Archive/File: imt/tgmwc/tgmwc-04/tgmwc-04-32.05
Last-Modified: 1999/09/25

Soon after the passage of the decree of 12th November defendant
Funk delivered a speech on the Jewish question. He made it clear
that the programme of economic persecution was part of the larger
programme of extermination, and he boasted of the fact that the
new programme ensured the complete elimination of Jews from the
Germany economy. I offer in evidence Document No. 3545-PS as
Exhibit USA 659. This document, which is found on Page 76 of the
document book, is a certified photostatic copy of Page 2 of the
"Frankfurter Zeitung" of 17th November, 1938. I quote a brief
portion of that speech:

   "The State and the economy constitute a unit. They must be
   directed according to the same principles. The best proof
   thereof has been rendered by the most recent development of the
   Jewish problem in Germany. One cannot exclude the Jews from the
   political life and yet let them live and work in the economic
   sphere."

I shall omit the rest, with the request that the Tribunal take
judicial notice of this reprint from the German newspaper, the
"Frankfurter Zeitung."

I wish, however, to refer to just one more decree signed by
defendant Funk himself. On the 3rd of December, 1938, he signed a
decree which imposed additional and drastic economic disabilities
upon the Jews, and subjected their property to confiscation and
forced liquidation. This decree is set forth in the
Reichsgesetzblatt, 1938, Part 1, Page 1709. Defendant Funk himself
has admitted and deplored his responsibility for the economic
persecution of the Jews. I offer in evidence Document 3544-PS as
Exhibit USA 660. This document, which is the last document in
connection with this phase of the case, is an interrogation of
defendant Funk dated 22nd October, 1945. Your

                                                        [Page 200]

Honours will find it on Pages 102 and 103 of the document book. I
wish to quote from Pages 26 to 27 of the interrogation. The
corresponding page of the German translation is Page 21. Although
I propose to quote enough to place defendant Funk's statements in
their proper context, I do not, of course, intend to give any
credence to his attempts at self-justification:

   "Q. All the decrees excluding the Jews from industry were
   yours, were they not?"

Now, omitting the first nine lines of the reply:

   "A. So far as my participation in this Jewish affair is
   concerned, that was my responsibility, and I regretted later on
   that I ever did participate. The Party had always brought
   pressure to bear on me to make me agree to the confiscation of
   Jewish property, and I had refused repeatedly. But, later on,
   when the anti-Jewish measures and the force against Jews came
   into effect, something legal had to be done to prevent the
   looting and confiscation of all Jewish property.
   
   Q. You knew that the looting and all that was done at the
   instigation of the Party, did not you?"

Here defendant Funk wept, and answered:

   "Yes, most certainly. That is when I should have left, in 1938.
   Of that I am guilty; I am guilty; I admit that I am a guilty
   party here."

In the Propaganda Ministry defendant Funk, as we have seen, helped
solidify the German people in favour of war. When he moved on to
his position as Minister of Economics, and to other positions
which will appear, he used his talents even more directly for the
conspirators' main task: preparation for war. Immediately before
defendant Funk took over the Ministry of Economics from defendant
Schacht in 1938 there was a major reorganisation of that
Ministry's functions which integrated it with the Four Year Plan
as the supreme command of the German military economy. This
reorganisation was effected by a decree, dated 4th February, 1938,
signed by Goering as Commissioner of the Four Year Plan. This
decree is set forth in an official monthly bulletin issued by
Goering and entitled, in the English translation, "The Four Year
Plan," Volume 11, Page 105. It is requested that the Tribunal take
judicial notice of this publication.

At this point I would simply note that that decree makes it clear
that defendant Funk assumed a critical role in the task of
economic mobilisation during a decisive period. Indeed, in 1938 he
was directly charged with the task of preparing the German economy
for war. By a secret decree he was made Chief Plenipotentiary for
Economics and assumed the duties which once had been discharged by
defendant Schacht. In this connection I refer to Document 2194-PS,
which has already been placed in evidence. This document, which is
found on Page 111 of your Honours' document books, consists of a
letter dated 6th September, 1939, and that letter transmitted a
copy of the Reich Defence Law of 4th September, 1938. It is this
enclosure that we wish to deal with now. I wish to quote from Page
4 of the translation paragraphs 2 to 4:

   "It is the task of the G.B.W." - that is the Chief
   Plenipotentiary for Economics - "to put all economic forces
   into the service of the Reich defence and to safeguard
   economically the life of the German nation.
   To him are subordinate:
      the Reich Minister of Economics;
      the Reich Minister of Nutrition and Agriculture;
      the Reich Minister of Labour," and so on.
   
   "He is furthermore responsible for directing the financing of
   the Reich defence within the realm of the Reich Finance
   Ministry and the Reichsbank."

                                                        [Page 201]

To quote one more paragraph:

   "The G.B.W. must carry out the demands of the O.K.W., which are
   of considerable importance for the Armed Forces; and he must
   insure the economic conditions for the production of the
   armament industry directed immediately by O.K.W. according to
   its demands."

This law, in essence, re-enacted the provisions previously passed
in the Reich Defence Law of 1935, and I will not trouble the
Tribunal with further reading. I do wish to note, however, that
the law was, at the specific direction of Hitler, kept secret, and
that it was signed by defendant Funk, among others, as Chief
Plenipotentiary for Economics. Your Honours will find defendant
Funk's signature on the next to the last page of the document, and
I invite your attention to the names of his co-signatories.

Defendant Funk, in a speech which he delivered on 14th October,
1939, explained how, as Chief Plenipotentiary for Economics, he
had for a year and a half prior to the launching of the aggression
against Poland advanced Germany's economic preparations for war. I
offer in evidence Document 3324-PS as Exhibit USA 661. This
document is a German book by Berndt and von Wedel entitled, in the
English translation, "Germany in the Fight." That book reprints
the defendant's speech. I quote now from Page 2 of the translation
of Document 3324-PS, which is found on Page 116 of the document
book. The translation of this speech is somewhat awkward, and with
the Tribunal's permission I would rephrase it somewhat, without
changing its substance in the slightest:

   "Although all economic and financial departments were harnessed
   to the task of the Four Year Plan under the leadership of
   General Field Marshal Goering, Germany's economic preparation
   for war was also secretly advanced in another sector for well
   over a year, namely, through the formation of a national
   guiding apparatus for special war economy tasks which would
   have to be accomplished the moment that war became a fact. For
   this work all economic departments were combined into one
   administrative authority, the General Plenipotentiary for
   Economy, to which position the Fuehrer appointed me one and a
   half years ago."

THE PRESIDENT: What was the date of that?

LIEUTENANT MELTZER: The date of that speech, Sir, is October.

THE PRESIDENT: The 14th of October?

LIEUTENANT MELTZER: The 14th October, 1939.

In his dual capacity as Chief Plenipotentiary for Economics and
Minister of Economics, defendant Funk was naturally advised of the
requirements which the conspirators' programme of aggression
imposed on the German economy. In this connection I would invite
the Tribunal's attention to Document 1301-PS, which is already in
evidence. As your Honours will recall, this document is a top
secret report of the conference held in defendant Goering's office
on 14th October, 1938. Your Honours will find it on Page 142 of
the document book. I shall simply summarise the relevant portions
of this document.

During the conference Goering referred to the world situation and
to Hitler's directive to organise a gigantic armament programme.
He thereupon directed the Ministry of Economics to increase
exports in order to obtain the foreign exchange necessary for
stepping up armament. He added, as your Honours will recall, that
the Luftwaffe must be increased fivefold, that the Navy should arm
more quickly, and that the Army should accelerate the production
of weapons for attack. Defendant Goering's words, directed at
Funk, among others, were the words of a man already at war, and
his emphasis on quintupling the Luftwaffe and on the production of
weapons for attack was that of a man waging aggressive war.

                                                        [Page 202]

After Schacht's departure Funk was a key figure in the preparation
of plans to finance the war. This was natural, since he, after
1939, occupied three positions crucial to war finance, Two we have
already named: Minister of Economics and Chief Plenipotentiary for
Economics. In addition, he was President of the Reichsbank.

Funk's role in war financing is illustrated by Document 3562-PS,
which I now offer in evidence as Exhibit USA 662. This document
was found in the captured files of the Reich Ministry of
Economics. It consists in part of a letter from the Chief
Plenipotentiary for Economics, signed on his behalf by Dr. Posse.
The letter is dated 1st June, 1939, and encloses the minutes of a
conference concerning the financing of the war which was held
under the chairmanship of Funk's Undersecretary in the Ministry of
Economics, Dr. Landfried. A copy of the document which I have
offered into evidence bears a marginal note on Page 1 in the
bottom left-hand corner, dated 5th June, stating, and I quote: "To
be shown to the Minister" - that is, Funk - "for his information."

During the course of the meeting, which was attended by twelve
officials, five of whom were directly responsible to defendant
Funk in his various capacities, the conferees discussed a
memorandum regarding war finance which had been prepared by the
Chief Plenipotentiary for Economics on 9th May, 1939. I wish to
quote briefly from Page 2 of the English translation, which is
found on Page 153 of your Honours' document book:

   "Then a report was made of the contents of the notes on the
   question of internal financing of war of 9th May of this year,
   in which the figures given to me by the Reich Minister of
   Finance are also discussed. It was pointed out that the General
   Plenipotentiary for Economy is primarily interested in
   introducing into the legislation for war finance, the idea of
   financing war expenditures by anticipating future revenues to
   be expected after the war."

If I may quote another brief excerpt from this important
memorandum, which is found on Page 2 of the English translation,
Page 153 of your document books:

   "State Secretary Neumann first submitted for discussion the
   question of whether the production would be able to meet, to
   the assumed extent, the demands of the army, especially if the
   demands of the army, as stated in the above report, should
   increase to approximately 14 billions in the first three months
   of war. He stated that, if the production potential of the
   present Reich territory is taken as a basis, he doubts the
   possibility of such an increase."

It is plain then that defendant Funk exercised comprehensive
authority over large areas of the German economy, whose proper
organisation and direction were critical to effective war
preparation. The once powerful military machine, which rested on
the foundation of thorough economic preparation, was a tribute to
the contribution which defendant Funk had made to Nazi aggression.

Funk made this contribution with full knowledge of the plans for
military aggression. A compelling inference of such knowledge
would arise from the combination of several factors: from Funk's
long and intimate association with the Nazi inner circle, from the
very nature of his official functions, from the war-dominated
setting of Nazi Germany, and from the fact that force and the
threat of force had become the primary and the open instruments of
German foreign policy. And the final element in weighing the
question of defendant Funk's knowledge is, of course, the fact
that, at the same time that defendant Funk was making economic
preparation, specific plans for aggression were being formulated,
plans which were later carried out and plans which could be
effectively carried out only if they were synchronised with the
complementary economic measures.

                                                        [Page 203]

The conclusion concerning defendant Funk's knowledge is reinforced
beyond any question by considering, in the light of the factors
described above, the more specific and direct evidence which has
already been placed into the record. We have seen from Document
1760-PS that defendant Funk had told Mr. Messersmith that the
absorption of Austria by Germany was a political and economic
necessity, and that it would be achieved by whatever means were
necessary.

We have already referred to Document 1301-PS, in which defendant
Goering laid down directives which could be understood only as
directives to prepare the economic basis for aggression. And
Document 3562-PS has revealed that defendant Funk was making
detailed plans for financing the war, that is, of course, a
particular war, the war against Poland. In this connection I wish
to refer to another vital piece of evidence which has already been
introduced in the record. It is the letter dated 25th August,
1939, which defendant Funk wrote to Hitler. In that letter, as
your Honours will recall, defendant Funk expressed his gratitude
at being able to experience those world-shaking times, and to
contribute to those tremendous events. And he thanked Hitler for
approving his proposals, designed to prepare the German economy
for the war.

Moreover, the record contains evidence showing that defendant
Funk, both personally and through his representatives,
participated in the economic planning which preceded the military
aggression against the Soviet Union. I would refer the Tribunal to
Document 1039-PS, which revealed that in April of 1941 defendant
Rosenberg, who had been appointed deputy for the centralised
treatment of problems related to the occupation of the Eastern
Territories, that is, the Soviet Union, discussed with defendant
Funk the economic problems which would arise when the plans for
aggression in the East matured. And Document 1039-PS also reveals
that defendant Funk appointed one Dr. Schlotterer as his deputy,
to collaborate with Rosenberg in connection with the exploitation
of the Eastern Territories and that Schlotterer met with defendant
Rosenberg almost daily.

It is clear, then, that Funk participated in every phase of the
conspirators' programme, from their seizure of power to their
final defeat. Throughout he worked effectively, if sometimes more
quietly than others, on behalf of the Nazi programme, a programme
which, from the very beginning, he knew contemplated the use of
ruthless terror and force within Germany and, if necessary,
outside of Germany. He bears, we submit, a special, a direct and a
heavy responsibility for the commission of Crimes against
Humanity, Crimes against Peace and War Crimes. The record makes it
clear, if we may summarise the evidence, that by virtue of his
activities in the Ministry of Propaganda and in the Ministry of
Economics, he is responsible for stimulating and engaging in the
unrelenting persecution of the Jews and other minorities, for
psychologically mobilising the German people for aggressive war,
and for weakening the willingness and capacity of the
conspirators' intended victims to resist aggression. It is also
clear, we submit, that defendant Funk, with full knowledge of the
conspirators' purposes, in his capacity as Minister of Economics,
President of the Reichsbank and Chief Plenipotentiary for
Economics, actively participated in the mobilisation of the German
economy for aggression. In these capacities, and as a member of
the Ministerial Council for Defence and the Central Planning Board
he also participated in the waging of aggressive war. Moreover, by
virtue of his membership in the Central Planning Board which, as
your Honours will recall from Mr. Dodd's presentation, formulated
and directed the programme for the enslavement, the exploitation
and degradation of millions of foreign workers; defendant Funk
also shares special responsibility for the Nazi Slave Labour
programme.

The French prosecution, I am informed, will deal with this matter
in greater detail. Moreover, the French and Soviet prosecutions
will submit evidence

                                                        [Page 204]

showing that defendant Funk actively participated in the programme
for the criminal looting of the resources of occupied territories.

MR. THOMAS DODD: May it please the Tribunal, we would like to call
at this time the witness Dr. Franz Blaha.

THE PRESIDENT (To the witness): Is your name Franz Blaha?

THE WITNESS (In Czech): Dr. Franz Blaha.

THE PRESIDENT: Will you repeat this oath: I swear by God the
Almighty and Omniscient that I will speak the truth, the clear
truth, and will withhold and add nothing.

(The witness repeated the oath.)

THE PRESIDENT: You can sit down if you wish.

DIRECT EXAMINATION QUESTIONS BY MR. DODD:

Q. You are Dr. Franz Blaha, a native and a citizen of
Czechoslovakia; are you not?

A. (In Czech) Yes.

Q. I understand that you are able to speak German, and for
technical reasons I suggest that we conduct this examination in
German, although I know your native tongue is Czech; is that
right?

A. (In Czech) In the interest of the case I am willing to testify
in German for the following reasons:

1.For the past seven years, which are the subject of my testimony,
I have lived exclusively in German surroundings.

2. A large number of special and technical expressions relating to
life in and about the concentration camps are purely German
inventions, and no appropriate equivalent for them in any other
language can be found.

Q. Dr. Blaha, by education and training and profession you are a
Doctor of Medicine?

A. (In German) Yes.

Q. And in 1939 you were the head of a hospital in Czechoslovakia?

A. Yes.

Q. You were arrested, were you not, by the Germans in 1939, after
they occupied Czechoslovakia?

A. Yes.

Q. And were you confined in various prisons between 1939 and 1941?

A. Yes.

Q. From 1941 to April of 1945 you were confined at Dachau
Concentration Camp?

A. Yes, until the end.

Q. When that camp was liberated by the Allied Forces?

A. Yes.

Q. You executed an affidavit in Nuremberg on the 9th day of
January of this year, did you not?

A. Yes.

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