Q Witness, within the framework of the activity were Russian prisoners of war ever used to load bombs on aircraft?
A Such an order is not known to me.
Q Were they employed to carry ammunition?
A No.
Q To service anti-aircraft guns?
A Not on the behalf of the GL.
Q But is it known that Russians were ordered to serve anti-aircraft guns?
A I know that Russians were employed in anti-aircraft duties but I cannot recall where they came from - from which sector they were taken.
Q Is it known to you that Milch was opposed to this because he didn't want to lose those people as workers?
AAs I said already, that at this moment I don't know where they came from I should have a little time to think about this.
Q Can you tell us what things belonged to the air armament? What this term was supposed to mean?
AAir armament factories comprised first, aircraft producing factories, second, engine factories, thirdly, producing air intelligence instruments, four, firms of general equipment, five, factories producing ammunition and fire-arms, six, special ammunition factories, eight, ground equipment factories and in addition all repair shops of these various offices and factories.
Q Just a moment please. Witness, the prosecution has submitted a document - this is the report by Himmler of 9 March 1944, correspondence between Goering and Himmler on the employment of concentration camp inmates at the air armament industry. This is exhibit No. 71, Doc. No. 1584 PS and from Document Book 4 of the Prosecution concerning the Jaegerstab.
Exhibit No. 71, it's the fourth exhibit reading from the top in that book. I would ask the Court to look at the table which is attached at the top--which is attached to the document. Witness, it is said here as aerial industry the anti-aircraft staff Auschwitz. Was that part of the air armament?
A No.
Q The east Machine Factory -- the GMBH -- was that part of the air industry?
959-A
A. No, the production of anti-aircraft guns was part of the Waffen -the armament office.
Q. Siemens & Schuckert, Auschwitz, at first completion of plant, later switch and control instruments for night fighters.
A. I do not know that factory. I couldn't say exactly; that factory is net known to me.
Q. The Erla Machine Factory, the MBH?
A. Yes, that was part of it.
Q. Was the Junkers Flug and Motorwerk at Schoenobeck?
A. Yes, they were.
Q. The Bolde-Arnstadt?
A. That was weapons office.
Q. Light metal work Braudenbach?
A. At Werdinger Rode?
Q. Yes.
A. Yes.
A. Then Dachau? It says here high frequency.
A. High frequency development?
Q. Had that anything to do with aerial armament? I refer to highfrequency development work.
A. I only knew no institute in Ober*fafien hofen. This one I do not know.
Q. Page 63 of the document bock. The BMW Munich Allach? and the Durnier plant? Were they part?
A. Yes, they were.
Q. Engineer Dr. Kimmel of Munich. How about that factory?
A. I do not know if the Kimmel factory was a part of it.
Q. The Air Force Research Institute, in Munich is shown here. Is that a part of the aerial industry in Munich?
A. I do not know that one.
Q. How about the Mosserschmitt works?
A. They were a part.
Q. The Air Force Planning Office at Sudelfeld?
A. I did not know it.
Q. Breezifix, Dachau?
A. Breezifix, in my opinion, worked for several branches of the Wehrmacht.
Q. What about the Sachse Company at Kempten?
A. They were sub-suppliers. They work not commissioned by GL. They were sub-suppliers.
Q. Deutsche Erd-und Stein Werke?
A. Yes, I know about this.
Q. Spare parts were produced?
A. Spare parts were produced for the Regensburg factory.
Q. Starting at what date?
A. That I do not know. I only heard about this during a journey. I believe it was in March 1944. The Regensburg works had been attacked and became decentralized after that. Apparently part of its work was trans ferred there.
Q. GL had no influence on this?
A No. The firms did that independently.
Q How about the Ceramic Works, Bohemia in Neurolau? Plane parts production.
A He is a sub-supplier.
Q Luftfahrtgeraetewerk, Zwodau? (Aeroplane Equipment Works).
A That is unknown to me.
Q Then, once again, Deutsche Erd Steinwerke G.m.b.H. at Herzogenbusch, airplane assembling plant, for repair of aeroplane motors.
A Oh, yes.
Q That is a stripping plant?
A Yes.
Q Had that anything to do with GL?
A These factories, at that time, were -- it is hard for me to answer the question at this time. I would have to refresh my memory first. I really do not know what the state of affairs was at that time. This was a sub-supplier without knowledge of the GL.
Q Then Deutsches Erd & Steinberg Werk at Mauthausen, airplane parts for Messerschmitt.
A Could only be a sub-supplier.
Q Flugmotoren G.m.b.H., Wiener-Neudorf? Initially construction measures, later airplane parts.
A That again most likely was a sub-supplier.
Q Heinkelwerke ?
A Yes.
Q They were ?
A Yes.
Q This time the plant in Natzweiler?
A This is a stripping plant.
Q Jastramm? Bergedorf, Hamburg and Neuedamme, airplane parts.
A That was a factory for equipment.
Q Did that belong to the GL or was it a supplying works?
A It was a supplying works.
Q 962 Q Dassag G.m.b.H. in Hamburg which manufactures magnetos?
A I do not know about that. r
Q How about the Air Ministry testing ground at Ragensbruck? Construction measures.
A It is not known to me.
Q Geraete Werk Bommen G.m.b.H.?
A Not known to me.
They produce aerial terpedoes?
A Oh, yes.
Q Then the Heinkelwerke. Then Mechanische Werkstatte G.m.b.H., Neubrandenburg?
JUDGE MUSMANNO: Dr. Bergold, might you suggest to the Tribunal just what 962a relevancy this has to the charges in the indictment against the defendant?
DR. BERGOLD: He is charged with having employed prisoners and concentration camp inmates. For that reason the prosecution has submitted this document.
JUDGE MUSSMANO: Can you not with some few direct specific questions draw from this witness whatever he knows on those charges?
DR. BERGOLD: I only wanted to acquaint him with this sort of list before I go into detailed questions; however, I have reached the conclusion. I can easily stop here.
Q Witness, in all these factories concentration camp inmates were employed. Was this done by order of the GL? Did the GL know at all that that happened?
A The employment of these concentration camp inmates has not been done by order of the GL. I said before that the GL had no influence on which workers were put at his disposal.
Q Did he hear about the details of this?
A He did not hear about the details but I, myself, found this out while on an official journey. Whether this was known to the different officials I do not know. It was not known in our office to this extent.
Q You heard about this during an official trip in the spring of 1944. Did you report to Milch about this or did you omit to do this?
A Immediately after this, the Jaegerstab was founded, everything was changed.
Q You did not report about this at all, did you?
A No.
Q Do you know the agreement with the French about the construction of aircraft?
A I know there was an agreement with France at that time. In that agreement the quota of five to one was decided upon.
Q Is it correct that Milch, as early as 1942, fought against Sauckel's withdrawing workers from French air armament factories?
A Yes, he did. This taking away of workers from factories was a disadvantage to us, because when Sauckel took his first measures of returning the workers from France we did not only lose these workers. All the other ran away for fear that a second recruitment would occur and the factories in France almost stood at a standstill.
These factories were the basis for the availability of our airfleet in France; therefore, considerable arguments followed. This measure mas ridiculous because these workers who were experts of aircraft construction could not be employed in Germany in the same branch of their work, but had to be employed in completely alien fields, such as the construction of tanks.
Q. Were you ever present at meetings of the Central Planning Board?
A. No. I was never present.
Q. Witness, on 8 April 1943 Milch wrote to the Plenipotentiary for the Four Year Plan the following letter.
DR. BERGOLD: Your Honors, this is Exhibit Number 49 and Document Number NOKW 287. It is in Volume 2-C of the Prosecution's document book. In the German document book it is 136. It is a letter dated 8 April 1943. In the index of document book 2, it is the 11th exhibit, reading from the top. I am sorry, I have made a mistake. On the second page of the index
THE PRESIDENT: It is Exhibit 49. We have it.
DR. BERGOLD: Very well.
Q. Witness, this is a letter to the Plenipotentiary of the Four Year plan, Commissioner for the Allocation of Labor.
"The continuously increasing drafting of German members of the staff, from the production as well as from the security teams (plant protection and plant fireguards), make it necessary to assign more and more foreign labor to the factories of the armament industry. This assignment of foreign labor offers special tasks to the plants of the armament industry with regard to security measures which can no longer be guaranteed with the forces at present at the disposal of the industry."
"Therefore, you are urgently requested to direct the labor offices to place at the disposal of the armament plants upon their request as quickly as possible the competent forces for protection and fire guards, because otherwise normal security in the plants can no longer be guaranteed.
Witness, by this request, did that mean that those people should guard the foreigners or were they meant for protection against sabotage, theft, espionage or fire?
A I do not know the letter.
Q What do you mean by plant protection?
A Protection of the works was an organization --
MR. DENNEY: Your Honor please, he has now read him the letter which the witness did not write, and the witness said he does not know of the letter, and he is now asking him to interpret the letter, which I submit is going far afield, and I think he has certainly been given a lot of latitude up to now.
DR. BERGOLD: I don't think I have asked him about the letter. I am merely asking him about a technical term, that is, "What is plant protection," that the witness knows from his own specialized knowledge.
THE PRESIDENT: You could have asked him that without reading him the letter.
DR. BERGOLD: I thought he know about the letter, and he could make a specific statement. Had I known this, I would have asked him direct.
THE PRESIDENT: All right, ask him now what the term "plant protection" means.
BY DR. BERGOLD: What is plant protection?
A Plant protection is to protect the plant. In the first place the Security Service to avoid theft and to provide the protection at night, guard the entrances, etc.
Q But watching prisoners of war was not their task?
A No, it was not.
Q Do you know the term "Slacker"? (Bummolanten)
A Yes, they were German or foreign workers; I recall that at one of the meetings, the questions of bummolanten, slackers, was very thoroughly discussed. There were some difficulties at the time because of the current fluctuations among the workers.
THE PRESIDENT: Now the question was, what does the word "slacker" mean, and he starts out on a long story about somebody holding a meeting.
965a
DR. BERGOLD: He wanted to explain that was where he heard the term for the first time.
THE PRESIDENT: You did not ask him that.
DR. BERGQLD: Quite right. That is a German characteristic, never to answer a question direct. It unfortunately is a German mistake, and I can not change it.
THE PRESIDENT: Then we concede it is a bad habit.
DR. BERGOLD: It is probably a different kind of an attitude which you take towards the question in Germany, and which you think of differently in America. He merely do it differently in Germany. It is a national difference. I don't wish to decide whether it is better of verse.
THE PRESIDENT: Neither do I, but I think we will just fellow the American order, whether it is for the better or worse, of requiring an answer to the question directly.
BY DR. BERGOLD: Witness, would you please be mere specific?
A Yes, between the terms of "slacker" and "loafer", the leafer means people who had been under duty to work for a long time, and wanted to return to their families, of course, and, therefore, used opportunity to run away without permission, and certainly guarded against that on the other hand to provide the work near his family. The term "slacker" were those who did not like to work, who tried to change their place of work, to get an increase of ration tickets and food supplies, and thereby, to get easier terms of living.
Q Thank you. Were those German workers, or foreign ones?
A These were Germans. Both categories.
Q Did they take any measures against such people, or did they hand them over to Himmler, to place them into a concentration camp?
A I could not say anything about this. It is not within my memory any more.
Q. In your opinion was Milch in a position to hang or shoot foreign workers who did not appear for work, or have cruelties inflicted upon them?
A. No.
Q. Or the transfer to a concentration camp?
A. No.
Q. In the German Aircraft Industry, in the last year of the war, were there many cases of sabotage or espionage, or any sabotage eases at all?
966 A
A. In the industry itself, espionage occurred only in a very small measure. I myself only remember very few important cases of sabotage which in my opinion occurred early in 1944. For the rest not one case of sabotage was known to me which might have endangered the production program.
Q. Witness, is it right that when factories were bombed, the foreign workers voluntarily aided to combat the fires?
A. Yes, I recall reports submitted by the firms which stated that the foreigners had volunteered their help in saving the equipment --- the firms stressed this help.
Q. Do you know that at the time the Jaegerstab was founded, Milch made a statement that because of his nervous complaint he wanted to retire as soon as possible from his office?
A. This statement is not known to me because I was travelling when the Jaegerstab was founded.
Q. Witness, in the exhibit we find the expression of planning --central planning, planning office of the GL, planning office of the Armament Ministry; now were they identical with each other?
A. No, these offices had nothing to do with each other.
Q. Were they not subordinate to the same command?
A. No, they were offices of a completely different --of completely different designations, and they were not part of the Air Ministry.
Q. Can you tell me who ordered that certain factories should be transferred underground; did Milch order this, or somebody else?
A. No, the GL so far as I recall it was in no position to issue such an order. I am not quite clear whether this order was issued by Goering, or by Hitler.
Q. Do you know Mich's attitude towards this?
A. I believe that it was discussed to the effect that a great number of workers is needed, which should be used for protection purposes.
Q. Do you know if the GL recruited foreign workers in occupied territories?
A. The GL himself had no permission to recruit foreign workers.
Q. Were you a member of the Jaegerstab?
A. I was ordered by Field Marshall Milch to take part in conferences of the Jaegerstab in order to report to him about them.
Q. Did the Jaegerstab have authority to recruit foreign workers in occupied territories?
A. The question in this form I can not answer. The situation was such that the Jaegerstab consisted of members of various offices, and these representatives had to execute in their offices the decisions of the Jaegerstab, or, if the execution was not possible, had to give a sound reason why.
Q. Did the Jaegerstab unanimously decide upon the recruiting of foreign workers?
A. Not that I know of.
Q. Is it right to say that before the Jaegerstab was founded, the Air Armament was at a disadvantage in the whole framework?
A. Yes.
Q. Thank you very much. There is a teletype letter of Goering's here in which he applied to Himmler for concentration camp workers. He wrote it on 14 February 1944; do you know of that letter?
A. No, I don't know of the letter.
Q. The Contral Planning Board once gave to the Jaegerstab an extra allocation of steel plate arms. Was that for airplane production, or for construction for O.T.
A. I don't know of that particular allocation but the O. T. does not use steel plates for construction. It can only have been used for aircraft purposes.
Q. Do you know when the GL began to transfer certain armament works to the overground?
A. This overground transfer started very early, before the GL was in office even. It was taken into consideration right away when industry-planning began.
Q. I come back once more to the Jaegerstab. Did the Jaegerstab have to supervise the building for the SS ******* and the SD, or did the Jaegerstab say who should move into the building?
A. I don't think the Jaegerstab had the supervision of the building. It could, however, decide who should move in.
Q. Do you know whether Herr Stobbee-Detleffsen was a member of the Jaegerstab?
A. I think he was.
Q. What was his task?
A. I could not say at the moment. I should think this over.
Q. Building companies of the Luftwaffe are sometimes mentioned. Are these foreign workers or German soldier companies?
A. The building companies were always German soldiers.
Q. Can you recall whether Milch asked Hitler for miners from Bertesgaden for building purposes?
A. I don't know.
Q. Do you know whether when Hitler had things built in Berchtesgaden foreign workers or Germans only were employed there?
A. I know nothing about this.
Q. Sauckel once gave an estimate. He said that of 5,000,000 workers only 200,000 had come to Germany voluntarily. Do you think that that estimate is correct, or how high would you estimate the figure should be concerning voluntary workers?
A. An estimate is very difficult because these workers were not sent to Germany only for the Luftwaffe but for all sorts of armament. In any case, the figure in my opinion was not very high.
Q. What do you mean not very high? Were they 200,000 or were they more in your opinion?
A. I do not wish to pass any judgment here because I do not know.
Q. Can you describe relations between Goering and Milch?
A. The relations were not very good. There were frequent conflicts. I said before now on the trip to Berchtesgaden there was an argument.
Q. What attitude did Milch take toward his small employees?
A. Milch's attitude was very good. Milch was always nice to his small employees end if they were in difficulties he helped. them.
DR. BERGOLD: For the time being I have no further questions of this witness.
THE. PRESIDENT: The prosecution may cross examine.
CROSS EXAMINATION BY MR. DENNEY:
Q. Witness, Dr. Bergold asked you about a film that was shown in the Air Ministry in Berlin which you saw. Do you recall that?
A. I did not understand the question.
Q. Do you remember Dr. Bergold asking you about a movie which you saw in the Air Ministry in Berlin?
A. Yes, I do.
Q. How long did the movie last?
A. I should say ten minutes or a quarter of an hour.
Q. Ten minutes or a quarter of an hour. Could it have been longer?
A. That is how I estimate it at the moment. After such a long time I cannot commit myself.
Q. Did they have a lecture after the movie was over?
A. No.
Q. Was it a talking moving picture? Did it have a sound track with it?
A. As far as I recall, it was not a talking picture.
Q. In other words, it was a silent film?
A. Yes. At any rate, I believe so.
Q. So, you saw a movie that lasted fifteen minutes, and there was no lecture afterwards, and it was silent. Was there any lecture before the movie?
A. No.
Q. Did you talk to anybody about the movie before you went to see it?
A. At the end we were told briefly, as I said before, that the experimental person was a prisoner who, because of heavy crimes, volunteered in order to save his life. That was all.
Q. And you went in and stayed ten or fifteen minutes end saw a movie and then came out, is that right?
A. Yes.
Q. Do you remember telling the Court that after 35 or 40 minutes the person who was the experimental subject was normal?
A. Yes. That was the greatest duration of the experiment. The film, of course, was interrupted at times in order to press the pictures together.
Q. Or in order to take some out.
A. Take out? No. I saw distinctly that the person experimented on was alive when reaching the ground.
Q. How was the man dressed in the picture?
A. I cannot describe the uniform. I don't know what nation he belonged to. It was a suit which had no insignia on it and which did not point to any particular nation.
Q. Was it a military uniform?
A. It was some sort of uniform, a kind of working uniform.
Q. Do you recall who was at the meeting other than yourself?
A. What meeting are you referring to?
Q. Where you saw the movie.
A. Do you mean the meeting while the film was being shown? There was no such meeting.
Q. Did you go in there alone to see it?
A. No, I said before that at regular intervals films of a secret content or of a technical nature were shown and a certain circle was asked to take part, and that was the sort of film on that occasion.
Q. Well, who were the certain circle of persons who were asked to take part?
A. That circle of persons was usually the same.
Q. Who were the circle of persons? If they were the same ones, you ought to remember them.
A. Yes.
Q. You told Dr. Bergold that you couldn't. You can tell us who they were.
A. I can recall that Colonel Pendele was one of them and Colonel Angermund. They were both adjutants. I came in when the film was just starting. It was dark and I cannot recall the other persons right now.
Q. Well, if they were the same people who went to all of these films, you must have at sometime been in there when it was not dark, so who were they? You can remember Pendele and Angermund. Who else?
A. The state of affairs was such that a certain circle of persons was admitted to these films. It is obvious that they did not all turn up. The number of people present changed. People who had nothing else to do usually attended. What I meant before by saying that the participants were always the same was that the circle of persons who were allowed to take part - that was a definite rule.
Q. Were any SS people there?
A. No.
Q. All Luftwaffe people?
A. They were all films that were shown within a small circle of the Luftwaffe.
Q. Answer the question, witness. I said were they all Luftwaffe people who were there. You talk to me about films. Don't do that. Were they all Luftwaffe people?
A. I saw only Luftwaffe people.
Q. Did you ever see the defendant at any of these films?
A. I think I saw him once during a technical film but not at the film being referred to. He certainly was not present then.
Q Now that wasn't very technical, was it?
A No
Q You said, I believe, at the beginning, that you were a general engineer; at least that's what came through the -
A Yes.
Q Are you a graduate engineer?
A Yes.
Q And are you a professional soldier?
A I am a professional soldier; yes.
Q How long have you been in the army?
A I was with tho Luftwaffe from -- Should I give my military career?
Q Well, no. No; I don't want you to go into that. Just toll me when you went in the army. What year?
A In the last war I was an infantry officer -
Q Will you just answer the question? What year did you enter the Army? It must be 19 hundred and something.
A I was first a technical employee of the army and then later with the technical office of the Air Ministry, and when the engineer corps of the Luftwaffe was founded, in 1936, I was taken into the engineer corps.
Q That's all I wanted to know. In 1936 you entered the army; is that right as a soldier?
A Yes.
Q How did you find out that these people in the movie were people who were very bad criminals?
A That was explained to us, briefly, at tho end of the film, as I said before.
Q Now, you visited some of these plants in connection with the Generalluftzeugmeisterwerke, and you said that everybody was happy there; were there foreign workers in some of the plants you were in?
A Yes.
Q They were all happy?
A Yes; they were happy.
Q Where did they live?
A They lived in huts. They were accomodated in huts; some of them in firm stone buildings.