A. Yes, I do.
Q. Do you know how this labor allocation of inmates came about?
A. Herr Dr. Bobermin had submitted a report to Herr Pohl, in which he suggested that the work in the Golleschauer Cement factory be stopped. He said he had received a compensation for discontinuation of work from the Reich Economie Minister, or the trade agencies. I couldn't tell you which agency. Thus, he would have been able to pay all the expenses which occur when a factory is no longer in operation. After the conference, Herr Dr. Bobermin told me, and I also saw that on the letter, that Herr Pohl had ordered that the work continue in the enterprise. I can remember that letter very well. It had a green slash of writing across it --"No production".
Q. Did Herr Dr. Bobermin tell you his opinion about the allocation of inmate labor ordered by Herr Pohl, and if so, how did he do it. Tell us about it.
A. Herr Dr. Bobermin, in his entire actions, is a business man. He never did want to have anything to do with inmates, with people who were not free. That is part of his nature, part of his attitude. He is not exactly soft, but he is a man with feelings. That was the reason why I knew that. Apart from that, he was of the opinion that inmates would never work with such pleasure as free laborers do.
DR. GAWLIK: Your Honors, I have no further questions.
THE PRESIDENT: Cross Examination by any defense counsel?
CROSS EXAMINATION BY DR. HAENSEL (for Georg Loerner):
Q. I have very few questions, witness, concerning two problems. The first problem is one, as I can see from the records, which was touched upon by the Tribunal during my absence, the problem of the deputization and how far deputization can go. And I want to elucidate that question, in the case of Georg Loerner. You know that the defendant Georg Loerner, witness, formally speaking, was Pohl's deputy, with certain limitations.
Now as you had knowledge of the method of the business in the WVHA, I would appreciate it if you would tell me if Loerner as Pohl's Deputy could decide important, practical questions?
A. Herr Loerner, if I can say this in a few brief terms, was nothing but a dummy. In Amtsgruppe W he hardly appeared as a deputy. He was only used when companies were established and when general questions were discussed, which, however, were of no importance. Herr Pohl was the one who made all the decisions. I can only remember during one occasion when Herr Pohl had taken him along to visit a new factory; that even struck me, but I took it as a more or less loyal action. I can say that Herr Loerner was just taken along for one visit.
Q. Witness, do you remember that the prosecution showed us a decree by Pohl that the W Office Chiefs had to inform Georg Loerner of all important matters?
A. Yes, that decree is contained in the documents.
Q. Do you know anything about what happened to that order, was it carried out or not?
A. That order possibly existed for two months. I couldn't give you the exact date, and I couldn't swear to the dates, but Herr Pohl cancelled that decree one day. I believe I can remember that the Office Chiefs of W Offices no longer came to see him, and if they did, they only came to see him for a very short time, and, that the cooperation didn't work very well. That was the reason why certainly after that the decree was cancelled. Herr Pohl even prohibited the office chief to see Georg Loerner first, and he wanted to have the Office Chiefs see him directly.
Q. Thank you, witness, no more questions in connection with this point. The Tribunal spoke of a subject today while examining the defendant Volk, and I believe that one of the most important questions is still missing, that is the activity of the SS after 1939. Herr Volk, you said something about the training of the SS and drill. Did that refer to the time prior to 1939 or after 1939?
A. What I described -
THE PRESIDENT: That was the Allgemeine SS?
DR. HAENSEL: Yes, but I believe that it is also very important for the Tribunal to know what the Allgemeine SS was after 1939. That is what I wanted to find out. What he answered before was about the Allgemeine SS prior to 1939.
THE PRESIDENT: Well, the Allgemeine SS after 1939 was nothing, I mean it just disappeared, didn't it?
DR. HAENSEL: That is excellent, Your Honor, that is more than I could hope for. Thank you, no further questions.
BY DR. HEIM (Counsel for defendant Hohberg):
Q. Witness, I would like to clarify a few small points in connection with the defendant Hohberg, and I want you to help me clarify those points.
First of all, the resignation of Dr. Hohberg as an auditor of the DWB - by that I mean the fact that he was considered indispensable. Could you tell me, Dr. Volk, whether Dr. Hohberg was deferred as essential until he left as an auditor?
A. I couldn't answer that question of yours with one hundred percent certainty. I remember that Dr. Hohberg had been deferred as essential by the auditors association, I believe. I don't remember what the conditions were, but I believe that union handled the matter. I still couldn't swear to it. I believe I am in a position to say that it wasn't the DWB G.m.b.H. that actually deferred him as essential.
Q. Witness, you believe that you can recall that somebody deferred Dr. Hohberg as essential?
A. I really couldn't tell you for sure. It is possible -- but in any case I believe I can tell you with more certainty that it was not done by DWB, G.m.b.H. You see, I didn't have the time to deal with all those individual cases, Mr. Defense Counsel. After all, I wouldn't tell you anything incorrect.
Q. Dr. Volk, I have two additional questions in that connection. Was Dr. Hohberg in a position to be conscripted into the Wehrmacht during the time when he was deferred as essential?
A. No.
Q. Can you recall whether, shortly before the resignation of Dr. Hohberg, Herr Pohl, the defendant, had made an application to have him deferred as essential?
A. Yes, I was the one who submitted that application -- there were two.
Q. Was that application approved?
A. The first application was approved. The second application was not approved.
Some general of the Luftwaffe had signed it, and it was stated that Dr. Hohberg was to be conscripted on the first of August 1943. Pohl signed both of these applications which I had to set up, as a legal advisor of the organization.
Q. Witness, now let me discuss another point. The witness Karoli testified here in this Tribunal that complaints went directly to the Reich Economy Ministry from professional circles according to which Herr Dr. Hohberg no longer was permitted to work as an auditor of the DWB because his position was too high and too powerful in the DWB.
You were a lawyer, weren't you, witness, and at the same time, for quite a while, you were a personal referent of Herr Pohl. Can you tell us something on the basis of your position at the time?
A. The fact which you just touched upon, Mr. Defense Counsel, is correct. The Union of Auditors received a report to the effect that Herr Dr. Hohberg in Staff W, with the Economic Enterprises GMBH, was carrying out a function which was similar to a commercial body.
Q. Do you know what was done upon this report, and when this was?
A. Well, when that was I couldn't tell you for certain. It could have been towards the end of 1942 or it might have been the middle of 1942 or even early 1943. I just couldn't tell you about the date.
Q. What did the Institute of Auditors cause against Dr. Hohberg upon this report?
A. I believe that they asked Dr. Hohberg to come and see them, and they made a report. I don't know what kind of report that was, but in any case they told him that there was some sort of denunciation against him.
Q. Is that in any connection with the case of Rucks which was discussed by Dr. Hohberg when he was a witness?
A. Yes.
Q. Would you tell us something about it in a few brief terms?
A. A certain man by the name of Rucks, who used to be an auditor with Dr. Hohberg, was the one who was the denunciator.
Q. What happened to him?
A. He received a one-year jail term by the SS and Police Court. According to my impression, Rucks was not the man who had made the denunciation.
Q. Well, witness, that doesn't make any difference who the denunciator was. Did the Institute of Auditors speak to Mr. Pohl about it in this connection?
A. Yes.
Q. Do you know what letter Herr Pohl had sent to the Auditors' Union?
A. Herr Pohl covered up for Dr. Hohberg.
Q. What do you mean by "covering up" for him?
A. Herr Pohl stated that formally, of course, Dr. Hohberg was an auditor because, after all, he had a contract on commission. But the position which he held he had got by Pohl, so that it looked as if he had a position of a body, according to commercial law.
BY JUDGE PHILLIPS:
Q. The position that you referred to was that he was chief of Staff W, isn't that correct?
A. Yes.
Q. And Pohl was covering up so that the Institute would not know that he was the chief of Staff W, but to the contrary, he was trying to make it appear that he was only an auditor. Is that correct?
A. Yes.
Q. And then when the Institute found out that he was the chief of an office, then they asked that he be relieved?
A. Well, then the Institute would have put Dr. Hohberg on trial; he was no longer permitted to be an auditor. But, Mr. Federal Judge, I believe that the Institute of Auditors, politically speaking, was so weak that it couldn't possibly have been able to do anything against Herr Pohl or Herr Himmler.
Q. In other words, if he was violating the rules of the Institute under the orders of Himmler and Pohl, the Institute could do nothing about it?
A. Actually not, Your Honor -- but legally, yes.
BY DR. HEIM:
Q. Witness, if I understood you correctly, then Herr Pohl informed the Institute of Auditors that Herr Hohberg was nothing but an auditor, whereas, according to your testimony, he was not an auditor, because, according to your testimony, witness, Herr Dr. Hohberg was Chief of Staff W. Is that correct?
A. Mr. Defense Counsel, Dr. Heim, in order to clear up this mysterious problem I would have to hold a speech--
THE PRESIDENT: That is what I was afraid of. This isn't mysterious. We have understood it for a week, and you are just going over and over it again. We understood it before, and now you give us fair warning that it calls for a long speech. We would rather not hear the speech, if you please.
BY DR. HEIM:
Q. Witness, would you please answer my question very briefly, the way I have put it to you?
A. Herr Dr. Hohberg, on the one hand, was an auditor. Well, after all, I can't answer your question with yes or no because the Tribunal will get the wrong impression, and I am not going to give you the wrong testimony.
Q. Witness, I asked you the following: Did I understand you correctly, namely, that you said the following to Judge Phillips. Pohl stated at the time to the Institute of Auditors that Herr Dr. Hohberg was nothing but an auditor. In reality, however, Dr. Hohberg was not only an auditor but also chief of Staff W.
Did I understand you correctly, witness? That you wanted to tell that to Judge Phillips?
A. No, I didn't want to say that. All I wanted to say--- After all, that question cannot be answered that way--
THE PRESIDENT: Now, the translation was "I didn't want to say that.
That is all I wanted to say."
WITNESS: No, Mr. President--
THE PRESIDENT: That is right.
WITNESS: Dr. Heim didn't give me time enough to finish my statement.
BY DR. HEIM:
Q. Witness, after all, as far as I am concerned, you can go into detail and hold a long speech. I don't care.
A. Herr Dr. Hohberg was an auditor and, apart from that, he also had the title Chief of Staff W. That can be seen from the documents. I don't have to tell you more.
THE PRESIDENT: That is nothing new. We certainly knew that day before yesterday.
BY DR. HEIM:
Q. Witness, was Dr. Hohberg chief of Staff W, or did he have only the title? After all, you should be in a position to clarify this problem, being a legal expert. After all, you did work with the DWB for years and years.
A. I can clear up that question of yours.
Q. Then please do.
A. If Mr. President permits me to say three sentences, then I will be able to solve that problem.
THE PRESIDENT: Now, let's understand the question. Was Hohberg chief of Staff W, or did he just have a title? Now, answer that as best you can.
WITNESS: The chief of Staff W had the position of a chief of office, just as all the other office chiefs of the "W" offices, W-1 to W-8. In the WVHA there are two kinds of office chiefs. You have the real office chiefs, who were members of the office groups A to D, who had been appointed by the Reichsfuehrer-SS or the Personnel Main Office and who were receiving Reich pay; in Amtsgruppe W you had so-called Pohl office chiefs, who did not comply with the prerequisites which were necessary for the office chiefs of office groups A to D. If that is a title or if it is an official term, I couldn't tell you, Mr. Defense Counsel.
Q Dr. Volk, at the time, Thank God, I was not with the DWB. Therefore, I could not clear up this problem, but there is bound to be a way to express this clearly. Was Dr. Hohberg Chief of Staff-W or was he never Chief of Staff-W? This is a question, which according to my opinion can be answered with "yes" or "no."
AAll right then. I would have to speak about the activity of Dr. Hohberg.
Q Witness, if the Tribunal agrees to listen to you, please do.
THE PRESIDENT: No, we don't agree at all. Either you can answer that question -- You understand the question? You understand the question, "Was Dr. Hohberg Chief of Staff-W?" Now you can say "yes" and "I can't answer that."
THE WITNESS: Herr Dr. Hohberg had the title "Chief of Staff W." Sometimes he did have the title and sometimes he didn't have the title. It depended. It was not clear at all with him.
THE PRESIDENT: All right, that's a pretty fair answer. Now go ahead from there, Dr. Heim.
BY DR. HEIM:
Q Witness, was the Chief of Staff W in a position to give orders to the members of Staff W?
A Not military orders, no.
Q What kind of orders then?
A He could, for instance, tell Dr. Wenner, who was in charge of the Finance and Tax Department, to take care of this or that file.
Q Herr Dr. Hohberg, in the direct examination, you testified that you were not in a position to issue orders to your collaborators, because they had the same or a higher SS official rank than you did. Now, if, as SS Hauptsturmfuehrer, you could not give any orders to your collaborators, and give them instructions, how do you think that Dr. Hohherg, as a civilian, would be able to issue orders to his collaborators, if we assume that he was Chief of Staff-W?
A Your question, Dr. Heim, is not logical.
Q Mr. Witness, I didn't ask you if my question was logical or not. I am simply asking you to answer my question as best you can.
A You asked me about orders and instructions, while in direct examination I stated that I was not in a position to give orders. By orders, Mr. Defense Counsel, I as a legal expert understand military orders and military orders I couldn't issue usually. Instructions are something entirely different.
Q Therefore, you could issue instructions, could you?
A But of course, as a man in charge of the Legal Department, I could give instructions to my collaborators.
Q You further stated literally, Witness, "I could not become Chief of Staff W, because I had too low a rank for that." Would you please explain this contradiction on your part: Dr. Hohberg, as a civilian, could become Chief of Staff W. You as a Hauptsturmfuehrer in the SS had too low a rank to become Chief of Staff W.
A Mr. Defense Counsel, in the WVHA, a person who knew something in civilian life was stronger than any SS leader, because the SS leader had to stand at attention whereas the civilian didn't have to do that. That was the reason why I, as Hauptsturmfuehrer, could never become Chief of Staff W or Chief W. Do you think that the higher ranks would have let me tell them something? That was the reason why I made my testimony. That is what I meant by my testimony.
THE PRESIDENT: Nobody claims that this witness was ever Chief of Staff W, do you? Do you, Mr. Robbins?
MR. ROBBINS: Yes, Your Honor, for a few months. A document introduced in evidence shows that he was.
THE PRESIDENT: During that interim between Hohberg and Baier?
MR. ROBBINS: Yes. I think he himself says he was in charge of the office.
THE PRESIDENT: That is right.
THE WITNESS: Yes, I was in charge of the business during one month and eight days, but I was not Chief W, nor was I Chief of Staff W.BY DR. HEIM:
Q Witness, doesn't your testimony contradict your statement on direct examination when you testified to the following and this is a literal translation: "In the DWB, the leadership forces were mostly members of the SS". Now you just said that an intelligent civilian would have a more powerful position with the DWB than an SS officer.
A I said "he could have." I didn't say, "he did."
THE PRESIDENT: What has this to do with your client, Dr. Heim? How are you concerned in this cross-examination? How does it affect your client?
DR. HEIM: Your Honor, Herr Dr. Hohherg at no time was a member of the SS. Dr. Volk, who was an SS Hauptsturmfuehrer testified that he would not be able to become Chief of Staff W, because he only had the rank of SS Hauptsturmfuehrer. Now the conclusion out of this is that a civilian, who did not have an SS rank, could by no means become Chief of Staff W.
THE PRESIDENT: Don't you think that's a point that you ought to argue to the Tribunal, rather than with the witness?
DR. HEIM: Your Honor, I only wanted to have shown by the witness what his opinion was about this problem, as, after all, he was with the DWB for years and particularly was working with the Legal Department there.
THE PRESIDENT: Well, if this continues much longer, we are going to have to limit cross-examination, as we are permitted to do under the Ordinance. The cross- examination is taking altogether too much time and covering too much territory, too much ground. Go ahead.
DR. HEIM: Your Honor, I am sorry, but the witnesses are all incriminating my client and I simply have to defend his position.
BY DR. HEIM:
Q Did you know the contract which existed between Herr Dr. Hohberg and the DWB?
A Yes.
Q Can you tell us whether that contract was an official contract or a working contract?
A It was a contract which was similar to a working contract, a contract on commission.
Q Did you also know the first contract, or did you only know the second contract?
A I don't know whether I saw the first contract or not: I couldn't tell you for sure.
Q Witness, you testified before that you had connections with the Property Manager of the Apollinaris and that was the Reich Commissioner for the Administration of Enemy Property.
A I didn't want to say that. As a matter of fact, I didn't want to go into detail in regard to this problem before the Tribunal, because I am going to bring in a number of affidavits on that question. That is the reason why I spoke briefly and you may have misunderstood me. The Reich Commissioner for Enemy Property at the time was a man named Ernst. The administrator is another man. He was only appointed later on.
Q Do you know who the Manager of the Apollinaris was?
A Wirtz was his name.
Q That's all. Do you know who carried out the compulsory auditing the DWB after Dr. Hohberg?
A I believe it was the Trusteeship and Auditing A.G., but I don't know if those were compulsory auditings with a certificate.
THE PRESIDENT: The Tribunal will be in recess.
THE MARSHAL: The Tribunal will recess for 15 minutes.
(A recess was taken.)
THE MARSHAL: Take your seats, please.
The Tribunal is again in session.
BY DR. HEIM:
Q Your Honor, I have only four more questions.
Witness, I would like to read to you four lines of an affidavit by Frau Fauler. I want to do that in order to refresh your memory about your classification as being indispensable. I want to read from Hohberg Document 24, Exhibit #24, and it is on page 55 of Hohberg Document Book #1. The last paragraph and I quote:
"I further know that Dr. Hohberg was neither a member of the NSDAP nor the SS. As a result of this, finally in 1943, his classification as being indispensable to this office was suspended and he was assigned to the Wehrmacht, in this case the Luftwaffe."
A Other wise Hohberg could not have been called up to the Luftwaffe.
Q Witness, does that affidavit refresh your memory to some extent with regard to your classification of being indispensable?
THE PRESIDENT: His classification or Hohberg's?
BY DR. HEIM:
Q I'm referring to the classification of Hohberg.
A This testimony does not contradict my statement. This classification was suspended because otherwise Dr. Hohberg could not have been conscripted into the Luftwaffe.
Q Witness, while you were at Minden in prison did you give the defendant Hohberg an affidavit?
A Yes.
Q Do the contents of this affidavit contradict the testimony which you have given today?
A No.
Just a moment please, Dr. Heim, I have not as yet completed my statement. At Minden we discussed the legal importance of the so-called Office Chief W. We were quite worried about the subject at the time and regained the conviction that this Office Chief W was not an office chief in the sense of the technical designation of an office chief, as I have explained before, With regard to Office Groups A to D. And in this affidavit it is stated that Dr. Hohberg was not an office chief.
Of course, here we were referring to the technical sense of the designation. After all, this affidavit was dictated by Dr. Hohberg and the it was submitted to me.
Q Didn't you have this affidavit changed and didn't you have it rewritten by your secretary?
A I don't think this was done with regard to that point.
Q Witness, that is sufficient. Witness, you stated that Hohberg had a contract which resembled that of a working employment contract and I would like to show you your affidavit of the 2 of December 1946. I want you to identify it and please read it to us.
(Affidavit is handed to witness)
Witness, please read this affidavit to us.
THE PRESIDENT: Has this affidavit been marked as an exhibit and admitted in evidence?
DR. HEIM: Your Honor, I have just offered this affidavit now for identification.
THE PRESIDENT: Well, before he reads it, have it marked as an exhibit and do you have a copy for the prosecution?
DR. HEIM: Yes, Your, Honor. It is Hohberg Document 69 and will become Exhibit #42.
THE PRESIDENT: Do you have a copy for the prosecution?
DR. HEIM: Your Honor, unfortunately the copies were not finished in time. I would like to ask the witness, with the permission of the Tribunal, to read the affidavit now into the record.
THE PRESIDENT Well, that's the thing that you object to when the prosecution does it.
DR. HEIM: No, Your Honor, I objected at a time when the prosecution submitted the document about the Gallus Printing shop but then it did not have any document number and it did not give it any exhibit number.
THE PRESIDENT: Well, isn't there some particular part of this affidavit, just a single statement in it, that you are interested in?
DR. HEIM: Dr. Volk, please be kind enough and read the sentences which I have provided with parenthesis.
DR. GAWLIK: Your Honor, I object to the reading of this document as long as this affidavit has not been presented here in evidence.
DR. HEIM: Your Honor, I have already offered this affidavit as Hohberg Document 69, as Exhibit #42.
THE PRESIDENT: Any objection, Dr. Hoffman?
DR. HOFFMAN: No, I only advised my colleague because, on the one hand, you asked for a copy for the prosecution, and I advised him to present this document after the noon recess so the prosecution will have a copy too. Otherwise, I am afraid that later on when I complain that Mr. Robbins hasn't submitted a copy to me in time he will use that same excuse and I want to clear that excuse out of the way for later on.
THE PRESIDENT: Dr. Gawlik, do you object to this affidavit? It has been offered in evidence.
DR. GAWLIK: I have no objection whatsoever, Your Honor, if it is offered in evidence.
THE PRESIDENT: Mr. Robbins, you are eloquent in your silence.
MR. ROBBINS: I have no objections, Your Honor.
THE PRESIDENT: Just ask the witness to read the small part of the affidavit that you're interested in.
DR. HEIM: Your Honor, on Saturday morning I have already turned over a stencil to the Reproduction Division. Unfortunately, I still have not received any copies yet.
Witness, please read the sentences now which I have provided with parenthesis.
WITNESS: I would prefer to read the entire affidavit now.
THE PRESIDENT: I would prefer that you didn't. Just remember you're a witness now, not the lawyer.
WITNESS: "Auditor Certified Merchant Hans Hohberg, by virtue of a contract, was with the DWB as a free auditor and he also worked for a large number of affiliated companies."
Now, the first sentence:
"One day Pohl gave Hohberg the designation of an office chief. As I found out later, Pohl was trying to bring Hohberg under the SS jurisdiction at the time. The term "office chief" was purely fictional because there was neither an office in existence nor did it have that name or a budget either. No document or written appointment was compiled and there were no functions with regard to the Party or the SS and there was no function to be carried out for the Reich or for the Party."
That is what I have explained with regard to the position of office chiefs.
"Some time later a collaborator of DWB denounced Hohberg to the Auditing Institute at Berlin. He gave the reasons that Dr. Hohberg is qualified as an auditor and was being questioned because he accepted that designation. Pohl then replied to that inquiry of the Auditing Institute that Dr. Hohberg as an editor, was completely independent and therefore there was no contract between him and DWB but that he was only working for the DWB. Then the person who had made the denouncement, Mr. Rux, from Berlin, Harmsdorf was sentenced to one year's imprisonment because he knowingly had made a false denouncement."
And this does not contradict my statement at all.
DR. HEIM: Witness, do you still maintain the statement you have made in your affidavit?
A The statement which I have made here in the witness stand is true.
Q Witness, I didn't ask you about that.
THE PRESIDENT: Now, wait a minute. The witness has said that he does not repudiate the affidavit and that it agrees with his testimony and I think it does too. He says the affidavit is true. Now, what more do you want?
DR. HEIM: If the affidavit is true, according to the witness' statement then I am, of course, completely satisfied. Thank you. I have no further questions.
BY DR. FROESCHMANN (Defense Counsel for defendant Mummenthey)
Q Witness, you have known the conditions of the affiliated companies since 1940 and the conditions of what, later on, became the DWB?
A Yes, I knew them very slightly.
Q Do you know the conditions of the DEST in general?
A Yes, I know about them generally. I have never worked in DEST but I know its general status.
Q Who, in the year 1940, was the business manager of DEST?
A The first business manager and office chief was Dr. Salpeter. That was in the year 1940.
Q At the time was the defendant Mummenthey also a business manager, that is to say, was he an assistant business manager?
A Whether he was an assistant business manager already in 1940 I don't know. However, I believe that I can recall that he only was a prokurist at that time. However, I can't give you the exact date, Dr. Froeschmann.
Q In order to judge the activity of Mumenthey, it may be of importance as to just what the character of Salpeter was. Are you able to tell the Tribunal very briefly about this subject?
A Dr. Salpeter in his field was a very good lawyer. However, he was a very bad businessman. He was personally very ambitious and inconsiderated to collaborators. He exploited them, only gave orders to them, and he followed the so-called Fuehrer Principle even in the economic field.
Q Is it correct that Salpeter in all important matters would reserve his right to make his own decision?
A In my field of activity--I was the liaison referent with him to III-A/4, and this was always the case. I recall that on one occasion I had to compile a draft -- the prosecution has read this draft in part in his opening statement -- at the time he gave me the exact details, and he told me precisely just how I had to work out this draft of this speech. I requested him at the time to leave something to my own initiative, because after all in the position which I had. occupied in peace-time I had something of a higher position. However, he did not do that, and he treated me just like a small apprentice. From that, I must conclude that he acted in the same way toward all the other experts.
Q Witness, there was a second person who played a very important part in the DEST and this might be important for Mumenthey's activities while he was working there, that is the so-called Schondorf who has already been mentioned several times. Have you known Schondorf?
A Yes.
Q What was Schondorf's relationship to the DEST, or what was his relationship to Pohl?
A His relationship to the DEST was the following: Schondorf as far as I know, was first of all, a prokurist. Later on a business manager. He was a technician and he lectured at the Brick Works in the camp. In the DEST he was the competent man actually, that was, with regard to the Brick Works and with regard to technical questions. He carried out his work at Stadlag. The second part of your question Dr. Froeschmann, was his relationship to Pohl. Pohl had put Engineer Schondorf in charge of all the technical aspects of all the raw production places in the WVHA, and he was always bragging about this. And he stated that he would only work four days a week. And I also know from discussions that he had the right to report directly to Pohl. In these technical companies, as it always is the case, there was a constant struggle between the technicians and the businessmen. As a result of this, he always emphasized the fact that the businessmen, including Mumenthey, could not give him instructions.
Q May I conclude from your statement that Schondorf held a very important position within the DEST?
A He did not only hold outstanding position in the DEST, but he also held an outstanding position in many companies. I know that Dr. Bobermin only succeeded with the utmost effort in achieving in a discussion with Pohl, that Schondorf was not the man in charge of the technical management of the Eastern Brick works of which Dr. Bobermin was in charge. However, Dy. Bobermin's efforts did not clarify this question either.
Q Witness, if the technical management was in the hands of Schondorf, then he also had in his hands the planning of the Works, that is to say, he still had to obtain the approval of Pohl, is that correct?
A I don't know that, but I have to assume so. I can't tell you that from my own knowledge, since I was not there; however, I must draw that conclusion from the facts which have become accessible to me.
Q Were you ever consulted on how the planning was drafted?
A No.
Q Consequently, you do not know how the planning was carried out in the DEST?
A I only know from the time when I began my work in 1940 that Dr. Salpeter, who was the outstanding person in this case, in that office, I know that he went to Pohl together with Schondorf. Just what happened later on with Mumenthey, I don't know. However, I must conclude from that that Schondorf usually would go to see Pohl by himself, and that he did not take Mumenthey along anymore.
Q In your opinion, wasn't the figuring out of the necessary labor part of the planning? Can you give us any statement about that?
A I am not a technician, Dr. Froeschmann.
Q But I would like to ask you some other questions. Did you know Mumenthey's business management in the DEST?
A Yes.
Q Did Mumenthey maintain a policy of expansion by constantly including more plants in his organization?
AAs far as I am able to judge that. Mumenthey did not want to have any new plants. He said that he had so much work to do, and that he had to bring so many commercial matters into order which Salpeter had left behind; for this reason, after Dr. Salpeter left, a businessman from the Economy was placed at his disposal. For his assistance in order to clarify the status and the business matters in the DEST. That was Dr. Opperbeck.
Q After Dr. Salperter left, did Mumenthey become more independent in his business management or was he continually tied down by special circumstances? Do you know anything about that?
A I don't know at the moment just what circumstances you are referring to.
Q May I use the word "Corporation" to you, and then the orders which were issued in that respect.