  14 says that your father Art Sampson was the last  15 person to use the Red Creek territory, right?  16 A    Mh'm.  17 Q   So it's the people who are trapping on the  18 territories who really have the knowledge of the  19 territories?  20 A   Yeah.  21 MR. MACKENZIE:  Now —  22 MR. GRANT:  That question that you just asked?  23 MR. MACKENZIE:   Yes.  24 MR. GRANT:  I presume and you may want to clarify it, but what  2 5 you are asking is you just focused on his father.  26 MR. MACKENZIE:  Yes.  27 MR. GRANT:  And I assume you were asking that question with  2 8 respect to Tsabux territory?  29 MR. MACKENZIE:  Yes, that's correct.  30 MR. GRANT:  And I assume it is with regard to the Tsabux  31 territory who trapped there?  32 MR. MACKENZIE:  33 Q   That's a good point.  34 Would you say the same about the Nii Kyap  3 5 territory, the people who are trapping there would  36 know it best?  37 A   Yeah, it is Jerry Gunanoot.  38 MR. MACKENZIE:  Your chief's name you've told us is Haimadimtxw.  39 Is that a chief's name in Nii Kyap?  40 MR. GRANT:  The house?  41 MR. MACKENZIE:  42 Q   Yes.  43 A   As far as I know, yes.  44 Q   When you were at Bear Lake, did you know William  45 Charlie?  46 A   Yes.  47 Q   And where does he live now? A. Sampson (for Plaintiffs)  Cross-exam by Mr. Mackenzie  1 A Burns Lake.  2 Q Did you know where his traplines are?  3 A No.  4 Q When you were at Bear Lake did you know William  5 French?  6 A I heard of him, but I never seen him.  7 Q Did you know Mary French?  8 A I heard — well, I never seen them.  I heard the  9 name.  10 Q You told us you knew Paul Jack?  11 A Yeah.  12 MR. MACKENZIE:  Where was his trapline?  13 MR. GRANT: Registered?  14 MR. MACKENZIE:  15 Q I'm sorry.  Do you know where Paul Jack's house  16 territory is?  17 A That will be in Nii Kyap's.  18 Q Do you know where his registered trapline was?  19 A It's the head end of the lake, somewhere in there.  20 I haven't been through there.  21 Q Bear Lake?  22 A I never went through there at the head end.  23 Q Did you ever know of Jimmy Johnny?  24 A No.  2 5 Q Or Moisa Johnny?  26 A No.  27 Q Did you know Johnny Teegee?  2 8 A I heard of him.  2 9 Q Did you know Charlotte West?  30 A No.  31 Q Dominic West?  32 A I have heard of them too.  33 Q Did Dominic West live at Bear Lake?  34 A I think he was living in Fort Graham.  35 MR. FREY: Sorry, I missed it.  Where?  36 MR. GRANT: Fort Graham.  37 MR. MACKENZIE:  3 8 Q Do you know where his trapline was?  39 A No.  40 Q I would just like to ask you a couple of questions  41 about your affidavit.  You signed this affidavit  42 which is Exhibit 600 on May 13, 1988?  43 A Mh'm.  44 Q Yes.  And where did you sign it?  In which location  45 did you sign it?  46 A In Hazelton.  47 Q Where in Hazelton did you sign the affidavit? A. Sampson (for Plaintiffs)  Cross-exam by Mr. Mackenzie  1 A At the Gitanmaax office.  2 Q Oh, at the Gitanmaax Band Council office?  3 A No.  Yeah.  4 Q Yes?  5 A Yeah.  6 Q On the reserve?  7 A Yeah.  8 Q Yes.  And did you have a meeting with anyone before  9 that day that you signed the affidavit to discuss  10 it?  11 A Yeah.  12 Q Who did you meet with?  13 A Neil.  14 Q Is that Neil Sterritt?  15 A Yeah.  16 Q Can you tell me when you met with Neil Sterritt?  17 A No, I don't — I don't recall.  18 Q Can you tell me whether it was the same year?  19 A Yeah, same year.  20 Q And can you tell me where you met with Neil?  21 A In his office.  22 Q And is that in the Tribal Council office?  23 A Yeah.  24 Q And did you — what  did you discuss with Neil   during  25 that meeting?  26 A Well, he — he showed me what my dad had — what he  27 had shown him, and just asked me if it was correct.  2 8 I remember that everything was correct.  29 Q Yes.  Because Neil had met with your dad?  30 A Yes.  31 Q Several times?  32 A Yes.  33 Q And Neil showed you the notes that he had made?  34 A Yes.  3 5 Q Yes.  And what happened after that meeting, if  36 anything?  37 A Nothing.  3 8   MR. MACKENZIE:  And is the next event that related to this  39 someone giving you the affidavit? After you met  40 with Neil Sterritt immediately you got the affidavit  41 to sign it?  42 MR. GRANT: You mean at the other meeting?  43 MR. MACKENZIE:  44 Q Yes, let me rephrase the question.  You had the  45 meeting with Neil?  46 A Mh'm.  47 Q And sometime later you went to the Band Council 34  A. Sampson (for Plaintiffs)  Re-exam by Mr. Grant  1 office and signed the affidavit?  2 A Yes.  3 Q And at the Band Council office there was a lawyer  4 there?  5 A I don't know.  6 Q Was there someone there when you signed your name?  7 A Oh, yeah.  I don't remember who.  8 Q It doesn't matter.  Was it a lawyer?  9 A Yeah.  10 Q And without   telling me what he  said,   T take  it you  11 went  in and  signed  the affidavit?  12 A Mh'm.  13 Q Did you read over the affidavit?  14 A Yes.  15 Q Was the affidavit — any part of the affidavit  16 translated to you?  17 A No, I understood it quite well.  18 MR. MACKENZIE:  Thank you very much.  I have no further  19 questions.  20  21 RE-EXAMINATION BY MR. GRANT:  22 Q Is Wilmer Johnson related to Kathleen Wale?  23 A Yes.  24 Q How are they related?  2 5 A I'm not too sure.  26 Q You know they are related?  27 A Yeah.  2 8 Q When you travelled into the Red Creek territory with  29 your father, what time of year did you usually  30 travel up there with your father?  31 A In the early fall right up until February.  32 Q So you would stay there for several months on the  33 territory?  3 4 A Yeah, about a month at that time and come back home.  3 5 Q Okay.  So you would go back and forth?  36 A Yes.  37 Q And you did that first when you were about 13?  38 A Mh'm.  3 9 Q And then you  did  it  the  subsequent year when you  40 were 14?  41 A Yeah.  42 Q Did you do it the year that you were 15?  43 A No.  44 Q So you would go up for — in each year how many  45 times would you go up on the territory .between the  46 fall and February?  47 A We actually go out there all year-round really. 35  A.   Sampson   (for  Plaintiffs)  Re-exam by Mr.   Grant  1 Q   Mh'm.  2 A   In the summer we go up the mountain to hunt  3 groundhog and goats, caribou.  4 Q   So between the time you were 13 and the time that  5 you left Bear Lake, did you spend more time on the  6 territory in those years on the Red Creek territory?  7 Did you spend more time each year on the territory  8 or at the village of Bear Lake?  9 A   Well, the village of Bear Lake is — well, we are  10 down from the river actually.  Actually I was on our  11 territory all the time staying right on there all  12 year-round.  13 Q   Did you know Peter Wilson, the former Haimadimtxw?  14 A   Yes.  15 Q   Did Peter Wilson ever talk to you about this  16 territory up at Kluatantan River?  Did he ever talk  17 to you about why he was there?  18 A   A little bit.  I heard a little bit of it how he got  19 it.  2 0 Q   What did you hear as to how he got it?  21 A   His uncle went up trapping up the Skeena and the  22 Stikine people came down and his uncle got murdered  23 there, killed.  He went back up that way to avenge  24 the death of his uncle.  25 Q   Mh'm.  26 A   But for some reason they didn't want to fight and in  27 return they gave him that part of — in return they  2 8 gave him part of that territory, that's how he got  29 ahold of it.  3 0 Q   And when you say they gave him that territory, was  31 that Gitksan or Stikine that gave him the territory?  32 A   The Stikine gave it to him.  3 3 Q   Do you know when that murder of his uncle occurred  34 in relation — put it this way, was it in Peter's  35 lifetime or before Peter was born?  36 A   Before Peter was born.  37 Q   Did you know the name of his uncle who got killed?  3 8 Do you remember that?  39 A   No.  4 0 Q   If you can't remember that's okay.  41 A    No.  42 Q   Now, Mr. Frey asked you about Peter Abraham and he  43 asked if he was a Babine person and you said yes.  44 A   Now, yeah.  4 5 Q   Okay.  Now, when you say a Babine person, what do  46 you mean?  I mean Mr. Frey used that term, but what  47 did you mean by that reference to Babine person? 3G  A. Sampson (for Plaintiffs)  Re-exam by Mr. Grant  1 A   He is in a different band.  2 Q   That means he is a member of the Babine band?  3 A   Yeah.  4 Q   Do you know if he is a Gitksan person, that is he is  5 a member of a Gitksan house or if he is a Carrier  6 person or a Sekani or a Ts'ets'aut? Maybe Miss  7 Howard can translate that.  8 A   Yeah, I know what he means.  9 Q   Okay.  10 A   I'm not too sure if I can explain it.  I think his  11 father was from Hazelton and his mother was a  12 Ts'ets'aut, so I don't really know.  13 Q   Do you know his father's name?  Do you remember  14 that?  15 A   Michelle Abraham.  16 Q   Do you remember his mother's name?  17 A   No, I don't.  18 Q   You were asked about Peter Abraham's registered  19 trapline and if he ever asked your father to trap on  20 your father's — well, I am unclear whether it was  21 territory or trapline, but let me ask you this.  To  22 your knowledge, did Peter Abraham ever trap on the  23 Tsabux territory at the Red Creek territory?  24 A    No.  25 Q   You were asked by Mr. Frey about the war, the wars  26 between the Ts'ets'aut and the Gitksan with respect  27 to Ingenika.  You asked — Mr. Frey asked you if  2 8 they — which nation ended up with the Ingenika  29 territory and you said with reference to the  3 0 Kisgagaas people they took back what they had owned.  31 Prior to the wars between the Ts'ets'aut and the  32 Gitksan, whose territory was it around Ingenika from  33 the territory that you've been taught? Was it  34 Gitksan or was it Ts'ets'aut?  35 A   It was Gitksan.  36 Q   Did your father's house own part of Dam Giist or all  37 of Dam Giist or none of Dam Giist?  38 A   All of it.  3 9 Q   You were asked by Mr. Mackenzie about fishing on the  40 Bear River and you said there were four places on  41 the Bear River where there were fishing sites, you  42 remember that?  43 A   Mh'm.  44 Q   Were each of those places owned by different chiefs  45 or were they all owned by one — by the same chief?  46 A   It was more like just family.  47 Q   Can you explain what you mean by that by giving an T7  A. Sampson (for Plaintiffs)  Re-exam by Mr. Grant  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  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  42  43  44  45  46  47  house  example?  For example, the site you used, who would  use it? Who else would use it?  A   The whole family.  Q   Okay.  By family here are you referring to the  of Tsabux or to your mom and dad and j ust the  children or the other relatives of the house of  Tsabux?  I just want to be clear what you mean.  A   The whole house, yeah.  THE  MR.  INTERPRETER:  GRANT:  The whole house.  A  Q  A  Q  A  Q  A  MR. GRANT:  Now, Mackenzie asked you about if you were — I  think it was on Xsu Wii Ax if you were facing  downstream and you said who had the territory facing  downstream and you said Wii Kaax.  And then he asked  you about what side it was on, and you said:  I  don't know the boundaries.  When you say you don't  know the boundaries, are you talking about the  boundaries of Wii Kaax's territory or all of the  that you don't know?  Kaax.  Kaax?  boundaries  All of Wii  All of Wii  Yeah.  You were asked  described what  about Xsu Wii Lax Amaawx, and you  it was.  Was that Xsu Wii Lax Amaawx,  was that partly on Tsabux's territory?  Is it partly  on the Red Creek territory?  Yes, it is down the creek.  And whose territory was next to it?  Wii Kaax.  Thank you very much, Mr. Sampson.  (PROCEEDINGS CONCLUDED)  I hereby certify the foregoing to  be a true and accurate transcript  of the proceedings herein to the  best of my skill and ability.  LISA 'FRANKO, '■OFFICIAL REPORTER  UNITED REPORTING SERVICE LTD. 

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