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Terrorism
Sterio, M. (2012). Katyn forest massacre: Of genocide, state, lies, and secrecy. Case Western Reserve Journal of International Law, 44 (3), 615-631.

Introduction

Katyn Forest, a wooded area near the village of Gneizdovo outside the Russian city of Smolensk, was the scene in early 1940 of a wholesale killing by the Soviet NKVD (Narodny Komissariat Vnutrennykh Del), or secret police. The soviets targeted over 22,000 Polish intelligentsia—military, officers, doctors, engineers, police officers, and teachers—which Stalin, the Soviet leader, sought to eradicate preventively (Sterio, 2012). For 50 years, this massacre was subject to a massive cover up. Initially the Soviet Union blamed the Nazis for the murders, saying that the killings took place in 1941 when the territory was in German hands. It was not until 1990 that the Russian government admitted that the executions actually took place in 1940 and were carried out by the Soviet secret police. In 1990, Russian prosecutors launched a criminal investigation into the massacre, but the case was terminated in 2004, its findings were classified as top secret, and it appeared that the tragedy would once again be subject to "historical amnesia."
Discussion
The Poles fell as POWs into Soviet hands just after the Soviet Red Army occupied the eastern half of Poland under the terms of two notorious Molotov-Ribbentrop pacts: the Nazi-Soviet agreements signed between the USSR and Nazi Germany in August and September 1939. The crime, committed on Stalin's personal orders at the opening of World War II, is often referred to as the Katyn Massacre or the Katyn Forest Massacre.
These first deaths came after one of the most notorious of several repressions by the Stalin regime against Poles. In 1939, notes Robert Conquest, besides the 440,000 Polish civilians sent to Soviet concentration camps as a result of the Soviet occupation of eastern Poland beginning in September, the Soviets took 200,000 POWs during the Red Army's

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