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They will hear one counsel on either side, that is to say, one counsel for the prosecution and one counsel for the defence, for fifteen minutes each, and after that open session the Tribunal will adjourn into closed session upon procedural matters.

COLONEL POKROVSKY: Yesterday, in the course of my representation, I referred to four photographs in our possession, two of which were submitted to the Tribunal there and then. I must apologize that yesterday, for technical reasons, we were unable to produce the remaining two at the proper time. The first of these photographs shows the distribution of food to the prisoners; the second - hungry Soviet prisoners searching for, and eating, oil cakes intended as cattle food. I now submit the originals of these two photographs as Exhibits USSR 358 and 359.

An autopsy of the exhumed bodies, performed during the investigation of fascist crimes in the so-called "Lazarett," at Slavuta, confirms that:-

"The Command Headquarters and the Stalag guards repeatedly resorted to refined forms of torture. Amongst the bodies exhumed on which autopsies were performed, the medico-forensic examination established that the corpses of four prisoners of war, murdered with cold steel, had received bayonet wounds penetrating the cavity of the skull."

The Hitlerites compelled sick and wounded prisoners, despite their extreme weakness and acute state of exhaustion, to carry out work which was entirely beyond their strength. The prisoners had to carry heavy burdens, were forced to shoulder the bodies of murdered Soviet citizens and carry them out of the Stalag. Exhausted prisoners who fell by the way were shot out of hand. The road to and from work, according to a report of the Roman Catholic priest at Slavuta, was marked, as by milestones, with small grave mounds. The fascist fanatics did not always have the patience to wait for the actual death of one or another prisoner of war, and they buried persons who were still alive. I quote from a document which I have previously submitted to the Tribunal. You will find this quotation once again on Page 153 of your Document Book:-

"As a result of the discovery of a 'considerable quantity of grains of sand' in the lower respiratory tracts of the corpses of four prisoners, grains which penetrated right down to the very smallest bronchial tube, and which could not have penetrated thus far unless propelled by the respiratory movements of persons smothered by sand, the medico-forensic experts found that at the 'Grosslazarett' the guards at Command Headquarters had buried the Soviet citizens alive. This was done with the connivance of the German doctors."

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The town of Slavuta lies in the Shepetov district. On 15th January, 1942, the District Commissioner of Shepetov, Dr. Worbs, issued a special order to the effect that if those directly responsible for helping escaped prisoners were not found, ten hostages would be shot in every case. Father Zhukovsky reported that 26 peace loving citizens were arrested and shot for helping prisoners of war.

A medical examination of the 525 prisoners liberated from the "Grosslazarett" revealed that 435 suffered from extreme inanition, 59 from complications following untended, infected wounds, and that 31 suffered from neuropsychiatric disturbances.

I quote (with the permission of the Tribunal) the last and the penultimate paragraphs of the left column on Page 5 of our document. In your file this quotation is on Page 154 of the document book:-

"During the 2 years of Slavuta's occupation, the Hitlerites, with the connivance of the German doctors Borbe, Schturp and other medical personnel in the 'Grosslazarett,' exterminated about 150,000 Red Army officers and men."

In other graves, layers of earth were placed between several rows of corpses. For instance, ten bodies were found in Grave No. 625. When a layer of earth, ten centimeters thick, had been removed, two further rows of corpses were found in the same grave; the same occurred at the excavation of Graves Nos. 627 and 628.

Numerous graves were camouflaged by flower-beds, trees, plants, paths, etc., but no disguise can ever hide the bloody crimes committed by the Hitlerite evil-doers.

If I am not mistaken, there was a case when one of the participants in these trials, evidently forgetting where he was and under what circumstances, expressed a wish to follow the procedure laid down by German law. The Tribunal immediately made the necessary inquiries, and the intention of operating in accordance with the standards of German law was, of course, promptly rejected. At present I am fully able to submit to the Tribunal documents which, in my opinion, are of importance in our case, although they are compiled in complete accordance with the rules laid down by German law.

Among the numerous documents found in the police archives of the town of Djitomir, Red Army troops seized a certain piece of correspondence. This is a police inquiry. The authors of this document could not foretell that it would be read into the record at a session of the International Tribunal for the punishment of the major war criminals.

The documents constituting this correspondence were intended exclusively for the chiefs of police, and they were compiled in accordance with all the customary requirements of German law and of the police investigations of fascist Germany.

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At the same time this correspondence is useful to us. So much has been said in the comparatively small number of pages that I should have to analyse the documentation section by section in order that you could appreciate it fully and from every angle. I submit this correspondence to you both in the German photostats and in the Russian translation. I repeat - this is a police inquiry. The document is submitted to the Tribunal as Exhibit USSR 311, and we have, in accordance with the wishes of the Tribunal, asked for the original copy, which we may possibly receive from Moscow this very day.

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