DR. WECKER:The next document is Krupp 237 as Exhibit -
JUDGE DALY:Excuse me, Dr. Wecker, did you say Exhibit 105 is Document 47?
PRESIDING JUDGEWILKINS: 145 -- 105 would be 62, would it not?
DR. WECKER:Yes, 62. Perhaps you mean the reference I made to the document which was introduced.
JUDGE DALY:This may be my error. I was listening to it coming over this way and I thought I heard you say Exhibit 45 for your Document 105, but I thought it should have been 62 and I was asking whether I was confused or not.
DR. WECKER:However, I can clarify the matter.
PRESIDING JUDGE WILKINS:It is all clarified. 63 is 127.
DR. WECKER:Yes, that is Exhibit 63. This is an affidavit by Lt. General of the Cavalry, Siegfried Westphal, from 1935 to 1939 Chief of the Operations Department of the General Staff in Berlin. He states on page 33, 3rd paragraph:
"The initiative to the rearmament of Germany, which was carried on in the course of those years, rested with the political leaders of the Reich.
"The Army and the German General Staff desired likewise a rearmament, since Germany's position between her highly armed neighbor states became more and more untenable, the longer the efforts of the international Disarmament Conference remained without any practical results. However, the Army Command did not think of creating an army of 36 divisions, as was proclaimed by Hitler on 16 March 1935. They rather regarded the triplication of the army of 100,000 men up to 21 divisions as the maximum of what was absolutely indispensable and practicable."
A short comparison of the strength would have been opposed in the event of a war, according to our calculations, by 32 Czecho-Slovak, 40 Polish and at least 110 French divisions. These three potential adversaries had consequently more than double the strength of the German field armies of 1938/39. Likewise, the total strength of their tanks COURT III CASE X surpassed considerably that of Germany's which had, at that time, to be assessed at roughly 1500 light types."
The next document being offered is Krupp 18a. This is an excerpt from the official transcript of the IMT dated 9 August 1946, the examination of Field Marshal von Manstein. In 1929 the General joined the Reich Ministry for the Armed Forces and from 1929 to 1932 he was the First General staff Officer.
The question of Defense Counsel was and I quote: the second to the last paragraph is the question: "Q. But then you must have been informed about the aim and the degree of rearmament?" "A: Yes, the goal of our rearmament, first of all, in the years before the seizure of power, was the most primitive security against an unprovoked attack on the part of even one of our neighbors."
Two sentences further:
"We wanted to make sure we could go on fighting until the League of Nations would interfere."
Two sentences further:
"We knew at all times, therefore, that we had to avoid everything which might be considered a violation of the Treaty of Versailles or a provocation."
To disprove the document presented by the Prosecution we find on page 39 the following comment in response to a question put to the General Field Marshal and I quote:
"P. 14991: The intentions we had for the fortification of the Rhineland afterwards were purely defensive. The western wall was planned, just as was the Maginot line, as a wall, if possible, insurmountable in the event of attack."
The next document is Krupp 126 as Exhibit 65. This is an affidavit by Cavalry General Siegfried Westphal who in this document speaks of the various German plans. He differentiates between the Troop concentration Red and another plan Green. His statements on page 42 are fairly interesting under paragraph 2:
"The General Staff of the Army had not worked out any troop concentration plan of any kind against Austria. The only provision was a border guard to secure the German-Austrian border, contained in plan "Red."
"Therefore the decision to march into Austria came as a complete surprise to the High Command of the Army, as well as to the General Staff of the Army. The orders to accomplish this had to be improvised to a certain extent. At the time many of the General Staff officers were on a training trip in Thuringia connected with their tactical training and had to be called back from there by teletype."
Under 3 the General discusses the General Staff trips made in the years '35 to '38 under the supervision of the Chief of the General Staff, General of the Army Beck. He says:
"They were designed to continue the training of the higher General Staff officers. The Chiefs of the General Staffs of the Group and Corps Headquarters participated in these trips. The problems on all of these trips were concerned with the defense against a French or combined French and Czechoslovakian attack on German territory."
The next document is Krupp 106 as Exhibit 66. This is an affidavit of Lt. General Adam (retired) of whom we already have one or two affidavits.
On page 43 of the affidavit we find the statement:
"The entire training of officer and General Staff officer replacements was based on the idea of the defense of the nation."
He continues and I quote:
"As Chief of the Troop Department and in my later positions I carried out this training of General Staff officers and other subordinates by means of numerous assignments, studies and General Staff trips. The given situation always provided that our forces had to defend themselves against an attack by superior forces of the enemy. In my problems the attack upon another country never occurred.
"The 'Strategy of the Inner Line' that means our strategic behaviour COURT III CASE X in case of enemy attack from several sides was, so to speak, the daily bread of our teaching and training.
My successor and friend, Gen. Beck followed the same principles."
We now hear Lt. General Beck himself in the form of an affidavit of the just mentioned Lt. General Adam, the purpose of Krupp Document 107, Exhibit 67. In it there is a description of how the then Commanderin-Chief of the Army General von Brauchitsch ordered the Commanding Officer of the Army Group to attend a conference of the military and political situation and there is a question of a treaty in a memorandum by General Beck, the Chief of the General Staff concerning the internal political situation and foreign policy of Germany and I quote on page 46:
"In case of such a war, Germany would have to count on the entry of France and Great Britain into it, even if it broke out, at first, between Poland or Czechoslovakia on the one side and Germany on the other. Unavoidably the USA, with its tremendous war potential, would be drawn into it just as in 1917. Soviet Russia, with whom we have broke all bridges and whose leaders are daily being abused by the German government, would not stand aloof. On our side would only be insecure and unimportant countries. In case of a war Germany would have to count on fighting almost the entire world. There could be no doubt about the result of such a battle. These thoughts of Beck's were backed up with ample factual and statistical material."
The affiant then describes how General von Brauchitsch asks him, the affiant, Lt. General Adams, who gave his opinion on Beck's attitude, and he states that he agreed with Beck's argument as he said on page 46 especially in regard to the air superiority of the potentially hostile states, and the extraordinary vulnerability of Germany to air attack. "I called such a war a war of desperation without any hope."
He then turns to the so-called western fortifications, and on page 47 he states: "'I am painting black with black. That is the truth.'".
And on page 4 7 at the bottom, "The generals present agreed with B eck's and my arguments. General von Brauchitsch closed the conference with the conclusion that the higher officers of the Army were united in rejecting a war."
This is an interrogation of General von Brauchitsch who, as everyone knows, was examined before the IMT, and I present this Krupp Document 18 as Exhibit 68. The German page of the transcript is 14946.
This is once more about the speech read by General Beck at that time where General von Brauchitsch states on page 49: "I had very serious qualms regarding a policy supported by military measures. General Beck had composed a memorandum in which he reached the military conclusion that a war in the center of Europe would have to lead to a world conflict. Since I considered these conclusions as a perfectly sound basis I used this opportunity to present them to the commanding Generals. There was another reason why I had ordered those generals to appear in Berlin -- the discussion of the internal questions of the army. In conclusion I asked everyone for his opinion. We unanimously agreed to this opinion. Hitler received this memorandum later on. There was quite an excited argument about this, and he told me essentially, among other things, that he knew by himself what he had to do."
The first port of this confirms what General Adam said in Krupp 107, Exhibit 67.
The statements on page 50 are interesting, namely, Exhibit 68, where Field Marshal General Brauchitsch comments about the plans of attack of the enemy and the plans within the German general staff. Above all there is a sentence: "Si Vis pacem para bellum.
On page 51 there is a dramatic conference with the Fuehrer, and I quote; "On 5 November 1939 I asked therefore for an audience with the Fuehrer. As I was unable to use political reasons anymore, I had to restrict myself to purely military reasons. This I did, by referring to the condition of the army. At first Hitler listened quietly to my statements. Then he flew into a rage, so that any further conversation was quite impossible, and I left. The order to attack on 12 November arrived on the evening of the same day. But this order was rescinded again on the 7th of Novombert. That is how Hitler mot the supreme Commander of the Army.
The next document is the affidavit of the success of of General Beck, who was General Franz Haider. This is Krupp Document 47 which I offer as Exhibit 69. The General relates the geographical situation of Germany, and on page 52 at the bottom he states; "The army always only gave consideration to the defense of its own country. It was backed up in this by the announced policies of the German governments -- including the government of Reich Chancellor Hitler."
The statements on page 53 should be of significance, namely, the proclamation on the occasion of the re-establishment of a general conscription on 16 March 1935. "'Germany intends to guard the integrity of Reich territory and to safeguard Germany's international position as a co-guarantor of universal peace with the reconstruction of its Wehrmacht.
Before the German people and the entire world it is proclaimed that Germany as a power of equal rights will contribute its part to the pacification of the world in a voluntary and open collaboration with the other nations. The national Wehrmacht of Germany shall not be an instrument of aggression, but rather exclusively one of defense and maintenance of peace."
It is interesting to realize from the documents that I have presented that the decisions in the reign of Adolf Hitler were not even given to the supreme military leaders until the very last moment, and it is further interesting for the question which we shall deal with later on, the question of the good faith and statements and proclamations of the Reich government. And in this proclamation the Reich government considers the re-establishment of general conscription intended for the defense and for the maintenance of peace.
On page 53, at the bottom of the affidavit of General von Haider, the definition is dealt with concerning which I examined the witness schmidt, namely, the definition of the term "agressive war" and "defensive war". He relates here that one has to distinguish between the defensive war on the one hand and the operational conduct of war on the other. The political conception of a war of aggression has to be distinguished from the military conception of an aggressive war. An aggressive warfare also is conceivable in the defensive war, and he relates on page 54 that "The German military theory distinguishes expressly between defense and repulsion.
Training in the German army was aimed, at conducting defense if at all possible actively in the tactical as well as in the operational framework, because purely passive defense is usually without success, according to the experiences of military history."
On page 54 at the bottom, the affiant states: "When I took over the office as Chief of the General Staff of the Army, only preparations of an attack on Czechoslovakia which had matured during the term of office of my predecessor Beck and which bore the stamp of a military bluff rather than of a serious attack were passed on to me."
On page 55 at the top, I quote the first paragraph: "Apart from that, until 1939, no plan of the General Staff which can be designated as a plan for the concentration of troops for action or an operational plan existed, either to the East or to the West."
And on page 55, the third paragraph states: "The plans for an aggressive war in the west occasioned by the declaration of war on the part of England and France were only made after the Polish campaign on orders from the OKW."
Your Honors, in time of danger it is not only the right but the duty of the state to arm, and this is shown from Krupp Document 58 which I offer as Exhibit 70. This is an excerpt from speeches and statements of General George C. Marshall, Chief of Staff of the United States Army. The heading is "National defense, the Business of every citizen."
And on page 11 of this document, which is page 57 of the book, "Our policy is, I think, thoroughly in keeping with American thought and characteristics -- only the means necessary to defend ourselves until the vast resources of this country, in men and industry, can be mobilized."
And on page 58 we find the following statements: "Today, we must be prepared to go to war with the most efficient machines of death and destruction mankind has ever devised and in quantities corresponding to the production capacity of the present age. It is the true philosophy of the maximum war effort of any nation to devote to this purpose as much manpower in the form of soldiers and sailors, and as much supply power in the manufacture of weapons and ammunition as the country can support."
I go on to quote the concluding paragraph which is very interesting because it gives the basis of a comparison with Germany: "The Army has two general missions. It must be prepared to protect the United States and our overseas possessions against any external attack or raid and it must prevent the domination of territory in the Western Hemisphere by an overseas power. Our geographical position simplifies this task. Two oceans guard us against sudden attack."
Germany was not in a position to exist between these highly armed nations with which it was surrounded. Germany was not able to have two oceans as they were described by George C. Marshall.
The next document is Krupp 102 as Exhibit 71. This is an affidavit by General Heinz Guderian, who from 21 July 1944 was Chief of the General Staff, and who subsequently held many high positions within the German armed forces.
On page 50 he speaks of the initiative of the German rearmament and states: "The initiative for the German rearmament up until 1933 lay with the chiefs of the army and navy high commands. They requested the Reich Government to take the necessary measures and authorize the necessary funds, to be used, for instance, for fortifications and for the development of planes and tanks."
Page 60: "Insofar as the possession of the new arms was outlawed by the Treaty of Versailles, they were developed in friendly foreign countries, the development of tanks for example, was effected in Russia beginning 1927.
"2. In addition to that, the firm of Krupp had received, among other things, an order for the construction of a tank. Moreover, the later development of Tank I in the firm of Krupp originated from a corresponding order of the Army High Command. The latter had bought in England a Carden-Dloyd Tractor and, as early as 1932, arranged for the construction of a self-propelled anti-aircraft mount to be later converted into a tank.
"3. The Army High Command regarded the allocation of such development orders as rightful. Germany had fulfilled the obligation of disarmament imposed on her by the Treaty of Versailles. The treaty partners however, failed to disarm on their part although they too were under obligation to comply with this agreement. In view of this fact, the armed forces, left to Germany, could only then be placed in a position to fulfill their assigned tasks of defending the Reich with some chance for success, if they were increased in numbers and given better arms. To effect this and prepare a rearmament on a moderate scale was regarded by the Army High Command not only as itsright but as its duty.
"4. Morever, in placing orders for the development of tanks, the Army High Command only thought of the defense of their own country."
Then the author cones to the topic which we are interest in, namely, the topic of to what extent certain weapons, particularly heavy weapons, are a case of agressive intentions, and it states on page 61 and I quote:
"All weapons serve the purpose of attack as well as the defense. If there are weapons at all which, according to their nature and purpose, are constructed primarily for the purpose of attack, this also includes tanks. In this connection, however, the 'attack' is a tactical conception and not an operational or stategical one. Nowadays a country cannot conduct a defensive war against a well-armed enemy without tanks or airplanes unless extraordinarily favorable geographical conditions make it difficult or impossible for the aggressor to use his modern weapons of attack.
"Germany's strategic geographical situation was not so favorable. On the contrary, her borders to the West, and above all, to the East were completely open to attack."
Moreover, those two oceans are lacking which might have prevented a number of things.
Under 6 on page 62, the author states: "An armament equality with that of all possible enemies was not even nearly accomplished up to 1939. This equality, if one included England and Russia into the group of possible enemies, was not possible to achieve at all.
"In 1937 Russia had about 17,000 tanks compared to Germany with only 1200 (all Tanks I.)
"In 1940 Great Britain and France moved up 4,500 tanks to the western front, Germany's theoretical strength at that time amounted to 2,800 tanks including the armored scout cars serving the purpose of reconnaissance. On May 10, 1940, the number of German tanks that were actually available was about 2,200.
"In 1941 Russia had about 20,000 tanks; Germany started the compaign against Russia with 3,200 tanks."
The next document to be presented is Krupp Number 63 as Exhibit 72.
PRESIDING JUDGE WILKINS:Dr. Wecker, let me assure you again that the Tribunal will read thoroughly each one of these documents, and you have stated a time or two that you are very much pressed for time; and I am just merely making this suggestion to he helpful so that if you wanted to utilize the time to some other extent and just refer to these briefly, it is your time and you may use it as you wish. But it is just a suggestion.
DR. WECKER:I shall endeavor to do so. This is an affidavit by General of the Infantry Walter Buhle who discusses the fact that in the middle of the 1920's the German government decided to take all measures necessary for the defense of the country. Until the end of the war, Walter Buhle was chief of the General Staff of the OKW.
On page 63 at the bottom, he mentions that "on the basis of this decision the Army Command conducted its first deliberations in regard to increasing the German armament preparedness. So-called "Wehrwirtschaftsoffiziere", Military-Economy officers,were appointed.
On page 64, he is referring to the experimental fields in Russia which are mentioned by the Prosecution and describes that these experimental fields were erected with the complete approval of the government and that he had no knowledge that any of the nations opposed these experimental fields.
The next document is Krupp Number 14. That is offered as Exhibit 73, and it is an affidavit by Otto Hartmann. Otto Hartmann from 1933 to 1935 was military attache with the German embassy in Moscow. He also discusses the three Russo-Germany military proving grounds which existed in Russia, early in 1933 and states: "These proving grounds -- in the middle of page 65 -- were to my knowledge established upon the suggestion of the former German ambassador in Moscow Graf Brockdorft-Rantzau and the chief of the German Army Command, General von Seeckt, with the mutual understanding of the German and Russian governments, around the middle of the twenties.
On the part of the Germans no intention existed then to rearm secretly by way of these proving grounds. Rather, the leading German authorities, as far as I know, were guided by the idea that in the case of the hoped for future relaxation of the provisions of the Versailles Treaty and the then possible modernization of the Reichswehr of that time, they would possess the necessary initial practical knowledge and experiences without which a rebuilding of German armament forbidden by the Versailles treaty would be unthinkable."
Krupp Document Number 45 is offered as the next document as Exhibit 74. This is an affidavit by the former General of the Cavalry Ernst Koesterring. From 1931 to '33 Koesterring was military attache with the German embassy in Moscow. He too speaks of the proving grounds.
Therefore, the affidavit is important where it states: "According to my notes of that time these experiments were also known to the Diplomatic Corps in Moscow. Any protests of the signatory powers to the Versailles Treaty against the military cooperation of the German Reich and the Soviet Union and against the participation of German armament firms have not become known to me."
The next document to be offered is Krupp 43 as Exhibit 75. A new topic is being opened here, the topic dealt with this morning by the Witness Schmidt,namely, agressive war. May I be permitted to read the third paragraph because the wording is very important. It states in the fourth footnote from the top on page 69:
"I know of no weapon which might be called a pronounced weapon for an offensive war. Apart from the fact that a defensive war has to be waged in an offensive way, it could not even be said that some specific weapons are destined only for offensive use.
"The character of any weapon depends on its actual use at a given occasion, since all weapons may be used both for purposes of attack and defense.
Imagining the tactical defense as purely passive, conducted without any counterattack and counter-thrust, one might arrive at calling one or another weapon, say, bombers, armored cars, or heavy guns destined for the distinction of enemy concrete emplacements or tank cupolas, offensive weapons. It is, however, one of the tasks of the passive defense to smash preparations of the enemy for an offensive in time. This applies to transport installations and troop concentrations as well as concentration of artillery both openly and under concrete and armour."
On page 70: "What is essential is not the weapon and its construction, but its actual way of use.
"All attempts to define the notion of an 'offensive weapon' are therefore useless, and have always failed so far. Nor has any definition been laid down at the disarmament conference because there, too, it was found to be impossible." That is the last quotation on page 70.
The next document I offer is Krupp 143 as Exhibit 76. This is an excerpt from a book by Dr. Karl Schwendemann headed, "Equal Rights and Equal Security", and it describes the Geneva disarmament conference which has been discussed this morning. It deals with the topic shortly touched on by the witness, Schmidt, this morning more elaborately, and it is stated here:
"In the face of heavy French resistance the conference adopted after a lengthy discussion in a resolution of 22 April 1932 the principle of qualitiative disarmament, that is, the principle of the selection of specific categories of armament or types of weapons, the possession and use of which should by means of an international agreement be either prohibited to all states or internationalized." Page 72:
"The technical committees now set about defining the offensive weapons.
"Their discussions lasted for about two months with a completely negative result.
"The attempt to achieve a definition of the offensive weapons failed."
The dependance of the character of a weapon on its actual use has not only been confirmed by the statements of German Generals but of American Generals as well, who have dealt with this subject in this very building.
We now come to Krupp Document 109 which I offer as Exhibit 77. In this document we find an excerpt from the transcript of Case IX before the Military Tribunal II.
MISS GOETZ:The Prosecution objects to the admissibility of this document as without probative value which the Prosecution says is not evidence in this case or any other, and, finally, it is not relevant, a statement taken out of context. General Taylor is not talking about offensive or defensive weapons but is merely describing the use of the atomic bomb which is criticized.
PRESIDING JUDGE WILKINS:Is it your idea, Dr. Wecker, that General Taylor is an authority on weapons of this kind?
DR. WECKER:At any rate, I consider General Taylor an authority. It is possible that if he spoke of atomic bombs that he must know something about them.
PRESIDING JUDGE WELKINS:It will be admitted for whatever value it may have.
JUDGE DALY:Don't you think a lot of people are talking about the atomic bomb these days who know nothing about it?
DR. WECKER:Well, . . .
Paragraph 2 reads as follows:
"The atomic bomb, therefore, is neither more nor less legal than ordinary bombs; under the rules of warfare, the question is not as to the character or explosive capacity of the bomb, but how it is used." I simply wanted to show with this document that in any weapon the important thing is how it is used, and may I hint at the relativity of all things which were indicated by my colleague this morning when he cited the very "bon mot" of the gun which seemed to be an offensive weapon when you looked into the barrel but which is a defensive weapon when you look at it from behind.
MISS GOETZ:In connection with Exhibit 77 I hesitated to make any corrections of the index because the context in the index is not evident, but I think the index describes the excerpt from General Taylor's closing statement incorrectly. I don't think that he stated as this excerpt says that the character of a weapon depends on its actual use, which I understood by "character". This entire section is devoted to the question of offensive and defensive weapons.
PRESIDING JUDGE WILKINS:All right, it may be changed, Miss Goetz, if you think that it states it incorrectly. However, it will have no bearing on it anyway, and I doubt seriously if there will be any probative value in the particular document, but we will admit it anyway.
MISS GOETZ:I find that statement satisfactory, Your Honor.
DR. WECKER:The next document is Krupp 64, and I offer it as Exhibit 78.
This is an affidavit by General of the Infantry Herbert von Boeckmann. This General from 1932 to 1935 was the consultant in the Reich War Ministry for disarmament questions, and he speaks of the fact that at the disarmament conference at Geneva which took place at this time the attempt was made to determine the concept "aggressive weapons", and that this effort failed. He states and I quote: -- this is on page 74 at the middle of the page.
"The reason for this was that it is not possible from the construction or effect of a weapon to determine whether this is to be regarded as a weapon of attack or a weapon of defense.
"Only the manner in which a weapon, for instance, a special purpose gun, a tank or a bomb is used decides whether it is to be classified as a weapon of attack or a weapon of defense.
"In no event can the person employed on the construction or manufacture of weapons know whether this weapon will be used as a weapon of attack or weapon of defense."
The last sentence is of cardinal importance to this case since the defendants are reproached for constructing tanks, for instance, and the Prosecution feels that anyone who builds tanks must have been of the opinion that these tanks would be used for aggressive purposes.
The next document is Krupp 82 as Exhibit 79. This is an affidavit by Major General Erich Stud, retired, a specialist in the weapons field because he was the chief of the Economic Group and chief of supply of the Army Ordnance Office. He, too, states in paragraph 3 of the affidavit on page 76:
"There are no distinct attack or defense weapons. Whether a weapon serves attack or defense results not from its construction but from its tactical deployment.
"Even weapons which appear to be genuine weapons of attack, in view of their construction and effect, as, perhaps, tanks or the heaviest guns, are, used in defense, defense weapons. On the other hand, weapons which seem to be genuine defense weapons, in view of their construction and effect, as, perhaps, anti-tank guns, mines or anti-tank weapons of the infantryman, used in attack, can become distinct weapons of attack."
On page 77, second to the last paragraph he states, and this is very important for our case:
"I consider it impossible to draw conclusions as to the intent to wage offensive war from the development and manufacture of certain weapons."
The next document to be offered is Krupp 41 as Exhibit 80. We are addressed here by General of the Artillery, Emil Leeb, who from 1940 until 1945 was Chief of the Army Ordnance Office, and he states that the Army Ordnance Office was responsible for the development and testing of new weapons, new ammunition and new equipment for the Army.
PRESIDING JUDGE WILKINS:On my copy it shows page 74. I assume that is a typographical error; it should be 79.
THE PRESIDENT: 79.
DR. WECKER:Yes, 79. I beg your pardon. The two last paragraphs of this affidavit on page 80 I quote:
"The responsible contact of the Army with industry, in connection with armament, occurred only through the Army Ordnance Office. It has also been shown that, as a rule, the impetus for the development of new weapons, ammunition and new equipment, as well as for the mass production of these things, comes from military agencies.
"Before 1933 the Army Ordnance Office also worked on the development of weapons which were not allowed by the provisions of the Versailles Treaty, including armored vehicles (Panzer I and II) and anti-aircraft weapons. These weapons are absolutely necessary for the conduct of a defensive war."
This disproves the assertion of the Prosecution where it states in the Indictment, point 17, the firm of Krupp was one of the main sources of supply of aggressive weapons like heavy tanks, submarines, artillery which was needed for the conducting of aggressive war. It also disproves quotations from the transcript of 11 December, page 326 in the German transcript.
We consider this an important document for the reason that the production of tanks according to Article 73 of the Versailles Treaty is strictly prohibited and because tanks constituted a part of the "Blitzkrieg".
The next document is Krupp 15 as Exhibit 81, and it is on page 81. This is an affidavit by Rear Admiral Hans Steenbock. Hans Steenbock from 1938 until 1944 was Commander of the Regional Armament Office in Essen. He states at page 81, third paragraph:
"As such it was my job to give my support to production matters of the armament industry in my territory, including the flow of production of the Fried, Krupp firm, and to be of assistance in case of production difficulties and bottlenecks.
Above all I had to transmit to the armament firms, for execution, directions and directives which I received from the Armament Office; an agency of the OKW and later of the Ministry of Armament and War Production, through the Armament Inspectorate at Muenster.
The representatives of the Krupp firm with whom I had to deal primarily were Professor Goerens and Direktor Girod, who was in charge of mobilization matters and also of the liaison between the Regional Armament Office and the Krupp firm.
I knew about all of the armament orders the Krupp firm received. Up to the beginning of the war in 1939 these orders were so small that it would have been impossible to draw the conclusion from them that the political leaders had war intentions." And towards the end, page 82:
"The orders allotted to the Krupp firm for the delivery of certain weapons did not indicate a war of aggression. The weapons could be used either for defense or for offense. Their later tactical use was not dependent on their design."
The next document is Krupp 42 as Exhibit 82. This is an affidavit by General of the Artillery, Emil Leeb, the Chief of the Procurement Office and later on Chief of the Army Ordnance Office. General Leeb says:
"The attempts made before 1933 to raise the production capacity of German industry to a point where it could accomplish industrial mass production of weapons for the Army were entirely insufficient and unimportant. The Krupp firm did not participate in these efforts to increase industrial mass production."
PRESIDING JUDGE WILKINS:Excuse me. We will adjourn at this time.
(A recess was taken.)