[Page 147]

THE PRESIDENT: Mr. Dodd, is not this letter that you have just read the very letter which is referred to in the letter which you put to him immediately before?

MR. DODD: Yes, sir, it is. It referred to Document EC-271. I am sorry, I said 271, I meant 270.

THE PRESIDENT: Exhibit GB-No. 649 is the letter you just read. Will you look at the first paragraph of Document EC- 270; the letter referred to there, criticising, is the defendant Funk's letter you just read.

MR. DODD: Yes, it is, your Honour.

BY MR. DODD:

Q. My point here, Witness, is that, you see, you told the Tribunal that you really just worked under Goering; that you did not have much to say about these things, but now we find that you were writing a letter asserting your supreme authority and saying now, "it is a fact that I am really only answerable to Hitler," and, you see, these two are quite inconsistent. What have you to say about that?

A. Yes; in fact, I was never successful.

Q. Now, let us see if you were not. Now you turn to another page in that document and you will find another letter from Lammers, written on 6th April, 1938, and it is written to you, and he tells you that you are just right in what you understood to be your position; that you are indeed only subordinate to the Fuehrer and that he has sent a copy of your letter to both Field Marshal Goering and the Commander of the OKW. Now, what do you say about that?

A. I see from this that I tried at that time to obtain that post, but in fact I never succeeded because the Reichsmarshal himself stated later that he would never turn over the war economy to me. The formal authority of the Plenipotentiary for Economy was turned over to the Four-Year Plan by a decree of the Fuehrer of December, 1939.

Q. Well, is that your answer?

Now, you also have told the Tribunal, as I understood you at least, that you really did not have much to do with the planning of any aggressive wars, and that your activities were restricted to regulating and controlling the home economy, so to speak. Now, actually on 28th January, 1939, which was some months before the invasion of Poland, you were considering the use of prisoners of war, weren't you?

A. That I do not know.

Q. Are you sure about that? Now I will ask that you be shown another document, EC-488, which becomes Exhibit USA 842. This is an unsigned letter, a captured document from your files. This letter, by the way, was transmitted under the signature of Sarnow. You know who he was; he was your deputy.

Now, this letter dated 28th January, 1939, says that its subject is "Re: Employment of Prisoners of War." Then it goes on to say:-

[Page 148]

"Under the Reich Defence Law of 4th September, 1938, I have the direction for the economic preparations for the Reich Defence, except the armament industry."

But what I want to call your attention to particularly is the sentence in the second paragraph which says:-

"The deficit in labour has to be made up by the employment of eventual prisoners of war as far as possible and practical. The preparations, therefore, have to be made in close co-operation with the OKW and GBW. The offices under my jurisdiction will be duly informed."

A. No, I have never seen that letter, and never signed it. But that letter relates to the matters about which I spoke this morning. The Office of the General Plenipotentiary for Economy - moreover I see "General Plenipotentiary for War Economy" is scratched out - was continuously occupied with these things. I personally had nothing to do with it.

Q. Well now, that is rather playing with words. This was your ministry that was making these suggestions, and your principal deputy who transmitted this letter, isn't that so?

A. No, that was -

Q. (Interposing). Now, look up in the right-hand corner of that letter and see if it does not say "The Plenipotentiary General for the Economy," and then it gives the address and the date.

A. Yes, and it is signed "By Order of Sarnow."

Q. That's right, and he was your principal deputy, wasn't he?

A. No.

Q. What was he?

A. He only worked in the office of the General Plenipotentiary. My main deputy, who was in charge of those things, was Posse.

Q. Well now, at any rate -

A. (Interposing). As I have said before, I personally had nothing to do with these things whatsoever.

Q. It has just been called to my attention that if you say the man was Posse, then in the second paragraph of that letter you can find his name: "I can refer to the statements of Colonel General Keitel, Secretary of State Dr. Posse."

In any event, important people in your organization were involved in this thing, weren't they?

A. Certainly.

Q. All right. Now, you remember the Document 3562-PS. It was introduced here as Exhibit USA 662. It is the minutes of a meeting set out by Dr. Posse, your deputy, which discussed a memorandum for financing the war, and you talked about that this morning and you said that despite the fact that there is a note on it "to be shown to the Minister," you never saw it.

A. I would have had to initial it if I had seen it.

Q. Well, whether that is so or not, I am not concerned about that just now. Instead, I want you to listen while I read an excerpt from it. If you would like to see the document you can have it, but I hardly think it is necessary.

You recall that in that document one of your memoranda is referred to, is it not? Do you remember? Do you remember that Posse said:-

"It was pointed out that the General Plenipotentiary for Economy is primarily concerned with introducing, into the legislation for war finance the idea of financing war expenditures by anticipating future revenues, to be expected after the war."

Q. All right. That is all I have to ask about that document. We can move right along here.

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A. In all probability not. For months there was a latent danger of war, but already in August one could see that it was imminent.

Q. Had you been planning or making economic plans for war with Poland for more than a year before the attack on Poland? You can answer that yes or no.

A. I do not know.

Q. You mean you do not know whether you had or not? What do you mean by that kind of an answer? Don't you remember?

A. I do not remember.

Q. All right. Then I can help you.

There is a document, 3324-PS, which is already in evidence. You must remember it; it is Exhibit USA 661. That is a speech that you made. Isn't that so? Don't you remember saying in that speech that you had been planning in secret for well over a year for the war on Poland? Do you remember that? Would you like to see the document?

A. Yes, please.

Q. The sentence is here:-

"Although all the economic and financial departments were engaged in the tasks and work of the Four-Year Plan, under the leadership of General Field Marshal Goering, the war economic preparation of Germany has also been advanced in secret."

A. Yes, now I know.

Q. You will also notice it says here "for well over a year," and you went on to say this had been done under you. Is that true?

A. Yes, that was the activity of the General Plenipotentiary for Civilian Economy. I already explained that this morning.

Q. Very well. I just wanted to have your answer -

A. (Interposing). I did not speak of Poland.

Q. Well, that is the only war that was on when you made this speech. It was October, 1939.

A. The preparations were not made for a specific war, it was -

Q. All right.

A. It was a general preparation.

Q. Now, actually you and Goering were even contesting for power to some extent, weren't you? Was the Goering door one of those that you were also trying to open?

You can answer that very simply. You told us you were trying to get in through various doors, but you would get as far as the threshold and never get in. I now ask you if the Goering door was one of those.

A. I do not believe that I was so presumptuous as to want to obtain Goering's post. That was far from being my intention. I had very little ambition.

Q. I didn't say that you wanted to obtain his post, but you wanted to have some of his authority, didn't you? Or don't you remember? Maybe that is the solution.

A. No.

Q. Well, your man Posse was interrogated here by representatives of the prosecution and the Document is No. 3894-PS. He was asked these questions:-

"Question: What was the nature of the conflict between the Plenipotentiary for Economy and the Four-Year Plan?

Answer: The struggle for power.

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"Question: The struggle for power between Funk and Goering?

"Answer: The struggle for power between Funk and Goering, between Funk and the Ministry for Agriculture and the Ministry of Communications.

"Question: How was the struggle finally resolved?

"Answer: It never was. It was a struggle always continuing under the surface."

"Question: Did Funk, who had very important powers as Minister of Economics and later as Reichsbank President and as Chief Plenipotentiary for Economy, actually exercise these powers?

"Answer: Yes. But the powers of Goering were stronger.

"Question: Nevertheless, Funk did exercise important powers?

"Answer: Yes, as President of the Reichsbank, Minister of Economics, and Plenipotentiary for Economy."

A. Yes, but Posse's position was somewhat different. My deputy was Landfried and in the Reichsbank, Puhl. They knew these things better than Posse.

Q. Well, all right.

A. They should know more about it than Posse.

Q. You do not think he really knew what he was talking about when he said you were in the struggle for power? Is that your answer?

A. No.

MR. DODD: That becomes Exhibit USA 843. We have not offered it up to now.

BY MR. DODD:

Q. Now, Witness, I want to ask you about when you first heard of the impending attack on Russia. I understood you to tell the Tribunal that you heard about it sometime - I think you said - in May. Is that right? Or June?

A. When Rosenberg was appointed.

Q. Well, that is what we want to know. When Rosenberg, in April of 1941, was appointed, you knew then there was to be an attack on Russia, didn't you? But this morning I don't think you made that clear. Isn't that right, Dr. Funk?

A. Yes, I said that the reason given us for that appointment was that the Fuehrer considered a war with Russia to be likely.

Q. Yes, but you know what you told the Tribunal this morning. You said that Lammers sent you notice of Rosenberg's appointment because of your interest in improving the trade relations with Russia. That is the answer you made this morning. Now, that was not so, was it?

A. Yes, Lammers has said that here, too.

Q. I don't care what Lammers said. I am asking you now if it isn't a fact that you were told by Lammers, because you were to co-operate with Rosenberg in making ready for the occupation of those territories after the attack began. Now you can answer that very simply. Isn't that true?

A. No.

Q. Now, we'll see. You know, on another occasion you have given another answer, by the way, I might say parenthetically. Do you remember telling the interrogator that you first heard from Hess about the impending attack on Russia? Do you remember you gave that answer at one time as the source of your first knowledge? Do you remember telling us that?

A. No.

Q. I'll tell you about that in a minute. We will continue with the question of Rosenberg.

There is a document, 1031-PS, and it is dated 28th May, 1941, which would be a little more than a month after the Rosenberg appointment, "Top Secret Notes; Meeting with Reich Minister Funk." Do you know what you were

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A. No.

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