Q. Do you know whether at that time, there was discussion about breaking through the maginot line from Italy and that this should be studied.
A. That, too, I cannot recall.
Q. Witness, do you know that at the end of the conference, Goering began a discussion regarding what the various parts of the Wehrmacht had to do in the way of construction, what the ship-building program was and what years the armaments program should be oriented toward?
A. I cannot recall that nor can I imagine that it took place, because in General, Hitler's conferences were not subsequently discussed.
Q. In other words, it was not usual that discussion should take place after such a conference?
A. So far as I can recall, no.
Q. One more question, was there any discussion of invading Holland, Belgium or wanting to coerce them to take up arms against England or to make their harbors available to Germany?
A. I can say nothing precise on that subject, but I could not believe it was at that time. Later, however, there was considerable discussion of that.
DR. BERGOLD: No further questions.
CROSS-EXAMINATION BY MR. DENNEY:
Q. You say the conference lasted two or three hours?
A. Yes, I have said that I believe that would be approximately correct.
Q. And you were on duty as Adjutant; is that correct?
A. Yes, as one of the adjutants of the Wehrmacht branches.
Q. With whom did you come to the meeting?
A. Really, I went to the Conference alone; there were a large number of participants. We really only had ordnance matters to discuss at that conference.
Q. How many people who were there, do you recall?
A. I believe I can say that the high commander of the different branches of the Wehrmacht, were certainly there, I am sure that Colonel-General von Brauchitsch was present. As far as I recall, the chiefs of the General Staff were also present: Colonel General Halder, I believe; General Jeschennek; Grand Admiral Raeder was there, from the Navy. His Chief of Staff was there, whose name I do not know, any longer. A few other gentlemen whom I cannot recall, exactly. Let me emphasize, again, that it was more than eight years ago
Q. Well, how many would you say were there total, at the Conference, how many made up the party?
A. I should estimate, from ten to twelve persons.
Q. Well, you were a captain then, weren't you?
A. Yes.
Q. So that you must have gone there as an Aide to somebody. After all, if Hitler had all these people come, and there were only twelve of them, he didn't reach down into the Hauptmann, and bring you there alone, did he?
A. No, I said I was the Adjutant in the Wehrmacht and was responsible to the High Commander of the Army, and we were to arrange matters for the Army that was to come.
Q. That was von Brauchitsch?
A. Yes; and the General Staff; those who were members of the Army.
1359 A MR. DENNEY: I do not think the translation come out correct; you mean "Halder", did you not?
THE WITNESS: "H-a-l-d-e-r"; also yes.
MR. DENNEY: Did you make any notes of this conference?
A. No; I took no notes.
Q. And you never talked to anybody about it, afterwards?
A. Oh, yes, I probably did. We probably spoke about it, among ourselves.
Q. Were you in end out of the meeting?
A. Yes; that is always done, because the telephone had to be serviced. Some documents had to be brought in, that is true of every conference.
Q. But the ones that go out and fetch things, are the Junior officers, are they not?
A. No, these are the officers that have to do with ordnance matters; the lower officers.
Q. Yes, That is what I said, the "Junior" officers go out; Hitler wasn't going to run out an bring in anything himself, was he?
A. I couldn't imagine that he would do such a thing.
MR. DENNEY: Nor could I.
Q. Do you know how much of the meeting you were in attendance there, and how much you were out?
A. That I can no longer say.
Q. So that when you told Dr. Bergold that Hitler didn't say something about one subject or the other, you might well have been out of the room when he was talking about that; isn't that true?
A. That is quite possible.
Q. You are just giving us your best recollection, of some thing that happened almost nine years ago; isn't that right?
A. That is right.
Q. Part of the time you were present and part of the time you were absent?
A. Yes; that's right.
MR. DENNEY: No further questions, your Honor.
THE PRESIDENT: Mr. Denney, would you think it relevant to ask him whether Milch was there?
MR. DENNEY: Did you see Field Marshal Milch at the meeting?
A That I cannot say; I can give no information on that.
MR. DENNEY: No further questions.
TNE PRESIDENT: Just one matter further: One of my associates suggested that I ask you whether or not you wish to give us the impression that Milch was not present at this meeting?
THE WITNESS: No. Milch was present.
DR. BERGOLD: No further questions.
MR. DENNEY: Who is your next witness?
DR. BERGOLD: If your Honor please, I wish to call as our next witness: Xavor Dorsch.
XAVOR DORSCH, * witness, took the stand and testified as follows:
BY JUDGE SPEIGHT: Witness, raise your right hand and repeat after me:
"I swear by God, the Almighty and Omniscient, that I will speak the pure truth and will withhold and add nothing."
(The witness repeated the oath.)
JUDGE SPEIGHT: You may be seated.
DIRECT EXAMINATION BY DR. BERGOLD:
Q Please state to the court your first and last name?
A Xavor Dorsch.
Q When were you born?
A 24th of December, 1899.
Q What was your last position in the German Reich?
A I was Chief of the Todt Organization, in the Speer Ministry.
Q On the 28th of December 1943, you signed an affidavit, can you recall?
A Yes, sir.
DR. BERGOLD: Your Honor, this is Exhibit No. 74, Document NOKW 447, in the Document Book Four of the Prosecution.
1361-A The PRESIDENT:
That is on page 151 of the Document Book Four.
DR. BERGOLD: Yes, your Honor.
Q Witness, you made the following statement:
"As deputy of Minister Speer in his capacity as Chief of the Todt Organization, I received from Hitler at the end of April 1944 an order to construct with the OT six bombproof fighter factories, of which two should have priority." Can you tell me about the history of this construction?
A Yes, but I must go into detail.
Q Proceed.
AApproximately eight months before this date, I made a suggestion to Minister Speer as to how bombproof factories above around could be built, in this way; not only that they could secure manufacture, but would also be more secure against bomb damage. The source of this idea came from the Todt Organization which had built a similar building for the manufacture of these tools in France. Speer told me that I should take the plans with me on my next visit to the Fuehrer's headquarters, and two weeks later I was with Speer, visiting Hitler, and after other matters had been discussed -- discussions were hold about the Atlantic Wall at that time -- and before going, Speer mentioned this matter and Hitler says: "We must absolutely achieve bombproof aircraft protection and construction for the Luftwaffe because the danger is so great that transportation can be attached, and then we cannot make up the time we have lost." Hitler wanted large-sized, large-scale units, in which planes and fighters could be protected from the beginning to the end, because he saw a danger in the fact that transportation could be Attacked and interrupted, and then the different parts if they were made in various factories could not be assembled any longer.
To said that be imagined the matter roughly as follows: In narrow mountain valleys in Saxonian Switzerland, for example, caves could be dug which would provide these bombproof factory installations. Then Speer said, "Dorsch, or the OT has another suggestion in regard to this matter," and I then submitted to him my plans for the special OT construction, which as I said had already been built in France, and I also showed him the Dutch factories, which, oven as they were being built, were relatively sure against bomb attack.
This was roughly eight months before this date in April on which this commission of which I spoke in my affidavit was given to me. Hitler said to me that it was a matter of indifference to him according to what system these things were built but that it was important to him that something really constructive should be done.
On the next day there was a discussion on the same subject with Goering. Speer's representative, as Plenipotentiary for Construction Matters, and then the Leador of the Main Committee for Construction, Gaertner, were present. I had to explain again the thought behind this special construction which I was proposing. Goering was greatly enthusiastic and said that that was the solution and that the OT should begin immediately with that construction. There upon Speer said, "The OT cannot build these factories because the OT builds only outside the Reich, with the exception of the Ruhr district, and in the Reich itself the Main Committee for Construction should carry out the construction," and for that reason, he had called the two gentlemen I mentioned above. Goering also said that it was indifferent to him who built the factories, that the important thing was that they should be built soon.
In April of 1944 I was visiting Speer at the so-called "Zoiser Alus" near Horan when a call came that I should go immediately to Hitler.
Speer asked me if I had any idea what was afoot, but I did not. I wont immediately to Berchtesgaden, There Hitler asked me, "What has become of your fighter production?" I told him that I did not know precisely because in the Reich the Todt Organization did not do the constructing but another organization. He was greatly 1363-A excited and said roughly that he had heard enough about this other organization, that he did no want it, and he demanded that the Todt Organization should take over that construction immediately.
Then the plans were fetched overnight from Berlin. I explained the whole system to him once more. I told him that I could only carry out these constructions if it were given priority above all other constructions as far as workers, machines, building materials, trucks and so on -- whatever is neede for constructions -- were concerned. I was given assurances that that priority would be given the, and I then took over this construction program.
I was able to assure myself that the Hauptausschuss Bau -- the Main Committee for Construction -- which had been in charge before I took over had begun at three locations constructions. One of those we immediately closed down because both architecturally and, as the Fighter Staff told me, technically, the factory was not any good.
C Witness, you then said that the wish to build these bombproof fighter factories by the Todt Organization was communicated to you by the Fighter Staff. What do you know about that personally?
A I know the following: The Fighter Staff, as far as the entire work of the Plenipotentiary for Construction was concerned, who was responsible for all the constructions in the Reich, was not satisfied with the work. Sauer complained continuously about how work dragged on and asked me repeatedly to step in and do something. He called me to this meetings in the Fighter Staff and asked me to develop further plans. I then was called continuously by other gentlemen.
I remember Major Dr. Krelner, who also asked me to stop in and again and again I had to say that that would not do because, I said, the 1364a Todt Organization did not carry out construction in the Reich.
I was pressed continuously by the Fighter Staff, because it was the organization that would benefit from these constructions,
Q Do you know whether Milch went in that direction too, or only Sauer?
A That I cannot say. I did not speak about that to him myself. I did speak with Sauer and a few other gentlemen -- I believe with Schlemp, 1364-b who was later representative of the Todt Organization in the Fighter Staff.
Q When was that first pressure on the part of Sauer? Was that before March of 1944? That might have been eight months before you were put in charge.
A Yes. That was in my opinion oven earlier, but I cannot say precisely. It might have been in February, even.
Q. Do you know whether Sauer visited the Fuehrer in this matter?
A I was not present, but I assumed that it must have been so, I cannot prove it, however.
Q So, This afternoon you told me what you thought Milch's function was in the Fighter Staff, You used a rather striking expression. Would you like to repeat it here?
A I called him "the breakfast director",
Q I ask the defendant to pardon the expression. He shouldn't hold it against me.
Q What do you mean by this "breakfast director"?
A Well, it is sort of difficult for no to say that.
Q Milch won't be angry.
A Well, I only saw him at a Fighter Staff meeting once, when he invited me and when he asked for the support of the Todt Organization. No explained to me the general situation. He told me what his worries and troubles were, but the real work, the whole functioning of the thing, I don't believe he concerned himself with. That is why I used tho expression "breakfast director", but perhaps that was a little exaggerated.
Q I quite understand. After the end of April 1944, when you were commissioned will these construction matters, what did you do?
AAs I told Hitler very exactly, I took German Todt Organization units from France and from the Atlantic Wall.
Q How many was it?
A 2,000 or 3,000 -- I cannot remember the number exactly.
Q Your affidavit says 10,000.
A No, that is incorrect. That cannot have been the number in France. The second time that I went to the Plenipotentiary General for 1365-A Chemistry Professor Grau and told him of the serious situation, and I finally brought him to the point of giving me 15,000 workers from his department.
Q What workers were these?
A First of all, in the Baltic States -- that was a Todt Organization itself -- I took away most of the German workers, and took some elsewhere as additional workers, engineers, experts of sons sort or another, machinists. Then came Leuna on the 10th or 12th of May 1944. That was on the occasion of the first attack on Leuna. At that time there was a conference with Hitler with regard to the oil situation. He said, "This cannot be tolerated -- that at the very moment when we are, as a result of the air attacks, in need of oil, workers are taken away from Leuna."
I then answered him that first of all I had undertaken this measure before the air attack, and secondly, it was not a question of cutting down on oil production, but of oil capacity. Hitler took over and said, "No, that cannot be." Then Speer said, "If we don't get the workers, we can't do the building." Hitler said, "Quiet down, you will get 50,000 Italians," and then I said, "I don't believe that", and I said that for the following reasons. We as the Todt Organization had taken such workers from Italy for the construction program Riese in Schlesien, but we did not do this via Sauckel but by applying to Italian firms to take over construction commissions in Germany, and then they automatically brought their workers, their directors and architects, and so on with them, particularly after we had assured them that we with cur organization -- that is to say, with the Todt Organization in Italy -- would take care of paying wages, paying for the hospitalization fees, insurance, and so on, but at the moment when workers were fetched by Sauckel, I understood clearly that workers such as we needed would not be provided in any considerable numbers. At any rate, I told Hitler, "I do not believe in these Italian workers, and I won't believe in them until they have crossed the Brenner Pass." He then said to me, "You can believe in them because tomorrow Mussolini is signing an agreement that 1,000,000 workers will come to Germany."
He then said to me: "You can believe in then, because, tomorrow, Mussolini is finding an agreement that one million workers will come to Germany." If I nay mention it, it is also worthy of mention, that in January, the beginning of January, I was at a conference with Hitler, or rather, I did not take part in it, but I knew of it. There, a new worker contingent was demanded, and, in this conference, Hitler himself named the number of 250,000 workers mainly for the construction of bomb proof facilities. In other words, it wasn't Speer but Hitler who demanded those workers, and it is possible - that at any rate, it is the way I construetit now - that he was thinking of these fighter plants. Then I asked Hitler to obtain for me 10,000 OT Todt Organization workers from Southern Russia. I must mention that here, because I did that as Speer's representative with Hitler. I could have said to Speer that he should give me those 10,000 workers. I had to do that through Hitler, because the High Commanders, in this case the High Commander of the Army Group of Southern Russia, were in charge of these people and they had to be released by them. Thereupon those 10,000 OT workers were released. However, they unfortunately arrived very slowly and some of them never got to the fighter plant, but were taken over by Speer to build bomb proof constructions for roller bearings - ball bearing plants - in Wellen, in Thuringia, and then, when no workers came, the plants were to be built by Hungarian Jews. I do not know precisely when it was, but I do remember an armaments conference in Linz - I guess it was about the middle of June or maybe later, but I can't say for sure - and it was then that the first one began to arrive.
Q Were they approved by Hitler?
A Yes.
Q Witness, when you of the Todt Organizations fetched Italians on your own initiative, were they volunteers or were they more or less forced labor?
A Precisely in Italy, we had very good work because as a matter of principle we turned to Italian firms, gave then contracts and they provided the workers. I believe I can say that the Todt Organizations was 1367 a known for taking model care of its workers.
I like to mention, for instance, in Norway and Holland, the Dutch or Norwegian Todt worker received higher wages than the German OT, who was working right beside him. I consider it very important to make this statement here, if I am permitted to make use of this opportunity.
Q But that is not an answer to my question, whether they were volunteers or forced labor?
A They were not forced. They were brought by their firms.
Q Through the Italian firms?
A Yes; that was, from the very beginning, the intention, so that the Italian firms could provide their trained and expert personnel to us, and in this way, they were simply volunteers; volunteers do much better work than people who are forced.
DR. BERGOLD: No further questions.
CROSS-EXAMINATION DY MR. KING:
Q Witness, you stated that Milch was only present at a few of the early meetings of the Jaegerstab. May I ask you -
A What I said refers only to these meetings of the fighter staff at which I was present and that was perhaps four or five.
Q Now, you said, in your affidavit, which has been submitted as a prosecution exhibit referred to by Dr. Bergold, you received an order for the construction of fighter factories at the end of April 1944?
A Yes.
Q Do you recall being present at a conference at Berchtesgaden with Goering, among others, on the 19th of April, 1944?
A I cannot say whether that was the precise date, but I did take part in some such conference.
Q Do you recall who was present at that conference?
A Yes. Goering was there, Filch was there; the others I'm not sure about. Sauer -- I'm not sure he was there. I know for sure that Milch and Goering were present, but as to the others I no longer recall.
Q Do you recall what was discussed at this conference?
A The construction of fighter plants was discussed there, and, if I remember, Goering pointed out that the OT was to receive all sorts of support but I do not remember the details at the moment.
Q And a few days later, on April 21, 1944, you received the order from Hitler to build the six fighter plants?
A Yes.
Q Do you recall that possible sources of labor were discussed at this meeting? That is, labor for the construction of the fighter factories?
A I should like to assume that, but I do not remember precisely now. Probably all sorts of conditions and possibilities were discussed, but I cannot answer this precisely.
Q You were discussing a large scale construction; you must have known where this labor was to come from. Can you tell me what possible sources were discussed at that meeting?
A I do not knew whether or not that question was discussed at this conference. I assume that it was, but that was such a long time ago that it is impossible for me to recall these details. But I was clear in my own mind about the fact. That we needed so and so many workers, was of course obvious. I did make the demand that this construction program should receive top priority and I stated previously that I wanted primarily German workers, which was then done, and in the sector of the plenipotentiary General for Chemistry, I wanted to take some workers; I was convinced of the fact that in Germany it was still possible to obtain workers. Later, when we of the OT took over the construction program in Germany, we saw that a large number of construction offices had so little manpower that they had to stop production, and there again we found workers. If I may mention this again, the whole situation was somewhat unclear because when we took over building these fighter factories, the entire construction had to be turned over to the OT, and no one could take the responsibility for such important constructions unless he could control the direction of the whole construction program, but, with the best will in the world, I can't recall the details. There wore so many conferences, one followed the other so rapidly, I do not any longer recall.