To prove, for instance, that the shelling of the Winter Palace was premeditated, I could mention that the 30 shells did not hit the Hermitage all at once but during a longer period and that not more than one shell hit it during each shooting.

In Peterhof, besides the damage caused to the Great Palace by fire which completely destroyed this monument, I also saw gold sheetings torn from the roofs of the Great Palace, the dome of Peterhof Cathedral, and the building at the opposite end of this enormous palace. It was obvious that the gold sheetings could not fly off because of the fire alone, but were intentionally torn off.

In Monplaisir, the oldest building of Peterhof, built by Peter the Great, the damage showed also signs of long and gradual ravages, and was not a result of a catastrophe. The precious oak carvings covering the walls were torn off. The ancient Dutch tile stoves, of the time of Peter the Great, disappeared without trace, and temporary, roughly-built stoves were put in their place. The Great Palace, built by Rastrelli in Tsarskoye Ssyelo, shows indubitable traces of intentional destruction. For example, the parquet floors in numerous halls were cut out and carried away, while the building itself was destroyed by fire. In Catherine’s Palace, an auxiliary munition plant was installed, and the precious carved 18th century fireplace was used as a furnace and was rendered absolutely worthless.

Paul’s Palace, which was also destroyed by fire, showed many a sign that the valuable property that once could be found in its halls was carried out before the Palace had been set on fire.

MR. COUNSELLOR RAGINSKY: Tell me, please, you said the Winter Palace as well as the other cultural monuments that you mentioned were intentionally destroyed. Upon what facts do you base that statement?

ORBELI: The fact that the shelling of the Hermitage by artillery fire during the siege was premeditated was quite clear to me and to all my colleagues because damage was caused not casually by artillery shelling during one or two raids, but systematically, during the methodical shelling of the city, which we witnessed for months. The first shells did not hit the Hermitage or the Winter Palace—they passed near by; they were finding the range and after this they would fire in the same direction, with just a little deviation from the straight line. Not more than one or two shells during one particular shelling would actually hit the Palace. Of course, this could not be accidental in character.

MR. COUNSELLOR RAGINSKY: I have no more questions for the witness.

THE PRESIDENT: Do any of the other Prosecuting Counsel want to ask any questions? Do any of the Defense Counsel want to ask any questions?

DR. HANS LATERNSER (Counsel for the General Staff and High Command of the German Armed Forces): Witness, you have just said that through artillery shelling and also through aerial bombs, the Hermitage, the Winter Palace, and also the Peterhof Palace were destroyed. I would be very much interested to know where these buildings are located; that is, as seen from Leningrad.

ORBELI: The Winter Palace and the Hermitage, which stands right next to it, are in the center of Leningrad on the banks of the Neva on the Palace Quay, not far from the Palace Bridge, which during all the shelling, was hit only once. On the other side, facing the Neva, next to the Winter Palace and the Hermitage, there are the Palace Square and Halturin Street. Did I answer your question?