Edward W. Heath was the first witness and said he was a resident of Tacoma and had built the steamer 'Clallam'. He was a shipbuilder by trade, and had been in the business for sixteen years and had had twenty-four years experience. He had been on the coast for five years.
He said he built the 'Clallam' from his own design, subject to the approval of the Pacific Sound Navigation Company. He then detailed the measurements of the vessel, giving full dimensions over keel and gave the size of the timbers used in the construction.
She was built from good, sound fir, free from sap or any defect, and had an oak saddle port, sided 14 inches at top, tapering to 10 inches at bottom and 15 inches deep, kneed with 12 inch knees and thoroughly bolted with one inch iron. The stanchions went down five feet below the main deck, 4 x 6, each of these had a hanging knee under the upper deck. These stanchions were spiked to the frame and were put in before the planking and were planked with 2 x 4, matched, from the main rail to string above with 1 x 4.
The 'Clallam' had ports below the main deck. They had a brass deadlight - an eight inch light, six inches in clear glass. The frame was let in flush with the planking and fastened with heavy brass screws. Witness thought they only had the single glass shutter. The frame snares were not boxed around these lights. They were closed with a double clamp. The deck houses were held down by a three-quarter inch rod every six feet. Main deck houses were fastened to clamps, with two seven-eighths bolts in each beam. There were no bent beams and were supported by beam stanchions. He supplied the boats for the 'Clallam'. The contract called for them, but he allowed the Pacific Sound Navigation Company to look after the fitting of them. The 'Clallam' had two watertight bulkheads, one aft and one just forward of the bunkers. His contract was for $28,000 but there was a little over $2,000 in extras. All his contract called for was the hull and no furnishings or fixtures. Capt. Roberts himself saw the 'Clallam' several times before she was finished. The 'Clallam' had no deadlights less than three feet from the waterline. The 'Clallam' was the fiftieth boat he had built, and outside the 'Albion' which was wrecked, none of them have ever had a mishap.
The deadlights on the 'Clallam' were the heaviest he ever put in. He often improved on the specifications and did so on the 'Clallam'. He had no explanations to offer as to how the 'Clallam' sunk.
She had a natural crook and her deadwork was at least six feet through. She had only about two carloads of freight, and if that had shifted it would never have listed enough to let water through the deadlights. He also felt certain that if the 'Clallam' was raised her hull would be in as perfect condition as when she left the yard.