THE PRESIDENT:Proceed.
DIRECT EXAMINATION -- Continued BY DR. KOESSL:
Q.The President asked you whether you made preparations, general preparations for inspections?
A.No, I did not make any preparations for any such inspections, either.
DR. KOESSL:Your Honor, I have just been informed that the interpreter translated "inspect" and "supervise" with the same English word.
What I mean by "inspect" this does not mean "supervise", but only to look at something so that the person who gives instructions to inspect may receive a report about this.
That is all one has to do when inspecting, while "supervising" means a kind of work which includes some power of comand and I wanted to point this out in particular that the witness said that he never supervised but only inspected.
THE PRESIDENT:Dr. Koessl, it isn't necessary to amplify this any further; so long as the witness uses the words, "inspect" and "supervise". I am sure the interpreters will give us those words in English.
DR. KOESSL:Yes, Your Honor.
THE PRESIDENT:Because we don't have any possibility of con fusion between "inspect" and "supervise" as we had between "fehler" and "irrtum."
QWitness, was the execution concluded when you left the location.
ANo, it was not.
QYou also witnessed the shooting of several persons.
Who supervised this incident?
AThis was supervised by the regimental Sturmbannfuehrer, that is, the officer holding the rank of a Major.
QWhat did you have to do with the transport of the persons to be executed at the collecting place in Sinferopol?
AWith the actual transport I had nothing to do, merely had to look at this, too.
I myself did not load any persons, or give any instructions to load any persons.
QTherefore, you were not entitled to supervise or to guard, it was not up to you?
ANo, I was not in charge of the supervision. I did not have to supervise any one, and I was not in charge of anything except for watching and seeing.
MR. WALTON:If it please the Tribunal, I have not serious objection to counsel for the defendant loading him, a little bit, but when he suggests the answer, the complete answer for him, I find myself objecting.
THE PRESIDENT:You want to make a differentiation between leading the witness, and dragging the witness.
MR. WALTON:Yes.
THE PRESIDENT:You think he is dragging him.
MR WALTON:By the bridle, yes, sir.
THE PRESIDENT:Please don't drag the witness.
DR. KOESSL:It was only meant to be a summary of what the witness has already said.
BY DR. KOESSL:
QWitness, did you take part in the preparation of getting ready the execution in any way?
ANo, neither in the preparation nor in the actual execution did I take part in any way.
QPlease look at your own affidavit, Document Book I, English page 108, German page 141, Document No. 3055, Exhibit No. 28.
Are the events as you described them during the execution, correctly related in this affidavit?
AInsofar as they refer to the location or the Period they are correct, but the very formulation in the nature of my mission is incorrect.
This refers in particular to the expressions "supervise" and "Inspect," I think it is the same in English.
I think the word "supervise" means those two words in the German language; also the formulation of "I took care of it."
These wordings do not correspond with my actual mission.
QWhy did you not correct these expressions when signing your affidavit?
ABefore signing my affidavit I talked to Mr.Wartenberg for some time about these wordings.
I told him that in place of "supervise", which is obviously deducted from the English, it would be better to use the words, " To inspect" because that was my actual mission, to inspect and not to supervise.
In English I would express it, "To look at".
THE PRESIDENT:Dr. Koessl, I, of course, don't recall now whether you questioned Mr. Wartenberg on this subject.
DR. KOESSL:Yes.
THE PRESIDENT:Did you question Mr. Wartenberg?
DR. KOESSL:I asked why the witness did not correct these expressions immediately because that would be obvious.
And now the witness is about to say why he didn't make those corrections, I myself questioned Mr. Wartenberg for a long time.
THE PRESIDENT:Yes. Would you please give me the reference to that interrogation in the transcript so I may look at it when we recess?
DR. KOESSL:Yes.
MR. WALTON:I shall get a copy of the transcript during the lunch hour, Your Honor.
THE PRESIDENT:Very well, Mr. Walton will get me the English transcript.
That will be allright, Dr. Koessl?
DR.KOESSL:Yes, your Honor.
BY DR. KOESSL:
QWhy did you not correct this, witness?
AI was not able to make these corrections. During our conversation Mr. Wartenberg gave me repeatedly to understand that he did not see any difference in the wording he used and my explanations in his opinion.
He said repeatedly this was merely quibbling, and the correction of the expressions was not permitted, and, I would like to say here specifically that, if I wished to make corrections that I had to tell Mr. Wartenberg about these beforehand, and, Mr. Wartenberg had declared repeatedly, "you can only make such corrections which I allow you to make", and thus, on 21 February, when this affidavit was submitted to me for the first time, I was allowed to make eight corrections, but the corrections of the other wordings or phrases, however, I was not allowed to make, but Mr. Wartenberg told me that at an appropriate time I would be able to explain these wordings as I wanted to.
QWhen did you sign this affidavit?
AThis affidavit, which is here in the Document books now, was signed on 24 February 1947.
THE PRESIDENT:Dr. Koessl, opposite paragraph 3 in that affidavit there appears a note, "handwritten corrections initialed H/ScH, 24/2/47."
Witness, what correction did you make in that paragraph?
AYour Honor, if I understood you correctly, this must be the only correction which I made in the affidavit on 24 February in my handwriting.
QWell, did it refer to a correction in paragraph 3, or did it refer to a correction on that page, generally?
ASofar as I can recollect, your Honor, this handwritten correction refers to the beginning of this paragraph 3, namely, the date "in December 1941."
I believe this was changed in handwritten, and that it said previously "in January or February 1942."
this is - and I shall come to that again - the change of the text of the other affidavit which I gave on 21 February 1947, concerning the same subject.
QWell, if you were already addressing yourself to that paragraph, and making one important change, namely the date, why couldn't you insist upon changing the word "Supervise" if you did not like the word "Supervise."
AYour Honor, in this paragraph 3 there is another important point which I would like to have had corrected, if Mr. Wartenberg would have permitted me to do so.
It is the wording, "I was assigned for this by Ohlendorf or by Seibert," right at the beginning.
At the time I pointed out to Mr. Wartenberg that this wording "or by Seibert" could not be right because at that time Herr Seibert was not with the Einsatzgruppe at all, but he was on leave.
I, therefore, would have liked to cross it out, but Mr. Wartenberg told me that in my interrogation on 18 February I had said when he questioned me that "Herr Ohlendorf or Seibert gave me that order."
I told him thereupon that possibly I might have said that at first, but when considering this I had to correct myself. Of course, I knew exactly at that time that Herr Seibert was not present.
THE PRESIDENT:Would you think that this might be an appropriate time to recess. For Lunch-Time, Dr. Koessl?
DR. KOESSL:Yes.
THE PRESIDENT:The Tribunal will be in recess until 1:45.
THE MARSHAL:The Tribunal will recess until 1345 hours.
(Recess until 1345 hours, 5 January 1948.)
AFTERNOON SESSION (The session began at 1345 hours, 5 January 1948.)
DIRECTEXAMINATION - continued
HEINZSCHUBERT - resumed
THE MARSHAL:The Tribunal is again in session.
DR. KOESSL:May I go on?
THE PRESIDENT:Proceed. BY DR. KOESSL:
QWitness, when did you sign the affidavit which was discussed before?
AThis affidavit which was mentioned in the proceedings which is contained in the Document Book was signed by me 24 February 1947 but I would like to draw the attention of the Tribunal to the fact that as early as 21 February 1947 I signed an affidavit of the same contents. In this affidavit I had 8 corrections which I made before I signed it. After it had been signed by me and I returned it to Mr. Wartenberg, in 8 copies, Mr. Wartenberg informed me that now he would have this affidavit re-written owing to the fact that so many. corrections in handwriting had been made and that he would then give it back to me for signature.
QDid you, before you signed the affidavit on 21 February 1947, ask Mr. Wartenberg whether you might be able to correct these sentences and what did he say to you when you asked him?
AHe said to me what I have already said before, that he saw no reason for any corrections as the corrections and limitations which I had made he only regarded as a game with words and, therefore, he was not willing to have this correction made and he also added that at the proper time I could give the proper explanations and make any statements I would like to make.
Therefore, this correction never came about.
THE PRESIDENT:Let me understand this clearly. One affidavit was signed 4 February, is that correct?
AYes, Your Honor.
THE PRESIDENT:Then which one was it in which the 8 corrections were made, the one of 4 February or the one dated 24 February?
ANeither the one nor the other but that was the affidavit of the 21 February in which the corrections were made in handwriting and these corrections which were made in handwriting were then contained in the affidavit of 24 February except one particular part.
MR. WALTON:Owing to circumstances surrounding the affidavit which is not before the Tribunal and which has not been introduced in evidence I think such testimony is immaterial.
THE PRESIDENT:Well, which one is before the Tribunal? which number?
MR. WALTON:The one of the 4th of February and one of the 24th and now he speaks of one of the 18th which has nothing to do with the affidavit in the hands of the Tribunal as a prosecution exhibit.
THE PRESIDENT:Well, calling your attention, witness, to the affidavit which was signed on 24th day of February we see opposite paragraph 3 the words "handwritten correction - initials H.Sch. 24/2/47". Was this written by you after the affidavit had been rewritten by Wartenberg?
A your Honor, the copy which your Honor is quoting at the moment I have not seen but I may assume that it is the original of the affidavit which I made out on 24 February in 8 copies and which I signed but I myself have not seen the affidavit since then.
I only know the cyclostyled copy in the Document Book.
THE PRESIDENT:Yes. An affidavit was submitted to you and you made numerous corrections or a number of corrections. Mr. Wartenberg then said he would have it rewritten, is that correct?
AYes, your Honor.
THE PRESIDENT :And he brought it back to you and you signed it?
AFirst I read it through. Mr. Wartenberg submitted it to me making the remark that this was the affidavit of the 21 February newly issued but unfortunately I had to establish the fact that it was not the same wording - it was not like the affidavit of the 21. Therefore, I was a bit suspicious and I looked at the affidavit and I was very much shaken because this particular point had meanwhile been changed in the text. I had trusted that this, the copy which had already been made out, would be submitted to me again without the text being changed.
THE PRESIDENT :Well, you did even on this re-written affidavit then make a correction?
AYes, as far as I remember one correction and that was referring to the change in the text of the affidavit of the 21st. In this affidavit of the 21st it had said under # 3 "In December 1941" and if I remember correctly this date December 1941 in the affidavit on 21 February was put in by me in handwriting and after it was put in its final form on the 24, now, in the new edition, the wording appeared "In January or February 1942."
THE PRESIDENT:And you made the correction?
AYes, but only the date, nothing to the wording which in this connection is most important.
I was not permitted to make any further corrections and I drew the attention of Wartenberg to the fact that this period in connection with my statement as to who gave me the order and now to my surprise the date had been changed.
THE PRESIDENT:Mr. Wartenberg brought you the re-written affidavit.
He handed it to you and you read it. After reading it you made a change in the date.
That's correct, isn't it?
AYes, your Honor.
THE PRESIDENT:Now, why didn't you also make whatever other corrections were required since you did make one correction?
AYour Honor, I think that Mr. Wartenberg said when I said that some statement of mine had been changed that he could not have resisted and he had to admit that the wording should be chosen again which had already been chosen - that was December 1941.
THE PRESIDENT:Now, just a moment. We are through with the date.
You have made that correction. Let's not talk about that date any more.
you have made that correction.
Now we ask you why didn't you correct the word 'supervise# if you didn't like that word?
AI didn't like it on the 24, and I uttered my misgivings but on the 24 again I was not permitted to correct this just as it was on the 21st.
THE PRESIDENT:I don't understand you saying you were not permitted.
You had the paper in your hands. you crossed out "January - February 1942". you wrote in "December". Why didn't you then go over to the word "supervise", cross that out, and write in another word.
you had it physically in your possession - why didn't you do that?
A your Honor, of course physically I could have done something.
Theoretically, one can see that after the event has taken place but at the time the situation was such that physically I was not in a position to do what I wanted to do.
I said I wanted to change that but Mr. Wartenberg said "Any corrections you want to make you have to discuss with me before and I will tell you whether it is to be changed or not."
And this permission - - -
THE PRESIDENT:Well, did you tell him, "Mr.Wartenberg, I would like to change the word 'supervise'"?
AYes, your Honor. The word supervise as well as other wordings which I tried to change.
THE PRESIDENT:Did you say "Mr. Wartenberg, I want to change this word 'supervise'?" Did you call that specifically to his attention?
AI am almost certain, your Honor, that I said such because I remember specifically that just because of this wordings I discussed this particular bit with him for quite some time and my mind was put to the fact that this particular word should be changed.
THE PRESIDENT:You can dwell on possibilities. We must know definitely whether it did or did not happen.
Did you specifically call to Mr. Wartenberg's attention the word "supervise"?
AYes, your Honor.
THE PRESIDENT:And did you call to his attention the word Seibert,the name Seibert?
AYes, your Honor. And I would like to say here the answer that I got from Mr. Wartenberg concerning this particular wording of the answer.
THE PRESIDENT:What was the answer?
AI don't know literally but I thin, I can give its drift. when I told Mr. Wartenberg that the date had been changed and the passage "or Seibert" is also contained again Mr. Wartenberg told me words to this effect - "Yes, but in January or February Seibert was there again". I told Mr. Wertenberg that that of course was correct, but...
THE PRESIDENT:Listen, witness. We are going over ground which you have tilled a number of times. Now we have cultivated that ground and we have got the harvest - mainly the correction. Don't go back to the date. Let's go back to the other things. We understand the conversation you had about the date - that is settled. you called it to his attention, you convinced him that the correction should be made, and you made the correction as evidenced by the fact that it does appear corrected and your handwritten corrections are here. Well, now why didn't you go through the same procedure on the matter of the word "supervise". That's the question.
A your Honor, I should like to be very brief on this point. I asked for this change to be made on various occasions and was not permitted to make it.
THE PRESIDENT:Not on various occasions but on this one occasion when you corrected this date, why didn't you correct "supervise"?
AYour Honor, perhaps I was not insistent enough in my resistance to this word. If I have changed the wording of the dage, if I succeeded in doing so, it may be so because I was particularly obstinate on this point because I didn't want a co-defendent of mine to be indicted by a negligent remark in this document. All other wordings referred to my own person and after Mr. Wartenberg told me that at the proper time I would be able to explain everything as I meant it, I thought, in the state I was in at the time, that I could no longer resist, that I thought I would have to sign this statement being able to explain later because I did not want to appear in dubious light in case I would resist too long and trusting that I would be able to make use of this promise that I would be able to explain the text, I did not insist any more and now I think the moment has come in which I am able to explain it.
THE PRESIDENT:Well, it you feared that you would be put in dubious light by signing something that said something different from what you intended.
Wasn't that the occasion to correct the dubiosity of the situation?
Wasn't that the time to make the correc tion?
AIf I had had the possibility, Your Honor, I would have loved to do it -
THE PRESIDENT:Well, now just a moment, did Mr. Wartenberg threaten you in any way?
AYour Honor, I must go a little farther....
THE PRESIDENT:Well, please answer that, did he threaten you?
AOn this occasion I was not threatened but I certainly did not feel myself free, in any case not so free that I could say today that without any misgivings whatsoever I just signed this affidavit but I think I must make this explanation, this correction, why I did sign it although I was of the conviction that it was not quite correct.
THE PRESIDENT:Did you read this? "I had the opportunity to make changes and corrections in the above statement.
I made this statement of my own free will without any promise of reward and I was not sub jected to any threat or duress whatsoever". Did you read that?
A yes, but I may say the following, Your Honor. This way of putting it is both correct and incorrect at the same time, objectively speaking.
I was in the position to make some corrections, 8 corrections in fact, and I was in the position to make only 8 corrections, but not in the position to make all corrections.
When it says "I read this statement and" that "I had the opportunity to make corrections" then it is in a way not false, not wrong, but it doesn't explain everything.
THE PRESIDENT:You were allowed to make 8 corrections but not 9 corrections?
Is that what you are telling the Tribunal?
AI had to ask for the permission of Mr. Wartenberg for everyone of these 8 corrections but I did not receive permission for this owrding "supervise". I do not know at the moment whether those are the only corrections which I wished to make on that occasion .
The PRESIDENT: Suppose you do this witness. You indicate to the Tribunal the corrections which you actually made end then indicate the corrections which you want to make now and then we will have it on the record just what this statement should be. Tell us what corrections you did make and what corrections you want to make now. Dr. Koessl, will you please take him over that field? BY DR. KOESSL:
QI will. witness, please state on what passages of your affidavit of 24 February you wanted to make any corrections on your own behalf?
AI may first draw the attention of the Tribunal to the fact that I do not want to make out a new affidavit now, but that I only want to carry out what Mr. Wartenberg had promised me that is to explain what I mean and what unfortunately he worded incorrectly.
QTell us, therefore, very briefly, what words you want to correct?
AWherever it says "supervise" it would say "inspect" or "to look at".
QI may draw the attention of the Tribunal to the fact that it is contained under #3 of the German, the fourth line, paragraph 3-A at the beginning of 3-B, the first expression. Furthermore again at #3 C. Then under paragraph 4, line 3, in the German and then in the next line -
THE PRESIDENT:Well, just a moment, are you making these corrections?
DR. KOESSL:The witness has already stated that all these points where it says "supervise" instead of "look at" or "inspect" - that all these points should be changed. Personally I have marked these points in my affidavit. I therefore wanted to tell you briefly. The witness is in position to do so himself - it would be the same.
THE PRESIDENT:Yes. Now, you said that 3-A was wrong but you didn't indicate how it was wrong.
Suppose you let the witness do it Dr. Koessl. Let him point out in the affidavit where it is wrong. Now, what is wrong with 3-A?
DR. KOESSL:Tell us, witness, under #3 any passages, what passages you want to be changed?
AThe wording in 3-A is completely unclear and it makes no sense. I would like to say -BY THE PRESIDENT:
QWell, tell us why it doesn't make sense. It seems to read very clearly to us. It makes sense. "To see that the location of the shooting be remote enough so that there could be no witnesses to the shootings". I don't know how it reads in German but it is clear in English. why is it so obscure in German?
AI don't know, your Honor, whether you are quoting now from the English, and whether it says there "to see". It says in the German "beaufsichtigen". That would be "supervise" in the English. If it says there "to see" I am in agreement, as I approve of the wording this way, although to "confirm" would be quite correct. I only had to convince myself of the actual order.
QWe will tell you what our impression is from reading this sentence: that you would go to the location to make an observation and make certain that the location of the shooting was far enough away that people who might be in the vicinity would not see the shooting. That, in other words, is what we gather from this 3-A. is the thought you intended to convey?
AI am on principle in agreement with this way of putting it, but according to the wording in the affidavit it means that I had to supervise this particular place where executions took place. I cannot have a supervision of a place. therefore I object to the way of putting it here.
QThis says that you went out and looked over the scene and made certain that the shooting scene would be far enough away that witnesses might not see the actual shooting.
AYes, I was to confirm, myself, to establish the fact that it was in a proper state and that is what I think I have said in my statement. The wording of the affidavit means something else, in my opinion.
QDo you want to emphasize that you did not actually select the shooting place, is that what you want to emphasize?
AYes, Your Honor.
QAll right. This does not say that you selected it. It says that you went there to make certain that the place selected for the shooting was so located that it would fall within the regulations, namely that there would not be any unnecessary witnesses to the shooting.
A yes, your Honor.
THE PRISIDENT:Yes. Let's proceed to the next one. We understand that.
DIRECT EXAMINATION (Continued) BY DR. KOESSL:
QNow, tell us about the other expressions and passages which you did not like.
AThen the next figure,Paragraph 3-B, there again it says "to supervise" so that.....
THE PRESIDENT:So that -- proceed, proceed. BY DR. KOESSL:
QWhat was the wording that you approve?
AIt should read, and I think I said that in my interrogation, that I convinced myself that the collection of money and valuables of people to be shot was not done by force, etc. The next passages, 3-0, here it says again "to supervise that executions were carried out as far as possible in a humane and military fashion."
QAnd what should it be?
AIt should say "to convinced myself" or "to look" or "see" that matters would be carried out like that.
QAny further corrections?
AYes, under figure 4 it says in the second sentence "I went into the Gypsy quarter of Simferopol and I supervised the loading into the trucks of people to be executed". Again it should say "I convinced myself" that this was to be done and not what it says here in the affidavit.
QWhat next?
AThe same sentence in the next paragraph "I took care that people were loaded as fast as possible and that no unrest and no disturbances should take place on the part of the native population. Furthermore, I took care that people who were to be executed should not be beaten while they were loaded into the vehicles.
QWhat should it say?
AThere again it should say "I convinced myself" of the fact of that, etc., there it could not even be formulated "I saw to it." I could only have meant "I convinced myself", because there is nothing else that could have been meant, and I could not have said anything to a different effect during my interrogation. In the last paragraph of No. 4 it says "as it was my task to supervise the whole execution I could only remain a short time at each of the different phases". There again "supervise" is wrong. Again it should say "to inspect" here or "to see", in order to get the true meaning, in order to be able to cope with my task.
THE PRESIDENT:Are those the corrections you want to make in the affidavit?
THE WITNESS:No, unfortunately, they are not all,
THE PRESIDENT:All right, let's have them all.
THE WITNESS:In No. 5 of the affidavit again there is the word, "I supervised". On page 3 of the original, the second sentence begins, "I supervised the SS and regular police that these people should not keep any of the valuables that were collected. Again there was nothing to supervise but only to convince myself, and I had to supervise how these things were carried out and whether they were in agreement with the orders which were given. Again it should not say "supervise". Under No. 5 again, the next hit one sentence, there it says. "This stage was supervised by me in detail so that all valuables should be turned over to the Einsatzgruppe for the purpose of passing them on to Berlin at a later date". This wording might permit the conclusion that it was my assignment to supervise and to take care that everything that was to be taken, actually was taken, so that everything would actually be transferred to Berlin. I think that Mr. Wartenberg thought of this way of constructing it when he formulated the sentence, but again I can only say that it was not my task to supervise these people taking the valuables, that it was not my assignment, but only, and that is what I said this morning, the stage of events, while I was there, to look at it and see to it that it was complied with, according to orders given.
I did not have to actually supervise this procedure. but I only had to see to it that it was done. BY DR. KOESSL:
QAny further corrections?
AUnder paragraph 6 it says "a short while when these executees were already in position in the ditches I supervised the shooting". This supervision again is wrong because I have already stated this morning that the task of supervision was the task of an officer who held the rank of a major. Therefore, there was nothing for me to supervise because there was already somebody who was supervising it who had a much higher rank than I had, and I did not have the executive power that these things were carried out.
QYou have already mentioned this morning one correction referring to Seibert. In the compiling of your corrections I think it would be a good thing if you now mentioned this particular point again.
AIt is No. 3 where it is said that "in December, 1941 - I do not remember the exact date - I was detailed by Ohlendorf or Seibert to supervise the execution of seven hundred to eight hundred people". This wording "or Seibert" is completely wrong for the mere reason that Seibert at that time was not present in Simferopol at all. I think I have already clarified this point by saying that I told Mr. Wartenberg that this was wrong, but he did not permit me to make any corrections concerning Seibert because, allegedly, I had said in the interrogation "Ohlendorf or Seibert". This possibility I could not contest at the time, but I do not want to contest it today, that in the first moment when this question was put to me whether I ever or "what would you say, Herr Schubert, if we had proofs that you had actually to inspect executions?"
that was the question that was put to me at the time.
It was put by Mr. Wartenberg. I think that it is possible that first of all I said when the question was put to me, "Ohlendorf or Seibert". I cannot and do not want to contest that, but before signing the affidavit on the 21st, as well as on the 24th of February, I drew the attention of Mr. Wartenberg to the fact that if that had been what I had said, I would have to correct it now, because Seibert actually was not there at the time but he was on leave in Berlin.
Therefore, it would have to be crossed out, but unfortuna tely, it remained.
THE PRESIDENT:Does that cover all the corrections now?
DR. KOESSL:I just wanted to put that same question to the witness.
BY DR. KOESSL:
QHave you now made all the corrections which you wanted to make?
AI see here under Paragraph 1 of the affidavit another passage which is inessential but which should be corrected.
It is the last but one sentence of paragraph 1. "On the 9th of May, 1934, I was transferred from the Hitler Youth to the Party". It should say "on the 1st of May". I do not know whether I made this statement at the time or whether it is just a printing mistake.
QAnd now let's just discuss again Paragraph 2. Is Paragraph 2 correct as it is put here, or do you have any other remarks to make?
AUnder Figure 2 it says in this second sentence, "Otto Ohlendorf was chief of the Einsatzgruppe his deputy was Willy Seibert". I should like to state in order to explain this and to enlighten the Tribunal on this matter what was meant by his deputy, and I believe that in the interrogation which followed I clarified these matters or at least tried to explain them a little more clearly then they were actually understood and put down by Mr. Wartenberg in this very general form, what can be meant here is only that Herr Seibert in the staff of Einsatz gruppe D and only for the staff of the Einsatztruppe D was the deputy of Ohlendorf, only in this one function, but never, and that is what I said, the case could have happened in which Seibert would have been the deputy of Ohlendorf for the entire Einsatzgruppe D. Therefore I would like to explain this particular wording "Seibert was his deputy", and that is what I said, I think, in my interrogation very clearly, and I certainly did not put it into this very general form.