[Page 399]

BY MR. ROBERTS:

Q. It is on your Page 52, witness, at the very beginning, or just at the end of Page 51:

"All leaders must keep firmly fixed in their minds the fact that the destruction of the Anglo-French army is the main objective, the attainment of which will enable suitable conditions to obtain for later and successful employment of the German Air Force against other objectives. The brutal employment of the German Air Force against the heart of the British will to resist can and will follow at the given moment."

A. You are asking me continuously about a document which, from the first to the last word, was written by the Fuehrer, as I have already told you. You are producing a rather interesting picture of the Fuehrer as a strategist and as a military leader, and it is of interest to the world, but I cannot see how this concerns me. These are the thoughts which the Fuehrer put down as military commander, and are of great interest for all soldiers in the world. But what does it have to do with me? That I do not understand.

Q. But may I point out, witness, that your own counsel produced it and you relied on certain parts of it. That is how it concerns you; you relied on it.

A. Yes.

THE PRESIDENT: We will adjourn now.

(A recess was taken until 1400 hours.)

BY MR. ROBERTS:

Q. Witness, I only have two other questions on the alleged aggression against the Low Countries. Will you look at your diary, Document 1809-PS, for the 8th of May, 1940. It is Page 141 in the Document Book 7, and it is Page 115 in the German Book. The actual quotation is Page 143 in the Document Book 7; at the top of the page:

"May the 8th. Alarming news from Holland. Cancelling of furloughs, evacuations, road blocks, other mobilization measures."

A. I was sure that the Dutch would defend themselves against Germany.

Q. Was it alarming because you thought the Dutch might have suspected you were going to break your treaties and assurances?

A. I did not understand the question.

Q. I will go on. "According to the reports of the Intelligence Service, the British have asked for permission to march in, but the Dutch refused. According to reports, measures of the Dutch partly directed against the coast and partly against us. It is not possible to obtain a clear picture whether the Dutch do not work hand-in-hand with the English, or whether they really want to defend their neutrality against the first attacker."

It is clear from that, is it not, that you had no information at all that Dutch neutrality was going to be broken?

[Page 400]

Q. Now, on the 10th of May, without any declaration of war, these three countries, small countries, were invaded with all of the armed might of Germany, were they not?

A. The attack began on the 10th of May along the whole front.

Q. What had those countries done at all to deserve the horrors of invasion and the misery of German occupation?

A. That, again, is an historical question. I have already said that, according to my personal point of view, England and France in fact forced them to give up their strictly neutral attitude. That was my impression.

Q. Their only fault, was it not, was that they stood in the way of your air bases and U-boat bases?

A. They were not only in the way, but by tolerating actions incompatible with neutrality, they helped England in the war against us. That was my subjective impression.

Q. Now, I have only got ... with the permission of the Tribunal, there was one question I should have asked on Norway; only one; and if I might go back to that, I want to ask you about your diary entry, Document 1809-PS, Page 145 in Document Book 7. I have not got a reference to the German, but it is about at that place. I will read it slowly:

"March 13th: Fuehrer does not give order yet for 'Weser.' He is still looking for an excuse" - or 'justification' - to use your word. And the next day, 14th March: "Fuehrer has not yet decided what reason to give for 'Weser' exercise."

A. Because for this operation the Fuehrer considered it absolutely essential to have some documentary proof. So far, there had only been very strong indications which came near to a proof, but we had as yet no documentary evidence.

Q. Very good. I leave that part of the case, and I now go to Yugoslavia, and I have only two or three questions on Yugoslavia.

I want you to look at Document 1746-PS, Page 127 in Document Book 7; German Book 112.

Before we deal with the document, witness, Yugoslavia had also received assurances from Hitler. That is so, is it not, or do you not know?

A. Yes. Not only did Yugoslavia receive assurances from Hitler, but we also received them from the Yugoslav Government, which had concluded a treaty with us on the previous day.

Q. Now, you will find the document I am going to refer to. It has got a piece of paper headed with the German word for "discussion," "Besprechung." Have you found it? It should be a piece of paper with the word "Besprechung."

A. " Discussion on the situation in Yugoslavia"; yes.

Q. Yes, that is right.

A. Yes.

Q. Dated 27th March, 1941?

A. Yes.

Q. Now if you turn to - I think it is Page 2:

"The Fuehrer is determined, without waiting for loyalty declarations of the new government, to make all preparations to destroy Yugoslavia militarily and as a national unit. No diplomatic inquiries will be made nor ultimatums presented. Assurances of the Yugoslav Government, which cannot be

[Page 401]

trusted anyhow in the future, will be taken note of. The attack will start as soon as the means and the troops suitable for it are ready. It is important that action be taken as soon as possible."

"Politically it is especially important that the new blow against Yugoslavia is carried out with unmerciful harshness, and military destruction is done by a lightning-like undertaking."

"The main task of the Air Force is to start as early as possible with the destruction of the Yugoslav Air Force ground installations, and to destroy the capital, Belgrade, in attacks by waves."

A. I do not know what preparations for warning the Yugoslav Government had been made, but at the moment of the putsch it immediately made military preparations and deployed its forces along our border.

Q. May I ask you this? Do you approve, as an honourable soldier, of attacking a city crowded with civilians without a declaration of war or even half-an-hour's warning?

A. I do not hold that view. I have already said that I, personally, and, half-an-hour or an hour later, the Reich Foreign Minister, suggested an ultimatum.

Q. When you lost air superiority and people were able to hit back, you Germans. made a great deal of fuss then about terror attacks, did you not?

A. This city was, at that time, the centre of a "Putsch" government, which had annulled a treaty concluded with Germany, and which from that moment on had made preparations along the whole front for war with Germany.

Q. Well, I am going to leave the incident. Do you remember how you referred to it in the notes for your lecture? It appears on Page 292 of Book 7, and at 304 of the German. You refer to it as "an interlude." Do you remember? The German word is "Zwischenspiel," "interlude." Is that your idea of an interlude?

A. To be juridically exact, you mean the first draft of my lecture and not my lecture, which you do not know. However, even in this first draft, I cannot recall mentioning an interlude.

Q. How many civilians, how many thousands, do you think were killed in the first movement of that interlude, in the bombing of Belgrade without warning?

A. I cannot say, but surely only a tenth of the number killed in Dresden, for example, when you had already won the war.

Q. Now I come to the alleged aggression against the Union of Soviet Socialist Republics. Hitler decided to attack the Soviet Republic in July of 1940, did he not?

A. In July of 1940 he had not yet reached that decision.

Q. But at any rate - I do not want to waste time - we know that on the 22nd of June, 1941, Germany invaded the Soviet Union contrary to her non-aggression pact. That is history, is it not?

A. Yes. The surprise attack on the 22nd of June, 1941, is a historical fact which took place because the politicians were of the opinion that the Soviet Union had not kept the pact.

Q. Now, witness, I am going to pass from this part of the case altogether. I want to put one last question. Do you not think that this record of broken pledges will dishonour the name of Germany for centuries to come?

A. It might, if historical research, after exact investigation of Russian documents, delivers clear proof that Russia had no intention of strangling us politically or of attacking us. In that case, yes; otherwise, no.

Q. I now want to ask - to come to quite a different part of the case under Counts 3 and Counts 4. The documents have been put to you so often, I do not: want to put them again.

[Page 402]

A. It was dealt with in the Quartermaster Section of the Wehrmachtfuehrungsstab.

Q. Well now, would you agree that that was a shameful order to have to issue?

A. I agree. I have already said that there was no soldier who did not oppose this order; they all did so.

Q. Very good. Now we know that on the 17th of July - and this is Document C-51, which is in Document Book 7, at Page 190, German Page 150 - we know that from the same office, the WFS, L, there was issued an order that the previous order was to be destroyed, but its validity was not to be affected, destroyed below corps level. What was the object of the destruction of that order?

A. Unfortunately, I cannot tell you; I do not recall this order. I do not believe I ever saw it, at least not before this trial.

Q. Perhaps you would look at it, witness, C-51, Page 190, Book 7; Page 150, German Book. Now, that comes from WFS L - that is, Wehrmachtfuehrungsstab - Department "L" - and then "Q" for "Quartermaster," in brackets. That is your office, is it not?

A. That is a part of the Wehrmachtfuehrungsstab.

Q. It is signed Keitel.

A. Yes. But I do not know this order; it was shown to me for the first time here in Nuremberg; I had never seen it before. I do not know what it is about or what order is being rescinded. I have already said that these questions of military justice and jurisdiction were dealt with by Field Marshal Keitel, and that he used my quartermaster section as a working staff, without my having any part in these matters. I do not know this order.

Q. And you cannot suggest any reason why it had to be destroyed?

A. No; I cannot give you any information about it.

MR. ROBERTS: Now then, I want Document C-52, which has not yet been put in. Your Lordships will find it on Page 191 of Book 7. I offer it as Exhibit GB 485, and it is in the German Book on Page 153.

BY MR. ROBERTS:

Q. Now this is another Keitel order. It comes from "Wehrmachtfuehrungsstab," "L"; then, in brackets, "1 Op." Is that your department?

A. That is the section which worked with me on all operational questions.

Q. Do you remember that order?

A. Yes, I remember the order.

Q. Now ... I think you took part in drafting it; did you not?

A. Certainly, because it is an operational order, which supplements a directive.

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