Archive/File: imt/tgmwc/tgmwc-15/tgmwc-15-148.07
Last-Modified: 2000/03/30

MR. ROBERTS: My Lord, there was one more passage from that
document I should like to read. If Your Lordship is thinking
of adjourning, perhaps I might read it, and then I will have
finished with the document. My Lord, it is the next page,
and it is toward the end of the page. It is against the
lettering - the number P-52. It is just above "Time of
Attack."

BY MR. ROBERTS:

Q. It is on your Page 52, witness, at the very beginning, or
just at the end of Page 51:

  "All leaders must keep firmly fixed in their minds the
  fact that the destruction of the Anglo-French army is the
  main objective, the attainment of which will enable
  suitable conditions to obtain for later and successful
  employment of the German Air Force against other
  objectives. The brutal employment of the German Air Force
  against the heart of the British will to resist can and
  will follow at the given moment."

Did that mean terror attacks against the civilian
population?

A. You are asking me continuously about a document which,
from the first to the last word, was written by the Fuehrer,
as I have already told you. You are producing a rather
interesting picture of the Fuehrer as a strategist and as a
military leader, and it is of interest to the world, but I
cannot see how this concerns me. These are the thoughts
which the Fuehrer put down as military commander, and are of
great interest for all soldiers in the world. But what does
it have to do with me? That I do not understand.

Q. But may I point out, witness, that your own counsel
produced it and you relied on certain parts of it. That is
how it concerns you; you relied on it.

A. Yes.

THE PRESIDENT: We will adjourn now.

(A recess was taken until 1400 hours.)

BY MR. ROBERTS:

Q. Witness, I only have two other questions on the alleged
aggression against the Low Countries. Will you look at your
diary, Document 1809-PS, for the 8th of May, 1940. It is
Page 141 in the Document Book 7, and it is Page 115 in the
German Book. The actual quotation is Page 143 in the
Document Book 7; at the top of the page:

  "May the 8th. Alarming news from Holland. Cancelling of
  furloughs, evacuations, road blocks, other mobilization
  measures."

Were you afraid that the Dutch might actually take some
steps to defend themselves against your invasion?

A. I was sure that the Dutch would defend themselves against
Germany.

Q. Was it alarming because you thought the Dutch might have
suspected you were going to break your treaties and
assurances?

A. I did not understand the question.

Q. I will go on. "According to the reports of the
Intelligence Service, the British have asked for permission
to march in, but the Dutch refused. According to reports,
measures of the Dutch partly directed against the coast and
partly against us. It is not possible to obtain a clear
picture whether the Dutch do not work hand-in-hand with the
English, or whether they really want to defend their
neutrality against the first attacker."

It is clear from that, is it not, that you had no
information at all that Dutch neutrality was going to be
broken?

                                                  [Page 400]

A. That is not clear from the entry; it is only a brief
argument on the basis of masses of reports which we received
from Canaris on that day or on the previous day. If they
were to be followed up accurately, the reports immediately
preceding this entry would have to be at hand; the entry
refers to the latest reports, and not to the many thousands
which had come in before.

Q. Now, on the 10th of May, without any declaration of war,
these three countries, small countries, were invaded with
all of the armed might of Germany, were they not?

A. The attack began on the 10th of May along the whole
front.

Q. What had those countries done at all to deserve the
horrors of invasion and the misery of German occupation?

A. That, again, is an historical question. I have already
said that, according to my personal point of view, England
and France in fact forced them to give up their strictly
neutral attitude. That was my impression.

Q. Their only fault, was it not, was that they stood in the
way of your air bases and U-boat bases?

A. They were not only in the way, but by tolerating actions
incompatible with neutrality, they helped England in the war
against us. That was my subjective impression.

Q. Now, I have only got ... with the permission of the
Tribunal, there was one question I should have asked on
Norway; only one; and if I might go back to that, I want to
ask you about your diary entry, Document 1809-PS, Page 145
in Document Book 7. I have not got a reference to the
German, but it is about at that place. I will read it
slowly:

  "March 13th: Fuehrer does not give order yet for 'Weser.'
  He is still looking for an excuse" - or 'justification' -
  to use your word. And the next day, 14th March: "Fuehrer
  has not yet decided what reason to give for 'Weser'
  exercise."

If you had a good reason for breaking Norwegian neutrality,
why should the
Fuehrer be unable to find one?

A. Because for this operation the Fuehrer considered it
absolutely essential to have some documentary proof. So far,
there had only been very strong indications which came near
to a proof, but we had as yet no documentary evidence.

Q. Very good. I leave that part of the case, and I now go to
Yugoslavia, and I have only two or three questions on
Yugoslavia.

I want you to look at Document 1746-PS, Page 127 in Document
Book 7; German Book 112.

Before we deal with the document, witness, Yugoslavia had
also received assurances from Hitler. That is so, is it not,
or do you not know?

A. Yes. Not only did Yugoslavia receive assurances from
Hitler, but we also received them from the Yugoslav
Government, which had concluded a treaty with us on the
previous day.

Q. Now, you will find the document I am going to refer to.
It has got a piece of paper headed with the German word for
"discussion," "Besprechung." Have you found it? It should be
a piece of paper with the word "Besprechung."

A. " Discussion on the situation in Yugoslavia"; yes.

Q. Yes, that is right.

A. Yes.

Q. Dated 27th March, 1941?

A. Yes.

Q. Now if you turn to - I think it is Page 2:

  "The Fuehrer is determined, without waiting for loyalty
  declarations of the new government, to make all
  preparations to destroy Yugoslavia militarily and as a
  national unit. No diplomatic inquiries will be made nor
  ultimatums presented. Assurances of the Yugoslav
  Government, which cannot be
  
                                                  [Page 401]
  
  trusted anyhow in the future, will be taken note of. The
  attack will start as soon as the means and the troops
  suitable for it are ready. It is important that action be
  taken as soon as possible."

Now I go to Page 3, witness:

  "Politically it is especially important that the new blow
  against Yugoslavia is carried out with unmerciful
  harshness, and military destruction is done by a
  lightning-like undertaking."

Now I go to Page 5, witness:

  "The main task of the Air Force is to start as early as
  possible with the destruction of the Yugoslav Air Force
  ground installations, and to destroy the capital,
  Belgrade, in attacks by waves."

The Fuehrer was not going to give the civilian population
even half-an-hour's warning, was he?

A. I do not know what preparations for warning the Yugoslav
Government had been made, but at the moment of the putsch it
immediately made military preparations and deployed its
forces along our border.

Q. May I ask you this? Do you approve, as an honourable
soldier, of attacking a city crowded with civilians without
a declaration of war or even half-an-hour's warning?

A. I do not hold that view. I have already said that I,
personally, and, half-an-hour or an hour later, the Reich
Foreign Minister, suggested an ultimatum.

Q. When you lost air superiority and people were able to hit
back, you Germans. made a great deal of fuss then about
terror attacks, did you not?

A. This city was, at that time, the centre of a "Putsch"
government, which had annulled a treaty concluded with
Germany, and which from that moment on had made preparations
along the whole front for war with Germany.

Q. Well, I am going to leave the incident. Do you remember
how you referred to it in the notes for your lecture? It
appears on Page 292 of Book 7, and at 304 of the German. You
refer to it as "an interlude." Do you remember? The German
word is "Zwischenspiel," "interlude." Is that your idea of
an interlude?

A. To be juridically exact, you mean the first draft of my
lecture and not my lecture, which you do not know. However,
even in this first draft, I cannot recall mentioning an
interlude.

Q. How many civilians, how many thousands, do you think were
killed in the first movement of that interlude, in the
bombing of Belgrade without warning?

A. I cannot say, but surely only a tenth of the number
killed in Dresden, for example, when you had already won the
war.

Q. Now I come to the alleged aggression against the Union of
Soviet Socialist Republics. Hitler decided to attack the
Soviet Republic in July of 1940, did he not?

A. In July of 1940 he had not yet reached that decision.

Q. But at any rate - I do not want to waste time - we know
that on the 22nd of June, 1941, Germany invaded the Soviet
Union contrary to her non-aggression pact. That is history,
is it not?

A. Yes. The surprise attack on the 22nd of June, 1941, is a
historical fact which took place because the politicians
were of the opinion that the Soviet Union had not kept the
pact.

Q. Now, witness, I am going to pass from this part of the
case altogether. I want to put one last question. Do you not
think that this record of broken pledges will dishonour the
name of Germany for centuries to come?

A. It might, if historical research, after exact
investigation of Russian documents, delivers clear proof
that Russia had no intention of strangling us politically or
of attacking us. In that case, yes; otherwise, no.

Q. I now want to ask - to come to quite a different part of
the case under Counts 3 and Counts 4. The documents have
been put to you so often, I do not: want to put them again.

                                                  [Page 402]

But you remember the "Barbarossa" order. That is C-50, in
Document Book 7, Page 187; and German Book 146. That was
circulated by your office, was it not -
Wehrmachtfuehrungsstab, L?

A. It was dealt with in the Quartermaster Section of the
Wehrmachtfuehrungsstab.

Q. Well now, would you agree that that was a shameful order
to have to issue?

A. I agree. I have already said that there was no soldier
who did not oppose this order; they all did so.

Q. Very good. Now we know that on the 17th of July - and
this is Document C-51, which is in Document Book 7, at Page
190, German Page 150 - we know that from the same office,
the WFS, L, there was issued an order that the previous
order was to be destroyed, but its validity was not to be
affected, destroyed below corps level. What was the object
of the destruction of that order?

A. Unfortunately, I cannot tell you; I do not recall this
order. I do not believe I ever saw it, at least not before
this trial.

Q. Perhaps you would look at it, witness, C-51, Page 190,
Book 7; Page 150, German Book. Now, that comes from WFS L -
that is, Wehrmachtfuehrungsstab - Department "L" - and then
"Q" for "Quartermaster," in brackets. That is your office,
is it not?

A. That is a part of the Wehrmachtfuehrungsstab.

Q. It is signed Keitel.

A. Yes. But I do not know this order; it was shown to me for
the first time here in Nuremberg; I had never seen it
before. I do not know what it is about or what order is
being rescinded. I have already said that these questions of
military justice and jurisdiction were dealt with by Field
Marshal Keitel, and that he used my quartermaster section as
a working staff, without my having any part in these
matters. I do not know this order.

Q. And you cannot suggest any reason why it had to be
destroyed?

A. No; I cannot give you any information about it.

MR. ROBERTS: Now then, I want Document C-52, which has not
yet been put in. Your Lordships will find it on Page 191 of
Book 7. I offer it as Exhibit GB 485, and it is in the
German Book on Page 153.

BY MR. ROBERTS:

Q. Now this is another Keitel order. It comes from
"Wehrmachtfuehrungsstab," "L"; then, in brackets, "1 Op." Is
that your department?

A. That is the section which worked with me on all
operational questions.

Q. Do you remember that order?

A. Yes, I remember the order.

Q. Now ... I think you took part in drafting it; did you
not?

A. Certainly, because it is an operational order, which
supplements a directive.

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