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It is known how mercilessly the German fascist invaders carried out the economic plunder of the Ukrainian population. The destruction and plunder of Ukrainian cultural and historical treasures played no lesser part in the plans of the Hitlerite conspirators, and was carried out with the same savage zeal.

In accordance with their criminal plans for the enslavement of the freedom-loving Ukrainian people, the Hitlerite conspirators endeavoured to annihilate its culture. From the very first days of their invasion of the Ukraine, the Hitlerites, in execution of their criminal designs, embarked upon the systematic destruction of schools, higher educational institutions, scientific establishments, museums, libraries, clubs and theatres.

The historical and cultural treasures in the cities of Kiev, Kharkov, Odessa, in the Stalinsky and Rovensky provinces, and many other larger and smaller cities, were subjected to plunder and destruction.

From the document presented by the Soviet Prosecution as Exhibit USSR 32, containing the sentence pronounced by the Military Tribunal of the 4th Ukrainian Front on 15-18 December, 1943, it is evident that the German fascist armies in Kharkov, in the Province of Kharkov, acting on the direct instructions of Hitler's Government, burnt, plundered and destroyed the material and cultural treasures of the Soviet people. These excerpts, your Honours, you will find on Page 359 in your document book.

I now proceed to the evidence of crimes committed by the Hitlerites in the capital of the Ukrainian Republic - Kiev.

I quote one paragraph of the document presented by the Soviet Prosecution as Exhibit USSR 248. You will find it on Page 363 of your document book; it is an extract from the records of the Extraordinary State Commission, "about the destruction and plunder by the fascist aggressors of Kiev's Psychiatric Hospital". Amongst other destruction they:

" . . . burnt the archives of the Institute, priceless from a scientific point of view, destroyed the magnificent hospital library of 20,000 volumes, plundered the cultural reservation together with a priceless monument of the eleventh century - the famous Kirilovsky Cathedral, situated in the Institute grounds."

"Before the German invasion, Kiev possessed one hundred and fifty secondary and elementary schools. Of this number, seventy-seven schools were used by the Germans as military barracks, nine served as warehouses and workshops, two were occupied by military staffs and eight were turned into stables. During their retreat from Kiev, the German barbarians destroyed one hundred and forty schools."

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" . . . On 5th September, 1943, the Germans burnt and blew up one of the most ancient centres of Ukrainian culture - the 'T. G. Shevtchenko' State University in Kiev, founded in 634.

In the fire perished the greatest of cultural treasures which for centuries had represented the scientific and educational foundations on which the work of the university was built, and the priceless documents from the Historical Archives of Ancient Manuscripts. The library containing over 1,300,000 books perished, and with it the Zoological Museum of the University, with over 2 million exhibits, together with a whole series of other museums....

. . . The German occupants also destroyed other institutions of higher education in Kiev; they burned and looted the majority of the medical institutions.

In Kiev the fascist barbarians burned down the building of the Red Army Dramatic Theatre, the Theatrical Institute, the Academy for Music, where the instruments were burned together with the very valuable library and all the equipment; they burned down, with its entire equipment, the 'Gorki Theatre for Juvenile Audiences'; they destroyed the Jewish Theatre....

In the Museum of Western European and Eastern Art only some large canvases were left; the robbers had not had time to remove them from the high walls of the stairway shafts. From the Museum of Russian Art the Hitlerites carried off, together with all the other exhibits, a collection of Russian icons of inestimable value. They looted the Museum of Ukrainian Art until only 1,900 exhibits of the National Art section of this museum were left of the original 41,000."

"The Hitlerites plundered the 'T. G. Shevtchenko' Museum and the historical Museum. They looted the greatest monument to the Slav peoples - the Cathedral of St. Sophia - from which they removed fourteen twelfth century frescoes."

"By order of the German Command the troops plundered, blew up and destroyed a very ancient cultural monument - the Kievo-Pecherskaya Abbey.

The 'Uspenski Cathedral', built in 1075-89 by the ruling Grand Duke, Svyatoslav, with murals painted in 1897 by the famous painter V. V. Vereshchiagin, was blown up by the Germans on 3 November, 1941."

"We cannot gaze without sorrow," states Nicholas, Metropolitan of Kiev and Galicia, and member of the Extraordinary State Commission, "on the heaps of rubble of the Uspenski Cathedral, created in the eleventh century by the genius of its immortal builders. The explosions formed several huge craters in the area surrounding the Cathedral, and - beholding them - it would appear that the very earth had shuddered at the sight of the atrocities committed by those who no longer had a right to be called human beings. It was as if a terrible hurricane had passed over the Abbey, overturning everything, throwing down and destroying the mighty building of the Cathedral. For over two years Kiev lay shackled in the German chains. Hitler's executioners brought death to Kiev, together with ruin, famine and executions. In time all this will pass from the near present to the far distant past, but never will the people of Russia and the Ukraine, or honest men all the world over, forget these crimes."

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The first, document 035-PS, is entitled:

"A brief report on security measures of the Chief Labour Group in the Ukraine during the withdrawal of the Armed Forces."

It was presented to the Tribunal by our American colleagues on 18 December, 1945. A characteristic peculiarity of this document is that it undisguisedly testifies to the looting. It is quite clear to all that reference is made to a gang of robbers, although the Hitlerites still persist in referring to robbery as work. They shipped the most valuable exhibits of the Ukrainian Museum to Germany as " Miscellaneous Textiles".

The report begins with the description of the creation of a safe little corner for the "Einsatzstab" establishments, a purpose for which the inhabitants of an entire district were thrown out of their quarters. There then follows, in this document, a list of booty removed from the plundered museums of Kharkov and Kiev, from archives and even from private libraries.

I shall quote one brief excerpt only from this document, dealing with the contents of the Ukrainian and the Prehistorical Museum of Kiev. You will find this excerpt on Page 368 of the document book. I quote:-

"1. The 1 October, 1943, Materials of the Ukrainian Museum in Kiev.

On the basis of the general evacuation orders of the City Commissioner, the following were sorted out by us and loaded for shipment to Cracow:

Miscellaneous Textiles.

Collections of valuable embroidery patterns.

Collections of brocades.

Numerous wooden utensils, etc.

The major part of the Prehistorical Museum was carried away."

"2. The removal of Cultural property.

A great deal of material from museums, archives, institutions and other cultural establishments was systematically removed from Kiev in the autumn of 1943.

These actions to safeguard the material were carried out by Special Purpose Staff RR, as well as by the individual directors of institutes, etc., at the instigation of the Reich Commissar."

"At first, a great deal of the evacuated property was taken only to the areas of the rear: later on, this material was forwarded to the Reich, When the undersigned, towards the end of September, received the mission from the Cultural Division of the Reich Commissar to take out of Kiev the remaining cultural effects the most valuable materials, from a cultural point of view, had already been removed. During October some forty carloads of cultural effects were shipped to the Reich.

In this case it was chiefly a question of valuables which belonged to the scientific institutions of the National Research Centre of the Ukraine. These institutions are at present continuing their work in the Reich and are being directed in such a manner that at any given moment they can be brought back

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to the Ukraine. The cultural valuables which could not be promptly safeguarded were plundered. In this case, however, it was always a question of less valuable material, as the essential assets had already been systematically removed in accordance with orders received.

In October, 1943, factories, workshops, plants and other equipment were removed from Kiev by the order of the military Commander of the town, but where it was taken, I do not know." (This letter ends with the following sentence):- "At the time the Soviets entered the city there was nothing valuable, in this respect, left in the city."

"The German Military Command plundered the museums of Odessa, carrying away hundreds of unique objects,"

"According to a plan, drawn up in advance, the German fascist conspirators blew up or burned 2,290 of the largest buildings of architectural, artistic and historical value. Among these were the house of A. S. Pushkin ... the Sabansky barracks, built in 1827, and others, representing in themselves valuable monuments to the material culture of the beginning of the nineteenth century.

In Odessa the German and Roumanian invaders destroyed: The first hospital for contagious diseases, the second district hospital, the sanatological hospital, the psychiatric hospital, and two children's hospitals, a children's polyclinic, seven infant consulting centres, fifty-five day nurseries, two maternity homes, one dispensary, one leprosarium, six polyclinics and the following research institutions: for the study of tuberculosis, for studying conditions in spas and others. They destroyed twenty-nine sanatoria located around Odessa."

I omit the rest of this page and pass to Page 68 of the report. The report of the Extraordinary State Commission, presented by the Soviet Prosecution as Exhibit USSR 2, gives an enormous number of facts. I shall not quote all of those, your Honours, but I shall confine myself to several excerpts only from the above-mentioned document, which have not yet been read into the record by my colleagues.

They can be found on Pages 374 and 375 in your document book. I quote:

"During their retreat from Stalino, the Hitlerites completely destroyed . . . one hundred and thirteen schools, sixty-two kindergartens, three hundred and ninety shops, the Winter and Summer Theatres, the Palace of the Pioneers seating 1,100 persons, the Radio-Theatre, the Museum of the Revolution, the Picture Gallery and the Dzerjinsky Club of the City.

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Special detachments of engineers went from school to school, pouring incendiary liquid over them and setting them on fire. Those Soviet people who tried to extinguish the fires were immediately shot by the fascist scoundrels.... Exceptionally severe damage was caused by the invaders to the medical establishments of the city."

"The Medical Institute, a model scientific establishment for 2,000 students, was destroyed on the orders of 'Oberfeldarzt' Roll, Chief Medical Officer of Belindorf, and Chief Medical Officer of Kuchendorf.

Of a total of 600,000 books on science and art, 530,000 volumes were burned by the Hitlerites."

I shall not enumerate all the cities. These facts were mentioned in a document which, according to Article 21 of the Charter, provides irrefutable evidence. In agreement with the rulings of the Tribunal, this document will not be read into the record in full. I must, however, draw your attention to the fact that in the Province of Stalino, the Hitlerites burned down schools, theatres, day nurseries, hospitals and even churches. Thus in the town of Gorlovka "they destroyed thirty-two schools, attended by some 21,649 children, burned down the town hospital, five polyclinics, a church and the Palace of Culture".

In the city of Konstantinovka "The Occupational Authorities blew up and burned down all the twenty-five city schools, two cinemas, the principal city library with 35,000 volumes, the Pioneers' Club, the children's technical centre, the city hospital and the day nurseries".

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