Archive/File: imt/tgmwc/tgmwc-21/tgmwc-21-201.02
Last-Modified: 2000/11/19

BY GENERAL ALEXANDROV:

Q. Please, witness, look at Section 3 of the decree, point
C. I shall read it into the record: "For this task the
ruthless conscription of the civilian population,
uninfluenced by any false softness, the speedy commencement
of work and the establishment of construction battalions,
including female construction battalions, must be enforced."
Do you consider this method of utilising the civilian
population, including the female population, as a method
necessitated by military considerations?

A. As I see it there, I do not doubt at all that it was
necessary from a military standpoint. Whether or not it was
correct from a human point of view is another, question. But
I must point out that the use of the civilian population,
including the women, was something we learned from the
Soviet Union, which did just that to a large extent,
otherwise the creation of Russian anti-tank ditches many
kilometres long would not have been possible in a few days.

BY THE PRESIDENT:

Witness, is it your contention that it is in accordance with
the laws of war to  turn the females of a country into a
construction battalion for the purposes of your army?

A. I am not absolutely certain at the moment whether that is
in accordance with the laws of war of 1939. That in this war
International Law was exceeded in many cases is an
ascertained fact. That the use of labour, also of female
labour, is one of the rights of an occupying power, is, I
should think, true.

BY GENERAL ALEXANDROV:

You have just stated that the Red Army widely used the
civilian population for constructing anti-tank ditches, etc.
I want to explain that to you. That was really so, because
the whole Soviet people, including the Soviet women of
course, participated in all possible actions against the
Fascist invaders; but give me an illustration, just one
illustration, of the Red Army utilising German women for
purposes of this kind.

A. I cannot give you an instance in this war.

                                                   [Page 80]

Q. Because there were none, but this decree of Hitler talks
of utilising Soviet women for erecting defence constructions
for German forces. That is what I am speaking about. Now we
will go to another question. Did you know that in May, 1944,
a special conference of generals of the German Army was held
in Sonthofen on the subject of National Socialist education
of the Army units?

A. In May, 1944, I was no longer in service, and therefore I
did not hear anything about this conference.

Q. You never heard anything about the conference?

A. I did not hear anything about that conference, no.

Q. I should like to mention one fact in connection with that
conference. You will probably know that at that conference
the defendant Keitel, among others, stated as follows:
"Officers who express any doubt about victory or who
criticise the Fuehrer I shall have shot."

THE PRESIDENT: The witness says he knows nothing about it.
Is this a new document you have got or not? Is it some new
document?

GENERAL ALEXANDROV: No. We do have a document on which I
think it is necessary to ask the witness some questions, but
we are not submitting this document immediately, because we
have only just received it and it has not yet been
translated. It is an affidavit of Lt.-General Vincent Muller
of the German Army, in which he mentions Keitel's remark. If
the Tribunal considers it necessary, this document will be
put in at the end of this afternoon's session, or at the
latest tomorrow morning.

THE PRESIDENT: Yes, all I mean is this: If you are not
putting in the document and the witness says he was not at
the conference and never heard of the conference, I do not
think you can put to him what was stated at the conference
in order to get that in evidence.

GENERAL ALEXANDROV: I understand, Mr. President. In that
case I will ask another question.

BY GENERAL ALEXANDROV:

Q. Witness, are you aware that the command of the German
Navy suggested the invasion of Norway in October, 1939? Were
you aware of that?

A. No. I knew nothing about that. I heard of the entire
Norwegian affair only when it had become an accomplished
fact. I learned the details only from the Indictment, before
that I did not hear a word about it.

Q. What do you know about the plan for an operation under
the code name "Jolka"?

A. I did not understand the code name.

Q. Under the code name "Jolka" - that means "Christmas Tree"
in English or "Tannenbaum" in German.

A. "Tannenbaum?" No, it does not mean anything to me, I do
not know.

Q. I shall point out to you a few details relating to the
plan. In the middle of July, 1940, after the armistice with
France, the Chief of the German General Staff, General
Halder, visited von Leeb's headquarters in Dijon. General
Halder told von Leeb to prepare a plan for the occupation of
Switzerland, taking into consideration the fact that the
Swiss would resist. This plan was worked out under the code
name "Christmas Tree" and submitted to the OKH for action.
Do you know anything about it?

A. No, I was Commanding General at the time, and in the
summer I went to the Channel coast. I heard nothing about
this plan.

Q. You frequently emphasized here in your answers that the
war against the Soviet Union was a "special war," and that
you, as other German generals, acted only as soldiers, and
that the so-called "ideological" war was conducted by Hitler
and his colleagues. Did I understand that correctly?

A. Yes.

                                                   [Page 81]

Q. My American colleague reminded you yesterday about your
own decree in which you were speaking about the annihilation
of the Soviet political system and other basic enterprises
in the occupied territories. You also stated you were aware
of the decree of Field-Marshal Reichenau about the conduct
of the troops required in the East. Was such a decree, in
your opinion, prompted by a military sense of duty, or by
other considerations?

A. No, it was certainly issued only out of a military sense
of duty. In connection with this, I should like to add that
these ideas were appearing in every newspaper and were, of
course, promoted by higher authorities. They certainly did
not originate with us. We, together with our soldiers,
conducted the war in a military manner.

Q. Do you not think that such decrees can only be explained
by the fact that their authors, were not generals brought up
in the military tradition, but in the Hitlerite tradition.

A. I did not quite understand that. May I ask you to explain
the meaning of the question again.

Q. I will repeat it. Do you not think that such decrees,
political decrees really - I mean the order issued by
Reichenau - do you not think that such decrees can only be
explained by the fact that their authors were not generals
brought up in the military tradition, but generals brought
up in the Hitlerite tradition?

A. I can only speak for myself, for my own order. That I,
personally, was nothing more than a soldier, to that I think
every one of my subordinates and my superiors can testify. I
was not a political general, nor was I, shall we say, a
National Socialist general in the sense in which you mean
it. This order was a consequence of the growing danger of
the partisans, and the necessity to make it clear to our
soldiers that they could not afford to be so careless, and
that they must be aware that the fight on both sides was an
ideological fight. The order itself falls into two entirely
different parts. Part one, which deals with the necessity of
safeguarding the rear against attack, etc., and with the
alertness of the soldiers, contains some ideas about the
meaning of this struggle. When the order speaks of the
extermination of a system, then it means the political
system, and not human beings; it means exactly what is today
meant when the other side speaks of the extermination of
National Socialism. The second part I would say contains my
own ideas, it states what has to be done positively, and it
also states quite clearly that the soldiers must avoid all
arbitrary action, and that any violation of the honour of
the soldier will be punished. I believe that this order is
evidence of the fact that I conducted the fight as a
soldier, and not as a politician.

Q. What you were during the war, your own decree shows best,
and the Tribunal will be able to judge it.

My last question. Did you know what measures the Supreme
Command of the Wehrmacht initiated for the purpose of
conducting biological warfare?

A. Biological warfare? I do not know at the moment what you
mean by the expression "biological warfare." Would you
explain that, please?

Q. The use of various types of dangerous bacteria in
warfare. That is what I mean by "biological warfare."

A. No. I knew nothing about it. I have never heard of a
bacteriological war or of poison warfare.

Q. You will now be shown several details of this plan for
biological warfare, and you may then be able to recall it. I
am submitting to the Tribunal Document USSR 510, which
consists of the affidavit of the former Major-General of the
Medical Corps of the German Army, Professor of the Military
Medical Academy in Berlin, Walter Schreiber. I am reading it
into the record.

  "In connection with the trial of the major war criminals
  in Nuremberg, I, as Professor of Hygiene and Bacteriology
  of the Military Medical Academy in Berlin and former
  Major-General of the Medical Corps of the German Army,
  consider it my duty to our people, who have undergone
  such severe

                                                   [Page 82]

  trials, and to the whole world, to disclose one more page
  of Germany's preparation for war which has not been
  touched upon in Nuremberg. Apart from the former
  political and military leadership of Germany a large part
  of the guilt is born by the German scientists and
  particularly by German doctors. Had that type of weapon
  which was being prepared been used, it would have meant
  putting to a shameful and evil use the great discoveries
  of Robert Koch, whose native country was Germany and who
  was a great teacher - "

THE PRESIDENT: Dr. Laternser, counsel for the defence, would
like to say something.

DR. LATERNSER: I should like to raise an objection. By
looking through the document, I discovered that the author
of this affidavit is raising particularly grave accusations.
I do not know against whom these accusations are directed,
but I should like to ask that the author of this document
appear as a witness, so that I may cross-examine him.

THE PRESIDENT: Where is he?

GENERAL ALEXANDROV: I can answer that. The former General
Walter Schreiber is now in the Soviet Union as a prisoner of
war. If the Tribunal thinks it necessary to have Walter
Schreiber testify here as a witness, the prosecution will
not object,

DR. LATERNSER: I think that if he is making such a serious
allegation he should appear here in person.

THE PRESIDENT: General Alexandrov, could you inform the
Tribunal how long it would take to get this witness
Schreiber brought here for the purpose of cross-examination?

GENERAL ALEXANDROV: We shall take all steps to get the
witness here in the shortest possible time, but I cannot
guarantee or state a number of days, since the distance is
rather great. I would like the Tribunal to take this into
consideration. However, regardless of whether the witness is
going to be brought here or not, I request the permission of
the Tribunal to have this document presented in the cross-
examination.

DR. LATERNSER: May I be allowed to reply to that?

THE PRESIDENT: Dr. Laternser, you can make your objections
if you wish to do so now and then the Tribunal will consider
the matter when they adjourn. We do not propose to allow the
document to be presented now at the moment. We will consider
the matter when we adjourn.

DR. LATERNSER: I request that the Tribunal decide that the
document must not be read until Walter Schreiber can appear
here as a witness.

THE PRESIDENT: Your application is that the document should
not be admitted unless the witness is brought here for
further examination?

DR. LATERNSER: I should like to go even farther, Mr.
President, and apply that the document should not be
admitted at all, since the witness is now going to be
produced by the prosecution, and can then state these facts
under oath.

GENERAL ALEXANDROV: Mr. President, may I oppose the
application of the defence. It seems to me that the
affidavit of Walter Schreiber could and should be read
during the cross-examination of this witness, regardless of
whether Walter Schreiber will or will not appear here as a
witness. A photostat of his affidavit is before the
Tribunal, it is certified by the Extraordinary State
Commission, which is the Plenipotentiary of the Soviet
Government. Therefore regardless of what the Tribunal may
decide about calling Walter Schreiber as a witness, I insist
that the document which I put in as USSR 510 be accepted by
the Tribunal and that I be given an opportunity of reading
it into the record during the present cross-examination.

                                                   [Page 83]

THE PRESIDENT: No, General Alexandrov, the Tribunal has said
that they will not admit the document at this stage. We
propose to adjourn at 11.30 and will then consider the
application. I observe that the affidavit was made in April,
1946, and there was plenty of time to bring the witness
here.

GENERAL ALEXANDROV: The question of bringing the witness
here has never had to be considered up to now. If the
Tribunal commands me not to use the document, I shall not be
able to ask the witness the questions which arise out of the
affidavit of Walter Schreiber. Moreover, I shall thereby be
prevented from putting questions on Walter Schreiber's
affidavit at another stage of this trial.

THE PRESIDENT: General Alexandrov, you will be able to ask
him the question after the Tribunal has decided upon the
admissibility of the document, that is to say, if it is
decided as to its admissibility, can you not ask him then?
But he has already said he knows nothing of biological
warfare.

GENERAL ALEXANDROV: He does not know what is in the
affidavit of Dr. Schreiber. I have no further questions at
the moment, Mr. President.

THE PRESIDENT: Is there any further cross-examination?

RE-EXAMINATION

BY DR. LATERNSER:

Q. Field-Marshal, you were questioned about the order, or
alleged order, of the Quartermaster-General Wagner, which
prohibited the feeding of prisoners of war from supplies of
the armed forces. I would like to ask you, do you know that
Colonel-General Halder, during a visit to the front on the
occasion of a conference at Orscha, actually ordered that
the food supplies to the troops should be cut so that
prisoners of war could be better fed?

A. This is not known to me, because it did not take place in
my area. I do know that in the winter of 1941-42 I had to
reduce the rations in the Crimea since the supplies from
home did not arrive in sufficient quantity on account of the
shortage of railroad transportation, and also since we could
not completely strip the country of all food reserves to
feed the population and the prisoners. As far as I can
recollect, we reduced the meat ration at that time, and I
know that I expressly prohibited that the one cow, which
would have remained the farmer's own property even under the
Soviet Government, should be taken away from him, even
though the Army needed the meat. I also remember that when
the food situation became critical at times during that
winter, we sent flour down to the south coast, although
hundreds, in fact thousands of horses belonging to our army
on the south coast perished, at that time, because on
account of the shortage of transport space we could not
bring down hay and straw for them.

Q. The order USSR 155 was submitted to you. Who signed that
order?

A. I do not know which one you mean, USSR -

Q. I mean Document 115.

A. I do not have the number.

THE PRESIDENT: We can see for ourselves by whom it is
signed.

BY DR. LATERNSER:

Q. I merely want to know by whom it is signed.

A. Oh, yes, I see, it is signed by Adolf Hitler.

Q. Yes, that is the order. You were questioned with regard
to number 2-d. It says there that "the land should be made
useless and uninhabitable." Do you know, Field-Marshal, if
that was actually carried out?

A. I cannot give information about the district of Kuban,
because I was not there, and it did not belong to my area.

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