OCR Text |
Show that the incident occurred when 182 the stage of water was low . We recall no evidence that any such alleged depths or ( diffi- diffi ) culties were or would have been encountered at any normal stage of the river . We have referred to the testimony of many witnesses for Defendant who have had occasion , either in boating or in fording , to observe stream ( depths deptlis ) during the low water season between Bluff and the mouth of the San Juan . ( Nbne None ) of them has ever observed such shallow depths as those described by some of ( Complainant's Complainants ) witnesses . K . D . Williams , who was chain man with the government survey party in charge of Mr . Moore in . 1924-5 , ( saw saNv ) no ( sec- sec ) tion of the San Juan River were it was less than ( waist-deep waistdeep ) in the channel , and he saw no difficulty in the boating ( opera opera- opera ) ¬ tions . ( R . 4332 , Vol . 25 . ) ( Complainant's Complainants ) witness Raymond M . Priest , who was with the government survey party ( en- en ) gaged in surveying the Bluff damsite and who had occasion to cross the river back and forth in the course of his work ( be- be ) low Bluff and for a distance of some thirty or forty miles upstream from Bluff to the end of the reservoir site about September , 1914 , says that where he crossed , the stream its average depth was from ( twenty-four twentyfour ) to , ( thirty-six thirtysix ) inches ; that this was its depth at Bluff and that said depth ( "seemed seemed ) uniform throughout the whole stretch of river we worked on ; " that at said time ( "it it ) was probably low water period , or nearly so . " ( R . 1836-8 , Vol . 10 ) . We recall no evidence being introduced tending to rebut ( the -the the ) testimony of ( Defend Defend- Defend ) ( ant's ants ) witnesses that the shallowest place on the , San Juan River is in the immediate vicinity of Bluff . At page 85 of ( Complainant's Complainants ) Exhibit No . 63 , being ( Water-Supply WaterSupply ) Paper 380 , it is stated : ( "The The ) San Juan is a perennial stream . Along its upper course it receives the waters of vigorous ( tribu tribu- tribu ) taries which have their sources in the San Juan and La Plata mountains . Within , the ( 90-mile 90mile ) stretch of winding channel from Bluff to Colorado River it receives no continuous supply of importance , but maintains a depth of 3 to 5 feet even in the dry ( " 19Y ) ( season sea-sou seasou ) . In this connection we invite attention to certain ( un uv ) , contradicted evidence coming in part from the lips of ( Com Com- Com ) ( plainant's plainants ) witnesses Kumen Jones , John Adams , Frank H . Hyde and Jens Nielsen , whose testimony on , this subject is hereinbefore abstracted . |