AtoM
David Conde fonds
International Military Tribunal for the Far East
Trial transcripts
Conde, David W.
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I « . C t f - i \ \ \ 10 OCTOBER 194-6 I N D E X Of WITNESSES Prosecution's Witnesses Page KASAHABA, Yukio 7459 Direct by Colonel Ivanov 7459 Cross by Mr. HANAI 7464 " " Dr. KIYOSE 7477 " " Mr. Furness 7495 » " Mr. OKAMOTO 7498 I N D E X Of EXHIBITS Pros. Def. For In No. No. Description Ident. Evidence 692 Summary of Conversation Between HIEOTA and HARADA 7447 693 Affidavit of KASAHABA, Yukio 7447 694 Proposals made by Japanese General Staff dated 9 Feb 1931 Concerning the Russo-Japanese Fishing Problems 74-57 695 Affidavit of KASAHABA, Yukio (in Japanese language) 7462 I N D E X Of EXHIBITS (cont'd) Pros, Def. For In No. No. Description Ident. Evidence 696 Summary of an Address made to his Excellency HARADA by Lt. Colonel KASAHARA 74-62 7490 697 Affidavit of KASAHARA, Yukio 7462 698 Copy of the Anti-Soviet Strategy Plan of Major KANDA when he was serv- ing in the Special Service Division, Japanese Army, in Harbin 74-64 699 Affidavit of MIYAKE, Mitsuharu, dated 22 Feb 194-6 in Moscow 7501 700 A Cable from Consul-General OHASHI in Harbin to Foreign Minister SHIDEHARA dated 7 Nov 1931 No. 516 (2) 7505 7505 701 Photocopy of Report dated 14 July 1932 of Lt. Colonel KAWARE, Torashiro, the Japanese Military Attache in Moscow 7508 702 "A Message of Lt. Colonel KANDA of 16 July" 7510 703 Affidavit of General USHIROKU, Jun, dated 21 March 1946 7515 I N D E X Of EXHIBITS (cont'd) Pros. Def. For In No. No. Description Ident. Evidence 704 Decision of the Conference of Four Japanese Ministers of 7 Aug 1936 under the title of: "Foreign Policy of the Empire 7523 705 Affidavit cf TOMINAGA, Keoji 7526 706 Table of the Increase of the Strength of the Kwantung Army and of the Japanese Army as a whole from 1932 to 1945 7531 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 IS 1 9 20 21 22 2 3 2 4 2 5 Thursday, 10 October, 1946 INTERNATIONAL MILITARY TRIBUNAL FOR THE FAR EAST Court House of the Tribunal War Ministry Building Tokyo, Japan The Tribunal met, pursuant to adjournment, at 0930. Appearances: For the Tribunal, same as before. For the Prosecution Section, same as before. For the Defense Section, same as before, with the addition of: MICHAEL LEVIN, who is now also Associate Counsel for the Accused KAYA, Okinori. (English to Japanese, Japanese to English, Russian to English and. Japanese to Russian interpretation was made by the Language Section, IMTFE.) 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 4 7 MARSHAL OF THE COURT; The International Military Tribunal for the Tar East is now in session. THE PRESIDENT; Mr. Yamaoka. MR. YAMAOKA: If the Tribunal please, I desire to announce that Mr. Michael Levin, who is already well known to the Tribunal, has filed his appearance as additional associate American counsel for the Accused KAYA, Okinori. THE PRESIDENT: Mr. Iva.nov. COLONEL IVANOV: We present to the Tribunal in evidence prosecution document No. 1990A, with the the affidavit of KASHARA, Yukio attached to it, prosecution document No. 2659. This secret document, a photostat copy of which is being presented, is dated 1931 and contains the summary of the talk between Ambassador HIROTA and Major General HARADA. THE PRESIDENT: Admitted on the visual terms. CLIRK OP THE COURT: Prosecution's document No. 1990A will be given exhibit No. 692. Prosecution docum nt No. 2659 will be given exhibit No. 693. They are bound together, the first three pages thereof being document No. 1990 and the rest of it No. 2659. (Whereupon, the documents above referred to were marked prosecution's exhibits No. 692 and No. 693 > respectively, and received in evidence.) 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 4 8 THE PRESIDENT: Major Blakeney. Q MR. BLAKENEY: May it please the Tribunal, we wish to object to the acceptance of this affidavit unless the witness is presented for cross-examination. He is, I understand, available. THE PRESIDENT : We made it a condition. MR. GOLUNSKY: We did not intend to bring in the witness because his affidavit is confined strictly to identification of the document, but if the Tribunal thinks that the witness should be here we can easily do it. The witness is available. THE FRESIDENT: Other affidavits have been admitted on the condition that the deponent, if avail- able, must be called if the Court so requires, or interrogated if the Court so requires. That condition will obtain here. MR. • v-LUlISKY: Does the Court require us to bring him right now in9 THE PRESIDENT: Not until otherwise directed. COLONEL IVANOV: There is an inscription on the back of the photocopy of this document. MR. HANAI: v'ith respect to document 1990, only a photostat has been tendered as evidence. The original of this document is unknown, hasn't been cleared. 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 4 9 MR. GOLUNSKY: If the Tribunal please, we have not the original document at our disposal, only a photostatic copy, and that is why, before offering it to the Tribunal, we have shown it to the author, KASAHARA, and produced it in evidence before the Tri- bunal only when we had the affidavit of KASAHARA con- firming the authenticity of this document. THE PRESIDENT: You have the author's certi- ficate that he wrote it. Admitted on the usual terms as already stated. COLONEL IVANOV: There is an inscription on the back of the photocopy of this document. This inscription was made by KASAHARA, Yukio, former Japanese military attache in Moscow, in his own hand. I quote the contents: "The. article written in Japanese on the other side of this photograph was recorded by me in my own handwriting, fifteen years ago, in 1931 (Show?, 6) , when Major General HARADA was in Moscow. It contains the gist of the conversations between Ambassador HIROTA and Major General HARADA. I hereby certify the above with my own signature. "September 3, 194-6. KASAHARA, Yukio." If the Tribunal please, I shall draw their special attention to the fact that the defendant HIROTA 1 2 3 - 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 5 0 was at that time the Japanese Ambassador in Moscow. (Exhibit No. 108.) We present this document to prove first that the question of a war of aggression against the U.S.S.R. has already been put on the agenda in 1931 and second that the same HIROTA, who was Prime__ Minister of Japan at the time of the conlusion of the Anti-Comintern Pact, pointed out in 1931 that the main purpose was rather the seizure of the Far East and Siberia than the defense against communism. If the Tribunal please, I shall read the contents of the affidavit of KASAHARA, mentioned by me before. I quote exhibit No. 693= "Affidavit. "I, Lieutenant General Yukio KASAHARA of the Japanese Army, d^ hereby certify under oath as follows: "That the phctsstatic cony of the document in Japanese under the title of Conversation of Ambassador HIROTA and Major General HARADA:' ;is the photographic copy of the record of the outline, of conversation of /mbassador HIROTA and Major General HARADA which took place while the latter was in Moscow in 1931, fifteen years ago. "This record is in my handwriting, written at the request of Major General HARADA. The contents of the document are as follows: 1 2 3 4 5 6 7 r» O 9 10 11 121 4 1 4 15 16 1 7 IS 1 9 20 21 22 2 3 2 4 2 5 7 , 4 5 1 "Concerning the Conversation of Ambassador HIROTA and Major General HARADA." THE PRESIDENT: Mr. Smith. MR. SMITH: If your Honor please, I understood the Russian prosecutor to say the witness was available. I am wondering why they don't put him in the box before they read this affidavit. THE PRESIDENT: This is a delayed application v. by you, Mr. Smith. MR. SMITH: I had been standing at the lectern here for nearly a minute and the Russian prosecutor wouldn't do me the favor of stopping his reading long enough for me to say anything. THE PRESIDFNT: You didn't come to the lectern until some ftcnsiderable time after the docu- ment had been admitted and he had commenced to read. ) MR. SMITH: Well, I understood y-ur Honor hr.s already ruled dn this that he had to call the vriLtness and he didn't do it. I THE PRESIDENT: I made it a condition that the deponent should be called as a witness if required by I the Tribunal. The Tribunal has not yet required him to be called. Cdlonel Ivanov. COLONEL IVANOV: Th contents: 1 2 3 4 5 6 7 O o 9 10 A i a i j\ 1 4 15 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 5 2 "Concerning the conversation of Ambassador HIROTA and Major General HARADA. "In reference to the national policy of x x to be transmitted by Ambassador HIROTA to the Chief of General Staff. "1. Desire the following matters be especially transmitted to the Chief of General Staff. "Aside from whether Japan will wage a war against Soviet Russia, it is necessary for Japan to have strorg policies against Soviet Russia being ready for war at any time. Its principal purpose is not defense against Communism but rather the conquest of Erstern Siberia, "2. x x (words illegible) stated by Ambassador j HIROTA on the disarmament problem. Generally:speaking, more than half of the diplomats of the world are in favor of military disarmament. However, since this refers to the general theory of disarmament, if it becomes clearly known that the military preparations of Japan is for use against Soviet Russia, it is only natural that she cannot reduce her armaments; and the world powers also (the remainder of the sentence was not submitted to me). "In the above mentioned photostatic copy of the record, however, there are two letters each on lines; 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 5 3 15 and 21 of the first page too indistinct to be read. Therefore,marks 'x x' were inserted. "I have no recollection as to the recorded items in the remaining portion which was not presented to me. "I hereby identify this affidavit in my own handwriting and that it is true." Signed: "Ki.SAHARA, Yukio." End of quotation* MR. FURNESS: May it please the Tribunal. THE PRESIDENT: Major Fumess, MR. FURNESS: Defense now makes formal request that this witness be called to be cross-examined on the following grounds: It appears that the entire document was not submitted to him. Second, the source, accord- ing to the certificate, is the Red Prosecution Staff, not any department of the Japanese Government or any other department of the Russian. Third, the original exhibit which has been filed with the Court is almost wholely illegible. Fourth, the translation is apparently from Japanese into Russian and then the Russian trans- lation is translated into English, according to the certificates filed. < THE PRESIDENT: Mr. Smith. MR. SMITH: If the Court please, as counsel 1 2 3 4 5 6 7 S 9 10 1 *r 12 1 3 1 4 1 5 16 1 7 IS 1 9 20 2 1 " 22 2 3 2 4 2 5 7 , 4 5 4 for Mr. HIROTA, we ask that the affiant be produced for cross-examination and, until such time that he is produced, that this affidavit stand struck out by order ; of the Court. THE PRESIDENT: Does the prosecution desire ; I to be heard on this? Minist. r Golunsky. MR. GOLUNSKY: As I have already stated, we did not intend, we did not consider it necessary to put in the witness here because his affidavit was strictly confined to identification of the document. If we were to call him here we certainly would ask him only one question, if he confirms the contents of the document as stated in his affidavit, Under those con- ditions, according to the practice of this Tribunal, the cross-examination should be strictly limited to the question of identification only and it is thought that this would be n waste of time. If the defense want to question him as to the events about which the inscriptinn just read stated, they can put him ^n the stand as their own witness. ' "x THE PRESIDENT: The Tribunal directs that the deponent be called. MR. GOLUNSKY: The witness will be here in several minutes. THE PRESIDENT: In the meantime we can be 1 2 3 4 5 6 7 S 9 10 ! 1 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 14 25 7 , proceeding with other matters. COLONEL IVANOV: We present to the Tribunal for identification prosecution document No. 1753, the proposals made by the Japanese General Staff dated February 9, 1931? concerning Russo-Japanese fishing problems. This document proves that the attitude of the Japanese General Staff was that any pretext should be used for an attack against the U.S.S.R. In 1931? particularly, the General Staff was ready to use the tension in the negotiations of fishing between Japan and the U.S.S.R. for the purpose of intervening by armed forces and starting a war. THE PRESIDENT: We have hoard enough for the time being. You are reading the document, aren't y^u? We have enough for the time being. Major Fumess. MR. FURNESS: Defense objects to the admission of this document in evidence on the ground that the certificate of source shows only thrt it comes from the files of the Red Army Chief Military Prosecution Depart- ment, Moscow. THE PRESIDENT: Well, we will look at it first. It is very hard to decide •~n objection without seeing the document. MR. FURNESS: In that case, no certificate 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 15 16 1 7 18 1 9 2 0 21 22 2 3 2 4 2 5 7 , 4 5 6 would be necessary since all the prosecution would have to do would be to produce it. If they produce it, it proves it comes from them. THE PRESIDENT: A similar objection has already been made against a document tendered by the American Section of the prosecution. "Te held that the certificate of Mr. Danly, 1 think, was not sufficient. This r object4on is sustained. MR. GOLUNSKY: If the Tribunal please, there is a difference between the case the ^resident has mentioned just now and this one. In the American case the certificate came from a department of this prose- cution; in this case the certificate comes from the Chief Military Prosecutor of the Soviet Union, an organization entirely independent from this prosecu- tion, and in my opinion it comes complete under the conditions provided for by Article 13 of the Charter. TEE PRESIDENT: It is still the Russian prosecution, whether it be in Moscow or in Tokyo. I will consult my colleagues. They may take a differ- t view. (Whereupon, the Members of the Tribunal conferred upon the bench). THE PRESIDENT: We think the Russian prosecu- tion should tell us where this document was obtained 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7,4-57 by the Russian Government, and should give us a certifi- cate to that effect. MR. GOLUNSKY: I will undertake to supply the certificate as soon as we can have it. THE PRESIDENT: For the time being the docu- ment is rejected as evidence. We will admit it con- ditionally as we did in the case of the French documents CLERK OF THE COURT: Prosecution's document No. 1753 will receive exhibit No. 694. (Whereupon, the document above referred to was marked prosecution's exhibit No. 694 and received in evidence.) THE PRESIDENT: Colonel Ivanov. COLONEL IVANOV: I shall quote in evidence extracts from Chapter 6, entitled, "Counter-Measures which the Empire should Adopt." I quote page 9 of the English translation, paragraphs 5 rnd 6: "Japan must be convinced of the urgent necessity of considering the reason by which her interests in Russia is authorized, and with the deter- mination to make the unlicensed fishing absolutely safe in the future, firmly and boldly push through her insistence during the negotiations. "Judging from the internal and external state of Soviet Russia, if we showed our determination to 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , obtain unlicensed fishing, they will have no courage to maintain their insistence. However, if we carried out our insistence in spite of Russian resoluteness, by force of circumstances, the result be the severance of diplomatic relationship with Russia, and it will give us the opportunity to promote our sincere desire of executing our basic national policy against Russia.." THE PRESIDENT: It appears on page 9. v — I MR. GOLUNSKY: The witness KASAHARA is in the room, if the Tribunal please. We will call him right now. 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 KASAHARA DIRECT 7 , 4 5 9 Y U K I O K A S A H A R A , called as a witness on behalf of the prosecution, being first duly sworn, testified through Japanese inter- preters as follows? DIRECT EXAMINATION BY COLONEL IVANOV: Q Mr. Witness, tell the Court your full name. A I am KASAHARA, Yukio. Q How old are you? A Fifty-eight. Q What post did you hold in 1931, fifteen years ago? A Military attache, Japanese Embassy, in Soviet Russia. Q I present to you prosecution document 2659, affidavit written bv you in your own hand in the Japanese language. I ask you to consider this docu- ment. Mr. Witness, please tell the Court, did you write and sign this document? A Yes, this was written by me. Q Mr. Witness, please tell the Court, is every- thing stated in your affidavit true? A It is the truth. Q I presented to you a photostat copy of the document 1990-A. Please consider it, Mr. Witness. KA3AHARA DIRECT 7 , 4 6 0 1 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 25 Mr. Witness, tell to this Court, what is this cocument? A '/hen Major General HARADA was on a tour of inspection in Europe and visited Moscow, I brought him to the then Japanese Ambassador in Moscow, Mr. HIROTA, for a courtesy call} and this is an out- line of what Ambassador HIROTA told Major General HARADA at that time, which I wrote and gave to General HARADA. COLONEL IVANOV: If the Tribunal please, I shall present to the witness several documents for identification, which he testified by his own signa- ture previously. Q I present to you prosecution document 2657, affidavit written in the Japanese language. I ask you, Mr. Witness, to consider this document. Did you sign this document, Mr. Witness, and is everything stated in it true and correct? A I wrote it, and everything in it are true. THE PRESIDENT 3 These documents should be tendered for identification, with a short explanation of what they are. COLONEL IVANOVs If the Tribunal please, I ask them to accept in evidence this document, ana I shall read from it certain excerpts. I present KA3AHARA DIRECT 7 , 4 6 1 1 2 17 18 20 21 22 2 3 2 4 25 prosecution document 2657, affidavit of KASAHARA, Yukio. I shall read certain excerpts later on. MR, GOLUNSKY; There was an inexactness in 4 the English, translation. The Colonel said he was 5 offering at this time the document for identification. 6 Q j MR. FURNESS: If the Court please, none of 7 the defense can find the document referred to. 8 THE PRESIDENT: This is for identification 9 only. It cannot be tendered except in accordance io with the rules. If there is any attempt to tender a n document as an exhibit, the defense will have the right 12 to cross-examine first. 13 Q Mr. Witness, I present to you a photostat 14 copy of prosecution document 1990-B. Please look at 15 this document and tell the Court what it is. A This is a copy of some of the things I told Major General HARADA with respect to conditions in Russia at the time I net him when he was passing 19 through Moscow. COLONEL IVANOV: If the Court please, I present document 1990-B for identification. CLERK OF THE COURT: Prosecution document No. 1990-B will receive exhibit No. 696. The previous prosecution document, 2657, which was received for identification only, was given exhibit No. 695. KASAHARA DIRECT 7,4-62 1 2 3 (Whereupon, document No. 2657 was marked prosecution's exhibit No. 695 for iden- tification; and cocume"t No. 1990-B was marked 4 prosecution's exhibit No. 696 for identification.) 5 Q Mr. 7itness, I present to you prosecution 6 document 2652 — correction: 2658, This document 7 is an affidavit written by you. I ask you to consi- 8 der this document and tell the Court whether you 9 signed it. 10 A Yes, this was written by me. 11 Q Is everything written in this affidavit by 12 you correct and true? 13 A It is the truth. 14 COLONEL IVANOV: If the Tribunal please, I 15 present prosecution document 2658, affidavit of KASA- HARA, Yukio, for identification. CLERK OF THE COURT: Prosecution's document No. 2658 will receive exhibit No. 697 for identifica- tion. (Whereupon, document No. 2658 was marked prosecution's exhibit No. 697 for identification.) THE PRESIDENT: Captain Brooks. MR. BROOKS: If the Tribunal please, I wanted to call the attention that the defense do not 16 1 7 18 1 9 20 21 22 2 3 2 4 25 7 , 4 6 3 KASAHARA DIRECT . • . * have the other affidavits of this witness, 2657 and 2658, that are being offered for identification, and we would like to protect ourselves on that and have at least twenty-four hours to study it before we have to cross-examine the man on it. The prosecution will keep that in mind. THE PRESIDENT: They cannot be tendered as exhibits until the rules as to service have been com- plied with. That is all I can say. The tendering of documents for identification is a matter of precaution, and the precautions are not barred by our rules. It has been applied to jail -A sections of the prosecution. BY COLONEL IVANOV (Continuing)- Q Mr. Witness, I present to you a photostatic copy of the prosecution document 2460. Tell me, what is this document? A This is a copy of the Anti-Soviet Strategy Plan which Major KANDA showed me in his private capa- city and which was prepared in his private capacity when he was serving in the Special Service Division, Japanese Army, in Harbin. COLONEL IVANOV: If the Tribunal please, I shall present for identification prosecution document 2460, which is a report made by KANDA, Masatane, KASAHARA CROSS 7 , 4 6 4 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 19 20 21 22 2 3 2 4 25 on military measures against the TJ.S.S.R. THE PRESIDENT : It will be marked for identi- fication. CLERK OF THE COURT: Prosecution's document No. 2460 will receive exhibit No. 698 for identifica- tion. ^hereupon, cocument No. 2460 was marked prosecution's exhibit No. 698 for identification.) COLONEL IVANOV: If the defense has any questions concerning the identification of this docu- ment, they may ask these questions now. THE PRESIDENT: The defense may cross-examine in the usual way. CROSS-EXAMINATION BY MR. HANAI: Q '.'/hat was the mission on which Major HARADA want, I ask the witness? MR. GOLUNSKY: If the Tribunal please, the prosecution objects to this question as being outside the scope of the direct examination. THE PRESIDENT: The Tribunal thinks it arises out of the affidavit. It may be asked. A Major General HARADA's principal mission to Europe was to make a study of military education in 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 6 5 KAS AEIARA GROSE that prrt of the world. He was dispatched to Europe on this mission by the General Education Bureau of the Army. His visit in Moscow had nothing to do with his mission; he merely passed through, and on that occasion visited me, at which time we had private, informal conversations. JAPANESE MONITOR: Office of the Inspector General of Military Training, is the regular term. A (Continuing) Major General HARADA was never attached with either the General Staff or the War Office. He has been wholly connected with military education. Q Then, in other words, in passing through Moscow he just drooped in on you? A Yes. Q And on that occasion you just incidentally took Major- General HARADA there on a courtesy vis^t to Ambassador HIROTA, is that not so? A Ordinarily, the military attache does not present to the ambassador any lower militpry officers. But in the case of general officers, it was general practice and custom for the military attache to trke the general officer to the ambassador to make a crll of courtesy; and I fo^owed that custom. Q Was there any particular purpose in interviewing 1 2 3 4 5 6 7 S 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 25 7 , 4 6 6 KAS AEIARA GROSE the ambassador? A There was no particular purpose outside of making a call of courtesy. Q Then, how long were the conversations which took place? THS FRE3JDENT: That is unnecessary. A I do not remember the length of the conversation bv>t I do not think it was long. Q Were the contents of the conversation exactly as reproduced in the photostatic copy of the document? A No, this is only an outline of the conversation and not a verbatim transcript of the conversation. I cannot say with confidence that it is an exact repro- duction of the conversation. THS PRESIDENT: We will recess now for fifteen minutes. (Whereupon, at 1045, a rocess was taken until 1100, after which the proceedings wore resumed as follows:) 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 IS 1 9 20 21 22 2 3 2 4 2 5 KAS AEIARA GROSE 7 , 4 6 7 MARSHAL OF THE COURT: The International Military Tribunal for the Far East is now resumed. BY MR. HANAI (Continued): Q I should think Major General HARADA presented many questions with regard to the situation in Russia during his visit in Moscow at this conversation; how about It? THE PRESIDENT: That is too general. I understand the IBM is not v/orking. THE MONITOR: The IBM is not working; just a minute, please. A Before Major General HARADA was taken by me on this courtesy call to the Ambassador, I spoke to him generally on the situation in Russia and it was on the basis of the information that I had imparted to him that he asked questions of the Ambassador and the Ambassador made remarks to him. 0 Then, is it not so that you made this docu- ment after making your own selections and analysis of the questions and replies which took place during the conversation?? A "'ill counsel please repeat the question? I was unable to hear all of it.. 0 is it not so that you yourself, Mr. Witness, on the basis of the questions and replies which took KASAHARA CROSS 7 , 4 6 ? Vf 0 1 f & Y e 1 d e n 0 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 25 MARSHAL OF THE COURT: The International Military Tribunal for the Far East is now resumed. BY MR. HANAI (Continued): 0 I should think Major General HARADA presented many questions with regard to the situation in Russia during his visit in Moscow at this conversation; how about it? THE PRESIDENT-: That is too general. I understand the IBM is not working. THE MONITOR: The IBM is not working; just a minute, please. A Before Major General HARADA was taken by A me on this courtesy ca^l to the Ambassador, I spoke to him generally on the situation in Russia and it was on the basis of the information that I had Imparted to him that he asked questions of the Ambassador and the Ambassador made remarks to him. 0 Then, is it not so that you made this docu- ment after making your own selections and analysis of the questions and replies which^ took place during the conversation? A Till counsel please repeat the question? I was unable to hear all of it. I / V 0 Is it not so that you yourself, Mr. 7/itness, jon the basis of the questions and replies which took KASAHARA CROSS 7 , 4 6 8 o 4 i 5 6 7 8 9 I 10 j 11 I 12 1 3 1 4 1 5 16 1 7 18 1 9 20 ?1 JL 22 2 3 2 4 one. place during the conversation, boiled the whole thing down and prepared the document? A Yes, I myself summarized and wrote down the gist of the conversation. It was not submitted to Ambassador HIROTA for inspection. 0 Did you write this document during the course of the conversation or at a later date'̂ A Not during the conversation but after I had returned to my own office by request of Major General HARADA, who asked me to note some of the points in the conversation at the time of his departure- just before his departure. Q You just said, Mr. Witness, that you did not present this document to Ambassador HIROTA for inspec- tion, but did you ask the Ambassador for his approval with respect to the contents or for his views thereto? A "fith respect to this document, I did not show It to the Ambassador nor talk about it to him. However, with respect to Russian questions in general, I have had occasion to exchange views with him. Q On the basis of the conversation, as well as the fact that you wrote notes thereof later on, can you positively say that your own personal views did not enter into this particular document? A As you say, I should think that some of my KAS AEIARA GROSE 7 , 4 6 9 private views also entered into this document at the i 2 3 4 5 6 7 8 9 10 11 12 13 time of Its writing inasmuch as I did not present this document for inspection to the Ambassador. I cannot say positively whether I had expressed the Ambassador's thoughts truthfully and fully. Also, it might have been the case where I might have put a personal twist or interpretation to what Mr. HIROTA said. Because of the fact that there were many pending questions between Russia and Japan at the time and Japanese opinion at home was not very enthusiastic about some of these questions and Japanese opinion happened to be in favor of the disarmament question, it might be that Ambassador HIROTA wanted to draw the General's 1 4 i attention to some of these questions — wanted to 1 5 16 1 7 i IS 1 9 20 21 draw public attention to some of these questions. THE MONITOR: And he might have used certain words purposely to accomplish this. MR. GOLUNSKY: If the Tribunal please, I object to this question because It does not fit to ask the witness what HIROTA might have thought. THE PRESIDENT: He cannot depose as to HIROTA's mere thoughts; that is, thoughts unrevealed to the witness. 25 0 What was HIROTA's diplomatic policy, especially }his policy vis-a-vis the Soviet Union in its practical 22 2 3 74 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 7 0 KAS AEIARA GROSE and realistic aspects. MR. GOLUNSKY: If your Honor please, I object to this question as being too broad and out- side the scope of direct examination. THE PRESIDENT: Objection upheld. MR. HANAI: May I state to you, Mr. President, that this has a direct connection with the document in question. THE PRESIDENT: You may endeavor to do so. I cannot see any connection. I®. HANAI: I find relevancy on this ground: that Ambassador HIROTil was a strong advocate'ttf a non-aggression pact between Japan and the Soviet Union, a strong advocate of a policy of diplomatic cooperation between the two countries, and actually i himself endeavored to carry this policy out. The document in question gives the impression that HIROTA's policy was exactly the opposite and I am trying to disprove this fact. THE PRESIDENT: You may ask questions on all matters dealt with in the memorandum made by the witness. So far we have not had the advantage of hearing what is in that memorandum. Q 'fas not the main question discussed during the conversation between Ambassador HIROTA and Major 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 KAS AEIARA GROSE 7 , 4 7 1 General HARADA with regard to the disarmament question? A I cannot recall exactly but inasmuch as dis- armament was the foremost question, one of the fore- most questions, at that time, I should think from my own imagination that that was the topic of conversation, that was the main topic of conversation. THE PRESIDENT: Before we can effectively deal with any objections that may be raised, we should know what is in the memorandum. MR. GOLUNSKY: If the Tribunal please, this document which is alluded to as a memorandum here has been read by Colonel Ivanov as exhibit 692. THE PRESIDENT: There is a Japanese document in the exhibit, in the affidavit, or annexed to it. I was not sure wheth >r that was read or not and according to the witness that is only a part of the memorandum. We should know what was in the other part, if that is available. The witness may be able to recall what was omitted. THE WITNESS: I don't think that memorandum was in its entirety but I do not know what was omitted — I cannot recall what has been omitted. Q Have you any recollection, Mr. Witness, whether there was any talk about the fact that Soviet armaments were being strengthened at the time? KAS AEIARA GROSE 7 , 4 7 2 A Yes, I spoke of it and so did Ambassador o 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 j 2 4 | 2 5 i HIROTA. THE PRESIDENT; Is the document shown to the witness a fair representation of all that was said at the interview of which he made a record? THE WITNESS: As I have stated in the affidavit, this was merely an outline of the main points of the conversation. It is not a verbatim transcript of the entire conversation. 0 When this photostat was shown to you, Mr. Witness, were you able to read it? Yes, I was able to read it, 0 We ourselves cannot read it. THE PRESIDENT: You must take his answer, A Yes, I was able to read it because it was in my own handwriting and there are certain habits which are clear to me. 0 Mr. Witness, will you be good enough to read it. ('".'hereupon, a document was handed to the witness.) Q (Continuing) Mr. Witness, will you be good enough to read that aloud? MR. GOLUNSKY: If the Tribunal please, I should like that the witness should be handed the same 7,4-73 KASAHARA CROSS l ! 2 3 4 I 5 6 I 7 I 3 9 10 11 12 | 1 3 | 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 25 document he has been reading while he gave his affi- davit and not one of the copies which were distributed to the defense because I do not know how clear this particular copy is. THE PRESIDENT: I understand he is now looking at the copy that was shown to him before he made his affidavit. A (Reading in Japanese.) THE PRESIDENT: That should be put into English. ii "Re the conversation between Ambassador HIROTA and Major General HARADA." Then there are some sections blurred, unreadable, illegible. "And with respect to Japanese policy"— THE PRESIDENT: We want the words the witness used. A (Continuing) "Regarding the conversation between Ambassador HIROTA and Major General HARADA with respect to points to be communicated from Ambas- sador HIROTA to the Chief of the General Staff." Then after that the words are illegible. THE PRESIDENT: Did the witness say the words were illegible? THE MONITOR: Yes, Mr. President, he did. THE WITNESS: I was unable to read it because 1 2 •3 4 5 6 7 8 9 10 11 12 1 3 1 4 15 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 KAS AEIARA GROSE 7 , 4 7 4 the words were not legible and even at that time I struggled very much in order to understand or to find out what those blurred passages meant. 0 Reading by imagination— THE MONITOR: Just a minute. The witness used the word, "that I deciphered or I tried to surmise what it was that I had written," and the defense attorney in this asked him, "By deciphering or by guessing what you wrote, or what you mean —!imagine'?" THE WITNESS: The document, not being clear — legible — there are some places where my imagination has entered in. THE MONITOR: And I imagine that this sentence must be this way, or it must be so. Q There seems to be some difference, Mr. Witness, between the passage you just read and the same passage — supposedly the same passage — in your affidavit. A I should think there would be the possibility of such differences arising from the fact that my imagin- ation has entered into figuring out the blurred passages. Q in the document you just read you said, "from Ambassador HIROTA"; in the affidavit, the word, "from," is missing. In the passage you just read the words, "request for communication," has been. mentioned. In your affidavit, "request" is missing. 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 KAS AEIARA GROSE 7 , 4 7 5 THE PRESIDENT; Now, that is counsel's statement. Does the witness admit that? It may be supported by the record when we make comparisons. THE WITNESS: I confirm that. 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 25 KASAHARA CROSS 7 , Q Where did you put the original of this document? A What do you mean by "original"? Q The document you wrote in your own handwriting. A The document was written with a carbon copy. One copy was given to Major General H a R A D A and the other copy was placed in the vault of the military attache's office in Moscow. Q Is this document still in the deposit since then? A I do not know whether or not this document is still in the vault — in the deposit. I left Moscow in the Spring of 1932, and I do not know whether this document has remained there since then. THE MONITOR; I know that it was there until then. Q Do you know how the photostat of this copy was made .— ohotostat of this document was made? THE PRESIDENT; That is immaterial. A I do not know how it was made. Either it was made from the copy in the hands of Major General HARADA or the cony which I left in the strong box or in the vault of the military attache's office in Moscow, a nhotostat of which was taken by the Soviets without our knowledge. 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 KAS AEIARA GROSE 7 , 4 7 7 0 Ho.v v*ere you able to tell whether this was your own handwriting by looking at the photostat and not the original? A I judged that this was my own by two ooints: one, my own calligraphic habits, and the other, by the contents of the document itself; although I do not remember exactly, at least my recollection is of the general subject matter. Did you, Mr. Witness, remember that such a conversation had taken olace even before you were shown this photostatic copy? A I did not know — I did not recall this con- versation, not even until I was called here as a witness. I recalled it only when I was shown this document. MR. HANAI: That is all, sir. THE PRESIDENT: Dr. KIYOSE. CROSS-EXAMINATION (Continued) BY DR. KIYOSE: 0 There are four more lines, Mr. Witness. I should like to have you read the balance. A The witness says "I don't have the document with me. 11 THE PRESIDENT: Hand it to him. (Whereupon, a document was handed to the 1 2 3 4 5 6 7 S 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 * 2 4 2 5 7,4-78 KASAHARA CROSS witness.) A (Continuing): "With respect to the dis- armament question, HIROTA stated", and then the passage is blurred, "with respect to the disarmament question — over half of the general public and diplomats seem to be in favor of the reduction of armaments. Eut, this being a general argument in favor of disarmament — but, if this is clarified as being mainly -- that Japanese arm: .r.ents are mainly directed towards the Soviet Union, it would be natural that reduction could not be Possible in Japan, and the nowers also"— and that is all. Q It seems to be a little different, Mr. Witness. Wasn't there one more line between what you previously read and what you just read now? A I do not think there was another line. Q Is there not a passage written in very small characters? A The passage written in small characters between the lines is: "With respect to the disarmament question HIROTA", and that is all it is possible to read. "What HIROTA stated", and that is all I could read. There are a few characters after that which are blurred. THE PRESIDENT: He read from the photostatic copy shown to him before he made the affidavit. That 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 KAS AEIARA GROSE 7 , 4 7 9 has already, as I understand, been tendered for identi- fication. It should now be tendered finally by the defense, I take it, if they rely on their cross-examin- ation in that resnect. DR. KIYOSE: Then prosecution document 1990-A is tendered in evidence. THE PRESIDENT: It is tendered for identifica- tion. MR. GOLUNSKY: If the Tribunal please, it has been tendered in evidence. THE PRESIDENT: It is already in evidence. DR. KIYOSE: One more question. Q In the latter part, after the passage you have just read, there is a part missing entirely. Now, are there more passages to follow? THE MONITOR: Slight correction: "The passage that you read -- the last passage that you read, is that complete? Are there more to follow?" A Yes, there are more passages to follow, but this is all that was shown to me. Q How many pages were there in the document which you wrote yourself? A I do not recall how many pages; but I am positive in saying that there is more to follow. Q Did the document you wrote have a meaning as 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 KAS AEIARA GROSE 7 , 4 8 0 a whole, or does each of its parts have a separate meaning? A I do not know just how much would follow, "but I am quite positive in saying that it was not just two or three characters. THE PRESIDENT: Major Furness. MR. FURNESS: The defense requests the pros- ecution to produce the other pages of the original document of which the ohotostat of the first page has already been taken; and which is part of exhibit 692, I understand. We believe that if they have the first page of which they could take a photograph, they also nrobably have the other nages. If not, we would like to know what happened to them. THE PRESIDENT: Colonel Ivanov. MR. GOLUNSKY: If the Tribunal please, this page, this photostat which has been presented to the Tribunal was assured by the Intelligence Service at the time, and that is the only page of which you have the ohotostat. THE PRESIDENT: Read out what Minister Golunsky said, please. (Whereupon, Mr. Golunsky's last statement was read by1the official court reporter.) MR. FURNESS: We would like to get the original, 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7,4-81 KASAHARA CROSS particularly the other pages'., THE PRESIDENT: Are they available? MR. GOLUNSKY: We don't have them at our disposal, and we tried to find the original here in Tokyo and failed. THE PRESIDENT: Did you try in Russia, Minister Golunsky? Did you try in Moscow or elsewhere in Russia? MR. GOLUNSKY: Certainly. In Moscow we tried first. That is the only part of the document which we could have in Moscow. We tried to find in Tokyo the original which General HARADA should have brought here with him and didn't find it. MR. FURNESS: May we ask when the photostat was taken? THE PRESIDENT: No, that is immaterial. We want to know whether the whole original is available or a copy of the whole. That is the point. The time when the photostat was taken does not help us. MR. FURNESS: I thought it would be material, sir, if the photostat was taken recently. THE PRESIDENT: Well, we are not cross-.examining the orosecution at this stage. We want to know the facts first. MR. GOLUNSKY: If the Tribunal please, I draw the attention of the Tribunal that there are two numbered 1 2 3 4 5 6 7 S 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 KASAHARA CROSS 7, paragraphs in the part of the document which we have submitted to the Tribunal. The first numbered para- graph is complete, and that is the one which is impor- tant to us. MR. FURNESS: I thought the witness stated that the first paragraph was not in the document, that he imagined it. j THE WITNESS: What has just been said is not clear to me. THE INTERPRETER: This is statement of the witness. MR. FURNESS: I would also like to know whether General HARADA is available because he might know where the original is. THE PRESIDENT: The Tribunal wants the whole document if it is available. MR. GOLUNSKY: Y.Te tried to find HARADA, but we failed to find him. After the recess I can give the Tribunal definite information as to what happened to him. THE PRESIDENT: In the absence of the whole document the Tribunal may find some difficulty in acting on what has been produced. I do not speak for them all now, but that is a possibility, of course. In the absence of the production of the whole document, 1 2 3 ' 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 KASAHARA CROSS 7 , 4 8 3 we may have to consider also whether HARADA should "be called, if he is available. But so far we have not undertaken to call witnesses. I doubt whether the Charter contemplates that course in any circumstances. MR. FURNESS: It is our understanding, it is the understanding of the defense that the only documents to which this witness has testified are exhibits 692 and 693. It is our further understanding that when the others which have been identified are introduced, we will have further right to cross-examine. On that understanding the defense has no further questions to ask this witness at this time. THE PRESIDENT: A colleague raises the fol- lowing question: whether the witness has read — rather, he says he has the impression that the witness has read parts of the document which are not translated yet. He refers to the passage beginning with "aside" and ending with "Eastern Siberia." MR. GOLUNSKY: If the Tribunal please, the orosecution would like to have the possibility to com- pare the record of what the witness read here in Court with the text he gives in his affidavit. We have not been able to do it yet. THE PRESIDENT: We will adjourn until half-past o n e . 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 8 4 KAS AEIARA GROSE ('"'hereupon, at 1156, a recess was taken.) 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 17 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 8 5 KASAHARA MARSHAL OF THE COURT: The International Military Tribunal for the Far East is now resumed. THE INTERPRETER: Mr. President, just before the noon recess you said that a Member of the Bench called to your attention the fact that the entire passage quoted by the witness from the document had not been translated into English. Shall we make that transla- tion now on the basis of the Japanese stenograph transcript? What is the Court's pleasure? THE PRESIDENT: We want to know what the witness read out as he looked at that document. Can you recall what the witness said as he read it out? THE INTERPRETER: The translation is to be made on the basis »f the shorthand transcript taken in Japanese. THE. PRESIDENT: That is sufficient. THE INTERPRETER: Then we shall proceed? THE PRESIDENT: Yes. THE INTERPRETER: "Regarding the conversation between Ambassador HIROTA and HARADA, request by Ambassador HIROTA for transmission to the Chief of the General Staff." /fter this the passage is blurred and I cannot read. "With regard to national policy: 1. Especially dasirous that this be transmitted to the Chief of the General Staff. Putting aside the 7 , 4 8 6 KASAHARA 1 2 3 4 5 6 7 8 9 10 If 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 25 question of whether or not Japan should make war against the Soviet Union, there is the need to take a strong policy vis-a-vis the Soviet Union with the resolve to fight the U.S.S.R. at any time when necessary. The objective, however, should not be defense against Communism but, rather, the occupation of Far Eastern Siberia. "To Ambassador HIROTA regarding the dis- armament question." At this p^int the President acknowledgedcounsel KIYOSE who appeared at the lectcrn. Is that sufficient, sir9 THE PRESIDENT: Yes, that is sufficient. MR. GOLUNSKY: There will be no redirect examination. THE PRESIDENT; The witness is released on the usual terms. Is there anybody in charge of the witness? Where is Crptain Van Meter? Take him from the box. Mr. Smith. Do you want the witness? MR. SMITH: Yes, I would like him for a moment. If the Tribunal please, there must be an error somewhere. We listened to the English translation as this witness was reading from the document -̂ nd we didn't hear anything that even resembles what was just 7 , 4 8 7 KASAHARA read back from Japanese notes. THE PRESIDENT: I understand that what he said was taken in Japanese and we got the translation of that Japanese. That is all we ever get. MR. SMITH: Well, your Honor, in the interest of fairness, could we have the English read back as : to what this witness said was in this document, that is, what part of it he could make out? THE PRESIDENT: He read that document in Japanese. He read the Japanese in the document and I what he said in Japanese was translated into English. MR. SMITH: Then,'your Honor, the English translation must be incorrect and the transcript of the record would be incorrect. That is what is copied into this record. Well, I am really confused, your Honor. Notwithstanding what my associates say, that evidently something was left out of the English trans- lation. If it was I would like to have it gone back over and make sure of this because it is highly important to my client. THE PRESIDENT: If anything has been left out it should be nut in. Eut I understand that every word the witness used as he read that Japanese docu- ment and he spoke in Japanese has now been translated into English. If that is not the case, I would like 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 1 9 20 21 22 23 24 2 5 KASAHARA 7, the Language Section to soy so. THE INTERPRETER: As far as the Language Section is concerned, Mr. President, the passage which was just read was taken from the Japanese stenographic transcript, a portion of which was not translated into English this morning. THE PRESIDENT: Was: that the only portion not translated into English this morning? THE INTERPRETER: Thr t was the passage es- pecially referred to by the Honorable President this morning. THE PRESIDENT: Crn you tell me whether any other passage remains untranslated? THE INTERPRETER: Yes. With respect to a portion which has not been given a complete transla- tion into English; only a partial translation was given this morning. THE. PRESIDENT: We require nonr a complete translation of that portion. THE INTERPRETER: May we proceed, sir? THE PRESIDENT: Yes. THE INTERPRETER: The Witness: "No. 2. What Embassador HIROTA said with resnect to the dis- armament question and a few words following are illegible and I cannot read them. Continuing quoting: 1 2 3 4 5 6 7 S 9 10 11 12 13 14 15 16 1 7 18 19 20 21 22 23 24 25 7 , 4 8 9 KASAHARA 'Regarding this disarmament question, it seems that more than half of the general public and diplomats are in favor of disarmament but, this being with regard to the disarmament question in general, if it is clarified that Japan's armaments are directed toward the Soviet Union, naturally that armament could not be reduced. The world powers also® — The remainder is blurred and the witness said, 'That is all.'" THE PRESIDENT: Have you now translated all the witness said as he read from that document" THE INTERPRETER: To my knowledge, yes, sir, in isp far as the document is concerned. THE PRESIDENT: Colonel Ivanov. MR* 'DDLUNSKY: . If the Tribunal please, we are now going to Introduce other documents identified by the same witness. Therefore, perhaps we had better keep the witness on the stand while we are introducing them. COLONEL IVANOV: I have already presented to the Tribunal for identification prosecution docu- ment No. 1990S, exhibit No. 696, summary of an address made to His Excellency HARADA by Lieutenent Colonel KAS/.Hi-RA. This document is also dated 1931. On thfe back of the last page of the photo copy, which is also dated 1931, there is an inscription made by 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 9 0 KASAHARA KASAHARA which reads as follows: "The record of this document was taken by me in my own hand September 3, 1946. KASAHARA, Yukio." If the Tribunal please, I shall quote in evidence excerpts from "Summary of an Address made to his Excellency HARADA by Lieutenent Colonel KASAHARA." I quote this document to show aggressive against the U.S.S.R. THE PRESIDENT: Admitted on the usual terms. CLERK OF THE COURT: Prosecution 'document No. 1990S was given for identification exhibit No. 696 and is now admitted according to the orde? of the Court. (Whereupon, prosecution's exhibit No. 696 was received in evidence.) COLONEL IVANOV: I quote this document, to show aggressive designs against the U.S.S.R. "Summary of an Address made to His Excellency HARADii by Lieutenent Colonel KASAHARA." The following is from the secand chapter of the summary of an address under the title of "National Defense of Soviet Russia," I quote page 2 of the English translation: "Soviet Russia at present is not offensive but defensive and is particularly afraid of foreigil invasion." In the third chapter under the title of 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 9 1 KASAHARA "Conclusion" the following is said c meerning the Soviet Union. I quote page 3 of the English text, paragraphs 2 and "At present, however, in view of her national powers in general, it is judged that she h-~s not enough strength to execute a war. "There is never a better time than now for Japan to solve her For East problems. The western neighboring countries (Poland, Rumania) are able to rise now in unison with Japan but as the years pass it will get more and more difficult. If we are deter- mined to solve the Far East problem now even at the risk of waging war, it may be solved without a war, although there is no objection even if by chance a war j s should be waged." I ask the Tribunal to accept in evidence prosecution document Wo. 2657* exhibit No. 695. This is the affidavit of KASAHARA, Yukio. THE PRESIDENT: Major Furness. MR. FURNESS: If the Court please, we didn't — | get this document until this noon. I has not been served on us within — beyond the twenty-four hour limit. THE PRESIDENT: You may see fit not to rest on your rights in view of the short nature of the 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 IS 1 9 20 21 22 2 3 2 4 2 5 7 , 4 9 2 KASAHARA document. I take It you are not pressing your objec- tion. MR. FURNESS: A g3od many of us, sir, haven't got the document at all. Personally, I don't insist on it. THE PRESIDENT: Well, you are the only counsel to take it so far, Major Furness. Proceed. Proceed to describe it. COLONEL IVANOV: (Reading) 1 2 3 4 5 6 7 8 9 10 11 12 13 1 4 15 16 1 7 18 19 20 21 22 2 3 24 25 KASAHARA 7 , 4 9 3 "AFFIDAYTT "I3 Lieutenant-General Yukio KASAHARA, state under oath as follows: "During my service as a military attache to the Japanese Embassy in Soviet Russian from 1930 to 1932, I came to know the following matters through my duties. "1. In 1931, when Major-General HARADA of the Japanese Army passed through MOSCOW on his return trip to Japan from Europe, he had a talk regarding the situation in the Soviet Union and Japan's policy toward Soviet Union with me and Japanese Ambassador HIROTA, "At the time of the conversation between Major- General HARADA and me, my Assistant, Major YAHAOKA was present and at the time of the conversation between Major-General HARADA and Ambassador HIROTA, I was present. "2. The ohotostatic copy of the document in Japanese entitled 'Outline of the Talk to his Excellency, General HARADA' which is now presented to me, is the one in which the matters that I told Major-General HARADA during his stay in MOSCOW in 1931 was correctly recorded, as far as its contents are concerned. I think the matters in oages 1 to 9 of the document are in Assistant Officer Michitake YAHAOKA1s own handwriting. 1 2 3 4 5 6 7 S 9 20 11 12 1 3 14 1 5 16 17 18 19 20 21 22 23 24 2 5 7 , 4 9 4 KASAHARA In order to affirm the said facts, this day I subscribed my signature on the back of the said photogranhic docu- ment and the date on which the document was presented to mo. "3. The photostatic copy of the document in Japanese entitled rMatters concerning the talk between Ambassador HIROTA and Major-General HARADAf is the one in which the outline of the talk between Major-General HARADA and Ambassador HIROTA was recorded, during the former's stay in Moscow fifteen years ago, in other words, 1931. , "This record was made by me at Major-General HARADA's request. "I certified the above fact in my own hand- writing on the back of the taid document." /s/ "KASAHARA, Yukio" 1 2 3 4 5 6 7 8 9 1,0 11 12 1 3 1 4 1 5 16 1 7 18 19 20 21 22 2 3 2 4 2 5 KAS AEIARA GR O SE 7 , 4 9 5 The defense may question the witness in connection with the affidavit I have read and the document I have read before. THE PRESIDENT: Major Fumes, s. CROSS-EXAMINATICM BY MR. FURNESS: Q I call your attention to prosecution docu- ment No, 1990-B which is exhibit No. 696. I call your attention to paragraph three which is headed "Conclu- sion." I ask you to read the first sentence of that paragraph. (1!?hereupon, a document was handed to the witness.) Q (Continuing) I request you to read aloud. THE PRESIDENT: You had better get some Japanese counsel to point it out to him. A Do you want me to read all of it? 0 I want you to read the first sentence of that paragraph. A Do you want me to read the conclusion in its entirely or with respect to Soviet defense — nation- al defense, or what passage do you mean? THE PRESIDENT: The first sentence only. A (Continuing) "In short, it should be self- evident that Soviet Russia will change her policy 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 4 9 KASAHARA CROSS from that of passive defense to aggression in the future parallel with the completion of her economic power and defense." Q I now refer you to section 2, sub-section (f) and ask you to read the first sentence of that sub-section. » THE INTERPRETER: Major Furness, the document which the witness has and the document which we have is different, sir. I wish you would instruct him to that effect. The witness has only a photostat. MR. FURNESS: Well, it is the document which is before the Court, and it is supposed to be a copy of the exhibit; the paragraph which is headed "Mili- tarization of the people." (hereupon, an off the record dis- cussion was had between the witness and the monitor.) A "The militarization of the people. All possible efforts are being bent on the militarization of the public. In Japan the year before last, three million; in Japan last year, five million; and" — J cannot read the month, but it must be at the end of the year or thereabouts — "this year, nine million." 0 Will you read the last sentence. A "The effect has infiltrated even the rank of 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7,4< r KASAHARA CROSS kindergarten age." Q And then referring to the "public" there, you were referring to the Russian public, were you not? THE PRESIDENT: Why are you asking him to read those passages, Major Furness? Are you testing his ability to read the photostat, or are you trying to get in matters favorable to you? I don't question your right to do either. MR. FURNESS: I am trying to bring out matters favorable to the defense. THE PRESIDENT: Well, it is going to be very expensive of timec Q General, at the time that you made this report, you were military attache in the Japanese Embassy at Moscow, were you not? A Yes. This is not a reporte This is a sort of an informal lecture that I gave to his Excellency, General HARADA. I am under no obligation to make reports to General HARADA. Q AS military attache, you were under the general staff, were you not? A Yes. Q And you were making this informal report to a major general who was traveling through Europe and was attached to the military training section 1 2 3 4 5 6 7 8 9 10 i.l 1.2 1 3 14 1 5 16 1 7 18 19 20 21 22 23 24 2 5 KA3-tt.Hi.7TA CROSS 7 , 4 9 8 of the army. A Yes. n And can you give us the approximate date? A No, I cannot recall the date. Q Can you give us the year? A I think it was in the sixth year of Shows. 1931. Q And this informal report expresses your per- sonal views, does it not? A Yes. MR. T. 0KAM0T0: Mr. President, there is one more point on which I should like to get confirmation from the witness on this document. CROSS-TOMINATION (Cont inued) BY MR. T. OKAMOTO: P T"fith respect to the passage which counsel Furness requested the witness to read, the passage marked "3. Conclusion," it seems that in the Japanese original there is the phrase " . . . economic strength vis-a-vis the United States." I think that this passage was not read when the witness read the document. Now, I should like to ask the witness if the phrase " . . . economic strength vis-a-vis the United States" is Included in this passage. The entire meaning of the conclusion changes, and, therefore, I KAS AEIARA GROSE 7 , 4 9 9 should like to have this confirmed by the witness. A Yes, the word "vis-a-vis the United States" was written in such small characters on the side that I could not read it and, therefore, omitted it. But now that it has been pointed out to me by counsel, I can confirm that the words are "vis-a-vis the United States," if read carefully. j Q Then if I should include this particular passage in the English text, it would read somewhat as follows: "It is self-evident that Soviet Russia will change her policy towand.the United States from I passive defense. . ." et cetera. And I should like to have the witness confirm if that is the real meaning of the conclusion. Is that the purport of your conclusion, Mr. Witness? A Yes, exactly. THE PRESIDENT: Is that all the cross- examination? Any re-examination? MR. GOLUNSKY: There will be no redirect. I suppose the witness might be now released, because the next document which has been identified by him we intend to produce tomorrow. He will be available then. THE PRESIDENT: He is at liberty until tomorrow morning, (Whereupon, the witness was excused.) 7 , 5 0 0 r i 2 3 4 5 6 7 8 9 10 11 12 1 3 j 1 4 1 5 ! 16 17 18 1 9 20 21 22 2 3 2 4 25 THE PRESIDENT; Colonel Ivanov. COLONEL IVANOVs As it has already been shown here by my colleague, Mr, Darsey, the instigators of aggression in the Far East started on September 18, 1931, the realization of the plans of occupying Man- churia, which had been prepared beforehand. See pages 2847 and further of the record. We shall present evidence which will show that Kanchuria was necessary to the Japanese military for further aggression against the U.S.S.R. and China. We tender in evidence prosecution document No. 1950, the affidavit of MIYAKE, Mitsuharu, a lieutenant general of the Japanese Army, who was Chief of the Kwantung Army Headquarters from July 1928 to May 1932. This affidavit was drawn up on February 22, 1946, in Moscow. THE PRESIDENT: Major Blakeney. MR. BLAKENEY: We ubject to the reception of this affidavit, also, unless the witness be produced for cross-examination. THE PRESIDENT: It will be admitted on the condition, among others, that the witness is to he produced for cross-examination if the Court directs. At present we have not heard enough to warrant such 1 2 3 4 5 6 7 p O 9 10 11 12 1 3 1 4 1 5 16 17 13 1 9 20 21 22 2 3 2 4 25 7 , 5 0 1 a direction. Admitted on the usual terms, CLERK OF THE COURTs Prosecution's document Wo. 1950 will receive exhibit No* 699. (Whereupon, the document above referred to was marked prosecution's exhibit No. 699, and was received in evidence.) COLONEL IVANOVj The most important part of this affidavit is Lieutenant General MIYAKE's testimo- ny that the plan of occupation of Manchuria was the most important part of the general plan of a war against U.S.S.R. drawn up by the Japanese General Staff. I quote the following extract from this affit- davit, page 3 of the English translation; MIYAKE in answer to the questions put by the interrogator stated the following; "That plan of operation was signed in Man- churia by Lieutenant General HONJO, the Commander of Kwantung Army, by me, and my assistants, Colonel ITAGAKI and Lieutenant Colonel ISHIHARA. Then that plan, as I have mentioned, was submitted to the Army General Staff of the Japanese Army in July of 1931. Chief of General Staff KANAYA Hanzo gave his approval in the same month. As far as I know, that plan for the occupation of Manchuria was an important part of 7 , 5 0 2 l 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 - 1 5 16 17 18 1 9 20 21 22 2 3 2 4 25 the general plan of the operations of Japanese forces against the Soviet Union and was drafted by the General Staff of Japanese Army. It was then, when I started out for my new post as Chief of Kwantung Army Staff, in July 1928, that I found out the existence of a plan to attack the U.S.S.R. Our functions to participate in that plan were known by the Staff of the Kwantung Army. Some parts of that plan were modified in later years." I stop quoting this affidavit now, but I shall return to It later on concerning other questions. THS PRESIDENT: Major Furness. MR. FURNESf On the bosis of what has been read from this affidavit, we request that the witness be produced for cross-examination. THE PRESIDENT s Whereabouts is this deponent? The affidavit is signed in Moscow. MR. GOLUNSICY: I cannot tell exactly where he is at the present moment. He was in Moscow when he was examined in February of this year. THE PRESIDENT: For the time being, I think the majority of the Tribunal think that interrogatories should be sufficient if he is not in Japan. KRv LOGAN: If the Tribunal please, in view of the prosecutor's statement to the effect that he 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 17 18 1 9 20 21 22 2 3 2 4 2 5 7 , 5 0 3 intends to read more of this affidavit later on, which is marked on the copies we have, it affects some of the other accused in this case, and I think steps should be taken at this time to have him here later. THE PRESIDENT; Mr. Smith. MR. SMITH: Your Honor, I would like to point out the practical futility of substituting interroga- tories for the right of cross-examination. THE PRESIDENT: It was done extensively at Nuernberg. MR. SMITH: In the first place, we have no funds to take any depositions. We have no stenographers available to send to Moscow or any other place to take any depositions. THE PRESIDENT: That is a consideration. MR. SMITH: I would also like to point out to your Honor that unless counsel are present and are able to see the witness and size him up, we would not have the remotest idea what kind of questions to put to him or how to go about it. THE PRESIDENT: Perhaps we should hear all he has to say first. MR. LOGAN: May I say a further word, if your Honor please? In examination of the last answer given by 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 15 16 17 18 1 9 20 21 22 2 3 2 4 2 5 7 , 5 0 4 this affiant in his affidavit, it may very well be that he is on trial in Russia. I do not know. Perhaps j V the prosecutor could advise us. MR. GOLUNSKY; Shall I answer this question? THE PRESIDENT; If you are in position to do so, MR. GOLUNSKY: Well, to the best of my know- ledge, he is not on trial. But I know an investigation is being carried on in the Soviet Union about the activities of the Kwantung Army, and I do not know of course, to what result this investigation might lead in the future. THE PRESIDENTs We have open minds on the need for calling him. But I think we would prefer to i hear all he has to say in that affidavit before we come to a decision. He is a very important witness. 1 2 3 4 5 6 7 3 9 10 11 12 13 14 15 16 17 18 19 JO 21 22 23 24 25 7 , 5 0 5 COLONEL IVANOV: We present to the Tribunal for identification prosecution document No. 1513? a cable from Consul General in Harbin OHASHI to Foreign Minister SHIDEHARA of November 7, 1931, No. 516 (2). CLERK OF THE COURT: Prosecution document No. 1513 will receive exhibit No. 700 for identifica- tion only. (Whereupon, document No. 1513 was marked prosecution's exhibit No. 700 for iden- tification) . COLONEL IVANOV: I quote in evidence an ex- tract from this telegram to show that not only Japanese military but Japanese foreign ministry officials as well took active part in spreading Japanese aggression in Manchuria. THE PRESIDENT: Admitted on the usual terms. CLERK OF THE COURT: Prosecution document No. 1513? exhibit No. 700, is now admitted by order of the C o u r t . (Whereupon, prosecution's exhibit No. 700 was received in evidence). COLONEL IVANOV: I quote the cable: "It is hard for me to approve of the plan for the independence of Manchuria which the government tacitly seems to permit. I think it would be fairer, 7 , 5 0 6 i ' 2 3 4 6 7 8 9 10 11 12 1 3 * » ' 1 4 1 5 16 1 7 18 1 9 20 21 22 more correct and complete for us to adopt the policy of carrying out the guarantee occupation of all Man- churia ĉ na administer it ourselves for the time until all pending problems with China are solved. If we do not do this, everything will be at best incomplete, .and the policy for the control of North Manchuria will become useless. "Although it would have been better to have • left Manchuria alone from the beginning, -it would be . much, more damaging to all policies to leave things half way, since we already have meddled with Manchuria. I tender in evidence Prosecution document . No. 1991, the photocopy of the report dated July i4, 1932, of Lieutenant Colonel KAWABE3 Torashiro, the Japanese military attache in Moscow, who was later on promoted to the rank of Lieutenant General-of the Japanese Army. This document proves the military preparations of Japan for an attack against the U.S.S.R. it 2 3 2 4 25 7 , 5 0 7 i 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 | 1 7 18 1 9 20 I 21 I 22 2 3 2 4 25 THE PRESIDENT: Major Furness. MR. FURNESS: If the Court please, we make the same objection as to the source of this document which, from the certificate-,, appears to be the Red Army- Chief Military Prosecution Department, Moscow. We also call attention to the fact that the document was apparently translated from Japanese into Russian, and then that Russian translation into English, there being no direct translation from Japanese into English. We understand further that Colonel KAWABE is presently available, since he is in Sugamo Prison. MR. GOLUNSKY: If the Tribunal please, the question of the certificate I think does not arise in this instance, because on the back of the document we have the inscription by KAWABS himself that this was the document writibea by him under the circumstances mentioned by Colonel Ivanov. According to the information received by us from the Investigation Section of the International Prosecution Section, KAWABS is not in Sugamo Prison, but is In the Nagoya Prefecture. We have requested that KAY/ABE should be found and brought to Tokyo, and they have promised that he would bo here either this evening or tomorrow. Therefore, in order not to break 7 , 5 0 8 l 2 3 4 5 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 t 2 4 25 the logical sequence of the case, I respectfully request that the Tribunal allow us to read this docu- ment now, and the defense will have the opportunity to cross-examine KAWABS as soon as he is brought to Tokyo. THE PRESIDENT 2 Admitted on those terms, and otherwise on the usual terms. CLERK OF THE COURTs Prosecution's document No. 1991 will receive exhibit No. 701. (Whereupon, the document above referred to was marked prosecution's exhibit No. 701, i'and was received in evidence.) COLONEL IVANOVs KAWABE, Torashiro, made the following inscription on the back of each page of this document; "I hereby certify that this photocopy is a copy of the document written in my own hand. KAvrABE, Torashiro, September 3, 1946." The English translation of the note is given in the record of presentation of this document to AWABE? Torashiro, attached to this document. In this report KAWABE sees the nos?; urgent task of Japan in exploitation of Manchuria and Mongolia and says the following. I quote page 1 of the English translation, paragraph 3. 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 17 18 1 9 20 21 22 2 3 2 4 2 5 7 , 5 0 9 "As to the obstacles such as Chinese maneuvers restr aints by the League of Nations, acts of America and Russia, etc., against the accomplishment of the great task, we should employ proper diplomacy and endeavor to exclude the obstacles as well as avoiding making matters worse, but it is necessary for us to be ready to appeal to arms against Russia, China and under certain circumstances against America if it is inevi- table. Therefore, the emphasis must be laid on the repletion of military armaments against Russia." In a special chapter of the report KAWABE expresses the views concerning the "Attitude Towards the Soviet Union" and writes the following. I quote only the first statement which serves for KAWABE as a starting point, page 1 of the English translation, paragraph 5'- "A Kusso-Japanese Wir in the future is unavoidable." KAWABE in his report recommends the following. I quote page 2 of the English translation, paragraph 3s "As to the conclusion of a non-aggression pact proposed by the U.S.S.R., we must be non-committal and reserve our freedom of action. "Regarding the construction of transportation networks in Northern Manchuria, we must take into 1 2 3 4 5 6 7 8 9 10 11 12 1 3 14 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 ' 25 7, consideration the drain of the East China Riilway and strategy towards the U.S.S.R." We shall introduce evidence which proves that it was not only KAWABE's own opinion, and that both of his conclusions which I have just quoted were carried into effect. My colleague, Major General TADEVOSYAN, will present to the Tribunal evidence proving that the Japanese Government as regards the conclusion of the non-aggression pact actually took "such a stand which would provide a free hand for the Empire," and that was what KAWABE had advised to do. We shall present to the Tribunal a series of evidence concerning the fact that the communication net in Manchuria was built only with the view of "strategic considerations against the U.3.S.R." Now I tender in evidence the photocopy of prosecution document No. 1654, "A Message of Lieutenant Colonel KANDA of July 16." THE PRESIDENTS Admitted on the usual terms. CLERK OF THE COURT.- Prosecution's document No. 1654 will receive exhibit No. 702. . (Whereupon, the document above referred to was marked prosecution's exhibit No. 702, and was received in evidence.) 7 , 5 1 1 THE PRESIDENT; We will recess now for fifteen minutes. (Whereupon, at 1445, a recess was taken until 1500, after which the proceedings were resumed as follows;) 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 17 18 1 9 20 21 22 2 3 2 4 2 5 7 , 5 1 2 MARSHAL OF THE COURT: The International I Military Tribunal for the Far East is now resumed. THE PRESIDENT: Colonel Ivanov. COLONEL IVANOV: The document which I have tendered is a message of Lieutenant Colonel KANDA, | dated July 15, 1932. KANDA at that time was Military Attache in Turkey. He was on his way from Tokyo to Istanbul via Moscow. He gave this message to Lieuten- ant Colonel KAWA3E, Torashiro, the Japanese Military Attache to U.S.S.R. THE PRESIDENT: Major Furness. MR. FURNESS: We wonder where any of that evidence as to where this Colonel KANDA was gojng and what he was is in the document. It does not appear to be. We also see various dots indicating things have been left out; possibly that is due to illegibility but we have no information. THE PRESIDENT: Mr. Golunsky. MR. COLUNSKY: If the Tribunal please, this document has been identified by the witness KASAHARA, who explained to the Tribunal what this document was. THE PRESIDENT: Did he say anything about KANDA's movements? MR. GOLUNSKY: I apologize; I made a mistake. I referred to another document by KANDA. This document 7,5" ! 3 l 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 I 1 7 18 1 9 | 20 21 22 2 3 2 4 25 was addressed to KAWABE and received by him and identified by him. That is why I requested the Tribunal before the recess that we be allowed to read this document today and that the defense will have their opportunity to cross-examine KAWABE on this matter as soon as he will be in Tokyo. That will be perhaps tomorrow. MR. FURNESS; I assume it will also appear who Colonel KANDA was, where he was going and in what capacity. MR. GOLUNSKY: He was at the time a Military Attache of Japan in Turkey and was on his way from Tokyo to Istanbul and stopped in Moscow. THE PRESIDENT: The defense is objecting to your saying that because it does not appear in the document. It is only a trifle. MR. GOLUNSKY: I am anticipating now the evidence of KAWABE, who will be here tomorrow. Of course, I do not insist that anything I say has any probative value. THE PRESIDENT: On page 2 of the interrogation there are two certificates there by KAWABE which ought to be sufficient evidence of origin or of authenticity, whatever you might call it, COLONEL IVANOV: KAWABE, Torashiro, 1 2 3 4 5 6 7 O o 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 5 1 4 following on the back of the page one of the photo- copy of the document: "I hereby certify that this photocopy is a copy of the document written by me in my own hand. September 3, 1946, KAWABE, Tora- shiro." And on the back of the page 2 of the photo- copy of the document KAWABE made the following in- scription: "I hereby certify that this is a photo- copy of the record of the message which was forwarded to me by Lieutenant Colonel KANDA, in Moscow, on July 16, 1932, on behalf of Liertenant Colonel KASAHARA, of the General Staff. KAWABE, Torashiro." THE PRESIDENT: Admitted on the usual terms. CLERK OF THE COURT: Prosecution's document No. 1970 will'receive exhibit No. 703. THE PRESIDENT: Mr. Mantz. (Handing document to Clerk of the Court.) CLERK OF THE COURT: Correction, please: Prosecution's document No. 1654 will receive exhibit No. 702. (Whereupon, the document above referred to was marked prosecution's exhibit No. 702 and was received in evidence.) THE PRESIDENT: Proceed to read it. COLONEL IVANOV: As it appears in the record, the Chief of the Russian Section of the 2d Department 1 2 3 4 5 6 7 8 9 10 11 12 13 1 4 15 16 1 7 18 19 20 21 22 23 24 2 5 7 , of the Japanese General Staff, Lieutenant Colonel KASAHARA, Yukio, gave the following information. I quote page 1, paragraph 1: "It was decided that the (army and navy's) preparations for waging war against Russia should be completed before the middle of 1934. However, it does not moan that hostilities will be opened immediately after the preparations have been completed. In order to consolidate Manchuria, the war against i Russia is necessary for Japan. This is, however, not the intention of the entire (army)." What were the plans of a war of aggression against the U.S.S.R. drawn up by the Japanese General Staff in 1934-1935? We can find the answer to this question in the testimony given by General USHIROKU, Jun, who was at that time Chief of the 3d Department of the Japanese General Staff. We introduce in evidence prosecution docu- ment No. 1970, the affidavit of General USHIROKU, Jun, of March 21, 1946. THE PRESIDENT: Admitted on the usual terms, CLERK OF THE COURT: Prosecution's document No. 19.70 will receive exhibit No. 703. ('^hereupon, the document above referred to was marked prosecution's exhibit 1 2 3 4 5 6 7 3 9 10 11 12 1 3 1 4 15 16 1 7 18 19 JO 21 22 2 3 2 4 25 7 , 5 1 6 No. 703 and was received in evidence.) COLONEL IVANOV: If the Tribunal please, I shall read the following extracts from the document. I quote page 3 of the English translation, beginning from paragraph 2: "Q. Do you know anything about the operation codes KOO, OTSU and HEI in the General Staff Head- quarters? "A. I know them: KOO means the T"rar against the U.S.A. OTSU against the U.S.S.R. and HEI against China. "Q. Describe the outlines of the OTSU plan at the time #ien you were The Chief of the 3d Depart- ment in the General Staff Headquarters during 1934 to 1935. "A. Concerning the Plan of 1935, I knov; the following facts. The gist of it is: in connection with the affairs of the 3d Department in the General Staff Headquarters, to carry on mass transportation of troops from Japan proper to Northern Manchuria and the transferring of main farces in Manchuria from central areas to Northern Manchuria. The main portion of troops was concentrated to the east, i.e., the Matchiang area and the other portions were respectively concentrated to the north, i.e., South of Helho and to 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 17 18 19 20 21 22 2 3 2 4 2 5 7 , 5 1 7 the vicinity of Hailar. The above-mentioned is all that I know of the Otsu plan of that time." I omit one question and answer and quote page 3 of the English translation. "Q. How many divisions intended to be transported from Japan proper according to the above plan of the General Staff Headquarters? "A. Twenty Division." I shall read one more excerpt from this document, page 4 of the English translation: "Q. T"ho drew up and who approved" — THE PRESIDENT: Mr. Logan. MR. LOGAN; In respect to this excerpt, your Honor, the last question asked contains conclusions and it is immaterial as to whether or not the plan was submitted to and sanctioned by the Emperor as he is not one of the defendants in this case, and on that ground I object to that question being asked and the answer given. THE PRESIDENT: Yesterday Dr. KIYOSE pointed out that a plan was only a draft. This evidence tends to show this was a perfected plan and not a draft for what it is worth. It is difficult to say that it is irrelevant and/or immaterial. DR. KIYOSE: This is quite different from ! 7 , 5 1 8 the plan to which I called the attention of the Court yesterday. The year is different — the date is different. MR. LOGAN: I understand, your Honor, that this is a different plan being spoken about in this document but in any event the question as asked here assumes that it had been submitted and sanctioned by the Emperor and therefore it is objectionable in addition because of the form of the question. It puts the answer in the witness' mouth. THS PRESIDENT: All these questions and written interrogatories, affidavits, are leading as a rule. That is one of the main objections to this form of evidence. I think we will have to admit it for whatever probative value it has, Mr. Logan. I did not suggest that this plan was the same as the one Dr. KIYOSE referred to yesterday but the distinction between draft plans and perfected plans is always material. MR. LOGAH: As far as the purpose of this trial is concerned, your Honor, I think the previous question and answer definitely establishes all that the prosecution would wish to establish insofar as this trial is concerned in that apparently it was approved by someone of the General Staff. I fail to 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 17 18 1 9 20 21 22 2 3 2 4 2 5 7 , see how any further sanctioning or submission of the document to the Emperor would be of any probative value insofar as the prosecution's case is concerned because certainly he is not one of the accused here. THE PRESIDENT; It also fixes a date, as I am reminded by one of my colleagues. MR. LOGAN: It may very well be that the prosecution has other evidence or can prove the date it was approved, as claimed here, by the General Staff in other portions of this document, I don't know, or they may have other evidence on it. THE PRESIDENT: I think we must admit it, Mr. Logan. I must overrule your objection. COLONEL IVANOV: (Reading) "Q. Who drew up and who approved the Otsu plan of 1935V "A. This plan was drawn up by Lieutenant General KIY0SHI, Imai, Chief of the 1st Department in the General Staff Headquarters, and approved by Field- Marshal Frince KAN-in, Chief of the General Staff. "0. "Tien was this plan submitted to and sanctioned by the liiiperor? "A. In March, 1935." Now we shall Introduce In evidence evidence showing that the large-scale military preparations of Japan against the U.S.S.R. were determined in full accordance with the aims and wishes of the Japanese Government. G 0 1 d to e r & S P r a t t .THE ..PEESIDENI: Major Elakeney. MR. BLAKENEY: Inasmuch as I understand that ese are all the excerpts from this interrogation ich will be read, I should like to request the ibunal to order the production of this witness; and, this connection, I should like to point out to the 5 Tribunal that annarently this is all of this affidavit 6 wh^ch will be heard, although the entire document is in 8 9 m 1 3 evidence against the several defendants. THE PRESIDENT: You mean heard during the secution's case, Major. Of course, you may read nruch of the balance as you think fit when you are Lng evidence. MR. BLAKENEY: I don't wish to read the r§|niiinder, sir; I wish to be able to cross-examine on tlp£t remainder which is already in evidence although read. THE PRESIDENT: If we direct that the witness ailed for cross-examination, and we will consider , of course, seeing you have made an application, we will decide how much of the balance you can out to2ihjlm having regard to our rules. > Colonel Ivanov. COLONEL IV/;NOV: I present to the Tribunal for id&iificati on prosecution document No. 1857 — the 2 5 17 base that tmn 22 23 7 , 5 2 2 o 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 '"> /, 25 top secret decision of the conference of the four ministers: the Prime-Minister, Foreign Minister, Far Minister, and Navy Minister of August 7, 1936 under the title of: "Foreign Policy of the Empire". Allow me to draw the attention of the Tribunal to 'the fact that the defendants HIROTA and NAGANO were amon?! the participants of that conference. THE PRESIDENT: Major Furness. MR. FURNESS: We make the same objection, that there is no indication of where the Russian prosecution found this document. THE PRESIDENT: A certificate of origin must be attached or they must undertake to procure it. MR. FURNESS: Then we need not make the objection to each document of that type. MR. GOLUNSKY: If the President please, this is the second time we discussed this question. I think in order to save time we could agree that the prosecution will undertake to furnish to the Tribunal a certificate showing in which way those documents came into possession of the Soviet Government. All those documents, by whoever got them, were handed over to the officers of the Military Procurator of the Soviet Union and that is where we got them from; but, since the Tribunal has directed us to furnish I 2 3 4 5 6 7 a 9 10 11 12 13 1 4 1 5 36 1 7 18 19 20 21 22 2 3 2 4 25 7 , 5 2 3 certificates of the origin of those documents, we will gladly (> so as soon as it is practically possible. THE PRESIDENT: We understand the defense to object to every document that has not a certificate of origin. There will be no need to repeat the. objection. MR. FURHESS» The ruling of the Court is that it is accepted only conditionally? TEE PRESIDENT-, That applies in every case where there is no certificate of origin. CLERK OF THE COURT: Prosecution's document No. 1857 will receive exhibit No. 704 for identification. (Whereupon, the above-mentioned document was marked prosecution's exhibit No. 704- for identification.) COLONEL IVANOVs I shall quote in evidence l an extract from the second chapter of this decision, under the title of "The Most Important Trends of the Policy." THE PRESIDENT i Better call out the number again. CLERK OF THE COURT: Prosecution document No. 1857 will receive exhibit No. 704. COLONEL IVANOVs I quote page 4 of the English translation, second half of paragraph three: 1 2 3 4 5 6 7 8 9 10 11 12 1 3 14 15 16 L7 18 19 20 21 22 2 3 24 25 7, "But at present taking into consideration today's state of the relations between Janan and the Soviet Union, it is rendered the important point in the practical scheme for China, first to make the North China immediately a special district of nro-Japan-and- Manchukuo and anti-Communism, to obtain resources for national defense and to extend traffic establishments as well as to make whole China anti-Soviet and oro- Jananese. (Measures which should be carried out practically for the present shall be made up separately. Now we shnll show how the Japanese General Staff fulfilled the tasks set by the leaders of the militarist clique, which ruled in Japan, by preparing the invasion of the: Japanese Army onto the territory of the Soviet Union. The evidence concerning the plans of a war against the U. S. S. R. from 1939 and 1941 will be presented later by my colleague Colonel Rosenblit. We shall establish the contents of the olan of a war against the U. S. S. R. in 1940 through the testimony of TOMINAGA, Keoji, Lieutenant-General of the Japanese Army, whoso affidavit of February 21, 1946 I present to the Tribunal in evidence under No. 1984 and ask to admit it on the usual terms. THE PRESIDENT: Mr. Blewett. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 \ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 1 5 16 17 18 1 9 20 21 22 23 24 2 5 7 , 5 2 5 COLONEL IVANOV: Ve wished to bring witness TOM NAG A to be examined before the Tribunal in Tokyo b cause his testimony is very important. But due to the illness of the witness we are bereft of this opportunity. I present to the Tribunal the certifi- cate of his illness. MR. BLE,rrETT: If your Honor please, I didn't hear that. I was under the impression that the affi- davit was going to be introduced in evidence; but I understand that it is just the affidavit, or just that portion of it that — well, as a matter of fact ' I didn't hear it at ail through this earphone. THE PRESIDENT: His affidavit is tendered, but with a certificate of illness which is the excuse for not calline him personally. Neither document has been admitted yet. What is your objection? How can we talk to you if you don't wear your earphones? MR. BLE-"ETT: Ily objection, sir, is: If this affidavit is offered in evidence, I am going to ask the Tribunal to exercise its discretion and give the defense the•opportunity of cross-examining the witness. THE PRESIDENT-. Unless we indicate the contrary, we will make it .a condition of the acceptance of any affidavit that the proponent will be called, if directed by the Tribunal, or will be subjected to interrogation 1 2 3 4 5 6 7 8 10 J.1 12 13 1 4 15 16 1 7 18 19 20 21 22 23 2 4 25 7 , 5 26 if directed by the Tribunal. But, in most cases, we would want to read what is in the affidavit before we would give such a direction. MR. BLEWETT: Your honor, if the Tribunal please, the defense has examined this affidavit, and it is quite clear that to do justice to these accused we should be permitted and granted the right of cross- examination,, THE PRESIDENT: Let us read it first to see whether we agree with you or not. For the time being, I do not know a single word it contains, nor does any other Member„ MR. BLEWETT: We shall renew our request, sir, at the nroper time. THE PRESIDENT: Admitted on the usual terms. CLERK OF THE COURT: Prosecution's document 1984 will receive exhibit No. 705. (Whereupon, the above-mentioned docu- ment was marked prosecution's exhibit No. 7C-5 and received in evidence.) COLONEL IVANOVs TOMINAGA in 1940 was Chief of the 1st, i.e. operation, department of the General Staff and thus directed the drawing un of operation nlans. I quote the following extracts from his affi- davit concerning the plan of 1940, pages 4 to 5 of the 7 , 5 2 7 English translation; "A. I, as the Chief of 1st Department of General Staff Headquarters, drew an agression plan against U. S. S. R. in 1940. According to this plan, the main attack should be operated from Lake Hanka area in the direction of Khabarovsk to separate the Maritime Province from U. S. S. R. For this purpose 12 infantry divisions, as main forces, and 2 artillery brigades, 3 tank regiments, 2 cavalry brigades and 5 bombardment groups, as auxiliary forces, were to be applied. After attacking Khabarovsk and occupying Vladivostok plain, the Northern Front Forces, formed from 7 divisions; an artillery brigade and other units were to begin to attack. In case of success, the Western Front Forces were- also to open their attack, having a main attack in direction of Chita, with the intention to occupy Soviet territory extending to Lake Baikal. "0 To whom did you report this plan? "A I reported it to Prince KANIN, Chief of General Staff Headquarters. "Q Was there anybody else to whom you reported this Plan? "A I, myself, reported this plan to His Majesty the Emperor in company with Prince KANIN, "Q Did the Emperor sanction the plan? 1 2 3 4 5 6 1 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 5 2 8 "A. After a few days the sanction to this plan was given by the Emperor. " I omit several questions and quote one more • xcerot on page 5 nf the English translation, last paragraph. "Q In what month was the plan sanctioned? "A It was in March of 1940." Such were the Plans of the Japanese General St'ff against the U. S. S. R. prior to the attack of Germany on the Soviet Union. As I have said before, my colleague, Colonel Rosenblit, will present evidence to the Tribunal concerning more recent plans of a war against the U. S. S. R. THE PRESIDENT: Mr. Blewett. MR. BLEWETT: It seems to me that that has been sufficient to Indicate that this witness should be called. The affidavit is along the same tenor, and names specifically several of these accused, and certainly, if there is any of these affidavits where the witness should be produced, this is an example. THE PRESIDENT; I understand the prosecution to agree with you, but they say he is sick. We think he should be called. MR. BLEWETT: We understand the witness is in Tokyo, your Honor. 1 2 3 4 5 6 7 8 9 10 11 12 1 3 1 4 1 5 16 1 7 18 1 9 20 21 22 2 3 2 4 2 5 7 , 5 2 9 MR. GOLUNSKY: No, the witness is in Moscow. It was also our desire to bring him here personally. We sent a request to Moscow to send him, and in answer we got the certificate which I right now handed to the Tribunal. THE PRESIDENT: A majority of the Tribunal require his attendance. MR. GOLUNSKY: As soon as I will take measures, that is as soon as his health will permit, he will be brought to Tokyo. THE PRESIDENT: Mr. Brooks. MR. BROOKS: If the Tribunal please, I would like to call the attention of the Language Section for correction, if it is proper, on page 4 of exhibit 705 in the second line, the word "aggression plan" appears. I understand that in the original it should read "attack plan" as distinguished from a defense plan; and these words have certain reaning to military personnel, and such plans are customary in all armies of various nations. THE PRESIDENT: The point is referred to the Language Section. Colonel Ivanov. COLONEL IVANOV: Now I shall introduce evidence proving that the plans of a war of aggression against 7 , 5 3 0 the U. S. S. R., which during all those years were being drawn up by the Japanese General Staff and on which I have spoken before the Tribunal, were not theoretical plans drawn up at random, but led to actual preparation for a war against the U. S. S. R. We shall present to the Tribunal evidence that the Japanese Government headed by the defendants spent hundreds millions yen, many rare materials and manpower for the purpose of building barracks, mili- tary dumps, strategic roads, fortified districts and other military constructions in Manchuria and Korea on the U. S. S„ R. frontiers. I shall present to the Tribunal a number of docuiiEnts from the Red Army General Staff which contain data characterizing the increase of the Japanese armed forces in Manchuria in the period after 1931 and of turning Manchuria into a military base. I tender in evidence prosecution document No. 2237, '"Table of the Increase of the strength of the Kwantung Army and of the Japanese Army as a whole from 1932 to 194-5." 7 , 5 3 1 THE PRESIDENT: Admitted on the usual terms. CLERK OF THE COURT: Prosecution's document No. 2237 will receive exhibit No. 706. C'hereuoon, the above-mentioned docu- ment was marked prosecution's exhibit No. 706 and received in evidence.) COLONEL IVANOV: To make the understanding of the data given in the table easier, we have drawn up diagrams containing this data. I beg Mr. President and Members of the Tribunal to consider the chart on cage 1 of the appendix to the table and to follow the changes which took olace during the above-mentioned years in the strength of the Japanese army as a whole and of the Kwantung army which was its part. In this chart the first small columns on the left side show that by Janaury 1, 1932 the Kwantung Army was 50,000 men strong, and the Japanese Army as a whole was by that time 256,000 men strong. The Kwantung Army at that time comnrised about twenty nercent of the Japanese Army. By January 1, 1937 the strength of the Kwantung Army was increased more than five times as much and amounted already to 271,000 men. And the Japanese Army as a whole was by that time 872,000 men strong. The 1 2 3 4 5 6 7 8 9 10 11 12 1 3 14 15 16 17 18 19 20 21 22 2 3 2 4 25 7 , 5 3 2 Kwantung Army already comprised more than thirty percent of the Japanese Army. By January 1, 1942 the strength of the Kwan- tung Army was at its highest — 1,100,000 men and was twenty-two times higher than the strength of the Kwan- tung Army in 1932 and four times higher than the strength of the Kwantung Army in 1937. In 1942 the Japanese Army as a whole was 3?200,000 men strong. And the Kwantung Army comprised at that time about thirty-five percent of the whole Japanese Army. This diagram expressly shows the extremely rapid increase of the strength of the Kwantung Army during all these years up to 1942 inclusive. After the occupation of Manchuria the strength of the armament of the Kwantung Army also was rapidly increased. I ask you, Mr. President and Members of the Tribunal, to consider the chart on page 2 of the appen- dix, the table of the increase 'of the strength of the Kwantung Army tank park and of the Japanese Army as a whole from 1932 to 194-5. I quote only the data con- cerning the Kwantung Army. The Kwantung Army had by January 1, 1932 — 40 tanks, by January 1, 1937 — 439 tanks, by January 1, 1942 — 1000 tanks. 1 2 3 4 6 7 3 10 21 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 , Now I ask you to consider the table which shows the increase of the artillery oark, page 4 of the appendix. The Kwantung Array had by January 1, 1932 — 300 Pieces of ordnance: by January 1, 1937 -- 1193 pieces of ordnance; by January 1, 1942 — 5000 oieces of ordnance. I also ask you to consider table of the increase of the fighting olanes, page 5 of the appen- dix. The Kwantung Array had in 1932 — 180 planes; in 1937 — 500 planes; in 1942 -- 1500 ->1 nes I ask you now to consider table on the increase of the number of the Kwantung Array infantry divisions, page 3 of the appendix. The Kwantung /rmy by January 1, 1932 had 2 division; by January 1, 1937 — 6 divisions; by January 1, 1942 — 7 divisions. I do not bring the attention of the Court t-̂ the corresponding indices of the number of divisions in the whole composition of the Japanese Army, although this information is given for comparison in the diagram and in the table, and I present to the Tribunal — THE PRESIDENT: We will adjourn now until half-past nine tomorrow morning. (Whereupon., at 1600, an adjournment was taken until Friday, 11 October, 1946, at 0930.)
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