MR. COUNSELLOR SMIRNOV: No, it is a photograph taken by some Gestapo official, Your Honor, 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, second column of the text, 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 Rovno. I quote:

“The witness Karpuk, 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: The German butchers brought the doomed people to the place of execution, forced them to dig a ditch, 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.’ ”

One can judge how widespread was this infamous and cruel method of mass execution from an excerpt concerning the executions in Maidanek. I quote from a Soviet-Polish communiqué already presented to the Tribunal as Exhibit Number USSR-29 (Document Number USSR-29). The Tribunal will find this on Page 65 of the document book, first column of the text, Paragraph 14. I begin the quotation:

“On 3 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 SS brought the people, stripped naked, to the ditches in groups of 50 or 100 men. They were packed into the bottom of the ditch face down and shot with automatic rifles. Then a new group of people were 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 started in the second half of 1942. But in general, it may be stated that similar methods of shooting were already adopted by the German police detachments in Poland in 1939.

Thanks to the kindness of our British colleagues, I 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 place, which the Tribunal may find on Page 391 of the document book, second volume, Paragraph 2, (Document USSR-342). 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. . . .”