LITUANUS LITHUANIAN QUARTERLY JOURNAL OF ARTS AND SCIENCES   Volume 36, No.3 - Fall 1990 Editor of this issue: Antanas Klimas, University of Rochester ISSN 0024-5089 Copyright © 1990 LITUANUS Foundation, Inc.

A SHORT HISTORY OF DIPLOMATIC RELATIONS BETWEEN THE UNITED STATES AND THE REPUBLIC OF LITHUANIA

JOHN JOSEPH LAPINSKI, J.D.

The Soviet invasion of the Republic of Lithuania in the summer of 1940 began one of the most unusual chapters in U.S. diplomatic history. For nearly a half a century, the United States has refused to formally recognize the forcible incorporation of Lithuania into the Union of Soviet Socialist Republics and continues to acknowledge the diplomatic mission of the pre-war independent government of Lithuania as the only legitimate representatives of the Lithuanian nation. The Lithuanian American community has played an important role in both the fight to gain recognition for the Republic of Lithuania and the struggle to maintain that continuing recognition during the decades since the Soviet invasion.

I. Rebirth of the Lithuanian nation

The Lithuanian people have inhabited the coastline of the Baltic Sea since at least 3000 B.C.1 Lithuanians are an ethnically distinct people speaking one of the world's most archaic living languages, as old if not older, than Sanskrit.2 The Lithuanian tribes united in the thirteenth century under the leadership of King Mindaugas. Over the next two hundred years Lithuania grew to be one of the largest and most powerful nations in Europe with its borders extending from the Baltic Sea in the North to the Black Sea in the South with the Ukraine and Byelorussia coming under its protection.3 The marriage of the Lithuanian Grand Duke Jogaila to the daughter of the Polish King in 1386 resulted in a close affiliation of the two nations which eventually led to the creation of the Lithuanian-Polish Commonwealth in 1569.4 In the eighteenth century, under pressure from its powerful neighbors: Russia, Austria and Prussia, the Commonwealth was partitioned three times (1772, 1792 and 1795) with the final partition leaving Lithuania under Russian rule.5 The fiercely independent Lithuanians never accepted Russian rule which lead to a number of national revolts: 1794, 1831, 1863, 1905.6 In retaliation for the Revolt of 1831 the Russian authorities closed the University of Vilnius (founded in 1579) and after the 1863 uprising the Russians prohibited the Lithuanian language to appear in Latin-alphabet print.7 This effort to destroy the Lithuanian identity led to the development of a nationalist movement both within Lithuania and abroad.

Near the close of the first World War, the Imperial armies of Germany and Russia moved back and forth across eastern Europe. Lithuania, which had been occupied by Imperial Russian forces for more than a century, suddenly found itself occupied by the Kaiser's armies. With the abdication of the Russian Czar in 1917, the new Soviet government of Russia declared that all nationalities of the former Russian Empire had the right to establish independent states.8 The Germans, concerned that this might lead to nationalist insurrections, responded to the Russian statement by offering independence to Lithuania under a German monarch. The National Council of Lithuania was established in September of 1917 and accepted the German offer inviting the German Duke William, Herzog von Urach to take the title of King Mindaugas II of Lithuania.9 As German fortunes began to decline, the National Council of Lithuania took advantage of a change in the German government and declared Lithuania an independent republic on February 16th, 1918. In November of that year, the National Assembly withdrew its offer to Duke Urach and the new Lithuanian Republic began to seek recognition of its independence from the other nations of the world.

II. The quest for recognition

The new nation quickly discovered that it was easier to declare independence than it was to gain the recognition of that independence from the rest of the world. As the armistice neared, the fate of the Lithuanian people and their lands were shrouded in uncertainty as German, Polish and Russian (both communist and royalist) armies vied for control of the Baltic region. The new Republic had to establish a government, borrow money, secure borders and raise an army. Without the formal recognition of the principal world powers, these tasks would be extremely difficult to accomplish. The Lithuanian Republic sent a delegation to the Paris Peace Conference to lobby for recognition from the principal world powers and to seek membership in the newly created League of Nations. However, the delegation's pleas fell upon deaf ears.

With the failure to obtain recognition from the League of Nations, Lithuania turned its attention towards the one principal power that was not a member of the League: The United States. However, despite President Wilson's declared principles of self-determination for the nations of the world, the Wilson administration, like the other principal powers, was unwilling to recognize the existence of the Lithuanian Republic based upon the theory that the Russian Empire should remain intact.10

At the close of the first World War, the feeling among the Allied powers was that a strong Russia would be needed to check any future threat by Germany. This position was furthered by the hopes that the Czar or a pro-democratic government might be returned to power in Russia. Consequently, the Allied powers were very hesitant to recognize the independence of the Baltic Republics and cut Russia off from the ice free ports of Riga, Tallin and Klaipėda. The Baltic delegations argued that they were not Russians, but distinct nationalities with languages, cultures and histories completely separate from that of Russia. Lithuania pointed to its 500 years of independent self-rule in support of its claim to recognition. However, the Wilson administration held firm to the belief that the Russian Empire should be preserved, as made clear in a note dated August 10,1920 from the U.S. Secretary of State to the Italian Ambassador at Washington, concerning the Lithuanian application for admission to the League of Nations:

The United States maintains unimpaired its faith in the Russian people, in their high character and their future, that they will overcome the existing anarchy, suffering and destitution.

Until that time shall arrive, the United States feels that friendship and honor require that Russian interests must be generously protected, and that, as far as possible, all decisions of vital importance to it, and especially those concerning its sovereignty over the territory of the former Russian Empire, be held in abeyance. By this feeling of friendship and honorable obligation to the great nation whose brave and heroic self-sacrifice contributed so much to the successful termination of the war, the Government of the United States was guided in its reply to the Lithuanian National Council, on October 15, 1919, and in its persistent refusal to recognize the Baltic States as separate nations independent of Russia."11

Despite the initial rejection, the Lithuanian Republic knew that the United States would play an important role in the future development of their country, especially since so many people from the Baltic region had emigrated to the United States in the previous decades. The Lithuanian Alliance of America had been instrumental in organizing those immigrants into a large and influential organization. The Alliance became an important factor in a lobbying effort to persuade the American government to extend de jure recognition to their former homeland. These lobbying efforts culminated in the presentation of a petition containing the signatures of one million Americans to the newly elected President Warren Harding asking that the U. S. grant de jure recognition to the Republic of Lithuania.12

By 1921, America had a new President, the Bolsheviks were firmly in control of Russia, the Czar and his family were dead and each of the Baltic Republics had individually entered into peace treaties with the Soviet Union recognizing Baltic independence. With the change in circumstances in Europe, along with the lobbying effort at home by American-Lithuanians, the Harding Administration began to re-examine the issue of formal recognition of the Baltic Republics. Late in 1921, U.S. Secretary of State, Charles Evan Hughes, requested that the American Commissioner at Riga (Latvia), Evan Young, prepare a report on the political situation in the Baltic States of Lithuania, Latvia and Estonia. Commissioner Young responded in a letter dated April 6, 1922 with the following observation:

"Although,. . . the machinery of government in each of these States contains many weak parts and although the officials and authorities not infrequently give evidence of their lack of experience in statecraft, yet one must record the fact that the operations of the administrative machinery has on the whole been attended with a large measure of success. All three States are now functioning under either permanent or provisional Constitutions. In each country, National Assemblies were elected more than two years ago. These Assemblies, in a peaceful and orderly manner, have enacted such legislation as deemed requisite for the welfare of the population. Taxes have been imposed and collected in a legal and orderly manner. Small, though well trained and disciplined, armies have been organized and equipped. Commerce and trade is being carried on with neighboring countries and with the world at large. Law and order is fully maintained. In short, each of these countries unquestionably today fully meets all of the requirements, which so far as the recognition of their governments is concerned, may reasonably be exacted. In the conduct of their foreign relations, they have met with no less measure of success. The old petty jealousies and bickering which existed in the early days of their statehood no longer prevail."13

In June of that same year, the Conference of Ambassadors met in Paris. At the conference, the Principal Allied Powers (France, Great Britain, Italy, and Japan) decided to grant de jure recognition to the Republics of Lithuania, Latvia and Estonia despite Lithuania's continuing dispute with Poland over the Polish occupation of the Lithuanian capital city of Vilnius.14 Lithuania became a member of the League of Nations on September 22, 1921, and was granted official de jure recognition by the Principal Allied Powers on December 20th.15

With the Peace treaty with Moscow signed, came recognition by the European powers and membership in the League of Nations. The remaining obstacles to U.S. recognition were removed. Consequently, Secretary of State Charles Evans Hughes met with President Harding and it was decided that the United States would also extend de jure recognition to the three Baltic Republics. On July 25, 1922, at 4 p.m. (EDT) Secretary Hughes in Washington sent the following instruction to Commissioner Young in Riga, Latvia:

"Advise Foreign Offices of Est(h)onia, Latvia and Lithuania as nearly at the same time as possible on the morning of July 28th that the United States extends to each full recognition. The fact will be communicated to the press at Washington for publication in the morning papers of July 28 and the following statement will be made: 'The Governments of Esthonia, Latvia and Lithuania have been recognized either de jure or de facto by the principal Governments of Europe and have entered into treaty relations with their neighbors.

In extending to them recognition on its part, the Government of the United States takes cognizance of the actual existence of these Governments during a considerable period of time and of the successful maintenance within their borders of political and economic stability.

The United States has consistently maintained that the disturbed conditions of Russian affairs may not be occasion for the alienation of Russian Territory, and this principle is not deemed to be infringed by recognition at this time of the Governments of Esthonia, Latvia and Lithuania which have been set up and maintained by an indigenous population.

Pending legislation by Congress to establish regular diplomatic representation Mr. Young will continue as Commissioner of the United States and will have the rank of Minister.

Request from respective governments temporary recognition pending formal application for exequaturs of John P. Hurley, Charles H. Albrecht and Clement S. Edwards, Consuls at Riga, Reval and Kovno, respectively."

Hughes16

With the formal recognition of the Baltic Republics, Commissioner Young was appointed U.S. Minister to the Baltic States with the American mission being located at Riga, Latvia.17 At the same time, the formally unofficial representatives of the Baltic governments in the U.S. were given the title Charges dAffaires along with full diplomatic privileges.18 Finally, the long awaited day of recognition had come and Lithuania officially became a full-fledged member of the world community of nations.

II. Diplomatic relations during the period of Baltic independence

The relations between the Republic of Lithuania and the U.S. during the period between 1922-1939, can be characterized as cordial and cooperative with the two countries entering into a number of treaties. The United States was interested in the survival of the Baltic States, as they served as a buffer between the West and Communist Russia. Conversely, the Baltic countries relied on American recognition to protect their sovereignty and U.S. trade for a large part of their economic livelihood. Accordingly, some of the most important treaties entered into between Lithuania and the U.S. were those granting most favored nation status in trade dealings. As a result, Consular offices were opened in major American cities to promote trade between the two countries. Other treaties between the United States and the Republic of Lithuania dealt with a wide variety of issues including, extradition, postal matters, peaceful settlement disputes and military service.

The 1920s and 30s was a period of economic, social, cultural and political prosperity for the Lithuanian Republic. However, fear of Russian intervention into Lithuanian affairs continued to haunt the infant republic. An attempted communist coup in Estonia in 1924 lead to concerns in both Lithuania and the United States of Soviet intervention. The 1926 Lithuanian elections resulted in a victory by a coalition of leftwing parties which was followed by a bloodless coup d'etat staged by the former Christian-Democrat President, Antanas Smetona. That same year Lithuanian entered into a treaty of non-aggression with the Soviet Union which included further assurances of continuing recognition of Lithuanian independence by the Soviet Union.19 In an effort to further strengthen their position against the Soviet Union, the Republics of Lithuania, Latvia and Estonia agreed to form an alliance known as the Baltic Entente which pledged economic and diplomatic cooperation.20

IV. Soviet occupation

In 1939 Adolph Hitler and Josef Stalin entered into c secret agreement dividing up their respective spheres o' influence in eastern Europe. By March of 1939, the Nazis seized the Lithuanian port city of Klaipėda (Memel) which had formerly been occupied by Germany prior to World War I. The Soviet Union also began to pressure the Baltic Republics of Lithuania, Latvia and Estonia to allow Soviet troops to be stationed in their countries and the turning over of certain ports to the Soviet military. The Baltic governments stalled, but in September of 1939 German and Russian forces jointly invaded Poland and it became apparent that it was simply a matter of time before the Baltic countries became involved in another war.

On October 10th, 1939, Lithuania was pressured into concluding a "Mutual Assistance Pact" by the Soviet Union which once again emphasized the territorial integrity of the Lithuanian Republic.21 In addition, the Soviets returned to Lithuania its ancient capital city of Vilnius previously under Polish occupation. Despite Soviet assurances, Russia accused the Lithuanian Government of being involved in the disappearance of three Soviet soldiers stationed in Lithuania. Two of the soldiers returned to their base within a few days of their disappearance and the Lithuanian government offered to set up a commission to investigate the disappearance of the third. On June 14, 1941, the Soviet Union accused the Lithuanian government of the kidnapping of the three Soviet soldiers and entering into secret alliances with the Republics of Latvia and Estonia against the Soviet Union.22 This was followed by an ultimatum to the Lithuanian government demanding return of the missing soldier and access to Lithuanian ports or face invasion from the Soviet Union.

On June 15,1940, some 300,000 Soviet troops invaded the Republics of Lithuania, Latvia and Estonia. President Smetona of Lithuania left the country taking with him a government-in-exile. Those who remained were not so fortunate. Twelve cabinet members and members of non-communist political parties were arrested. By July 11th, over 2,000 persons had been arrested and jailed.23 The Soviet invaders were quick to establish a pro-Communist puppet government in each of three countries with the end result being the forcible incorporation of the Baltic States into the Soviet Union. This action came in spite of the fact that the Soviet Union had entered into a number of treaties renouncing all claims to the Baltic territories and guaranteeing the independence of the three Baltic nations. The new Communist government of Lithuania nationalized all private lands, banks, railroads, mines and industrial enterprises.

As Hitler's forces invaded the Soviet Union, Russian forces withdrew from Lithuania which allowed a provisional Lithuanian government to be created on June 23, 1941. However, Nazi troops occupied Lithuania and the provision-al government came to an end in August of 1941.24

VI. American response to the Soviet invasion

The Soviet invasion had not come as a complete surprise to the leaders of the Baltic Republics. Several weeks before the Soviet invasion, the Lithuanian government issued orders to its legations around the world to continue to represent the government interests despite the lack of further instructions which might occur in the event of an invasion.25 The hope was that independence might be restored through diplomatic channels as the Soviet invasion was a clear violation of international law. However, many nations were not so quick to condemn the Soviet action and in several countries, legations of the independent government of Lithuania were closed or consigned to the Soviet authorities.

The United States immediately condemned the Soviet action, with Secretary of State, Sumner Wells, clarifying the position of the United States in a statement issued on July 23, 1940:

"During these past few days the devious processes where under the political independence and territorial integrity of the three small Baltic republics Estonia, Latvia and Lithuania were to be deliberately annihilated by one of their more powerful neighbors, have been rapidly drawing to their conclusion.

From the day when the peoples of these republics first gained their independence and democratic form of government, the people of the United States have watched their admirable progress in self-government with deep and sympathetic interest.

The policy of this Government is universally known. The people of the United States are opposed to predatory activities no matter whether they are carried on by uses of force or by threats of force. They are likewise opposed to any form of intervention on the part of one state, however powerful, in the domestic concerns of any other sovereign state, however weak. These principles constitute the very foundations upon which the existing relations between the 21 sovereign republics of the New World rests.

The United States, will continue to stand by these principles, because of the conviction of the American people that unless the doctrine m which these principles are inherent once again governs the relations between nations, the rule of reason, of justice and of law—in other words, the basis of modern civilization itself cannot be preserved."26

In protest to the Soviet annexation, the United States closed its legation in Riga and recalled its representatives on September 5th, 1940.27 In addition, the status of the Baltic representatives in the United States were only slightly modified and the legations were allowed to continue to represent their governments as if nothing had changed. Also, the assets of the independent Baltic governments on deposit with American banks were frozen, with the legations being allowed to draw upon the funds to support their operations despite Soviet protests.28

VI. Development of the U.S. non-recognition policy

The compromises made by the Allied leaders; Roosevelt, Churchill and Stalin at the Yalta Conference in 1945, made it apparent that the restoration of independence to the Baltic countries would not be forthcoming in the near future as Soviet forces once again occupied the Baltic States. However, with the emergence of the "Cold War", the U.S. State Department developed the so-called "Baltic—Non-Recognition Policy" with the basis of the policy being that the U.S. would not recognize the "forcible and unlawful incorporation of Estonia, Latvia, and Lithuania into the U.S.S.R."29 In addition, the U.S. government only recognized the diplomatic representatives of the independence Baltic Republics and allowed those diplomatic officials to continue to enjoy full diplomatic privileges.

The practical effects of this policy went beyond symbolic resistance to the Soviet occupation and found its way into the American courts. In a series of cases which came to be known as the "Baltic Ship Cases," American courts of law continued to dismiss law suits brought by the Soviet-backed governments of Lithuania, Latvia and Estonia to claim possession or insurance proceeds for ships under Baltic flags harbored in American ports. The decisions in these Baltic Ship Cases can be summarized by a decision in the case of Silberberg v. The Kotkas et al., in which agents of the Soviet government of Estonia attempted to claim title to an Estonian ship in the port of New York with the Consul General of the Republic of Estonia challenging the Soviet's claim. In his decision, Judge Galston stated that:

"There was offered in evidence a communication from our State Department as of October 24, 1940, reciting that this Government does not recognize the absorption of Estonia by the Union of Soviet Socialist Republics and indeed, continues to recognize Johannes Kaiv as acting¦ Consul General of Estonia ... Not only does our Government not recognize the validity of the (Soviet) decrees, but also the executive order of the United States Government, No. 6560 of April 10,1940, supplemented by executive order¦ of July 15, 1940, popularly known as 'freezing orders,' in effect prevents the transfer of property of nations of invaded countries so that such property may not inure to the benefit of the aggressors."30

Similarly, in the areas of wills and estates, a number of cases were litigated in U.S. Courts. Most of these cases¦ involved the estates of Lithuanian, Latvian and Estonian nationals who had died in the United States and left property to relatives living in the occupied Baltic countries. In order for claims on the estates to be paid to the relatives documents had to be notarized by an official of the government. The American courts consistently refused t( recognize Soviet notarization on official documents concerning Lithuanians, Latvians and Estonians, stating the Soviets had no authority over citizens of those countries. As a result, the Soviet authorities were denied the revenues generated from the heavy taxes they imposed on the transfer of such property.

VII. The Helsinki accord and Soviet de facto recognition

The American non-recognition policy was proving to be an inconvenience to the Soviet Union. Consequently, the issue of the status of the Baltic States became a topic for discussion when the United States and the Soviet Union met in Helsinki, Finland in 1975. Out of this meeting between the two powers came the Helsinki Final Act, which in effect gave de facto recognition to the Soviet sponsored governments of the occupied Baltic countries.31 The practical effect of the Helsinki accord was to allow direct contact between the United States and the Soviet Union on issues concerning the people living under Soviet occupation in the Baltic region. However, this apparent change in policy led to some uncertainty as to the future status of the Baltic governments-in-exile and their diplomatic representatives in the United States.

In recent years, the Reagan Administration has attempted to clarify the U.S. position regarding this country's view on U.S.-Baltic relations. In an address to the United Nations in July 1983, President Reagan stated, "Americans share the just aspirations of the Baltic nations for national independence. We cannot remain silent in the face of the continual refusal of the Government of the USSR to allow these people to be free. We uphold their right to determine their own national destiny, a right contained in the Helsinki Declaration which affirms that 'all people always have the right, in full freedom, to determine when and as they wish, their internal and external political status, without external interference, and to pursue as they wish their political, economic, social and cultural development/ For this reason, the Government of the United States has never recognized the forcible incorporation of the Baltic States into the Soviet Union and will not do so in the future."32

To further protest the continuing occupation of the Baltic Statems by the Soviet Union, the Bureau of Public Affairs at the Department of State lists the following "policy applications" when dealing with issues involving U.S.-Baltic relations;

"—The Secretary of State annually issues National Day greetings to the Baltic peoples through the Charges dAffaires; and senior representatives of the Department of State attend the official National Day functions of the three missions.

—So that the U.S. Government speaks with a consistent voice regarding our nonrecognition policy, we seek to coordinate actions of other U.S. agencies on such matters as captions and place names relative to Estonia; Latvia, and Lithuania on official U.S. Government maps.

—We support the flow of news and information to the Baltic peoples in their native languages through broadcasts of the Voice of America and Baltic Services Division of Radio Liberty.

—We reiterate on all appropriate occasions our policy of not legally recognizing the forcible incorporation of the three countries into the U.S.S.R.

—Our Ambassador in Moscow and Cabinet-level officers of the U.S. Government do not visit the Baltic Republics"33

The State Department publication Treaties in force, continues to list treaties entered into between the three Baltic Republics and the United States along with the notation that, "The United States has not recognized the incorporation of Estonia, Latvia and Lithuania into the Union of Soviet Socialist Republics. The Department of State regards treaties between the United States and those countries as continuing in force."34 Furthermore, the State Department continues to maintain a "Baltic States Affairs" desk located in the Eastern European Section, separate from the Soviet Affairs desk, which is responsible for dealing with the official representatives of the Baltic legations. Passports issued by the Governments of Lithuania, Latvia and Estonia prior to 1940 are still officially recognized by the United States.35

VII. The future of America-Baltic diplomatic relations

The diplomatic missions to the United States from the Republics of Lithuania, Latvia and Estonia continue to operate legations in Washington as well as Consular offices in major U.S. cities. However, despite the reassurances of America's non-recognition policy towards the Soviet occupation of the Baltic countries, the future of the diplomatic representation of Baltic interest in this country is facing some serious obstacles. One problem confronting the Baltic missions is that the American non-recognition policy only extends full diplomatic recognition to those members of the Baltic legations who were members of their country's foreign service prior to the 1940 Soviet invasion.36 The missions have attempted to circumvent this obstacle by appointing "honorary" consuls and representatives, however, the holders of these honorary positions may not receive salaries from the missions. Another difficulty is the funds that were frozen by the U.S. Government in 1940, which have been used to support the legations, are dissipating with time.37 However, efforts are being made by members of the Lithuanian, Latvian and Estonian communities in this country to assist the legations.

VII. Conclusion

The continuing recognition of the Lithuanian, Latvian and Estonian countries by the United States raises a number of interesting diplomatic and legal issues. This continued de jure recognition of the Republic of Lithuania by the United States serves more than a mere symbolic gesture of resistance to the Soviet Union's occupation, rather it serves an important function in reminding the world that the Soviet occupation of Lithuania, Latvia and Estonia is a continuing violation of international law.

1 Juozas Prunskis, Lithuania, (Chicago, 1982) p. 6.

2 A. Bilmanis, A History of Latvia, (1950) p. 30.

3 Prunskis, op. cite, p. 8.

4 Id. at p. 11.

5 Id.

6 The Annexation of the Baltic States and its Effect on the Development of Law Prohibiting Forcible Seizure of Territory. New York Law School Journal of International and Comparative Law, Vol. 6, p. 352.

7 Prunskis, op. cit. p. 11.

8 Albertas Gerutis, Lithuania 700 Years, (New York, 1969), p. 180.

9 Id. at p. 158.

10 Foreign Relations of the United States, (Washington, D.C, 1919) p. 668.

11 Max. M. Laberson, "The Recognition of Latvia," American Journal of International Law. XXXVII, 1943, p. 241.

12 Antanas Kucas, Lithuanians in America (Boston, 1975), p. 180.

13 Foreign Relations of the United States, p. 873-874.

14 Gerutis, op. cite p. 180.

15 Ibid.

16 Foreign Relations of the United States, pp. 873-874.

17 Id.

18 Kucas, op. cite., p. 185.

19 Gerutis, op. cit., p. 219.

20 Id. at p. 234.

21 Id. at p. 263. 

22 Id. at p. 263.

23 New York Law School Journal of international and Comparative Law, Vol. 6 p. 381.

24 Prunskis, op. cit., p. 12.

25 "Lithuanian Diplomatic Service," Encylopedia Lituanica, (1978 ed.) v. VI, p. 430.

26 Department of State Bulletin, Vol. III, No. 27, July 27, 1940, p. 48.

27 Ibid.

28 "Bank of Lithuania," Encylopedia Lituanica, (1978 ed.), vol. l p. 384.

29 Cist, Department of State; Bureau of Public Affairs, August 1984.

30 35 F. Supp., 983 (D.C.N.Y., 1940). See: Herbert W. Briggs, "Non Recognition in the Courts: The Ships of the Baltic Republics," -America Journal of International Law, XXXVII, 1943, p. 585.

31 CIST, op. cit.

32 Ibid.

33 Ibid.

34 Ibid.

35 Treaties in Force, U.S. Department of State (Washington, D.C., 1985), p. 107.

36 Steve Sanders, "Keeping Faith" Chicago Tribune Magazine, March 17, 1985. p. 32.

37 Ibid.