THE PRESIDENT: Pardon me, General von Behr -
THE WITNESS: Yes.
THE PRESIDENT: The prosecutor is reading from a document that you apparently do not have, so if you will give attention to the question he is propounding, it might be advisable.
MR. FULKERSEN: I am reading from the transcript of the afternoon session of December 19, 1947, on page 8055. This is General Dehner's testimony:
"I could not issue the order to shoot hostages. That authority has been once and for all vested in the divisional commanders by the highest headquarters.
"Question: Well, who, then, had this latitude, this discretion you are talking about if you didn't have it? You are saying now that the divisional commanders had it, but that you didn't?
"Answer: This becomes quite clear from the order. The divisional commander is the responsible man for the various reasons which I have given on direct examination."
Then from page 8056:
"It might have occurred in individual cases that the divisional commanders did it, in fact, that they used their right which was given them in the Army order. Of course, I discussed these things with the divisional commanders, but what I discussed I can't pay in detail."
Now, I ask you again -- you say that you, as a divisional commander, had a certain amount of latitude and discretion in carrying out or not carrying out this order. Do you also say that you were the only person who had any discretion in carrying out and deciding whether the order was or was not to be carried out within your divisional area?
A. I cannot recall as to whether I alone was the person who was to be held responsible and bear the responsibility. That was where the corps commander was precluded. It is possible, but as I said before today, I cannot give the desired answer today, as I feel and believe that the divisional commander who was especially close to the troops and in charge of these matters, that within his divisional area, he was the only person responsible for giving such orders, and that accordingly, the corps commander ought to have been precluded from this responsibility from the giving of such orders, because he was more removed and could only gain an insight into these affairs from the reports furnished to him; whereas, the divisional commander is on the spot, and can decide and ascertain as to whether a reprisal measure is justified or not.
Q. General, in the 8th paragraph of your affidavit you take up the operation Kammerhofer.
A. Yes.
Q. When did this operation take place?
A. I can't say with certainty. It may have been in October, the end of September or October, I can't say with certainty. But I think it is in the document book.
Q. Never mind the document book. Did you ever hear of another operation called Ferdinand?
A. I can't remember it.
Q. Can you remember one called Arnim?
A. No, I don't either.
Q. Do you remember any operation in which police troops during the year 1943 carried out an operation in conjunction with the Wehrmacht?
A. I believe that something of that nature took place with a certain group, Lecimir or Kuberevci. These two names I do recall.
Q. Did your division carry out an operation in conjunction with the first Cossack Division right after the first Cossak Division arrived in Croatia?
A. I don't think so. I can't recall that ever having happened.
Q. It's still your testimony, is it, that you don't know of a single case of a reprisal measure which was ever ordered by the troops of the 173rd Infantry Reserve Division the whole time you were its divisional commander?
A. When I was in charge of the Division, yes, I do maintain that. For about three or four weeks there was a period when I was on leave. I was not present. What happened in that period, of course, I cannot say but even during that period I have been informed by my Deputy and I have not learned that in my absence anything of the kind happened.
Q. Within your corps area, General, I mean within your division area -
A. Yes.
Q. -- were you the highest German authority?
A. The German authority? Yes, the highest German authority being the commander. But after all there was the Croatian authority, Croatia being a sovereign state, so that they exercised power and I regarded myself and my troops merely as being there for the protection of the country.
Q. Was it possible for German units who were not directly subordinate to you to wander around in your corps area within your division area without your being apprised of where they were or what they were doing?
A. That was quite possible, especially seeing that the police were completely independent, and whenever a police operation was carried out, then I was not previously informed, but only when the operation started, and I had no influence whatever if I thought the operation was in expedient to stop it.
Q. Did you ever make any complaints to your Corps about activities of the police within your division area which you thought were reprehensible?
A. Yes, I did. I have done that repeatedly, I think. I cannot recall details, individual cases. Above all, I didn't like the idea of the 1st Cossak Division appearing on this scene.
Q. I am asking now about the police, not about the 1st Cossak Division.
A. Yes, as I have said, I repeatedly made complaints in writing or verbally.
Q. What were the nature of these complaints? Do you know?
A. As I have already said, they dealt mainly with the fact that I was not informed in time of these operations, that these operations were often carried out with inadequate means so that only set-back could result from them and the troops after the police withdrew only had to suffer from the consequences -- from the consequences, that is, the greater unrest of the partisans who had been touched in this operation.
Q. Well, as a result of these complaints of yours, what was done, General?
A. I don't know. I do not recall that upon my complaints any measures were taken on the part of the Corps or were carried out and I don't know any longer whether such measures were communicated to me.
Q. Where did the police in your Corps area get their ammunition from -- in your Division area, I'm sorry?
A. I can't say that. I believe and I dare day that the police obtained their ammunition that they brought them along themselves, but I cannot say with certainty.
Q. Where did they get their transports?
A. The police you mean or the Wehrmacht?
Q. Where did they get their food and supplies?
A. I don't know that either.
Q. Did you ever try by direct means to restrain the police and to change their method of operation so that it suited you?
A. I believe that I may occasionally have talked with Kamnerhofer regarding his operations, but I don't know whether that could be termed as a direct influence, or whether I had discussed it with him in that way. I really can't say that from memory. It's too long since it happened.
Q. You say that the gist of these complaints which you made to the Corps was that these police troops were constantly biting off more than they could chew, that they were attempting to do too much with too few troops -- was that the substance of it?
A. Not always. Now and then, of course, that did happen. At least that is what I meant to convey and, of course, that did happen. Sometimes I should have preferred it if they had never undertaken operations, but if they had refrained from such operations.
Q. But that was the gist of your complaints to the Corps about the police?
A. I think so, I think that was as you suggested.
MR. FULKERSEN: Take the witness.
REDIRECT EXAMINATION BY DR. GAWLIK:
Q. Witness, I shall now submit to you once again the teletype dated the 3rd of December 1943 from document book 16 on page 81 of the German version. Unfortunately, I don't know the page number of the English version. It's a teletype which the prosecution has already submitted to you before. Did you issue the order for the killing of these persons?
A. No, indubitably I haven't.
Q. In the teletype there is a mention of elements of the Pioneer Battalion. What did you understand by the term "Elements"?
A. This may refer to a Company. It may refer to two Companies. It may also refer to single groups or to Platoons, according to the purpose to which Pioneers were assigned, whether they were assigned as combat troops or for technical reasons, to build a bridge or to effect some repairs, etc.
Q. Could the leaders of these elements of the Pioneer Battalion, could they order any such reprisal measures?
A. No, in my opinion they could not. Reprisal measures would have to be ordered by the Divisional Commander.
Q. Can you comment on the question as to whether elements of the Pioneer Battalion might have ordered these reprisals?
A. Everything is possible. Everything may happen, but I suppose that it did not happen.
Q. Did the Croatians also have Panzer platoons?
A. I don't think they had a Panzer platoon, but I can't say with certainty. I only know about the German platoon which was assigned in this case.
Q. Going by this short telegram style report which I have here, can you make any statement as to the objective of the operations, especially regarding the elements of the Pioneer Battalion? Perhaps, General, could you answer first whether you can comment on that question at all?
A. That can hardly be gleaned from this short report.
Q. In the course of cross examination by the prosecution you were also shown the Army Order dated 15th of September '43. If I understood you correctly, you said that according to this Army Order it was actually within the discretion of the Divisional Commander to order reprisal measures, is that correct, General?
A. Given the condition that the prerequisites were there for taking such an action.
Q. Can you once again explain as to why, in Croatia regarding this very Army Order, conditions were very different? How can you deduce that fact?
A. The Croatian State was a Sovereign State and the German Wehrmacht partisans armed forces were there merely as a protective power for the Government, in order to protect the Government and the population against excesses on the part of the partisans etc. Consequently, it ought to be within the power of the Croatian State to order such incisive measures and to carry out such incisive measures as the killing of people.
Only in an emergency when the security of the troops required it and made it imperative would the Divisional Commander, by virtue of this order, be impowered to order these reprisal measures but as I have said, while I was in charge of my Division I never thought that there was a necessity for doing it.
Q. General, you went on to answer the question of the prosecution as to whether you were the highest German authority in the Divisional area. You affirmed that question. What did you mean by the term "highest authority"?
A. The highest Command authority, the highest Military Command.
Q. Did you also have the sole responsibility within the Divisional area over all other agencies?
A. No, certainly not.
Court No. V, Case No. VI.
Q What agencies were not subordinate to you?
AAll such agencies and commands as did not belong to the divisional troops. For instance, the police were not under my command; the Croatian authorities were not under my command and any other German civilian agencies that might have been there. I can't recall what German agencies there may have been in my then area of command.
Q Could you give orders to the German police within your divisional area?
A No.
Q Was Kammerhofer subordinate to you?
A No.
Q Were the police territorial commanders subordinate to you?
A No.
Q One witness testified before this Tribunal that the German police in Croatia was unable to do anything at all without the agreement or consent of the Wehrmacht and the Army authorities. Can you comment on that? Was that also the case in your divisional command?
A No, not at all. I have already emphasized that I was very often surprised by the appearance of the police and was frequently surprised at them but that I had no influence at all on their attitude, on their behavior and their carrying out certain measures.
Q And how was the relationship with the Croatian armed forces?
A The Croatians, the Croat elements were independent in my opinion. There was a certain liaison between me and them but there was in the main no relationship of subordination and I cannot recall exactly whether a relationship of subordination did come about in the last few weeks. I can't recall that. At any rate such subordination, if it did exist, must have been purely tactical. I had no liaison officer, no Croat liaison officer.
Q Did you have the opportunity and possibility as Divisional Commander, when you gained knowledge of the fact that the German Court No. V, Case No. VII.
police planned some kind of enterprise, and wanted to carry it out, to give an order to restrain the police from doing it?
A No, I did not have any such possibilities.
Q Could you in the carrying out of such operations by order of the police intervene in any way and in any way have any influence upon the operation?
A No, I couldn't do that either.
Q General, you were asked whether you had any complaints and whether you made such complaints to the corps about measures of the police. In order to support and refresh your memory, General, I will submit to you a document from Document Book XIV; that is page 28a. Do you now recall this incident?
A This incident happened in my absence when I was on leave but I do recall it. I certainly do recall it.
DR. GAWLIK: May it please the Tribunal, I beg the pardon of the Tribunal. It is Document NOKW-509, Exhibit 340, page 48 of the English text and page 284 of the German document book XIV.
A Of course I learned of this operation upon returning from my leave but I myself cannot comment on this affair because at that time I was not present. My Ia, Lieutenant Colonel Kaudewitz, reported to me on the details.
MR. FULKERSON: Your Honors, I thought it was unnecessary to object after the last answer.
THE PRESIDENT: There is no objection pending.
MR. FULKERSON: I object to the witness's testifying to things he was just told by someone else.
THE PRESIDENT: Am I to infer that is an objection on the basis of hearsay?
MR. FULKERSON: Yes, your Honor.
DR. GAWLIK: I am surprised that the Prosecution did raise the objection because the whole material of the Prosecution is founded on.....
Court No. V, Case No. VII.
THE PRESIDENT: Objection overruled. Proceed.
Q What do you know about this incident from your own knowledge, or rather, what did your Ia, Kaudewitz, tell you about it?
A Substantially such as is put down in this report.
Q In cross examination you were asked whether you could state any complaint of the 173rd Reserve Division to the corps regarding the behavior of the police. Can you now supplement the answer which you gave then, on the basis of this document?
A Hardly; I cannot recall details.
Q Did this incident have any reference to the complaints to the corps, complaints made by the 173rd Reserve Division about the police?
A Yes, it does.
DR. GAWLIK: Thank you. I have no further questions.
THE PRESIDENT: Are there any other defense counsel who wish to interrogate this witness? Any further examination on behalf of the Prosecution?
MR. FULKERSON: No, your Honor.
THE PRESIDENT: Any questions by members of the Tribunal?
JUDGE CARTER: No questions.
THE PRESIDENT: The witness may be excused.
MR. FENSTERMACHER: If your Honor please, in order that there will be no unclarified innuendos hanging fire with respect to the letter which the witness this morning, Willy Finger, stated that he wrote to authorities here in Nurnberg, I would like to ask that he be recalled to the stand to answer just two or three questions of mine.
THE PRESIDENT: You may do so. The only thing the Tribunal is interested in is that there be no inferences that the Tribunal had received or had written anything, that is the only thing that I was interested in or that any of the members of the Tribunal was interested in. If you care to bring him back, you may do so but, Court No. V, Case No. VII.
apparently, for the satisfaction of the Tribunal and as far as the records are concerned, I think it shows that the Tribunal never received that letter. You may do as you see fit, though.
MR. FENSTERMACHER: I would like to recall the witness to put the record entirely in order, if your Honors please.
DR. LATERNSER: May it please the Tribunal, this is not a topic for rebuttal.
MR. FENSTERMACHER: It is just to clarify, Dr. Laternser, one of your usual unfounded insinuations.
WILLY FINGER - Resumed CROSS EXAMINATION BY MR. FENSTERMACHER:
Q Mr. Finger, I would like to show you this document and ask you to identify it, please.
A Yes, that is my letter.
Q It is in your handwriting and your signature.
A Yes, it is.
Q To whom did you address that letter?
A I addressed this letter, as is written thereon, to the Evidence Division, Nurnberg.
Q Was that the address also on the envelope of the letter?
A The same address was also on the envelope.
Q Is that the first letter you ever wrote to any authorities here in Nurnberg?
A Certainly, that was the first letter which I sent here.
Q Did you get a reply to that letter?
A I did receive a reply to this letter.
Q And by whom was the reply to your letter signed?
A This letter bore the signature of Mr. Kauffmann.
Q Did you have additional communications with Mr. Kauffmann after that time?
A We exchanged a few more letters and then I was once near Court No. V, Case No. VII.
Nurnberg; it was when I was in Regensburg. I communicated that fact to Mr. Kauffmann. Mr. Kauffmann told me to call on him.
MR. FENSTERMACHER: I think that clarifies the matter for the record, your Honors.
THE PRESIDENT: The witness may be excused.
MR. FENSTERMACHER: If your Honors please, the Prosecution would now like to offer an additional rebuttal document. I just want to recall that during the cross examination of the defendant Speidel there was discussion of the relationship between the military commander in Serbia, General Felber, and the higher police and SS leader in Serbia, Meyssner, and there was discussed with General Speidel the matter of Felber giving orders to the higher SS and police leader in Serbia for the carrying out of reprisal measures.
At that time the defendant Speidel stated that the subordination -- that is, the relationship between himself as military commander Greece and the Higher SS and Police leader in Greece -was something contrary to the ordinary type of subordination of police leaders.
That statement of his appears on page 7783 of the English transcript.
In the course of the further cross examination he stated that in effect the relationship between Felber and Meyssner in Serbia was different from the relationship between himself and Schimana in Greece.
In Weichs Document Book No. I, which, of course, was not offered or received into evidence, there is, as Weichs Document No. 671, service instructions for the military commander Southeast dated 7 October 1943.
THE PRESIDENT: Pardon me, Mr. Fenstermacher; we will take our afternoon recess at this time.
Court No. V, Case No. VII.
THE MARSHAL: The Tribunal will be in recess until fifteenfifteen.
(A recess was taken.)
THE MARSHAL: All persons in the Courtroom, be seated, please.
The Tribunal is again in session.
DR. LATERNSER: If it please the Tribunal, briefly before the recess I heard to my intense surprise that the Prosecution is using a Document Book which I compiled in my capacity as Defense Counsel for Field Marshall von Weichs, submitted, but did not use. By referring to the rule which the Prosecution upheld when distributing documents which they later didn't use and which they asked to be given back to them, I would like to make the same request -- that is, to hand the book back and not use any of it in evidence.
MR. FENSTERMACHER: Your Honor, the document in question is one of the documents which came from Washington and was made available to the Defense. I didn't know about it until the other day, when I happened to be glancing through the Defense Document Books. I take it, however, that the Document itself is entirely in order, because it is included in Weichs Document Book Number 1. In the first page in this Document Book is a certificate by Dr. Laternser that the documents contained in the Document Book are true copies of the original. I see, therefore, no objection to offering the document into evidence.
DR. LATERNSER: If the Tribunal please, where this document originated from, I can not state at the moment, much as I would like to. At any rate, the Prosecution is not entitled to use documents now which I have not used and I ask for the Document Book to be returned to me from the Prosecution since the same was done in similar cases, and we have in all cases handed it back to them and returned it to them, and we ask that the Prosecution return to us the Document Book in question.
THE PRESIDING JUDGE: Dr. Laternser is a little bit too late. Now that I have seen the documents, I take it that the various -- these various documents have been with the Translation Section in order to be translated, the document was at one time in existence, and I take it also that by virtue of the certificate which Dr. Laternser has attached to the Document Book that the two or three mimeographed sheets in the Document Book are exact and complete translations of the original document.
Just because Dr. Laternser happened to find the document out of the batch of documents that came from Washington, I submit, has nothing to do with whether he is the only one entitled to use it.
DR. LATERNSER: That was purely an allegation by Mr. Fenstermacher that I found this document among the Washington documents. That is merely his assertion. I can not make any statement to that effect now. I could only do that if I would be allowed to look into that; then I can say whether it is an original document which was prepared in Washington or not. I think that if we observe the rule which the Prosecution asks us to observe, then they will have to return the Document Book back to me, and the material included in it. At this moment -
MR. FENSTERMACHER: Well, I assume that Dr. Laternser would not be asked to certify that document if the original is not in existence. It was at one time in existence, I am sure, but if it has become lost, then I certainly maintain that he would be allowed to offer it in evidence on behalf of his certificate.
DR. LATERNSER: If the Tribunal please, I don't think the original got lost. I think the exhibit exists. That is also an assertion by Mr. Fenstermacher.
THE PRESIDING JUDGE: Have you got the actual exhibit, Dr. Laternser? The exhibit which is the basis for Weichs Document Number 671?
DR. LATERNSER: I assume for certain that I have the original exhibit, but I see no cause to hand it to the Prosecution. But that is even going one step further than what I asked. I merely asked that the Prosecution observe the same procedure that we have been asked to observe in turn. That is, to hand back those documents which the Prosecution have not used but distributed to us, and I insist that the same procedure be observed by the Prosecution as is observed by us.
MR. FENSTERMACHER: If Your Honors please, this is a very important piece of evidence in connection with the acts committed by the defendant Speidel and I see no reason why it shouldn't be offered in evidence in the interest of truth, no matter who happened to find it or get original possession of it first.
DR. LATERNSER: I presume that the Prosecution has in the hands a number of -- a great number of very important documents for us, the existence of which is not known to us. I ask the Prosecution to observe the same towards us that they ask us to observe towards them. I therefore ask them to hand back to me that particular document book.
MR. FENSTERMACHER: Your Honor --
THE PRESIDENT: Just a minute, please. Somewhere along this circuitous route there must be a stopping place. Now, I take it that both you gentlemen have to a reasonable extent expressed yourselves on the matter.
MR. FENSTERMACHER: I just have one more thing to add, your Honor. There is a remedy. In the event the prosecution has some documents which the Defense would like to have possession of, and I assume there is a parallel remedy for us. I found that remedy two days when I called the Defense Information Center and inquired about this document and I learned then that a procedure had been withdrawn. I learned then that the matter had been taken up with Dr. Laternser and he made a reply to the effect that either he didn't know where it was or he didn't want to give it up. That is a vague recollection that I have of the answer I got from the Defense Information Center. Now, I would ask then that the Court grant the application on behalf of the prosecution to make Dr. Laternser give us the original document. But, because there was a certificate of Dr. Laternser in this Document Book which contains this document, I assumed that it would not be necessary and there would not be any quarrel about the mimeographed pieces of paper being a true translation of the original document.
DR. LATERNSER: If your Honor please, may I add something? Of course, I have been asked, and to that extent Mr. Fenstermacher is correct-I have been asked if I did put a document at the disposal of the Prosecution.
My answer, of course, was to deny that. After all, as Defense Counsel, it is not my task to hand over material to the Prosecution. I shall only do that if a ruling to that effect exists. I refuse now, as then, to hand over any document, and I am asking for the documents to be returned to us.
THE PRESIDING JUDGE: I think that both of you gentlemen have expressed yourselves sufficiently, and to give the court an opportunity to rule at this time would not be out of place. No piece of evidence, if it is competent, is the sole possession of any one individual, of either the Prosecution or the Defense. The Tribunal is interested in getting to the truth of those matters which are before this Tribunal. If there is any question as to this copy, some procedure may be necessary in order to obtain it -- in order to obtain the original. The document, in such form as it may be presented, will be considered by the Tribunal, and the objection as made by Dr. Laternser will be overruled. As to whether or not the copy will be admitted will be a matter which will be taken up next, if necessary.
DR. WEISGERBER: Dr. Weisgerber for General Speidel.
If the Tribunal please, I also object against the introduction of a copy of a document, the copy of which is contained in Weichs Document Book I. I believe I have a claim to see at least a photostat of that document. Up till now, that has been the procedure and I see no cause why in this particular case that rule should not be observed. The reason given by Mr. Fenstermacher that the copy as contained in Document Book Weichs I which has not been submitted, has been certified by Dr. Laternser. This indication is by no means sufficient. In many instances we have had the experience that on photostat and original documents there were extremely important notes in handwriting or initial which the copies as contained in the Document Books did not show.
THE PRESIDENT: Your objection will be sustained, Dr. Weisgerber. Dr. Laternser, do you know where the document is?
Did you understand my question?
DR. LATERNSER: Yes, your Honor. Yes, I know where the document is.
THE PRESIDENT: Could you present it to the Tribunal? And would you?
DR. LATERNSER: If the Court orders me to do so, then I shall do it.
THE PRESIDENT: The court request you to do it.
Dr. LATERNSER: If your Honors please, it is a difficult situation in which I find myself. Voluntarily as Defense Counsel I can never hand any material to the Prosecution which incriminates any one of the defendants. In that case I would violate the duties of Defense Counsel. That is my point.
THE PRESIDENT: In order to protect you, Dr. Laternser, that you are not violating any professional obligation on your part, I will change the nature of my statement and make it as the order of the Tribunal.
DR. LATERNSER: Yes, your Honor.
THE PRESIDENT: I was endeavoring to couch my words in a manner which would not seem arbitrary.
MR. FENSTERMACHER: May I offer this document now, your Honor, or would it be better to wait until Dr. Laternser actually brings it in?
THE PRESIDENT: Dr. Weisgerber has made an objection which has been sustained as to the copy. If you will present -- if you will get the document, Dr. Laternser, if you don't have it here.
Well, if you will get it, please.
If we could pass on to some other matter while we are waiting for it, please.
MR. FENSTERMACHER: Yes, your Honor. The Prosecution has made two additional lists which I hope will not be objected to, because they are simply an index to the transcript, the English transcript, with respect to the dates on which certain of the Prosecution witnesses have testified and the page in the transcript; and the second list is the page on which witnesses ordered on behalf of the Defense testified and the corresponding page in the English transcript. These lists are not in evidence. They are simply for the convenience of the Tribunal in finding material in the transcript. The first list we offer is a list of the Prosecution witnesses, the date on which they appeared, and the corresponding page in the transcript. For purposes of identification, they should be marked Exhibit 675. The second list is with respect to witnesses which appeared on behalf of the Defense, the date on which they appeared, and the corresponding page of the transcript. This list should be marked Exhibit 676.
THE PRESIDENT: May I inquire as to whether or not a similar document is -- I take it from what I observed now that a similar document is being furnished the Defense Counsel with reference to the German transcript?
MR. FENSTERMACHER: No, your Honor, we didn't feel it incumbent on us to index the transcript for them. We only did it for the convenience of ourselves and the Tribunal with respect to the English transcript.
THE PRESIDENT: Very well.
MR. FULKERSON: I would like to request the Tribunal to call the Affiant Hans von Selchow, who is, I believe, here now.
This affiant's affidavit appears in Dehner Document Book V, page 73, as Document Number 27. I believe it was also introduced as Exhibit 27, wasn't it, Dr. Gawlik?
HANS VON SELCHOW, a witness, took the stand and testified as follows:
THE PRESIDENT: The witness will raise his right hand and be sworn.
I swear by God, the Almighty and Omniscient, that I will speak the pure truth and will withhold and add nothing.
(The witness repeated the oath.)
THE PRESIDENT: You may be seated.
Will you repeat again the page, document, and exhibit?
MR. FULKERSON: It is Dehner Document Book V, Exhibit 27, and Document 27, on page 73.
CROSS-EXAMINATION BY MR. FULKERSON:
Q. Please give your name, birth date and birthplace.
A. Hans Harold von Selchow, born in Leobschuetz, Upper Silesia, on the 17th of April 1894.
Q. What is your profession, please, sir?
A. I was a farmer.
Q. What did you do during the war?
A. At the beginning of the war I was IIa with a Division and later I was with Army Busch; then in Brussels with an Administrative SubArea Headquarters; and later on I was in Zagreb with the German Plenipotentiary General.
Q. According to your affidavit, I notice you say you were the Chief of Staff with the German Plenipotentiary General for Croatia is that right?
A. Yes.
Q. What did this Staff do, Colonel?