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MARSHAL: May it please the Court: The Defendant Fritzsche will be absent until further notice on account of illness.

MR. COUNSELLOR RAGINSKY: May it please Your Honors, may I begin the submission of evidence to prove the charge that the defendants are guilty of the destruction of towns and villages and of the perpetration of other kinds of destruction. This charge is laid down in Section C of Count Three of the Indictment.

We shall present evidence proving that the destruction of cities and towns was brought about neither by the hazards of war nor by military expediencies. We shall submit evidence that this deliberate destruction was carried out in accordance with the thoroughly elaborated plans of the Hitlerite Government and orders of the German military command; that the destruction of towns and cities, of industry and transportation was an integral part of the conspiracy which aimed at enslaving the peoples of Europe and other countries, and establishing a world hegemony of Hitlerite Germany.

Wherever the German fascist invaders appeared, they brought death and destruction. In the flames of the fires were lost the most valuable machines devised by the genius of mankind; factories and dwellings giving work and shelter to millions were blown up. People themselves perished, especially old men, women, and children, left without a roof over their heads or any means of existence.

With particular ruthlessness the Hitlerites annihilated and destroyed the towns and cities in the territories of the Soviet Union which they temporarily occupied, where, acting on direct orders of the German High Command, they created a desert zone.

As proof, I read into the record an excerpt from the document which had been submitted to the Tribunal as Exhibit Number USSR-51(2) (Document Number USSR-51(2)). This excerpt the Members of the Tribunal will find on Page 3 of the document book. I quote:

“An order recently seized near the town of Verkhovye, Orel region, issued to the 512th German Infantry Regiment and signed by Colonel Schittnig, stated with unparalleled brazenness:

“ ‘A zone which, in view of the circumstances, is to be evacuated, upon withdrawal of the troops should present a desert zone. In order to carry out a complete destruction, all the houses shall be burned. To this end they should first be filled with straw, particularly stone houses. Structures of stone are to be blown up, particularly cellars. Measures for the creation of desert zones . . . are to be prepared beforehand and carried out ruthlessly and in their entirety.’ ”

So runs the order to the 512th German Infantry Regiment.

“In razing our towns and villages, the German command demands of its troops that a desert zone be created in all Soviet localities from which the invaders are successfully expelled by the Red Army.”

This order to the 512th Regiment, which is mentioned in the document I just quoted, is submitted as Exhibit Number USSR-168 (Document Number USSR-168).

THE PRESIDENT: Do you know the date of it?

MR. COUNSELLOR RAGINSKY: The date of this order is 10 December 1941. From this document it is clear that the German military command underwrote a ruthless and complete destruction of inhabited localities and that this destruction was planned and prepared in advance.

A large number of documents and facts concerning this question are in the possession of the Soviet Prosecution. I shall limit myself to reading into the record an excerpt from the verdict of the regional military court in the case of the German war criminals Lieutenant General Bernhardt and Major General Hamann. I submit this verdict to the Tribunal as Exhibit Number USSR-90 (Document Number USSR-90).

The military court established that the generals, Bernhardt and Hamann, had acted in accordance with the common plans and directives of the High Command of the German Army and that they—I quote a short excerpt from the verdict which Your Honors will find on Pages 24 and 25 of the document book:

“. . . had carried out a planned destruction of towns and inhabited localities, determined in advance, along with the destruction of industrial buildings, hospitals, sanatoria, educational institutions, museums, and other cultural educational institutions, as well as dwellings. The latter were blown up without any previous warning to the Soviet citizens living in them, with the result that people as well perished.”

As in the case of the destruction of inhabited localities, plants, and factories, power-stations and mines were also destroyed with premeditation.

For confirmation I shall draw the attention of the Tribunal to the report of the Extraordinary State Commission of the Soviet Union which was submitted to the Tribunal as Exhibit Number USSR-2 (Document Number USSR-2). This document is on Page 28 of the document book.

In this report is quoted the secret directive of the leader of the department of economics (Wirtschaftsoffizier) of Army Group South of 2 September 1943, under Number 1/313/43, which ordered army leaders and leaders of the economics detachments to carry out a thorough annihilation of industrial institutions, emphasizing particularly that “. . . the destruction must be carried out not at the last moment when the troops may be engaged in combat or in retreat, but ahead of time.”

The note by V. M. Molotov, the People’s Commissar for Foreign Affairs of the U.S.S.R. of 27 April 1942, deals with the orders of the German Supreme Command and with the manner in which these orders were executed. This note was submitted to the Tribunal as Exhibit Number USSR-51(3) (Document Number USSR-51(3)).

I shall now quote several excerpts from Part II of the note just mentioned, which is entitled, “The Devastation of Cities and Towns,” excerpts which were not read into the record before. These excerpts will be found on Pages 6, the reverse side, and 7 of the document book which is in the hands of the Tribunal. I read:

“By direct order of its High Command the German fascist Army has subjected Soviet towns and villages to unparalleled devastation upon seizure and in the course of the army’s occupation.”

I omit the end of Page 4 and the beginning of Page 5 of my report.

THE PRESIDENT: I do not think you ought to omit the first four lines of Page 5.

MR. COUNSELLOR RAGINSKY: I omitted it inasmuch as I read this document into the record yesterday, but if the Tribunal wishes—I shall gladly do it.

THE PRESIDENT: If you read it yesterday, do not read it again. I do not remember. Was it read yesterday?

MR. COUNSELLOR RAGINSKY: Yes, I read this into the record yesterday.

THE PRESIDENT: Very well.

I am told that—and I think—that you did not read those lines “from 10 October 1941” at the top of Page 5. I think you had better read them. I am referring to the order of 10 October 1941, which is set out in your exposé.

MR. COUNSELLOR RAGINSKY: This is the excerpt from the order given to the 6th German Army, on 10 October 1941, signed by Von Reichenau. This document is presented to the Tribunal as Exhibit Number USSR-12 (Document Number USSR-12). I quote:

“The troops have an interest in extinguishing fires only inasmuch as military quarters have to be conserved. Otherwise the disappearance . . . also of buildings, is within the limits of the fight of extermination.

“At the end of 1941 and the beginning of 1942 the German command issued a number of orders instructing German army units to destroy, in the course of their retreat under the pressure of the Red Army, everything that had remained unscathed during the occupation. Thousands of villages and hamlets, whole city blocks, and even entire cities are reduced to ashes, blown up, or razed to the ground by the retreating German fascist army. The organized destruction of Soviet towns and villages has become a special branch of the criminal activity of the German invaders on Soviet territory; special instructions and detailed orders of the German command are devoted to methods of devastating Soviet populated centers; special detachments, trained in this criminal profession, are set up for this purpose. Here are some of the many facts which are at the disposal of the Soviet Government:”

Once again I refer to the order addressed to the 512th Infantry Regiment already presented to the Tribunal as Exhibit Number USSR-168 (Document Number USSR-168).

“This order . . . is an exposition, consisting of seven typed pages of the most precisely detailed plan for the methodical destruction of village after village, from 10 December to 14 December inclusive, in the regiment’s area. This order, which follows a model used throughout the German Army, states:

“ ‘Preparations for the destruction of populated centers must be carried out in such a way that:

“ ‘(a) No suspicions whatever be aroused among the civilian population prior to its announcement;

“ ‘(b) The destruction should begin and be carried out in a single blow at the appointed time. On the day in question particularly strict watch must be kept to see that no civilians leave this place, especially after the destruction has been announced.’

“An order of the commander of the 98th German Infantry Division, dated 24 December 1941, after listing 16 Soviet villages designated to be burned down, states:

“ ‘Available stocks of hay, straw, foodstuffs, et cetera, are to be burned. All the stoves in dwelling houses are to be wrecked by placing hand grenades in them, thus making further use of them impossible. This order under no circumstances is to fall into the hands of the enemy.’ ”

The following order of 3 January 1942, issued by Hitler, is of the same nature. The order states:

“ ‘Cling to every populated center; do not retreat a single step; defend yourself to the last soldier, to the last grenade. That is the requirement of the present moment. Every point occupied by us must be turned into a base, which must not be surrendered under any circumstances, even if outflanked by the enemy. If, however, the given point must be abandoned on superior orders, it is imperative that everything be razed to the ground, the stoves blown up. . . .

“ ‘(Signed): Adolf Hitler.’

“Hitler felt no embarrassment about publicly admitting that the devastation of Soviet towns and villages was carried out by his Army. In his speech. . .”

THE PRESIDENT: That order of 3 January 1942, signed by Hitler, is that in the official Soviet State report? Where did it come from?

MR. COUNSELLOR RAGINSKY: This order is incorporated in the note of People’s Commissar for Foreign Affairs Molotov. I quote an excerpt from it, a document which was presented to the Tribunal as Exhibit Number USSR-51(3).

THE PRESIDENT: That is Mr. Molotov’s report?

MR. COUNSELLOR RAGINSKY: Yes, this is a note of the Foreign Commissar, Molotov.

THE PRESIDENT: All right.

MR. COUNSELLOR RAGINSKY: “. . . In his speech of 30 January 1942, Hitler stated:

“ ‘In those places where the Russians have succeeded in making a break-through and where they thought that they would once again be in possession of populated centers, these populated centers no longer exist; they are but a heap of ruins.’ ”

While retreating from the Kuban under the thrust of the Red Army, the German High Command worked out a detailed plan of operations which bore the code name of “Movement Krimhild,” and a considerable part of this plan, a whole section, in fact, is devoted to the demolition plan. I omit one paragraph of my report.

This plan is mentioned in a two-page secret document transmitted by telegraph to the chiefs of the higher staffs. The document is signed by Hitler and has the following heading on the first page: “Top secret (A) 2371; 17 copies.” The document which we submit to the Tribunal as Exhibit Number USSR-115 is the 17th copy of the Hitler order. This document is listed as Document Number C-177; in your document book it is contained on Pages 31 to 33. I shall read into the record the second point of this document:

“2. Demolitions in case of retreat.

“(a) All structures, quartering facilities, roads, constructions, dams, et cetera, which may be useful to the adversary have to be thoroughly destroyed.

“(b) All railroads and field railways are to be either removed or completely destroyed.

“(c) All constructed corduroy roads must be torn up and rendered useless.

“(d) All oil wells in the Kuban bridgehead must be entirely destroyed.

“(e) The harbor of Novorossiysk will be so demolished and obstructed as to render it useless to the Russian fleet for a long time.

“(f) Extensive sowing of mines, delayed-action mines, et cetera, also come under the heading of destruction.

“(g) The enemy must take over a completely useless, uninhabitable desert land where mine detonation will occur for months hence.”

Many other documents bear witness of similar orders, but I want to draw the attention of the Tribunal to just two of them. I refer to an entry in the diary of the Defendant Frank which dealt with this subject in particular, as well as a directive issued by the commanding general of 118th German Jäger Division which operated in Yugoslavia.

In Frank’s diary, which has already been submitted to the Tribunal, there is the following entry for 17 April 1944, contained in the volume which was started on 1 March 1944 and ended on 31 May 1944, entitled, “The Business Meeting at Kraków on 12 April 1944.” Your Honors will find the quotation on Page 45 of the document book. I read:

“It is important that the troops be given an order to leave only scorched earth to the Russians. In cases when it becomes necessary to withdraw from a certain area, no distinction should be made between the territory of the Government General and any other territory.”

May I remind the Tribunal that according to Exhibit Number USSR-132 (Document Number USSR-132), which is a secret instruction issued to the 118th German Jäger Division with the signature of Major General Kübler and was captured in June 1944 by units of the Yugoslav People’s Liberation Army, the troops were to treat the population “ruthlessly with cruel firmness” and to destroy the inhabited localities which were abandoned.

May it please Your Honors, in concluding this part of my report I deem it necessary to draw your attention to another circumstance. The destruction of peaceful towns and villages was not only planned, not only carried out deliberately and with exceptional ruthlessness, but was executed by special detachments created by the German High Command for that very purpose. By way of evidence I shall quote several excerpts not yet read into the record from official Soviet Government documents.

In the note of 27 April 1942 is stated—I quote an excerpt which is on Page 9 of your document book:

“The special detachments set up by the German Command for the purpose of setting fire to Soviet populated centers and for the mass extermination of the civilian population during the retreat of the Hitlerite Army, are perpetrating their sanguinary deeds with the cold-bloodedness of professional criminals. Thus, for instance before their retreat from the village of Bolshekrepinskaya, Rostov region, the Germans sent down the streets of the village special flame-throwing machines which burned 1,167 buildings, one after the other. The large, flourishing village was turned into flaming bonfires which consumed the dwellings, the hospital, the school, and various other public buildings. At the same time machine gunners, without any warning, shot at inhabitants who approached their burning houses; some of the residents were bound, sprayed with gasoline and thrown into the burning buildings.”

I omit part of Page 9 of my report and pass on to the next, to the last paragraph on that page of my report. The report of the Extraordinary State Commission of the Soviet Union which was presented to the Tribunal as Exhibit Number USSR-46 (Document Number USSR-46) states:

“In their insane fury against the Soviet people, which was caused by defeats suffered at the front, the commanding general of the 2d German Panzer Army, General Schmidt, and the commander of the Orel administrative region and military commander of that city, Major General Hamann, had created special demolition commandos for the destruction of towns, villages, and collective farms of the Orel region. These commandos, plunderers, and arsonists destroyed everything in the path of their retreat. They destroyed cultural monuments and works of art of the Russian people, burned down cities, towns, and villages.”

In the document submitted to the Tribunal as Exhibit Number USSR-279 (Document Number USSR-279), the following facts are described—I read:

“In Viazma and Gjatsk, the commanding generals—Major General Merker of the 35th Infantry Division, Major General Schäfer of the 252d Infantry Division, and Major General Roppert of the 7th Infantry Division—organized special incendiary and demolition commandos to set on fire and blow up dwellings, schools, theaters, clubs, museums, libraries, hospitals, churches, stores, and industrial plants, so that only ashes and ruins would be left in the wake of their retreat.”

In the document which is presented to the Tribunal as Exhibit Number USSR-2 (Document Number USSR-2) there are several depositions of German prisoners of war. I shall quote one of these depositions. I read at the end of the page:

“Herman Verholtz, a private first class, from the 597th Infantry Regiment of the 306th Division of the German Army, deposes as follows:

“ ‘As a member of a demolition squad I took part in setting fire to and blowing up government buildings and dwellings on First Line, the main street of Stalino. My job was to place the explosives, which I then ignited and thus blew up the buildings. Altogether I participated in the demolition of five large houses and in the burning of several others.’ ”

Your Honors, one could go on with the same kind of quotations. I repeat that scores of them are contained in the documents and depositions which we presented to the Tribunal, but I consider that there is no necessity to do that. What has already been read into the record permits us to conclude that the premeditated and deliberate devastations which were carried out by the Hitlerites in the occupied territories were really a system and not individual acts, and that those devastations were not perpetrated only at the hand of individual officers and soldiers of the German Army, but that these devastations were carried out on the orders of the German Supreme Command. Therefore, I omit Page 11 of my report, and I begin with Page 12.

In the criminal plans of the fascist conspirators, the devastation of the capitals of the Soviet Union, Yugoslavia, and Poland occupied a particular place. Among these plans the destruction of Moscow and Leningrad received special attention.

Intoxicated by the first military successes, the Hitlerites elaborated insane plans for the destruction of the greatest cultural and industrial centers dear to the Soviet people. For this purpose they prepared special task forces. They even hurried to advertise their “decision” to refuse the capitulation of the cities which never even took place.

It is necessary to note that such expressions as “raze to the ground” or “wipe from the face of the earth” were used quite frequently by the Hitlerite conspirators. These were not only threats but criminal acts as well. As we shall see from the subsequent presentation, in some places they did succeed in razing flourishing towns and villages to the ground.

I omit one paragraph of my report.

I shall now present two documents which reveal the intentions of the Hitlerite conspirators.

The first document is a secret directive of the naval staff, numbered I-a 1601/41, dated 22 September 1941. It is entitled, “The Future of the City of Petersburg.” (Document Number C-124, Exhibit Number USSR-113). Therefore, as we are in possession of the original of this document, which was distributed in several copies, I believe that it does not have to be read into the record. With your permission, Mr. President, I shall remind the Tribunal of the contents of this directive. In this directive it is stated, “The Führer has decided to wipe the city of Petersburg from the face of the earth,” that it is planned to blockade the city securely, to subject it to artillery bombardment of all calibers, and by means of constant bombing from the air to raze Leningrad to the ground. It is also decreed in the order that should there be a request for capitulation, such request should be turned down by the Germans. Finally, it is stated in this document that this directive emanates not only from the naval staff, but also from the OKW.

I omit Page 13 of my report and begin with the last paragraph of the page.

The second document, bearing the number Document C-123, presented to the Court as Exhibit Number USSR-114, is also a top secret order of the Supreme Command of the Armed Forces, dated 7 October 1941, Number 44/1675/41, and signed by the Defendant Jodl. This document, Your Honors, is to be found on Pages 69 and 70 in the document book. I read into the record the text of this document, or rather a few excerpts from this letter on Page 14 of my presentation. I read the first paragraph of the letter:

“The Führer has again decided that a capitulation of Leningrad or, later, of Moscow is not to be accepted even if it is offered by the enemy.”

And further the last but one paragraph of this page:

“Therefore, no German soldier is to enter these cities. By our fire we must force all who try to leave the city through our lines to turn back. The exodus of the population through the smaller, unguarded gaps toward the interior of Russia is only to be welcomed. Before the cities are taken, they are to be weakened by artillery fire and air attacks, and their population should be caused to flee.

“We cannot take the responsibility of endangering our soldiers’ lives in order to save Russian cities from fire, nor that of feeding the population of these cities at the expense of the German homeland. . . .

“All commanding officers shall be informed of this will of the Führer.”

The Hitlerite conspirators began to put their criminal ideas about the destruction of Leningrad into effect with unprecedented ferocity. In the report of the Leningrad city commission for the investigation of the atrocities of the German fascist invaders, the monstrous crimes of the Hitlerites are described in detail.

This document had been presented to the Court as Exhibit Number USSR-85. I shall read into the record only a general summary of the data presented on Page 1 of the report, which is on Page 71 of the document book. I read:

“As a result of the barbarous activities of the German fascist invaders in Leningrad and its suburbs, 8,961 household and annexed buildings, sheds, baths, et cetera, with a total volume of 5,192,427 cubic meters were completely destroyed, and 5,869 buildings with a total volume of 14,308,288 cubic meters were partially destroyed. Completely destroyed were 20,627 dwellings, with a total volume of 25,429,780 cubic meters, and 8,788 buildings, with a total volume of 10,081,035 cubic meters were partially demolished. Six buildings dedicated to religious cults were completely, and 66 such buildings partially, destroyed. The Hitlerites destroyed, ruined, and damaged various kinds of institutions valued at more than 718 million rubles, as well as more than 1,043 million rubles’ worth of industrial equipment and agricultural machinery and implements.”

This document establishes that the Hitlerites bombed and shelled, methodically and according to plan, day and night, streets, dwelling houses, theaters, museums, hospitals, kindergartens, military hospitals, schools, institutes, and streetcars, and ruined most valuable monuments of culture and art. Many thousands of bombs and shells hammered the historical buildings of Leningrad, and at its quays, gardens, and parks.

I omit the end of Page 16.

In conclusion, I shall permit myself to quote one of the many German depositions which are quoted in the document, namely paragraph 4 on Page 14. Your Honors will find this deposition I am quoting on Page 84 of the document book. I quote:

“Sergeant Fritz Köpke, commanding Number 2 gun of the 2d battery of the 2d Detachment of the 910th Artillery Regiment stated:

“ ‘For the bombardment of Leningrad, there was in the batteries a special stock of munitions supplied over and above the limit to an unlimited amount. . . .

“ ‘All the gun crews know that the bombardments of Leningrad were aimed at ruining the town and annihilating its civilian population. They therefore regarded with irony the bulletins of the German Supreme Command which spoke of shelling the “military objectives” of Leningrad.’ ”

The Hitlerite conspirators aimed at the complete destruction of the Yugoslav capital, Belgrade.

I remind you of Document Number 1746-PS, presented to the Tribunal on 7 December 1945; it is an order by Hitler, dated 27 March 1941, dealing with the attack on Yugoslavia. It is known that this order, entitled “Instruction Number 25,” gives in detail the military strategy for the attack and, besides, decrees that all the Yugoslav Air Force ground installations and the city of Belgrade shall be destroyed by means of continuous day and night air raids.

I omit the first paragraph of Page 18 of my report, inasmuch as the facts which are mentioned in this paragraph have been read into the record on 11 February. I shall read a few excerpts from Pages 22 and 23 of the official report of the Yugoslav Government. This corresponds to Pages 111 and 112 in your document book. I read:

“The planned and systematic execution of these crimes, based on the orders of the Government of the Reich and of the OKW, is confirmed by the fact that the destruction of inhabited localities and of the population did not cease even at the time of the retreat of the German troops from Yugoslavia.

“Typical for thousands of such cases is the destruction of Belgrade and extermination of its citizens in October 1944.

“The fights for the liberation of Belgrade lasted from 15 to 20 October 1944. Even before the fighting started, the Germans prepared a plan for the systematic destruction of the city. They sent into the city a large number of specially trained units whose duties consisted of mining houses and killing the population. Though, because of the swift advance of the Red Army and of the Yugoslav National Liberation Forces, they failed to carry out their task as ordered by the German commanders, they succeeded in destroying a large number of houses in the southern part of the city and in killing a considerable number of its inhabitants.

“To a still greater extent, this happened in the northern part of the city, on the Rivers Sava and Danube. The Germans went from house to house, herded the inhabitants, unclothed and unshod, into the streets, sprayed inflammable chemical explosives into every apartment, and set fire to all the buildings. If a house happened to be made of a very solid material, they mined it. They fired at the inhabitants, killing defenseless people; in several large houses the inhabitants were locked in, and were destroyed by fire and by mine explosions. The entire damage thus caused in the city of Belgrade totals the sum of 1,127,129,069 dinars at prewar value.”

Thus, the destruction of Belgrade was prescribed by Hitler’s order of 27 March 1941 and was carried out on direct orders of the Defendant Göring; in October 1944 it was carried out by the same methods as those employed by the Hitlerites in the occupied territories of the U.S.S.R.

I shall now present evidence of the intentional and unexampled destruction by the Hitlerites of the capital of the Polish nation, Warsaw.

I shall quote three documents which reveal the criminal intentions of the fascist conspirators to raze this city. As the first document, Exhibit Number USSR-128 (Document Number USSR-128), I present to the Tribunal a telegram Number 13265, addressed to the Defendant Frank, and signed by the Governor of the Warsaw District, Dr. Fischer. This document can be found on Page 148 of the document book. I read into the record the text of this telegram: