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                                                        [Page 234]

SIXTEENTH DAY

MONDAY, 10th DECEMBER, 1945

THE PRESIDENT: The Tribunal has received a letter from Dr. Dix on
behalf of the defendant Schacht. In answer to that, the Tribunal
wishes the defendants' counsel to know that they will be permitted
to make one speech only, in accordance with Article 24 (h) of the
Charter, and this speech will be at the conclusion of all the
evidence.

At the conclusion of the case for the prosecution, the defendants'
counsel will be invited to submit to the Tribunal the evidence
they propose to call, but they will be strictly confined to the
names of the witnesses, and the matters to which their evidence
will be relevant, and this submission must not be in the nature of
a speech. Is that clear? In case there should be any
misunderstanding, what I have just said will be posted up on the
board in the defendants' counsel room so that they can study it
there.

MR. ALDERMAN: May it please the Tribunal. When the Tribunal rose
on Friday, I had just reached the point in my discussion of
aggression against the U.S.S.R. where, with the campaign in the
West at an end, the Nazi conspirators had begun the development,
of their plans to attack the Soviet Union. Preliminary high level
planning and action was in progress. Hitler had indicated earlier
in November that more detailed and definite instructions would be
issued. These would be issued as soon as the general outline of
the Army's operational plans had been submitted to him and
approved by him. We had thus reached the point in the story
indicated on the outline submitted last Friday as Part 3 of the
"Plan Barbarossa".

By 18th December, 1940, the general outline of the Army's
operational plan having been submitted to Hitler, the basic
strategical directive to the High Command of the Army, Navy and
the Air Force for "Barbarossa", directive No.21, was issued. This
directive, which for the first time marks the plan to invade the
Soviet Union, was specifically referred to in an order, although
the order was classified Top Secret. It also marked the first use
of the code word "Barbarossa" to denote this operation.

The directive is No. 446-PS, and was offered in evidence in the
course of my opening statement, as Exhibit USA 31. Since it was
fully discussed at that time, it is, I believe, sufficient now
merely to recall to the Tribunal two or three of the most
significant sentences in that document. Most of these sentences
appear on Page 1 of the English translation. One of the most
significant, I believe, is this sentence with which the order
begins:

   "The German Armed Forces must be prepared to crush Soviet
   Russia in a quick campaign even before the end of the war with
   England."

On the same page it is stated:

   "Preparations requiring more time to start are - if this has
   not yet been done - to begin at once and are to be completed
   by 15th May, 1941.
   
                                                        [Page 235]
   
   Great caution has to be exercised that the intention of the
   attack will not be recognised."

The directive then outlines the broad strategy on which the
intended invasion was to proceed, and the parts that the various
services (Army, Navy and Air Forces) were to play therein, and
called for oral reports to Hitler by the Commanders-in-Chief,
closing as follows:-

   "V." - That is on Page 2 - "I am expecting the reports of the
   Commanders-in-Chief on their further plans based on this
   letter of instructions.
   
   The preparations planned by all branches of the Armed Forces
   are to be reported to me through the High Command, also in
   regard to their time.
   
   Signed by Hitler, and initialled by: Jodl, Keitel, Warlimont
   and one illegible name."

It is perfectly clear, both from the contents of the order itself,
as well as from its history, which I have outlined, that this
directive was no mere planning exercise by the Staff. It was an
order to prepare for an act of aggression, which was intended to
occur, and which actually did occur.

The various services which received the order certainly understood
it as an order to prepare for action, and did not view it as a
hypothetical staff problem. This is plain from the detailed
planning and preparation which they immediately undertook in order
to implement the general scheme set forth in this basic directive.

So we come to the military planning and preparation for the
implementation of "Plan Barbarossa". The Naval War Diary for 13th
January, 1941 indicates the early compliance of the O.K.M. with
that part of directive No. 21, which ordered progress in
preparation to be reported to Hitler through the High Command of
the Armed Forces. This entry in the War Diary is Document C-35 in
our numbered series, and I offer it in evidence as Exhibit USA
132.

This document contains a substantial amount of technical
information concerning the Navy's part in the coming campaign and
the manner in which it was preparing itself to play the part. I
feel, however, that it will be sufficient for the establishment of
our point - that the Navy was actively preparing for the attack at
this early date - to read only a small portion of the entry into
the record, beginning on Page 1 of the English translation, which
is Page 401 of the diary itself. The entry reads:-

   "30th January, 1941, Page 401 of the diary.
   7. Talk by Ia about the plans and preparations for the
   'Barbarossa' case to be submitted to the High Command of Armed
   Forces."

I should note that "Ia" is in this case the abbreviation for a
deputy chief of naval operations. Then follows a list of the
Navy's objectives in the war against Russia. Under the latter,
many tasks for the Navy are listed, but I think one is
sufficiently typical to give the Tribunal an idea of all. I quote
from the top of Page 2 of the English translation:-

   "II. Objectives of War Against Russia.
   (d) To harass the Russian fleet by surprise blows such as:-
   1. Lightning-like commitments at the outbreak of the war of
   air force units against strong points and combat vessels in
   the Baltic, Black Sea, and Arctic."

                                                        [Page 236]

The purpose of the offer of this document is merely that it
indicates the detailed thinking and planning, which was being
carried out to implement  "Barbarossa", almost six months before
the operation actually got under way. It is but another piece in
the mosaic of evidence which demonstrates, beyond question or
doubt, that the invasion of the Soviet Union was one of the most
cold-bloodedly premeditated attacks on a neighbouring Power in the
history of the world. Similarly, the Naval War Diary for the month
of February contains several references to the planning and
preparation for the coming campaign. Extracts of such references
are contained in Document C-33, which I am now offering in
evidence as Exhibit USA 133.

I think it will be sufficient to quote for the record, as typical,
the entry for 19th February, 1941, which appears at Page 3 of the
English translation, and at Page 248 of the diary itself.

   "In regard to the impending operation 'Barbarossa' for which
   all S-boats in the Baltic will be needed, a transfer of some
   can only be considered after conclusion of the 'Barbarossa'
   operations."

On the 3rd February, 1941, the Fuehrer held a conference to assess
the progress thus far made in the planning for "Barbarossa." The
conference also discussed the plans for "Sonnenblume" - which was
the code name for the North African operation - "Sunflower."
Attending this conference were, in addition to Hitler, the Chief
of the Supreme Command of the Armed Forces, the defendant Keitel;
the Chief of the Armed Forces Operations Staff, the defendant
Jodl; the Commander-in-Chief of the Army, Brauchitsch; the Chief
of the Army General Staff, Halder; as well as several others,
including Colonel Schmundt, Hitler's Adjutant.

A report of this conference is contained in our Document 872-PS,
which I now offer as Exhibit USA 134.

During the course of this conference, the Chief of the Army
General Staff gave a long report about enemy strength as compared
with their own strength, and the general overall operational plans
for the invasion. This report was punctuated at various intervals
by comments from the Fuehrer.

At Page 4 of the English translation of the conference plan, which
is at Page 5 of the German original, there is an interesting
extract, which although written in semi-shorthand, is at least
sufficiently clear to inform us that elaborate timetables had
already been set up for the deployment of troops as well as for
industrial operations. I quote:

   "The intended time period was discussed with a plan: 1st
   Deployment Staffel (Aufmarschstaffel) transfer now, front
   Germany - East; 2nd Deployment Staffel (Aufmarschstaffel) from
   the middle of March will give up three divisions for
   reinforcement in the West. Army Groups and Army High Commands
   are being withdrawn from the West. There are already
   considerable reinforcements though still in the rear area.
   From now on, 'Attila'" - I might state here parenthetically
   that this was the code word for the operation for the
   occupation of Unoccupied France - "'Attila' can be carried out
   only under difficulties. Industrial traffic is hampered by
   transport movements. From the middle of April, Hungary will be
   approached about the march-through. Three deployment staffels
   from the middle of April. 'Felix' is now no longer possible,
   as the main part of the artillery is being entrained." -
   "Felix" was the name for the proposed operation against
   Gibraltar.
   
                                                        [Page 237]
   
   
   "In industry the full capacity timetable is in force. No more
   camouflage.
   
   From 25. IV-15- V. Four staffels to withdraw considerable
   forces from the West." - "Seeloewe", or "Sea Lion", was a code
   word for the planned operation against England, and "Marita",
   which we shall see a little later in the quotation, was the
   code word for the action against Greece-" 'Seeloewe' can no
   longer be carried out. The strategic concentration in the East
   is quite recognisable.
   
   The full capacity timetable remains. Eight 'Marita' divisions
   complete the picture of the disposition of forces on the plan.
   
   C.-in-C. Army requested that he no longer have to employ five
   control divisions for this, but might hold them ready as
   reserves for commanders in the West.
   
   Fuehrer: 'When "Barbarossa" commences, the world will hold its
   breath and make no comment.'"

This much, I believe, when read with the conference conclusions,
which I shall read in a moment, is sufficient to show that the
Army as well as the Navy regarded "Barbarossa" as an action
directive and were well advanced with their preparations even as
early as February, 1941 - almost five months prior to 22nd June,
the date the attack was actually launched. The conference report
summarised the conclusions of the conference, in so far as they
affected "Barbarossa", as follows; I am now reading from Page 6 of
the English translation, which is on Page 8 of the German:-

   "Conclusions:-
   
   1. 'Barbarossa'
   
   (a) The Fuehrer on the whole was in agreement with the
   operational plan. When it is being carried out, it must be
   remembered that the main aim is to gain possession of the
   Baltic States and Leningrad.
   
   (b) The Fuehrer desires that the operation map and the plan of
   the disposition of forces be sent to him as soon as possible.
   
   (c) Agreements with neighbouring States, who are taking part,
   may not be concluded until there is no longer any necessity
   for camouflage. The exception is Roumania with regard to the
   reinforcing of the Moldau.
   
   (d) It must, at all costs, be possible to carry out 'Attila.'
   
   (e) The strategic concentration for 'Barbarossa' will be
   camouflaged as a feint for 'Seeloewe' and the subsidiary
   measure 'Marita'."

On 13th March, 1941, the defendant Keitel signed an operational
directive to Fuehrer Order No. 21, which was issued in the form of
"Directives for Special Areas". This detailed operational order is
Document 447-PS in our numbered series, and I now offer it in
evidence as Exhibit USA 135.

This order which was issued more than three months in advance of
the attack, indicates how complete were the plans for practically
every phase of the operation. Section I of the directive is headed
"Area of Operations and Executive Power," and outlines who was to
be in control of what and where. It states that while the campaign
is in progress in territory through which the army is advancing,
the Supreme Commander of the Army has the executive power, During
this period, however, the Reichsfuehrer S.S.

                                                        [Page 238]

is entrusted with "special tasks". This assignment is discussed in
Paragraph 2(b), which appears on Page 1 of the English
translation, and reads as follows:-

   "(b) In the area of operations, the Reichsfuehrer S.S. is, on
   behalf of the Fuehrer, entrusted with special tasks for the
   preparation of the political administration, tasks which
   result from the struggle which has to be carried out between
   two opposing political systems. Within the realm of these
   tasks, the Reichsfuehrer S.S. shall act independently and
   under his own responsibility. The executive power invested in
   the Supreme Commander of the Army (O.K.H.) and in agencies
   determined by him shall not be affected by this. It is the
   responsibility of the Reichsfuehrer S.S. that through the
   execution of his tasks, military operations shall not be
   disturbed. Details shall be arranged directly through the
   O.K.H. with the Reichsfuehrer S.S."

The order then states that, in time, political administration will
be set up under Commissioners of the Reich, and discusses the
relationship of these officials to the army. This is contained in
Paragraph 2(c) and Paragraph 3, parts of which I should like to
read:-

       "(c) As soon as the area of operations has reached
       sufficient depth, it is to be limited in the rear. The
       newly occupied territory in the rear of the area of
       operations is to be given its own political administration.
       For the present, it is to be divided, according to its
       genealogical basis and to the positions of the Army Groups,
       into North (Baltic countries), Centre (White Russia) and
       South (Ukraine). In these territories the political
       administration will be taken care of by Commissioners of
       the Reich who will receive their orders from the Fuehrer.
   
   (3) For the execution of all military tasks within the areas
   under the political administration in the rear of the area of
   operations, commanding officers who are responsible to the
   Supreme Commander of the Armed Forces (O.K.W.) shall be in
   command.
   
   The Commanding officer is the supreme representative of the
   Armed Forces in the respective areas and the bearer of the
   military sovereign rights. He will have the tasks of a
   Territorial Commander and the rights of a Supreme Army
   Commander or a Commanding General. In this capacity he will be
   responsible primarily for the following tasks:-
       
       (a) Close co-operation with the Commissioner of the Reich
       in order to support him in his political tasks.
       
       (b) Exploitation of the country and securing its economic
       values for use by German industry."

The directive also outlines the responsibility for the
administration of economy in the conquered territory, a subject I
will develop more fully later in my presentation. This provision
is also in Section 1, Paragraph 4, which I shall read:-

   4. The Fuehrer has entrusted the uniform direction of the
   administration of economy in the area of operations, and in
   the territories of political administration to the Reich
   Marshal, who has delegated the Chief of the 'Wi. Rue Amt' with
   the execution of the task. Special orders on that will come
   from the O.K.W./Wi./Rue/Amt."

                                                        [Page 239]

The second section deals with matters of personnel, supply, and -

THE PRESIDENT: Mr. Alderman, will you tell us at some time who
these people are? Who is the Reich Marshal?

MR. ALDERMAN: The Reich Marshal is the defendant Goering.

THE PRESIDENT: And who was the Reichsfuehrer of the S.S. at that
time ?

MR. ALDERMAN: Himmler.

THE PRESIDENT: Himmler?

MR. ALDERMAN: Yes.

Section II deals with matters of personnel, supply and
communication traffic, and I shall not read it here.

Section III of the order deals with the relations with certain
other countries, and states in part as follows - I am reading from
Page 3 of the English translation:-

   "III. Regulations regarding Roumania, Slovakia, Hungary and
   Finland.
   
   (9) The necessary arrangements with these countries shall be
   made by the O.K.W., together with the Foreign Office, and
   according to the wish of the respective high commands. In case
   it should become necessary during the course of the operations
   to grant special rights, applications for this purpose are to
   be submitted to the O.K.W."

The document closes with a section regarding Sweden, which is also
on Page 3 of the English translation.

   "IV. Directives regarding Sweden.
   
   (12) Since Sweden can only become a transit area for troops,
   no special authority is to be granted to the commander of the
   German troops. However, he is entitled and compelled to secure
   the immediate protection of railroad transports against
   sabotage and attacks.
   
   The Chief of the High Command of the Armed Forces.
   
   (signed) KEITEL"


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