The Nizkor Project: Remembering the Holocaust (Shoah)

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                                                  [Page 109]


THE PRESIDENT: I have an announcement to make.

The defence motion for a recess cannot be granted. When a
recess at Christmas was decided upon, the Tribunal informed
the defence counsel that no further recess would be granted.

As counsel for the prosecution has pointed out, defence
counsel have already had several months in which to prepare
their defences to a case which depends principally upon
documents in the German language, written by the defendants
themselves or their associates. They have also had constant
assistance from the Tribunal and the prosecution in
connection with documentary evidence and witnesses.

The Tribunal has observed that many of the defence counsel
have already found it possible, quite properly, to absent
themselves from Court, and the Tribunal sees no reason why
some of the time which must elapse for the conclusion of the
case for the prosecution should not be utilised in
preparation of their defence out of Court.

The Tribunal therefore decides that, after the conclusion of
the prosecution's case against the individual defendants,
the argument on the groups or organisations alleged to be
criminal shall take place, and that thereafter applications
for documents and witnesses by those defendants whose
witnesses and documents have not already been decided upon
shall be heard in open session. In this way several days
will be occupied in which many of the defence counsel can be
absent from court and can prepare their defences out of

That is all. You may continue, Colonel.

COLONEL SMIRNOV: Your Honour, you asked me yesterday who, in
January, 1942, was the Chief of the Armament and Ordnance
Department of the German Army. I could not answer yesterday,
but to-day I can report to you that General of the Infantry
Thomas held this position.

As to the second question which you put to me, that is, what
measures were taken in regard to the correspondence
connected with the report of Major Roesler, I requested
information from Moscow, where this correspondence is kept.
There are only excerpts from this correspondence in the
archives there. The rest of the correspondence is in another
archive. We requested information from this archive and as
soon as the latest disposition of this correspondence is
ascertained, I will immediately report to the Tribunal. This
will take about a day or two.

Before continuing my statement, I wish to remark that to-day
I should conclude the presentation of all the evidence
concerned with my statement. I have to submit a considerable
number of documents, and therefore my statement will be
rather fragmentary. I will not dwell on particulars and will
try not to repeat what has already been said by the
prosecutors of other countries. This will render my
statement somewhat piecemeal, for which I must beg your

I will now proceed with my statement.

The medico-forensic experts' report drawn up in the city of
Smolensk has already been submitted to the Tribunal as
Exhibit USSR 48. It was signed by a member of the
Extraordinary State Commission, President of the Medical
Academy and eminent Soviet physician, Academician Burdenko,
by the principal medico-forensic expert of the Ministry of
Health, Dr. Prozorovsky, and other experts. In addition to
the final conclusions which have already been presented by
my colleague, Colonel Pokrovsky, I now submit to the
Tribunal the actual

                                                  [Page 110]

record of these experts' investigation. From this the
Tribunal will be able to judge, not only the final
conclusion but also the methods used for this investigation.
The Tribunal can see for itself the detailed description of
each burial ground investigated by experts, as well as the
detailed examination of the corpses exhumed from the
ditches. I will not repeat those parts of the account which
have already been partially quoted by Colonel Pokrovsky.
Therefore I omit four pages of my statement and pass on to
Page 213. The part which I wish to quote now, your Honours
will find on Page 377 of the document book, volume 2,
paragraph 2 of the page. The experts describe a typical
scene of a burial site of victims of German terror in 1941
and the beginning of 1942. I quote:-

  "The ditches from which the corpses were exhumed were not
  common burial grounds. The corpses were not laid out in a
  row nor one next to the other, but layer upon layer, a
  solid mass of women's and men's bodies heaped together in
  confusion. In this mass of corpses some were bent or half
  bent, some were lying on their faces, on their sides, or
  on their backs, some were on their knees, with faces down
  or up, with legs and arms interlinked. It was impossible
  to separate the corpses before, they were exhumed from
  the ditch."

However, this chaotic manner of burial of the corpses
appears to characterise only the mass burials of victims of
the first mass shootings which were carried out toward the
end of 1941 and the beginning of 1942.

During subsequent exhumations the medico-forensic experts
discovered very many burial grounds where the corpses were
laid down in orderly fashion, layer on layer.

A typical scene of such a burial ground the Tribunal can
find in the album regarding the Lvov Camp. On Page 15 of
this album there is a picture of a burial ground of the
later period. The bodies are lying in regular layers, and
this can be explained by . . .

THE PRESIDENT: Which album is this?

COLONEL SMIRNOV: It is the album which concerns the Lvov
Camp, your Honour. It was submitted to the Tribunal
yesterday. The picture I am talking about is on Page 15 of
the album. It is a photograph which was discovered in the
Gestapo headquarters at Lvov.

The reason that caused this regular disposition of bodies
will become clear to the Tribunal from an excerpt of the
Extraordinary State Commission's report on atrocities.

THE PRESIDENT: Is this a photograph of the bodies as they
lay in the trench or after they had been moved?

COLONEL SMIRNOV: No, it is a photograph taken by some
Gestapo official, your Honour, and was discovered in the
archives of the Lvov Gestapo. If you will look at this
picture, you will see that the corpses are lying almost in
regular rows on the spot of this mass shooting.

What was the reason for this regular laying out of the
corpses? The Tribunal will find the answer to this on Page
290 of the document book, paragraph 8. This is a report of
the Extraordinary State Commission on Atrocities committed
by the German fascist invaders in the City and Region of

  "The witness Kapuk, a worker on a German farm near
  Belaya. Street, testified:
  Several times I saw how the Hitlerites exterminated
  Soviet citizens, Ukrainians, Russians, Poles and Jews.
  This took place usually in, the following manner:

                                                  [Page 111]

  The German butchers brought the doomed people to the
  place of execution, forced them to dig a ditch, and
  ordered them to undress and to lie down in the ditch,
  face downward. The Hitlerites fired at the back of the
  necks of the victims with automatic pistols. Then another
  group of people lay down on top of the bodies of those
  shot and were finished off in the same manner, and then a
  third row, and so on until the ditch was filled. Then
  they poured quicklime over the corpses and covered them
  with earth".

How widespread this infamous and cruel method of mass
execution was can be judged from an excerpt concerning the
executions in Maidanek. I quote from a Soviet-Polish
communique, already presented to the Tribunal as Exhibit
USSR 29. The Tribunal will find this on Page 65 of the
document book, paragraph 14:-

  "On 3rd November, 1943, 18,400 people were shot in the
  camp. 8,400 came from the camp itself, and 10,000 were
  herded there from the city and other camps."

I omit the next sentence.

  "The shootings started early in the morning and ceased
  late in the evening. The S.S. brought the people,
  stripped naked, to the ditches in groups of fifty or one
  hundred. They were packed into the bottom of the ditch
  face down and shot with automatic rifles. Then a new
  group of people was piled on the corpses and shot in the
  same manner; and so on until the pits were full".

I especially concerned myself with determining the exact
date when this method was used for the first time. According
to Soviet documents this was in the second half of 1942. But
in general, it may be stated that similar methods of
shooting were adopted by the German police detachments in
Poland, in 1939.

Thanks to the kindness of our British colleagues, I am able
to submit to the Tribunal a document which was received by
our delegation from the British prosecution. It is a
photostat of the document - the original is in the archives
of the British Delegation and I think I am safe in saying
that if the Tribunal requires the original copy, it can be
presented. The authenticity of the information which is
contained in this correspondence cannot be questioned. It is
a German report taken from the archives of Hitler's aide de
camp. I quote one passage, which the Tribunal may find on
Page 391 of the document book, Volume II, paragraph 2. The
German staff doctors considered it necessary to report to
Hitler about these shootings because "since these shootings
were done publicly, enemy propaganda may derive much
material ...."

From this correspondence I quote a short excerpt from the
record of Corporal Paul Kluge's interrogation. Paul Kluge
belonged to a medical detachment stationed in Shwetz. He had
heard that an execution of Poles would take place on Sunday,
8th October, 1939, in the Jewish cemetery. Out of curiosity
he decided to visit the place of execution. I quote only
that part of his interrogation which describes the manner of
shooting. The Tribunal will find this quotation on Page 393
of the document book, Volume II, paragraph 2.:-

  "We decided that we were the victims of silly rumours and
  were about to go back to our barracks, when suddenly a
  large bus full of women and children drove into the
  cemetery. We returned to the cemetery. Then we saw how a
  party consisting of a woman and three children, aged from
  three to eight years, were led to an open grave about two
  metres wide and eight metres long. The woman was forced
  to descend into this grave and took the youngest child
  with her in her arms. Two men, members of the punitive
  expedition, handed the other two children to her. The
  woman was forced to lie, face down, in the grave and
  beside her three children, in the
                                                  [Page 112]
  same manner, on her left. After that, four men of the
  detachment also climbed down into the grave and aimed
  their guns so that the barrels were about 30 centimetres
  away from the napes of their necks. Thus they shot the
  woman and her three children.
  Then the chief of the detachment called on me to help
  fill in the grave. I obeyed this order and, being quite
  near, I was to see how the next party of women and
  children were shot in the same manner as were the first.
  In all, there were nine or ten groups of women and
  children, all shot in the same way. Four at a time in the
  same grave."

We can therefore see that this method of mass shooting is of
very early origin.

I omit the next page of the report, as it contains the
second of another interrogation with similar information,
and submit to the Tribunal proof of other, even more cruel
methods of mass shootings which the Hitlerite criminals
invented, beginning with 1943 and continuing to the end of
the war.

The Hitlerite criminals, beginning with 1943, began to adopt
different methods to cover the traces of their crimes, in
particular, to burn the bodies. It has been proved by
documents that the Hitlerites compelled their victims, first
to prepare the kindlings, and logs, then to lie down on
these wood piles. Then the first group was shot.

The next party of condemned persons brought logs, laid them
down on the layer of corpses, then lay down themselves on
these logs, and were executed.

I beg your Honours to turn to the album concerning the
Auschwitz camp, where the pictures of another camp, Kloga,
are also included. You will find there a typical example of
this cruel manner of shooting. In order to prove this, I
turn to a document which has already been submitted
previously to the Tribunal as exhibit USSR 39. The excerpt
which I wish to quote is on Page 233 of the document book,
last paragraph:-

I start the quotation:-

  "On the 19th September, 1944, the Germans began the
  liquidation of the Kloga camp. Unterscharfuehrer of the
  camp Schwarze, and the chief of the office,
  Hauptscharfuehrer Max Dalmann, selected three hundred
  people from among the internees, and made them carry
  firewood to a clearing in the woods. Seven hundred other
  men were forced to build pyres. When these pyres were
  ready the German butchers began mass shootings of the
  In the first place, those who carried the wood and built
  up the pyres were shot, and then the remaining victims.
  The shooting was carried out in the following manner: At
  the point of a gun members of the S.D. units forced the
  prisoners to lie down on the platforms of the pyres and
  then they shot them with submachine guns or revolvers.
  The bodies were burned on the pyres."

To save time I omit the next part of the quotation. In order
to prove that the methods in other camps were even more
cruel, but of the same type as the ones described above, I
beg the Tribunal to turn to a document, which has already
been submitted as exhibit USSR 38. It is the report on the
atrocities of the German invaders in the town of Minsk. I
refer to a quotation which the Tribunal will find on Page
215 of the document book, last paragraph.

In the first part of this quotation you will read how, in
order to conceal the traces of their crimes, the German
Hitlerite invaders built near the camp in Maly Trostianets
primitive crematorium installations. I begin my quotation
with that passage of the report which speaks of the
shootings carried out in the immediate neighbourhood of
these primitive crematorium installations. To facilitate the
task of the translators, I inform you that I omit three
pages of the text and I read now from Page 233 of the
Russian text of the speech.

                                                  [Page 113]

I begin the quotation with the testimony of the witness
Savinsky, who stated as follows:

  "Having reached a point ten kilometres from Minsk, near
  the village of Maly Trostianets, the lorry stopped near
  one of the barns. We all understood that we were brought
  here to be shot.... By order of the German butchers the
  interned women were brought out in groups of four from
  the lorry. . . .
  Seeing it was my turn, together with Anna Gobubevich,
  Yulia Semashke and another woman, whose name I did not
  know, I climbed on top of the pile of bodies. Shots were
  heard. I was slightly injured on the head and fell."

I omit the next part of the quotation which described how
this woman saved herself. I quote the last paragraph:

  "The medico-forensic experts discovered bullet wounds in
  the necks of these bodies. In the barn and on the stacks
  of logs the Germans shot and burned 6,500 persons."

I omit the next three pages of the text and next submit to
the Tribunal as proof of the organisation by the German
fascist invaders....

THE PRESIDENT: The translation came through to us that sixty-
three people were killed. The translation in writing is

COLONEL SMIRNOV: The translation in writing is absolutely
correct, Mr. President. For the confirmation of this, one
could turn to the original document - the report of the
Extraordinary State Commission. This was a gross error on
the part of the interpreters.

I omit the following three pages of the statement and will
present evidence of the existence of special places of mass
executions where the number of victims was numbered by
hundreds of thousands of persons, and where the doomed were
brought in not only from the surrounding regions but from
many countries of Europe.

By means of brief excerpts I submit to the Tribunal proof of
the existence of two such centres, which were among the most
infamous: They are the centre of mass executions of Panarai,
eight kilometres from Vilnus, and Fort Number 9, the "Fort
of Death", in Kaunas, which has acquired a particularly grim

I quote a report which has been submitted to the Tribunal,
the Report of the Extraordinary State Commission on the
Atrocities of the Hitlerite Invaders in Lithuania. The
Tribunal will find this quotation on page 294, last
paragraph. For the convenience of the interpreters I inform
you that I am quoting from page 228. I omit the first three
paragraphs, which state that the mass execution place at
Panarai was established in July, 1941, and existed until
June, 1944. I continue the quotation, starting with the
fourth paragraph, which describes how the Hitlerites
attempted to cover up the traces of their crimes in this
place of mass executions.

  "In December, 1943," stated witness Saydel Matvey
  Federevich, " we were forced to exhume and burn the

I omit the next sentence and continue the quotation

  "For this purpose we placed on each pyre about three
  thousand corpses, poured oil over them, placed incendiary
  bombs on four sides, and set it on fire."

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