A. In principle, no. This decree related only to children who had been brought to Germany from somewhere else, and in this case, to stick to the Polish example, they were the children of Polish mothers who, as workers, had come from the Government General, shall we say, - I don't know whether that actually happened - to the Incorporated Eastern Territories. And I would also ask you to bear in mind that this decree of November 1944 was promulgated at a time when that question probably, in practice, played no part at all.
Q. I didn't hear you express any disapproval of the sentiments of this decree in the order that you sent out. May I ask you what you thought of this sentence when you wrote it?
"Those illegitimate children of the above-mentioned foreign female workers, who fathers belonged to the German nation or to the Danish, Flemish, Dutch, Norwegian, Swedish, or Waloon, and who can be considered valuable from the racial point of view, should not be cared for at the nurseries for children of foreigners, but should be brought up like German children."
Now, as a good Catholic, will you explain to me why one soul should be brought up differently from another?
A Yes, I can explain that, because where one can no longer speak of the ability to do a thing one can no longer speak of a "must" either. It became an impossibility in Germany to attempt to educate all those children as if they were German children, for there was a spate of children and that was why everything failed. And the steps that were taken constituted a true effort to look after these children decently. That those children whose father was a German or, as one said at that time, of the same race, reaped the first benefit of education with a family, that is to say that we got them foster-parents, that we took that step is of course only natural. It seems to me that the essential point is whether these children were treated badly and unfairly, but one can't speak of any such thing.
Q You weren't concerned about that then much as a Catholic?
A Well, I don't quite know what I should have been concerned about.
Q I only go back to the fact that I want to know what it is could have concerned you about membership in your church and the actions of Himmler if none of these things disturbed you. What was it that you thought Himmler was going to ask you to do as a member in the SS that was different from this that you approved?
A I didn't met that question.
Q What was there that you thought Himmler would ask you to do as a member of the SS which was any worse than treating children differently on the basis of their parentage?
A Mr. Prosecutor, that presupposes that I should have been of the opinion that those children who were sent to nurseries or whatever else we called them, were treated badly and unfavorably, but there is no indication that that was so. The difference lay on an entirely different plane. The difference was simply this, in one case the costs were born by the Labor Front and by the Reich Food estate, and in the other case the costs were borne by the NSV or the costs were paid out of public funds. As in all these welfare questions, that point in the last analysis represents the crux of the matter.
German children, too, were sent to nurseries and for German children too, we had just emergency homes. There is no other way out in wartime.
Q May I ask you then why does the last sentence of this order read this way: This circular decree is not to be published, not even in the Information Gazettes for official use, either?
A I don't know what you mean, not even for official use and not in the Information Gazettes, for what?
Q "Not even in the Information Gazette for official use, either", is the translation that I have. That is the best I can do for you.
A Well, I couldn't see anything in that clause, because art that time, that is at the beginning of 1944, we came across that clause very frequently, and the true reason why such measures were taken, in other directions as well, was that we were compelled to save labor and material, and also it was obvious that many things were only of temporary significance. Therefore one did not wish to burden the official gazettes with such matters which were only of temporary significance.
Q Who operated these nurseries?
A I don't know. In the decree it only says that the Labor Front and the Reich Food Estate and the NSV would be in charge of them.
Q And the judges of the courts under your administration were advised as to where they were to send these children, were they not?
A No. The Guardianship courts had nothing to do with the accommodation of those children. That was a matter for the agencies of the internal administration to deal with, and the Guardianship Courts were there for people to apply to them who had some legal complaint to make or people applied to those courts to ask for aid in some way or another.
Q You were telling them what to do when they applied, were you not?
A I told them that they had to observe international private law.
Q Now let me ask you if you ever heard of this situation according this is dated in January, 1946, but it relates to the period during the war at Braunschweig.
See if you ever heard of this. According to the Associated Press an examination has been completed of the methodical Nazi murder of 462 babies and the removal of their bodies in cardboard containers to unnamed graves from two baby homes. The babies were considered -
THE INTERPRETER: Would you repeat, please? There was something wrong here.
MR. LA FOLLETTE: According to the Associated Press an examination has been completed of the methodical -
THE PRESIDENT: The electrical transcription has run out of film. We will take our recess now instead of five minutes later.
(A recess was taken.)
THE MARSHAL: The Tribunal is again in session.
THE PRESIDENT: Mr. La Follette, will you pardon us a moment while we dispose of a matter here before you start? These matters are not ordinarily discussed in open court. They are matters which relate to the administrative work of the Tribunal, but this presents a situation which is different from anything which we have had before. We have here two applications for additional witnesses for the defendant Rothenberger. The application in one case -
MR. LA FOLLETTE: If Your Honor please, may I interrupt a minute? I believe Mr. Wandschneider is right outside.
THE PRESIDENT: WEll, he can read it in the transcript. We have here two applications for additional witnesses for the defendant Rothenberger. One is dated 12 September and the other the 11th of September. In both cases the statement as to the proposed evidence which will be sought from the requested witness shows that the matter and the evidence offered or sought is purely cumulative. It relates to the matter of guidance of jurisdiction of the Special Courts in Hamburg by Dr. Rothenberger, concerning which we have had testimony on the Rothenberger attitude toward the Jewish question, which was fully covered in their main defense.
We do not look with favor upon applications at this late date for matters which have already been covered in the main defense of the respective defendants, and we call attention to the very real distinction which exists between the situation of the prosecution and the defense.
The defense, before it put on its testimony in chief, had heard the testimony of the prosecution and had an opportunity to rebut it. The prosecution, on the other hand, has not had an opportunity as yet to rebut the defense's testimony, which is put in by the defendants in their case in chief. It may be that some proper evidence in rebuttal may be receivable when offered by the prosecution because it will be their first opportunity to rebut the evidence presented by the defendants. The defendants have already had that opportunity as to the prosecution's case. The matter is within the discretion of the Court, but we see no good purpose in calling witnesses requested at this late date for purely cumulative evidence, so the application will be denied.
You may proceed.
CROSS EXAMINATION BY MR. LA FOLLETTE:
Q. I want to read you this account and ask you whether you heard of any of these things during your time in the Ministry of Justice, and, if so, what you did about them.
"According to the Associated Press, an examination has been completed of the methodical Nazi murder of 462 babies and the removal of their bodies in cardboard containers to unnamed graves in two baby homes, The babies were considered illegitimate children of slave laborers. The mothers worked on farms and in the Volkswagen factory near Braunschweig. They were taken from their mothers at the age of up to three months, and taken to two clinics in the village of Welbke and Ruhen. Out of 114 babies who were located in wooden huts in Welbke, 92 died, but the mortality figure in the corrugated huts in Ruhen was 100 percent. Three hundred seventy were located there and 370 died. The baby homes were supervised by a German administrator and medical personnel. The British investigators have arrested 16 men and 3 women who are to be interrogated as war criminals.
The babies were killed by wilful neglect, wrong feeding, and premature separation from their mothers, and the general filthy condition in the clinics."
Did you ever hear about that during the time that these children were being sent to these babies' nurseries?
A. No, never. I cannot remember any case of that kind at all.
Q. How many trips did you take between January 1943 and the end of the war around Germany?
A. Within the country?
Q. Yes.
A. That is very hard to say. In the beginning, on the average, I had to attend a meeting of a committee concerning civil cases, which was out of town, every two weeks. Then in the summer, about May 1943 that is, I went to negotiations concerning legal means and legal remedies which took place outside of Germany. In June and July again, about every two weeks, I made a duty trip. Then from the month of August on, after the department had been evacuated, regularly every week I went once to Boehmisch/Laipa and once to Berlin. In addition, I made official trips to the districts of Koenigsberg, Hamm, and Zweibruecken, Duesseldorf, Innsbruck, and Graz. Then during the entire year of 1944, that is to say, from April on until August inclusive, altogether perhaps 8 to 10 times I traveled to Kochem to attend courses which took place there and which I had to direct. I cannot guarantee that that is complete, but there were so many trips that I just came and went.
Q. Yes. And in none of these many trips, so numerous that you can't remember, you never made any inquiry in any place about how these foreign children were kept?
A. I had nothing to do with it at all. That was not within my sphere of work. I only had to take care of the Surrogate's Courts. I said before already that the care of the children was a matter of another administration.
Q. You have answered it. You never made any investigations. Did you ever, in all of these trips, did you ever go to see any of your friends in the SS at any concentration camp?
A. No, no. I was never in any concentration camp, and I never had any SS friends.
Q. You were at Kochem when Himmler Came and made this speech of 1944, were you not?
A. Yes.
Q. Did you and your old hometown friend have time to talk together while you were there?
A. Yes.
Q. About how much time did you have to talk with him - approximately?
A. I did not speak alone with Himmler, but I was in the group where Himmler was received when he arrived. It was intended that Himmler should arrive toward noon and then make his speech about three o'clock. He arrived at half-past three and had to begin speaking at four o'clock. After the speech he left again, so that the time was very short. Moreever, the time was filled in by short conversations with the Minister.
Q. When you went to visit him at his headquarters, how much time did you spend? Didn't you spend overnight with him?
A. No. I used to arrive in the morning at half-past ten. I had spent the night on the train, and I had expected that sometime in the afternoon there would be a possibility of a conference, but that did not succeed. All day long I was free. I was told that I wouldn't have anything to do until dinner. Then at a table where Himmler was also eating there were about 12 people sitting around. At a certain distance from Himmler I ate my dinner, and subsequently after the dinner I had the possibility of having a very short conference with Himmler and I left again at half-past eight.
Q. Do you remember any of the people who were at that dinner on this occasion?
The twelve people?
A. I remember two people: one was Himmler's adjutant, by the name of Brandt, and the other one was an Obergruppenfuehrer by the name of Pohl.
Q. Was Brandt the man who was sentenced in Tribunal II recently be convicted?
A. Yes.
Q. And is Pohl the man who has just been tried in Tribunal II -- I believe the other was Tribunal I -- is that the same Pohl who has been on trial here?
A. Yes, he is on trial at present, yes.
Q. During this meal, what did the men at the table talk about?
A. As far as I remember, the conversation dealt with quite general problems, such as, well what one discusses at a table, art and similar matters, but certainly not crimes.
Q. Now then, this was just about the time of Stalingrad, wasn't it?
A. Yes.
Q. And Himmler and everyone was very busy? All these men were busy men, were they not?
THE PRESIDENT: We will assume they were busy.
MR. LAFOLLETTE: I am entitled to an answer, Your Honor.
THE PRESIDENT: Well, we know the answer.
BY MR. LAFOLLETTE:
A. I said already that just because they were very busy, because Himmler was very busy indeed, I only had the opportunity of speaking very briefly with him.
Q. And at this time with these busy men you talked about art and incidentals and nothing about concentration camps and the runnings of the war or duties of the SS? That wasn't mentioned at the dinner?
A. I could imagine, Mr. Prosecutor, that if all day long one has to worry about all possible and impossible questions, that the dinner time is certainly the time used for some relaxation, since the whole time was about a half-hour altogether.
Q. Yes. How many times had you seen Himmler between the time you saw him in 1937 and the fall of 1942?
A. In the fall of 1942 I did not see Himmler.
Q. I said how many times between November '42 and 1937 did you see him? I don't say you saw Him in November '42, only from that interval.
A. I spoke to him twice.
Q. In five years?
A. In five years. Yes, in five years.
Q. And you testified that you never served actively in any of these legal capacities with which you were connected with the SS. Then may I ask you, how do you account for the fact that on the 18th of September 1942, at the meeting with Thierack and Dr. Rothenberger where the matter of the disposition of Jews and gypsies was discussed, Himmler said, and pointed you out as an example, as a reliable SS-Obersturmfuehrer, Reichsgerichtsrat Dr. Altstoetter?
A. I am not of the opinion that Himmler made that emphasis in my person as a positive emphasis in connection with the extermination of Jews and so on. And how he came to point at me, that is also unknown to me. It could be that his attention was drawn to my person by some information which he may have received about the fact that I, as an older man during the war, received an important decoration for wartime service.
Q. Yes. Now, in the SS, you said that you were never very busy or active, and in the letter of the third of June 1943, you said this:
"Both this promotion and the honoring of this decoration with the skull and cross-bone ring, I will take not only as a token of the Reich Fuehrer's most distract proof of trust in me, but also as an incentive for further active proof of my loyalty and for strict adherence to my duties in my career as an SS man."
Now if you had no duties, what were you referring too?
A. Mr. Prosecutor, from the context you can see quite clearly that I wanted to tell Berger that I shall do my duty and anything which is said around that, as far as the phraseology is concerned, these are just phrases that at that time were very frequently used-possibly too frequently.
Q. But this reference to "further active proof of my loyalty to my duties," what did you mean by the "further active proof"? Was that just talk too?
A. I considered my life and my life's work as one unit, and if during the war and in my profession and elsewhere did any duty in a loyal manner and as I believed as a docent citizen toward the State and the Nation to which I do happen to belong, then I may very well summarize that in the way in which I have expressed it.
Q. And so you summarized that by saying, "And for strict adherence to my duties in my career as an SS man." That is the career you referred to?
A. It doesn't say only as an SS man, but altogether.
THE PRESIDENT: What exhibit was that?
MR. LA FOLLETTE: That is Exhibit 426, Your Honor.
BY MR. LA FOLLETTE:
Q. I ****** ***** *** ***********. I have read accurately the translation. It may not be correct, but I have read it accurately.
Now let's talk about this trip to Corinthia a minute. That was outside of the Alt Reich, I believe, in Trieste, was it not?
A. Yes, it belonged to Austria.
Q. And the court which you were discussing with the Gauleiter Reiner and the prosecutor was the People's Court? The defendants were people who lived within the jurisdiction of the Corinthia Gau and committed their crimes there, is that right?
A. I couldn't say it off-hand. I only know that the majority of these people were German soldiers who deserted -- mostly the cases about which we received information -- there may have been 12 cases or so. Whether they were Austrians themselves or deserters from the Alt Reich, I do not know. At that time, we considered the Reich a unit including Austria, and I did so too.
Q. And now are these men deserters from the Armed Forces?
A. Yes, yes. That is what I was told.
Q. Do you mean deserters from the Army and the Wehrmacht had to be tried by the People's Court?
A. Yes. If you read that letter very carefully, you will find that there is mention of people who head the bands. I didn't look entirely through the whole thing asto how far the jurisdiction of the People's Court extended. I did not know, and I don't bother about that, because I had nothing to do with it. All I was interested in was to be informed to the extent that I would be in a position to tell the Minister about what the Reichsstatthalter complained. I did not have to know any more about it, and I wasn't told any more about it.
Q. Well, you read the letter of the 3rd of June 1944, which is Exhibit 484, and what did you think this meant: "For the effective prosecution of Reich enemies, and especially of bandits, the prosecution of bandits can only be carried out effectively when their arrest is immediately followed by trial." Did that mean deserters from the Wehrmacht?
A. I could imagine that also in the cases of such bands which consisted of deserters who had left the troops that even there quick justice was necessary; first of all, to protect the population--I can imagine that. But there it was the question to introduce or to carry out procedures which would exclude the possibility that people who for having participated in the activities of such bands were brought to arrest, that these people would have to remain for a year or a year and a half under arrest before the trial started. That was to be avoided or prevented, and that was the reason why the Reich Governor, the Reichsstatthalter, made these efforts. It washis wish that socalled "blitz courts" should be established for that purpose, which however was refused by the Minister.
Q. And those are the men that you described just two minutes ago as deserters from the Wohrmacht? Is that right?
A. I can't tell you any more, Mr. Prosecutor, than what was told to me, because I do not happen to know any more. I did not carry out any investigations. I did not see any files. I only was told what I know, and what I was told, I passed on to the Minister.
Q. Well now you have glibly said on your direct examination that this was all according to international law. Why would you have to refer to international law if these people were deserters from the Wehrmacht?
A. I do not know that in this connection I had said anything about international law. I said something entirely different. I said I went to the Gauleiter and Reichsstatthalter Reiner with the express purpose to discuss with him other questions which had nothing at all to do with these trials and these procedures, and these were questions of lega remedies; that is the question, for instance, by what means a court in the occupied area of Tireste, in the foothills of the Alps, would have to deal with a court in Germany. If you are interested.
I can give you some more information about that. The legal basis was the treaty between Italy and Germany concerning legal remedies which dates back to the time before -
THE PRESIDENT: Just a minute. Are the defendants able to hear the translation all right? I thought perhaps from the demonstration that the defendant was unable to hear. I gather that he does hear all right. Well then, the demonstration will be unnecessary.
Q. Now then, you did know that the People's Court had jurisdiction of treason, of high treason, and of preparation for high treason.
A. Yes.
Q. All right, and you also know now that the people to be tried before the People's Court were not deserters from the Wehrmacht.
A. Yes, I knew that at the time already.
Q. Did you investigate the crimes for which these people were to be tried; or anything about the individuals and the purpose of ascertaining whether they owed any allegience - to the German Reich?
A. I already said there, Mr. Prosecutor, what I know about the whole matter; I have told you. I only know also that I received a list; upon that letter there, I believe there were twelve names on that list; there it also said for what reason these people were in prison; the time since they were under arrest; how long their detention was before being brought to trial. I believe that is correct; it could be seen why that man was arrested; it was assumed that that was known. And that list together with the letter I handed to the Minister. Since that time I have not seen that list again. I saw it later again here in this courtroom.
Q. In addition to Himmler, did you know Martin Bormann very well?
A. No, I neither saw Martin Bormann or ever spoke to him. I only heard his name frequently mentioned by Minister Thierack, but that was all; and that was sufficient.
Q. May I hand you the record from your personnel file, which is a letter dated 2 September, 1944, addressed to Minister Thierack, signed by Martin Bormann, who asked you to be present at a meeting the 23rd of September in Munich. Do you find that stated in the letter?
A. Yes, it is in the letter.
Q. This was a series of meetings for the purpose of deepening the personal contact between the party and the man who occupied administrative positions and rendering officials -- is that what the first paragraph says substantially?
A. Yes, not only in the administration of justice, but in all branches of the administration.
Q. Will you account to me then for what outstanding service you had rendered which caused Martin Bormann to say in the last paragraph, should party member Alstoetter be prevented from coming, I request not to send a man to deputize for him.
A. I don't know; I don't know what that means.
Q. You don't know why.
A. That letter was addressed to Dr. Thierach.
Q. And you don't know what outstanding service you had done that caused Bormann to say if you couldn't come he didn't want anybody else; you don't know anything about that?
A. No, I don't know. I assume, however, I assume that the man who started with this, who had set down the people he wanted to come could not replace any one of them by anybody else; as to what the basis for that selection was, I don't know.
MR. LA FOLLETTE: That is all; I am finished.
THE PRESIDENT: Re-direct?
REDIRECT EXAMINATION BY DR. ORTH: (Attorney for the Defendant Alstoetter)
Q. I hand you Exhibit 421 in the German, and ask you now on the basis of that text to comment on the assertion by the Prosecutor that you had won the Blut Orden?
A. I gather from this document, that is page one of Exhibit 421, that here in fact, as I had assumed before, all decorations that one could think of are put down and if somebody received a decoration of that kind, then probably the decoration he received was underlined or the others crossed out. That is a form, a typed form, but neither the Blut Orden decoration or any other decoration is underlined in my case. Looking at the photostatic copy now, from that I can see there is no mark next to the Blut Orden, but there is a mark next to the death head; next to the SA brown sports medal I don't have to mention that there is nothing and there is some mark next to the Jule Tide Chandelier which I cannot decipher.
Q. The Prosecutor has pointed out that conclusions can be drawn from the death head insignia to the purposes of the SS. Did you happen to know of units or organizations in the old empire who used to wear the death head insignia?
A. Yes, as far as I remember there were units of the former German Army which wore those death head insignias.
Q. Didn't also the armored troops wear that insignia?
A. Yes, the armored troops of the German forces during the time from 1939 to 1945 wore that insignia; also, the ones who did not belong to the Waffen SS.
Q. I hand you Exhibit 460, NG-891, your circular letter concerning illegitimate children. The Prosecutor quoted from the last paragraph of the circular letter from the Minister of the Interior and he concluded that it was a secret decree. Did you designate it as secret in your sphere; or, did you make a directive and pass on instructions as far as your decree was concerned that it shouldn't be published?
A. Neither the one nor the other.
Q. Witness, the Prosecutor from the letter which you addressed to Gruppen Fuehrer Berger drew the conclusion that you had done some active service for the SS. Did you own an SS uniform at that time at all?
A. No, at that time I did not own any SS uniform.
Q. Did you at that time participate or attend any SS functions or did you become active for the SS in any way?
A. No, that is quite impossible because I did not belong to any unit; I was not a referent anywhere, and I wouldn't have been permitted to be in the service. I had no task, no mission; that is the essential point in connection with the special position which was held by a large number of higher officials, of the people from the field of national economy, or from the field of art and sciences; owing to the fact that they were appointed honorary leaders, that is true; they were brought a certain personal relationship to the SS, that is to say individuals to officials whom they had an opportunity to meet and whom they knew --but never into a professional relationship.
THE PRESIDENT: You have covered that all in your other testimony; that you have already testified to in full. It is unnecessary to repeat it.
BY DR. ORTH:
Q. Witness, the Prosecution put to you a letter from the party chancellery, dealing with a meeting at Feldafing.
A. Yes.
Q. What was discussed at this meeting?
A. No, I don't exactly remember when it took place; some lectures were given of a scientific nature; for instance , I remember there was a professor from the technical college in Munich; there was a professor from the university; and, of course, there was also a higher party official who discussed general questions of public life; but what was dealt with in detail, I could no longer tell. At any rate, it was not of major importance.
On the occasion of that meeting were there at all questions discussed or mentioned which in any way could have been considered to be of a criminal nature?
A. No, that is quite cut of the question. It isn't true that one only thought about crimes in Germany.
DR. ORTH: I have no further questions.
THE PRESIDENT: The witness is excused.
MR. LAFOLLETTE: If Your Honors please, the Prosecution only finds, from without seeing the original, that Document 20 in Document Book I, Document 26 in Document Book I, and Document 34 in Document II, Document 59 in Book II are objectional. The Prosecution would have no objection if Book I were offered as Exhibit 1, Document Book II offered as Exhibit 2, and Document Book III offered as Exhibit 3, with the exceptions which I have stated for the record. You can't hear me? I will try again. I said in Book I Documents 20 and 26 technically we find objectional; in Document Book II, Documents 34 and 59 technically we find objectional. I do not of course preclude counsel from presenting his case as he wishes; I simply state that the Prosecution has no objection to Alstoetter Document Book I being introduced as Exhibit 1; Document Book II as Exhibit 2; and Document Book III as Exhibit 3, with the exceptions noted.
THE PRESIDENT: If Counsel for the Defense will offer the books in the manner suggested, The Tribunal will make a blanket ruling admitting them all with the exception of the four which will have to be examined before a ruling is made.
DR. ORTH: From Document Book I I want to refrain from submitting Document 20 which was objected to by the Prosecution. The document was put into the document book at a time when the witness Suchomel was not yet here as a witness; about the contents of that document he has testified here as a witness; that document is not needed.
As for Document No. 26, in Document Book I, I shall also refrain from submitting that, for what is stated in the document has been corroborated in other documents. Therefore, I offer Document Book No. I as Alstoetter Exhibit No. 1, as a whole.
THE PRESIDENT: The book, as a whole, is received as Alstoetter Exhibit No. 1, subject to the limitations which Counsel for the Defendant Alstoetter has stated.
DR. ORTH: I refrain from submitting Document No. 34 in Document Book II.
MR. LAFOLLETTE: If Your Honors please, with reference to Document 59, in Book II, our objection is that there is nothing that shows that Dr. Kastner, who certified it, is a proper person. If counsel, if Dr. Orth will state to the Tribunal that Kastner is not a co-attorney and is qualified under the rules, I will withdraw that objection.
DR. ORTH: The document in the original is signed by Guenter W. Kastner, and it has a stamp of Kornwestheim; I should assume that it is an American office.
MR. LAFOLLETTE: That is satisfactory.
THE PRESIDENT: Do you desire to offer all of Document Book II with the exception of Document 34, to which you have referred as an exhibit?
DR. ORTH: Yes, Your Honor.
THE PRESIDENT: Document Book II is received as Exhibit 2.
DR. ORTH: And I offer Alstoetter Document Book III as Alstoetter Exhibit No. 3 in its entirety.
THE PRESIDENT: Document Book III is received as Exhibit 3 in its entirety.
DR. ORTH: Mr. President, in the course of the examination of yesterday, I had two individual documents identified as Nos. 1 and 2. These two documents are now received as part of the book. Therefore, in order to correct the record, I ask permission to point that out and that -
THE PRESIDENT: They are included in the book?
DR. ORTH: Yes, Mr. President.
THE PRESIDENT: They are received along with the rest.
DR. ORTH: Mr. President, I have Alstoetter Document Book IV which is a supplement volume; it is not quite ready. I ask to be permitted to submit it at the end of my case in chief.
As for the rest, I have concluded now my presentation of evidence.