[Page 245]

A. I do not know that the Fuehrer ever accused the Reichsmarshal of any offence in this respect. Discussions between Adolf Hitler and the Reichsmarshal were, in spite of all tension, always very moderate. The criticism, allegedly, did not become more vehement until 1944 and the beginning of 1945, but I was not present because I had been off duty since 20th July, 1944.

Q. I asked you a question. I did not intend to imply that the Fuehrer accused him of an intentional misstatement, but that he had misled him or he had misunderstood the strength of Germany's air defences. Was that not generally understood in your circle?

A. There could be no question of misleading. The reports which the Air Force made to the Fuehrer were always correct. The weaknesses of the Air Force were also reported to the Fuehrer.

Q. What were the efforts that were made by Goering, which you refer to as tremendous efforts, to recapture his influence with the Fuehrer?

A. The Reichsmarshal, whenever there were conferences, asked through me that he might participate. The Reichsmarshal came more frequently than usual to the Fuehrer's Headquarters, and he told me also: "I will try everything to regain the right contact with the Fuehrer." He said that personally to me.

Q. And he was particularly careful after the spring of 1944 not to do anything that would offend the Fuehrer?

A. I cannot say anything more about that period because then I was no longer active. I had no further contact.

Q. Now, this bombing of German cities had become very troublesome from the point of view of the German people's criticism of the government, had it not, in 1944?

A. The German people suffered terribly under these bombing attacks, and I can only say one thing - that Adolf Hitler suffered most from them. When I was present when the bombing of a German city was reported, he was really deeply moved, and likewise the Reichsmarshal, because the horror of such a bombing was indescribable. I have experienced a few such bombings in Berlin myself, and whoever has lived through that will never forget it as long as he lives.

Q. And this was all becoming very embarrassing to Hitler and to the Reichsmarshal, was it not, to explain to the German people why this was going on?

A. That did not have to be explained, because the German people felt it. No explanation was given. It was only said that all possible measures would be taken to master this peril.

Q. And you knew at that time, and the Reichsmarshal knew, that no measures could be taken that would prevent it?

A. No, no, no. I emphasized before that it was a radio- technical war, and there were moments when, in the defence, we could counter the measures of the enemy while discovering a new means to hit him.

Q. When you made the announcement to the German people that all means would be taken you had then no means at your disposal, that you knew of, had you, to use to prevent the bombing of the German cities?

A. Oh, yes, indeed.

Q. What were they, and why were they not used?

A. There were, for example, the following means: The most important areas were protected by flak. Also, there were radio-technical means, jamming

[Page 246]

Q. The movement to satisfy the German people under the bombing attacks was a matter of great concern to the Reichsmarshal, was it not?

A. The Reichsmarshal was very anxious that the population should be informed.

Q. And see that the population was satisfied, was he not?

A. It is easy to say "satisfied". He could only assure the German people that he would do anything in his power to master these attacks.

Q. Now have you seen the Reichsmarshal and Hitler when the reports came in of the bombing of Warsaw and Rotterdam and of Coventry?

A. I cannot remember whether I was present when the reports came.

Q. You never saw any such reactions on their part on these bombings, I take it?

A. I only know that Warsaw was a fortress which was held by the Polish Army in very great strength, provided with excellent pieces of artillery, that the forts were manned, and that two or three times Adolf Hitler announced that the city should be evacuated by civilians. That was refused. Only the foreign embassies were evacuated, while an officer with a flag of truce entered. The Polish Army was in the city defending it stubbornly in a very dense circle of forts. The outer forts were very strongly manned and, from the inner town, heavy artillery was firing towards the outskirts. The fortress of Warsaw was therefore attacked, also by the Luftwaffe, but only after Hitler's ultimatum had been rejected.

Q. Was Coventry a fortified city?

A. Coventry was no fortress. Coventry, however, was a city which housed the key industry of the enemy Air Force, in which the aircraft engines were built, a city in which, so far as I know, many factories were situated and many parts for these aircraft engines were manufactured. In any case, the Air Force had at that time received orders only to bomb the industrial targets. If the city also suffered it is understandable, considering the means of navigation at that time.

Q. You were interrogated in November of 1945, were you not, by Colonel Williams?

A. Yes, I was interrogated.

Q. And Colonel Williams asked you about certain fictitious incidents along the German-Polish border late in August of 1939, did he not?

A. Yes, he asked me about that.

Q. And would you care to tell the Tribunal what you knew about the fictitious incidents along the Polish border?

A. I do not know anything positive. I was asked by Colonel Williams whether I knew in advance about the incident of the Gleiwitz Broadcasting Station. I told him I knew nothing about it. It was only that the incidents on the Polish border were very similar to those which happened on the Czech border. It may have been presumed - that was only my opinion - that they were perhaps deliberate. But I had no positive proof that anything had been staged on our part.

Q. Did you tell him on 6th November, 1945, as follows:

"I heard about it, but I personally at that time had the feeling that all these provocations that had taken place had originated from our side, from the German side. As I said, I had no real proofs of that, but I always had that feeling."

A. Yes, I said that.

Q. And that you had talked with people about this, from whom you got that feeling. Is that right?

A. I cannot remember that very well now. I only know that the reports in the Press gave me that suspicion.

[Page 247]

"Question: But you are of the opinion that what appeared in the Press, and these incidents that were reported, were not true, but done merely to cause an incident as an excuse for an invasion?"

"I had that feeling. I cannot prove it, but I definitely know I had a feeling that the whole thing was being engineered by us."

A. The minutes will show it. If it is in the minutes, I said it. At the moment I cannot remember the exact words.

Q. You do not deny the fact, however?

A. I had that feeling, but it was a purely subjective opinion.

Q. But it was your opinion?

A. Yes.

Q. Now then, I ask you whether you were not interrogated about the Fuehrer's desire to make war on Poland and whether you did not give this answer:-

"Gentlemen, this question is very hard to answer, but I can state under my oath that the Fuehrer actually wanted the war against Poland. I can prove that he actually wanted a war of aggression against Poland by the circle surrounding the Fuehrer, and the remarks that were made. I was present during the night when Hitler gave Henderson his conditions, that he wanted Danzig, and I concluded from all the conferences that the Fuehrer had with the Ambassador - I had the impression that the Fuehrer did not really want the Poles to accept those conditions."

A. I can make the following answer to that.

I was not present at the conference. If I said that, I did not express myself correctly. I was not at the conference that the Fuehrer had with Henderson, but I was standing in the ante-chambers with the other adjutants, and in the hall one could hear the various groups, some saying one thing, some another. From these talks I gathered that the conditions which Henderson received for the Poles in the evening - that the deadline for answering these questions, which was noon of the next day, was so short that one could conclude there was some intention behind it.

Q. Well, that is the impression that you received from being in the ante-room and talking with the people who were about Hitler that night?

A. There were adjutants, the Reich Press Chief and the gentlemen who were waiting in the ante-room without taking part in the conference.

Q. I will ask you, in order to make this very clear, one more question about your interrogation on that subject. Were you not asked this question:-

"Then we can summarize your testimony this morning by saying that you knew in 1938, several months before Germany attacked Poland, that Hitler fully intended to attack Poland and wage an aggressive war against her; is that right?"

"I can only say this with certainty, that from the night when he told Henderson that he wanted Danzig and the Corridor, from that moment I was sure Hitler intended to wage an aggressive war."

A. If it is in the minutes, I said it.

Q. Well, if it were not in the minutes, it would still be your testimony now, would it not? It is a fact, is it not?

A. My definition precisely is this; that, from the handing over of Adolf Hitler's demands to Henderson and from the short time that Henderson was granted, I concluded that there was a certain intention. That is how I should like to define it precisely now.

[Page 248]

A. A copy of this document was shown to me by Colonel Williams, and I told him that I myself could not remember having been present. But if my name is on the minutes, then I was there.

Q. But your name is on the document, is it not?

A. Then I was there. I cannot remember the subject of this conference. I told Colonel Williams that that must have been discussed because Colonel Schmundt, whose handwriting I know - I was shown a copy - I told him that Colonel Schmundt was a man who was very conscientious in making his notes.

Q. That is all in his handwriting?

A. That is it as I see it here.

Q. And it is signed by Colonel Schmundt?

A. Yes, it is signed by Colonel Schmundt, Lt.-Colonel Schmundt. The corrections are not in his handwriting.

Q. But the body of the document is his handwriting?

A. Yes, that is his own handwriting. I know it, yes.

Q. And when you were asked about that by Colonel Williams, you took time to read it, and then you said, did you not: "I think that the thoughts are right as they are expressed here; these are the thoughts that the Fuehrer usually voiced to us in a small circle." You made that statement?

A , Yes, I did say that, yes.

Q. And you said: "I cannot remember whether these things were expressed on that day. However, it is possible that the thoughts which are put down here are the thoughts of Adolf Hitler." You said that to Colonel Williams, did you not?

A. Yes, I said that to Colonel Williams.

Q. That is all I care to ask about that, sir.

I now ask to have shown to you the original exhibit, Document 798-PS, Exhibit USA 29.

A. So far as I know, a copy of this speech by the Fuehrer was also shown to me by Colonel Williams.

Q. That is right. You said, did you not, that you did not recall whether you were present but that the thoughts that were expressed -

A. The thoughts expressed there are correct.

Q. They are correct. That is all about that.

A. Yes, but I must say one more thing. I tried to speak to Colonel Williams again and could not reach him. Probably I attended this meeting.

Q. Well, we will take that statement now and excuse you from looking for Colonel Williams.

I ask to have shown to you Document 3474-PS, Exhibit USA 580. Is that your handwriting?

A. Yes, that is my handwriting.

Q. And signed by you.

A. Yes.

Q. And it is a note of a conference of the 2nd day of December, 1936, is it not?

A. Yes.

Q. You prepared this memorandum for your files; is that right?

A. I do not know to whom I gave this.

Q. Well, it says the notes for the files on that discussion; is that correct?

A. Yes, that is a note for the files.

Q. Goering was present at that conference; is that correct?

A. Yes. He must have conducted it. It gives here as present: General Goering.

Q. In fact, the note says he conducted it, does it not?

A. Yes.

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