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My Lord, there is a similar assurance to the Netherlands,
the next part of the document:

  "The new Reich has endeavoured to continue the
  traditional friendship with the Netherlands. It has not
  taken over any existing differences between the two
  countries and has not created any new ones."

I submit it is impossible to over emphasise the importance
of those assurances of Germany's good faith.

My Lord, the value of that good faith is shown by the next
document, which refers to the very next day, 7th October.
Those two guarantees were 6th October. Now we come to
Document 2329-PS, dated 7th October. It is

                                                  [Page 206]

from the Commander-in-Chief of the Army, von Brauchitsch,
and it is addressed to various Army Groups. He said, third

  "The Dutch Border between Ems and Rhine is to be observed
  At the same time Army Group B has to make all
  preparations, according to special orders, for immediate
  invasion of Dutch and Belgian territory, if the political
  situation so demands."

"If the political situation so demands" - the day after the
guarantee! I put in the last document; that bears an
original typewritten signature of von Brauchitsch, and it
will be Exhibit GB 105.

My Lord, the next document is in two parts. Both are
numbered C-62. The first part is dated 9th October, 1939,
two days after the document I have read. My Lord, that was
all read by the Attorney General in opening, down to the
bottom of Paragraph (c). Therefore, I will not read it
again. May I remind the Tribunal of just one sentence.

  "Preparations should be made for offensive action on the
  Northern flank of the Western Front crossing the area of
  Luxembourg, Belgium and the Netherlands. This attack must
  be carried out as soon and as forcefully as possible."

In the next paragraph, may I just read six words:

  "The object of this attack is to acquire as great an area
  of Holland, Belgium and Northern France as possible."

That document is signed by Hitler himself. It is addressed
to the three accused: the Supreme Commander of the Army,
Keitel; Navy, Raeder; and Air Minister, Commander-in-Chief
of the Air Force, Goering. That is the distribution.

I will hold that document over and put that other one in
with it.

My Lord, the next document refers to 15th October, 1939. It
is from the Supreme Command of the Armed Forces. It is
signed by Keitel in what is to some of us his familiar red
pencil signature, and it is again addressed to Raeder and
Goering and to the General Staff of the Army.

Now, that also has been read by the Attorney General; may I
just remind the Tribunal that at the bottom of the page
there is:

  "It must be the object of the Army's preparations,
  therefore, to occupy - on receipt of a special order -
  the territory of Holland, in the first instance as far as
  the Grebbe-Maas" - or Meuse - "line."

The second paragraph deals with the taking possession of the
West Frisian Islands.

It is clear beyond discussion, in my submission, that, from
that moment, the decision to violate the neutrality of these
three countries had been made. All that remained was to work
out the details, to wait until the weather became
favourable, and, in the meantime, to give no hint that
Germany's word was about to be broken again. Otherwise these
small countries might have had some chance of combining with
themselves and their neighbours.

It will be Exhibit GB 106.

The next document is a Keitel directive. It is Document 440-
PS, Exhibit GB 107. It is again sent to the Supreme
Commander of the Army, the Navy and the Air Forces, and it
gives details of how the attack is to be carried out. I want
to read only a very few selected passages.

                                                  [Page 207]

Paragraph 2 on the first page:-

  "Contrary to previously issued instructions, all action
  intended against  Holland may be carried out without a
  special order as to when the general attack will start.
  The attitude of the Dutch Armed Forces cannot be
  anticipated ahead of time."

Then may I comment here, will your Lordships note here that
this is a German

  "Wherever there is no resistance, the entry should carry
  the character of a peaceful occupation."

Paragraph (b) of the next paragraph:-

  "At first the Dutch area, including the West Frisian
  Islands situated just off the coast, for the present
  without Texel, is to be occupied up to the Grebbe-Maas

The next two paragraphs I need not read. They deal with
action against the Belgians, however, and in Paragraph 5:

  "The 7th Airborne Division" - they were parachutists -
  "will be committed for the airborne operation only after
  the possession of bridges across the Albert Canal" -
  which is in Belgium, as the Court knows - "has been

Then, in Paragraph 6 (b), Luxembourg is mentioned. It is
mentioned in Paragraph 5 as well. The signature is "Keitel",
but that is typed. It is authenticated by a staff officer.

Then the next Document is C-10, Exhibit GB 108, and it is
dated 28th November, 1939. That has the signature of Keitel,
in his red pencil, and it is addressed to the Army, Navy and
Air Force. It deals with the fact that, if a quick break-
through should fail North of Liege, other machinery for
carrying out the attack will be used.

Paragraph 2 shows clearly that the Netherlands is to be
violated. It speaks of "(a) The occupation of Walcheren
Island and thereby Flushing harbour, or of some other
southern Dutch island especially valuable for our sea and
air warfare" and "(b) Taking of one or more Maas crossings
between Namur and Dinant."

My Lord, the documents show that from November until March,
1940, the High Command and the Fuehrer were waiting for
favourable weather before A-day, as they called it. That was
the attack on Luxembourg, Belgium and the Netherlands.

My Lord, the next Document, C-72, consists of 18 documents
which range in date from 7th November until 9th May, 1940.
They are certified photostats I put in, and they are all
signed either by Keitel personally or by Jodl personally,
and I do not think it is necessary for me to read them. The
defence, I think, have all had copies of them, but they show
successively that A-day is being postponed for about a week,
having regard to the weather reports. That will be Exhibit
GB 109.

My Lord, on 10th January, 1940, as the Attorney General
informed the Tribunal, a German aeroplane made a forced
landing in Belgium. The occupants attempted to burn the
orders of which they were in possession, but they were only
partially successful. The next document I offer is Document
TC-58a; it will be Exhibit GB 110. The original is a
photostat certified by the Belgian Government who, of
course, came into possession of the original.

                                                  [Page 208]

My Lord, I can summarise it. They are orders to the
Commander of the Second Air Force Fleet - Luftflotte -
clearly for offensive action against France, Holland and
Belgium. One looks at the bottom of the first page. It deals
with the disposition of the Belgian Army. The Belgian Army
covers the Liege-Antwerp Line with its main force, its
lighter forces in front of the Meuse-Schelde Canal. Then it
deals with the disposition of the Dutch Army; and then, if
you turn over to Page 3, you see that the German Western
Army directs its attack between the North Sea and the
Moselle, with the strongest possible air-force support,
through the Belgian-Luxembourg region.

My Lord, I think I need read no more. The rest are
operational details as to the bombing of the various targets
in Belgium and in Holland.

My Lord, as to the next document, my learned friend, Major
Elwyn Jones, put in Jodl's diary, which is GB 88, and I
desire to refer very, very briefly to some extracts which
are printed first in Bundle No. 4.

If one looks at the entry for 1st February, 1940, and then
some lines down -


MR. ROBERTS: Yes, that is right, my Lord.

THE PRESIDENT: We have not got the GB numbers on the

MR. ROBERTS: I am sorry, my Lord.

If your Lordship will look eight lines down it says: "1700
hours General Jeschennek" and then:-

  "1.Behaviour of parachute units. In front of The Hague
  they have to be strong enough to break in if necessary by
  sheer brute force. The 7th Division intends to drop units
  near the town.
  2. Political mission contrasts to some extent with
  violent action against the Dutch Air Force."

My Lord, I think I need not read the rest: it is operational

"2nd February." I refer again to Jodl's entry under "a" as
to "landings can be made in the centre of The Hague."

THE PRESIDENT: Which date?

MR. ROBERTS: That was 2nd February, my Lord, the bottom of
the same page, under "a". I was endeavouring not to read
more than a word or two.

THE PRESIDENT: Quite right.

MR. ROBERTS: If your Lordship will turn over the page - I
omit 5th February - you come to "26th February. Fuehrer
raises the question whether it is better to undertake the
Weser Exercise before or after case 'Yellow'."

Then on 3rd March, the last sentence:-

  "Fuehrer decides to carry out Weser Exercise before case
  'Yellow', with a few days' interval".

Then, my Lord, there is an entry to which I desire to call
your Lordship's  attention, on 8th May, that is, two days
before the invasion, the top of the page:-

  "Alarming news from Holland, cancelling of furloughs,
  evacuations, road-blocks, other mobilisation measures.
  According to reports of the intelligence service the
  British have asked for permission to march in, but the
  Dutch have refused."

                                                  [Page 209]

My Lord, may I make two short comments on that? The first is
that the Germans are rather objecting because the Dutch are
actually making some preparation for resistance. "Alarming
news " they say. The second point is that Jodl is there
recording that the Dutch armies according to their
intelligence reports, are still adhering properly to their
neutrality. But I need not read any more of the diary

My Lord, that is the story except for the documents which
were presented to Holland and to Belgium and to Luxembourg
after the invasion was a fait accompli, because, as history
now knows, at 4.30 a.m. on 10th May these three small
countries were violently invaded with all the fury of modern
warfare. No warning was given to them by Germany and no
complaint was made by Germany of any breaches of any
neutrality before this action was taken.

THE PRESIDENT: Perhaps this will be a convenient place to
break off until 2 o'clock.

MR. ROBERTS: Yes, my Lord.

(A recess was taken until 1400 hours.)

MR. ROBERTS: May it please the Tribunal, when the Court
adjourned, I had just come to the point at 4.30 a.m. on 10th
May, 1940, when the Germans invaded these three small
countries without any warning - a violation which, the
prosecution submits it is clear from the documents, had been
planned and decided upon months before.

My Lord, before I close this part of the case, may I refer
to three documents in conclusion. My Lord, the invasion
having taken place at 4.30 in the morning, in each of the
three countries, the German Ambassadors called upon
representatives of the three governments some hours later,
and handed in a document which was similar in each case and
which is described as a "Memorandum" or an "Ultimatum". My
Lord, an account of what happened in Belgium is set out in
our Document TC-58, which is about five documents from the
end of the bundle. It is headed "Extract From 'Belgium - The
Official Account of What Happened 1939-1940'", and I hand in
an original copy, certified by the Belgian Government, which
is Exhibit GB 111.

My Lord, might I read short extracts? I read the third

  "From 4.30 information was received which left no shadow
  of doubt: the hour had struck. Aircraft were first
  reported in the East. At 5 o'clock came news of the
  bombing of two Netherlands aerodromes, the violation of
  the Belgian frontier, the landing of German soldiers at
  the Eben-Emael Fort, the bombing of the Jemelle station."

My Lord, then I think I can go to two paragraphs lower down:-

  "At 8.30 a.m. the German Ambassador came to the Ministry
  of Foreign Affairs. When he entered the Minister's room,
  he began to take a paper from his pocket. M. Spaak" -
  that is the Belgian Minister - "stopped him: 'I beg your
  pardon, Mr. Ambassador. I will speak first.' And in an
  indignant voice, he read the Belgian Government's
  protest: 'Mr. Ambassador, the German Army has just
  attacked our country. This is the second time in 25 years
  that Germany has committed a criminal aggression against
  a neutral and loyal Belgium. What has just happened is
  perhaps even more odious than the aggression
                                                  [Page 210]
  of 1914. No ultimatum, no note, no protest of any kind
  has ever been placed before the Belgian Government. It is
  through the attack itself that Belgium has learned that
  Germany has violated the undertakings given by her on
  13th October, 1937, and renewed spontaneously at the
  beginning of the war. The act of aggression committed by
  Germany, for which there is no justification whatever,
  will deeply shock the conscience of the world. The German
  Reich will be held responsible by history. Belgium is
  resolved to defend herself. Her cause, which is the cause
  of Right, cannot be vanquished'."

Then I think I shall omit the next paragraph: "The
Ambassador read the note" - and in the last paragraph: "In
the middle of this communication M. Spaak, who had by his
side the Secretary-General, interrupted the Ambassador:
'Hand me that document', he said. 'I should like to spare
you so painful a task.' After studying the note, M. Spaak
confined himself to pointing out that he had already replied
by the protest he had just made."

THE PRESIDENT: The Tribunal would like you to read what the
Ambassador read.

MR. ROBERTS: I am sorry. I was thinking of the next document
I was going to read. I read the last paragraph on the first

  "The Ambassador was then able to read the note he had
  'I am instructed by the Government of the Reich,' he
  said, 'to make the following declaration: In order to
  forestall the invasion of Belgium, Holland, and
  Luxembourg, for which Great Britain and France have been
  making preparations clearly aimed at Germany, the
  Government of the Reich is compelled to ensure the
  neutrality of the three countries mentioned, by means of
  arms. For this purpose, the Government of the Reich will
  bring up an Armed Force of the greatest size, so that
  resistance of any kind will be useless. The Government of
  the Reich guarantees Belgium's European and Colonial
  territory, as well as her dynasty, on condition that no
  resistance is offered. Should there be any resistance,
  Belgium will risk the destruction of her country and loss
  of her independence. It is, therefore, in the interests
  of Belgium that the population be called upon to cease
  all resistance and that the authorities be given the
  necessary instructions to make contact with the German
  Military Command'."

My Lord, the so-called ultimatum, handed in some hours after
the invasion had started, is Document TC-57, which is the
last document but three in the bundle. It is the document I
handed in and it becomes Exhibit GB 112. My Lord, it is a
long document and I will read to the Tribunal such parts as
the Tribunal thinks advisable:

  "The Reich Government" - it begins - "has for a long time
  had no doubts as to what was the chief aim of British and
  French war policy. It consists of the spreading of the
  war to other countries, and of the misuse of their
  peoples as auxiliary and mercenary troops for England and
  The last attempt of this sort was the plan to occupy
  Scandinavia with the help of Norway, in order to set up a
  new front against Germany in this region. It was only
  Germany's last minute action which upset this project.
  Germany has furnished documentary evidence of this before
  the eyes of the world.

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