[Page 53]

DR. LATERNSER: This question was purely preparatory. I intended to connect this question with another one and, by the answer to the second question, I wanted to prove that under the alleged group, a group has been accused under a wrong name.

THE PRESIDENT: I do not see how it matters if it is a wrong name if the group is specified. But, anyhow, the defendant has already told us what he understands by the General Staff. Will you put your second question?

[Page 54]

Q. Witness, if the higher military leaders are considered collectively to form one group, which is designated as General Staff and O.K.W., do you consider this designation to be correct or misleading?

[Wilhelm Bodewin Johann Gustav Keitel] A. According to our German military concepts this designation is misleading, because to us the General Staff always means a body of assistants, whereas the commanders-in- chief of armies and army groups are commanding generals and represent the Leadership Corps.

Q. The military hierarchy has been discussed sufficiently in this trial. I only want to know the following from you:

Was the relation of these groups to each other that of military superiors and subordinates or did there exist an additional organisation embracing these ranks which went beyond purely professional military duties?

A. No, the General Staff - that is to say, the General Staff officers as assistants to the leaders - could be recognised by their uniforms as such. The leaders or so-called commanders themselves had no relation to each other through any inter-office organisation or through any other organised establishment of any kind.

Q. Yesterday the affidavit made by General Halder was put to you. I would now like to discuss the last sentence of that affidavit; I shall read it to you:

"That was the actual General Staff and the highest leadership of the Armed Forces."

A. I understand it this way, that Halder wanted to say that those few officers who had General Staff positions were the ones who did the real work in the General Staff of the Armed Forces, while the rest of the far more than one hundred General Staff officers in the O.K.H. had nothing to do with these matters. That is what I think he had in mind - a small group which was concerned with these problems.

Q. Do you know of a single occasion on which Hitler ever consulted a military leader in a political matter?

A. No, that did not happen.

Q. I assume that you were present, at least most of the time, at the conference with Hitler, where the situation was discussed. Could you tell me anything about counter- proposals made, with or without success, by any Commanders- in-Chief who had come from the front and who happened to be present?

A. As a rule, front Commanders-in-Chief who were present were silent listeners at the general discussion of the situation, and afterwards, according to circumstances, such commanders used to make a report to Hitler about their respective areas. This was also the opportunity which, I believe, was mentioned by Kesselring, to discuss these things personally and to utter opinions. But otherwise nobody had anything to say in these matters.

Q. Witness, were you ever present when particularly emphatic objections were raised by any Commander-in-Chief to Hitler?

A. During the discussion of the situation?

Q. No, whatever the occasion may have been.

A. I was not, of course, present at every conference which Hitler had with high ranking commanders and Commanders-in- Chief in his quarters, but I do not know of any such incidents. I have related in detail those cases which played a role in this war, namely the opposition of the generals in the West, before the beginning of the war, and I understood your question to mean whether I knew of any cases beyond that.

Q. Yes.

A. I have related all that and must emphasise once more that the Commander-in-Chief of the Army at that time went to the limit of anything which could be justified from the military viewpoint.

Q. What was the attitude of Hitler towards the General Staff of the Army

[Page 55]

THE PRESIDENT: We have heard all this once, if not more than once.

DR. LATERNSER: Mr. President, I do not believe that this witness has been asked about that. As far as I remember, this particular witness has not been asked about this point.

THE PRESIDENT: The Tribunal thinks he has been asked about it.

DR. LATERNSER: I would have noticed if this point had come up. I would have crossed off this question if one of my colleagues had put it before.

Q. Would Hitler, in case an application for resignation were tendered by one or more front commanders, have been willing to take back an order which he had once given?

THE PRESIDENT: Nearly every officer who has come and given evidence to this Court has spoken about that subject, certainly many of them.

DR. LATERNSER: Mr. President, does your objection refer to the question I have put now?

THE, PRESIDENT: Nearly all the officers who have been examined in this Court have told us it was impossible to resign. That is what you are asking about, is it not?

DR. LATERNSER: Yes, I will be glad to forgo that question, if I can assume that the Tribunal accepts those facts as true, as I wanted to prove.

THE PRESIDENT: The Tribunal thinks it is cumulative; whether it accepts its truth or not, is a different question.

DR. LATERNSER: Mr. President, also to this question I should like to say something. I do not believe that it can be considered cumulative, since, as it has already been pointed out by my colleague, Dr. Dix, the same question when put to two different witnesses is in each case a different question, because the subjective answer of the individual witness to this particular point is desired. But I will forgo that question.

THE PRESIDENT: Is there any other question you want to ask?

DR. LATERNSER: Yes, I have a few more questions.

Q. Witness, to what extent was the headquarters of the Fuehrer protected against attacks?

A. There was a special guard detachment of the Army and also, I believe, one company of the Waffen S.S. Very thorough security measures had been taken with every kind of safety device such as fences, obstacles and similar things. It was very well secured against any surprise attack.

Q. Were there several zones?

A. Yes, there was an inner zone and an outer zone-several areas which were fenced in separately.

Q. You have already stated that the Commanders-in-Chief Army Groups and Armies in the East did not have any authority outside their area of operation. Was there a tendency to keep that operational area as small as possible, or as large as possible?

A. Originally the tendency definitely was to have large areas of operation, in order to ensure the greatest possible freedom of movement in the rear of the armies and army groups. The Fuehrer was the first who, by drastic means, saw to it that these zones were limited.

Q. To make them as small as possible?

A. Yes.

Q. For what reasons?

A. As he said, in order to free military officers from administrative measures and get them out of the over- extensive territories for which they had been responsible and to concentrate them within narrower limits.

Q. You mentioned, during your interrogation, units of the Waffen S.S. which

[Page 56]

A. No, the units of the Waffen S.S. within the combined divisional forces were incorporated as such into the combined forces of the Army, and had nothing to do with anything else. They were in that case purely members of the Army.

Q. Was it possible for a Commander-in-Chief to punish an S.S. man for any offence?

A. If a man was caught in the act I believe no Commander-in- Chief would have hesitated; but apart from that, the last resort for disciplinary measures and jurisdiction was the Reichsfuehrer, Himmler, and not the Commanders-in-Chief of the Army.

Q. Did the executives of the special action groups of the S.D. have to report to the Commanders-in-Chief of the armies upon what they did in accordance with Himmler's orders?

A. This question has been dealt with here in great detail by the witness Ohlendorf, and I do not know what were the connections which existed between the Commanders-in-Chief and the special action groups and special action commandos. I was not involved and took no part in it.

Q. That is not what I wanted to hear from you, Field Marshal. I wanted to know whether the special action groups of the S.D., according to your knowledge of the regulations, were obliged to report to the military commanders in whose rear areas they had carried out some special action.

A. I do not believe so; I do not know the orders which were in force in this respect; I have not seen them.

Q. Do you know whether the higher military commanders at any time were informed of the intention of Hitler or Himmler to exterminate the Jews?

A. In my opinion, that was not the case, since I personally was not informed either.

Q. Now, I have only one more question concerning the prisoner-of-war complex. It became known during the war that the conditions relating to the food supply of Soviet prisoners of war during the first period of the Eastern campaign were miserable. What accounted for the conditions prevailing during that first period?

A. I can base my statement only on what the Commander-in- Chief of the Army said during the situation report conferences, at which he was almost invariably present. As I recall, he repeatedly reported that it was clearly a problem of vast numbers, for whom it required extraordinary efforts of organisation to provide food supplies, housing and security.

Q. These conditions were without doubt chaotic during a certain period of time. I am thinking of one particular reason, and in order to refresh your memory, witness, I would like to mention the following:

The Army had already prepared camps in the Reich for the future prisoners of war, because it was planned in the beginning that these prisoners should be transferred there. In spite of these preparations, however, as has been stated here, this action was negatived by a sudden order from Hitler which prohibited such a transfer of Soviet prisoners.

A. I explained that this morning, and I said that during a certain period, until September, the transfer of Soviet prisoners of war to the Reich was prohibited, and only after that was the transfer made possible, in order to utilise their manpower.

Could not the deficiencies which appeared during this first period have been remedied with the means at the disposal of the troops?

[Page 57]

Q. I have only a few more questions about the position of the Deputy Chief of the Armed Forces Operational Staff. When was that position set up?

A. I believe in 1942.

Q. 1942. What was the rank connected with that position?

A. That of a colonel or a general.

Q. I do not mean rank as to title but as to position. Was his position equal to that of a commander of a regiment or of a division?

A. Well, I, may say it was like the position of a brigade commander, a section chief.

Q. How many section chiefs were there in the O.K.W.?

A. I could not say exactly from memory, and I would not like to give you wrong figures.

Q. What is your estimate?

A. I had 8 department chiefs, each of whom had, I estimate, 4 sections, 3 or 4 sections. Therefore about 30 to 35 section chiefs may have existed.

Q. The Deputy Chief of the Armed Forces Operations Staff was one of the 30 section chiefs ?

A. No, I would not like to say that definitely. We had among the department chiefs so-called department group chiefs, who combined a few sections. That was about his position.

Q. What were the official duties connected with that position?

A. Naturally they were the supervision and direction of all the work of that part of the Armed Forces Operations Staff which belonged to the Fuehrer's headquarters. It was his task to direct that work, in accordance with the directives given by Jodl, the Chief of the Armed Forces Operations Staff.

Q. Was the Deputy Chief of the Armed Forces Operations Staff responsible for the strategic planning to a particularly high degree, as is maintained by the prosecution?

A. He was, of course, not responsible for that as D.C.A.F.O.S. but, as a matter of fact, he belonged to the small group of high ranking and outstanding general staff officers who were concerned with these things, as Haider has pointed out.

Q. I have one last question. Was the position of the Deputy Chief of the Armed Forces Operations Staff therefore not equal in importance to the other positions which are included in the alleged group of the General Staff and the O.K.W.?

A. I said that he was Chief of a departmental group in the Armed Forces Operations Staff, and co-worker in the small group of those who had to deal with operational and strategical questions, but subordinate to General Jodl and responsible for the work of the Arbeitsstab (working staff).

Q. Field Marshal, I believe that the question which I have put to you was not completely answered. I have asked you whether the significance of that position was equal or even nearly equal to that of the other offices which are included in the group of the general staff and the O.K.W.

A. No, certainly not, because in the group of the General Staff and the O.K.W. there were the Commanders-in-Chief, the Supreme Commanders and the Chiefs of the General Staff. He certainly did not belong to those.

Q. Thank you.

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