No. 15 Original, Brief for the United States, 1929

Brief for the U.S., 1929, p. 214

"914 ( Bock Rock ) found no data showing ( movement movenieut ) of ( com- com ) ( merce inerce ) ( 011 on ) the ( Arkansas Arkausas ) above the ( moiitli mouth ) of the Grand as recorded in the ( commercial coniluercial ) statistics and never ( knew Iniew ) of any practical use of the Arkansas for ( navigation nlIvigation ) purposes ( a"bove above above ) ( tlie the ) ( month mouth ) of the ( Grand Graud ) , which was ( considered cousidered ) as the head of naviga ¬ tion by ( steamboat steauiboat ) operators ( generally geuerilly ) and by ( prac- prac ) tically all of the ( Government Governmeut ) engineers and ( assist- assist ) ants ( mth -Nvith Nvith ) - ( whom Nrliolii ) ( he lie ) came in contact . ( Witness Al"itness Alitness ) at no ( time tinie ) came in contact with any records of any commerce above the ( mouth inouth ) of the Grand although he had heard and knew that one or two boats had in times past gone up there , but there was no ( com- com ) merce ( 011 oil ) the river . It could not be practically used for ( commerce coinnierce ) . ( He 1Ie ) stated that by practical navigation is ( meant naeant ) the navigation that can be ( re- re ) lied upon to justify or cause its use in the ( trans- trans ) portation of products . E divuwd Houston , steamboat man , stated that he was ( engaged eiigaged ) since 1853 in that business between the mouth of the ( Arkansas Arkausas ) and Ft . Gibson . ( He EIe ) stated that ( sometimes soineffines ) the river was not navigable between Little Rock and Pine ( Bluff BluK ) . In earlier days he stated that they did ( navigate utivigate ) it ( longer loiiger ) ( with -with with ) ( certain certzlin ) types of boats . The steamboats used in the early days drew ( from froin ) 9 to 19-1 2" and the keel boats drew only 3" . David D . ( Chapman Chapnian ) . ( Witness A1,71tuess A171tuess ) testified that up to 7 years ago ( he lie ) had operated on the river for a ( pe- pe ) riod covering about 40 years . He ( remembers renienibers ) the steamboat ( "Atint Atint "Annt Annt ) ( Sdllie Sallie ) . " Stated that while he was captain he ( took tools ) a trip to Arkansas City , , Kansas . It took 15 days going and 12 days getting ) back . Some difficulty was ( encountered elicouutered ) on the ( re- re )