MR. JUSTICE JACKSON: And why did you not want to be a member of the SS,

which was after all one of the important Party formations?

SPEER: No, I became well known for turning down all these honorary

ranks. I did not want them because I felt that one should only hold a

rank where one had responsibility.

MR. JUSTICE JACKSON: And you did not want any responsibility in the SS?

SPEER: I had too little contact with the SS, and did not want any

responsibility in that connection.

MR. JUSTICE JACKSON: Now there has been some testimony about your

relation to concentration camps, and, as I understand it, you have said

to us that you did use and encourage the use of forced labor from the

concentration camps.

SPEER: Yes, we did use it in the German armament industry.

MR. JUSTICE JACKSON: And I think you also recommended that persons in

labor camps who were slackers be sent to the concentration camps, did

you not?

SPEER: That was the question of the so-called “Bummelanten,” and by that

name we meant workers who did not get to their work on time or who

pretended to be ill. Severe measures were taken against such workers

during the war, and I approved of these measures.

MR. JUSTICE JACKSON: In fact, in the 30 October 1942 meeting of the

Central Planning Board you brought the subject up in the following

terms, did you not—quoting Speer:

“We must also discuss the slackers. Ley has ascertained that the

sick list decreases to one-fourth or one-fifth in factories

where doctors are on the staff who examine the sick men. There

is nothing to be said against SS and Police taking drastic steps

and putting those known to be slackers into concentration camp

factories. There is no alternative. Let it happen several times,

and the news will soon get around.”

That was your recommendation?

SPEER: Correct.

MR. JUSTICE JACKSON: In other words, the workmen stood in considerable

terror of concentration camps, and you wanted to take advantage of that

to keep them at their work, did you not?

SPEER: It is certain that concentration camps had a bad reputation with

us, and the transfer to a concentration camp, or threat of such a

possibility, was bound to reduce the number of absentees in the

factories right from the beginning. But at that meeting, as I already

said yesterday, there was nothing further said about it. It was one of

the many remarks one can make in wartime when one is upset.

MR. JUSTICE JACKSON: However, it is very clear—and if I misinterpret

you I give you the chance to correct me—that you understood the very

bad reputation that the concentration camps had among the workmen and

that the concentration camps were regarded as being much more severe

than the labor camps as places to be in.

SPEER: That is correct. I knew that. I did not know, of course, what I

have heard during this Trial, but the other thing was a generally known

fact.

MR. JUSTICE JACKSON: Well, it was known throughout Germany, was it not,

that the concentration camps were pretty tough places to be put?

SPEER: Yes, but not to the extent which has been revealed in this Trial.

MR. JUSTICE JACKSON: And the bad reputation of the concentration camp,

as a matter of fact, was a part of its usefulness in making people

fearful of being sent there, was it not?

SPEER: No doubt concentration camps were a means, a menace used to keep

order.

MR. JUSTICE JACKSON: And to keep people at work?

SPEER: I would not like to put it in that way. I assert that a great

number of the foreign workers in our country did their work quite

voluntarily once they had come to Germany.

MR. JUSTICE JACKSON: Well, we will take that up later. You used the

concentration camp labor in production to the extent that you were

required to divide the proceeds of the labor with Himmler, did you not?

SPEER: That I did not understand.

MR. JUSTICE JACKSON: Well, you made an agreement finally with Himmler

that he should have 5 percent, or roughly 5 percent, of the production

of the concentration camp labor while you would get for your work 95

percent?

SPEER: No, that is not quite true.

MR. JUSTICE JACKSON: Well, tell me how it was. That is what the

documents indicate, if I read them aright.

SPEER: Yes, it is put that way in the Führer minutes, but I should like

to explain the meaning to you. Himmler, as I said yesterday, wanted to

build factories of his own in his concentration camps. Then he would

have been able to produce arms without any outside control, which

Hitler, of course, knew. The 5 percent arms production which was to have

been handed to Himmler was to a certain extent a compensation for the

fact that he himself gave up the idea of building factories in the

camps. From the psychological point of view it was not so simple for me

to get Himmler to give up this idea when he kept on reminding Hitler of

it. I was hoping that he would be satisfied with the 5 percent arms

production we were going to give him. Actually this 5 percent was never

handed over. We managed things quietly with the Operations Staff of the

OKW and with General Buhle, so that he never got the arms at all.

MR. JUSTICE JACKSON: Well, I am not criticizing the bargain, you

understand. I don’t doubt you did very well to get 95 percent, but the

point is that Himmler was using, with your knowledge, concentration camp

labor to manufacture arms, or was proposing to do so, and you wanted to

keep that production within your control?

SPEER: Could the translation come through a bit clearer? Would you

please repeat that?

MR. JUSTICE JACKSON: You knew at this time that Himmler was using

concentration camp labor to carry on independent industry and that he

proposed to go into the armament industry in order to have a source of

supply of arms for his own SS?

SPEER: Yes.

MR. JUSTICE JACKSON: You also knew the policy of the Nazi Party and the

policy of the Government towards the Jews, did you not?

SPEER: I knew that the National Socialist Party was anti-Semitic, and I

knew that the Jews were being evacuated from Germany.

MR. JUSTICE JACKSON: In fact, you participated in that evacuation, did

you not?

SPEER: No.

MR. JUSTICE JACKSON: Well, I gather that impression from Document L-156,

Exhibit RF-1522, a letter from the Plenipotentiary for the Allocation of

Labor which is dated 26 March 1943, which you have no doubt seen. You

may see it again, if you wish. In which he says...

SPEER: I know it.

MR. JUSTICE JACKSON: “At the end of February, the Reichsführer

SS, in agreement with myself and the Reich Minister for

armaments and munitions, for reasons of state security, has

removed from their places of work all Jews who were still

working freely and not in camps, and either transferred them to

a labor corps or collected them for removal.”

Was that a correct representation of your activity?

SPEER: No.

MR. JUSTICE JACKSON: Will you tell me what part you had in that? There

is no question that they were put into labor corps or collected for

removal, is there?

SPEER: That is correct.

MR. JUSTICE JACKSON: Now you say you did not do it, so will you tell me

who did?

SPEER: It was a fairly long business. When, in February 1942, I took

over my new office, the Party was already insisting that Jews who were

still working in armament factories should be removed from them. I

objected at the time, and managed to get Bormann to issue a circular

letter to the effect that these Jews might go on being employed in

armament factories and that Party offices were prohibited from accusing

the heads of these firms on political grounds because of the Jews

working there. It was the Gauleiter who made such political accusations

against the heads of concerns, and it was mostly in the Gau Saxony and

in the Gau Berlin. So after this the Jews could remain in these plants.

Without having any authority to do so, I had had this circular letter

from the Party published in my news sheet to heads of factories and had

sent it to all concerned, so that I would in any case receive their

complaints if the Party should not obey the instruction. After that the

problem was left alone, until September or October of 1942. At that time

a conference with Hitler took place, at which Sauckel also was present.

At this conference Hitler insisted emphatically that the Jews must now

be removed from the armament firms, and he gave orders for this to be

done—this will be seen from a Führer protocol which has been preserved.

In spite of this we managed to keep the Jews on in factories and it was

only in March 1943, as this letter shows, that resistance gave way and

the Jews finally did have to get out.

I must point out to you that, as far as I can remember, it was not yet a

question of the Jewish problem as a whole, but in the years 1941 and

1942 Jews had gone to the armament factories to do important war work

and have an occupation of military importance; they were able to escape

the evacuation which at that time was already in full swing. They were

mostly occupied in the electrical industry, and Geheimrat Bücher, of the

electrical industry—that is AEG and Siemens—no doubt lent a helping

hand in order to get the Jews taken on there in greater numbers. These

Jews were completely free and their families were still in their homes.

The letter by Gauleiter Sauckel you have before you was not, of course,

submitted to me; and Sauckel says that he himself had not seen it. But

it is certainly true that I knew about it before action was taken; I

knew because the question had to be discussed as to how one should get

replacements. It is equally certain, though, that I also protested at

the time at having skilled labor removed from my armament industries

because, apart from other reasons, it was going to make things difficult

for me.

MR. JUSTICE JACKSON: That is exactly the point that I want to emphasize.

As I understand it, you were struggling to get manpower enough to

produce the armaments to win a war for Germany.

SPEER: Yes.

MR. JUSTICE JACKSON: And this anti-Semitic campaign was so strong that

it took trained technicians away from you and disabled you from

performing your functions. Now, isn’t that the fact?

SPEER: I did not understand the meaning of your question.

MR. JUSTICE JACKSON: Your problem of creating armaments to win the war

for Germany was made very much more difficult by this anti-Jewish

campaign which was being waged by others of your codefendants.

SPEER: That is a certainty; and it is equally clear that if the Jews who

were evacuated had been allowed to work for me, it would have been a

considerable advantage to me.

THE PRESIDENT: Mr. Justice Jackson, has it been proved who signed that

document, L-156? It has got a signature apparently on it.

MR. JUSTICE JACKSON: There is a signature on it, I believe the

plenipotentiary general for the employment of labor is my thought on it.

We will look at that.

THE PRESIDENT: Perhaps the defendant could tell what the signature is.

[_The document was shown to the defendant._]

SPEER: I do not know the man. Yes, he must be one of the smaller

officials in the offices of the Plenipotentiary for Labor, because I

knew all the immediate associates of Sauckel personally—no; I beg your

pardon, the document comes from the Regierungspräsident in Koblenz, as I

see here. Then it is an assistant in the Government District of Koblenz,

whom of course I did not know.

MR. JUSTICE JACKSON: In any event, there is no question about the

statement as you have explained it?

SPEER: No.

MR. JUSTICE JACKSON: Now I want to ask you about the recruiting of

forced labor. As I understand it, you know about the deportation of

100,000 Jews from Hungary for subterranean airplane factories, and you

told us in your interrogation of 18 October 1945 that you made no

objection to it. That is true, is it not?

SPEER: That is true, yes.

MR. JUSTICE JACKSON: And you told us also, quite candidly, on that day

that it was no secret to you that a good deal of the manpower brought in

by Sauckel was brought in by illegal methods. That is also true, is it

not?

SPEER: I took great care at the time to notice what expression the

interrogating officer used; he used the expression “they came against

their wish”; and that I confirmed.

MR. JUSTICE JACKSON: Did you not say that it was no secret to you that

they were brought in an illegal manner? Didn’t you add that yourself?

SPEER: No, no. That was certainly not so.

MR. JUSTICE JACKSON: Well, in any event, you knew that at the Führer

conference in August of 1942 the Führer had approved of all coercive

measures for obtaining labor if they couldn’t be obtained on a voluntary

basis, and you knew that that program was carried out. You, as a matter

of fact, you did not give any particular attention to the legal side of

this thing, did you? You were after manpower; isn’t that the fact?

SPEER: That is absolutely correct.

MR. JUSTICE JACKSON: And whether it was legal or illegal was not your

worry?

SPEER: I consider that in view of the whole war situation and of our

views in general on this question it was justified.

MR. JUSTICE JACKSON: Yes, it was in accordance with the policy of the

Government, and that was as far as you inquired at the time, was it not?

SPEER: Yes. I am of the opinion that at the time I took over my office,

in February 1942, all the violations of international law, which

later—which are now brought up against me, had already been committed.

MR. JUSTICE JACKSON: And you don’t question that you share a certain

responsibility for that program for bringing in—whether it is a legal

responsibility or not, in fact—for bringing in this labor against its

will? You don’t deny that, do you?

SPEER: The workers were brought to Germany largely against their will,

and I had no objection to their being brought to Germany against their

will. On the contrary, during the first period, until the autumn of

1942, I certainly also took some pains to see that as many workers as

possible should be brought to Germany in this manner.

MR. JUSTICE JACKSON: You had some participation in the distribution of

this labor, did you not, as among different plants, different

industries, that were competing for labor?

SPEER: No. That would have to be explained in more detail—I do not

quite understand it like that.

MR. JUSTICE JACKSON: Well, you finally entered into an agreement with

Sauckel, did you not, in reference to the distribution of the labor

after it reached the Reich?

SPEER: That was arranged according to the so-called priority grades. I

had to tell Sauckel, of course, in which of my programs labor was needed

most urgently. But that sort of thing was dealt with by general

instructions.

MR. JUSTICE JACKSON: In other words, you established the priorities of

different industries in their claim for the labor when it came into the

Reich?

SPEER: That was a matter of course; naturally that had to be done.

MR. JUSTICE JACKSON: Yes. Now, as to the employment of prisoners of war,

you—whatever disagreement there may be about the exact figures, there

is no question, is there, that prisoners of war were used in the

manufacture of armament?

SPEER: No, only Russian prisoners of war and Italian military internees

were used for the production of arms. As for the use of French and other

prisoners of war in this production I had several conferences with

Keitel on the subject. And I must tell you that Keitel always adopted

the view that these prisoners of war could not be used in violation of

the Geneva Prisoner of War Convention. I can claim that on the strength

of this fact I no longer used my influence to see that these prisoners

of war should be used in armament industries in violation of the Geneva

Convention. The conception, of course, “production of arms” is very much

open to argument. It always depends on what position one takes, whether

you have a wide conception of “armaments” or a narrow one.

MR. JUSTICE JACKSON: Well, you succeeded to Dr. Todt’s organization, and

you had all the powers that he had, did you not?

SPEER: Yes.

MR. JUSTICE JACKSON: And one of his directives was dated 31 October

1941, a letter from the OKW which is in evidence here as Exhibit 214,

Document EC-194, which provides that the deputies of the Reich Minister

for arms and munitions are to be admitted to prisoner-of-war camps for

the purpose of selecting skilled workers. That was among your powers,

was it not?

SPEER: No. That was a special action which Dr. Todt introduced on the

strength of an agreement with the OKW. It was dropped later, however.

MR. JUSTICE JACKSON: Now, on 22 April 1943, at the thirty-sixth meeting

of this Planning Board, you made this complaint, did you not, Herr

Speer? Quoting:

“There is a statement showing in what sectors the Russian PW’s

have been distributed, and this statement is quite interesting.

It shows that the armament industry only received 30 percent. I

always complained about that.”

That is correct, is it not?

SPEER: I believe that has been wrongly translated. It should not say

“munitions industry”; it should say, “The armament industry received 30

percent.”

MR. JUSTICE JACKSON: I said “armament.”

SPEER: Yes. But this is still no proof that these prisoners of war were

employed in violation of the Geneva Prisoner of War Convention, because

in the sector of the armament industry there was ample room to use these

workers for production articles which, in the sense of the Geneva

Prisoner of War Agreement, were not armament products. However, I

believe that in the case of the Russian prisoners of war, there was not

the same value attached to strict observance of the Geneva Convention as

in the case of prisoners from western countries.

MR. JUSTICE JACKSON: Is it your contention that the prisoners were not

used—I now speak of French prisoners of war—that French prisoners of

war were not used in the manufacture of materials which directly

contributed to the war, or is it your contention that although they were

used it was legal under the Geneva Convention?

SPEER: As far as I know, French prisoners of war were not used contrary

to the rules of the Convention. I cannot check that, because my office

was not responsible for controlling the conditions of their employment.

During my numerous visits to factories, I never noticed that any

prisoner of war from the western territories was working directly on

armament products.

MR. JUSTICE JACKSON: Just tell exactly what French prisoners of war did

do by way of manufacture. What were they working on?

SPEER: That I cannot answer. I already explained yesterday that the

allotment of prisoners of war, or foreign workers, or German workers to

a factory was not a matter for me to decide, but was carried out by the

labor office, together with the Stalag, when it was a question of

prisoners of war. I received only a general survey of the total number

of workers who had gone to the factories, and so I could get no idea of

what types of labor were being employed in each individual factory. So I

cannot give a satisfactory answer to your question.

MR. JUSTICE JACKSON: Now let us take the 50,000 skilled workers that you

said yesterday you removed and put to work in a different location, that

Sauckel complained about. What did you put them to work at?

SPEER: Those were not prisoners of war.

MR. JUSTICE JACKSON: Let us take those workers. What were you doing with

them?

SPEER: Those workers had been working on the Atlantic Wall. From there

they were transferred to the Ruhr to repair the two dams which had been

destroyed by an air attack. I must say that the transfer of these 50,000

workers took place without my knowledge, and the consequences of

bringing 50,000 workers from the West into Germany amounted to a

catastrophe for us on the Atlantic Wall. It meant that more than

one-third of all the workers engaged on the Atlantic Wall left because

they, too, were afraid they might have to go to Germany. That is why we

rescinded the order as quickly as possible, so that the French workers

on the Atlantic Wall should have confidence in us. This fact will show

you that the French workers we had working for the Organization Todt

were not employed on a coercive basis, otherwise they could not have

left in such numbers when they realized that under certain circumstances

they, too, might be taken to Germany. So these measures taken with the

50,000 workers from the Organization Todt in France were only temporary

and were revised later. It was one of those mistakes which can happen if

a minister gives a harsh directive and his subordinates begin to carry

it out by every means in their disposal.

MR. JUSTICE JACKSON: Are you familiar with Document EC-60, which reports

that the labor organization of Todt had to recruit its manpower by

force?

SPEER: At the moment I cannot recollect it.

MR. JUSTICE JACKSON: I beg your pardon?

SPEER: At this moment I cannot recollect it. Could I see the document?

MR. JUSTICE JACKSON: Yes, if you would like to. I just remind you that

the evidence is to the contrary of your testimony on that subject.

Page 42, the paragraph which reads:

“Unfortunately the assignments for the Organization Todt on the

basis of Article 52 of the Hague Convention on Land Warfare have

for some time decreased considerably, because the larger part of

the manpower allocated does not turn up. Consequently further

compulsory measures must be employed. The prefect and the French

labor exchanges co-operate quite loyally, it is true, but they

have not sufficient authority to carry out these measures.”

SPEER: I think that I have perhaps not understood correctly. I do not

deny that a large number of the people working for the Organization Todt

in the West had been called up and came to their work because they had

been called up, but we had no means whatsoever of keeping them there by

force. That is what I wanted to say. So if they did not want to work,

they could leave again; and then they either joined the resistance

movement or went into hiding somewhere else.

MR. JUSTICE JACKSON: Very well. But this calling-up system was a system

of compulsion, was it not?

SPEER: It was the calling-up of French workers for service in the Reich

or in France. But here again I must add something. This report is dated

June 1943. In October 1943 the whole of the Organization Todt was given

the status of a “blocked factory” and thereby received the advantages

which other blocked factories had. I explained that sufficiently

yesterday. Because of this, the Organization Todt had large offers of

workers who went there voluntarily, unless, of course, you see direct

coercion in the pressure put on them through the danger of their

transfer to Germany, and which led them to the Organization Todt or the

blocked factories.

MR. JUSTICE JACKSON: Were they kept in labor camps?

SPEER: That is the custom in the case of such building work. The

building sites were far away from any villages, and so workers’ camps

were set up to accommodate the German and foreign workers. But some of

them were also accommodated in villages, as far as it was possible to

accommodate them there. I do not think that on principle they were only

meant to be accommodated in camps, but I cannot tell you that for

certain.

THE PRESIDENT: Has the document been introduced before?

MR. JUSTICE JACKSON: I was just going to give it to you. The document

from which I have quoted is United States Exhibit 892.

Now, leaving the question of the personal participation in this...

THE PRESIDENT: Is it new, Mr. Justice Jackson?

MR. JUSTICE JACKSON: No, it has been in.

THE PRESIDENT: It has been in before?

MR. JUSTICE JACKSON: I am told that I am wrong about that, and that it

is new. 892 is a new number.

[_Turning to the defendant._] Leaving the part of your personal

participation in this program...

THE PRESIDENT: Could you tell us what the document is and where it comes

from? I see it is EC-60; so it must be captured. But...

MR. JUSTICE JACKSON: It is one of the economic documents. It is a very

large document.

THE PRESIDENT: Could you tell us what it is or who signed it? It is a

very long document, apparently, is it?

MR. JUSTICE JACKSON: It is a long document, and it is a report of the

Oberfeldkommandant—L-i-l-l-e is the name of the signer.

Now, coming to the question...

THE PRESIDENT: Let me look at the document, will you?

You see, Mr. Justice Jackson, my attention has been drawn to the point

that as far as the record is concerned, we have only this extract which

you read. We have not got the date, and we do not have the signature, if

any, on the document.

MR. JUSTICE JACKSON: I was merely refreshing his recollection to get out

the facts, and I was not really offering the document for its own sake.

I will go into more detail about it, if Your Honor wishes. There is a

great deal of irrelevant material in it.

THE PRESIDENT: If you do not want to offer it, then we need not bother

about it.

MR. JUSTICE JACKSON: A great part of it is not relevant.

THE PRESIDENT: Yes.

MR. JUSTICE JACKSON: The quotation is adequately verified.

THE PRESIDENT: In that case you may refer to it without the document

being used. Then we need not have the document identified as an exhibit.

MR. JUSTICE JACKSON: [_Turning to the defendant._] Leaving the question

of your personal participation in these matters and coming to the

questions dealt with in the second part of your examination, I want to

ask you about your testimony concerning the proposal to denounce the

Geneva Convention.

You testified yesterday that it was proposed to withdraw from the Geneva

Convention. Will you tell us who made those proposals?

SPEER: This proposal, as I already testified yesterday, came from Dr.

Goebbels. It was made after the air attack on Dresden, but before this,

from the autumn of 1944 on, Goebbels and Ley had often talked about

intensifying the war effort in every possible way, so that I had the

impression that Goebbels was using the attack on Dresden and the

excitement it created merely as an excuse to renounce the Geneva

Convention.

MR. JUSTICE JACKSON: Now, was the proposal made at that time to resort

to poison gas warfare?

SPEER: I was not able to make out from my own direct observations

whether gas warfare was to be started, but I knew from various

associates of Ley’s and Goebbels’ that they were discussing the question

of using our two new combat gases, Tabun and Sarin. They believed that

these gases would be of particular efficacy, and they did in fact

produce the most frightful results. We made these observations as early

as the autumn of 1944, when the situation had become critical and many

people were seriously worried about it.

MR. JUSTICE JACKSON: Now, will you tell us about these two gases and

about their production and their effects, their qualities, and the

preparations that were made for gas warfare?

SPEER: I cannot tell you that in detail. I am not enough of an expert.

All I know is that these two gases both had a quite extraordinary

effect, and that there was no respirator, and no protection against them

that we knew of. So the soldiers would have been unable to protect

themselves against this gas in any way. For the manufacture of this gas

we had about three factories, all of which were undamaged and which

until November 1944 were working at full speed. When rumors reached us

that gas might be used, I stopped its production in November 1944. I

stopped it by the following means. I blocked the so-called preliminary

production, that is, the chemical supplies for the making of gas, so

that the gas-production, as the Allied authorities themselves

ascertained, after the end of December or the beginning of January,

actually slowed down and finally came to a standstill. Beginning with a

letter which is still in existence and which I wrote to Hitler in

October 1944, I tried through legal methods to obtain his permission to

have these gas factories stop their production. The reason I gave him

was that on account of air raids the preliminary products, primarily

cyanide, were needed urgently for other purposes. Hitler informed me

that the gas production would have to continue whatever happened, but I

gave instructions for the preliminary products not to be supplied any

more.

MR. JUSTICE JACKSON: Can you identify others of the group that were

advocating gas warfare?

SPEER: In military circles there was certainly no one in favor of gas

warfare. All sensible Army people turned gas warfare down as being

utterly insane since, in view of your superiority in the air, it would

not be long before it would bring the most terrible catastrophe upon

German cities, which were completely unprotected.

MR. JUSTICE JACKSON: The group that did advocate it, however, consisted

of the political group around Hitler, didn’t it?

SPEER: A certain circle of political people, certainly very limited. It

was mostly Ley, Goebbels and Bormann, always the same three, who by

every possible means wanted to increase the war effort; and a man like

Fegelein certainly belonged to a group like that too. Of Himmler I would

not be too sure, for at that time Himmler was a little out of favor with

Hitler because he allowed himself the luxury of directing an army group

without being qualified.

MR. JUSTICE JACKSON: Now, one of these gases was the gas which you

proposed to use on those who were proposing to use it on others, and I

suppose your motive was...

SPEER: I must say quite frankly that my reason for these plans was the

fear that under certain circumstances gas might be used, and the

association of ideas in using it myself led me to make the whole plan.

MR. JUSTICE JACKSON: And your reasons, I take it, were the same as the

military’s, that is to say, it was certain Germany would get the worst

of it if Germany started that kind of warfare. That is what was worrying

the military, wasn’t it?

SPEER: No, not only that. It was because at that stage of the war it was

perfectly clear that under no circumstances should any international

crimes be committed which could be held against the German people after

they had lost the war. That was what decided the issue.

MR. JUSTICE JACKSON: Now, what about the bombs, after the war was

plainly lost, aimed at England day after day; who favored that?

SPEER: You mean the rockets?

MR. JUSTICE JACKSON: Yes.

SPEER: From the point of view of their technical production the rockets

were a very expensive affair for us, and their effect compared to the

cost of their output was negligible. In consequence we had no particular

interest in developing the affair on a bigger scale. The person who kept

urging it was Himmler, in this case. He gave one Obergruppenführer

Kammler the task of firing off these rockets over England. In Army

circles they were of the same opinion as I, namely, that the rockets

were too expensive; and in Air Force circles, the opinion was the same,

since for the equivalent of one rocket one could almost build a fighter.

It is quite clear that it would have been much better for us if we had

not gone in for this nonsense.

MR. JUSTICE JACKSON: Going back to the characteristics of this gas, was

one of the characteristics of this gas an exceedingly high temperature?

When it was exploded it created exceedingly high temperature, so that

there could be no defense against it?

SPEER: No, that is an error. Actually, ordinary gas evaporates at normal

atmospheric temperature. This gas would not evaporate until very high

temperatures were reached and such very high temperatures could only be

produced by an explosion; in other words, when the explosives detonated,

a very high temperature set in, as you know, and then the gas

evaporated. The solid substance turned into gas, but the effects had

nothing to do with the high temperature.

MR. JUSTICE JACKSON: Experiments were carried out with this gas, were

they not, to your knowledge?

SPEER: That I can tell you. Experiments must certainly have been carried

out with it.

MR. JUSTICE JACKSON: Who was in charge of the experimentations with the

gases?

SPEER: As far as I know it was the research and development department

of the OKH in the Army ordnance office. I cannot tell you for certain.

MR. JUSTICE JACKSON: And certain experiments were also conducted and

certain researches conducted in atomic energy, were they not?

SPEER: We had not got as far as that, unfortunately, because the finest

experts we had in atomic research had emigrated to America, and this had

thrown us back a great deal in our research, so that we still needed

another year or two in order to achieve any results in the splitting of

the atom.

MR. JUSTICE JACKSON: The policy of driving people out who didn’t agree

with Germany hadn’t produced very good dividends, had it?

SPEER: Especially in this sphere it was a great disadvantage to us.

MR. JUSTICE JACKSON: Now, I have certain information, which was placed

in my hands, of an experiment which was carried out near Auschwitz and I

would like to ask you if you heard about it or knew about it. The

purpose of the experiment was to find a quick and complete way of

destroying people without the delay and trouble of shooting and gassing

and burning, as it had been carried out, and this is the experiment, as

I am advised. A village, a small village was provisionally erected, with

temporary structures, and in it approximately 20,000 Jews were put. By

means of this newly invented weapon of destruction, these 20,000 people

were eradicated almost instantaneously, and in such a way that there was

no trace left of them; that it developed, the explosive developed,

temperatures of from 400° to 500° centigrade and destroyed them without

leaving any trace at all.

Do you know about that experiment?

SPEER: No, and I consider it utterly improbable. If we had had such a

weapon under preparation, I should have known about it. But we did not

have such a weapon. It is clear that in chemical warfare attempts were

made on both sides to carry out research on all the weapons one could

think of, because one did not know which party would start chemical

warfare first.

MR. JUSTICE JACKSON: The reports, then, of a new and secret weapon were

exaggerated for the purpose of keeping the German people in the war?

SPEER: That was the case mostly during the last phase of the war. From

August, or rather June or July 1944 on I very often went to the front. I

visited about 40 front-line divisions in their sectors and could not

help seeing that the troops, just like the German people, were given

hopes about a new weapon coming, new weapons and wonder-weapons which,

without requiring the use of soldiers, without military forces, would

guarantee victory. In this belief lies the secret why so many people in

Germany offered their lives, although common sense told them that the

war was over. They believed that within the near future this new weapon

would arrive. I wrote to Hitler about it and also tried in different

speeches, even before Goebbels’ propaganda leaders, to work against this

belief. Both Hitler and Goebbels told me, however, that this was no

propaganda of theirs but that it was a belief which had grown up amongst

the people. Only in the dock here in Nuremberg, I was told by Fritzsche

that this propaganda was spread systematically among the people through

some channels or other, and that SS Standartenführer Berg was

responsible for it. Many things have become clear to me since, because

this man Berg, as a representative of the Ministry of Propaganda, had

often taken part in meetings, in big sessions of my Ministry, as he was

writing articles about these sessions. There he heard of our future

plans and then used this knowledge to tell the people about them with

more imagination than truth.

MR. JUSTICE JACKSON: When did it become apparent that the war was lost?

I take it that your attitude was that you felt some responsibility for

getting the German people out of it with as little destruction as

possible. Is that a fair statement of your position?

SPEER: Yes, but I did not only have that feeling with regard to the

German people. I knew quite well that one should equally avoid

destruction taking place in the occupied territories. That was just as

important to me from a realistic point of view, for I said to myself

that after the war the responsibility for all these destructions would

no longer fall on us, but on the next German Government, and the coming

German generations.

MR. JUSTICE JACKSON: Where you differed with the people who wanted to

continue the war to the bitter end, was that you wanted to see Germany

have a chance to restore her life. Is that not a fact? Whereas Hitler

took the position that if he couldn’t survive, he didn’t care whether

Germany survived or not?

SPEER: That is true, and I would never have had the courage to make this

statement before this Tribunal if I had not been able to prove it with

the help of some documents, because such a statement is so monstrous.

But the letter which I wrote to Hitler on 29 March, in which I confirmed

this, shows that he said so himself.

MR. JUSTICE JACKSON: Well, if I may comment, it was not a new idea to us

that that was his viewpoint. I think it was expressed in most of the

other countries that that was his viewpoint.

Now, were you present with Hitler at the time he received the telegram

from Göring, suggesting that Göring take over power?

SPEER: On 23 April I flew to Berlin in order to take leave of several of

my associates, and—I should like to say this quite frankly—after all

that had happened, also in order to place myself at Hitler’s disposal.

Perhaps this will sound strange here, but the conflicting feelings I had

about the action I wanted to take against him and about the way he had

handled things, still did not give me any clear grounds or any clear

inner conviction as to what my relations should be toward him, so I flew

over to see him. I did not know whether he knew of my plans, and I did

not know whether he would order me to remain in Berlin. Yet I felt that

it was my duty not to run away like a coward, but to stand up to him

again. It was on that day that Göring’s telegram to Hitler arrived. This

telegram was not to Hitler, but from Göring to Ribbentrop; it was

Bormann who submitted it to him.

MR. JUSTICE JACKSON: Submitted it to Hitler?

SPEER: Yes, to Hitler.

MR. JUSTICE JACKSON: What did Hitler say on that occasion?

SPEER: Hitler was unusually excited about the contents of the telegram,

and said quite plainly what he thought about Göring. He said that he had

known for some time that Göring had failed, that he was corrupt, and

that he was a drug addict. I was extremely shaken, because I felt that

if the head of the State had known this for such a long time, then it

showed a lack of responsibility on his part to leave such a man in

office, when the lives of countless people depended on him. It was

typical of Hitler’s attitude towards the entire problem, however, that

he followed his statement up by saying: “But let him negotiate the

capitulation all the same.”

MR. JUSTICE JACKSON: Did he say why he was willing to let Göring

negotiate the capitulation?

SPEER: No. He said in an offhand manner: “It doesn’t matter anyway who

does it.” He expressed all his disregard for the German nation in the

way he said this.

MR. JUSTICE JACKSON: That is, his attitude was that there was nothing

left worth saving, so let Göring work it out. Is that a fair statement

of his position?

SPEER: That was my impression, yes.

MR. JUSTICE JACKSON: Now, this policy of driving Germany to destruction

after the war was lost had come to weigh on you to such a point that you

were a party to several plots, were you not, in an attempt to remove the

people who were responsible for the destruction, as you saw it, of your

country?

SPEER: Yes. But I want to add...

MR. JUSTICE JACKSON: There were more plots than you have told us about,

weren’t there?

SPEER: During that time it was extremely easy to start a plot. One could

accost practically any man in the street and tell him what the situation

was, and then he would say: “This is insane”; and if he had any courage

he would place himself at your disposal. Unfortunately, I had no

organization behind me which I could call upon and give orders to, or

designate who should have done this or that. That is why I had to depend

on personal conversations to contact all kinds of people. But I do want

to say that it was not as dangerous as it looks here because actually

the unreasonable people who were still left only amounted perhaps to a

few dozen. The other 80 million were perfectly sensible as soon as they

knew what it was all about.

MR. JUSTICE JACKSON: Perhaps you had a sense of responsibility for

having put the 80 million completely in the hands of the Führer

Principle. Did that occur to you, or does it now, as you look back on

it?

SPEER: May I have the question repeated, because I did not understand

its sense.

MR. JUSTICE JACKSON: You have 80 million sane and sensible people facing

destruction; you have a dozen people driving them on to destruction and

they are unable to stop it. And I ask if you have a feeling of

responsibility for having established the Führer Principle, which Göring

has so well described for us, in Germany?

SPEER: I, personally, when I became Minister in February 1942, placed

myself at the disposal of this Führer Principle. But I admit that in my

organization I soon saw that the Führer Principle was full of tremendous

mistakes, and so I tried to weaken its effect. The terrible danger of

the authoritarian system, however, became really clear only at the

moment when we were approaching the end. It was then that one could see

what the principle really meant, namely, that every order should be

carried out without criticism. Everything that has become known during

this Trial in the way of orders carried out without any consideration,

finally proved—for example the carrying-out of the order to destroy the

bridges in our own country—to be a mistake or a consequence of this

authoritarian system. The authoritarian system—or let me put it like

this—upon the collapse of the authoritarian system it became clear what

tremendous dangers there are in a system of that kind, quite apart from

the personality of Hitler. The combination of Hitler and this system,

then, brought about these terrible catastrophes in the world.

MR. JUSTICE JACKSON: Well, now—Hitler is dead; I assume you accept

that—and we ought to give the devil his due. Isn’t it a fact that in

the circle around Hitler there was almost no one who would stand up and

tell him that the war was lost, except yourself?

SPEER: That is correct to a certain extent. Among the military leaders

there were many who, each in his own sphere, told Hitler quite clearly

what the situation was. Many commanders of army groups, for instance,

made it clear to him how catastrophic developments were, and there were

often fierce arguments during the discussions on the situation. Men like

Guderian and Jodl, for instance, often talked openly about their sectors

in my presence, and Hitler could see quite well what the general

situation was like. But I never observed that those who were actually

responsible in the group around Hitler, ever went to him and said, “The

war is lost.” Nor did I ever see these people who had responsibility

endeavor to unite in undertaking some joint step with Hitler. I did not

attempt it for my part either, except once or twice, because it would

have been useless, since at this stage, Hitler had so intimidated his

closest associates that they no longer had any wills of their own.

MR. JUSTICE JACKSON: Well, let us take the Number 2 man, who has told us

that he was in favor of fighting to the very finish. Were you present at

a conversation between Göring and General Galland, in which Göring, in

substance, forbade Galland to report the disaster that was overtaking

Germany?

SPEER: No; in that form, that is not correct. That was another

conference.

MR. JUSTICE JACKSON: Well, tell us what there is about General Galland’s

conversation with Göring, as far as you know it.

SPEER: It was at the Führer’s headquarters in East Prussia in front of

Göring’s train. Galland had reported to Hitler that enemy fighter planes

were already escorting bomber squadrons as far as Liége and that it was

to be expected that in the future the bomber units would travel still

farther from their bases escorted by fighters. After a discussion with

Hitler on the military situation Göring upbraided Galland and told him

with some excitement that this could not possibly be true, that the

fighters could not go as far as Liége. He said that from his experience

as an old fighter pilot he knew this perfectly well. Thereupon Galland

replied that the fighters were being shot down, and were lying on the

ground near Liége. Göring would not believe this was true. Galland was

an outspoken man who told Göring his opinion quite clearly and refused

to allow Göring’s excitement to influence him. Finally Göring, as

Supreme Commander of the Air Force, expressly forbade Galland to make

any further reports on this matter. It was impossible, he said, that

enemy fighters could penetrate so deeply in the direction of Germany,

and so he ordered him to accept that as being true. I continued to

discuss the matter afterward with Galland and Galland was actually later

relieved by Göring of his duties as Commanding General of Fighters. Up

to this time Galland had been in charge of all the fighter units in

Germany. He was the general in charge of all the fighters within the

High Command of the Air Force.

THE PRESIDENT: What is the date of that?

MR. JUSTICE JACKSON: I was going to ask.

SPEER: It must have been toward the end of 1943.

THE PRESIDENT: Mr. Justice Jackson, perhaps we had better adjourn now.

[_A recess was taken._]

MR. JUSTICE JACKSON: If it please the Tribunal, I wanted to ask you

whether it was known in the days when you were struggling for manpower

enough to make armaments for Germany, that Göring was using manpower to

collect art and transport art for his own purposes. Was that known to

you at the time?

SPEER: He did not need many workers for that purpose.

MR. JUSTICE JACKSON: Well, very few were very valuable, were they not?

SPEER: The art treasures were valuable, not the workers.

MR. JUSTICE JACKSON: To him?

SPEER: Yes.

MR. JUSTICE JACKSON; Well, let me ask you about your efforts in

producing, and see how much difficulty you were having. Krupp’s was a

big factor in the German armament production, was it not?

SPEER: Yes.

MR. JUSTICE JACKSON: The biggest single unit, wouldn’t you say?

SPEER: Yes, but not—just to the extent I said yesterday. It produced

few guns and armaments, but it was a big concern, one of the most

respected ones in the armament industry.

MR. JUSTICE JACKSON: But you had prevented, as far as possible, the use

of resources and manpower for the production of things that were not

useful for the war, is not that true?

SPEER: That is true.

MR. JUSTICE JACKSON: And the things which were being created, being

built in Krupp’s, whether they were guns or other objects, were things

which were essential to carrying on the economy or to conducting the

war? That would be true, would it not?

SPEER: Generally speaking one can say that in the end every article

which in wartime is produced in the home country, whether it is a pair

of shoes for the workers, or clothing, or coal is, of course—is made to

assist in the war effort. That has nothing to do with the old

conception, which has long since died out, and which we find in the

Geneva Prisoner of War Convention.

MR. JUSTICE JACKSON: Well, at the moment I am not concerned with the

question of the application of the Geneva Convention. I want to ask you

some questions about your efforts to produce essential goods, whether

they were armament or not armament, and the conditions that this regime

was imposing upon labor and adding, as I think, to your problem of

production. I think you can give us some information about this. You

were frequently at the Krupp plant, were you not?

SPEER: I was at the Krupp plant five or six times.

MR. JUSTICE JACKSON: You had rather close information as to the progress

of production in the Krupp plant, as well as others?

SPEER: Yes, when I went to visit these plants, it was mostly in order to

see how we could do away with the consequences of air attacks. It was

always shortly after air raids, and so I got an idea of the production.

As I worked hard I knew a lot about these problems, right down to the

details.

MR. JUSTICE JACKSON: Krupp also had several labor camps, did they not?

SPEER: Of course, Krupp had labor camps.

MR. JUSTICE JACKSON: Krupp was a very large user of both foreign labor

and prisoners of war?

SPEER: I cannot give the percentage, but no doubt Krupp did employ

foreign workers and prisoners of war.

MR. JUSTICE JACKSON: Well, I may say to you that we have investigated

the Krupp labor camps, and from Krupp’s own charts it appears that in

1943 they had 39,245 foreign workers and 11,234 prisoners of war, and

that this steadily increased until in September 1944 Krupp had 54,990

foreign workers and 18,902 prisoners of war.

Now, would that be somewhere near what you would expect from your

knowledge of the industry?

SPEER: I do not know the details. I do not know the figures of how many

workers Krupp employed in all. I am not familiar with them at the

moment. But I believe that the percentage of foreign workers at Krupp

was about the same as in other plants and in other armament concerns.

MR. JUSTICE JACKSON: And what would you say that percentage was?

SPEER: That varied a great deal. The old established industries which

had their old regular personnel had a much lower percentage of foreign

workers than the new industries which had just grown up and which had no

old regular personnel. The reason for this was that the young age groups

were drafted into the Armed Forces and therefore the concerns which had

a personnel of older workers still retained a large percentage of the

older workers. Therefore the percentage of foreign workers in Army

armaments, if you take it as a whole and as one of the older industries,

was lower than the percentage of foreign workers in air armaments,

because that was a completely new industry which had no old regular

personnel.

But with the best will in the world I cannot give you the percentage.

MR. JUSTICE JACKSON: Now, the foreign workers who were assigned to

Krupp—let us use Krupp as an example—were housed in labor camps and

under guard, were they not?

SPEER: I do not believe that they were under guard, but I cannot say. I

do not want to dodge giving information here, but I had no time to worry

about such things on my visits. The things I was concerned about when I

went to a factory were in an entirely different sphere. In all my

activities as Armament Minister I never once visited a labor camp, and

cannot, therefore, give any information about them.

MR. JUSTICE JACKSON: Well now, I am going to give you some information

about the labor camp at Krupp’s, and then I am going to ask you some

questions about it. And I am not attempting to say that you were

personally responsible for these conditions. I merely give you the

indications as to what the regime was doing and I am going to ask you

certain questions as to the effect of this sort of thing on your work of

production.

Are you familiar with Document D-288, which is United States Exhibit

202, the affidavit of Dr. Jäger, who was later brought here as a

witness?

SPEER: Yes, but I consider that somewhat exaggerated.

MR. JUSTICE JACKSON: You don’t accept that?

SPEER: No.

MR. JUSTICE JACKSON: Well, you have no personal knowledge of the

conditions. What is the basis of your information that Dr. Jäger’s

statement is exaggerated?

SPEER: If such conditions had existed, I should probably have heard of

them, since when I visited plants the head of the plant naturally came

to me with his biggest troubles. These troubles occurred primarily after

air raids when, for example, both the German workers and foreign workers

had no longer any proper shelter. This state of affairs was then

described to me, so that I know that what is stated in the Jäger

affidavit cannot have been a permanent condition. It can only have been

a condition caused temporarily by air raids, for a week or a fortnight,

and which was improved later on. It is clear that after a severe air

raid on a city all the sanitary installations, the water supply, gas

supply, electricity, and so on, were out of order and severely damaged,

so that temporarily there were very difficult conditions.

MR. JUSTICE JACKSON: I remind you that Dr. Jäger’s affidavit relates to

the time of October 1942, and that he was a witness here. And, of

course, you are familiar with his testimony.

SPEER: Yes.

MR. JUSTICE JACKSON: Well now, I call your attention to a new document,

which is D-361, and would become United States Exhibit 893, a document

signed by the office chief of the locomotive construction works,

describing conditions of his labor supply, foreign labor.

And I am not suggesting—I repeat I am not suggesting that this was your

responsibility. I am suggesting it is the responsibility of the regime.

I should like to read this despite its considerable length. This is

dated at the boilermaking shop, 25 February 1942, addressed to Hupe by

way of Winters and Schmidt.

“I received the enclosed letter of the 18th of this month from

the German Labor Front, sent to my private address, inviting me

to the Office of the German Labor Front. I tried to settle the

business, which I did not know about, by telephone. The answer

from the German Labor Front was that the matter was very

important and called for my personal appearance. Thereupon I

asked Herr Jüngerich of the Department for Social Labor Matters

whether I had to go. He answered, ‘You probably do not have to,

but it would be better if you went.’ About 9:50 I went to Room

20 at the place indicated and met Herr Prior.

“The following provided the subject of this conversation, which

Herr Prior carried on in a very excited manner, and which lasted

about half an hour:

“On the 16th, 23 Russian prisoners of war were assigned to

Number 23 Boiler Shop. The people came in the morning without

bread and tools. During both breaks the prisoners of war crept

up to the German workers and begged for bread, pitifully

pointing out their hunger. (For lunch on the first day the

factory was able to distribute among the Russians rations which

remained over from French PW’s.) In order to alleviate these

conditions, I went to the Weidkamp kitchen on the 17th, on

instructions from Herr Theile, and talked to the head of the

kitchen, Fräulein Block, about the provision of the midday meal.

Fräulein Block promised me the food immediately, and also lent

me the 22 sets of eating utensils which I asked for. At the same

time I asked Fräulein Block to give any food left over by the

800 Dutchmen messing there to our Russian PW’s at noon until

further notice. Fräulein Block promised to do this too, and the

following noon she sent down a container of milk soup as an

extra. The following noon the ration was short in quantity.

Since a few Russians had collapsed already, I telephoned

Fräulein Block and asked for an increase in the food, as the

special ration had ceased from the second day onwards. As my

telephone conversation was unsuccessful, I again visited

Fräulein Block personally. Fräulein Block refused in a very

abrupt manner to give any further special ration.

“Now, regarding the discussion in detail, Herr Prior, two other

gentlemen of the DAF and Fräulein Block, head of the Weidkamp

kitchen, were present in the room. Herr Prior commenced and

accused me, gesticulating, and in a very insulting manner, of

having taken the part of the Bolsheviks in a marked way. He

referred to the law paragraphs of the Reich Government which

spoke against it. I was unfortunately not clear about the legal

position, otherwise I would have left the conference room

immediately. I then tried to make it clear to Herr Prior, with

special emphasis, that the Russian PW’s were assigned to us as

workers and not as Bolsheviks; the people were starved and not

in a position to perform the heavy work with us in the boiler

shop which they were supposed to do; sick people are a dead

weight to us and not a help to production. To this remark Herr

Prior stated that if one was no good, then another was; that the

Bolsheviks were a soulless people; and if 100,000 of them died,

another 100,000 would replace them. On my remarking that with

such a coming and going we would not attain our goal, namely the

delivery of locomotives to the Reichsbahn, who were continually

cutting down the time limit, Herr Prior said, ‘Deliveries are

only of secondary importance here.’

“My attempts to get Herr Prior to understand our economic needs

were not successful. In closing, I can only say that as a German

I know our relations to the Russian prisoners of war exactly,

and in this case I acted only on behalf of my superiors and with

the view to the increase in production which is demanded from

us.”

It is signed, “Söhling, Office Chief, Locomotive Construction Works.”

And there is added this letter as a part of the communication, signed by

Theile:

“I have to add the following to the above letter:

“After the Russian PW’s had been assigned to us on the 16th of

this month by labor supply, I got into touch with Dr. Lehmann

immediately about their food. I learned from him that the

prisoners received 300 gr. of bread each between 0400 and 0500

hours. I pointed out that it was impossible to last until 1800

hours on this ration of bread, whereupon Dr. Lehmann said that

the Russians must not be allowed to get used to western European

feeding. I replied that the PW’s could not do the work required

of them in the boiler shop on that food, and that it was not

practical for us to have these people in the works any longer

under such conditions. At the same time I demanded that if the

Russians continued to be employed, they should be given a hot

midday meal, and that if possible the bread ration should be

split so that one-half was distributed early in the morning and

the second half during our breakfast break. My suggestion has

already been carried out by us with the French PW’s and has

proved to be very practicable and good.

“Unfortunately, however, Dr. Lehmann took no notice of my

suggestion, and on this account I naturally had to take matters

into my own hands and therefore told Herr Söhling to get the

feeding of the Russian PW’s organized on exactly the same lines

as for the French PW’s, so that the Russians could as soon as

possible carry out the work they were supposed to do. For the

whole thing concerns an increase in production such as is

demanded from us by the Minister of munitions and armaments and

by the DAF.”

Now, I ask you, in the first place, if the position of the chief of the

locomotive construction works was not entirely a necessary position in

the interests of production?

SPEER: It is clear that a worker who has not enough food cannot achieve

a good work output. I already said yesterday that every head of a plant,

and I too at the top, was naturally interested in having well-fed and

satisfied workers, because badly fed, dissatisfied workers make more

mistakes and produce poor results.

I should like to comment on this document. The document is dated 25

February 1942. At that time there were official instructions that the

Russian workers who came to the Reich should be treated worse than the

western prisoners of war and the western workers. I learned of this

through complaints from the heads of concerns. In my document book,

there is a Führer protocol which dates from the middle of March

1942—that is, 3 or 4 weeks after this document—in which I called

Hitler’s attention to the fact that the feeding both of Russian

prisoners of war and of Russian workers was absolutely insufficient and

that they would have to be given an adequate diet, and that moreover the

Russian workers were being kept behind barbed wire like prisoners of war

and that that would have to be stopped also. The protocol shows that in

both cases I succeeded in getting Hitler to agree that conditions should

be changed and they were changed.

I must say furthermore that it was really to Sauckel’s credit that he

fought against a mountain of stupidity and did everything so that

foreign workers and prisoners of war should be treated better and

receive decent food.

MR. JUSTICE JACKSON: Well, we will go on with the conditions later.

Because I am going to ask you, if you are not responsible and Sauckel is

not responsible, who is responsible for these conditions, and you can

keep it in mind that is the question that we are coming up to here.

I will show you a new document, which is a statement, D-398, which would

be Exhibit USA 894-A, taken by the British-American team in the

investigation of this work camp at Krupp’s.

Well, D-321. I can use that just as well. We will use Document D-321,

which becomes 893.

THE PRESIDENT: 894 was the last number you gave us. What number is this

document that you are now offering?

MR. JUSTICE JACKSON: 398 was 894. 321 will be 895.

Now, this relates to the—this is an employee of the Reich Railways.

None of our investigation, I may say, is based upon the statements of

the prisoners themselves.

“I, the undersigned, Adam Schmidt, employed as Betriebswart on

the Essen-West Railway Station and residing ... state

voluntarily and on oath:

“I have been employed by the Reich Railways since 1918 and have

been at Essen-West Station since 1935. In the middle of 1941 the

first workers arrived from Poland, Galicia, and the Polish

Ukraine. They came to Essen in trucks in which potatoes,

building materials and also cattle had been transported, and

were brought to perform work at Krupp’s. The trucks were jammed

full with people. My personal view was that it was inhuman to

transport people in such a manner. The people were packed

closely together and they had no room for free movement. The

Krupp overseers laid special value on the speed with which the

slave workers got in and out of the trucks. It was enraging for

every decent German who had to watch this to see how the people

were beaten and kicked and generally maltreated in a brutal

manner. In the very beginning when the first transport arrived

we could see how inhumanly these people were treated. Every

truck was so overfilled that it was incredible that such a

number of people could be jammed into one. I could see with my

own eyes that sick people who could scarcely walk (they were

mostly people with foot trouble, or with injuries, and people

with internal trouble) were nevertheless taken to work. One

could see that it was sometimes difficult for them to move. The

same can be said of the Eastern Workers and PW’s who came to

Essen in the middle of 1942.”

He then describes their clothing and their food. In the interest of

time, I will not attempt to read the entire thing.

Do you consider that that, too, is an exaggerated statement?

SPEER: When the workers came to Germany from the East, their clothing

was no doubt bad, but I know from Sauckel that while he was in office a

lot was done to get them better clothes, and in Germany many of the

Russian workers were brought to a considerably better condition than

they had previously been in in Russia. The Russian workers were quite

satisfied in Germany. If they arrived here in rags, that does not mean

that that was our fault. We could not use ragged workers with poor shoes

in our industry, so conditions were improved.

MR. JUSTICE JACKSON: Well, now, I would like to call your attention to

D-398.

THE PRESIDENT: Well, before you pass from that, what do you say about

the conditions of the transports? The question you were asked was

whether this was an exaggerated account. You have not answered that

except in reference to clothing.

SPEER: Mr. President, I cannot give any information about this transport

matter. I received no reports about it.

MR. JUSTICE JACKSON: Well, I will ask you about Exhibit 398, which

becomes USA-894. I mean Document 398, which becomes Exhibit 894, a

statement by Höfer, living in Essen:

“From April 1943 I worked with Löwenkamp every day in Panzer

Shop 4. Löwenkamp was brutal to the foreigners. He confiscated

food which belonged to the PW’s and took it home. Every day he

maltreated Eastern Workers, Russian PW’s, French, Italian, and

other foreign civilians. He had a steel cabinet built which was

so small that one could hardly stand in it. He locked up

foreigners in the box, women too, for 48 hours at a time without

giving the people food.

“They were not released even to relieve nature. It was forbidden

for other people, too, to give any help to the persons locked

in, or to release them. While clearing a concealed store he

fired on escaping Russian civilians without hitting any of them.

“One day, while distributing food, I saw how he hit a French

civilian in the face with a ladle and made his face bleed.

Further, he delivered Russian girls without bothering about the

children afterwards. There was never any milk for them so the

Russians had to nourish the children with sugar water. When

Löwenkamp was arrested he wrote two letters and sent them to me

through his wife. He tried to make out that he never beat

people.”

There is a good deal more of this, but I will not bother to put it into

the record.

Is it your view that that is exaggerated?

SPEER: I consider this affidavit a lie. I would say that among German

people such things do not exist, and if such individual cases occurred

they were punished. It is not possible to drag the German people in the

dirt in such a way. The heads of concerns were decent people too, and

took an interest in their workers. If the head of the Krupp plant heard

about such things, he certainly took steps immediately.

MR. JUSTICE JACKSON: Well, what about the steel boxes? The steel box

couldn’t have been built? Or don’t you believe the steel-box story?

SPEER: No, I do not believe it; I mean I do not believe it is true.

After the collapse in 1945 a lot of affidavits were certainly drawn up

which do not fully correspond to the truth. That is not your fault. It

is the fault of—after a defeat, it is quite possible that people lend

themselves to things like that.

MR. JUSTICE JACKSON: Well, I would like to have you examine Document

258, and I attach importance to this as establishing the SS as being the

guards:

“The camp inmates were mostly Jewish women and girls from

Hungary and Romania. The camp inmates were brought to Essen at

the beginning of 1944 and were put to work at Krupp’s. The

accommodation and feeding of the camp prisoners was beneath all

dignity. At first the prisoners were accommodated in simple

wooden huts. These huts were burned down during an air raid and

from that time on the prisoners had to sleep in a damp cellar.

Their beds were made on the floor and consisted of a

straw-filled sack and two blankets. In most cases it was not

possible for the prisoners to wash themselves daily, as there

was no water. There was no possibility of having a bath. I could

often observe from the Krupp factory, during the lunch break,

how the prisoners boiled their under-clothing in an old bucket

or container over a wood fire, and cleaned themselves. An

air-raid trench served as shelter, while the SS guards went to

the Humboldt shelter, which was bombproof. Reveille was at 5 a.

m. There was no coffee or any food served in the morning. They

marched off to the factory at 5.15 a. m. They marched for

three-quarters of an hour to the factory, poorly clothed and

badly shod, some without shoes, and covered with a blanket, in

rain or snow. Work began at 6 a. m. The lunch break was from 12

to 12:30. Only during the break was it at all possible for the

prisoners to cook something for themselves from potato peelings

and other garbage. The daily working period was one of 10 or 11

hours. Although the prisoners were completely undernourished,

their work was very heavy physically. The prisoners were often

maltreated at their work benches by Nazi overseers and female SS

guards. At 5 or 6 in the afternoon they were marched back to

camp. The accompanying guards consisted of female SS who, in

spite of protests from the civil population, often maltreated

the prisoners on the way back with kicks, blows, and scarcely

repeatable words. It often happened that individual women or

girls had to be carried back to the camp by their comrades owing

to exhaustion. At 6 or 7 p. m. these exhausted people arrived

back in camp. Then the real meal was distributed. This consisted

of cabbage soup. This was followed by the evening meal of water

soup and a piece of bread which was for the following day.

Occasionally the food on Sundays was better. As long as it

existed there was never any inspection of the camp by the firm

of Krupp. On 13 March 1945 the camp prisoners were brought to

Buchenwald Concentration Camp, from there some were sent to

work. The camp commandant was SS Oberscharführer Rick. His

present whereabouts is unknown.”

The rest of it doesn’t matter. In your estimation that, I suppose, is

also an exaggeration?

SPEER: From the document...

DR. FLÄCHSNER: Mr. President...

THE PRESIDENT: May I hear the answer. I thought the defendant said

something.

DR. FLÄCHSNER; May I call the attention of the Court to the document

itself, of which I have only a copy? It is headed “Sworn on oath before

a military court,” and there is an ordinary signature under it. It does

not say that it is an affidavit or a statement in lieu of oath, or any

other such thing, it says only, “Further inquiries must be made,” and it

is signed by Hubert Karden. That is apparently the name of the man who

was making the statement. Then there is another signature,

“Kriminalassistent Z. Pr.” That is a police official who is on probation

and who may later have the chance of becoming a candidate in the

criminal service. He has signed it. Then there is another signature, “C.

E. Long, Major, President.” There is not a word in this document to the

effect that any of these three people want to vouch for the contents of

this as an affidavit. I do not believe this document can be used as an

affidavit in that sense.

THE PRESIDENT: Yes, Mr. Justice Jackson? Do you wish to say anything?

MR. JUSTICE JACKSON: I—the document shows for itself. I am not—as I

have pointed out to this witness, I am giving him the result of an

investigation. I am not prosecuting him with personal responsibility for

these conditions. I intend to ask him some questions about

responsibility for conditions in the camp.

THE PRESIDENT: Well, there is a statement at the top of the copy that I

have got, “Sworn on oath before a military court.”

MR. JUSTICE JACKSON: Yes, they were taken in Essen, in this

investigation. And of course, if I were charging this particular

defendant with the responsibility there might be some argument about it.

They come under the head—they clearly come under the head of the

Charter, which authorizes the receipt here of proceedings of other

courts.

THE PRESIDENT: Have you got the original document here?

MR. JUSTICE JACKSON: Yes.

[_A document was submitted to the Tribunal._]

THE PRESIDENT: The Tribunal sees no objection to the document being used

in cross-examination.

Did you give it an exhibit number?

MR. JUSTICE JACKSON: I should have; it is USA-896.

THE PRESIDENT: Yes.

MR. JUSTICE JACKSON: [_Turning to the defendant._] I now want to call

your attention to Exhibit Number 382.

SPEER: I wanted to comment on the document.

THE PRESIDENT: Mr. Justice Jackson, there are some photographs which

have been put before us. Are they identified and do they form part of an

exhibit?

MR. JUSTICE JACKSON: They form part of the exhibit which I am now

offering.

THE PRESIDENT: I see.

MR. JUSTICE JACKSON: But the witness desires to comment on the last

document, and I will listen to that before we go ahead.

Yes?

SPEER: First I should like to say, as you have so often mentioned my

nonresponsibility, that if in general these conditions had been true, on

the basis of my statement yesterday I should consider myself

responsible. I refuse to evade responsibility. But the conditions were

not what they are said to have been here. There are only individual

cases which are quoted.

As for this document I should only like to say from what I have seen of

it that this seems to concern a concentration camp, one of the small

concentration camps near the factories. The factories could not inspect

these camps. That is why the sentence is quite true where it says that

no factory representative ever saw the camp. The fact that there were SS

guards also shows that it was a concentration camp.

If the question which you asked me before, as to whether the labor camps

were guarded—those for foreign workers—if that refers to this

document, then your conclusion was wrong. For as far as I know, the

other labor camps were not guarded by SS or by any other organizations.

My position is such that I feel it is my duty to protect the heads of

plants from any injustice which might be done them. The head of a plant

could not bother about the conditions in such a camp. I cannot say

whether conditions were as described in this camp. We have seen so much

material on conditions in concentration camps during the Trial.

MR. JUSTICE JACKSON: Now I will ask to have you shown Exhibit Number

D-382—I should say Document D-382—which would be United States Exhibit

897. Now that is the statement of several persons as to one of those

steel boxes which stood in the foreign workers’ camp in the grounds of

Number 4 Armor Shop, and of those in the Russian camp. I do not know

that it is necessary to read the complete descriptions.

Is that merely an individual instance, or what is your view of that

circumstance?

SPEER: What is pictured here is quite a normal locker as was used in

every factory. These photographs have absolutely no value as evidence.

MR. JUSTICE JACKSON: Very well. I will ask to have you shown Exhibit

D-230. Together with D-230 is an interoffice record of the steel

switches, and the steel switches which have been found in the camp will

be shown to you. Eighty were distributed, according to the reports.

SPEER: Shall I comment on this?

MR. JUSTICE JACKSON: If you wish.

SPEER: Yes. Those are nothing but replacements for rubber truncheons. We

had no rubber; and for that reason, the guards probably had something

like this.

MR. JUSTICE JACKSON: That is the same inference that I drew from the

document.

SPEER: Yes, but the guards did not immediately use these steel switches

any more than your police use their rubber truncheons. But they had to

have something in their hands. It is the same thing all over the world.

MR. JUSTICE JACKSON: Well, we won’t argue that point.

SPEER: I am not an expert. I only assume that that is the case. I cannot

testify on oath that that was the case. That was only an argument.

THE PRESIDENT: Did you give a number to that?

MR. JUSTICE JACKSON: 898, Your Honor.

Now, 899 would be our Document D-283, which is a 1943 report from the

Krupp hospitals taken from the files of Krupp’s.

“The subject:

“Cases of Deaths of Eastern Workers.

“Fifty-four Eastern Workers have died in the hospital in

Lazarettstrasse, 4 of them as a result of external causes and 50

as a result of illness.

“The causes of death in the case of these 50 Eastern Workers who

died of illnesses were the following: Tuberculosis, 36

(including 2 women); malnutrition, 2; internal hemorrhage, 1;

disease of the bowels, 2; typhoid fever, 1 (female); pneumonia,

3; appendicitis, 1 (female); liver trouble, 1; abscess of the

brain, 1. This list therefore shows that four-fifths died of

tuberculosis and malnutrition.”

Now, did you have any reports from time to time as to the health

conditions of the labor which was engaged in your production program?

SPEER: First I should like to comment on the document. The document does

not show the total number of the workers to which the number of deaths

refers, so that one cannot say whether that is an unnaturally high

proportion of illness. At a session of the Central Planning Board which

I read here again, I observed it was said that among the Russian workers

there was a high rate of tuberculosis. I do not know whether you mean

that. That was a remark which Weiger made to me. But presumably through

the health offices we tried to alleviate these conditions.

MR. JUSTICE JACKSON: There was an abnormally high rate of deaths from

tuberculosis; there is no doubt about that, is there?

SPEER: I do not know whether that was an abnormal death rate. But there

was an abnormally high rate of tuberculosis at times.

MR. JUSTICE JACKSON: Well, the exhibit does not show whether the death

rate itself was abnormally high, but it shows an abnormal proportion of

deaths from tuberculosis among the total deaths, does it not? Eighty

percent deaths from tuberculosis is a very high incidence of

tuberculosis, is it not?

SPEER: That may be. I cannot say from my own knowledge.

MR. JUSTICE JACKSON: Now I would like to have you shown...

THE PRESIDENT: Did you give that a number? That would be 899, would it

not?

MR. JUSTICE JACKSON: 899, Your Honor.

Now, let me ask you to be shown Document D-335. This is a report from

the files of Krupp, dated at Essen on 12 June 1944, directed to the “Gau

Camp Physician, Herr Dr. Jäger,” and signed by Stinnesbeck:

“In the middle of May I took over the medical supervision of the

PW Camp 1420 in the Nörggerathstrasse. The camp contains 644

French PW’s.

“During the air raid on 27 April of this year the camp was

largely destroyed and at the moment conditions are intolerable.

“315 prisoners are still accommodated in the camp. 170 of these

are no longer in huts, but in the tunnel in Grunerstrasse on the

Essen-Mülheim railway line. This tunnel is damp and is not

suitable for continued accommodation of human beings. The rest

of the prisoners are accommodated in 10 different factories in

Krupp’s works.

“Medical attention is given by a French military doctor who

takes great pains with his fellow countrymen. Sick people from

Krupp’s factories must be brought to the sick parade too. This

parade is held in the lavatory of a burned-out public house

outside the camp. The sleeping accommodations of the four French

medical orderlies is in what was the urinal room. There is a

double tier wooden bed available for sick bay patients. In

general, treatment takes place in the open. In rainy weather it

has to be held in this small room. These are insufferable

conditions! There are no chairs, tables, cupboards, or water.

The keeping of a register of sick is impossible.

“Bandages and medical supplies are very scarce, although people

badly hurt in the works are often brought here for first aid and

have to be bandaged before being taken to the hospital. There

are many strong complaints about food, too, which the guard

personnel confirm as being justified.

“Illness and less manpower must be reckoned with under these

circumstances.

“The construction of huts for the accommodation of the prisoners

and the building of sick quarters for the proper treatment of

the sick persons is urgently necessary.

“Please take the necessary steps.

“(Signed) Stinnesbeck.”

SPEER: That is a document which shows what conditions can be after

severe air raids. The conditions were the same in these cases for

Germans and foreign workers. There were no beds, no cupboards, and so

forth. That was because the camp in which these things had been provided

had been burned down. That the food supply was often inadequate in the

Ruhr district during this period was due to the fact that attacks from

the air were centered on communication lines, so that food transports

could not be brought into the Ruhr to the necessary extent. These were

temporary conditions which we were able to improve when the air raids

ceased for a time. When conditions became even worse after September or

October of 1944, or rather after November of 1944, we made every effort

to give food supplies the priority for the first time over armament

needs, so that in view of these difficulties the workers would be fed

first of all, while armaments had to stand back somewhat.

MR. JUSTICE JACKSON: Well, then you did make it your business to get

food and to see to the conditions of these workers? Do I understand that

you did it, that you took steps?

SPEER: It is true that I did so, and I am glad that I did, even if I am

to be reproached for it. For it is a universal human obligation when one

hears of such conditions to try to alleviate them, even if it is

somebody else’s responsibility. But the witness Riecke testified here

that the whole of the food question was under the direction of the Food

Ministry.

MR. JUSTICE JACKSON: And it was an essential part of production, was it

not, to keep workers in proper condition to produce? That is elementary,

is it not?

SPEER: No. That is wrongly formulated.

MR. JUSTICE JACKSON: Well, you formulate it for me as to what the

relation is between the nourishment of workers and the amount of

production produced.

SPEER: I said yesterday that the responsibility for labor conditions was

divided up between the Food Ministry, the Health Office in the Reich

Ministry of the Interior, the Labor Trustee in the office of the

Plenipotentiary General for the Allocation of Labor, and so on. There

was no comprehensive authority in my hands. In the Reich, because of the

way in which our state machine was built up, we lacked a comprehensive

agency in the form of a Reich Chancellor, who would have gathered all

these departments together and held joint discussions. But I, as the man

responsible for production, had no responsibility in these matters.

However, when I heard complaints from factory heads or from my deputies,

I did everything to remove the cause of the complaints.

MR. JUSTICE JACKSON: The Krupp works...

THE PRESIDENT: Shall we break off now?

MR. JUSTICE JACKSON: Any time you say, Sir.

[_The Tribunal recessed until 1400 hours._]

_Afternoon Session_

THE PRESIDENT: The Tribunal wish to hear from, defendants’ counsel what

arrangements they have found it possible to make with reference to the

apportionment of time for their speeches.

DR. NELTE: I should like first of all to point out that the defendants’

counsel, with whom the Tribunal discussed the question of final defense

speeches during an earlier closed session, did not inform the other

defendants’ counsel, since they were under the impression that the

Tribunal would not impose any restrictions on the Defense in this

respect. I personally, when I raised my objections, had no knowledge of

this discussion, as my colleagues who conferred with you earlier have

authorized me to explain.

On the suggestion of the Tribunal, counsel for the individual defendants

have discussed the decision announced in the session of 13 June 1946,

and I am now submitting to the Tribunal the outcome of the discussion;

in doing so, however, I shall have to make certain qualifications, since

some of my colleagues are either not present or differ in their opinion

on the apportionment of time.

The defendants’ counsel are of the opinion that only the conscientious

judgment of each counsel can determine the form and length of the final

defense pleas in this unusual Trial, notwithstanding the generally

recognized right of the Tribunal, as part of its responsibility for

guiding the proceedings, to prevent a possible misuse of the freedom of

speech. They also believe that, in view of this fundamental

consideration and in view of the usual practice of international courts,

the Tribunal will understand and approve that the defendants’ counsel

voice their objection to a preventive restriction of the freedom of

speech, for a misuse on their part must not simply be taken as a

foregone conclusion. This fundamental attitude is, of course, in accord

with the readiness of the Defense to comply with the directives and the

wishes of the Tribunal as far as is reconcilable with a proper

conception of the defense in each case. Under this aspect the individual

defendants’ counsel have been asked to make their own estimates of the

probable duration of their final pleas. The result of these estimates

shows that, despite the limitations counsel have imposed upon

themselves, and with due respect to the wishes of the High Tribunal, a

total duration of approximately 20 full days in court is required by the

Defense.

THE PRESIDENT: Dr. Nelte, the Tribunal asked Defense Counsel for an

apportionment of the 14 days between them.

DR. NELTE: I believe, Mr. President, my statement makes clear that it

appears impossible to accept that principle. If the Tribunal consider

these 14 full days as indisputable, then the entire Defense will submit

to that decision. But so far as I know, it will be quite impossible,

under such circumstances, to obtain agreement among Defense Counsel, and

considerable danger therefore exists that counsel who make their pleas

later will be under pressure of time.

THE PRESIDENT: Yes, I think the Tribunal probably fully understands that

you think 14 days—you and your brethren consider that 14 days is too

short—but, as I say, what the Tribunal asked for was an apportionment

of the time, and there is nothing in what you have said to indicate that

you have made any apportionment at all, either of the 14 days or of the

20 days which you propose.

DR. NELTE: The period of 20 days was arrived at when each defendant’s

counsel had stated the presumed duration of his speech. It would,

therefore, be perfectly possible to say that if the Tribunal would

approve the duration of 20 days, then we could state our solution for

the length of the individual speeches. But it is impossible, in

practice, to apportion the time, if the total number of days is only 14.

You can rest assured, Mr. President, that we have all gone into the

question conscientiously and that we have also reflected on the manner

in which individual subjects can be divided among individual defendants’

counsel; but the total number of about 20 days appears to us, without

wanting to quote a maximum or minimum figure, to be absolutely essential

for an apportionment. It is perfectly possible, Mr. President, that in

the course of the speeches...

THE PRESIDENT: Dr. Nelte, as I have indicated to you, what the Tribunal

wanted to know was the apportionment, and presumably you have some

apportionment which adds up to the 20 days which you say is required;

and the Tribunal would like, if you have such an apportionment, that you

should let them see the apportionment, or if you have no such

apportionment, then they would wish to hear from each individual counsel

how long he thinks he is going to take. If you have got a list, it seems

to the Tribunal that you could hand it in.

DR. NELTE: The figures are available and they will be handed to the

Tribunal, but some of my colleagues have said that their estimates are

only valid on the assumption that no more than a specific number of days

was to be granted. That is the point of view of which I said earlier

that it differed in some respect. But we all thought that the decision

of the Tribunal was only a suggestion, and not a maximum to be

apportioned. I hope, Mr. President, that your words now are also to be

understood in that way, and that the Tribunal will still consider

whether the proposed period of 14 days could not be extended to

correspond with the time which we consider necessary.

THE PRESIDENT: What the Tribunal wants is an apportionment of the time

as between the various counsel. That is what they asked for and that is

what they want; and either we would ask you to give it to us in writing

now, or we would ask you, each one of you, to state how long you

anticipate you will take in your speech.

DR. NELTE: I think that I may speak on behalf of my colleagues and say

that we shall submit our estimates to the Tribunal in writing.

THE PRESIDENT: Dr. Nelte, the Tribunal feels that it would like to have

the apportionment now. It gave notice before, yesterday I think it was,

that they were wishing to hear defendants’ counsel upon the question of

the apportionment this afternoon at 2 o’clock; and they would,

therefore, like to have that apportionment now.

DR. NELTE: In that case, I can only ask that the Tribunal hear each

individual counsel, since naturally I cannot say from memory how each

made his estimate.

THE PRESIDENT: You could have had it written down; but if you have not

got it written down, no doubt you cannot remember. But perhaps you had

better give us what you would take.

DR. NELTE: I estimated 7 hours. My colleague Horn, for Ribbentrop, just

tells me he requires 6 hours.

THE PRESIDENT: We will take each counsel in turn, if you please.

Yes, Dr. Stahmer?

DR. OTTO STAHMER (Counsel for Defendant Göring): Seven hours.

THE PRESIDENT: Dr. Sauter?

DR. MARTIN HORN (Counsel for Defendant Von Ribbentrop): May I, on behalf

of Dr. Siemers and Dr. Kranzbühler, ask to allot each of them 8 hours?

DR. SAUTER: For the case of Funk, 6 hours, and for the case of Von

Schirach, 6 hours.

DR. SERVATIUS: For Sauckel, 5 hours.

THE PRESIDENT: Wait a minute. I cannot write as quickly as all this. Who

was it that Dr. Horn wished to represent? Siemers and who else? And how

many hours was it?

DR. HORN: Dr. Siemers and Dr. Kranzbühler, 8 hours each.

DR. SERVATIUS: For Sauckel, 5 hours.

DR. KAUFFMANN: For Kaltenbrunner, approximately 4 to 5 hours.

DR. HANNS MARX (Counsel for Defendant Streicher): For Streicher, 4

hours.

DR. SEIDL: For Hess and Frank, 11 hours together.

DR. OTTO PANNENBECKER (Counsel for Defendant Frick): For Frick, 5 hours.

I remember from the list that Dr. Bergold wants 3 hours for Bormann. Dr.

Bergold is not present, but I remember that the list said 3 hours.

DR. RUDOLF DIX (Counsel for Defendant Schacht): For Schacht, 5 hours.

PROFESSOR DR. FRANZ EXNER (Counsel for Defendant Jodl): For Jodl, 5

hours.

DR. KUBUSCHOK: For Papen, approximately 5 hours.

DR. STEINBAUER: For Dr. Seyss-Inquart, 5 hours.

DR. FLÄCHSNER: For Speer, 4 hours.

DR. VON LÜDINGHAUSEN: For myself, Mr. President, 8 hours. For Professor

Jahrreiss, who before the final pleas will deal with a technical

subject, 4 hours.

THE PRESIDENT: What will Professor Jahrreiss speak about?

DR. VON LÜDINGHAUSEN: About a subject approved by the Tribunal, namely

the general question of international law.

DR. SEIDL: The defense counsel for the Defendant Rosenberg said that he

would require 8 hours.

DR. FRITZ: Mr. President, I would ask the Tribunal to take into

consideration that the case of Fritzsche has not yet been presented and

that therefore I cannot give exact information; but I estimate

approximately 4 hours.

THE PRESIDENT: Now, Dr. Nelte, the Tribunal would like to know first of

all whether counsel propose to write down and then read their speeches.

DR. NELTE: As far as I have been informed, all defense counsel will

write down their speeches before delivery. Whether they will actually

read every word of the text, or whether they will read parts of it and

submit other parts, is not yet certain.

THE PRESIDENT: Have they considered whether they will submit them for

translation, because, as the Tribunal has already pointed out, it would

be much more convenient for the members of the Tribunal who do not read

German to have a translation before them. It would not only greatly

assist the Tribunal, but the defendants themselves if they do that.

DR. NELTE: This question has not yet been settled. We discussed it, but

have so far not come to a final conclusion. We think that the short time

now available may perhaps make it impossible to translate the

manuscripts into all four languages.

THE PRESIDENT: The defendants’ counsel, of course, understand that the

speeches, if they are submitted for translation, will not be

communicated to anybody until the speech is actually made. So they will

not be given beforehand either to the Tribunal or the Prosecution or

anything of that sort, so that the speech will remain entirely private

until it is made. And the second thing is that, of course, a great

number of the speeches will be delayed by the counsel who precede them

and, therefore, there will be very considerable time during either the

14 days or some longer period, if such a longer period is given, which

will enable the speeches to be translated, and Defense Counsel will

appreciate that if their speeches are written down they can tell exactly

how long they will take to deliver, or almost exactly.

And there is one other thing I want to bring to their attention. There

are 20 or 21 defendants, and naturally, there are a variety of subjects

which are common to them all; and there ought to be, therefore, an

opportunity, as it appears to the Tribunal, for counsel to divide up the

subjects to some extent between them and not each one to deal with

subjects which have been dealt with already, any more than they ought to

have been dealt with in evidence over and over again; and I do not know

whether Counsel for Defense have fully considered that in making this

estimate of the time they laid before us.

Anyway, the Tribunal hopes that they will address their minds to these

three matters: First of all, as to whether they can submit their

speeches for translation in order to help the Tribunal; secondly,

whether they will be able, when they have got their speeches written

down, to assess the time accurately; and thirdly, whether they cannot

apportion the subjects to some extent among them so that we shall not

have to listen to the same subjects over and over again.

I do not know whether the Prosecution would wish to say anything. The

Tribunal has said, I think, in the order which we made with reference to

this question of limitation of time, that they anticipated, that the

Prosecution would take only 3 days. Perhaps it would be convenient to

hear from the Prosecution whether that is an accurate estimate.

SIR DAVID MAXWELL-FYFE: Yes, My Lord, the Prosecution do not ask for any

more than the 3 days. It might conceivably be a little less, but we do

not ask for any more than the 3 days.

MR. JUSTICE JACKSON: I should like, Your Honor, to call your attention

to this. I hope it is not expected that we will mimeograph and run off

on our mimeograph machines, 20 days of speeches or anything of that

sort. We simply cannot be put under that kind of a burden. I think it

is—a citizen of the United States is expected to argue his case in the

highest court of the land in one hour, and counsel’s own clients here

have openly scoffed at the amount of time that has been asked. This is

not a sensible amount of time to give to this case, and I must protest

against being expected to mimeograph 20 days of speeches. It really is

not possible.

THE PRESIDENT: The Tribunal would like to know whether the Prosecution

intend to let them have copies of their speeches at the time that they

are delivered.

SIR DAVID MAXWELL-FYFE: As far as the closing speech of the Attorney

General is concerned, we certainly did expect and hope to give the

Tribunal copies of the speech.

THE PRESIDENT: And translations?

SIR DAVID MAXWELL-FYFE: Yes, that will be done. My Lord, I just

wondered, out of optimism—it was Dr. Nelte who said that it would take

a long time to translate. I know, as far as translating into English is

concerned, we had the problem of a 76-page speech the other day, and

that was done by our own translators in one day. So I hope that perhaps

Dr. Nelte has been a little pessimistic about that side of the problem.

THE PRESIDENT: The Tribunal will consider the matter.

Now, the Tribunal will go on with the cross-examination.

[_The Defendant Speer resumed the stand._]

MR. JUSTICE JACKSON: I think perhaps, Your Honor, the photographs in

evidence are left a little unintelligible, if the record does not show

the description of them. I shall read it briefly.

“Torture cabinets which were used in the foreign workers’ camp

in the grounds of Number 4 Armor Shop and those in the dirty

neglected Russian Camp were shown to us, and we depose the

following on oath:

“Photograph ‘A’ shows an iron cupboard which was specially

manufactured by the firm of Krupp to torture Russian civilian

workers to an extent that cannot possibly be described by words.

Men and women were often locked into a compartment of the

cupboard, in which hardly any man could stand up for long

periods. The measurements of this compartment are: Height 1.52

meters; breadth and depth 40 to 50 centimeters each. Frequently

even two people were kicked and pressed into one compartment.

The Russian....”

I will not read the rest of that.

“Photograph ‘B’ shows the same cupboard as it looks when it is

locked.

“Photograph ‘C’ shows the cupboard open.

“In Photograph ‘D’ we see the camp that was selected by the

Krupp Directorate to serve as living quarters for the Russian

civilian workers. The individual rooms were 2 to 2½ meters wide,

5 meters long, and 2 meters high. In each room up to 16 persons

were accommodated in double tier beds.” (Document USA-897)

I think that covers it.

THE PRESIDENT: Mr. Justice Jackson, one moment. I think you ought to

read the last three lines of the second paragraph, beginning, “At the

top of the cupboard....”

MR. JUSTICE JACKSON: Oh yes, I am sorry.

“At the top of the cupboard there are a few sievelike air holes

through which cold water was poured on the unfortunate victims

during the ice-cold winter.”

THE PRESIDENT: I think you should read the last three lines of the

penultimate paragraph in view of what the defendant said about the

evidence.

MR. JUSTICE JACKSON: “We are enclosing two letters which Camp

Commandant Löwenkamp had smuggled out of prison in order to

induce the undersigned Höfer to give evidence favorable to him.”

And perhaps I should read the last:

“The undersigned, Dahm,”—one of the signers—“personally saw

how three Russian civilian workers were locked into the

cupboard, two in one compartment, after they had first been

beaten on New Year’s Eve 1945. Two of the Russians had to stay

the whole of New Year’s Eve locked in the cupboard, and cold

water was poured on them as well.”

I may say to the Tribunal that we have upwards of a hundred different

statements and depositions relating to the investigation of this camp. I

am not suggesting offering them, because I think they would be

cumulative, and I shall be satisfied with one more, D-313, which would

become Exhibit USA-901, which is a statement by a doctor.

THE PRESIDENT: Mr. Justice Jackson, was this camp that you are referring

to a concentration camp?

MR. JUSTICE JACKSON: Well, it was, as I understand it, a prisoner-of-war

camp and a labor camp. There were labor camps and prisoner-of-war camps

at Essen. I had not understood that it was a concentration camp, but I

admit the distinction is a little thin at times.

This document reads:

“I, the undersigned, Dr. Apolinary Gotowicki, a physician in the

Polish Army, was taken prisoner by the Germans on 3 January 1941

and remained as such until the entry of the Americans. I gave

medical attention to the Russian, Polish, and French prisoners

of war who were forced to work in various places of Krupp’s

factories. I personally visited the Russian PW camp in the

Raumastrasse in Essen, which contained about 1,800 men. There

was a big hall in the camp which could house about 200 men

comfortably, in which 300 to 400 men were thrown together in

such a catastrophic manner that no medical treatment was

possible. The floor was cement and the mattresses on which the

people slept Were full of lice and bugs. Even on cold days the

room was never heated and it seemed to me, as a doctor, unworthy

of human beings that people should find themselves in such a

position. It was impossible to keep the place clean because of

the overcrowding of these men who had hardly room to move about

normally. Every day at least 10 people were brought to me whose

bodies were covered with bruises on account of the continual

beatings with rubber tubes, steel switches, or sticks. The

people were often writhing with agony and it was impossible for

me to give them even a little medical aid. In spite of the fact

that I protested, made complaints and petitions, it was

impossible for me to protect the people or see that they got a

day off from work. It was difficult for me to watch how such

suffering people could be dragged to do heavy work. I visited

personally, with danger to myself, gentlemen of the Krupp

administration, as well as gentlemen from the Krupp Directorate,

to try to get help. It was strictly forbidden, as the camp was

under the direction of the SS and Gestapo; and according to

well-known directives I had to keep silent, otherwise I might

have been sent to a concentration camp. I have brought my own

bread innumerable times to the camp in order to give it to the

prisoners, as far as it was possible, although bread was scarce

enough for me. From the beginning in 1941 conditions did not get

better, but worse. The food consisted of a watery soup which was

dirty and sandy, and often the prisoners of war had to eat

cabbage which was bad and stank. I could notice people daily

who, on account of hunger or ill-treatment, were slowly dying.

Dead people often lay for 2 or 3 days on the beds until their

bodies stank so badly that fellow prisoners took them outside

and buried them somewhere. The dishes out of which they ate were

also used as toilets because they were too tired or too weak

from hunger to get up and go outside. At 3 o’clock they were

wakened. The same dishes were then used to wash in and later for

eating out of. This matter was generally known. In spite of this

it was impossible for me to get even elementary help or

facilities in order to get rid of these epidemics, illnesses, or

cases of starvation. There can be no mention of medical aid for

the prisoners. I never received any medical supplies myself. In

1941 I alone had to look after these people from a medical point

of view; but it is quite understandable that it was impossible

for me as the only one to look after all of these people, and

apart from that, I had scarcely any medical supplies. I could

not think what to do with a number of 1,800 people who came to

me daily crying and complaining. I myself often collapsed daily,

and in spite of this I had to take everything upon myself and

watch how people perished and died. A report was never made as

to how the prisoners of war died.

“I have seen with my own eyes the prisoners coming back from

Krupp’s and how they collapsed on the march and had to be

wheeled back on barrows or carried by their comrades. It was in

such a manner that the people came back to the camp. The work

which they had to perform was very heavy and dangerous and many

cases happened where people had cut their fingers, hands or

legs. These accidents were very serious and the people came to

me and asked me for medical help. But it was not even possible

for me to keep them from work for a day or two, although I had

been to the Krupp Directorate and asked for permission to do so.

At the end of 1941, two people died daily, and in 1942 the

deaths increased to three and four per day.