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                                                            [Page 249]
                                                                      
I shall now proceed to the second group of documents presented by the
Soviet prosecution, which characterise the espionage measures
undertaken by the Fascist conspirators in preparation for war against
the Soviet Union.

Trend and task of espionage work in connection with  Case
"Barbarossa," were, as we know, determined by a directive from the
Supreme Command of the German Armed Forces, addressed to Counter-
Intelligence on 6th September, 1940, and signed by the defendant Jodl.

This document, presented by the American prosecution as Document 1229-
PS; it is to be found on Pages 46 and 47 of our document book. I do
not intend to quote from this document again, but I do consider it
essential to remind you that in it the intelligence organisations
demand that the regrouping of armies on Germany's Eastern front should
be camouflaged in every possible way and

                                                            [Page 250]
                                                                      
that the Soviet Union should remain under the impression that action
of some kind was brewing against the Balkans.

The activities of the intelligence organisations were strictly
regulated. These activities included measures for concealing, as far
as possible, the number of German forces in the East and of giving an
impression of insignificant concentrations in the North of the Eastern
provinces, at the same time conveying the impression of very
considerable concentrations of forces in the Southern part, in the
Protectorate and in Austria.

The necessity was pointed out of creating an exaggerated impression of
the number of anti-aircraft units and of the insignificant extent of
road-building activities, etc.

I here take the liberty of making two pertinent observations.
According to Pieckenbrock's testimony, the intensification of the work
of these intelligence organisations against the Soviet Union began
prior to the appearance of this directive in August, 1940. And this
work, of course, was not limited to the spreading of false information
on the regrouping of forces from West to East.

I beg you, your Honours, to revert to the testimony which I have
already presented, of the former Chief of Abwehr III of the
Intelligence and Counter-Intelligence Services of the German Army, von
Bentivegny.

On Pages 1, 2 and 3 of the Russian text of Bentivegny's deposition, it
is said -- I quote the passage (underlined in blue pencil) beginning
at the last paragraph, Page 1 of the document, which corresponds to
Page 37 of the document book:

     "As early as November, 1940, I received from Canaris orders to
     intensify the work for counter-intelligence in the localities
     where concentration of the German armies on the Soviet-German
     frontier was taking place."
     
On Page 2 of the statement, Page 38 of the document book, paragraph 1,
Bentivegny continues:

     "In accordance with this order, I immediately gave the branches
     of the German military intelligence and counter-intelligence,
     Abwehrstelle Koenigsberg, Cracow, Breslau, Vienna, Danzig, and
     Poznan, the task of intensifying the countere-intelligence work."
     
And finally, on Page 3 of the statement, which corresponds to Page 39
of the document book, I read:

     "In March, 1941, I received from Canaris the following directives
     for the preparations for the execution of the  Plan "Barbarossa."
     
     (a) Preparation of all links of `Abwehr III' (Counter-
     Intelligence, Department III) for carrying out active counter-
     intelligence work against the Soviet Union, as, for instance the
     creation of the necessary counter-intelligence groups, their
     distribution among various fighting units intended for taking
     part in the operations on the Eastern front, and paralysing the
     activity of the Soviet intelligence and counter-intelligence
     organs.
     
     (b) Spreading false information via their foreign intelligence
     agencies, partly by creating the semblance of an improvement in
     relations with the Soviet Union and of preparations for a blow
     against Great Britain.
     
     (c) Counter-intelligence measures to keep secret the preparations
     being made for war with the Soviet Union and to ensure that the
     transfer of troops to the East be kept secret."
     
The same question is touched upon in the minutes of the interrogation
of the Chief of the Intelligence and Counter-Intelligence Abwehr I of
the German Army, Pieckenbrock, which I have already presented in
evidence. This statement contains the following passage regarding the
activities of the Intelligence Service of the German Army in
connection with the preparations

                                                            [Page 251]
                                                                      
for the realisation of  Case "Barbarossa." I would refer you to Page
35 of the document book, the 2nd paragraph from the top. This
corresponds to Page 2 of Pieckenbrock's testimony. Pieckenbrock
states:

     "In March, 1941, I was present at a conversation between Canaris
     and the head of the Diversion and Sabotage Department, `Abwehr
     II,' Colonel Lahousen, about measures connected with  Case
     `Barbarossa.' During this conversation they kept referring to a
     written order on this subject, which Lahousen had.
     
     I, personally, as head of Abwehr I, from February, 1941, to 22nd
     June, 1941, more than once had official talks with the head of
     the Foreign Armies Department of the General Staff, Lieutenant-
     General Tiepelskirch, and with the head of the detachment Foreign
     Armies East, Colonel Kienzl. These conversations dealt with the
     more precise definition of various tasks assigned to Abwehr, with
     regard to the Soviet Union, and in particular with the
     verification of old intelligence data about the Red Army, and
     also details about the dislocation of the Soviet armies during
     the period of preparation of the attack on the Soviet Union."
     
I now omit one paragraph and read further:

     "The field offices of the `Abwehrstelle,' which were working
     against Russia, were given the task of intensifying the dispatch
     of agents to the U.S.S.R. A similar task -- the intensification
     of espionage work against Russia -- was given to all intelligence
     agencies existing in the armies and army groups. For the most
     successful direction of all these `Abwehr' agencies, a special
     intelligence staff was created in May, 1941, under the code name
     of `Wally I.'
     
     Major Baun, as the best specialist on work against Russia, was
     appointed to direct Operation `Wally I.' Later, when following
     our example, `Abwehr II' and `Abwehr III' had also established
     staffs, `Wally II' and `Wally III,' these agencies became known
     as a whole staff , `Wally,' and directed the entire intelligence,
     counter-intelligence, and diversionary work against the U.S.S.R.
     At the head of staff 'Wally' was Colonel Schmalschlaeger."
     
I now pass on to the last paragraph of Pieckenbrock's statement on
Page 36 of the document book:

     "From numerous reports given by Colonel Lahousen to Canaris, at
     which I was also present, I know that a great deal of preparatory
     work for the war with the Soviet Union was carried out by this
     department. In the period of February to May, 1941, many
     conferences of the leaders of `Abwehr II' took place at the
     quarters of Jodl's deputy, General Warlimont. They were held in a
     cavalry school, in the small town of Krampnitz. One particular
     question settled at these conferences in accordance with the
     needs of the war with Russia, was that of increasing the special
     task units, `Brandenburg 800,' and of distributing contingents of
     these units among the individual Army Groups."
     
In Pieckenbrock's testimony which has just been read into the record,
special attention is drawn to his references to the special tasks with
which Lahousen's department had been entrusted, and to special task
units known under the code name of `Brandenburg 800.'

These points are here clarified by the testimony of a former Colonel
of the German Army, Erwin Stolze, who was Lahousen's deputy in Abwehr
II of of the German Military Intelligence and Counter-Intelligence
Services attached to the Supreme Command of the German Armed Forces.
Stolze was taken prisoner by the Red Army. I wish to submit to the
Tribunal as evidence

                                                            [Page 252]
                                                                      
Stolze's testimony of 25th December, 1945, which was given to
Lieutenant-Colonel Burashnikov, of the Counter-Intelligence Service of
the Red Army and which I submit to the Tribunal as Exhibit USSR 231
with the request that it be accepted as evidence. I will read into the
record individual extracts from this testimony, which are underlined
in red pencil. I begin the quotation from Page 48 of the document
book. Stolze testified as follows:

     "I received instructions from Lahousen to organise and to lead a
     special group under code name 'A,' which had to engage in the
     preparation of diversionary activities, and in the work of
     disintegration of the Soviet rearguard, in connection with the
     intended attack on the U.S.S.R.
     
     At the same time, in order that I should become acquainted with
     it, and for my guidance, Lahousen gave me an order which came
     from the Operational Staff of the Armed Forces and was signed by
     Field Marshal Keitel and General Jodl -- or General Warlimont on
     Keitel's instructions, I do not quite remember which -- and which
     contained basic directives for the conduct of subversive
     activities in the territory of the U.S.S.R., after Germany's
     attack on the Soviet Union. The order in question was for the
     first time marked with the code name `Barbarossa.'"
     
I am omitting two lines which are irrelevant to our case and read on:

     "It was pointed out in the order that for the purpose of
     delivering a lightning blow against the Soviet Union, `Abwehr
     II,' in conducting subversive work against Russia, must use its
     agents for kindling national antagonism among the people of the
     Soviet Union."
     
I now request you to turn over the page and on Page 49 in the document
book, on Page 2 of the minutes of the interrogation, to note the
following passages in his testimony:

     "In carrying out the above-mentioned instructions of Keitel and
     Jodl, I contacted Ukrainian Nationalists who were in the German
     Intelligence Service and other members of the Nationalist Fascist
     groups, whom I enlisted in to carry out the tasks as set out
     above.
     
     In particular, instructions were given by me personally to the
     leaders of the Ukrainian Nationalists, the German Agents Myelnik
     (code name 'Consul I') and Bandara to organise, immediately upon
     Germany's attack on the Soviet Union, and to provoke
     demonstrations in the Ukraine, in order to disrupt the immediate
     rear of the Soviet Armies, and also to convince international
     public opinion of alleged disintegration of the Soviet rear. We
     also prepared special diversionist groups for subversive
     activities in the Baltic Soviet Republics."
     
I must again request you to turn over the page. On Page 50 in the
document book, beginning with the third line from the top, you will
find Stolze's testimony:

     "Apart from this, a special military unit was trained for
     subversive activities on Soviet territory, a special duty
     training regiment `Brandenburg 800,' under the immediate command
     of the head of `Abwehr II,' Lahousen. Among the objects of this
     special unit, created in 1940, was the seizure of operationally
     important points, such as bridges, tunnels and defence
     installations, and holding them till the arrival of the advance
     units of the German Army.
     
At the same time, contrary to the international rules governing the
conduct of war, the personnel of this regiment, composed mainly of
Germans from beyond the border, made extensive use of enemy uniforms
and equipment in order to camouflage their operations:

     During the course of preparations for Germany's attack on the
     U.S.S.R., the command of the `Brandenburg 800' regiment also
     collected
     
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     supplies of Red Army uniforms, equipment and arms, and organised
     separate detachments of Germans acquainted with the Russian
     language."
     

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