Defense witnesses in transcripts09.html

DEMJANJUK TRIAL
(Jerusalem, Feb. 16, 1987 - Apr. 24, 1988)
SUMMARY of English-language TRANSCRIPTS

Edna Robertson; T007706 - 8311; 1987/08/06-13; Vol. 13
[1987/08/06, Thu.; T007706, Vol. 13; Robertson]
[Top] [1987/08/06] [1987/08/10] [1987/08/11] [1987/08/12] [1987/08/13] [Bottom]

T007706f - Gill direct examination of Edna Robertson
- lives in Panama City, Florida, BA and MA (1973) Psychology from U. West Florida
- studied handwriting analysis, document examination

T007708 - Nun/52 = statement of qualifications of Edna Robertson (resume)
- certified in grapho-analysis in 1971
- attended many one week courses, conferences, etc.; 500 hours of classroom instruction

T007714 - typist identification
- Thin Layer Ink Chromatography (TLC)

T007719 - part time practice in 1971, full time since 1974, over 1000 cases, over 10,000 signature comparisons, testified over 55 times, only 5% of cases actually go to court, director of World Association of Document Examiners (WADE)

T007721 - Esda machine "develops by an electrostatic process indented writing impressions on paper".
T007723 - more than 100 microperfs (microperforations) for TLC testing taken from tav/149
T007724 - Robertson first noticed the microperfs in tav/149 in the police laboratory (in Jerusalem?) during of last week of May 1987.

T007728f - In January 1984, Gill phoned Robertson to examine "the 11x14 inch black and white photographs that had been taken by Gideon Epstein".
- Mr. Fabian Tasson was also on the case.
- About a month later, Robertson received copies of photos, and 4 original signatures of John Demjanjuk on a sheet of white paper.

T007730 - At the end of 1986 and mid-February 1987, Robertson received several colored photographs from Fabian Tasson.
- "working off of the photographic copy of a photograph" she was able to give a qualified (when not working with an original document) opinion.

T007734 - from colored photos Robertson observed a large orange spot behind the photograph which she concluded was the result of a solvent.
- "On the enlarged color photographs, it was visually apparent that there were two colors of inks for the stamps. One color on the photograph and a different color on the paper.

T007737 - Robertson and Tasson arrived Monday, May 25, 1987 and left on Friday, May 29, 1987.
- Tues. 3:00 - 5:00 pm, Wed. 1:00 - 5:00 pm, thu. 9:00 - 1:00 pm

T007739 - On way home at [Zurich] airport "my film was dumped out of the lead bag, and rolled through on the conveyor in spite of my protests." "I was able to salvage 2 sections of 3 rolls of film."
- [Tasson had extra film.] Finished analysis by end of June 1987.

T007741 - Nun/53 = exhibit of Edna Robertson on tav/149
T007741f - Page 1, A-B = front and back of card
- Page 2, C-D = inside of card
- On Page 2C left edge (or Page 1B right edge), the edge is dog eared and worn, whereas there is no creasing along the right edge.
- There is a crease approx. 1 cm from the edge that is torn.
- It doesn't show excessive wear in the fold.
- Card could have been carried in a person's pocket only if it had been protected in a shield or envelope.

T007750 - Robertson: "I found the questioned signatures [of Teufel] to be stiff. It did not have the flowing quality or gracefulness that occurred in the standard signatures." ...some variations in the letter "e".
- With regards to Teufel... "... I cannot give a firm conclusion that the signature is genuine."

T007755f - Streibel signature
- In 1936 Streibel was writing in old German script; in 1940 he changed to Latin letters.
- The major difference is in the slants.
- Robertson agrees with Bezalely assessment.
- "Patching" on the first "e" of Streibel's signature.
- "And because of this variation, I have to say I cannot give an unqualified opinion that it is genuine. But there is a possibility that it is."

T007764f - Demjanjuk signature
- Two differences in the "D" - narrowness and termination
- The "e" is similar, but is connected to the following "m" which does not happen in the standard signatures
- The most significant difference is in the "ja"
- The "n" is structurally different
- The "o" [perhaps yu?] is also structurally different
- The "k" does not compare with any of the k's in the Cyrillic writing
- The period at the end also appears in some of the standard signatures
- The final stroke on the "D" is pointing downwards which is opposite the standards
- The slant was similar
- No significance in spacing variations or letter heights
- On ID card, there are no pen lifts after commencement of "e"; whereas on the standards, there are pen lifts after the e, m and ja.

T007771 - Robertson: "I reached an unqualified opinion that the signature, Demjanjuk, on the ID card, was not done by the same writer, who wrote Demjanjuk in Cyrillic standards."
- Gill asks about comparison of j (or ja) between the Demjanjuk signature and Russian writing on the ID card. Shaked objects since this was not included in nun/53 submission and Levin overrules question and wants conversation stricken from the record.

T007775 - Robertson: "I determined that from the enlarged photograph, that the paper clip had rusted on the page before the Streibel signature was written."

T007776 - In a humid environment paper clip rusts in about a week, in a less humid environment, it takes months or years.

T007779 - Orange mark on back of photograph "indicated to me an attempt or a possible removal of the photograph by means of some sort of solvent."
- Concludes that original photograph was removed and another photograph attached

T007781f - Staple holes in photo
- no cross line between staple holes - a document could have been on top
- purple ink in staple holes - very neatly placed, not example of idle doodling. Cracks in the emulsion surface caused by lifting of staple out of the hole.

T007782 - "If you look closely into the microperforation hole in the lower staple hole, you will see the yellow stain that is on the document." -- but not on the photograph.
- Purple ink in staple holes seems to match the color of the Russian handwriting on the ID card.

T007788f - "stretch mark" as a result of wetting paper with solvent
T007789f - Photo 49 of nun/53 is 5 times enlargement of the lower section of the photograph in the area of the swastika wreath and the stamp.
- probe marks at the base and edge of the photograph of an instrument used to remove and replace the photograph. These probe marks are "both on the photographic material and also on the card". There are torn fibers in the region.

T007793f - Photos 50 and 51 (stamp at bottom of photo on ID card); photos 52 and 53 (photo of driver's license of John Demjanjuk in 1947).
- Difference in color in the ink of the seal between the photo and ID paper is real, since a similar phenomenon does not occur between the photo and paper on the driver's license.

T007795 - Robertson did some tests with early 1940s photos of different thicknesses to see if stamps would be misaligned and depict different colors between photo material and paper. None did.

T007798f - Video Spectral Scanner (VSC) allows one to view luminescence in the infra red range. Police laboratory in Jerusalem had one and Robertson used it to observe that inks of seal were different. In fact, the Israeli expert who set up the machine pointed out that they were different.

Edna Robertson; T007805 - 7939; 1987/08/10; Vol. 13
[1987/08/10, Mon.; T007805, Vol. 13; Robertson]
[Top] [1987/08/06] [1987/08/10] [1987/08/11] [1987/08/12] [1987/08/13] [Bottom]

T007805 - Corrections of translation of testimony from previous week.
T007808 - With Video Spectral Scanner ... "I determined that the ink was fluorescing on the photograph and not on the paper."

T007812 - Photo 58 of nun/23 - "the offset is greater on the swastika wreath, than it is on the outer line where the stamps meet."

T007813 - Robertson: "In evaluating this wide difference in offset, I reached the conclusion that this could have occurred only by the use of two different stamps, which was an attempt to create an image of one stamp."

T007814f - Robertson suggests that "the numbers that are on the label on the uniform on the portrait of tav/149" are 1693 and not 1393.
- [W.Z. I simply cannot understand why this number is so faint in the first place. It should be pitch black! Presumably, its purpose is to identify the subject by number.]

T007817 - Robertson: "It would appear that sometimes in the past the forged portrait had been re-photographed."

T007818 - Nun/23/21a = strip of type set for Robertson by McDonald Printing Co. of which photos 62 to 65 were made.
- there are 4 leaders [dots] after the word mantel. The third dot is higher because typeset is presumably inverted. (Notches for font in English-speaking countries and in Germany are at bottom; but are on top in Eastern Europe.)

T007821f - re-photographs from tav/145 illustrating that photos were cut to size with scissors. Backgrounds are either black, white or blanket such that no identifying background is available.

T007825 - Robertson agrees with Bezalely on line quality but less so on structural features of writing. She was surprised that he did not testify on the infra red luminescence.

T007826 - Robertson disagrees with Cantu's "findings regarding the infra red luminescence of the stampings." ... "If he relied on the infra red luminescence for the thin layer chromatography, then he should have relied on it for his infra red luminescence of the ink stamps."
- [She criticizes Cantu's methodology ... which she will regret later.]
- [She does not seem to realize that chemicals in the substrate could affect the fluorescence.]

T007827 - Levin: "Your last comment concerning Dr. Cantu, is not entirely acceptable to the court."

T007828 - Robertson summary: The Trawniki ID card is an altered document.
- Photo was removed and replaced,
- signature of Demjanjuk is different,
- signatures of Streibel and Teufel are inconclusive,
- rust stain is unexplained,
- could not prove inks on stamps were the same,
- wet stretch mark,
- there are probe marks at base of photo,
- there is an offset of swastika wreath between photo and paper.

T007831 - **** Shaked cross-examination of Robertson for 480 pages ****

T007832 - Robertson sent her conclusion to John Gill on July 6, 1987, but not the total material in nun/53.

T007836 - In Cleveland, Robertson gave Gill a notarized affidavit on March 3, 1984, which was to be a counter-opinion to Mr. Gideon Epstein.
- For the next 20 pages, Shaked tries to undermine the credibility of Edna Robertson as an expert witness by referring to other cases.

T007857f - Levin refuses prosecution request to cancel afternoon session and a defense request for a fortnight's break to allow interview of witnesses. There will be inclusive sessions Mon., Tue., Wed. 8:30 - 1:00 pm, 4:00 - 6:00 pm, Thu. 8:30 - 2:30 pm until break between Aug. 26 to Sept. 6, 1987. Rogatories will be at the end of hearing witnesses.

T007859 - Shaked questions Robertson re wear and tear of tav/149.
T007863 - MISSING
T007864 - Presumably, yesterday (Sunday, Aug. 9, 1987) the prosecution received the 3 extra ID cards of Juchnowskij, Wolembachow, Bondarenko, photocopies of which were given to Gill by Mr. Gabai.

T007865 - Robertson testifies that she did not see, nor was she told about these photos.
- [This is not credible, according to testimony on T008025f, where it states that she actually accompanied Gill to Police Headquarters on August 9, 1987 [[Nagasaki Day]]]

- In 1984, Robertson referred to the ID card as a personalbogan which would normally be found in a filing cabinet.

T007867f - Shaked shows Robertson a photostat of tav/126 - which is a personalbogen and questions her on it.
- Judges act as full time prosecutors -- haranguing Robertson, claiming she should not use the term ID card, but rather personnel data card. This continues for 20 pages.

T007889 - Discussion of wear on the ID card, on person, in wallet, etc.
T007892f - Levin allows Shaked question as to whether Robertson knows details of Sobibor extermination camp, and then later about whether tav/149 was kept in room.
- Levin, himself, hounds Robertson for stating that the minimal wear on the card indicates that the card was not carried on the person a great deal.

T007897 - Robertson: "That is what I thought I explained a while ago, that it was merely to support my conclusion as to what the card was."

T007899f - Shaked: Robertson saw the color in tav/149 for the first time in February 1987, but on basis of b/w photo said that card was not authentic in 1984; whereas Gideon Epstein based his decision on colored photos.

T007906 - Shaked quotes Robertson from 1984: "In any event, I do believe that with the numerous errors, obvious alterations and the blotting out and other discrepancies, that I found and state above, leads me to the opinion that this document as a whole, government exhibit 5-35-6B, subvariations on it, is or may not be authentic."

T007912 - In her 1984 testimony Robertson stated that only one typewriter was used.
T007914 - Levin: "I heard, with regret, that in fact you have not retracted your statement concerning the wear."

T007916 - In 1984, the subject of signatures of Streibel, Teufel, Demjanjuk is absent.
T007924f - Long discussion of graphoanalysis: Book by Charles Scott equates graphoanalyst/document examiner with astrologer/astronomer.

T007929 - Robertson: "I have never testified in the capacity of a graphoanalyst in court."
- Shaked refers to case of Trafikin with which Robertson was involved.

T007933 - Shaked next undermines Robertson's credibility by saying she is not a forensic document examiner, just a document examiner.

T007935 - Robertson is not a member of American Society of Questioned Document Examiners, nor of American Academy of Forensic Sciences; whereas Gideon Epstein is.

T007937 - Tav/216 = Pamphlet of American Society of Questioned Document Examiners.
T007939 - Tav/217 = Pamphlet of Academy of Forensic Sciences in the U.S.A.

Edna Robertson; T007940 - 8089; 1987/08/11; Vol. 13
[1987/08/11, Tue.; T007940, Vol. 13; Robertson]
[Top] [1987/08/06] [1987/08/10] [1987/08/11] [1987/08/12] [1987/08/13] [Bottom]

T007941 - Tav/218 = Excerpt from Moyenson book "Scientific Evidence in Criminal Cases"
T007942 - Tav/219 = Rules and Regulations "American Board of Forensic Document Examiners"
T007943 - Robertson is director of World Association of Document Examiners
T007948 - Tav/220 = Judgement of State vs Lee Vanus
T007950 - Tav/221 = Judgement of Carroll vs State

T007953 - Robertson: "I've heard Dr. Cantu lecture and we've also had some personal conversations about what we can say about our findings." [WHEN?]

T007956 - Robertson maintains that her opinion is that the Trawniki ID card is not authentic. "Further, I cannot make any judgement as to when, where or who could have altered the document."
- [THIS THE PROPER ATTITUDE WHICH THE DEFENSE SHOULD HAVE ADOPTED, RATHER THAN TRYING TO PROVE THAT THE KGB ALTERED THE DOCUMENT.]

T007959f - Discussion of alteration of photo on tav/149. The original photo was replaced by the present photo. The number 1 appears to have been added to the photo and re-photographed such that number is now 1693 (not 1393).
- [W.Z. I CANNOT MAKE OUT ANY NUMBER AT ALL.]

T007971 - Robertson: "When I looked at the base of the 3, the fourth number, it was definitely different than the base of the second number. And therefore I could not conclude that it was a 3."

T007976f - Gill objects to Shaked asking Robertson to speculate on "mind and memory" rather than testify on document examination. Levin justifies himself as seeking clarification.

T007979 - Numerals on label appear to be stencil letters. "In other words are stamped with printing." [???] "... possibly a stencil or hand numerals that could be stamped on a label to make a set of numbers."

T007980 - Dorner: "We too have seen it. It is not entirely a closed circle."
- Robertson: "... but in my opinion that it would be a complete circle."

T007981 - Tal: "But it is a fact that on the re-photograph, the one, in fact, is invisible to the naked eye."
- [W.Z. I can't see anything either on my copy. REPEAT: WHAT GOOD ARE NUMBERS ON A PHOTO IF YOU CAN'T READ THEM? THEY SHOULD BE CRYSTAL CLEAR!]

T007981 - Tal cannot see the "1" on the original photograph with the naked eye; whereas Robertson says that she can and it is more clear than the other 3 numerals.

T007986f - Side show as to how film was damaged at Zurich airport (not Ben Gurion airport).

T007991 - Shaked: "How, for example, did you take the photographs in the Traficant case, do you recall?
- [??? James Traficant ???]
- [Gill objects to Shaked trying to demean the witness, but is once again overruled by Levin.]

T008003f - Discussion of 2 staple holes, when made, etc.
T008008 - Levin finally cautions Shaked: "No, the way these questions are being put are too offensive and is uncalled for in the nature of this questioning."

T008016 - Robertson: "OK, earlier, I had indicated but not enlarged on it, that it could be that the label itself was changed, before it was put on the jacket, but I don't know how that label is attached to the jacket. And it could be just the label that has been re-photographed."

T008017 - Levin suggests the photographer simply "reinforced the first digit, by going over it with ink" when he saw it was faint and then took the original photograph. Robertson agrees that that is a possibility.

T008017f - Discussion of receipt of 3 new documents similar to tav/149, which Robertson still hasn't seen.

T008021 - Shaked: "It is Dienstausweis 847 by Juchnowskij, Ivan and you will agree with me that this document, too, this is the word mantel and there is this jump of the one dot in the leader."
- Gill objects.

T008025 - Shaked explains that the 3 new cards were passed on to the prosecution from the prime minister's office on Sunday. Called Gill (but couldn't locate Sheftel) to ask him to look at them. Gill came with another attorney (not Sheftel) and asked for and received xerox photostats. In a further meeting Gill came with Robertson and took a further look at the documents.
- [IS IT CONCEIVABLE THAT ROBERTSON DID NOT LOOK AT THEM?]
- Long discussion as to the legality of submitting these documents without first having submitted them to the defense.

T008032 - MISSING
T008040 - Levin overrules objection and allows Shaked to question Robertson on new documents as it relates to her submission.

T008042 - Tav/222 = Trawniki ID card Dienstausweis 847 of Iwan Juchnowskij
- Tav/223 = Trawniki ID card Dienstausweis 1211 of Iwan Wolembachow
- Tav/224 = Trawniki ID card Dienstausweis 1926 of Mykola Bondarenko

T008043 - Shaked hands Levin color photographs of originals.
- [W.Z. and I only have b/w photos.]

T008050f - Robertson can't make out the last 1 of 1211 and can only clearly see the 4 in 847. T008056f - Reference to extensive wear on these documents.

T008057f - On tav/149, the color of stamp on paper is blue-black, whereas on the photo it is reddish
- On tav/223 (Wolembachow) the color on the paper is green, whereas on the photo it is red.

T008066 - All 4 ID cards have an upwardly displaced third dot after word "mantel".
T008074 - Discussion of solvents in glue for tav/149.
T008077f - Paper in tav/149 is pale green.
- Assumption that solvent was used to remove photo which caused orange discoloration in tav/149.

Edna Robertson; T008090 - 8240; 1987/08/12; Vol. 13
[1987/08/12, Wed.; T008090, Vol. 13; Robertson]
[Top] [1987/08/06] [1987/08/10] [1987/08/11] [1987/08/12] [1987/08/13] [Bottom]

T008090 -MISSING
T008091f - Long discussion of source of orange discoloration - solvent or glue?

T008096f - tav/223 - ID card of Wolembachow
T008097 - Shaked and Levin imply, that on the day previously, Robertson testified on the green-red color of the stamp and a 2 mm upward offset of the photo.
- [THE OFFSET HAD NOT BEEN MENTIONED.]
- **** On the the back of tav/223 behind the photo, there is an orange spot similar to that on tav/149. ****
- [But it is obvious that the photo had been removed and either replaced or a new one was put on.]
- [W.Z. On my copy, there appear to be two key-punch-type holes through the photograph and card, which are not mentioned in the transcripts.]
- [NEITHER IS IT MENTIONED THAT ON THE JUCHNOWSKIJ CARD, THERE ARE TWO STAMP MARKS ON THE PHOTOGRAPH, BUT ONLY ONE STAMP MARK ON THE PAPER.]

T008099 - The purple ink on tav/149 appears to be more faded than the ink on tav/223.
T008103 - Tav/225 = Black and white blowup of the photo on the driver's license, tav/21, which presumably shows an offset in the stamp associated with a fold.
- [ W.Z. I can't follow what is going on.]

T008104f - Streibel signature: if inks are lying over or under rust marks
- [W.Z. On my photostat of tav/149, I cannot see such paper-clip rust marks]
- Discussion as to alternate possibilities of paper clip.

T008128 - Robertson did not do chemical analysis of rust marks, but repeats that Streibel signature was written on top of rust marks.

T008128 - Shaked reads statement by expert in Journal of Forensic Sciences, that you need a scanning electron microscope (SEM) to determine which of two crossing lines is on top.
- Robertson didn't ask for SEM machine to be made available to her at Israeli Police Headquarters.

T008140 - Tav/226 = photo of segment of tav/149 taken by Israeli police similar to nun/53, picture 48, illustrating a groove or stretch mark.
- There is an elevation on either side of the paper.

T008142 - Tav/227 = 2 photos in which protrusions appear in different parts of tav/149.
T008145 - Robertson had noticed "an abrasion in the upper corner, like a rubbing" on the photo but couldn't attach any relevance to it.

T008147f - Video Spectro Scanner is brought in (probably the one used previously by Robertson at police headquarters) to examine the luminescence in the stamps. Even with Bezalely's help, they have difficulty operating it.

T008160 - Robertson: "But we are getting luminescence on the photograph and we are not getting luminescence in the printing below the photograph."

T008161 - Not receiving the same sharpness as Robertson had observed before.
T008162 - Shaked surprises Robertson by telling her that the photos on page 17 were made with a laser device and not a VSC.

T008164 - Bezalely replaces tav/149 with tav/21 (Demjanjuk 1947 driver's license) and shows that there is a similar effect there.
- [W.Z. Ink on photo tends to luminesce, whereas ink on paper does not.]

T008177 - Dorner: "Now, perhaps, now that you see that the reaction of tav/21 at least gives rise to the need for research, then perhaps you would agree that in fact one cannot draw any conclusions from the luminescence without also conducting control tests on documents which are not in dispute."
- W.Z. A VERY VALID COMMENT.]

T008178 - Tal: "Another phenomenon which is interesting in this document is that even though the outer ring of the stamp continues to luminesce on the paper, the letters of the same stamp, which appear on the paper, are not luminescent."
- [W.Z. VERY PUZZLING.]

T008179 - Tav/228 = 2 photographs illustrating luminescence on tav/21.
T008180 - MISSING
T008182 - Robertson outlines tests which should be done on tav/21, since she has "never observed it in my examinations of hundreds of documents".

T008127 - With respect to the stamps, Robertson carried out 3 tests:
- basic visual observation - blue-black vs reddish tinge
- enlarged color photographs
- VSC imaging on original

T008209 - Tav/229 = identity card of someone in general gouvernment in Poland. [WHO?]
T008210 - Tav/230 = photos of tav/229 from VSC machine
- There is luminescence of stamp on photo but not on paper.

T008215 - Tav/231 = ID card of a Ukrainian from Poland, May 19, 1944, which comes from the Yad Vashem archives.
- [??? WHY NO NAMES ASSOCIATED WITH THESE CARDS???]

T008217 - Tav/232 = photos of luminescence of tav/231 via VSC machine
T008222 - On the orange spot opposite the photograph on tav/149, the stamp "Dienstsitz Lublin, Ausbildungslager Trawniki" has changed to a purplish hue, whereas on the paper it is bluish.

Edna Robertson; T008241 - 8311; 1987/08/12; Vol. 13
[1987/08/13, Thu.; T008241, Vol. 13; Robertson]
[Top] [1987/08/06] [1987/08/10] [1987/08/11] [1987/08/12] [1987/08/13] [Bottom]

T008241 - MISSING
T008246 - Shaked: "..., in this particular case, there is no original document bearing an original signature of Teufel's, with the exception of tav/149, and on some of the documents which we received only in the last few days." [Which Robertson didn't know.]
- for the next 16 pages, shaked and judges hound Robertson as to why she didn't try to get original signatures of Teufel.

T008262 - Streibel signatures - variation in slants.
T008270 - Robertson: "... Except that someone signed for Streibel. Maybe an aide and we know that this happens. None of us saw him write any of these signatures."
- Dorner, especially, insists that all the Streibel standards are not in dispute, despite the reservations of Robertson.

T008275 - Robertson: "I stand by my opinion."

T008276 - Gill re-direct examination of Robertson.
- Cantu only came to Israel to test the age of the inks and paper of tav/149.

T008279 - Sheriff Traficant case in Cleveland, Ohio.
T008280 - Robertson: "The signature was on a signed confession of his activity with the mafia. Mr. Traficant had engaged my services and my findings were favorable to his cause."

T008280 - "The honorable James A. Traficant is a United States representative in the United States Congress."
- [W.Z. Of course, James Traficant was a major supporter of John Demjanjuk after the Verdict.]

T008287 - Gill: re 1393 vs 1693.
- Robertson: "In the second number we simply see the outline of a circle. So if the fourth number is a three, then the second number is not a three."

T008294 - Significance of the discoloration in the crease (opposite the photograph).
- "The document would already have had a crease in it, at the time that the solvent dispersed, because it dispersed down into the crease."
- [Indication that the orange discoloration on the back is not due to original solvent in glue.]

T008297 - Robertson gives example of order of lines determination she made for a client.

T008298 - Could not see brown color of the rust (of paper clip) over the black Streibel signature. Concluded that document had been around for some time before Streibel signature was placed on it.

T008303 - Presumably, Gideon Epstein gave firm opinion based on just two standards.
T008306 - Levin: "When it comes to the signature of Demjanjuk in fact, no questions were asked in cross examination and, therefore, there is no ground for re-direct on this subject."
- Robertson: "I should have done more examination on the inks, the VSC is apparently not as reliable as I had been led to believe."

W.Z. Summary:
The main points in Robertson's testimony concerning the Trawniki ID card, tav/149, were
(1) Signatures: Teufel and Streibel signatures could be valid; Demjanjuk signature is not valid.
(2) Rust mark of paper clip. The Streibel signature is overtop of rust mark.
(3) Orange mark at back of photograph indicated solvent was used to dissolve glue so as to remove the original photograph and replace it with the Demjanjuk photo.
(4) Staple holes in Demjanjuk photo indicate it had been previously attached to another document. Purple ink in the staple holes was placed there deliberately.
(5) Stamp at bottom of photograph overlapping onto paper
(a) Reddish color of stamp on photo is different from the blue-black color on the paper.
(b) Offset of the swastika wreath indicates that two different stamps were used.
(6) Number on label in photo is 1693 and not 1393; the numeral 1 has been darkened.

During the cross-examination, the strategy of the prosecution and judges was to destroy the credibility and composure of Robertson by attacking her qualifications and testimony during her earlier cases. The viciousness reached the point where Levin actually cautioned Shaked to tone it down.

The prosecution was incredibly well prepared. They appear to have deliberately ambushed Robertson on the luminescence (fluorescence?) of the stamp on the Demjanjuk photo, which really made Robertson look bad. But this is mostly hype. Although Robertson was wrong to state that differences in the fluorescence of the stamp ink on the photo and the paper necessarily proved that two different inks and therefore stamps were used, it is just as wrong to state that that if the fluorescence on the two portions is the same therefore the inks must be the same or that only one stamp had been used.

[My comments on the Cantu testimony is just as valid for Robertson's testimony.]

In my opinion, the defense made a serious error in handling the appearance of the the 3 new ID cards of Juchnowskij, Wolembachow and Bondarenko on August 9, 1987. First, they should have demanded a chain of custody and demanded that someone in the prime minister's office testify as to their receipt. Secondly, they should have demanded that Edna Robertson be given several days to examine the documents. Thirdly, they should have highlighted the discrepancies in all these cards.

The orange spot on the back of the Wolembachow card (similar to the Demjanjuk card) is obviously because the original photo had been re-glued or it had been removed and a new one substituted.

It is interesting that Shaked did not cross-examine Robertson on the Demjanjuk signature.

**** END of Robertson testimony 1987/08/13 and end of Vol. 13 ****

Anita Pritchard; T008312 - 8532; 1987/08/17-19; Vol. 14
[1987/08/17, Mon.; T008312, Vol. 14; Pritchard]
[Top] [1987/08/17] [1987/08/19] [Bottom]

T008312f - Anita Pritchard is Swedish living in Houston, Texas, real school 1959, gymnasia 1972, BA Psychology, Columbia Pacific University 1984, MA Psychology, U. of Oklahoma, PhD candidate Psychology, Columbia Pacific University.
- Studied document examination at San Jose State University in 1981; 5 year membership in World Association of Document Examiners.
- International Graph Analysis Society - certification 1979; Master certification 1980, Western Training Institute 1981. Wrote book "Identify Faces from Handwriting" 1983.
- PhD dissertation "Szondi Test as a diagnostic tool in a clinical setting" accepted and will be defended by end of December 1987.

T008320f - Gill first contacted her on Feb. 20, 1987 and then on June 20, 1987; received documents on June 22, 1987.
- Pritchard: "I was asked to give a statement of an opinion in regard to the visual impact of the manner in which facial montages were made or the visual impact that are made through transparencies, superposition methods."
- Physiognomy (morphology?) is the "systematic correlation of personality characteristics to facial or bodily features" including "the study of mimic expressions and emotions in the human face". "171 different characteristics could be systematically correlated to personality characteristics in the handwriting." "Part of the characteristics as perceived are in the perceiver."

T008331 - Methods of making facial composites.
T008333 - Nun/54 = expert opinion of Anita Pritchard dated July 27, 1987.
T008334 - Nun/55 = update of expert opinion of Pritchard dated Aug. 08, 1987.

T008334f - Pritchard criticizes the methodology of Reinhardt Altman's testimony.
T008340 - Nun/56 = exhibit 1.1 of Anita Pritchard
- Pritchard selected 12 photos of male faces out of 4 magazines and 1 newspaper. Two of the faces could not be matched; the other 10 photos could all be matched with at least one other face and some of them with 2 others. In doing this, she followed the criteria as used by Altman in his composites.

T008344 - Nun/57 = exhibit 1.2 of Anita Pritchard,
- showing different degrees of facial matching.

T008345 - Nun/58 = exhibit 1.3 of Anita Pritchard
T008346 - Nun/59 = exhibit 1.4 of Anita Pritchard
T008348 - Nun/60 = collection of publications from which nun/56-59 were taken.
T008349 - Pritchard: "In other words, the photographic collages of the twins demonstrate again that recognition of faces are based on the right side of the face." "Mouth had greater importance than eyes."

T008351 - Nun/61 = exhibit 2 (photographs) of Anita Pritchard,
- matching faces of a person ages 3 and 25.

T008353 - Levin asks Pritchard to try to make full composite faces from the halves she has demonstrated for the following day.

T008357 - Nun/62 = 4 composites of Trawniki ID photo (tav/149) and the German driver's license photo (tav/21?) and also from the American Naturalization Certificate (tav/??) (Pritchard exhibit 4)
- "We see no closer matching than seen in the random selection."

T008359 - Pritchard points out a scar on the rim of the right ear of the Trawniki ID card (which may be a photographic defect).

T008360 - Pritchard refers to a fraying hole in facial contour of 62.1
T008361 - Nun/63 = facial composites of known 3 (German driver's license) and known 5 (American Naturalization Certificate) (Pritchard exhibit 5)
- [Nun/63.1 = RHS of known 3 and LHS of known 5; nun/63.2 = RHS of 5 and LHS of 3]

T008364 - Nun/64 = reconstruction of Altman's tav/150
- Pritchard goes through a whole series of composites and reconstructions.

T008372 - Pritchard: "That photograph has been altered through omission or removal of the mid section of the photograph" ... "constitutes a change in the physiognomy of the individual."
- [Referring to photos 17 and 18 of Altman.]
- Pritchard continues with photo-montages 19-20 and 21-22 of Altman tav/150.

T008377 - The right side of a face is seen with the left eye and is processed in the right side of the brain, which is responsible for recognition.

T008380 - MISSING
T008381 - Nun/65 = set of samples (Pritchard exhibit 7)
- The Human Brain (1977), excerpts therefrom - distortion, perception, illusion.

T008392f - Pritchard refers to superpositions in nun/56
- "The same phenomenon was experienced in watching the tape of the TV evidence that I received. The session was simply of a fit of the superposed image onto the photograph or the video image of the known Demjanjuk."

T008395f - Shaked objects as to relevancy of testimony. Long discussion.
T008402 - Levin: "Now Professor Smith introduced a certain theory and proved it and Mr. Altman also proved it." ... "The present witness has not really made any reference to that or attempted to grapple with it."

T008403 - Robertson: "To my awareness, I don't know what kind of acceptance or of any criterion for facial montages in the field of forensic study." ... "I had neither heard, read or attended any seminars in document examination in which facial composites have been discussed."

T008404 - Gill: "That concludes the questions that I have at this time." [Surprise!]

T008407 - Levin: "..., the defense does not propose to put Mrs. Demjanjuk on the witness stand."
T008409 - Levin adjourns Aug. 17 session, cancels Aug. 18, to reconvene on Wed., Aug. 19, 1987.

Anita Pritchard; T008410 - 8532; 1987/08/19; Vol. 14
[1987/08/19, Wed.; T008410, Vol. 14; Pritchard]
[Top] [1987/08/17] [1987/08/19] [Bottom]

T008410f - Pritchard making comments after perusing the original tav/150.
- She retracts her qualified opinion of Aug. 8, 1987, because she could not detect changes in the original composites of Altman, which she saw in the photocopies.

T008412 - Nun/67b = composite of age 3 to 25 image as requested by Levin.
T008413 - Sheftel has Pritchard testify that "identifying a face on the basis of photographs by the use of morphological features is not a recognized science."

T008416f - Shaked cross-examination of Anita Pritchard.
- points out that she is not an expert on morphology.
- Shaked objects to her use of the term "random selection".

T008431 - Tav/233 = excerpt from book by William Hayes on statistics.
- Shaked objects to Pritchard's use of terms such as scientific study, comparative study.

T008451 - Tav/234 = excerpts from book of Solomon Diamant concerning psychology (1974)
T008452 - Tav/235 = excerpts from book of Melvin Marks, Introduction to Psychology (1976)
T008453f - Shaked discredits Szondi Test , physiognomy, etc.
T008466 - Tav/236 = photograph of blackboard on which Pritchard drew explanation of facial recognition via the right side of the brain.

T008469 - Tav/237 = article of James Kelly in book of Kandel and Schwartz concerning the retina of the eye.
T008481 - Shaked: "You can't have it both ways, if you say that you are not an expert of perception and you will retract your expert opinion, well, then I won't cross-examine you." [Blackmail?]

T008485 - MISSING
T008486 - Shaked questions Pritchard about WADE, which he has already attacked during Robertson testimony.

T008515 - Tav/239 = catalogue of APA
T008516 - Judges question Pritchard about not finding any references of photographic montages for identification purposes.

T008520f - Sheftel re-direct of Pritchard.
T008523 - Pritchard: "I do not think one has to know everything there is or even be an expert in biology or neurology in order to know how visual impressions affect an individual."

T008525f - Sheftel asks Pritchard about left side - right side recognition to which Shaked objects. Levin threatens to have Shaked resume cross-examination and Sheftel withdraws.

T008528 - Levin: "And it was a very unpleasant experience for the witness, so if you wish to re-open the subject, go ahead, put your question, and the prosecution would then be able to complete its cross-examination on the subject."

[W.Z. Summary: Really not much to say. Pritchard was battered, bruised and blue by the time Shaked got through with her. The two witnesses recruited by Gill were really attacked. Sheftel seemed to take over the defense from Gill towards the end.

The purpose of Pritchard's testimony was to discredit the circus-like visual presentations of Patricia Smith and Reinhardt Altman. She made valid points but they seemed lost in the tirade of abuse heaped on her. She should have asked Shaked to read out the dictionary definition of perception.]

**** END of Pritchard testimony on 1987/08/19 and in Vol. 14 ****
**** **** BREAK UNTIL MONDAY, OCTOBER 26, 1987 **** ****

Avraham Shiffrin; T008533 - 8845; 1987/10/26-28; Vol. 14
[1987/10/26, Mon.; T008533, Vol. 14; Shiffrin]
[Top] [1987/10/26] [1987/10/27] [1987/10/28] [Bottom]

T008533 - Gill welcomes Judge Tal (who was sick) back.
T008534 - Blatman objects to Shiffrin testimony which is a list of KGB evils.
T008540 - Sheftel is going to call on Prof. Buchner to testify on Nov. 16, 1987, which he discussed with Shaked.
- [W.Z. I NEVER HEARD OF HIM.]

T008547 - Levin: "Well, if Mr. Hammer is going to be mentioned by this witness, we are going to overrule the question, Mr. Sheftel."
- [W.Z. After the trial and shortly after his death, it has been confirmed that Armand Hammer was a KGB agent. Since Armand Hammer was instrumental in obtaining the Trawniki ID card for the Israelis, the judges are extremely sensitive about the issue.]

T008548 - Sheftel: "And we all know that this whole interrogation of the accused, started out by the information which reached the OSI in the United States from such sources."
- "Certain Soviet forgeries which were supposed to harm the National Ukrainian Movement ..."
- "..., the KGB and the Jews."

T008549 - Levin: "The accused belongs to the Ukrainian nation, not the Jewish nation."
- Sheftel: "For instance, the Zionist Organization was, in fact, involved with the Nazi extermination of the Jews."

T008552 - Blatman: "Therefore, Your Honor, we insist that this whole story, this entire story of how the USSR relates to lies, ..."

T008556 - Levin rules that they will listen to Shiffrin's testimony about KGB forging capabilities, but will not allow specific cases.

T008557 - Sheftel direct examination of Shiffrin.
T008559f - Shiffrin was born in Soviet Union in 1923, recruited into Red Army in 1941, participated in the defense of Moscow, defense front of Leningrad, wounded twice, ended war with rank of Captain, got 4 medals, leg amputated due to gangrene.
- After war Shiffrin was appointed chief investigator of Krasnokrovsky Krai on the shores of the Black Sea. Transferred to general prosecutor's office in Moscow, then to Tula region (because anti-Semitic campaign got under way in 1948).

T008564 - Shiffrin: "..., it became known to me that the KGB consulted me in order to fabricate dossiers on people who had fled from the Soviet Union."

T008565 - Shiffrin: "I was arrested in 1953 after the death of Stalin. I was accused of espionage for the United States and Israel."
- [W.Z. I wonder if him being part of Beria's terror apparatus had anything to do with it?]

T008566 - "I was sentenced to death which was later commuted to 25 years imprisonment, 5 years of exile and another 5 years of denial of rights." ....Siberia

T008567 - Levin: "You are a highly learned and respected person. You are a learned scholar."
- [Note the respect Levin shows a Jewish witness as contrasted to the 3 previous witnesses!]

T008572 - After 10 years, Shiffrin was sent to 4 years exile in Kazakhstan, in 1967 he went to Odessa to friends who were very active in Zionist movement there.

T008574 - Shiffrin came to Israel in 1970.
- in 1973 he testified before U.S. Senate Committee on KGB; anti-Semitism in the Soviet Union; arms industry. Later gave lectures.

T008577 - Shiffrin: "In 1973 we set up a research center on oppression of the KGB" in Israel. They published more than 20 studies, a book "A first Guide to the Concentration Camps and Psychiatric Prisons in the Soviet Union" in 1985, and a film "Imprisonment".

T008582 - Nun/68 = list of over 20 publications of Avraham Shiffrin's Research Center.
T008583 - Shiffrin: "Therefore, my job is, because I'm aware of their activities, to concentrate and serve as a sort of co-ordination center for the activities of these national liberation movements."

T008585 - Shiffrin: "Yes, but all this is connected to the defense of the Prisoners of Zion and other detainees in the Soviet Union."

T008586f - Levin disallows a question from Sheftel re "Jews who had served in Vlasov's Army."
T008592 - Levin: "We have said that we would hear his evidence about the KGB on two matters only - on policies regarding forgeries and on the attitude of the KGB to the Ukrainian nation."

T008593f - Levin overrules showing a film on Soviet concentration camps.
- Sheftel: "There is a specific [reference] relating to the Ukrainian people, Ukrainian clergy. There is specific relevance, specific relating and referring to it in certain pictures of the film."

T008600 - Shiffrin translates Russian writing from tav/149.
- "The fourth division of the KGB, 14 March, 1943"
- NGB [MGB?] is previous name of KGB.

T008601 - Shiffrin: "The forgery of documents is perhaps the best known function of the KGB as known in the free world."

T008608-9 - MISSING
T008611 - Vladislav "Bitman spoke about thousands of documents which were placed into six crates and were drowned in the bottom of a lake."
- "I also saw Reagan, Schultz, Clark and other politicians forged signatures."

T008616 - "When the leader of the National Ukrainian Liberation forces, Bandera, was killed in an ambush, the KGB published the forged statement by Nisbi as if he had killed Bandera. That he had killed Bandera upon the instruction of German intelligence."
- Levin: "..., witness is not to report specific cases but rather the methods of forgery, different methods, whether it was a forging of stamps, of signatures, ..."

T008618 - Levin adjourns session so that Sheftel can brief Shiffrin as to what is allowable testimony.

Avraham Shiffrin; T008619 - 8730; 1987/10/27; Vol. 14
[1987/10/27, Tue.; T008619, Vol. 14; Shiffrin]
[Top] [1987/10/26] [1987/10/27] [1987/10/28] [Bottom]

T008619 - MISSING
T008620f - Of the 10 units of the KGB, the Technical Division is responsible for preparing forged documents.
- "The Technical Unit and its forgery sub-division have access to a very large archive of documents compiled during WWII."

T008625 - Shiffrin: "I know exactly from my conversations with KGB workers that the archives taken out of Germany were stored in KGB warehouses."

T008626 - Nikolai Hachlov [Chofloff?] worked in the Assassinations Department of the KGB, defected to West and wrote "Right to Conscience".
- Shiffrin's main sources were Hachlov, Vladislav Bitman, Petro Deriaban; the latter two of which "were in charge of disseminating false information in the West".

T008630 - "... continual process of forgery against the Ukrainian National Movement of Bandera. A movement which originally was a national liberation movement and also anti-fascist. A movement which the Germans wanted to liquidate, and whose members were shot by them. Creating forged documents against such a movement, created the sort of situation where throughout the world today, it is felt that this is a Fascist Movement."
- As a result of KGB forgery and propaganda "the Bandera Movement in the Soviet Union is identical with Fascist".

T008631 - Katyn Forest Massacre eyewitnesses "have been in the Vladimir prison for more than 45 years, because they were actually witnesses to this murder at Katyn".

T008632 - Igor Levine, an ordinary seaman, defected to Canada in 1943. KGB sent a forged criminal case to Canadian government accusing him of rape.

T008633 - To Levin's skepticism that KGB would frame ordinary people, Shiffrin replies, "Because people should be frightened at all levels."

T008634 - Shiffrin points out that KGB prefers to use samples of documents already partially filled out. "No need to forge the whole of the document."

T008637 - Levin will not allow Sheftel to submit an organigram of KGB structure responsible for defaming Ukrainian Liberation Movement.

T008638 - Deportation of kulaks during collectivization: "Out of the 10 million who went to Siberia, 4 million died on way to Siberia."

T008640 - "At least 2 million Ukrainians went over to the Germans from the Red Army."
T008641 - Shiffrin questioned UPA members Gorbovoy (Shukhevich's son), Cardinal Slipyj, Duboy in the camps "about the history of UPA, which is why I know it so thoroughly".
- War between UPA and KGB in Western Ukraine: "It is astonishing that the Ukrainians managed to hold on during this struggle from 1945 to 1951."

T008643f - Shiffrin refers to famine in Ukraine after WWII; hundreds of thousands sent to concentration camps; after sentences were completed they were not allowed to return to Western Ukraine.

T008645 - KGB deliberately "began creating strife between Ukrainians and Russians"
- "I personally witnessed many cases in which many thousands of people were slaughtered."

T008653 - "This tendency of a certain rapprochement between the two peoples [Ukrainians and Jews] is regarded as most dangerous by the KGB." ... KGB has "issued many books concerning strife between Ukrainians and Jews and pitting one against the other".
- "because tomorrow when the verdict will have been pronounced, the KGB will say that the whole thing was based on false documents and will be interpreted against Israel."

T008655f - Blatman cross-examination of Shiffrin.
- Shiffrin will try to respond in Hebrew but will shift to Russian if necessary.

T008658 - Shiffrin testified in Feb. 1973 before the Committee on Internal Security on the Judiciary, United States Senate.

T008660 - He also testified before the Internal Security Department of the Congress on the subject of anti-Semitism both in the USSR and in the USA.

T008661 - "... both in the Senate and Congress a great deal was talked about detente."
T008863 - "from Golda Meir and others, I had been given instructions not to give out anything."
T008667 - Shiffrin brought along a box of books sent to him recently by Senate Committee.

T008671 - Shiffrin refuses to divulge name of person from Senate Committee who showed him the KGB forged documents, which the US authorities had confirmed.

T008683 - Tav/240 = Vladislav Bitman's testimony before Senate Committee.
- Big argument whether Bitman referred to "forged" documents

T008691f - Tav/241 = book by Vladislav Bitman, "The Deception Game".
- Presumably, Operation Neptune (documents at bottom of lake) induced West German government to remove statute of limitations on war crimes.

T008703f - Gillerstein is director of Para-Psychological Institute in Soviet Union with whom Shiffrin has had contact.
- Blatman questions Shiffrin about 3 interviews on para-psychology.

T008706 - Tav/242 = article in Yediot Achronot, May 6, 1976 re para-psychology
- Tav/243 = article in Bamachine, Nov. 26, 1981 re para-psychology

T008715 - Tav/244 = article in Yediot Achronot, Dec. 16, 1983 re para-psychology

T008722 - Mr. Gillerstein asked Shiffrin to work at the Para-Psychology Institute, but Shiffrin declined and went into exile.

T008725 - Penal battalion in Red Army, fought without arms, get weapons from Nazis, KGB behind with machineguns, wounded Jan. 1, 1942, sent to penal battalion again and wounded again, gave different name and year of birth, recovered and sent to regular unit, promoted to lieutenant, KGB no longer harassed me, finished war with rank of captain.

T008728f - Person in charge of Shiffrin at Defense Ministry in June 1953 was also Jewish, Alexander Lieberman (not Rabinowitz as stated in his book and prompted by his wife, who was ejected from the hall).

T008730 - Blatman: "When you came to Israel in 1970, and when you were asked to tell about your life in the Soviet Army, you didn't even mention that [penal] battalion."

Avraham Shiffrin; T008731 - 8845; 1987/10/28; Vol. 14
[1987/10/28, Wed.; T008731, Vol. 14; Shiffrin]
[Top] [1987/10/26] [1987/10/27] [1987/10/28] [Bottom]

T008731f - Shiffrin offers to give the surname of the senior official in Washington to the court only, but not to the prosecution or defense. Levin and Shaked refuse.

T008736 - Bitman "says that between 50-60% of the documents, which we used in the 115 operations against the West, are based on false documents. Later he speaks about 16 samples of actual forgeries."

T008744 - Blatman insists that Operation Neptune used only authentic documents; whereas Shiffrin insists that the whole operation was a disinformation campaign.

T008757f - Headquarters of Shiffrin's institute is his own flat and very few of the 20 researchers actually do any research.

T008760 - Shiffrin studied law under a pseudonym, continued studying by correspondence after the war, but didn't receive diploma because he was arrested.
- [W.Z. WHAT WAS HIS PSEUDONYM?]

T008763f - After arriving in Israel in October 1970, his biography stated he was drafted in September 1941, conscripted into Infantry Division 217 in October 1941, no training, mobilized for battle and received rank of senior lieutenant in November 1941.
- It doesn't say anything about penal battalion or rank of captain.

T008769 - Tav/245 = biographical protocol of Shiffrin dated Aug. 12, 1970.
- Tav/246 = 3 pages of Shiffrin testimony before sub-committee of Congress.

T008770 - Shiffrin's leg was amputated in 1969.
T008772 - Ibragim Shiffrin was his pseudonym. KGB indicated "That I was not revealed, because I had merely changed my first name, not my family name."
- [W.Z. Hard to believe and possibly not true.]

T008774 - Shiffrin was arrested on June 6, 1953 after KGB found his father's file and Beria was removed [shot] sometime later.
- [Josef Stalin died March 5, 1953; Lavrenti Beria was shot December 23, 1953.]

T008776 - Nikolai Chofloff [Hachlov] was with Department of Assassinations of KGB until he defected to West 30 years ago; graduated from Duke University and is a full professor of psychology at University of California. He is a renowned expert on para-psychology; sent to Israel twice to conduct talks on subject.
- [W.Z. Quite a metamorphosis from an assassin to a respected professor!]

T008776f - Blatman: John Baron's book "The KGB, the Secret Work of Soviet Secret Agent, John Baron" states that Chofloff [Hachlov] was assassinated by KGB in 1957.
- Shiffrin insists that Chofloff is alive, he talked to him, an attempt was made to poison him with thallium.

T008779 - Tal reads from book that Chofloff has remained bald and scarred.
T008783 - Blatman apologizes.
- Shiffrin: "I only know exactly that I did speak with Hochlov [Hachlov, Chofloff] on the phone two weeks ago." [WHY?]

T008789f - According to a letter dated July 20, 1977, Shiffrin was "not recognized as a Prisoner of Zion"
- Shiffrin says that by 1972 he had severed all ties with this organization, "because they never took any steps for the sake of Prisoners of Zion".
- Levin chastises him for the comment.

T008793f - Discussion of Katyn [Forest Massacre].
- Blatman seems to support the 1944 whitewash report of the Soviets, while Shiffrin supports the original 1942 International report.

T008807 - Tav/247 = 1944(?) Report of the Soviet Commission on the Katyn Forest Massacre.
- Tav/247a = pages 36 and 37 thereof.

T008812 - Shiffrin seems to think that false German documents were thrown into the graves at the time of the Massacre [April 1940] and not in 1944 at the time of the Soviet Commission.
- [W.Z. In my opinion, this seriously undermines Shiffrin's credibility as an expert witness.]

T008816 - Shiffrin is not familiar with the book "Ukrainian Nationalism" by John Armstrong.

T008818f - Sheftel re-direct of Shiffrin.
T008820 - From Vladislav Bitman compendium re Operation Neptune: "It was a campaign which lasted for about two years. A campaign actually manipulated against the West German establishment."

T008824 - Nun/69 = compendium of Shiffrin testimony before U.S. Senate Committee.
T008825 - Levin refuses Sheftel to submit Shiffrin's book on Soviet Concentration Camps as a defense exhibit.

T00827 - Shiffrin belongs to organizations Association for the Struggle for a Free Yugoslavia, headed by Mikhail Mikhailov; Association for the Freedom of Nations.

T008833 - Shiffrin's 3 sources of information about Katyn Forest Massacre: Karavansky report; book "Death at Katyn"; Avraham Kalinsky in Israel.

T008839 - Nun/70 = Arthur Koestler's book (on para-psychology?)
T008840 - Nun/71 = Shiffrin's quarterly publication on para-psychology.
T008841 - MISSING
T008845 - **** END Shiffrin testimony 1987/10/28 in Vol. 14 ****

[W.Z. Summary: In my opinion, Shiffrin's life story, as revealed in his testimony, should be taken with a grain of salt. He was obviously a privileged member of the KGB repressive organs before becoming an inhabitant of the Soviet Gulags. Since immigrating to Israel in 1970, he has been promoting himself as a VIP with access to important people.

Nevertheless, he came out strongly in favor of the Ukrainian Liberation Movement, Bandera and the UPA. We note that in the cross-examination the prosecution steered clear of this subject and concentrated on the Katyn Forest Massacre and defectors like Vladislav Bitman, Nikolai Hachlov(?), John Baron.

Why didn't Sheftel have Shiffrin view the 4 Trawniki ID cards and have Shiffrin comment on methods of forgery?]

Rogatories; T008846 - 8903; 1987/10/29; Vol. 14
[1987/10/29, Thu.; T008846, Vol. 14; Rogatories]
[Top] [1987/10/29] [Bottom]

T008846 - MISSING
T008851f - Sheftel: The prosecution "had already completed the interrogation of Alfred Bracha and if the contents of the tape had been in the hands of the defense at the onset of the cross-examination ..." cross-examination [by Counsel Kadar] would have been different.
- Similar concerns with May 1987 testimonies of Leonhardt and Otto Horn, which was before the arrival on August 9, 1987 of 3 new Trawniki ID documents.

T008853 - Levin: "Because this material [the 3 new Trawniki ID cards, tav/222, 223, 224] has not been received into evidence as far as we are concerned."
- [But Shaked did question Robertson on the raised 3rd dot after the word mantel, the orange spot behind Wolembachow's photo, color of stamp on photo and paper.]

T008856 - Sheftel: "... tav/222, 223, 224 do not contain Streibel's signature."
- [W.Z. Not true. Tav/224, the Bondarenko card, does have the Streibel signature. It also has a scrawled Bondarenko signature; whereas the other two cards do not have the signature of Juchnowskij and Wolembachow.]

T008857 - Sheftel: On tav/149 Demjanjuk serial number 1393, Teufel had a rank of Rottenbannfuhrer. But in tav/223 Wolembachow serial number 1211, the rank of Teufel is higher, even though it had presumably been issued earlier.

T008858 - Horowitz questioned Leonhardt and Mr. O'Connor used Mr. Stratman, a local attorney, who was not allowed to ask a question.
- Levin: "In Berlin, too, in Horn's testimony, where we were present, the same thing happened and there this lawyer was not permitted to put questions to the witness ..."

T008860 - Sheftel: Leonhardt "claims that the Russian was designed to translate for the Wachmanner who didn't know German and to tell them what it means."
- [This refers to the Russian handwriting by Bazelevskaya presumably in 1948. Sheftel scorns Leonhardt's expertise.]
- Leonhardt had no opportunity to see the other 3 ID cards.

T008862 - Sheftel: "Ever since 1979, we see that the OSI is in contact with the Russians and does ask them precisely for documents of the type that these three documents represent, tav/222, 223, 224."
- [That is why the Demjanjuk defense should have insisted on a chain of custody of these 3 new cards. For all we know they could have come from Israel, Germany or the moon.]

T008864 - At the Leonhardt rogatory Horowitz demanded that Stratman be removed from the court, even though Horowitz had Mrs. Etti Chai with him.

T008865f - Otto Horn testimony
- Sheftel refers to Nov. 20, 1979 deposition of Bernard Dougherty, which was fortunately retrieved from the trash bins of the OSI.
- This document was hidden by the OSI and not given to either the prosecution or the defense.
- This document differs substantially from the two that Dougherty wrote in May and December 1986.
- Horn did not identify the Trawniki ID photo and he even said that a different photo was vaguely familiar to him. Only later when the 1951 series of photos was shown to him did he make the connection between the two Demjanjuk photos.

T008871f - Garand deposition
- Garand's 1979 deposition, "Horn stated that he never witnessed Ivan beating, shooting or otherwise abusing any of the prisoners."
- "and in 1986 he says something totally different."

T008872f - Horowitz: "... Mr. O'Connor conduct 3 day long cross-examination of Leonhardt."
- Stratman had been at hearing of Kurt Franz; Rav Paked Chai helped Horowitz.
- Horowitz feels that knowledge of Dougherty's and Garand's 1979 depositions would not have affected O'Connor's cross-examination substantially.

T008881 - Tav/248 = testimony of Helmut Leonhardt in Koln [Cologne], West Germany, May ??, 1987.
- Tav/249 = testimony of Otto Horn in West Berlin, May ??, 1987.
- Tav/248a = personalbogen of Wachmann Demintrenko [Dmitrenko?]

T008885 - Tav/250 = drawing of Treblinka camp with Otto Horn markings.
- Tav/251 = photos shown Horn in Germany marked DBII [DB2?] dated 1951.
- Tav/252 = photos shown Horn in Germany marked DBIII [DB3?] dated 1942.

T008887 - Nun/72 = deposition of Horn at Berlin police, July 23, 1986 marked DB6.
- Nun/72a = deposition of Horn dated Aug. 19, 1983.

T008888 - Nun/72b = memorandum of Superintendent Kirschov dated July 29, 1983(?) or 1986(?).
- Horowitz: "Berlin Document Center which is run by American authorities."

T008889 - Tav/253a = original photographs, copies of which make up tav/251
- Tav/253b = original photographs, copies of which make up tav/252
-Tav/254 = deposition of Otto Horn before Judge Miller on July 25, 1986.

T008890 - Nun/73 = photo album of SS personnel who served at Treblinka,
and which were presented to Horn by the defense.
- Nun/74 = "letter by Dougherty to deputy OSI director" [Nov. 20, 1979?]

T008893 -Dorner: "... certain information that Streibel at a certain juncture disputed or rather denied that this was his signature ..." on the Trawniki ID card, tav/149.

T008897 - Sheftel: Affidavit of Streibel stating that "to the best of his recollection, he had never seen anything like tav/149 and he had never signed anything like it ..."
- Sheffler claimed that if Streibel confessed that it was his signature, he would be prosecuted again.

T008898 - Proposed witness Dr. Gertz says that this isn't true, and is scheduled to testify in week beginning Nov. 9, 1987.
- Shaked withdraws his objection.

T008900 - Discussion as to how to rectify errors of translation of Demjanjuk's testimony in Ukrainian into Hebrew. Audio cassettes of Demjanjuk's testimony will be made available to the defense for correction purposes.

T008903 - **** END of rogatories 1987/10/29 and END of Vol. 14 ****