Archive/File: imt/tgmwc/tgmwc-15/tgmwc-15-148.06
Last-Modified: 2000/03/30

Q. Yes. And I point out to you that it was Germany on every
occasion who violated the neutrality. The other countries,
the Allies, did not.

A. In the case of Norway, the English did that for the first
time in the case of the Altmark by laying mines and by
firing upon German ships in Norwegian territorial waters.
That has been proved indisputably. There is no doubt about
that.

Q. The Altmark case, as you very well know, witness, was not
an occupation at all; it was merely the act of the British
Navy in taking British prisoners from a German prison ship,
and I imagine your navy would have done the same if it had
had the chance. What is the good of talking about the
Altmark. It was not an occupation at all.

                                                  [Page 395]

A. But it was a violation of International Law as far as
Norwegian sovereignty was concerned. You could only request
that Norway do that, but you yourselves could not carry out
a combative action in Norwegian waters. I know the
regulations in this connection exactly.

Q. Why should you break your word to Norway and cause untold
suffering and misery to the inhabitants of that country
because the British went into the territorial waters and
took out a few hundred prisoners? What is the logic of it?
Why should the Norwegians suffer for it?

A. You have just quoted one small example of England's
violations of neutrality; there are hundreds of them.

Q. It is the example you quoted, witness, not I. I did not
quote it.

A. I can only say that up to the last moment, we were under
the definite subjective impression that we were carrying
through an enterprise for which British troops were already
embarked. If you can prove to me that that is not true, I
shall be extremely grateful to you.

Q. Well now, I am going to call your attention to the only
outside evidence that you have produced about that, because
it was read rather hurriedly - quite rightly, yesterday.

MR. ROBERTS: My Lord, it is in Jodl's Document Book 2, and
it is Page 176. Well, my Lord, it begins at Page 174. My
Lord, that is on the left hand top corner. Page 174. says
that Albrecht Soltmann was an expert specialist, that he
read the files from the British landing brigade, and that he
examined diaries. I read from the bottom of Page 175:

  " The documents and statements by prisoners showed that a
  short time before our landing in Norway, the British
  invasion troops had been embarked on destroyers. On the
  following day they were again disembarked and remained in
  the vicinity of the port of embarkation. They were then
  re-embarked after the German invasion of Norway and
  transported to Norway. What intention the English had in
  the embarkation of their troops before our landings could
  not be determined from the documents and from the
  statements of prisoners. Whether they intended to occupy
  Norway before our invasion could at that time only be
  conjectured, because the prisoners did not make any exact
  statements in this respect. The conjectures are based on
  the special equipment of these British troops. Insofar as
  I could evaluate the documents and statements furnished
  by prisoners, they did not contain proof of English plans
  with regard to Norway."

And this is the next question:

  "Have not the results of all documents and statements
  furnished by prisoners been to the effect that in the
  invasion of Norway we arrived only just ahead of the
  English?
  
  Answer: Yes, the information in the documents and the
  statements furnished by prisoners could be interpreted to
  mean that in our invasion we were just ahead of the
  English. However, whether this was considered
  unmistakable evidence I cannot judge."

And then they deal with French documents captured in a
railway train. The witness does not know anything about
them.

BY MR. ROBERTS:

Q. That is pretty poor evidence, is it not, on which Norway
was to be invaded, contrary to all the treaties and all the
assurances?

A. I quite agree with you on that; you are quite correct.
But that is only because Soltmann was unfortunately, not the
expert in this field. He was not even an officer of the
General Staff. I had forgotten that. We had further and
quite different evidence which lay before me on my desk;
namely, all the orders carried by the English landing
brigade. They confirmed our assumptions absolutely and
definitely.

Q. An invasion without any warning or any declaration of
war?

                                                  [Page 396]

A. That is a political question.

Q. You told the Tribunal yesterday what a stickler you were
about International Law, how keen you were to see that
International Law was observed. You knew that was against
International Law, did you not?

A. These matters were not in our regulations, but only the
agreements which applied to the Wehrmacht. The concept of an
aggressive war, or not, was not found in any regulation.
Only the Geneva Convention and the Hague Land, Warfare
Regulations were the things that we went by.

Q. I mean if an honourable German gives his word, he keeps
it, does he not? He does not break his word without saying
that he is going to depart from it, does he, an honourable
German?

A. That seems to be a practice which is generally observed
all over the world when human beings work together, but not
in the sphere of politics.

Q. If that is your code of honour, why is it not grossly
dishonourable for Germany to break her word over and over
and over again? Or would you rather not answer that
question?

A. No, you would do better to put that question to the
people who were responsible for German politics.

Q. Very well, I will leave that. Now I want to come to the
invasion of Holland, Belgium, and the Netherlands. I beg
your pardon, the Netherlands, Belgium and Luxembourg.

You have no doubt at all, have you, as shown by documents,
that, in the event of war in the West, it was always
Hitler's intention to violate the neutrality of those three
small countries?

A. From the beginning, in his orders for the attack in the
West, he had the intention to go through Belgium, but he had
reservations with regard to Holland for a long time, which
were only abandoned later, I believe in the middle of
November. Regarding Holland, his intentions were not
determined. Regarding Belgium, his intentions in that
direction were known comparatively early, that is, about the
middle or the early part of October.

Q. You could not, of course - I mean Germany naturally
wanted to wage an offensive war and an offensive war in
somebody else's country. That was the ambition, naturally,
is it not?

A. The German objective in this war was to win.

Q. Yes. You could not attack in the West unless you attacked
through Belgium, could you?

A. In any event, any other attack was tremendously difficult
and was highly questionable. I have already said that.

Q. Yes. That is why, of course, France built the Maginot
Line, so that you could not attack her frontally.

Well, now, if you secured the coast of Belgium and Holland,
you secured air bases from which you could annihilate
England or Great Britain. That is what you hoped, was it
not?

A. No doubt the strategic position of Germany in the battle
against England would have been much improved through our
having the coast; that is true.

Q. Yes. May I just remind you of a few documents with which
the Tribunal are already familiar. I do not intend to read
them, but the first document in order of date is 375-PS,
Exhibit USA 84, dated 25th August, 1938. It is during the
"Fall Gruen" time. That was the Air Force opinion in which,
in the last paragraph of the document, Page 9, I think, it
says:

  "Belgium and the Netherlands in German hands would
  represent an extraordinary advantage in the air war
  against Great Britain."

And the Army is asked to say how long the operation would
take. That was at the time of the Czechoslovakian crisis,
was it not?

A. Yes, but this document, I believe, has already been
characterised as a ridiculous piece of paper, being the work
of an insignificant captain.

                                                  [Page 397]

Q. He seems to have been a very good judge, at any rate,
judging from what happened afterwards.

Well now, the next document - I know you were in Austria,
but no doubt you heard about it from Keitel - was the
Chancellery meeting on 23rd May, 1939. That is Document
L-79, it is Book No. 7, Page 275. Do you remember that the
Fuehrer said:

  "The Dutch and Belgian air bases must be occupied by
  armed forces. Declarations of neutrality must be ignored
  .... The Army will have to hold positions essential to
  the Navy and the Air Force. If Holland and Belgium are
  successfully occupied and held, and if France is also
  defeated, then fundamental conditions for a successful
  war against England will have been secured .... Daily
  attacks by the German Air Force will cut her life lines."

There was not any doubt as to the policy of the Fuehrer in
May, 1939, was there?

A. It was in Court here that I first heard about this
conference and about the things which were purported to have
been discussed at that time, and I am not able to judge
whether it is correct, for I did not hear it, not even from
Keitel, nor even later.

Q. Very good. Did you hear about the speech made by the
Fuehrer on the 22nd of August, 1939?

MR. ROBERTS: I do not know if the Tribunal has got this. It
is not in the document book, Document 798-PS, in Document
Book No. 4. There are some loose copies, my Lord.

BY MR. ROBERTS:

  Q. " .... Holland, Belgium .... and Scandinavia will
  defend their neutrality with all available means. England
  and France will not violate their neutrality."

You always thought Hitler was a good prophet, did you not?
You thought Hitler was a good judge.

A. Very often, yes, very often.

Q. And he was a good judge that England and France would
keep their word, whereas Germany would break hers.

That is August. Now then I want to -

A. But that I do not know.

Q. Very good. Now, I want to come to the document which you
put in yesterday.

THE PRESIDENT: Well, wait a minute. Defendant, what do you
mean saying you do not know that? Do you mean that you did
not know the document? You said, "I do not know that."

THE WITNESS: I do not know what the Fuehrer actually said in
his conference on the 22nd of August. I did not even know
that a discussion had taken place, for I was in Vienna. I
only know what is in documents which have been submitted
here.

BY MR. ROBERTS:

Q. Now I want to go through the whole of Document L-52. Dr.
Exner, quite properly, of course, read some extracts, but I
want to read some more. Have you got copies for the
Tribunal?

Now, L-52 was Hitler's memorandum of 9th October, 1939. May
I point out that the 9th of October, 1939, was three days
after his renewed assurances to the Western neutrals.

Certain passages you have read; I want to refer to others.

MR. ROBERTS: My Lord, what I am now reading from, starting
with the outside page, is the 5th page. It is Page 27 of the
original.

BY MR. ROBERTS:

Q. I read the paragraph on Page 25 of your original,
witness:

  "Germany's military means of waging a lengthy war are, as
  far as our main enemy is concerned, the Air Force and the
  U-boat arm.
  
                                                  [Page 398]
  
  The U-boat can even today, if ruthlessly employed, be an
  extraordinary threat to England. The weaknesses of German
  U-boat warfare lie in the great distance of approach to
  the scene of their activity, in the extraordinary danger
  attached to these approaches and in the continuous threat
  to their home bases. That England has not, for the
  moment, laid the great minefields as in World War I,
  between Norway and the Shetland Islands, is possibly
  connected - provided the will to wage war exists at all -
  with a shortage of necessary barrage materials. But, if
  the war lasts long, an increasing difficulty to our
  U-boats must be reckoned with in the use of these only
  remaining inward and outward routes. Every creation of
  U-boat bases outside these constricted home bases would
  lead to an enormous increase in the striking power of
  this arm."

Is that a covert reference to the Norwegian bases, do you
think, giving access to the Atlantic?

A. I do not believe so. I believe it is a general correct
naval strategic consideration, and can apply just as well to
a base at Murmansk which, for instance, we already had at
that time, or in Spain, or in some other State that was
neutral at that time, but it is not a reference to Norway,
for I have declared under oath that at the time the Fuehrer
never gave a thought to Norway, not the slightest thought,
before he received the report from Quisling.

Q. I have heard your answer. Now, may I go on reading?

  "The German Air Force can only then succeed in effective
  operations against the industrial centre of England and
  her south and south-west ports which are gaining in
  importance during the war, when it is no longer compelled
  to operate offensively from our present small North Sea
  coast by tremendously devious routes involving long
  flights. If the Dutch-Belgian areas were to fall into the
  hands of the English and French, then the enemy air
  forces, in order to strike at the industrial heart of
  Germany, would need to cover barely a sixth of the
  distance required by the German bomber to reach really
  important targets. If we were in possession of Holland,
  Belgium, or even the Straits of Dover as jumping-off
  bases for German air attacks, then, without a doubt,
  Great Britain could be struck a mortal blow, even if the
  strongest reprisals were attempted.
  
  Such a shortening of the air approaches would be all the
  more important to Germany, because of our greater
  difficulties in fuel supply. Every 1000 kilograms of fuel
  saved is not only an asset to our national economy, but
  means that 1,000 kilograms more of explosive can be
  carried in the aircraft; that is, 1,000 kilograms of fuel
  would become 1,000 kilograms of bombs. This also leads to
  economy in aircraft, in mechanical wear and tear, and
  above all, in valuable airmen's lives."

Then I ask you to turn to your Page 41.

MR. ROBERTS: My Lord, it is two pages on, and your Lordship
will see "41" nearly at the top of the page, with an
asterisk, and the heading "The German Attack." Has your
Lordship got it?

THE PRESIDENT: Yes.

BY MR. ROBERTS,

  Q. "The German Attack. The German attack is to be
  launched with the fundamental object of destroying the
  French Army, but in any case it must create a favourable
  initial situation which is a prerequisite for a
  successful continuation of the war. Under these
  circumstances, the only possible area of attack is the
  section between Luxembourg in the South, and Nijmegen in
  the North, excluding the fortress of Liege. The object is
  to attempt to penetrate the area Luxembourg, Belgium, and
  Holland in the shortest possible time, and to engage and
  defeat the opposing Belgian-French-English forces."

I suppose I cannot ask you to say what is your opinion of
the honesty of giving those western neutrals a guarantee on
the 6th of October and saying that is the only

                                                  [Page 399]

possible means of attack in that memorandum of the 9th. I
suppose that is a question of politics, is it?

A. That is a political question, but the declarations were
always made only on the condition of the strictest
neutrality of these countries. But this neutrality was not
kept, for British flyers flew over this area by day and by
night.

Why should the wretched people of the Netherlands and
Belgium be destroyed and mutilated because British airmen
fly over their territory - destroyed and mutilated by the
German Army? What is the logic of your remark at all?

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