Q Yes, witness; and how about supper?
A Well, in the evening we used to use up whatever money or tickets we had, I remember that in the beginning we didn't even have enough money to honor our tickets --- to buy what we had on our tickets. Of course, we could sell things, but at the same time, we had already been there for six months and we couldn't go on selling forever. And I remember that all we had received for clothing at that time was a pair of wooden shoes.
Q You surely ate at the factory canteen, didn't you witness?
A There were two canteens, and meals were served at different times, according to where we worked, and I told the Tribunal already that the food in the factory, the quality of the food, always varied according to whether the factory had been bombed, or whether there had been new workers coming in; whether other workers had left, and so on.
Witness, I asked you -- and please try to answer my questions exactly. Yes, you ate at the factory canteen, together with the German workers? Yes or no?
A That is quite obvious, as we worked together with the German workers. It was quite impossible, if you worked together with the German workers in the same hall, not to eat together with them at the same meal table.
Q Very well; isn't it correct, then -- I am very well informed how this is done in Germany -- isn't it correct that this meal, and that the tickets were exactly defined so that neither you nor the German workers had to give more tickets, and that a certain number of tickets were fixed in advance for the meal; isn't that correct?
A If I may draw the attention of the defense counsel to another fact that is, of course these tickets were issued in advance, at least until the first air raid. Then afterwards it wouldn't be so regular. Sometimes it would be for a week, sometimes for two weeks, the tickets would be honored or they would not be honored, and besides that, there's something else. The German workers had additional tickets, and they could go to the war canteen and buy some sausage or something else -- so there was the difference.
Q But if you only use a certain number of tickets for your meals at noon then I'm sure that you have a certain number of tickets left for the evening.
1544a meal.
Your statement cannot be correct.
A What is the sense -- exactly the sense -- of your question?
Q It was just something I wanted to find out. I just want to consolidate this.
A But you forget that the tickets used for the noon meal, for lunch, could not be used for the evening meal; that is, if you couldn't use up your tickets at lunch, they were useless, they were void.
Q It's something entirely different. You received general meal tickets, like every other German, didn't you?
A Yes, that is correct.
Q Okay; thank you.
A That is quite correct, but what I was arguing about is the additional cards for the Germans. We had general cards, meal tickets, which were absolutely insufficient, whereas the Germans had additional meal tickets which sometimes would be ten or twenty times our rations.
Q Witness, you are under oath, and what you stated right now -- what you assert now -- you cannot possibly maintain that under oath. There were no additional cards which were ten times or twenty times as much greater than yours. There was no such thing in all Germany, and we -- I lived here as a German, and I also had the same cards that you had. I did not have any additional cards.
THE PRESIDENT: Dr. Bergold, you're not the witness. You have no right to offer your testimony against his, and to state facts that you claim to know which are different from the facts that he states. I think you're beginning to suffer a little bit from high blood pressure.
DR. BERGOLD: Yes, your Honor; that is quite correct. But I have to tell him that there were no such cards ten times as big as ours, or twenty times bigger; In Germany, there was no such thing.
THE PRESIDENT: You don't have to tell him that. You're not the witness, and you're not under oath. You can get the answers from the witness, but don't tell him what you claim to know.
DR. BERGOLD: Yes, forgive me, your Honors, but a fact which was generally known -- I have to out this fact before the witness. I want to ask him if he actually will stick to this statement of his.
THE PRESIDENT: You may ask the witness whether he knows what you state to be the fact. But you didn't ask him anything. You were telling him something, and that is not your province.
Q. (By Dr. Bergold) Witness, do you know that this additional card amounted to ten or twenty times the amount of yours?
A. At least as far as my workshop is concerned I can say that our work managers and the assistant work managers, at least, had ration cards which contained ten times as much food as mine. Incidentally, it is easy to see they all have the zero behind the quantities I had on my card, or else they had another system; that was that people would get several ration cards and the same person would get five, six, seven or eight of these cards.
Q. Witness, did you actually see that?
A. Of course I have seen that, because that enabled them to throw sausages away which we were obliged to eat afterwards very often.
Q. What could they throw away?
A. Well, that was what they called the Wurst; that is, the German sausage, because whenever it would arrive and would be three or four days old, then they wouldn't like it any more so they either would throw it away or just throw it outside, and as of course we had to purchase our food on the black market and we couldn't effort it, we would tell them -- don't throw it away, or we even had to get it after they had thrown it away. Of course, we didn't like that very much because, after all, we had our pride too, but they could purchase whatever they wanted. They had tickets enough and they had money enough.
DR. BERGOLD: I would like to tell this Tribunal that I can bring witnesses, but then, of course, the trials would have to become much longer -- I could produce witnesses who could actually testify to how the food was in Germany; that what the witness said was not possible in Germany.
Q. Witness, I have one last question to put to you. Yesterday you mentioned that you, together with the transport of twelve hundred men, arrived in Germany from. France. Is the number correct?
A. This figure is correct; that is, of course, you must make allowance for a possible difference of a hundred persons, but I referred to a figure of persons who left the Southeast for Paris, and I got that figure when I came back, on the strength of the number of persons that left the Southeast at that time to be directed towards Paris. I cannot tell you what was the number of persons who left Paris for Strassoff then.
Q. Witness, can you remember the approximate number of them? There must have been several hundreds.
A. There were several hundreds; at least, more than five hundred.
Q Very well. Now, do you know to which factories these other comrades of yours came?
A I remember that the comrades who came with me to Strassoff got some secondary jobs in the hotels with hairdressers, at the butchers, as mechanics, gardeners, and even servants of some high ranking German personalities. The others who came to Fishamend were later on sent to some other factory near Wiener Neustadt or to a metal factory near Vienna, or to a locomotive factory near Wiener Neustadt, and I know that the food down there was even worse than ours. I would like to say that if the defense counsel has the intention of bringing witnesses to show how the food was, then I can bring tomorrow twenty thousand witnesses who can testify that the situation was even worse than I have indicated here.
DR. BERGOLD: Witness, I know the report of the French Government, and this report of the French Government will be introduced here, and it says something entirely different there, and this concludes my examination.
MR. DENNEY: No further questions, your Honors.
THE RESIDENT: This witness may be excused.
(Witness excused.)
MR. DENNEY: I have another witness. I wonder if we might adjourn for a few minutes.
THE PRESIDENT: You wish to talk to him before you put him on?
MR. DENNEY: Yes, just for a moment.
THE PRESIDENT: How long do you want, Mr. Denney?
MR. DENNEY: If we could just have about ten minutes?
THE PRESIDENT: Well, let's say we will resume at 11:00 o'clock and combine the consultation with the recess. We will resume at 11:00 o'clock.
THE MARSHAL: This Tribunal is in recess until 11:00 o'clock.
(Recess was taken.)
THE MARSHALL: The Tribunal No.2 is again in session.
MR. DENNEY: If your Honor please, we would like at this time to call the second prosecution rebuttal witness, the witness Paul LeFriec. It is spelled L-E-F-R-I-E-C.
THE PRESIDENT: The Marshall will bring the witness to the stand, please.
PAUL LE FRIEC, a witness, took the stand and testified as follows: BY JUDGE MUSMANNO:
Q Witness, you will repeat after me. I swear to speak without hate or fear, to say the truth, all the truth and only the truth. You will now raise your right hand and say, "I swear."
(The witness repeated the oath)
JUDGE MUSMANNO: You may be seated.
MR. DENNEY: Before proceeding with this witness, just so there may be no question about it, I would like to say for the record that the only reason that we have put these witnesses on the stand at this time is to facilitate the proceedings, because of the fact that the witness is not here for the counsel for the defense. He has had a request in for some time, apparently he had been on his way from Muenster in the British Zone for the past several days; in the normal course of events, of course, the witness Ferrier and the witness Le Friec would have been called as rebuttal witnesses at the conclusion of the case for the defense.
BY MR. DENNEY:
Q Witness, will you state your name?
A My name is Le Friec, in two words. It is spelled L-E F-R-I-E-C. My Christian name is Paul.
Q Where were you born?
A I was born at Lanballon, in the District of the Northern Coast.
Q Spell Lanballon?
A That is spelled L-A -N-B-A -L-L-O-N.
Q When were you born?
A 7 March 1915.
Q Were you a member of the French Army in the recent war?
A Yes, I was.
Q When did you enter the Army?
A I joined the Army 2 November 1938, after I had completed my studies.
Q Will you tell the court about your schooling?
AAfter I had graduated from high school I got my law degree, and now I am assistant lawyer in the prosecution at St. Brieuc.
Q Were you a prisonner of war?
A Yes, I was a prisonner of war.
Q When were you captured?
A I was captured at the Somme on the Weygand line on 5 June 1940.
Q Where were you taken then?
THE PRESIDENT: Just a minute. (discussion)
DR. BERGOLD: May I be excused for five minutes, I have to make a call at my hone, something seems to have happened at home.
THE PRESIDENT: We will retire to the judges' chamber. We will not disperse, but will be back on a minutes notice. The court is now recessed.
(Temporary recess)
Q. (By Mr. Denney) May it please Your Honors, we were talking about your captivity which occurred early in June of 1940; I believe the 5th.
A. Yes, it was the 5th of June.
Q. And how long did you remain a prisoner of war?
A. I remained a prisoner of war in Germany until I was liberated by the Red Army on the 4th of May, 1945.
Q. Where were you liberated?
A. I was liberated near Altengrabow in a little village the name of which I cannot recollect.
Q. During your period as a prisoner of war did you at any time work in an aircraft factory?
A. Yes, that is correct. I worked in the Arado aircraft factory near Braundorf. That is from the 3rd or 4th of October of 1941 up to the 12th of April 1945.
Q. Repeat the date.
A. As from the 3rd or 4th of October 1941 up to the 12th of April 1945.
Q. Will you tell the Court the circumstances surrounding your entry into employment at the aircraft factory at Arado?
A. Yes. I had been at Wodern, which was a camp near Frankfurt on the Oder, for about one year and there we were used on fortification work. This camp was the Stalag 3-B, and then at the end of September 1941 we were transferred to the Stalag 3-A, and we travelled for a few days, and then we arrived at Lueckenwald. Lueckenwald was the main camp for the Stalag 3-A. We were lodged in barracks there.
Q. What were the conditions in the barracks involved?
Q. What were the conditions of the barracks at Lueckenwalde?
A. This was so-called "transient barrack", and there were no beds and no straw mats and we just slept on the floor. And, of course, it was full of vermin because everybody passed there and stayed there for a few days, and also we didn't stay for more than a few days in that barrack.
Q. How did you eat?
A. The food was very bad and it was as bad as in the Stalag III A, where everybody complained about the food because it was really insufficient. The bread they distributed to us in this Stalag III A was very bad quality.
Q. How much did you get to eat each day?
A. For six of us, we always had a loaf of military bread, the typical German military bread.
Q. So-called "black-bread"?
A. That was of course the black bread, and besides that, it was very often rotten.
Q. What else did you get to eat?
A. Some sort of soup, which was nothing but clear water.
Q. And what else?
A. Perhaps some margarine to put on the bread, and that's all.
Q. And where did you go from Lueckenwalde?
A. We wore loaded into railroad carriages and I myself asked one of the transportation chiefs there, where we were going to go. We were told that we were being sent to work in a factory which produced children's carriages -- baby carriages.
Q. This was in September 1941?
A. I couldn't give you exact percision as to that subject because it might have been at the end of September, but it might have been, also in the first days of October.
Q. Who guarded you at Lueckenwalde?
A. Camp guards, which were German soldiers.
Q. And, on the transport taking you from Lueckenwalde, who guarded you?
A. German soldiers also.
Q. And where did you go from Lueckenwalde?
A. We arrived at this town of Brandenburg -- it's called Braunburg, or something like that.
Q. Can you spell it for us?
A. B-R-A-N-D-E-N-B-U-R-G. Brandenburg.
Q. What were the conditions on the train on which you went from lueckenwalde to Brandenburg?
A. They were cattle wagons, and we were pushed into these cattle wagons and pressed together there.
Q. How many men to a car?
A. 50 to 60.
Q. Where these the normal German railway cars that one sees around now?
A. Yes; they were normal carriages, for 40 men or for eight horses.
Q. What did you do when you go to Brandenburg?
A. We were led to a camp,-- the man's camp, which was at the other end of the town, and this camp was already occupied. There were Franch prisoners of war, and we were lodge there. We were there about 26 per room, in the barracks.
Q. How big were the rooms?
A. Well, they had the normal size of the rooms in the German barracks, which would mean that, at the highest, they would be six meters long and about three meters wide.
Q. How were they furnished?
A. Well there were double ranges of bods, one above the other, but I must say that, in the beginning, we had to sleep two in a bed, and there was no straw and no mattresses, and we had to sleep two with one blanket also. But that was only in the beginning.
Q. Did they then send you to work?
A. Well, right on the next day we were gathered around the camp and some of our comrades told us: "Well, we don't produce baby carriages here; we produce airplanes. That's Arado Factory here." And then the camp commander came and divided us up in groups; whoever had to work in this factory.
I personally was sent to workshop X. They always numbered the workshops by "A", "B", "C", "D", etc.
Q. Where there any other prisoners of war other than French there?
A. At that time we, the French prisoners of war, were the only prisoners of war employed down there. At least at that time there no other prisoners of war of other nationalities, in the region of Brandenburg.
Q. Were there any foreign laborers there from other countries?
A. Yes; I saw foreign workers there, and I saw Italians who had come from Italy and who were so-called "volunteers." Now they themselves claimed they were not volunteers, but it was none of my business, and I didn't think of looking it up, whether they really were or not.
Q. Were there any other foreign workers there?
A. Not that I know.
Q. At any time prior to April 1945, when you left Brandenburg, did any other foreign nationals come there, either prisoners of war or people who had not been in the service?
A Yes, I remember other foreign workers. First of all we had again Italians who later on came as prisoners of war after Italy had sided with the Allies. Second, we had French civilian workers who came. Third, there were the Russians and Russian female workers. Of these Russians the main part were the Ukrainians, and it was always very difficult to know anything about these Russians because it was very vague. Some of them were escapees from prisoner of war camps and we couldn't know whether their status was actually real civilian workers or whether they were prisoners of war. Anyhow then they had escaped from prisoner of war camps they would declare that they were civilian workers and would come in as such.
Then there were the Russian prisoners of war. Then there were Lithuanians and Lithuanian female workers also, but we could never know whether they were volunteers or not, and we the Frenchmen didn't want to have any contact with them for personal reasons which I will indicate later on.
Q How many, people were at this camp at Brandenburg where you were?
A In order to make it quite clear I have to say that this was not a camp, but rather a group of camps. There was the French camp, the French POW camp, and next to the French camp, right close to it, was the Russian camp which gain was subdivided into two camps, one for male workers and one for female workers.
The Russian camp for female workers included the camp for Lithuanian workers. Then, eight hundred yards from there we had the camp for French civilian workers and also eight hundred yards from our camp, but in another direction, we had the camp for the Italians. As far as the figure of the foreign workers is concerned, I can say that we had fifteen hundred French POW's, but I must say that when the first air raid started and the camp management -- the factory management decided to decentralize the factories, some of our camp comrades left us and were sent elsewhere, so then we had some less French POW's there. That's as far as we go with French POW's.
That, of course, is the figure which I can give with most precision, and I think that from four to five hundred French civilian workers, deportees and workers who came in under the labor assignment program were also employed at our Arado Factory.
Also, I could say that about a thousand Russian workers, male, female and also children had been brought -- deported into cur camp for the benefit of the Arado Factory. I think there were about forty Lithuanians, male and female, and finally there were about five to six hundred Italian POW's who were in their own camp down there.
Q Did these Russian children work?
A Yes, these Russian children worked, but I would like to give some details concerning this question and these details bring me also to a typical case of my captivity. If it please the Tribunal, I would like to give these details now.
In about 1942 another camp was constructed near our camp, next to our camp, and during the first half of 1942 we saw the first Russian deportees arrive. Now I made already a restriction, a reservation with regard to this title of deportee. We used to call there deportees, but as I said before, we never actually knew whether they were deportees or escaped prisoners of war, and at that time we saw the first Russian women to come down there too.
I want to make it a point to say that I am stating here only what I have seen myself. I have seen Russian women arriving at that camp, women who were pregnant and women who were carrying newly born children, babies, and I have seen that the children were in the camp and worked there, children of all ages, and I think that the Arado Factory employed them from seven or eight years of age. I have seen children of seven or eight years of age work in the factory. These children were used for cleaning work, certainly not difficult work, no hard work, but it took a lot of time.
I must add that after a certain time the Arado Factory had to give up using the services of these children because they caused too much disorder in the Factory and also I may say that within the camp the children were very hungry, and they used to creep through these barbed wire enclosures and come into our camp in order to get some of the biscuits we got from the American Red Cross.
Also, I may add that several times we had to give condensed milk from our own rations from the American Red Cross to these newly born children in spite of orders by the German authorities, according to which nothing could be given to Russians. We had to do so for pity's sake.
Q. What were the conditions with reference to food in the camp during the time that you were there?
A. I am going to talk only of the French camp because that is the only camp where I really can give some details. When we arrived in 1941 the food was practically as bad as it used to be in the Stalag III A. The food situation even deteriorated, and throughout all this winter, from 1941 to 1942, the food situation deteriorated constantly. If we hadn't had these parcels from the Red Cross at that time the situation would have been impossible, and whenever we went to the Germans to complain, they would always answer us, "Yes, after all you have your Red Cross parcels."
Q. What were the hours of work?
A. The working hours at the beginning were eight to nine hours, but when we came to 1944 and 1945 they had reached fourteen hours a day in certain of the workshops, and even you had to work on Sunday morning, and I remember one of my colleagues who had to work seven Sunday mornings in a row.
Q. And what kind of airplanes were they making there?
A. I personally was engaged in work on the repair of the wings of the plane. Some others would construct the forms in which the wings would be molded, and others again worked on the motors, but I must say that the organization of the factory was such that all the kinds of work for airplane construction could take place there.
Q. What kind of planes did you work on?
A. First of all we worked for bombing aircraft for Junkers. At a certain time they started to construct a special plane which was not called an Arado plane. The trademark given to the plane was a Hoinkel, and I know that it was Heinkel 177. This plane had double landing wheels and it was the plane of which the "Voelkischer Beobachter", the German news paper, said that they would go and bomb America with that plane.
Q. Did you at any time make any complaint?
A. We complained about work in these aircraft factories. Is that what you mean?
Q. Yes, Tell the Court about it.
A. Yes, there were complaints made. After all, there were a few of us when we arrived down there who had some idea about the Geneva Convention; and we pointed out to our commandos that it seemed to us that if Article 31 of the Geneva Convention was applied this kind of work could not be done by us. There was a sort of a trustee for the workers; but actually we had no way of conversing with the authorities because this trustee was not a trustee who was elected by us but had been appointed by the camp authorities. Therefore, the prisoners had no confidence in him.
We eventually agreed that the only thing to do was a general strike. The password was passed on, on the 20th of January 1942. The general strike of the French workers broke out on the 21st of January 1942 at 9:00 a.m. All the French prisoners and all the French workers obeyed this word and followed this strike with the exception of a few whom the password had not reached.
Q. What happened after that?
A. They gathered all tho French workers at the airfield and made us stand at attention there. It was snowing and the temperature was at about minus 18 to minus 20 degrees centigrade. They made us stand to attention until 5:30 p.m. We had to stand there; and we were threatened. Some of our comrades fell; and I have to add that we were allowed to bring them to the dispensary when they collapsed.
At 5:30 some officers came out and asked why we had stopped the work and wanted to know the reasons for this strike, which seemed to have surprised them very much. The officers asked for some people who had the confidence of the workers to come out and speak; so at once I and some of my comrades came forward. Then I told them that first of all there was the Geneva Convention which was being violated and second that there were the food conditions, which were very impossible.
They told us that as far as the food was concerned this was a hard winter for everybody. Germans included; and as far as the Geneva Convention was concerned, we would get an official answer within some period of time.
Sometime later we actually received the answer; and in this answer they asserted that the Geneva Convention had been bypassed by the developments and that there was no reason for the existence of this geneva Convention as Germany had entered a period of total warfare. They alleged that we ourselves had violated the Geneva Convention by stopping work without lodging our complaints through the regular channels; but they forgot that they themselves had previously violated the Convention by appointing a trustee who was not in our confidence.
Q. Who were the officers that came out and talked to you when you had this strike?
A. Those were officers of the Stalag III-A and others whom I didn't know.
Q. In what service did their uniforms indicate they were?
A. It was the regular uniform of the German officer of the OKW.
Q. Did you ever see any Luftwaffe officers around?
A. Not in the camp. When we did see officers of the Luftwaffe, there were inspections. At these inspections we saw officers of whom we were told that they belonged to the Luftwaffe and we saw civilians of whom we were told also that they were officials in the Air Ministry. I must say that we only were told so because all we know was by hearsay. These visits by officers became more and more frequent towards 1944 and 1945 because at that time we had started production of rocket-propelled airplanes. There were few of them; there were only a very few.
I want to stress the point that this general strike which we had on the 21st of January 1942 was not the only manifestation of our will not to work in the armament factory. We made various representations at the Mission Scapini, which was the French Ministry for the Deportees during the Vichy government; and we got the most incredible answers. For instance, they would assert that the Germans would say the Geneva Convention was signed by a German democrat and now that National Socialism had come all those things were changed and that they could not answer for any obligations undertaken by German democrats.
Q. What were the health conditions in the camp at Arado?
A. I must say, frankly, that in camp the general sanitation was acceptable. I must also say that what I had to reproach in those camps was that they were overcrowded. I should add, too, that many a tubercular man had to go away to the Stalag because whoever had tuberculosis was sent to the Stalag and to the dispensary from Lueckenwalde. Our working command, our camp at Arado, was what all our comrades in the Stalag dreaded most. They were afraid of coming into our camp because they saw other comrades come back there sick. They were also afraid of the working conditions in our camp.
Q. How much were you paid?
A. These salaries, of course, varied, I might say that they would start at 18 marks as a minimum and 60 marks as a maximum per month; but I want to specify that when I say 60 marks I do not include specialist workers, who would at times get more than that. But I want to draw the attention of the High Tribunal immediately to the fact that we Frenchmen never did complain about the pay we received from the Germans because it would have been in contradiction with our honor as Frenchmen and as prisoners of war to go and argue with the Germans for a mark or something like that.
THE PRESIDENT: The Court is in recess until 1:30
THE MARSHAL: The Tribunal is in recess until 1330 this afternoon.
(A recess was taken until 1330 hours)