Documents Submitted to the Court After the Filing of the Memorial
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DOCUMENTS SUBMITTED TO THE COURT AFTER THE FILING OF THE MEMORIAL DOCUMENTS PRESENTES À LA COUR APRÈS LE DÉPOT DU MEMOIRE Washington, 14 March 1980. In response to your inquiry, the following information is provided to assist in establishing the reportoriai accuracy and authenticitg of the Foreign Broadwsi Information Service (FBIS) Daily Report items cited in the US Memorial filed in the litigation berore the International Court of Justice. We have attcmpted to provide a more detailed description of the FBIS Daily Report as well as some insighi into the manner in which the reporting is collected, assemblcd and dissemina ted. FBIS may be described as follows: the Foreign Broadcast Information Service, with some minor changes in title, has nionitored foreign media on bchalf of the US Government since the spring of 1941. Duririg World War II it was the prirnary source of information from the Axis radios, first from Germany and Itüty, and aller Deccmbcr 1941 from Japan and the areas under their control. In addition to monitoring foreign radio broadcasts, television and press agcncies, FRJS also has had the rcsponsihility since 1967 for translating foreign publica- tions as a service of common concern to US departmcnts and agencies. FBIS disseminates its product to al1 interested agencics of the US Governrnent. Its publications are available io the public in the United States and abroad by subscription through the National Technical Information Service (NTIS) of the US Department of Commerce. The FBIS Daily Repurf is a compilation of significant material monitored from foreign news media selected initially on the basis of potential inlcrcst to the US Gaverninent. It includes translations of foreign leilder speeches, government statements, official communiqués and interviews; major editorials, articles and commentaries; und ncws reports on significant political, cconomic, cultural and scientific developmcnts. It is published daily Mondily through Friday and is divided into eight gcographic volumes-People's Republic of China, Eastern Europe, Soviet Union, Asia and Pacific, Middle East and North Africa, Latin America, Western Europc, and Sub-Saharan Africa. Together the eight volumes carry about 210,000 words in 400 pages each dey. Thcy are printed overnight for distribution the ncxt rnorning in more than 7,000 copies distributed throughout the Government. Both paper and microfiche versions are available to the public in the US and abroad by subscription through NTIS. NTIS distributes more than 1,000 copies of the Doily Report. The Daily Report has a wide rcputation as a reliable and accurate source of current information on international affairs and is used as a rescarch aid by the US Government as well as the press, academic institutions and librarics. FBIS mat.eriats, including those used in the Baily Report, are derived from public radio and tclcvision broadcasts that are elecironically recordcd, press agency news rcports, and printed media such as newspapers and magazines. Audio recordings of radio and television news broadcasts are normally trans- lated into English direct from the original tape at the facility which madc the recording. The English language version of the item is then transmitted to ' See p. 513, infra. 330 DIPLOMATICAND CONSULAR STAFF Washington, DC, where the formalized daily publications of the FBIS are produced and disseminated. Given the high volume of recorded matter, it is not economically feasible to store the tapes for more than a temporary period. Typically they are erased and re-uscd within 30 days. Being able to retneve the original recordings of the FBIS items cited in the Mernorial thus is problematical at best. Because of their dates it is not reasonable to cxpect that many, if any. have not been re-used by this date. (Signed) John F. PEREIRA. 1. Student Staterncnt No. 91 LD 1 1 1750 Tehran Domestic Service in Persian, 1630 GMT, I 1 Jan. 80 LD. [Statemcnt No. 91 issucd "on the eve of the first lslamic Iranian presidential clcction'", by the Muslim Student Followers of the Imam's Policy; date not givcn -read by announcer.] [Text] In the name of God, the merciïul, the compassionate. The aleri and revolutionary lranian nation: The lslamic Revolution of Iran, ied by the Imam of the nation, the great Khorneini, put an end to monarchy in its first triumphant step and overthrew the corrupi and black Pahlavi régime. It has swiftly taken sieps to strengthen the Islamic Revolution, one of the greatest aspects of which is the stability of the Islarnic Republic. Toward this, having held a referendum, it succcsfully formulated and changed the constitution dunng its second vital and sensitive stage, despite al\ plots and atiacks. Now ihat the dear nation is in the proccss of electing its first president with ils own haiids, crirninal America has cxpanded the dimension of its plots to such an extent that it has even interfcred in the work of presidential candidates. Fortunately, the interference and plots by the great enemy, the criminal America, airncd ut disgracingkhe lsiamie RepuMic were discovered and then foiled by the Iranian pcoplc and exposed to the world. 2. Latin: Gotbzadeh Sends "Intransigcnt" Messages to the United Nations PA132022 Buenos Aires Latin in Spanish, 1919 GMT, 13 Jan. 80, PA. [By Paul Taylor.] [Texî] Tehran, 13 Jan. (Latin-Rcutcr)-ln an iniransigent message to United Nations Secretary-General Kurt Waldheim, lran stated that not even the formation of a committee by that international organization to study the charges against the deposed Shah would end the crisis between Tehran and Washington. The texi of lranian Foreign Minister Sadeq Gotbzadeh's message to Waldheim was published today by the Tehran daily Bamdad Informed sources have confirmed its authenticity. The message, which last night postponed a vote on economic sanctions against lran in the Security Council, made no reference to ihe 50 US hostagcs imprisoned in the US Embüssy in Tehran, which arc the cause of the request for sanctions. The group of Muslim students occupying the US Embassy for the pas1 10 weeks said it had no knowledgc of the Gotbzadeh message, but that its position is unchanged. "Our demands have not bccn modificd. The hostagcs will not be released until the Shah and his money are returned to Iran", a stiident spokesman told this agency. He added ihat lhey are sure that rcvolutionary leader Ayatollah Ruhollah Khomeini has not changed his position on the problem. The lranian Foreign Minister's lettcr made rcference to proposais discussed with Waldheim during his visit 10 lran 10 days ago to the effect that the United 332 DlPLOMATlC AND CONSULAR STAFF Nations would invcstigate the violation of human nghts under the Shah's government. "The only solution is that we talk about this. Naturally, the mere formation of this committee or the outlining of its views will not in itsclf solve any problem", stated the lelter. "Our demands for the extradition of the Shah and his properties must be confronted in a legal way", he said. He did not mention the release of the hostages. The letter concluded on a chalienging note: "Therefore, 1 once again declare that if the decisions of the Security Council are not based on the acceptance and implementation of our desires, they will be considered empty from our point of view." 3. Gotbzadeh on Hostages' Release OW140516 Hong Kong AFP in English, 0512 GMT, 14 Jan. 80 OW. [Text] 'Tehran, 14 Jan. (AFPjlranian Foreign Minister Sadeq Gotbzadeh said here today that the American hostages held by militants at the Tehran Embassy could bc released only after total acceptance of three demands presented by Iran to United Nations Secretary-General Kurt Waldheim. He said the three points were: Creation of an international committee to investigate the "crimes" committed by the Shah of lran during his reign. -Recognition by the United Nations of Iran's right to demand extradition of the Shah (who is currently living out his exile on the Panamanian island of Contadora). -Recognition of Iran's claim to the imperial family's wealth and property. Mr. Gotbzadeh, who held a brief press conference at Tehran airport before flying to the south of the country, said that inquiry into the Shah's "crimes" would not in itself be enough to obtain freedom for the hostages who have been held at the US Embassy in Tehran since 4 November. The Foreign Minister said that if sanctions were applied against his country, they "would have no efect", and that if the United States persisted in trying to have sanctions imposed, the result would be contrary to what Washington was trying to obtain. Asked about possible Iranian reprisais against countries which voted for sanctions, Mr. Gotbzadeh would only say that "the question would have to be studied". 4. Gotbzadeh Press Conference JN140935 Tehran International Service in Arabic, 0800 GMT, 14 Jan. 80 JN. [Text] Speaking about the United Nations Security Council resolutions at a press conference held at Mehrabad International Airport, Foreign Minister Sadeq Gotbzadeh has said: 1 have often told United Nations Secretary-General Waldheim that if the Security Council votes in favour of imposing an economic boycott on Iran, it would have marched in a direction contrary to the solution of the crisis, and that the United States pressures against Iran will aggravate the situation, The Iranian Foreign Minister denied reports which have been reitcrated, that Iran is ready to enter into negotiations on the release of the hostages. Hc süid international news agencies under the control of dirty Zionism are distorting facts and that certain domestic news media are falsifying reports. The Foreign Minister added: The issue of the hostages release loses its contcxt without the extradition of the deposed Shah. DOCUMENTS 333 5. Unaccepiability of United Nations Decisions LD141058 Tehran Domestic Service in Persian, 1030 GMT, 14 Jan.