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?
DR. LATERNSER: I meant the question a little differently. In what part of Leningrad were these buildings—in the south, the north, the southwest, or southeast section? Will you inform me on that?
ORBELI: The Winter Palace and the Hermitage are right in the center of Leningrad on the banks of the Neva, as I have already mentioned before.
DR. LATERNSER: And where is Peterhof?
ORBELI: Peterhof is on the shores of the Gulf of Finland, southwest of the Hermitage, if you consider the Hermitage as the starting point.
DR. LATERNSER: Can you tell me whether near the Hermitage Palace and Winter Palace there are any industries, particularly armament industries?
ORBELI: So far as I know, in the vicinity of the Hermitage, there are no military enterprises. If the question meant the building of the General Staff, that is located on the other side of the Palace Square, and it suffered much less from shelling than the Winter Palace. The General Staff building, which is on the other side of Palace Square was, so far as I know, hit only by two shells.
DR. LATERNSER: Do you know whether there were artillery batteries, perhaps, near the buildings which you mentioned?
ORBELI: On the whole square around the Winter Palace and the Hermitage there was not a single artillery battery, because from the very beginning steps were taken to prevent any unnecessary vibration near the buildings where such precious museum pieces were.
DR. LATERNSER: Did the factories, the armament factories, continue production during the siege?
ORBELI: I do not understand the question. What factories are you talking about—the factories of Leningrad in general?
DR. LATERNSER: The Leningrad armament factories. Did they continue production during the siege?
ORBELI: On the grounds of the Hermitage, the Winter Palace, and in the immediate neighborhood, no military enterprise worked. They were never there and during the blockade no factories were built there. But I know that in Leningrad munitions were being made, and were successfully used.
DR. LATERNSER: I have no further questions.
DR. SERVATIUS: Witness, the Winter Palace is on the Neva River. How far from the Winter Palace is the nearest bridge across the Neva River?
ORBELI: The nearest bridge, the Palace Bridge, is 50 meters from the Palace, at a distance of the breadth of the quay, but, as I have already said, only one shell hit the bridge during the shellings; that is why I am sure that the Winter Palace was deliberately shelled. I cannot admit that while shelling the bridge, only one shell hit the bridge and 30 hit the near-by building. The other bridge, the Stock Exchange Bridge, connecting Vasilievsky Island with the Petrograd side, is on the opposite bank of the Great Neva. Only a few incendiary bombs were dropped from planes on this bridge. The fires which broke out on the Stock Exchange Bridge were extinguished.
DR. SERVATIUS: Witness, those are conclusions that you are drawing. Have you any knowledge whatever of artillery from which you can judge whether the target was the palace or the bridge beside it?
ORBELI: I never was an artillery man, but I suppose that if German artillery was aiming only at the bridge then it could not possibly hit the bridge only once and hit the palace, which is across the way, with 30 shells. Within these limits—I am an artillery man.
DR. SERVATIUS: That is your conviction as a non-artillery man. I have another question. The Neva River was used by the fleet. How far from the Winter Palace were the ships of the Red Fleet?
ORBELI: In that part of the Neva River there were no battleships which were firing or were used for such kind of service. The Neva ships were anchored in another part of the river, far from the Winter Palace.
DR. SERVATIUS: One last question. Were you in Leningrad during the entire period of the siege?
ORBELI: I was in Leningrad from the first day of the war until 31 March 1942. Then I returned to Leningrad when the German troops were driven out of the suburbs of Leningrad and had a chance to inspect Peterhof, Tsarskoye Ssyelo, and Pavlovsk.
DR. SERVATIUS: Thank you. I have no more questions.
THE PRESIDENT: General, do you want to ask the witness any questions in re-examination?
MR. COUNSELLOR RAGINSKY: We have no further questions.
THE PRESIDENT: The witness can retire.
[The witness left the stand.]
STATE COUNSELLOR OF JUSTICE OF THE 3RD CLASS MAJOR GENERAL N. D. ZORYA (Assistant Prosecutor for the U.S.S.R.): May it please Your Honors, I want to begin to submit documentary evidence on the part of the Soviet Prosecution with regard to the employment of compulsory slave labor practiced by the Hitlerite