That was our ruling, and that an affidavit was to be submitted signed by this witness in lieu of further oral testimony.
MR. MC HANEY: Of course that is quite satisfactory with the prosecution, but I was under the impression that Dr. Seidl for one was of the opinion that the Tribunal was ruling that no crime had been committed with respect to the experiment, and hence he was no longer interested in it. Now, I just would like for the record to be clear, that is not the case, and then he can do what he will with what witnesses he has, or what other proof he has.
THE PRESIDENT: Sir, we didn't close the door on the prosecution making a further showing by any evidence available as to criminal food experiments.
MR. MC HANEY: Well, that is true, of course, Your Honor, and we perhaps shall have additional evidence to submit. I have in mind one particular document.
THE PRESIDENT: I don't know why it didn't go into your main case if it is proof of the res gestae.
MR. MC HANEY: Well, it didn't because we couldn't locate it at that time.
THE PRESIDENT: Of course, we have had twenty documents submitted here on cross-examination, which, we suppose, were for the purpose either of impeachment or refreshing the witness's recollection. When the documents came in, they did neither. They were simply cumulative evidence which might have been a part of the prosecution's case in chief. They were admitted without objection, however.
MR. MC HANEY: Well, the only point I wish to make clear is that the prosecution felt compelled to rise and make the remarks which I have made because we didn't want any misunderstanding or any feeling on the part of defense counsel of surprise or anything of that nature at a later stage.
THE PRESIDENT: The Tribunal's comment, which did not amount to a ruling, was clear and explicit, and I don't think is subject to any misunderstanding if carefully read by either prosecution or defense.
MR. MC HANEY: Very well, Your Honor.
DR. MAYER: May I continue, Your Honor?
BY DR. MAYER:
Q. Witness, you concluded by saying that when you reported to the office construction you found Dr. Kammler there, to your surprise. What was it that took place when you reported to Dr. Kammler on orders?
A. When I reported to Dr. Kammler, I first had a long conference with him. Dr. Kammler informed me that he had not resigned from the Luftwaffe himself. He then spoke about his conference with the personnel office, and that he found out that I had been drafted into the army, and that therefore I was no longer in the construction administration of the Luftwaffe, whereupon he immediately contacted the personnel office of the army, and after several difficulties he finally succeeded in getting the idea through that I didn't go through my apprenticeship in the army, but rather in the Waffen-SS, and that thus he had been given an opportunity to win me for his technical service of the WaffenSS, and to have me transferred to that service.
He further stated that in the summer of 1941 he received the order from the Reichsfuehrer, Himmler, to have a construction administrative office of its own for the Waffen-SS, to be sure a construction administration be built up on the example of other army branches, that is, army, navy, and air force. For that reason he needed specialists or experts, and that was the reason why he selected me. I had experience in that field. That was the reason why he had me transferred to the Waffen-SS. He furthermore informed me there was no regulation pertaining to employees in the Waffen-SS, and that he would apply to the Construction Council that I should be promoted to a Sturmbannfuehrer. That is a rank in the Waffen-SS.
In the course of that conference the following agreement was reached: The service with the construction administrative service of the Waffen-SS was to be limited to the duration of the war. My pay with the Waffen-SS was to be the same as with the Reich Air Ministry. The tasks which I had in the administrative office of the SS should at least mainly be the same as in the Luftwaffe. On the basis of the fact that they wanted to have a clear distinction between the two fields of task of mine, Dr. Kammler told me to carry out the dwelling construction and the preservation of cultural monuments after the war. Those were the same tasks as those I had with the Reich Air Ministry. He furthermore gave me the task to plan the construction of hospitals of the Waffen-SS.
Court No. II, Case No. 4.
Then the following thing was discussed. My main office, which at the time was no real office, was to be incorporated into an office which already existed: Napola, the national school. The Reich Education Minister and the Reich Treasurer were responsible for those two tasks. That is why Dr. Kammler wanted to supervise those two departments himself. He told me that was just a formal subordination because he had to put that department somewhere. In other words, I had as my main tasks within the framework of the new construction administrative office of the Waffen-SS for construction tasks, the regulations and the construction technicalities. That is, technically speaking, the observance of cubic footage for those constructions.
Q You were just speaking, witness, about dwelling and dwelling settlement construction after the war. Do you mean the preparation of those two, dwelling and settlements after the war?
A Yes. It dealt with the program which I already mentioned when I spoke of my activity with the Luftwaffe, the preparation of the dwelling and settlement program after the war according to the Fuehrer Order of September 1940.
Q You mentioned the observance of cubic footage, and the space rate. What do you mean by that?
A I would like to tell you in a few words, however, I think it rather important to give you a somewhat clearer description of it all because I believe that I was able to find out when I was interrogated that there can easily occur misunderstandings, and that, therefore, it isn't too simple to speak to a layman about such technical construction matters. I would like to say that right in this particular point that rate here means "permissible". Observance of cubic footage or space rate means a list about the space permissible for a building, for a construction project. It was to be understood thus, that in every branch of the Wehrmacht, the Main Administrative Office of the Wehrmacht, there were all sorts of construction projects. One of the regulations was which contained exact descriptions: what Court No. II, Case No. 4.kind of building this might have been, and that, according to the Reich Finance Ministry regulations, what rooms were to be contained in every one of those buildings.
And, also, of what size these individual rooms were to be. That regulation's name was Raumgebuehr, or space rate. The layman thinks the whole thing isn't very important. However, for all Wehrmacht construction administrations, and also for the Reich Construction Administration itself, this was the basis for the entire construction, particularly within the framework of the blocked budget during peacetime.
It can be understood that this space rate is a construction program which had been approved by the Reich Finance Ministry. That is, when all those construction projects are set up in the budget and they are to be approved, and if they have been planned according to the space rate, then, so to speak, there is already a permission of the Reich Finance Ministry-
THE PRESIDENT: We will have to make this more brief. For better than seven minutes now we have been having a definition of the words "minimum cubic footage" which we understood before the witness started. Let us get down to his connection with the things that are mentioned in the indictment as soon as you can.
DR. MAYER: May it please Your Honor, I agree with you. However, may I point out briefly that the statement concerning this space rate and the plans and framework and the observance of cubic footage are important because that actually mentions the main activity of the defendant. That is the reason why, in my opinion, it was necessary to give a clearer picture to this Tribunal what took up the time and the activity of the defendant in case it should show later on that he actually participated in those incriminating matters--or rather that he did not participate in those incriminating matters, and that he could know anything about them.
BY DR. MAYER:
Q Witness, I would like to ask you now very briefly about the Court No. II, Case No. 4.plans for framework and I would like to ask you in what connection they are with the observance of cubic footage or with space rate.
But I only want you to answer all those questions to a very small extent in order to show what your activity was.
A I shall try to be as brief as possible about the term "plans for framework". However, I would like to point out to the Tribunal that if someone looks through my affidavit, it becomes rather unclear as to what my activity really was.
Plans for framework and plans for construction are two entirely different things. According to the construction planning, you can build; according to the plans for framework, you cannot build, however.
On the construction site itself you cannot build according to those plans.
I would like to give an example here. For instance, you have the plans for framework for a house.
Those are just diagrams with numerous red, blue and colored lines. It is known that in the case of a chart of a sick person, you can see, when the patient went to hospital, when he was accepted there, and when he was released. You have various lines which go through those lines. You can see the medical treatment, care and clothing.
From all those lines you can see, among other things, that the lines of the average patient do not cross the lines of the sick who have an infectious disease. For the expert, the idea is to make the lines and to plan them in such a way that no misunderstandings can occur. In other words, it doesn't contain technical details or actual work as used by the carpenter on the site. It just deals with technical and administrative matters -
THE PRESIDENT: Now, if you just tell us that there is a difference between working plans and preliminary sketches we would know the whole story, and he need not bother about infectious diseases or anything of that kind. We know that when you start you make pre Court No. II, Case No. 4.liminary sketches, and then the architect makes the working plans.
DR. MAYER: The difference which is to be proved is that there is a space rate and also plans for framework, and you have got to differentiate between the two because you can't use either of them for a construction. Those plans that can be used for the construction were not completed by the defendant. That kind of planning and the execution of the construction was with other agencies than with the defendant. When this difference becomes clear, I will be able to continue.
THE PRESIDENT: All right.
BY DR. MAYER:
Q Witness, did the field of task--as you described it during your field of activity with Amtsgruppe C--change in any way?
A Yes, twice. The first time when, in 1942, the business plan of the Main Office appeared: construction and budget. That was my main department so far called Amt, or office, and I myself was the office chief, although I was not accepted as such until the very end. New fields of tasks had been added. The main department C-2-1, Ammunition; C-2, was the thing that I just said; C-2-1 was Clothing Department; C-2-2 was Ammunitions, Weapons and Communications. And the rural settlement so far was considered Economic and Special Constructions at the time.
However, those things were rectified a little while later, and they appeared in this organizational chart here as C-2-6. That is, Special Construction Work. There was a second change towards the end of 1942. The Department Napola and National Schools were transferred to Office C-4. At the same time the man in charge of that department took it over. That is Hauptsturmfuehrer Dr. Vier. And instead of that main department, Napola and National Political School Homestead Construction were interchanged.
Q The change, however, could only be seen in those outside symptoms--or was it really that your activity as such also change?
That is, as far as setting up the plans is concerned?
A No; that remained about the same.
Q Did your rank in the course of years change?
A Yes. On the 30th of January 1944 I was promoted to Obersturmbannfuehrer.
Q What was the rank, the official rank that the rank of an Obersturmbannfuehrer corresponded to in the army?
A Sturmbannfuehrer in the construction and administration of the army is a Baurat with the rank of major, and Obersturmbannfuehrer corresponds to chief construction counsellor with the rank of Lieutenant Colonel.
Q Witness, I shall now come to your fields of tasks individually, and I want you to take a look at Document Book No. 2, Document 1288, Exhibit No. 44. This can be found on page 76 of the English and page 82 of the German Document Book. It deals with the organizational chart of Amtsgruppe C of the WVHA of the first of January 1943.
Q. On page 12 of the German text you will find it in your book and it is also on page 5 of the English copy, under the title of Office Construction 2, Special Construction Tasks -- what was the meaning of that term, the title of your field of tasks?
A. May I say in advance that the term used there on the wall which speaks of construction tasks does not quite correspond to what is contained in the English document book, NO-498, Exhibit Number 47 in Document Book Number II, "Special building matters." I don't understand English myself well; and therefore I can't tell if the two terms actually mean the same or if they mean something different. But at least I just wanted to point it out.
As far as special constructions and the term are concerned, I can say the following. In the field of construction exactly as in all the other fields of free enterprise, a specialization expert appeared in the last ten years just as in any other professional special field. That is to say, construction of cities, construction of dams, and much more can be seen there. That special training started in the technical high schools; and the people who had been trained that way were used with special groups of city planning and state planning offices. Dr. Kammler also comprised such large series of fields of tasks as special tasks.
The plan was taken over by the Luftwaffe because there were two such departments in the Reich Air Ministry. There was the Hochbau Department Number 2; and you have there those special tasks which I have already mentioned when I spoke about my activities in the Reich Air Ministry, the chief of which was Dr. Kammler. Under special construction tasks, this plan is just like in the Amtsgruppe C, Office C II, for instance, where all the various special fields of construction are contained.
Q. Further down in the same page you will also find a department C II ZBV. What were the tasks you understood under C II ZBV?
A. The ZV Department, as can be seen in the back, is strictly police matters and construction.
It dealt with the various construction codes of the counties. Every county, every president of a county had its own code of construction. That's the way it was in Germany. There were various regulations, particularly for those people who were working here today and somewhere else tomorrow. It was absolutely impossible to find your way through this muddle of regulations. It was very hampering when carrying out the construction permission. That was the reason why I had the task under this Department CV to compile the various regulations according to the alphabet or according to abbreviations, so that they could be used by the various construction departments for their guidance.
At the same time, however, this compilation was to be used as a basis of the negotiations which had been prepared for after the war concerning a new construction law or construction code; and in this main department in 1943, in collaboration there, they tried to procure two trade transfers to the Waffen SS. There was one in Guden and one in Goenitz in Western Prussia. I had to carry out the negotiations with the office for space in the Reich, which was competent, according to the regulations, as to which office would then get the approval from certain ministries in order to be able to carry out the construction. This was the procedure of the so-called Auslegungsverfahren founded for the parade grounds for the army.
I received another task that I carried out in 1944 or 1945, in June or July. I received the order actually to teach in that particular SS school in Arolsen and in that leadership school about construction work. That was the work which took up my time from July 1944 with very short interruptions up to the bitter end in 1945.
Q. Before you speak about the sub-departments in your office, I should like to point out to you that it can be seen from the organizational chart that in all sub-departments of your Office C II it is repeatedly, "Auditing of the construction planning," and "Auditing of the Preliminary Sketches". Therefore, I should like to ask you if you had anything to do with the checking of the construction projects as such; or what can be understood?
A. In this Main Department with auditing of the Construction planning and also setting up of preliminary sketches, it is also stated that the plans for framework should be preserved in building regulations. That was the thing which I mentioned before. I should like to state the following about this; that this document, if it were to be used as a basis was not present at the time when the SS established that office. It was a task, actually a task in itself to set it up. As far as the estimates were concerned, estimates were not made for the duration of the open budget during the war. It was a peacetime matter, a peacetime budget. It can also be seen from this organizational chart that in this department in the examination of the estimates there were certain vacancies and furthermore that no such plans had been taken into consideration.
Q. Would you tell us about all the other departments contained in this organizational chart or all the other departments from your Department C II and add how and how far these fields of tasks were dealt with here? What did the title mean over those sub-departments, for instance C II/1? What did it mean, "Supply and Clothing Department"? What was your task there?
A. My task was to carry out the basic planning for a clothing office of the Waffen SS just according to the example of all the other SS agencies. When I got there and joined that office, I found a project which was ready, a project dealing with the construction of a clothing office for the Waffen SS. It had ceased during the war; and I was ordered by Dr. Kammler to complete it, that is, to complete the plans for the framework, and also was ordered not to forget the space rate and all those other things that play a certain part in it.
However, the work was already started in 1942 upon Dr. Kammler's orders. He stated as the reason that according to the air-raids all the bases for such construction projects were changed and other principles and other regulations were to be used after the war if the whole thing should be destroyed.
In the field of food it was in the following way. When I was working in the construction administration, I received the order to set up those plants. They gave them to me in 1942. They received a special rate according to the architect's rate; and I carried out the planning. Space rate was set up; and thus I had completed my job. It was then in 1942, towards the end of 19421943, that the work in the Main Department C II/1 was completed as such.
I should like to refer to the personnel structure of that Main Department, which speaks for itself. While we are speaking of one chief and two collaborators, including a man who drafts the plans, according to the personnel strength, not very much could have happened in such an office.
Q. Under C II/2, you will find Arms, Ammunition, and Communications. Would you tell me what the connection was among all of them?
A. In those three departments which I just mentioned, the communications department could have been eliminated ever since the beginning because it was not dealt with since in the operational main office those things were dealt with in a special, technical department. Communication constructions were not dealt with during the war in this office. Arms and ammunitions constructions were dealt with in their bases, that is to say, we can point out all the regulations of the counties and of the cities concerning the Luftwaffe and particularly concerning the precautions to be taken when building such constructions, dealing with constructions now taken care of in our department upon Dr. Kammler's order.
The Main Department Chief is the same Main Department Chief whom I mentioned before, Froese. At the same time he was in charge of all the departments and only one expert, a technical expert drawing the plans, is also contained as a collaborator. I believe that also speaks for itself and for the work that was not carried out by that department.
Toward the end of 1942, I suggested to Dr. Kammler the dissolution of those two main offices. Dr. Kammler did not agree with my proposal by saying that on the basis of that organizational chart which had been approved by the Reichsfuehrer, dated March 1942, there was no working plan. It was a competency defined by the Reichsfuehrer in the field of construction. He told me at that time explicitly even if the military situation should compel us to include all the various departments into one main department, nothing in his competence would change; therefore, nothing would change according to that organizational chart. The main departments, therefore, had to exist at least formally on paper until the end of the war without anything of importance actually occurring there.
Q. From document Book 12, please take Document 3032, Exhibit Number 329. It is on page 11 of the German Document Book. Unfortunately, I could not find out the page of the English Document Book.
THE PRESIDENT: Seven.
Q. Thank you. It is a letter by Pohl to the Reichsfuehrer-SS. It is dated 1942. It concerns the construction of a rifle factory. I ask you now, witness, did you in any way participate in that project?
A. No.
Q. Would such a project have been constructed by C II/2?
A. No. The project was unknown to me at the time. And the letter is also unknown to me. It contains a file note of Office C-V. That is the file note of Dr. Kammler personally. A rifle factory does not come under the Department of Arms and Ammunition of the Waffen-SS and it stated under Paragraph 2 that the planning will be carried out by the firm itself.
Q. Now, then, coming back to the Main Department D II/3, hospitals and dispensaries, what waste be done there.
A. I would like to tell you here that the word hospital must not be misunderstood. It can be considered only for the Army.
It is an Army hospital. You have a hospital which can be considered a hospital for civilians, for communities in the cities, then you have the clinics for the universities. The way I mean it, it is more of a station hospital or field hospital for the Armies. When you speak of a Laxarett in Germany, you just mean a hospital for the Army. I understood from the documents submitted by the Prosecution that the hospitals in the concentration camps were not called hospitals. They were called sick bays or sick barracks. That is not only in connection with the term as such, but according to my opinion, it is also in connection with the fact that various and different regulations esisted for both installations, that is the civilian hospital and the Army hospital. On the one hand you have the Army Administration and on the other hand the Justice Administration.
My task was to carry out the planning for the construction of hospitals for the Luftwaffe. Every branch of the Wehrmacht had those regulations. For instance, the administration of the Waffen-SS did not have that at the time. Therefore, it had to be set up at first. I received the order to work out the plans for the following hospital installations of the Waffen-SS:
First of all, war hospitals, hospitals with 150 beds, 300 beds, 400 beds, and 1,000 beds; In other words, four types of hospitals. In peacetime, 300 beds, 400 beds, and also hospitals for special purposes. Those were the tasks that were dealt with by me.
The work in April 1945 had not been completed as yet. The main reason for that were bombing raids. The attacks on the WVHA, which housed part of the basic documents which had been worked out, destroyed these, and we had to start all over again.
Here also, the Main Department C-II 3, according to the tasks on the ministerial level, the construction plants as I said before were carried out in the following way: By using the plants for framework and service of cubic footage and space rate.
There was a difference made. In 1942 I received the order to construct on the site of the University of Wuerzburg, a hospital department for people who had been wounded in the brain or spinal cord. That project was so different from all the other construction projects that Dr. Kammler did not transfer the planning of the construction to the medium level, but he transferred that task to Office C II. That was the only construction planning which was set up by C II. Otherwise, C-II only took care of plants for the framework.
Q. Under plans for framework for hospitals and dispensaries or experimental stations for concentration camps in connection with that?
I would like to read to you from Document Book No. 9, Document 987, Exhibit No. 223. This is contained on Page 42 of the English and Page 45 of the German Document Book. It is a letter from the Chief of the Ahnenerbe, and it deals with experiments or rather war scientific research in connection with the Concentration Camp Natzweiler. What do you have to say about that. Did your office have any connection with that?
A. No. In Office C-II, I never drew up plans for Concentration camps or any concentration camp installation. Office C-II only dealt with matters pertaining to the Armies. Construction of concentration camps were in a different office. They had been compiled there. As far as the document is concerned, I would like to say that under Paragraph 5 on Page 2 of the document, under the construction department, Natzweiler is also mentioned. From the point of view of size, this is only an object which is a small size. It will be taken care of by a construction department and not by us.
Q. Furthermore, I would like to show you from document Book 9, Document No. NO-265, Exhibit No. 219, which is contained on Page 7 of both the English and German Document Books, a document which contains the diary for virus and typhus research of the Hygienic Institute of the Waffen-SS.
On Page 4 of this document, the English Copy, the establishment of a hospital in Buchenwald is mentioned. That is a stone building. I ask you, now, witness did that field of task in any way relate to your field of task?
A. No. This was not to be a hospital. The hospital was not for the Army, but it was for the inmates. Apart from that, the Defendant Pohl declared here in the witness dock that the order was not given at all. Should it have been given, and should it have been executed, it would have been the task of the construction inspectorate. That is also correct according to the regulations concerning those matters.
Q. Before I turn to the following department, I would like to ask Your Honors if you do not think this is an opportune moment to have the recess.
THE PRESIDENT: I quite agree with you. We will resume tomorrow morning at 9:30.
THE MARSHAL: The Tribunal is in recess until 9:30 tomorrow morning.
(The Tribunal recessed at 16:30 to reconvene, 25 June 1947 at 0930 hours.)
Official Transcript of the American Military Tribunal in the matter of the United States of America against Oswald Pohl, et al., defendants, sitting at Nurnberg, Germany on 25 June 1947, 0945-1630, Justice Toms presiding.
THE MARSHAL: Persons in the courtroom will find their seats.
The Honorable, the Judges of Military Tribunal No. 2.
Military Tribunal No. 2 is now in Session. God save the United States of America and this honorable Tribunal.
There will be order in the Court.
MAX KIEFER*--Resumed DIRECT EXAMINATION --Continued
DR. MAYER (Counsel for the defendant Max Kiefer): Your Honor, I can continue if you wish. Yesterday we stopped while discussing Document 1288 from Document Book No. 2, Exhibit 44. We discussed the main departments of Office C-2 and, to be exact, the installations for feeding and clothing, weapons and munitions, and communications installations, hospitals and dispensaries.
I shall now proceed to the Main Department C-2-4, Industrial and Economic Constructions.
BY DR. MAYER:
Q. Witness, may I remind you again to please speak into the microphone; speak clearly and distinctly and, this above all, pronounce your special terms slowly so that the interpretation can follow.
THE PRESIDENT: May I add something on behalf of the interpreters? A good many technical, special terms are being used which are difficult to translate, and will you please not hurry either the question or the answer. Take it a little more slowly so that the interpreters can give a little thought to these special words and terms. Just take it a little more slowly, please, both questions and answers.
DR. MAYER: Thank you very much, Your Honor, and we shall certainly comply with it.
WITNESS: May I tell you that I can't hear very well. I can hardly understand anything at all with my earphones.
DR. MAYER: The witness just said, Your Honor, that he doesn't understand very well.
THE PRESIDENT: Test his earphones.
BY DR. MAYER:
Q. Witness, I would now like to ask you which plans you carried out in the Main Department C-2-4?
A. In the organizational chart it says here Industrial and Economic Constructions as one single term. The Industrial Constructions can be considered as big constructions and the Economic Constructions can be considered medium and small constructions, that is small work shops, as they are necessary for the economic life of settlements. That is the reason why they are compiled here into one single task in that department, namely to carry out those industrial and economic constructions. That field of task--Industrial and Economic Constructions toward the end of 1942 was added instead of the main department Napolas and schools.
It could be seen from advance what the tasks were that were to be dealt with. In this connection I would like to refer to the personnel strength of that main department--which actually amounted to just one person: the chief of that main department was Birkicht, and the chief of all three departments was the same person.
I would like to add here that this man, Untersturmfuehrer Birkicht was a specialist in the construction of hospitals and almost his entire activity and time in Office C-2 was used in the construction of hospitals. Early in 1943, when the civilian construction manager, Georgi, who was in charge of that main department hospital construction, resigned, the man I mentioned before took over that department. In the main department only one project was dealt with; that was in 1943. I received the order to make the preliminary sketches for a large construction which was to manufacture dehydrated egg powder and dried vo getables for the army.
That planning, however, was stopped upon Dr. Kammler's orders prior to completion because, as he said, the economic prerequisites for such at construction were not there. By economic constructions, and in this connection with the chief of the labor chamber, certain settlements were planned for after the war. However, those tasks also were stopped towards the middle of 1943 as it could be seen at the time that the construction of settlements and dwellings probably were not an urgent task due to the war situation at the time. Those were the tasks which were dealt with by Office C-2-4, and actually dealt with actively by that office.
Q. Witness, from Document Book No. 11, please take Document NI-034, Exhibit 297. It deals with the affidavit of Ferdinand Rudolf Hoess and is dated the 21st of May, 1946. A series of industrial constructions are mentioned here.
I would like to ask you if you participated in any of those in any way?
A. Actually, the affidavit speaks for itself. I would, therefore, prefer not to repeat several things contained in that affidavit. However, I would only like to point to page 6 of the document where it is stated--it is on page four of the English, really; I shall quote "Shortly after that the concentration camp of Auschwitz was visited by a commission of the I. G. Farben, which commission had plans for the construction of the Buna factory."
Similar statements about the independent working-out and execution of the industrial construction works in Auschwitz is dealt with on page 8 and 12 of this document.
Q. It is on page 7 of the English.
A. --Office C-2 had no connection whatsoever with any of this work.
Q. Within the framework of that field, did you draw any plans for Amtsgruppe W?
A. No, never.
Q. Take Document Book No. 16--take a look at Document 1032, Exhibit 427. It is on page 1 of the English, and it is on page 1 of the German text. It contains a list of all the privileges which the DEST received on the basis of their special position in the economy. I would like to ask you with reference to that: who was it that actually planned the construction of the W factories? Who drew the plans; who carried it out, and who maintained those plans?
A. I have no knowledge of my own concerning that. Those things had no connection with the work dealt with by Office C-2. However, on page 12 and on page 13 of this document.-
Q. Sixteen and 17 of the English-
A. I can see from this document here that the DEST (The German Earth and Stone Works) had a construction office of their own for the clinker works; and they had a special construction office for granite where the supervision of the planning calculations, and maintenance of the buildings was carried out. C-2 had no connection whatso ever with those construction offices; as I said before, I had no knowledge at the time of the existence of those construction offices.
Q. I shall now come to the following main department: the Main Department C-2-5, which is the maintenance of buildings. What were the tasks which you dealt with in that main department, and particularly did you use any inmates--or how was this construction carried out?
A. In Office C-2 no constructions were carried out. The knowledge of labor assignment of inmates couldn't possible be derived in that main department C as far as the other tasks were concerned herewhich are being mentioned here. I referred to it before when I was talking about my tasks with the Reich Air Ministry which tasks were the same as they applied to the Waffen-SS now. I had the task in connection with the Reich Building Commission to carry out, to plan the building project for the SS, and then for the period after the war, and particularly for the Allgemeine SS, the dwellings for the Allgemeine SS.