Kreis, the representative of artisans; Bograd, the representative of the
   Poalej-Zion Party.
   Petlura addressed the Delegation with a short speech in which he declared
   that he himself as well as the government were always standing on the
   side of the Jewish people, and were waging war against those elements who
   incited the unenlightened masses to various excesses against Jews. The
   Commander-in-Chief invited the representatives of the Jewish people to a
   closer cooperation of both peoples for the good of the Ukrainian State,
   for, only with united forces would it be possible to look after the
   interests of both peoples, which had always been identical.
   The Jewish delegation assured the Supreme Commander that all strata of
   the Jewish people, hand-in-hand with the Ukrainian people, would defend
   the independent Ukraine, because only a Ukrainian democratic government
   could guarantee full rights to the Jews. The delegation asked for
   granting of an opportunity to Jewish intellectuals to work toward
   strengthening Ukrainian statehood, and for protection of the Jewish
   population against the excesses which have taken place as the result of
   provocation on the part of various Russian reactionaries and Polish
   imperialists who thus wish to discredit the whole Ukrainian cause in the
   eyes of Europe.
   Petlura pledged himself to apply the severest measures in suppressing the
   crimes of the anti-Jewish agitators, and asked the delegation in
   particular to exert their influence also upon the Jewish population
   behind the battlefront that they should support the Ukrainian Army in its
   struggle against the Bolshevists.
   (Trudowa Hromada, July 18, 1919.)
   HOME DISINFORMATION PETLIURA 486 hits since 25Mar99
   Symon Petliura Decree of Cabinet 18Aug1919 Enemies organize pogroms
   The Ukrainian and Jewish peoples both of whom work at the
   reconstruction of the Ukrainian Democratic Republic, find themselves in
   the face of the common enemies who are trying to sow discord and
   anarchy in order to destroy the Ukrainian Republic which they hate.
   Decree of the Cabinet Council
   of the
   Ukrainian Democratic Republic.
   August 18, 1919.
   (Record of the Proceedings No. 171)
   The Cabinet Council, after hearing the report of the Minister for Jewish
   Affairs, Mr. P.A. Krasny, on the situation as it appeared in connection
   with the anti-Jewish pogroms in the Ukraine - particularly in Kiev and
   in connection with the reaction of public opinion abroad, resolve as
   follows:
   The Ukrainian and Jewish peoples both of whom work at the reconstruction
   of the Ukrainian Democratic Republic, find themselves in the face of the
   common enemies who are trying to sow discord and anarchy in order to
   destroy the Ukrainian Republic which they hate. For this purpose your
   enemies organize pogroms, spin provocative news about pogroms in the
   Ukraine so as to exploit them for their people - with the help of the
   Polish ruling classes, or of the Denikin reactionaries. In deliberately
   lying and provocative reports they are changing arbitrarily the places of
   the pogroms which are arranged in the Ukraine by the Bolsheviks and by
   the reactionary clique who are in close connection with Denikin's and
   Polish reactionary circles' secret plans. In mendacious publications and
   in public letters addressed to the leading representatives of European
   countries, all these happenings are charged to the account of the
   government of the Ukrainian Democratic Republic, although its aim is to
   suppress vigorously all pogroms.
   In view of the fact that such provocations and aims of the Polish and
   Denikin reactionaries endanger the struggle for freedom of the Ukrainian
   Republic as well as the peaceful coexistence of the peoples of the
   Ukraine, the government of the Ukrainian Democratic Republic have set
   themselves the most urgent task of doing away with all possibility of
   provocations, pogroms or other excesses, and of calling to account all
   persons hostile to the Ukrainian State, who are doing the treacherous
   pogrom work in the Ukraine.
   The Government has decided:
   1. To make at once a proposal to the Commander-in-Chief, Petlura that he
   issue an order by which all commanders of the respective bodies of
   troops, from the lowest to the highest ones, would be called to account
   for negligence and tolerating pogrom excesses, and that they would be
   immediately arrested as traitors and handed over to a special
   court-martial which would impose upon them the severest penalty,
   including the death sentence.
   2. To issue an order in the name of the Government and in the name of the
   Commander-in-Chief to the Ukrainian partisans on the other side of the
   battlefront that they also 1. should take a vigorous action against the
   instigators of pogroms, 2. fight against particular treacherous pogrom
   bands and annihilate them - always remembering that the army of the
   Ukrainian Democratic Republic does not tolerate pogroms on its victorious
   march and inflicts the severe punishment upon all the guilty ones.
   3. To appoint immediately a special government commission with extensive
   powers of investigating pogroms and of combating them; the said
   commission to be composed of one representative from the following
   offices: The Commander-in-Chief, the Inspector General, the Minister of
   Justice, the Minister of Internal Affairs, and the Minister for Jewish
   Affairs. The Commission should proceed at once to the frontline to the
   area of liberated cities and other places of the Ukrainian Democratic
   Republic. The Commander-in-Chief should be advised to order an
   authorization with full powers to the Commission.
   4. Through inspections, the bodies of troops and the commissioners of the
   Ukrainian Democratic Republic should be informed about the foreign
   provocative work of the enemies of the Ukrainian Republic, who exploit
   the pogrom excesses for their own purposes.
   5. By means of a special report from the Prime Minister, to inform the
   Directorate of the Ukrainian Democratic Republic of this Decree, and to
   manifest the Government's firm determination and effort in the direction
   of removing completely any possibility of pogroms in the Ukraine.
   6. To issue an appropriate proclamation of the government to the people.
   7. The Minister for Press and Information should initiate an intensive
   campaign against pogrom arrangers; inform the foreign press and foreign
   public about the actual state of affairs, and protest against the
   outrageous slandering of the government of the Ukrainian Democratic
   Republic.
   8. The Minister of Justice should at once take steps that all those who
   are guilty of pogrom excesses, i.e. those who already have been arrested
   as well as those who may be arrested, should be handed over to a special
   court.
   9. This Decree is to be made public.
   (Ukraina, August 21, 1919.)
   HOME DISINFORMATION PETLIURA 552 hits since 23Mar99
   Symon Petliura Army Order No. 131 26Aug1919 Do not stain those deeds
   It is time for you to understand that the peaceful Jewish population, their
   children and women the same as ourselves have been oppressed and
   deprived of national freedom. They can not be alienated from us, they
   have of old been always with us and they have shared with us their joys
   and sorrows.
   Army Order of the Supreme Command
   of the Ukrainian Democratic Republic,
   August 26, 1919.
   No. 131
   Officers and Soldiers!
   It is time for you to realize that the Jews together with the majority of
   the Ukrainian population have recognized the evil of the
   Bolshevist-Communist invasion, and know already where the truth lies.
   The most important Jewish parties, such as: "Bund", "United Jewish
   Socialists", "Poalej-Zion" and "People's Party", have decidedly placed
   themselves on the side of the Ukrainian independent state and are working
   together hand-in-hand for its good.
   It is time for you to understand that the peaceful Jewish population,
   their children and women the same as ourselves have been oppressed and
   deprived of national freedom. They can not be alienated from us, they
   have of old been always with us and they have shared with us their joys
   and sorrows.
   The gallant army which brings brotherhood, equality, and freedom to all
   peoples of the Ukraine should not be lending an ear to various
   adventurers and provocateurs who long for human blood. Likewise, the
   Army should not be a party to bringing a hard lot on the Jews. Whoever
   is guilty of permitting such a heavy crime is a traitor and enemy of the
   country and must be thrust out of human society.
   Officers and soldiers! The whole world cannot but admire our heroic
   deeds in the struggle for freedom. Do not stain those deeds - not even
   accidentally - by disgraceful actions and do not bring down burning shame
   upon our state in the face of the whole world. Our many enemies,
   external as well as internal, are already profiting by the pogroms; they
   are pointing their fingers at us and inciting against us saying that we
   are not worthy of an independent national existence and that we deserve
   to be again forcefully harnessed to the yoke of slavery.
   I, your Commander-in-Chief, tell you that this very moment the question
   of to be or not to be for our independent existence is being decided
   before the International Tribunal.
   Officers and soldiers! The judgement on this question rests in your
   hands, so decide it by showing an armed fist against our enemies
   remembering always that a clean cause demands clean hands. Be sure that
   a severe and lawful punishment by a people's court will overtake all
   enemies of our country; but remember also that vengeance - often the
   result of want of careful consideration - is not the way of the Ukrainian
   Cossacks. I most positively order that all those who are instigating you
   to pogroms be thrust out of the army, and as traitors to the fatherland
   be handed over to the court. Let the court punish them according to
   their crimes by giving them the severest lawful penalty.
   The Government of the Ukrainian Democratic Republic recognizing the harm
   done to the state by the pogroms has issued an appeal to the whole
   population of the Ukraine to withstand all attempts of the enemies who
   might arouse it to anti-Jewish pogroms.
   I command the whole army to obey this appeal and to provide for its
   widest dissemination among comrades-in-arms and among the population.
   This Army Order is to be read to all division, brigades, regiments,
   garrisons and squadrons of the Dnieper and Dniester armies, as well as
   the partisan detachments.
   The Commander-in-Chief:
   Petliura.
   The Chief of Staff of the Supreme
   Commander:
   Junakiv.
   F. Pigido (ed.), Material Concerning Ukrainian-Jewish Relations during
   the Years of the Revolution (1917-1921): Collection of Documents and
   Testimonies by Prominent Jewish Political Workers, The Ukrainian
   Information Bureau, Munich, 1956.
   HOME DISINFORMATION PETLIURA 504 hits since 25Mar99
   Symon Petliura Appeal to Ukrainian Army 27Aug1919 To sow discord among us
   Let the death sentence overtake the perpetrators of pogroms and
   provocateurs. I demand the strictest discipline from you so that not even
   a hair of an innocent's head be touched.
   Appeal of the Commander-in-Chief,
   Petlura,
   to the Ukrainian Army.
   Soldiers of the Ukrainian Army!
   The Ukrainian Republican People's Army of the Dnieper and Dniester
   territories, now united into one army, is advancing victoriously, is
   crushing the enemy, gaining each day new territories of the Ukraine to
   liberate them from the Bolshevist brigands, bringing with them freedom to
   the Ukrainian people as well as the certainty of happy days of living in
   a peaceful and orderly state.
   The Bolshevist anarchy and maladministration, the horrible Red terror,
   the tyranny of the extraordinary inquiry commission [the Cheka] and of
   other criminals for whom there is nothing sacred in life - have sapped
   our people's strength to the utmost and have flooded our steppes with
   human tears and with streams of blood of the innocent.
   Amidst a peal of church bells, with bread and salt, with flowers and
   tears of joy the weary, oppressed and pillaged Ukrainian people are
   greeting you, their valiant warriors, as liberators from the yoke and
   from Bolshevist atrocities, as flesh of their flesh and blood of their
   blood.
   A might national enthusiasm has seized our people at your entry into
   villages and towns, and everywhere a festive reception is awaiting you
   and all this has been brought about by you, officers and soldiers of the
   Ukrainian army!
   You are living now through glorious and never to be forgotten moments of
   your life, and together with you all peoples inhabiting the Ukrainian
   territory are experiencing the same enthusiasm.
   The holy crusade for the liberation of the oppressed, regardless of their
   nationality, for the rule of law and order under freedom and democracy
   and the independence of our republic - these are the ideals in this
   struggle.
   The union of all democratic forces of all nationalities in the Ukraine,
   standing for the independence of our Republic, and their participation in
   the reconstruction of the state will warrant our victory over our
   enemies, and will guarantee to us an independent life subject to no one.
   Our enemies, however, are not sleeping but only watching our every step
   in order to sow discord among us in one way or another, and thus to
   frustrate the immediate realization of our people's efforts.
   The Bolshevists themselves consider the Ukraine Moscow's inheritance
   with the difference that formerly it was the heritage of black Moscow,
   now of a Red one.
   They see that the end of their rule in the Ukraine is already approaching
   because the Ukrainian people themselves have risen against them: but they
   do not give up yet their hope of subjugating the Ukrainian masses. By
   provocations for which they are spending enormous sums of money they want
   to divide us from within, hiring criminal elements who are inciting our
   soldiers to all sorts of outrages and pogroms against the innocent Jewish
   population; in this way they want to stamp our soldiers as
   pogrom-mongers, although these soldiers are bringing liberty to all
   peoples of the Ukraine.
   Our enemies intend thus to split the Ukrainian and Jewish laboring masses
   whose ways, in fact, have been bound together by three hundred years of
   Russian tsarist yoke.
   Our national army must bring equality, brotherhood and freedom to the
   Ukrainian as well as the Jewish citizens who are also supporting actively
   the government of the Ukrainian Democratic Republic. All their parties,
   i.e.: Bund, Obyednantsi, Poalej-Zion and People's Party are standing on
   the principles of the independence of the Ukraine, and are participating
   in the reconstruction of the republic.
   I know myself how the representatives of the Jewish population have
   helped our army and supported our legal republican government.
   The enemies of our state, the Bolshevists, are shooting down not only the
   Ukrainian but also the Jewish people, depriving the others of the barest
   means of living.
   I have the highest esteem for the sacrifices made during this war upon
   the altar of the fatherland by the Jewish population.
   From the reports by the commanders of our brave divisions and corps as
   well from reports by State Inspectors I have already learned that the
   Jewish population brought help to our wounded and sick soldiers, in the
   hospitals which had been built hastily 3-5 kilometers behind the
   battlefronts.
   I have been touched deeply by tears of thankfulness in the eyes of our
   soldiers for the loving care and human aid given them by Jews, and I have
   noted with satisfaction how the soldiers of our army were standing guard
   at the shops and stores of Jews in order to protect them against
   plunderers.
   The restoration of a bridge at Starokonstantyniv - which had been
   destroyed by the Bolshevists - by the Jewish population in an exceedingly
   short time, as well as their help with foodstuffs and underwear testify
   also to the loyal conduct of Jews in relation to our army.
   I am convinced and I ardently hope that in the future such help on the
   part of Jews will occur ever more frequently and that they will continue
   to further the cause of peace in our country.
   The Minister for Jewish Affairs has by a series of measures already
   exercised some influence upon the Bolshevist circles of Jews so that many
   of them no longer support Bolshevism, since they consider it now to be
   their ruin.
   Together with you I call upon the Jewish citizens to go with us and to
   support wholeheartedly our army and our government; then we shall be able
   to affirm that the government of the Ukrainian Democratic Republic and
   you, its army, will finish that great responsible work which you are now
   doing - destroying the power of the Bolshevists and building up our
   independent republic in which each nationality enjoys full rights and a
   peaceful life.
   Officers and soldiers of the Ukrainian Army! The Ukrainian-Jewish
   laboring masses see in you their liberation, and future generations will
   not forget your services rendered to them; history will with pride record
   on its pages your achievements in this struggle. Beware of provocations,
   and have no mercy on provocateurs or on those who execute pogroms, or
   incite the weakest among you to this action.
   Let the death sentence overtake the perpetrators of pogroms and
   provocateurs. I demand the strictest discipline from you so that not
   even a hair of an innocent's head be touched.
   Bear in mind that you are the elite sons of your great nation which wants
   to live its independent life and to be subjugated by no one, and
   therefore keep an unflinching watch on its interests as well as on the
   interests of all those who help you and are well-disposed to you and to
   the liberation of your people.
   Those who are guilty before the Ukrainian people and before the republic,
   no matter what their nationality, shall suffer the severest punishment
   according to law prevailing in the territory of the Ukrainian republic;
   to the innocent, however, you must bring liberation from the hated
   Bolshevist yoke.
   The Republic's and my own cordial thanks to and high esteem for your
   martial bravery, devotion, and self-sacrifice which your offer upon the
   altar of the fatherland, while liberating our Ukraine and the
   nationalities living there - including the Jews - from the Bolshevists.
   May God help us in the great and sacred cause of liberating the nations
   from the heavy yoke of the Bolshevists!
   August 27, 1919
   Commander-in-Chief: Petlura.
   (Ukraina, September 2, 1919.)
   F. Pigido (ed.), Material Concerning Ukrainian-Jewish Relations during
   the Years of the Revolution (1917-1921): Collection of Documents and
   Testimonies by Prominent Jewish Political Workers, The Ukrainian
   Information Bureau, Munich, 1956, pp. 70-72.
   HOME DISINFORMATION PETLIURA 836 hits since 23Mar99
   Arnold Margolin The Ukraine and the Policy of Entente 1921 Russian and Ukrainian pogroms compared
   If the beginning of the demoralization of the Ukrainian army was at its tail,
   by Denikin's army the poison of demoralization came from the head.
   EXTRACTS
   from the book by Arnold Margolin
   "The Ukraine and the policy of the Entente"
   (Memorandum by a Jew and a citizen).
   Publisher C. Efron. Berlin, 1921. Chapter XXIV. Pages 310-315.
   Pogroms of the period of the Directorate, and of Denikin's Army. Parallels.
   - Nations and Governments.
   I have before me the report on pogroms, prepared by the Relief Committee
   for the Victims of Pogroms, at the Russian Red Cross in Kiev. It is
   stated in the report that there were no pogroms during the rule of the
   Central Council, or of Skoropadsky, or during the first two months of the
   Directorate's rule. Pogroms began after defeats that had been inflicted
   upon the troops of the Directorate by the Bolsheviks. The heavier the
   defeats and the farther Petlura's army was compelled to retreat, the more
   cruel was their vengeance upon the innocent Jewish population whom they
   identified with Communists. The slogan: "down with Jews and Communists,"
   or "all Jews are Communists" were raised throughout the Ukraine and
   provoked pogroms everywhere.
   This explanation of the origin of pogroms is quite identical with the
   statement made in Temnytsky's and Vasylko's telegram of August 1, 1919.
   In the course of centuries the entire population of Russia had been
   listening to accusations by the government of Jews being responsible for
   all the evils in the world. The ignorant masses believed even the
   legends about the ritual murder of Christian children by Jews, while even
   the "specialists" in this subject were declaring that Jews kill only
   boys. Karab-Tchevsky tells us in the first part of his memoirs ("What My
   Eyes Saw") that his mother had already in his childhood read to him the
   New Testament, and when it came to the torturing of Jesus Christ, his
   nurse or housemaid would exclaim: "the hideous Jews, they surely killed
   Christ by torture!" (p. 23).
   The pogroms of the years 1880 in Kishinev and Homel, came as the result
   of false rumors and of promises of exemption from punishment for
   plundering during three days. This time, however, the participation of
   Jews in the Bolshevist movement was no more a rumor, but a fact which it
   was very easy to exaggerate. On the other side, the impunity for
   plundering lasted this time not only three days, but indefinitely on
   account of the absence of any authority that could stop the plundering.
   For, what authority could exist during the panic of retreat before
   Trotsky's army? ... Under such conditions a favorable atmosphere was
   created for the rapacious instincts of the demoralized segments of the
   army, as well as for the development of the ideological barbarity of
   Semesenko and for the provocateurs from the Russian Black-Hundred camp,
   who were pogrommongers by conviction and wished at the same time to
   discredit the Ukrainian movement by branding it as being guilty of
   pogroms.
   All this, of course, is not justification, but only one of many
   explanations of the origin of pogroms during the period of the
   Directorate.
   Quite a different picture is displayed by the comparison of this period
   of pogroms with the pogroms by Denikin's army. Here is no question of
   retreat and of chaos that is connected with retreat. On the contrary,
   the more successful the advance, the more organized and stronger is the
   propaganda from above and the more according to plan the pogroms are
   developed. If the beginning of the demoralization of the Ukrainian army
   was at its tail, by Denikin's army the poison of demoralization came from
   the head. As we have seen already, the Denikin officers openly declared
   that they were fighting not against the Bolsheviks, but against the Jews.
   To be sure, there were also in Denikin's army many persons of a purely
   rapacious type. But the most horrible thing was the deeply rooted
   anti-Semitism of the chiefs that surrounded Denikin, and their sadistic
   hate of Jews. I, personally, am not inclined to assume that Denikin
   himself wanted pogroms. Even to Denikin, in spite of his anti-Semitism,
   it was impossible not to see the fatal results of pogroms for his army.
   But he, too, was powerless on the question of pogroms, nor had he any
   inclination to come forward in defense of the Jews.
   The second characteristic feature which distinguishes the very course of
   the pogroms in one area from the other consists in the fact that in
   Petlura's army, we surely find cases when some individual persons or
   groups succeeded in preventing or stopping pogroms. Two such cases are
   cited by Temkin in his report, the other two cases are given in the
   report of the Relief Committee for the Victims of Pogroms. Red Army
   soldiers arranged an anti-Jewish pogrom in the city of Korosten in March
   13, 1919. When the soldiers of Petlura's army which was at that time
   advancing, reached the city, they stopped the pogroms. In Bila Tserkva
   the Ukrainian army - having expelled in August the Denikin troops of Gen.
   Shkuro and then the Red troops, who one after another plundered and
   massacred the population - behaved in full dignity until in turn they
   were substituted by Zeleny's bands that immediately arranged a pogrom.
   Later the unfortunate town was attacked by Sokolov's bands, after which
   the Ukrainian troops again succeeded in restoring order for a short time.
   Lubny escaped a pogrom thanks to the fact that a hundred men were found
   in the Ukrainian ranks, who with their arms stood in the way of the
   pogrommakers. Fourteen of the defenders fell in the fight but the town
   was saved. While reading the story about Lubny in this part of the
   report, I recalled the year 1905 when a City Committee of Defense was
   organized in Lubny, which also saved the city from a pogrom.
   Such facts were unknown in Denikin's army. Here the "guilty" of such
   patronage and defense of Jews were punished with dismissal from their
   posts.
   The third feature, a very disadvantageous one for Denikin's army and
   government, appears as a result of the comparison of the declarations by
   the Ukrainian government on the Jewish question, of laws concerning
   personal-national autonomy and Jewish Communities on the one hand, with
   the clauses restricting the number of Jews in educational institutions as
   well as in civil and military services in Denikin's empire - on the other
   hand. Here, on the part of the Ukrainian government, an effort to draw
   on representatives of Jews in all levels of government posts, and over
   there - in Denikin's camp - removal of Jewish officers from the army, and
   of Jewish officials from district and city offices. And this - in spite
   of the fact that so many Jews joined voluntarily at the very beginning
   Koltchak's and Denikin's armies. And how many Jews having been brought
   up with a Russian culture died for Russia that had been always a
   stepmother to them? On the other hand, how small a group of us, Jews,
   joined the Ukrainian movement at the beginning of the second revolution!
   Of course, there was nothing strange in it. Wilson's points had been
   declared but recently, and the realization of the right of
   self-determination by the Ukrainian people wa such a new and fresh event
   that not only the average Jewish citizen, but also the intellectuals,
   with few exceptions, did not digest or understand all that had happened.
   But the fact remains, Jews were represented by a very considerable number
   in the ranks both of the Bolsheviks and, at the beginning, of Denikin's
   army. The Ukrainian movement was joined only by a few Jews.
   The representatives of Russian and Jewish capital and heavy industry were
   marching hand-in-hand with the Volunteer Armies of Denikin, Yudenitch,
   and Koltchak. And even after all those pogroms committed by Denikin's
   army, the Jewish capitalists and industrialists followed the call of his
   successor Wrangel, and joined him
   Finally, one more feature out of many others that distinguish the
   Ukrainian Movement from that of Denikin: An anti-Jewish pogrom was openly
   carried on in Kiev in the presence of Denikin's generals, Drahomirov and
   Bredov. Never did happen anything like that, wherever the Directorate
   set up headquarters, neither in Kiev, nor in Vynnytsia, nor in
   Kamanets-Pololsk. The Kiev population knows from bitter experience the
   difference between those two regimes.
   Nevertheless, in spite of all these quite essential differences, here
   abroad the pogroms of the followers of Petlura are much more known than
   those perpetrated by Denikin's army, although the latter numerically and
   qualitatively surpassed considerably the former. This is to be explained
   not only by the propaganda of the Russian groups which have old
   connections and larger means in Europe and America, but also by the
   incontestable fact that the first series of pogroms attracted the
   greatest attention and brought forth the strongest expression of
   dissatisfaction on the part of the public.
   (In F. Pigido (ed.), Material Concerning Ukrainian-Jewish Relations
   during the Years of the Revolution (1917-1921): Collection of Documents
   and Testimonies by Prominent Jewish Political Workers, The Ukrainian
   Information Bureau, Munich, 1956, pp. 48-51)
   HOME DISINFORMATION 60 MINUTES 989 hits since 12Aug98
   Ginsburg U.S. Court of Appeals 11Aug98 Serafyn vs. Federal Communications Commission
   Serafyn also submitted evidence that "60 Minutes" had no policy against
   news distortion and indeed that management considered some distortion
   acceptable. For example, according to the Washington Post, Mike
   Wallace, a longtime reporter for "60 Minutes," told an interviewer: "You
   don't like to baldly lie, but I have."
   An introduction to the United States Court of Appeals decision below can
   be found in an Associated Press article by Jeannine Aversa which is on
   the Ukrainian Archive.
   The original of the Court of Appeals decision below can be found on the
   United States Court of Appeals web site whose home page is at
   www.cadc.uscourts.gov and where the decision can either be accessed by
   following links from the Court of Appeals home page, or else accessed
   directly at www.cadc.uscourts.gov/common/opinions/199808/95-1385a.txt.
   As page numbering was not indicated in the Court of Appeals web site
   version, it could not be inserted below, although page boundaries could
   be inferred and are indicated below by means of horizontal lines.
   The version below inserts clickable yellow CONTENTS boxes to remedy the
   general problem of a reader's losing track of where he is within a large
   document when reading it on screen, and to facilitate moving effortlessly
   from one part of the document to another.
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   United States Court of Appeals
   FOR THE DISTRICT OF COLUMBIA CIRCUIT
   Argued January 23, 1998 Decided August 11, 1998
   No. 95-1385
   Alexander J. Serafyn, et al.,
   Appellants
   v.
   Federal Communications Commission,
   Appellee
   CBS Inc., et al.,
   Intervenors
   Consolidated with
   Nos. 95-1440, 95-1608
   Appeal of Orders of the
   Federal Communications Commission
   Arthur V. Belendiuk argued the cause and filed the briefs
   for appellants. Shaun A. Maher and Donna T. Pochoday
   entered appearances.
   C. Grey Pash, Jr., Counsel, Federal Communications Com
   mission, argued the cause for appellee, with whom Christo
   pher J. Wright, General Counsel, and Daniel M. Armstrong,
   Associate General Counsel, were on the brief.
   Richard E. Wiley, Lawrence W. Secrest, III, James R.
   Bayes, and Daniel E. Troy were on the brief for intervenors
   CBS Inc. and Westinghouse Electric Corporation. John
   Lane Jr., Ramsey L. Woodworth, and Robert M. Gurss
   entered appearances.
   Before: Ginsburg, Henderson, and Randolph, Circuit
   Judges.
   Opinion for the court filed by Circuit Judge Ginsburg.
   Ginsburg, Circuit Judge: Alexander Serafyn petitioned the
   Federal Communications Commission to deny or to set for
   hearing the application of CBS for a new station license.
   Serafyn objected that CBS was not fit to receive a license
   because it had aired a news program in which it intentionally
   distorted the situation in Ukraine by claiming that most
   Ukrainians are anti-Semitic. The Commission summarily
   denied the petition, holding that Serafyn had not submitted
   enough evidence to warrant a hearing. Because the Commis
   sion neither applied the correct standard nor provided a
   reasoned explanation in its decision, we vacate its order and
   remand the matter to the agency for further proceedings.
   Serafyn also petitioned to revoke CBS's existing licenses on
   the ground that CBS made a material misrepresentation to
   the Commission when it gave an affiliated station false infor
   mation regarding its handling of viewer letters complaining
   about the same program. The Commission denied that peti
   tion on the ground that Serafyn had not alleged that CBS
   intentionally misrepresented the matter to the Commission.
   We uphold the Commission's decision in this matter as rea
   sonable.
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   I. Background
   Section 309(a) of the Communications Act provides that the
   Federal Communications Commission may grant a broadcast
   license only when it determines that doing so would serve the
   "public interest, convenience, and necessity." 47 U.S.C.
   s 309(a). Under s 309(d) of the Act any interested person
   may petition the FCC to deny or to set for hearing any
   application for a broadcast license or to revoke an existing
   broadcaster's license. The petition must contain
   specific allegations of fact sufficient to show that ... a
   grant of the application would be prima facie inconsistent
   with [the public interest, convenience, and necessity].
   Such allegations of fact shall ... be supported by affida
   vit of a person ... with personal knowledge thereof.
   Id. The FCC must hold a hearing if it finds that the
   application presents a "substantial and material question of
   fact" or if it is otherwise unable to conclude that granting the
   application would serve the public interest. See s 309(e).
   As the Commission interprets it, s 309 erects a two-step
   barrier to a hearing: (1) a petition must contain specific
   allegations of fact that, taken as true, make out a prima facie
   case that grant of the application would not serve the public
   interest; and (2) the allegations, taken together with any
   opposing evidence before the Commission, must still raise a
   substantial and material question of fact as to whether grant
   of the application would serve the public interest. See Astro
   line Communications Co. v. FCC, 857 F.2d 1556, 1561 (D.C.
   Cir. 1988) (describing two-step test). At the first step, "[t]he
   Commission's inquiry ... is much like that performed by a
   trial judge considering a motion for a directed verdict: if all
   the supporting facts alleged in the affidavits were true, could
   a reasonable factfinder conclude that the ultimate fact in
   dispute had been established." Gencom, Inc. v. FCC, 832
   F.2d 171, 181 (D.C. Cir. 1987). At the second step, a substan
   tial and material question is raised when "the totality of the
   evidence arouses a sufficient doubt on the [question whether
   grant of the application would serve the public interest] that
   further inquiry is called for."
   Citizens for Jazz on WRVR,
   Inc. v. FCC, 775 F.2d 392, 395 (D.C. Cir. 1985).
   In determining whether an allegation of news distortion
   raises a question about the licensee's ability to serve the
   public interest, the Commission analyzes both the substantial
   ity and the materiality of the allegation. The Commission
   regards an allegation as material only if the licensee itself is
   said to have participated in, directed, or at least acquiesced in
   a pattern of news distortion. The Commission stated its
   policy about 30 years ago as follows:
   [W]e do not intend to defer action on license renewals
   because of the pendency of complaints of [news distor
   tion]--unless the extrinsic evidence of possible deliberate
   distortion or staging of the news which is brought to our
   attention, involves the licensee, including its principals,
   top management, or news management.... [I]f the
   allegations of staging ... simply involve news employees
   of the station, we will, in appropriate cases ... inquire
   into the matter, but unless our investigation reveals
   involvement of the licensee or its management there will
   be no hazard to the station's licensed status....
   .... Rather, the matter should be referred to the
   licensee for its own investigation and appropriate han
   dling.
   .... Rigging or slanting the news is a most heinous
   act against the public interest .... [b]ut in this democra
   cy, no Government agency can authenticate the news, or
   should try to do so.
   Hunger in America, 20 FCC 2d 143, 150, 151 (1969). In a
   footnote the Commission added:
   [W]e stress that the licensee must have a policy of
   requiring honesty of its news staff and must take reason
   able precautions to see that news is fairly handled.
   An allegation of distortion is "substantial" when it meets
   two conditions, as we summarized in an earlier case.
   [F]irst, ... the distortion ... [must] be deliberately
   intended to slant or mislead. It is not enough to dispute
   the accuracy of a news report ... or to question the
   legitimate editorial decisions of the broadcaster....
   The allegation of deliberate distortion must be supported
   by "extrinsic evidence," that is, evidence other than the
   broadcast itself, such as written or oral instructions from
   station management, outtakes, or evidence of bribery.
   Second, the distortion must involve a significant event
   and not merely a minor or incidental aspect of the news
   report.... [T]he Commission tolerates ... practices
   [such as staging and distortion] unless they "affect[ ] the
   basic accuracy of the events reported."
   Galloway v. FCC, 778 F.2d 16, 20 (D.C. Cir. 1985) (affirming
   Commission's holding that CBS's "60 Minutes" had not dis
   torted news by staging insurance investigator's interrogation
   of fraudulent claimant; because she "actually did participate
   in the fraud and did confess, even if not in precisely the
   manner portrayed, the 'basic accuracy of the events reported'
   ... has not been distorted").
   As we noted in Galloway, the Commission's policy makes
   its investigation of an allegation of news distortion "extremely
   limited [in] scope. But within the constraints of the Constitu
   tion, Congress and the Commission may set the scope of
   broadcast regulation; it is not the role of this court to
   question the wisdom of their policy choices." Id. at 21.
   In 1994 CBS produced and broadcast a controversial seg
   ment of "60 Minutes" entitled "The Ugly Face of Freedom,"
   about modern Ukraine. The broadcast angered some viewers
   who believed that many elements of the program had been
   designed to give the impression that all Ukrainians harbor a
   strongly negative attitude toward Jews. For example, inter
   viewer Morley Safer suggested that Ukrainians were "genet
   ically anti-Semitic" and "uneducated peasants, deeply super
   stitious." Also, soundbites from an interview with the Chief
   Rabbi of Lviv, Yaakov Bleich, gave viewers the impression
   that he believes all Ukrainians are anti-Semites who want all
   Jews to leave Ukraine. In addition, CBS overlaid the sound
   of marching boots on a film clip of Ukrainian Boy Scouts
   walking to church and introduced it in such a way as to give
   viewers the impression that they were seeing "a neo-Nazi,
   Hitler Youth-like movement." The narrator also stated that
   the Ukrainian Galicia Division had helped in the roundup and
   execution of Jews from Lviv in 1941, though this Division was
   not in fact even formed until 1943 and therefore could not
   possibly have participated in the deed. Perhaps most egre
   giously, when Ukrainian speakers used the term "zhyd,"
   which means simply "Jew," they were translated as having
   said "kike," which is a derogatory term.
   After the broadcast interviewees and members of the
   Ukrainian-American community deluged CBS with letters.
   In his letter Rabbi Bleich stated "unequivocally" that his
   "words were quoted out of the context that they were said"
   and that "the CBS broadcast was unbalanced" and "did not
   convey the true state of affairs in Ukraine." Cardinal Luba
   chivsky, the head of the Ukrainian Greek Catholic Church,
   who had also been interviewed, both sent a letter to CBS and
   released a statement to the press. In the latter he stated,
   "[M]y office was misled as to the actual thrust of the report.
   Mr. Fager [the producer] presented the piece as one about
   'post-communist Ukraine.' ... I can only deduce that the
   goal of the report was to present all Western Ukrainians as
   rabid anti-semites." Many other viewers pointed out histori