Regarding Hungary there is a further point:

Due to the development of events in Yugoslavia, Hitler, at the end of March, 1941, decided to attack Yugoslavia. On 27th or 28th March I was called to the Reich Chancellery in Berlin, where there had just been a conference between Hitler, Keitel and Jodl, in which the Commander-in-Chief and the Chief of Staff of the Land Forces had participated, that is, had been ordered to be present.

When I arrived I was advised by the Chief of Staff of the Land Forces, General Halder, that Hitler had decided to attack Yugoslavia, in the first place to eliminate a threat to the flank of the intended operation against Greece, get hold of the rail line going from Belgrade Southward through Nish, and then also with an eye to the future -- to Case "Barbarossa" -- to keep the right flank free from the outset.

I was instructed to go to Vienna, taking with me a number of competent General Staff officers of the Army, to deliver and explain pertinent orders to German commanders, and then to travel on without fail to the Hungarian General Staff in Budapest and to reach an understanding with it on the deployment of German troops on Hungarian territory and the participation of Hungarian troops in the attack on Yugoslavia.

On 30th March, early in the morning, I arrived in Budapest and had a conference with the Chief of the Hungarian General Staff, Lieutenant General Wert (of Infantry), and then with the Chief of the Operational Group of the Hungarian General Staff, Colonel Lazslo. These conferences went smoothly and ended very quickly, and the desired result was achieved. This result was then put down in map form. The map that I received from the Hungarian General Staff contained not only the deployment of the troops intended for the attack against Yugoslavia, but also forces on the Carpatho-Ukrainian border, which were to be placed there to protect our rear against the Soviet Union.

The fact of the creation and existence of this force is a sign that, even on the side of Hungary, there was the realisation that an attack by Germany against Yugoslavia would have to be considered as an aggressive action by the Soviet Union.

As regards the principle of calling upon Hungary in the preparation, and later in the execution, of the planned operations, I learned Hitler's view at that time. He was of the opinion that Hungary was anxious, through German help, to recapture and expand the areas lost in 1918, and in addition, that she was afraid of falling behind a Roumania which was allied with Germany. Hitler saw Hungary from this point of view also with regard to policy. But he was, as I could observe in many instances myself, very reserved toward Hungary, and for two reasons:

Firstly, he did not believe Hungary could guarantee secrecy with regard to future war plans, due to her close connections with foreign countries hostile to Germany, and secondly, he did not want to make too many premature promises of territory to Hungary. I can cite one example: The question of the Worulitsch oil territory. Later, when the attack began against Soviet Russia, the 17th German Army, which was fighting at that point had the explicit order from the Supreme Command to take the Worulitsch oil fields at all costs before the arrival of the Hungarians.

Regarding this future partner, according to my observation the procedure of Hitler was that he counted on her certain participation and therefore delivered the armament to her and helped with the training, but that he kept to himself the time when he would initiate the ally into his plans.

Thirdly, in regard to Finland:

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In December, 1940, the first visit of the Chief of the Finnish General Staff, Major-General Heinrich, was made to the Headquarters of the High Command of the Army in Zossen. Major-General Heinrich had a conference with the Chief of the Army General Staff, the matter of which I cannot now remember; but he made a speech about the Russo-Finnish war of 1939 to 1940 before the General Staff officers of the Army Groups who happened to be present at the time in connection with the discussion of the manoeuvres. This speech before these General Staff officers had its great significance at that time, because its delivery coincided with the issue of Directive No. 21 of 18th December.

This speech was significant; it dealt with experiences gained in the war with the Red Army and in addition gave an insight into the value of the Finnish troops as possible future partners in the war.

I took part in a second conference with the Chief of the Finnish General Staff at the headquarters of the Armed Forces High Command in Zossen, in the second half of May, 1941. The Chief of the Finnish General Staff arrived from Salzburg, where he had had conferences with the High Command of the Armed Forces. The subject of the subsequent conferences in Zossen with the General Staff of the Land Forces was the co-operation of the Finnish forces in the South in "Operation Barbarossa" with Army Group North, which was to proceed from the deployment area in East Prussia towards Leningrad. It was then that agreement was reached that the Finnish troops in the South were to synchronise their movements with the advance of German Army Group North, and likewise that the subsequent joint advance should be subject to consultations and agreements depending on the development of events.

Those are the personal observations which I made regarding the first appearance of, and the enlistment of, allies in preparation for the aggression.

Q. How, and under what circumstances, was the armed attack on the U.S.S.R. carried out; the attack which was prepared by the Hitlerite Government and the High Command of the German Army?

A. The attack took place, as I have related, according to a plan prepared carefully and well in advance. The troops for this attack were at first assembled in the rear of the concentration area. By special orders they were then moved by groups to their jumping-off positions, and then took up their stand along the entire long front from Roumania to East Prussia, for a simultaneous attack. The Finnish theater of war was excluded from this operation. Just as the large- scale operational plan, as I described it at the beginning, was to a certain extent tried out theoretically, so was the detailed employment of troops discussed during manoeuvres by the Staffs of Army Groups, Corps, and Divisions, and drawn up in orders in full detail long before the beginning of the war.

A large-scale diversion, which was to be organised in Norway and along the coast of France, was designed to simulate an invasion of Britain in June, 1941, and thus divert Russia's attention.

All measures were taken not only for operational but also for tactical surprise, as, for instance, the prohibition of open reconnaissance on and across the boundary before the beginning of the war. That meant, on the one hand, that possible losses which might be caused, due to the lack of reconnaissance, had to be taken into account for the sake of surprise, but, on the other hand, it meant that a surprise attack across the boundary by the enemy was not feared.

All of these measures show that it was a question of a criminal attack.

Q. How would you define the aims pursued by Germany in attacking Soviet Russia?

A. The aim to reach the Volga-Archangel line, which was far beyond German strength, is in itself characteristic of Hitler's and the National Socialist leadership's boundless policy of conquest. From a strategic point of view, the achievement of these aims would have meant the destruction of the Armed Forces of the Soviet Union. With the winning of the line I have mentioned the

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main areas of Soviet Russia with the capital, Moscow, would have been conquered and subjugated, together with the leading political and economic center of the Soviet Union. Economically, the winning of this line would have meant the possession of important agricultural areas, the most important natural resources, including the oil wells of the Caucasus, and the main centers of production in Russia and also the main network of communications in European Russia.

How much Hitler was bent on taking economic objectives in this war can best be shown from an example from my personal experience.

On 1st June, 1942, on the occasion of a conference of High Commanders in the region of Army Group South in Poltava, Hitler declared,

"If I do not get the oil of Maikop and Grozny, then I must end this war."

To summarise, I should like to state that the objectives given indicate that the conquest of the Russian territories was for the purpose of colonisation, and with the utilisation and spoliation of its resources, the war in the West was to be brought to a conclusion, with the aim of finally establishing domination over Europe.

Q. And one last question: Whom do you consider as guilty of the initiation of the criminal war against Soviet Russia?

A. May I please have the question repeated?

GENERAL RUDENKO: I repeat the question...

THE PRESIDENT: The Tribunal is about to address an observation to General Rudenko. The Tribunal thinks that a question such as you have just put, as to who was guilty for the aggression upon Soviet territory, is one of the main questions which the Tribunal has to decide, and therefore is not a question upon which the witness ought to give his opinion.

Is that what counsel for the defence wish to object to?

DR. LATERNSER: Yes, Mr. President, that is what I want to do.

Q. Then perhaps the Tribunal will permit me to put this question rather differently.

THE PRESIDENT: Yes.

Q. Who of the defendants was an active participant in the initiation of a war of aggression against the Soviet Union?

A. Of the defendants, as far as I observed them, the top military advisers to Hitler, that is the Chief of the Armed Forces High Command, Keitel; Chief of the Operations Branch, Jodl; and Goering, in his capacity as Reich Marshal, as Commander-in-Chief of the Air Forces and as Plenipotentiary for the Four Year Plan.

Q. In concluding the interrogation I shall make a summary. Have I rightly concluded, from your testimony, that long before 22nd June the Hitlerite Government and the High Command were planning an aggressive war against the Soviet Union for the purpose of colonizing the territory of the Soviet Union?

A. That is beyond doubt, according to all the developments as I described them, and also in the light of all the directives issued in the well-known "Green Folder."

Q. I have no more questions, Mr. President.

THE PRESIDENT: Does any member of the French prosecution wish to ask any questions?

FRENCH PROSECUTOR: No.

THE PRESIDENT: The British?

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BRITISH PROSECUTOR: No.

THE PRESIDENT: The United States?

UNITED STATES PROSECUTOR: No.

THE PRESIDENT: Any member of the defendants' counsel?

DR. LATERNSER: Mr. President, as counsel for the General Staff, I ask you to afford me the opportunity to examine the witness to-morrow morning. The presentation of the witness by the prosecution came as a surprise, to the defendants' counsel at any rate, and I think a consultation about the questions to be asked, especially in view of the importance of the testimony, is absolutely necessary. I therefore ask to be permitted to conduct the cross-examination at the beginning of to-morrow morning's session.

THE PRESIDENT: General Rudenko, if the prosecution has no objection, the Tribunal thinks that this application ought to be granted.

GENERAL RUDENKO: If the Tribunal wishes, the prosecution will not object.

THE PRESIDENT: Yes, very well. I don't know whether any other member of the defendants' counsel would prefer to cross-examine now.

DR. NELTE (counsel for the defendant Keitel): Mr. President, I assume that all defendants' counsel may conduct their cross-examination of the witness, General Paulus to-morrow morning.

THE PRESIDENT: Yes, certainly. I was only asking whether any other member of the defendants' counsel would prefer to cross-examine now.

DR. NELTE: I personally would be able to put my questions after the recess.

THE PRESIDENT: Very well. Then the witness can retire and the case will go on. He will be recalled to-morrow morning and in the meantime you will go on with your case.

General, you will not, I presume, think it necessary to read any more of Field Marshal Paulus' statement, will you?

GENERAL RUDENKO: No.

THE PRESIDENT: Very well, go on, then.

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