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Q. After that conference were any military orders given?

A. I think not even then, but Hitler told us at the time
that he wished to wait for the reaction to these discussions
in the Eastern area after the delegation had returned to
Russia. Certain orders had been given to the ambassador,
too, in that respect. However, orders were not given
directly after the Molotov visit.

Q. May I ask you to state the date when the first definite
instructions were given?

A. I can only reconstruct it on the strength of the
"Barbarossa" instructions, which have been shown to me here
and which came out in December. I believe it must have been
during the first half of December that the well-known
"Barbarossa" orders were given. To be precise, these orders
were given at the beginning of December, namely, the orders
to work out the strategic plan.

Q. Did you know about the conferences which took place at
Zossen in December and which have been mentioned by the
prosecution here? Perhaps I may remind you that the Finnish
General Heinrichs was present.

A. No, I knew nothing about the conference in Zossen. I
think General Buschenhagen was also there, according to the
statements he has made here. I did not know anything about
the Finnish General Heinrichs' presence in Zossen and have
heard about it for the first time here. The only way I can
explain this is that the General Staff of the Army wanted to
get documents or other things and that they discussed that
in addition with the persons concerned. I did not meet
General Heinrichs until May, 1941. At that time I had a talk
with him and General Jodl at Salzburg. Before that I had
never seen him and I had never talked to him.

Q. Is there any significance in the fact that Directive No.
21 says that Hitler would order the attack and the actual
troop dispositions eight weeks before the operational plan
would become effective?

A. Yes, there was considerable significance attached to
that. I have been interrogated about that by the Soviet
Union Delegation here. The reason was that according to the
Army's calculations, it would take about eight weeks to get
these troops, which were to be transported by rail, into
position; that is to say, if troops from Reich territory
were to be placed in position on an operative starting line.
Hitler emphasised, when the repeated revisions of the plan
were made, that he wanted to have complete control of those
dispositions. In other words, troop movements without his
approval were not to be made. That was the purpose of this
directive.

Q. When did it become clear to you that Hitler had decided
to attack the Soviet Union?

A. As far as I can recollect, it was at the beginning of
March. The idea was that the attack might be made
approximately in the middle of May. Therefore the decision
regarding the transport of troops by rail had to be made in
the, middle of March. For that reason, during the first half
of March a meeting of generals was called - that is to say,
a command reception of generals at Hitler's headquarters,
and the explanations given by him at that time had the clear
purpose of telling the generals that he had on his own
initiative decided to carry out those troop movements,
although an order had not yet been given. He produced
several suggestions, and issued certain instructions on
matters which are contained in these directives here for the
Special Case Barbarossa. This is Document 447-PS,

                                                   [Page 15]

and these are the directives which were eventually signed by
me too. He then gave us the directive for these guiding
principles and ideas, so that the generals were already
informed about the contents, which in turn induced me to
confirm it in writing in this form; for there was nothing
new in it for any one who had taken part in the discussions.

Q. It appears to me, however, that what Hitler told the
generals in his address was something new; and it also seems
to me that you who were concerned with these matters, that
is to say, who had worked on them, understood or should have
understood that now a completely abnormal method of warfare
was about to begin, at least when seen from your traditional
point of view as a soldier.

A. That is correct. Here views were expressed regarding the
administration and economic exploitation of the territories
to be conquered or occupied. There was the completely new
idea of setting up Reich Commissioners and civil
administrations. There was the definite decision to give
Supreme Command to the Trustee of the Four-Year Plan in the
economic field; and what was for me the most important point
and the one that affected me most was the fact that apart
from the authority of the commander of the occupation
forces, as such, to administer those territories, it was
clear that Reich Leader S.S. Himmler was to be given
extensive plenipotentiary powers concerning all police
actions which would, later, become necessary. I firmly
opposed that, since to me it seemed impossible that there
should be two forces working side by side. In the directives
here it says: "The authority of the Commander-in-Chief of
the Army is not affected by this."

That was a complete illusion and self-deception. Quite the
opposite happened. As long as it was possible, I fought
against it. I think I ought to say that I have no witness to
that other than General Jodl, who shared these experiences
with me. Eventually, however, Hitler worked out these
directives himself, more or less, and gave them the meaning
he wanted. That I had no power to order the things which are
contained in these directives is clear from the fact that it
says that the Reich Marshal receives this task, and the
Reich Leader S.S. receives that task, and so on. I had no
say in these matters.

Q. Was it never actually discussed that if one wanted to
launch an attack on the Soviet Union, one would have to take
diplomatic steps or else send a declaration of war, or an
ultimatum?

A. Oh yes, I discussed that. As early as the winter of 1940-
1, whenever there were discussions regarding the strength of
the Russian forces on the demarcation line - that is in
December-January - I asked Hitler to send a note to the
Soviet Union so as to bring about a cleaning up, so to
speak, of the situation. I can add now that the first time
he said nothing at all, and the second time he refused,
maintaining that it was useless, for he would only receive
the answer that this was an internal affair and that it was
none of our business, or something like that. At any rate,
he refused. I tried again, at a later stage, that is to say,
I voiced the request that an ultimatum should be presented
before we entered upon an action, so that in some form the
basis would be created to justify a preventive war, as we
called it, if attacked.

Q. You say "preventive war." When the final decisions were
made, what was the military situation?

A. I am best reminded of how we, or rather the Army judged
the situation, by a summary or memorandum - I believe it is
Document 872-PS - yes, 872-PS ... dated the end of January
or the beginning of February - of a report made by the Chief
of the General Staff of the Army to Hitler regarding the
state of operative and strategic preparations. In this
document I found full details as to what we then knew of the
strength of the Red Army, and other existing information.

Apart from that, I have to add that the intelligence service
of the O.K.W. - Admiral Canaris - placed at my disposal or
at the Army's disposal very little material, because the
Russian sector was closely sealed against German
intelligence.

                                                   [Page 16]

In other words, there were gaps up to a certain point. Only
the things contained in Document 872-PS were known.

Q. Would you like to say briefly what it contained, so as to
justify your decision?

A. Yes, there were - Halder reported that there were
approximately 150 Soviet divisions deployed along the line
of demarcation and the borders. Then there were aerial
photographs of a large number of aerodromes. In other words,
there was a degree of preparedness on the part of Soviet
Russia, which could at any time lead to military action.
Only the actual fighting later made it clear just how far
the enemy, had been prepared. I must say that we only fully
realised all these things during the actual attack.

Q. You were present during Hitler's last speech to the
Commanders in the East, made on 14th June, 1941, in the
Reich Chancellery, were you not? I ask you to state briefly,
without going over the same ground, what Hitler said on that
occasion, and what effect it had on the generals.

THE PRESIDENT: Isn't there a document in connection with
this? It must all be in the document. Isn't that so?

DR. NELTE: I wanted to ask one question on that subject and
then submit the document; or, if the Tribunal so desires, I
will not read the document at all, but will merely quote the
short summary which is at the end of it. Will the Tribunal
agree to that?

THE PRESIDENT: But what you did was to ask the defendant
what was in the document.

DR. NELTE: The document contains, if I may briefly indicate
it, the following:

The development, and the continuously increasing influence
of non-military organisations on the conduct of the war.
This document proves that the Armed Forces, during this war
- which must be called a degenerate war - tried, as far as
possible, to keep within the limits of International Law and
that when the .

THE PRESIDENT: I only want to know what your question is,
that is all.

DR. NELTE: My question was directed to Field Marshal Keitel,
and I asked him to tell me about the speech on 14th June,
1941; what Hitler ordered the generals to do, and what was
their reaction. With that, I intended to conclude the
preparations for the Russian campaign.

THE PRESIDENT: He can tell what the effect was upon himself,
but I don't see how he can tell what the effect was upon the
other generals.

DR. NELTE: He can only give his own opinion, of course, but
he can say whether the others reacted in any way, and if
there were arguments or expostulations? I merely wanted to
know whether this happened or not.

THE PRESIDENT: Perhaps you had better ask him what happened
that day at the conference; if you want to know what
happened at the conference, why don't you ask him?

BY DR. NELTE:

Q. Please say.

A. After short addresses regarding the operational orders to
the various commanders, there followed a recapitulation,
which I must describe as a political speech. The main theme
was that this was the decisive battle between two
ideologies, and that this fact made it impossible to use in
this war methods as we soldiers knew them and which were
considered to be the only correct ones under International
Law. The war could not be carried on by these means. In this
case completely different standards had to be applied. This
was an entirely new kind of war, based on completely
different arguments and principles.

After certain details had been explained, various orders
were given with regard, to the abolition of any legal system
in territories which were not pacified, and to the
suppression, by brutal means, of all resistance. Every local
resistance movement was to be considered as the logical
outcome of the deep rift between the two ideologies. These
were decidedly entirely new and very impressive ideas, and
they affected us deeply.

                                                   [Page 17]

Q. Did you, or any other generals raise objections to or
make any expostulations against these explanations,
directives and orders?

A. I personally did not - I had already voiced my
objections. As to the other generals, I do not know whether
any of them spoke to the Fuehrer on these matters.

They did not, in any case, do so after that conference.

DR. NELTE: Mr. President, I think that now the time has come
to decide whether you will accept the affidavits of the
defendant Keitel contained in my document book No. 2 under
the numbers 3 and 5, as exhibits. Perhaps the prosecution
will express an opinion on this.

Up to now we have merely discussed the history before the
actual Russian campaign. In so far as the defendant Keitel
and the O.K.W. is concerned, I should like to shorten the
examination by submitting these two affidavits. The
affidavit - No. 3 - is, an account of the conditions
concerning orders in the East. The extent of the territory
and the numerous organisations led to an extremely
complicated procedure for giving orders. To make it possible
for you to ascertain whether it was the defendant Keitel or
the O.K.W., or some department that was responsible, the
conditions concerning the giving of orders in the East have
been presented in detail. I believe it would save a great
deal of time if you would accept this document as an
exhibit.

SIR DAVID MAXWELL FYFE: My Lord, Mr. Dodd and I have no
objection to this procedure used by the defence and we
believe that it might probably help the Tribunal to have in
front of them the printed accounts.

THE PRESIDENT: Does Dr. Nelte intend to read or only
summarise these affidavits?

DR. NELTE: I intend merely to submit it to you after I have
asked the defendant whether the contents of the affidavits
have been written and signed by him.

THE PRESIDENT: And the prosecution, of course, have had
these affidavits for some time?

SIR DAVID MAXWELL FYFE: Yes.

DR. NELTE: The same applies, if I understand Sir David
correctly, to affidavit No. 5!

SIR DAVID MAXWELL FYFE: Yes.

THE PRESIDENT: Dr. Nelte, it would be convenient, I think,
if you gave these affidavits numbers in the sequence of your
exhibit numbers and give us also the dates of them so that
we can identify them. Can you give us the dates of the
affidavits ?

DR. NELTE: May I be permitted to arrange the matter in the
secretary's office during the luncheon interval?

THE PRESIDENT: Yes. The first is dated 8th March, isn't it,
and the other 18th March, I believe? Dr. Nelte, you can do
it at the recess and give them numbers.

It is nearly 1 o'clock now, and we are just going to
adjourn. You can give them numbers then. Does that conclude
your examination?

DR. NELTE: We come now to the individual cases which I hope,
however, to conclude in the course of the afternoon. I fear
I must discuss the prisoner-of-war circumstances and
individual matters. I think I still need this afternoon for
myself. I believe that if I bear in mind the interests of
the defendant Keitel, I am limiting myself a good deal.

THE PRESIDENT: Do you desire to put your questions to him
now or not?

DR. NELTE: I think - I don't know how the President feels
about it - it would be suitable if we had a recess now so
that in the meantime I can put the affidavits in order. I
have not yet finished the discussion of this subject.

THE PRESIDENT: We will adjourn now.

(The Tribunal adjourned until 14.00 hours.)

                                                   [Page 18]

DR. NELTE: Mr. President, of the two documents mentioned
this morning, the first document, No. 3 of the second
document book, entitled "The Command Relationships in the
East," will be given the number 10 of the Keitel Documents.

THE PRESIDENT: That is dated 14th March, 1946?

DR. NELTF: Yes.

THE PRESIDENT: The document that I have got is headed 23rd
February, 1946, and, at the end, 14th March, 1946. Is that
the one?

DR. NELTE: The document was first written down and later
sworn to. There is, therefore, a difference in the two
dates.

THE PRESIDENT: I only wanted to identify which it is, that
is all.

DR. NELTE: It is the document of 14th March.

THE PRESIDENT: Very well.

DR. NELTE: The affidavit is dated 14th March.

THE PRESIDENT: And you are giving it what number?

DR. NELTE: I give it No. K-10. The second document, which is
fifth in the document book, is dated 18th March, 1946, and
has at the end the defendant's attestation as of 29th March.
This document has received the number K-12. Permit me to
read a few points on Pages 11 and 12 of the German copy.
This, as it appears to me, is of very great importance for
this Trial.

THE PRESIDENT: Of which document?

DR. NELTE: Document No. 12.

THE PRESIDENT: Yes.

DR. NELTE: The question in this document -

THE PRESIDENT: Just a minute. I do not think the
interpreters have found the document yet, have they? It
comes just after a certificate by Catherine Bedford, and I
think it is about halfway through the book, and although the
pages are not numbered consecutively, it appears to have the
figure 51 on it.

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