Q But you did notice that most of them were wearing wooden shoes and you did observe that they had a lot of foot trouble, as has been testified to here a number of times by the inmates who wore them? That is right, isn't it, witness?
A Yes, they wore wooden shoes in certain cases in the plants, and Herr Mummenthey told the camp commandants in order to improve this problem in certain cases. This was done, and in certain other cases, because of simply difficulties, the shoes could not be obtained.
Q You didn't quit working the prisoners though because you couldn't get adequate clothing, and you couldn't get proper shoes, and you couldn't get socks, and couldn't get gloves, did you, witness? They kept right on working just as they had before, didn't they, witness?
A When the shoes were not in order they had to go on working temporarily until new shoes could be obtained, of course. Only inmates who were ill were not employed in our enterprises for the reasons which I named before.
Q Now, let's go to this "hours of work." I understand from your testimony that they worked these gravel quarries of the DEST right throughout the year, right through the winter months. Isn't that right?
A The gravel works did not work throughout the year. They worked from December -- they did not work between December and March. It was customary throughout Germany that these gravel pits are seasonal work. During the cold period, work is stopped as the river is frozen, which is one of the reasons that no work is possible. During the winter the various machines and tools were being repaired.
Q But they did work the granite quarries and the brick works right through the whole year, didn't they witness?
A Yes.
Q Would you say it got a little cold and miserable out in the cold in the winter, and it was raining and cold, snowing, freezing?
A Work was only discontinued when there was a fog or when it was too cold, when there was snow above ground, which happened in Flossenburg particularly often because its altitude is 800 meters.
Snow comes early there and, therefore, work had to be discontinued automatically during winter there. Work went on in the workshops because the raw material had been assembled in those workshops for the winter. The workshops themselves were all heated.
Q Witness, let's look at this memorandum from the defendant Pohl concerning the working conditions in the concentration camps. It is Document R-129, Prosecution Exhibit 40. It is on page 68 of Document Book No. 2. You testified that the hours of work were from eight to nine hours, is that right, witness?
A I testified nine to ten hours.
Q Nine to ten hours?
A Nine to ten hours, depending on the climate, the time of the year, plus a break for lunch. We also had periods during winter when work was done only four or five hours.
Q Well, now, do you take out the lunch period from this nine-hour day, we shall say. They got thirty minutes for lunch, and does that mean they worked eight and a half hours -- or did they still work nine hours, actual work?
A They worked nine hours, nine hours plus one hour for lunch, which adds up to ten hours. That was the maximum period.
Q How long did it usually take them to get from the concentration camp out to their place of work? How long did that take them, witness?
A In Flossenburg they had to march for four or five hundred meters -- six hundred meters; in Gross-Rosen about eight hundred meters; and Mauthausen and the Gusen plants about five hundred meters; in Mauthausen Betrieb Wienergraben, about four to six hundred meters; in Natzweiler, I don't know.
Q You never heard of any camp where it took them as long as thirty minutes to get from the camp to their place of work?
A That happened only in Oranienburg at the beginning when the so called "small camp" had not yet existed.
At that time the inmates had to march from the camp to the plant, but that was discontinued later on the advice of defendant Mummenthey, and the so-called "small camp" was built in Oranienburg in order not to have them to march to work.
Q Now, witness, in this document, which I have handed to you, do you find paragraph four there, where Pohl instructs camp commanders that this employment must be - in the true meaning of the word "exhaustive" in order to obtain the greatest measure of performance? Do you find that paragraph 4?
A One moment, I want to read it first.
Yes, but you must not interpret the term "exhaustive" like that. What I mean by that is "exhaustive", that it must be done completely, so to speak, but not to exhaust the man until he becomes too tired. Nor works manager nor any of us ever regarded it that way. We were interested in people who were capable of doing some work not people who were incapable of work.
Q What is that interpretation you gave to "exhaustive?" I didn't quite understand that, witness.
A The term "exhaustive" I don't regard as meaning that it means a man has to work until the point of exhaustion. It should be carried out "completely". I suppose you understand what I mean by that. I don't mean up to the point of exhaustion. I must not be meant and taken literally.
THE PRESIDENT: The Tribunal is about exhausted with this distinction, Mr. McHaney. We have had it many times; we have arrived at our own conclusion as to what was meant.
MR. MC HANEY: Very well, Your Honor.
THE PRESIDENT: We are at the point of exhaustion.
BY MR. MC HANEY:
Q Now, witness, in your inspection trips did you get any informa tion about the incidence of sickness among the inmates?
A Yes, I heard about that. In 1942 and 1943 -- especially in Mauthausen, and also in Gross Rosen, as far as I remember -- there was an epidemic. One case was dysentry and another occasion typhoid. Thereupon the camp was blocked at once and workers were not allowed to leave the camp for their work. The plant, therefore, had to be shut down for some time; and during that period of time no work was done at all, or at least only with the civilian workers who were still available.
Q And you reported back on these matters what you observed in connection with sickness to Mummenthey, didn't you?
A These reports reached us in writing by the Works managers so that we would be informed that the plant was doing no work during that period of time.
Q Didn't you receive periodic reports from the plant managers on sickness, deaths, turnover among the inmates?
A During the period of time of these diseases no work was done, and after this, of course, it was handled so that a large number of inmates who had gone out to work could no longer turn out. Therefore, the works managers complained to us; the plants could no longer be operated which was explained by the illness or the epidemic which had broken out.
QQuite aside from those incidents, witness, didn't W-I receive monthly reports from each plant manager concerning labor statistics: how many men were working, how many inmates, how many had gotten sick, how many had died, what the turnover among the inmates employees had been?
A No, we only received reports about those who actually went to work. Sometimes the works managers would also report that such-andsuch a number of inmates did not turn up at work because they were still ill. Fatalities and other matters we were not given either in writing or any other way.
Q. You weren't interested in these labor statistics; they didn't affect the operation of the DEST plant, is that right?
A We could not go on with our work when the workers were not available. The plant could not operate during that period.
Q I don't think you testified this morning as to whether or not foreign inmates -- that is, inmates from occupied countries were used in the DEST industries. You did have such foreign inmates, didn't you, witness?
A From the way they talked, you could say that there were not only Germans working in the camps.
Q Did Mummenthey ever go with you on any of these inspection trips?
A He and I once went together to Flossenburg; otherwise he always went by himself because the two of us could not be absent from Berlin at the same time.
Q How often did Mummenthey go on these inspection trips himself?
A That varied. Normally he would go to every plant twice or four times a year. Towards the end he went more frequently, particularly to Flossenburg and St. Goergen.
Q St. Goergen was at Mauthausen, wasn't it?
A Yes, near Linz.
Q Now, these plant managers, weren't they appointed by Mummenthey?
A The plant managers were appointed by Mummenthey.
Q And they were pretty good men, weren't they, witness, in your estimation?
A The plant managers were all experts, technicians, were extremely decent and courteous men who took their duties seriously.
Q And they reported regularly to Mummenthey about the operation of the plant, didn't they, witness?
AAs far as commercial matters were involved, of course; because when I returned from an official trip I had to give my report about the work I had done while I was away.
Q Well, witness, you testified at great length this morning that Mummenthey was a very socially-minded man, and that he went out of his way to be helpful to inmates. Now, where did he get his information about the difficulties the inmates were laboring under upon which to base his actions to help them?
A He received them either when he inspected the plant or when the managers came to Berlin to report, or else in writing.
Q And how often did the managers come to Berlin to report?
AAs a rule, once every three months, but then one of us would always go down to see the plant. Towards the end, the conferences were held more frequently as difficulties increased from month to month, particularly in the supply of material.
Q Do you know that a release of inmates who worked for DEST was considered important should be and was refused?
AAs far as I know with ourselves we released thirty to forty prisoners, by illegal methods. In order to do that we would have had to contact the commandant's office; then Mummenthey and other people endeavored to get those inmates who had worked as skilled workers in the plant, and who were efficient, decent people, released. A great many inmates later on were employed as civilian workers in the DEST enterprises.
Q Witness, I did not ask how many were released. I asked if you did know whether people whose release was justified, were retained by DEST as inmates, because their work was considered important. That their release was blocked by DEST. You knew that, didn't you, witness?
A I am afraid I have not understood your question. Please repeat it.
Q I said, did you not know that inmates who were ready to be released by the RSHA had their releases blocked by DEST because they were working for the DEST?
A I know nothing about that.
Q You testified about the nice conditions in the quarries.
A Yes.
Q Did they have covered places for the stone masons to work?
A The stone masons worked in the open air in the summertime, which is quite usual in that profession, and in the Autumn and Winter they worked in very up to date workshops in which there were heaters. In the summertime they were working in the open air, as it would have been too hot in a workshop.
Q In Document NO-1049, Prosecution's Exhibit No. 436, on page 46, in Book XVI, in a report by Mummenthey, in June 1942, he said in Flossenburg, and in the quarry of Brucksbuehl a covered working place for the stone masons, and a wooden barracks for a crane was erected.
Apparently in 1942 they were just getting around to erecting a covered working place for the stone masons. Do you know anything about that?
AAll workers in the Autumn and Winter when it was bad weather were working in workshops, no matter whether they were civilians or inmates.
Q Do you know anything about when they first erected the shed at Flossenburg for stone masons in 1942?
A The workshops were erected at the beginning of, or as early as 1939.
Q What do you know about the death rate among the inmates in the DEST Industries, and, particularly in the quarries? What percentage per month was it, do you know?
A I am afraid I can not make any statement about that, nor did we receive any report about that.
Q You did not inquire about that?
A No, I did not.
Q Well, you can not testify then that people were not killed, and did not die from exhaustion in the camps, if you did not receive any reports about it, can you, witness?
A We did not receive reports on that situation you named just now.
Q You said that there were pretty bad relations between the plant manager, and the camp commander. In connection with Flossenburg you mentioned that Mummenthey had a camp commander removed, is that right?
A He did not remove him himself. He merely reported it to Pohl, and suggested to Pohl that the man should be dismissed. Shortly after making that suggestion Kuenstler was removed from his office.
Q That indicates that Mummenthey had pretty considerable influence, doesn't it, witness?
A Yes, he wanted to obtain by that the relations between the plant works in Flossenburg and the camp management should improve.
Q You said something about the payment to skilled and unskilled labor, that is inmates?
A Yes.
Q You said that money was sent to the camp management. You don't mean to testify that the inmates got the money, do you, witness?
A No, they did not receive the money themselves. These four marks for unskilled, and six marks for skilled workers was paid right by the plant to the camp management, whereas, the inmate himself received bonuses, with which he could get in the camp by himself food, cigarettes and other articles of that sort.
Q I did not understand your connection with the Slate Oil Company. You were in 1944 manager of the Slate Oil Company?
A No, it was like this. Pohl asked me temporarily to act as a dummy, and become the manager as such. I managed the firm for about three months, or, at least, was listed on the commercial register as such, although I never did any work there and somebody after that took over for me, a man by the name of Frank, who was killed in a motor car accident, later, and, then as far as I know, Staff-W continued to direct that plant. What became of this Slate Oil business, I am not able to tell you, unfortunately, because I know nothing about it.
Q How long did you remain manager on the commercial register, do you know?
A Eight weeks, perhaps, or perhaps three months. Then I was struck off. I think that Dr. Volk of Staff-W can tell you more about that, or Dr. Hoffmann.
Q They know very little more about it than you do, witness. Did Staff W-I or Mummenthey have any connection to Slate Oil Company?
A No, he did not.
Q You know nothing about the conditions there?
A I know nothing about the conditions in Slate Oil Company G.m.b.H. because I did not do any work for that company. I did not receive any salary, nor did I do any work. As I said this morning, Pohl and I went to Schoemberg together once.
Q When did the DEST enter into the manufacturing of war material?
A In the granite works of Flossenburg in the Spring of 1943. In the granite plant work at St. Georgen in the Summer of 1943.
Q Now did you also inspect those operations?
A Yes, I did.
Q And they were controlled by W-I, and Mummenthey, just as were the quarries and brick works?
A I did not understand the question.
Q I say, those munition manufacturing operations were controlled by Mummenthey and W-I, just as were the quarries and the brick works?
A These were not producing munitions, but spare parts for aircrafts. They were, of course, controlled just as the quarries were.
Q Did the DAW have any connection with those armament operations?
A No, not so far as we were concerned.
Q You mentioned something the other day about the low insurance premiums paid by DEST, because of the lack of any accidents in the quarries.
A Yes.
Q You are not suggesting to the Tribunal that the inmates were insured, are you witness?
A No, no the inmates were not insured; the plant was insured and only the civilian workers were subject to accident insurances.
Q Doesn't that perhaps explain why the premiums were so low, because you had very few people insured, all who worked indoors were civilian workers?
A No, the reason was a different one, because our equipment was very much up to date, the security in the enterprises was extremely good.
That was the reason why it was possible to classify it at a low degree, the risks had been lower.
Q Did you state that Mummenthey sometimes had conferences with inmates, and tried to assist them?
A Yes, when Mummenthey visited the plants he often talked with men here and there about whether there was anything he could do for them. When, for instance, he heard that they were short of clothing, he told the works managers to try to get some; the same thing applied to foods. He attempted frequently to get additional food, such as bread, potatoes, and flour, and even milk for the inmates who were doing the heavy work.
Q. Whatever the conditions were in the DEST industries we can conclude that Mummenthey was well informed about them, wasn't he, witness, because he made these inspection trips, and even talked to the inmates and he had a very sociological attitude towards it, is that true?
A Yes, of course, he himself informed himself about these, and tried to do what he could.
Q Now, witness, getting back to the employment of Jews, and your knowledge about such matters.
A Yes.
Q Do you want the Tribunal to believe that you knew nothing about the systematic program of Jewish persecution in Germany during the war?
A It was entirely unknown to me. All I know was that in the scheduled diamond cutting works there were Jews to be employed at first, but that they were not employed in the final event, otherwise, I know nothing about the employment of Jews by the different plants up till this time -
THE PRESIDENT: Mr. McHaney, ask him the question again. Mr. McHaney you let him get away from you with the answer.
BY MR. MC HANEY:
Q Witness, I say, did you know anything about the systematic program of Jewish persecution in Germany during the war?
A No, that was entirely unknown to me.
A. No, that was entirely unknown to me.
Q. Now, on this Herzogenbush diamond cutting operation they had some Jews cutting diamonds in the concentration camp of Herzogenbusch in Holland, didn't they, witness?
A. No, that wasn't done there. As I said before it was to be started. Germans who had suffered injuries in the War had to learn how to cut diamonds in order to learn the profession of diamond cutting but this never came about. They were never trained nor did they work as no raw material was available.
Q. Now, witness, we have a document in the record, NO-1278, Prosecution Exhibit 440, Book 16, page 60, which tells us that this diamond cutting plant in Herzogenbusch concentration camp was established in December 1942. In July 1943 Mummenthey and W-I were ordered to take it over, which they did.
A. No diamond cutting work was established. All that happened was that machines which were available to the camp administration of Herzogenbusch were to be put up to do work later on. But, when the invasion started the machines were taken from the camp to Bergen, and I was at the time by orders of Mummenthey, together with Sommer, ordered to go to inspect the work shops where the machines might be put up. As we had no concrete for the bases of these machines these thirty-eight cutting machines were not put up in the end. These cutting machines which wee in Herzogenbusch at the time were not the property of DEST.
Q. You have seen from this document, I imagine, and you very well know that the reason that operation in Herzogenbusch was stopped was because those Jews were deported on order of Himmler of 1944, you know that.
A. All I can tell you is the machines were taken from Herzogenbusch to Bergen and no work was done -- never -- because if you don't have raw material you can't do work.
Q. And they took the machines from Herzogenbusch to BergenBelsen because the Jews had been transported from Herzogenbusch and you were ordered to set up the machines in Bergen and get 60 Jews to run the machines and you couldn't do it, could you?
A. We didn't do any work, nor did we take the machines to Bergen. The camp took them with it to Bergen when it was evacuated.
Q. I suppose you can tell us what you thought the reason was for stopping the diamond cutting operation in Herzogenbusch? They had Jewish diamond cutters cutting the diamonds in Herzogenbusch. Why did they quit and transfer to Bergen unless those Jews were transported and killed?
A. We didn't quit. We didn't even start it.
Q. Your testimony is that they never cut any diamonds in Gerzogenbusch?
A. Yes. Neither in Herzogenbusch nor later in. Bergen-Belsen did we cut one diamond.
Q. I suppose you know nothing about the fact that 1000 Dutch Jews were sent to your quarry in Mauthausen and killed there through work. You know nothing about that?
A. No, know nothing about that.
Q. No further questions.
THE PRESIDENT: Any further examination by defense counsel?
DR. FROESCHMANN FOR MUMMENTHEY:
Q. Witness, it becomes clear to me from the cross examination that I must ask you a few more questions. I shall start with the last question. It was alleged by the Prosecution and you were asked whether you knew that in Mathausen Dutch Jews were killed.
A. No, I did not know that.
Q. Just a moment, please. Did I understand you correctly that you told us this morning and this afternoon in the works of DEST nobody was being killed or worked to death because the DEST was interested only in people who were capable to work.
A. Yes, that is what I wanted to say.
Q. I asked you yesterday whether in Mathausen, apart from quarries of the DEST, there were other quarries. Is it correct that you said Yes to that yesterday?
A. In Flossenbuerg there was another quarry which did not belong to DEST. I did not say anything about Mauthausen. It is not known to me whether in the camp at Mauthausen there were such quarries.
Q. I don't mean whether there was one in the camp itself but whether in Mauthausen another quarry was in existence which did not belong to DEST.
A. Yes, two of a Vienna firm.
Q. Therefore, even if the statement is correct that has been put to you that Jews were killed in quarries in Mauthausen that does not mean necessarily that they were killed in quarries belonging to DEST.
A. I know nothing about that and I can say with certainty that nobody was killed deliberately in plants and works of DEST.
Q. It was my impression that the last but one question of the Prosecution you did not quite understand. The Prosecution asked you whether you knew anything of a systematic policy of exterminating of Jews in Germany during the last years of the War?
A. I never heard anything about that at all. It was for the first time when I was a prisoner in Dachau that I heard anything about the fact that in Auschwitz there was an extermination camp.
JUDGE MUSMANNO: Mr. McHaney said "Did the witness know of the program of systematic persecution of the Jews" which is much broader than extermination and even of that the witness said he knew nothing about it. Your question does not correctly reflect the scheme of the question by the Prosecuting Attorney.
DR. FROESCHMANN: If your Honor pleases, my impression was that the Prosecution wanted to ask this quite generally whether he knew anything of this broad policy of extermination.
JUDGE MUSMANNO: You changed the wording. I put it down here in my notes - program of systematic persecution.
DR. FROESCHMANN: I may have been wrong and the question becomes superfulous now.
BY DR. FROESCHMANN:
Q. Witness, on cross examination you frequently pointed out that the defendant Mummenthey investigated all complaints and made it possible, among other things, for a camp commandant to be dismissed in Flossenbuerg. That is correct, witness?
A. Yes, it is.
Q. The Prosecution did then put the question to you whether this would not show that Mummenthey was a highly influential man. My question to you is, was Mummenthey's work, which led for instance to the dismissal of the camp commandant of Flossenbuerg to be explained on his strong influence with Pohl or by the fact that he always insisted with Pohl that conditions should be improved and Pohl seemed inclined to comply with these suggestions?
A. Yes, this was an isolated instance. The case of Kunzler was so appalling that employees in the plant could no longer stand it and for that reason that made certain detailed information accessible to Mummenthey and on the basis of that Mummenthey succeeded in getting Pohl to have Kunnzler removed.
Q. Witness, it seems to me that you made one mistake concerning the question put to you by the Prosecution. Prosecution asked you whether the inmates working in DEST enterprises had been insured. And you answered in the negative. I should like to ask you, first, do you know all about the German legislature concerning accident insurance?
A. No, I don't, all I know is---
Q. Do you know that according to German Insurance laws concerning accidents it is always the plant which is insured which means that all persons who are working in that enterprise and the members of this enterprise are automatically insured, do you know that?
A. Yes, I know in a civilian enterprise it is the duty that every worker there must be insured. In the case of DEST it is different as civilian employees and inmates worked together at the same time.
Q. Now do you know whether inmates were excepted from the insurance?
A. I am unable to tell you that.
Q. That is what I wanted to know -- if you had sufficient legal knowledge to answer the question by the Prosecution just with No.
A. No, of course, I don't have sufficient knowledge.
Q. Therefore, you have to change your testimony to the effect that, in your opinion, the insurance was not extended to the inmates. But you must admit you do not have sufficient legal knowledge in order to judge any question.
A. Yes, that is quite true.
Q. Witness, on cross examination you also spoke about armaments. With what firms did DEST have any joint work in armaments?
A. With Messerschmitt in their enterprise in St. Georgen and Flossenbuerg.
Q. Do you know anything about the arrangements made between Messerschmitt and DEST concerning the production of these spare parts.
A. Messerschmitt supplied skilled workers, aircraft builders, engineers, who worked at Messerschmitt's expense. Some of the employees who had formerly worked with DEST were also made part of this operation. Messerschmitt supplied all the raw materials, such as aluminum and other materials needed for the production and in the plant the material was simply processed, put together, and the finished fuselage was sent on so that the engineer could complete it.
THE PRESIDENT: Dr. Froeschmann will you have considerable more questions?
DR. FROESCHMANN: If your Honor pleases, I think it will take me at least ten minutes.
THE PRESIDENT: Well, we will have the recess now.
THE MARSHAL: The Tribunal will recess for 15 minutes.
THE MARSHAL: The Tribunal is again in session.
BY DR. FROESCHMANN:
Q. Witness, we had just stopped with the relationship between the DEST and the Me. Now, I want to know who had the supervision over the inmates while they were making those armement parts?
A. Of course, the technicians and the engineers were there from Messerschmitt, because we didn't have any knowledge about the construction of airplanes and the development of airplane parts. We did not have the necessary background and only the technicians from the Messerschmitt A.G. were the only ones who could do that.
Q. Do you know anything in particular about the armament works in Mauthausen? What conditions prevailed there?
A. In Mauthausen there was a plant for the firm of Steyr with which we are not concerned at all. The DEST had only to put at the disposal of Steyr the existing halls were chiseling was being done to the Steyr works. That is where the Steyr people were carrying out their work. In this area of DEST there was also a plant for the manufacture of parts, fuselages, and wings. As of autumn 1943 or the spring of 1944 there was also an underground plant for the manufacture of airplane parts in St. Georgen, and small parts also were being manufactured for a Whermacht agency which were screws and so on. Nothing special.
Q. You couldn't tell us anything about the kind of work carried out?
A. No, I couldn't. All I can tell you is that a lot was welded and bolted, and also the various instruments were built in, which instruments were put at our disposal by Messerschmitt.
Q. The prosecution also put before you the death rate in concentration camps. Did the DEST have any knowledge of the death rate in the camps?
A. No, it didn't.
Q. Did monthly reports come to you from the individual plants about the work in those plants?
A. Yes.
Q. And those monthly reports, did they contain the death rate of the inmates who were working in the DEST?
A. No.
Q. One more question in this connection, witness. The prosecution when discussing the clothing of the inmates and the food for the inmates pointed out that the clothing, for instance, consisted of wooden shoes and that they had bad results on the inmates, particularly in the wearing of wooden shoes. Witness, I would like you to tell in a few brief terms the Tribunal if in Germany during the war years it was possible to cover the normal needs of a human being on the free resources of Germany?
A. Personally, I have three children and I was in a large city during the war. I can really tell you it was hardly possible for my wife to get the necessary shoes which we could get according to out ration coupons. Of course, in industrial enterprises where thousands and tens of thousands were used for work, it was the same way, exactly as it was at home in the family.
Q. Now, if the DEST, and by that I mean Mummenthey, tried to get additional clothing and additional food, and if Mummenthey was not in a position to do so, namely, to get that clothing to the inmates in addition to what they had, which would be a prerequisite during peacetime for civilian workers, then the reason for that was the result of his not being able to do so, not his not wanting to do so.
A. I would say it was the result of his not being able to do so. If there was no possibility to get the stuff, then, of course, we could not help. Our efforts were exhausted.
Q. Now, the last question which results from the cross examination today. The prosecution stated at the beginning and discussed the question of chief of office, which question was exhaustively discussed before. I want to ask you one question to clarify that. Was Mummenthey as the senior SS officer in a position to give you orders with reference to the management of your enterprise and by that I mean military, official orders?
A. No, not at all. That is not the way it is to be understood, either. Mummenthey had simply one rank higher than I was. Of course, it was my duty, as it used to be with the Wehrmacht before, to have the person who is lower in rank accept that orders as given by the person who is higher than he is.
DR. FROESCHMANN: Your Honor, I believe I have clarified all the questions in this connection, and I believe I have completed all my questions which resulted from the cross examination.
JUDGE PHILLIPS: Witness, you testified that you, prisoner of war for a period of approximately six months in an American military prison, were required to handle munitions in a munition dump. You don't wish to infer to this Tribunal that you did that during war times, do you?
A. No, it was after the capitulation, Your Honor, from the 20th of July 1945 to the 18th of February 1946, in Roth near Nuernberg. That was an ammunition dump.
JUDGE PHILLIPS: Just straightening up and piling up ammunition in an ammunition dump after the war was over?
A. Yes, indeed.
DR. FROESCHMANN: Mr. President, I believe that my colleague, Dr. Hoffmann, would like to clarify a mistake which I couldn't clarify because I am not as good as he is in English. Would you mind if Herr Hoffmann would clarify this question instead of me.
DR. HOFFMANN: Your Honor, the question which was put by Mr. MacHaney namely, if the witness didn't know about the constant persecution of the Jews in Germany. Mr. McHaney said "persecution" which is correct. The word used was "Extermination", and I can imagine that the witness did not quite understand what was meant by "persecution". The mistake was done in the German translation, from English into German. Of course, those things were known, and I don't believe that the witness doesn't know.