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Counsel for the defence tried to convince the Tribunal that their clients, by a whim of destiny, became involved in this sinister tragedy in spite of themselves. The defendants Keitel, Jodl, Doenitz and Raeder endeavoured to appear in the role of noble-minded simpletons. To do the defence justice, it did the best it could to help them in this attempt.

We have heard a great deal about the honour of the soldier, of military discipline, fidelity to duty, oaths of allegiance - and the consequent obligation to fulfil Hitler's orders, even those which in their hearts aroused both doubt and direct protest. Such a presentation of their position completely distorts the actual state of affairs. Before passing to the question of the guilt of Keitel, jodl, Doernitz and Raeder, I consider it necessary to ask the following three questions:

1. Did these defendants know that Hitlerite Germany, in violation of its international obligations, had prepared a series of aggressive and predatory wars?

2. Did they take an active part in the planning, preparing, launching and waging of these wars?

3. Are they guilty of cynically trampling on the laws and customs of warfare? Are they responsible for the atrocities and for the extermination of the peaceful population, for the sinking of passenger and hospital ships, for the towns and villages destroyed by the military machine of the Hitlerite Reich?

It seems to me that after this investigation which has so carefully gone into all the details of this case it would be impossible, unless we remain blind to the facts, to give any but an affirmative answer to these questions.

The evidence submitted to the Tribunal has fully proved that the military group of criminals is guilty of the most appalling crimes and that they have actively participated in the planning and execution of the common criminal conspiracy.

The very fact that these crimes were committed by men in uniform not only does not mitigate their responsibility, but, on the contrary, merely serves to heighten it.

How can they attempt to whitewash themselves by referring to the "duty of a soldier," "the honour of an officer," and the "obligation of fulfilling orders"? Since when has "the duty of a soldier" and "the honour of an officer " been compatible with the shooting, without trial, and the branding of prisoners, as well as with the extermination of women, children and old people?

The only true and correct explanation of the amazing fact that these generals and admirals did not commit what, in effect, were capital crimes lies in the fact that they were actually generals and admirals of Hitler's making. These are men of a special brand. They are Fascists in uniform, bound body and soul to the Nazi rgime.

This is the only reason why Hitler gathered these men around him and collaborated with them for so long a period of time. This is the only way to explain why they collaborated with Hitler in perpetrating crimes unprecedented in historv. They fitted and understood one another to perfection.

Keitel

" . . . the factual significance of Keitel's activities was immense. It was a monstrous, extremely ungrateful job and its miserly remuneration was a brilliant position in the immediate proximity to the head of the State."

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It is difficult to minimize the significance of all that was done at the time by Colonel Keitel in the Committee of Experts which painstakingly and consecutively sought and found means of circumventing or violating the treaty.

it was none other than Colonel Keitel in particular who gave instructions to the effect that in Geneva it was possible to say what one pleased, but care must be taken not to leave anything behind on paper.

This cynical statement fully tallies with the role played by Keitel in the subsequent preparation and execution of aggressive wars.

During the negotiations between Hitler and Schuschnigg, Keitel in person was the living reminder of Germany's preparedness to resort to arms.

Keitel issued orders for troops to cross into Czechoslovakia at the time when President Hacha was so treacherously called to Berlin "for continuing negotiations."

It was the OKW and none other which was fully prepared through the Department of the "Abwehr" to provoke an incident with Czechoslovakia in order to justify the invasion by the German hordes, ready to fall upon Czechoslovakia.

In his strictly confidential memorandum, Keitel demanded that Hess and Himmler advise the OKW in advance of all measures taken by Party organizations or police which were not included in "Case Green."

The declarations alleging that after the seizure of Czechoslovakia Germany had no more territorial aspirations in Europe were downright lies. This seizure was but a link in the chain of aggressive wars.

I wish to emphasize the leading role of the OKW in the preparation and carrying out of aggression. The directive regarding the waging of war and the invasion of Poland is known to us as Keitel's and Hitler's directive of May, 1939. It was forwarded to the command of the air, navy and land forces. How is it possible, after this, to maintain that the OKW was not the driving power behind the armed forces of the Fascist Reich?

If we once more peruse the documents pertaining to German aggression against Norway, Denmark, Belgium, Holland, Luxembourg, Yugoslavia and Greece, we again come across the name of Keitel. He appears as a participant in the most important events, or as the author of secret orders addressed to Raeder, Goering and the General Staff. We find the initials of Keitel and Jodl entered in their own hand on the secret directive signed by Hitler regarding "Operation Maritza."

Much has been said here of "Plan Barbarossa" and its authors. At present it is important to stress that this document took shape in the innermost depths of the OKW, and on its initiative, and that the methods planned a priori of a treacherous attack on the USSR were likewise the work of the OKW. The significance of a military specialist's visa on a document is clear to everybody.

Some of the defendants attempted to portray the attack on the USSR as a preventive war. This contention is to such a degree unconvincing and contradictory to the irrefutable evidence presented in Court (German documents) that I see no need for wasting the Tribunal's time.

Keitel's defence counsel stated that his defence is based on the point of view that Keitel "is fighting not for his head but to save his face."

I should like to help the Tribunal to see Keitel's true face. For this I should have to remind you of a number of Keitel's directives which may well lay claim to being among the foremost of all the infamous documents pointing to the barbarity of the German military clique, to its baseness and foul and unlimited contempt for every concept of the rules and customs of warfare.

Let us consider the documents dealing with the shooting of political officers. Keitel, the soldier, as he likes to call himself, ignoring his oath, shamelessly lied to the representatives of theAmerican prosecution at his preliminary investigation

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And what can be said of the following statement, appalling in its boundless cynicism:

"Human life in the countries concerned is absolutely of no account ... a terrifying influence can only be achieved by unheard-of brutality."

These are documents stained in blood. No one can compute how many thousands of prisoners of war-soldiers and officers of the Red Army - had been killed and tortured in the camps of Fascist Germany. You remember how, on 21st January, 1946, at the afternoon session, the witness Lampe testified that for Himmler's amusement the shooting of fifty Soviet officers was organized in Mauthausen camp. You remember the witness Blaha testifying that in the spring of 1944, ninety-four Soviet senior military officers were tortured and then killed for refusing to impart military information.

I should like to mention the testimony of the SS man Paul Waldman, regarding the slaughter of 840 Russian prisoners of war. You remember the testimony of the witness Kivelsh regarding the endless chain of torture and suffering to which Russians, captured by the Germans, were subjected?

It is impossible to overlook Keitel's directive calling for the branding of Soviet prisoners of war.

One cannot forget the Keitel directive of the i 6th December, 1942. It is entitled "Measure to be adopted against Bands." Under the word "bands" defendant Keitel understood any resistance movement and demanded that his troops revert to harsh methods, stopping at nothing, even in regard to women and children.

The Soviet prosecution submitted Lecourt's testimony as Exhibit USSR 162. Lecourt states that he shot and burnt Soviet citizens and razed their houses. He alone had shot over 1,200 persons, and for this achievement was promoted to the rank of Obergefreiter and awarded the medal for service in the East. He acted in accordance with Keitel's directives.

A directive of Keitel's, instituting courts martial in the "Barbarossa" region, freed such persons of all responsibility for their crimes. Keitel's hands are stained with the blood of the victims of Lecourt and his like.

It was in carrying out Keitel's directive, to the effect that life in the Eastern regions was of no value, that the soldiers and officers of Hitlerite Germany committed their atrocities.

Exhibit USSR 51, submitted by the prosecution, shows how, on the 28th August, 1941, attacking German troops drove a group of women, children and old men in front of their combat units. In the village of Kolpino the Fascists forced the peasants to dig trenches and build bridges for them. Then they shot all the peasants.

In Yugoslavia the mass shooting of hostages was a daily practice of the military command and military administration. In a secret report of the 15th February, 1940, addressed to Goering, the OKW ustifies the practice of seizing hostages.

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In this document, Admiral Canaris informs Keitel of the club-law prevalent in the prisoner-of-war camps, of the hunger, and of the mass shootings of Soviet prisoners of war. Even that hardened Fascist spy Canaris, fearing eventual responsibility, could not ignore a cruelty which cried to high heaven, and a flagrant violation of the accepted laws and customs of warfare.

You will remember Keitel's note on this report:

"I approve and support these measures."

"You, defendant Keitel, called a field-marshal, repeatedly referred to yourself as a soldier before this Tribunal, and you, by your bloodthirsty resolution, approved and sanctioned the murder, in cold blood, of thousands of captured soldiers. Do you confirm this?"

This resolution alone unveils the true, the authentic face of Field- Marshal Keitel. The highly involved arguments of the defence cannot absolve him of his responsibility for the bloodshed and for the innumerable human lives cut short by the Fascist military clique acting on orders and directives signed by Keitel's hand.

Jodl

Everything connected with the preparation and execution of the aggressive plans of Hitlerite Germany is inseparably linked to the name of Jodl, as well as to Keitel's.

There is no need to repeat all the aggressive acts of Hitler's Germany. They are already facts of common knowledge, and had been individually planned and executed with the direct connivance of defendant Jodl.

As the representative of the Union of Soviet Socialist Republics, I should like to emphasize once again that the criminal plan for the perfidious attack on the Soviet Union, coded by the Hitler clique under the name of the ill-fated conqueror, Friedrich Barbarossa, is signed not only by Hitler and Keitel, but by Jodl as well. But this is more than a mere signature.

As far back as the summer of 1940, in Reichenhalle, Jodl held the first conference of his staff officers, at which the question of a possible attack by Hitler Germany on Soviet Russia was discussed.

It was the defendant Jodl alone who, even before the attack against the USSR, issued his well-known "Instructions on the use of propaganda in the 'Barbarossa' region." In these instructions it is definitely stated that "propaganda directed at the partition of the Soviet Union should not, as yet, be carried out."

Thus, defendant Jodl knew beforehand of the actual aims of Germany's attack on the USSR, and knew of the predatory practical nature of a war which called for the dismemberment of the Soviet Union.

It was Jodl who participated in the preparation and organization of an incident staged on the Czechoslovak border intended to justify the aggressive act of Hitler's Germany against this peace-loving nation.

It was Jodl who signed the directive of the 28th September, 1938, regarding the order in which the so-called Henlein Corps was to be used should "Case Green" be realized.

How worthy of derision are the words of the defendant Jodl about the "honour of the soldier" when we read his order for the destruction of Leningrad, Moscow, and other cities of the Soviet Union.

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As Hitler's closest military adviser who had personally participated in the preparation and execution of all the bloodthirsty and aggressive plans of Hitlerite Germany, defendant Jodl has been justly included in the ranks of the major German war criminals.

Doenitz and Raeder

In the course of his cross-examination, Doenitz told the Soviet Prosecutor that he was unaware of the reasons for which Hitler had appointed him as his successor. I do not believe that Doenitz was quite sincere in making this statement. One has only to refer to the transcripts of the session, as from the 8th May, in order to understand, without any confession on his part, why he became Hitler's successor, when the Hitlerite Reich crashed to the ground. The important point is not the fact that an admiral was needed at a moment like this, but the fact that in the opinion of Hitler, so soon to fade from the picture, only the Nazi " Grossadmiral Doenitz could do anything to save the sinking ship.

Under Hitler, Doenitz commanded the submarine arm of the German Reich. We know the role which the German U-boats played in this war. In twis connection it is worthy of emphasis that Doenitz prided himself on being the author of the so-called "wolf-pack tactics." The people of the Soviet have not forgotten how Doenitz's submarines, in the Baltic and Black Seas, sank both hospital ships and steamers evacuating peaceful citizens - women and children.

The last head of the Hitlerite Government should also be one of the first to pay the penalty for all those crimes which have led to the trial of the major war criminals before the International Military Tribunal.

The name of Raeder is linked to the impious directive for the destruction of Leningrad.

At the trial, Raeder tried to act the part of an "honest soldier" But the mere fact that it was he, together with Hitler and Keitel, who conspired to "wipe Leningrad off the face of the earth" and to exterminate more than three millions of the population of that great city, whose very name is indissolubly connected with the development of the culture and history of mankind, makes Raeder one of the major war criminals.

Raeder participated in drafting all the most important plans of aggression of German Fascism. This participant in the criminal Fascist conspiracy must, therefore, bear the punishment meted out to his associates.

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