Q. Witness, did you not know when you took over your office as Quartermaster-General, that the preparations which Major- General Marx had already

[Page 265]

begun, and which you then continued, were intended only for a possible contingency?

A. One could think so, of course, but very soon in the course of the work, things appeared which made it seem very probable that these theoretical preparations were to be put to practical use. In connection with the formulation of this plan of operations for an attack in which, from the very beginning, we were thinking in terms of using Roumainian territory -- during that very time we saw the dispatch of the first military mission, with training groups and an entire Panzer division, just into that area for which the theoretical preparations for an attack were being made. Thus, gradually, the impression grew that this was a plan which eventually would be executed.

Q. The reason for my question is this: I believe the date which you gave as the inception of the plan, the autumn of 1940, is a little early, is it not?

A. The documents which I was given for that plan of offense I explained in detail yesterday. They were submitted on 3 September, for upon the basis of these documents everything was developed, and everything was actually executed like that later.

Q. I mean this: that first this plan was considered or conceived for an certain contingency, and then at a later date, after a decision had been taken, it was used.

A. In retrospect, they fit together in perfect sequence, first the theoretical preparation, and then the practical preparation and execution.

Q. Do you know Directive No. 18 of 12th November, 1940, issued by the former Supreme Commander of the Wehrmacht?

A. I cannot remember it.

DR. LATERNSER: Mr. President, I refer now to a document which has already been submitted by the American prosecution, Document 444-PS. (Handing the document to the witness)

Q. I submit it to you, Witness. Page 8 is the one to I am referring to.

A. I cannot remember that I have ever seen this.

Q. Witness, will you please repeat that answer once more?

A. I cannot remember ever having known anything about this letter.

DR. LATERNSER: To inform the Court I am going to quote the passage -- it is very short -- which I have just shown to the witness. It is Page 8 of Document 444-PS, this paragraph. I quote:

"(5) Russia: Political conferences with the aim of clarifying the attitude of Russia for the near future have been started."

A. I can only say from my personal experience and my own opinion as I look back now, following the entire development, that there was a clear line from the beginning: the conception of that plan as I found it on 3rd September, 1940, then the directive of December, 1940, and then its execution. Just at which precise date the decision was taken I do not know.

Q. Did you know that in 1939 the Soviet Union marched into Poland with, in the opinion of German military experts, very strong forces which were out of proportion -- according to the opinions of these experts -- to the problem to be solved at that time?

A. I only know of the fact that Soviet forces marched into Poland, but I have never heard anything about the size of the forces, nor have I ever heard anyone express surprise at the strength of the forces that took part in the invasion.

Q. Do you know that before the German deployment on the Eastern border much stronger Soviet forces had been aligned along that border, especially very strong armoured forces in the area of Bialystok?

A. No, I ever knew that.

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Q. Were not the first divisions transferred from West to East, only after very strong Soviet forces were already in position along the Eastern border?

A. About the relationship of troop movements from West to East, and the practical execution of the plan, I know nothing, because I had nothing to do it. First of all, in the months of April and May, because of other duties, I was present in the High Command of the Army for only a very short time.

Q. Witness, you said yesterday that at the end of March, 1940, there was a conference at the Reich Chancellery, and there General Halder gave you several points as reasons for the intended attack on Yugoslavia. You mentioned firstly the elimination of danger to the flank; secondly, the taking possession of the rail line to Nish, and you stressed the point that in case of an attack against Russia, the right flank would be free to move. Were there not different reasons for this attack? Were not there reasons which were more important than the ones you mentioned?

A. I do not know of any others.

Q. As to this attack upon Yugoslavia, was not that also to be done to relieve the Italians?

A. Yes, of course. That was the initial reason why an operation against Greece was considered, and why that menace to the flank had to be eliminated if we were to push forward into Greece from Bulgaria.

Q. Was not there at that time some concern about co- operation between Yugoslavia and Greece, which would have enabled England to land forces on the Greek coast and thereby gain a road to the Roumainian oil fields?

A. Yes, but it would also have been impossible to carry out the Plan "Barbarossa." We would have been menaced on our right flank and unprotected.

Q. I have received different information. In the decision to attack Yugoslavia the Plan "Barbarossa" did not play the important role which you said it did.

A. The Plan "Barbarossa" could not have been carried out if Greece and Serbia, strengthened by British landings, had fallen into the hands of the enemy.

THE PRESIDENT: Perhaps we can adjourn.

(A recess was taken.)

BY DR. LATERNSER:

Q. Witness, you were just speaking of the attack on Yugoslavia. If I understood you correctly, you said that this attack had to be carried out before the Plan Barbarossa could be undertaken, as otherwise there would have been a serious threat to the flanks. Did I understand you correctly?

A. Yes.

Q. You said yesterday that the overthrow of the government in Yugoslavia was the reason for Hitler's attack on that country. Do you know whether any plans for such an attack existed, even before the revolution in Yugoslavia?

A. That is not known to me.

Q. Do you happen to know that the attack against Yugoslavia had to be made at a very inconvenient time, and that it caused a delay of the attack against the Soviet Union?

A. That is exactly what I said yesterday. It caused a postponement of the attack on Russia, which had originally been planned for the middle of May, weather permitting.

Q. But then there is a sort of contradiction here, if you say that the attack against Yugoslavia took place at that time although it was inconvenient, as the attack against Russia was to be made.

A. I do not see any contradiction in that. As I saw the situation, the Yugoslavian Government had made an agreement with us, which placed the railway line from Belgrade to Nish at our disposal. After that agreement was concluded, a revolution took place in Yugoslavia which created a change in her policy.

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Therefore, the plan to attack Yugoslavia was believed necessary to eliminate a danger. In other words, I do not see that the decision to attack Yugoslavia and the fact that "Barbarossa" was delayed are contradictory. I merely see that one is a prerequisite for the execution of the other.

Q. Witness, were you present at a conference of the General Staff at the Obersalzberg on 3rd February, 1941?

A. Yes.

Q. Are you aware of the fact that at that time the strength of the Soviet Russian troops was estimated at 100 infantry divisions, 25 cavalry divisions, and 30 mechanized divisions, and that that strength was reported by General Halder?

A. I cannot recollect that at all. Nor am I sure whether General Halder was actually present during that conference.

Q. But, witness, such a conference must have been an unusual one?

A. Yes.

Q. And I believe that that conference must at least have given the impression that there was a very strong concentration of troops on the Eastern Front.

A. I myself have no recollection of any such impression.

Q. At the beginning of that attack against the Soviet Union, were you still Quartermaster-General?

A. Yes.

Q. As far as I have been able to ascertain in the meantime, it is part of the duties of that service department to make positive suggestions regarding military operations, is that correct?

A. That was once the case when there was a different allocation of duties. At the time when I was Deputy Chief of the General Staff I was not assigned that duty as part of my job. The operational department was not under my control, but immediately under the control of the Chief of the General Staff. The General Staff Department, first of all, gave me the task of running the training department and then the organisation department, and that was in autumn 1941. Therefore, it was not part of my sphere of activities to make suggestions to the Chief of the General Staff regarding operations which were in progress, or any other operations. I merely had to carry out the duties allotted to me.

Q. Witness, can you give information on the subject of how German prisoners of war were treated in the Soviet Union?

A. That question, about which such an incredible amount of propaganda has been made, which led to the suicide of so many German officers and other ranks at Stalingrad, I feel myself bound ---

THE PRESIDENT: One moment. Cross-examination is questioning on questions which are either relevant to the issues which the Tribunal has to try, or questions relevant to the credibility of the witness. Questions which relate to the treatment of prisoners in the Soviet Union have got nothing whatever to do with any of the issues which we have to try, and they are not relevant to the credibility of the witness. The Tribunal, therefore, will not hear them.

DR. LATERNSER: Mr. President, may I give a reason why I ask that question? May I make a short statement?

THE PRESIDENT: Yes.

DR. LATERNSER: I should like to put that question for the reason that I could ascertain how prisoners of war were, in fact, treated, so that a large number of German families, who are extremely worried on that subject, could thus be given information about it, so that their worries would be ended.

THE PRESIDENT: The Tribunal is of opinion that that is not a matter with which the Tribunal is concerned.

DR. LATERNSER: I have no further questions to ask the witness.

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