statements are the original ones. That, however, would be no strengthening of the statement. We do not doubt for one moment that statements of this kind are at the disposal of the Soviet delegation. The defense is not so much interested in those formal statements but in the possibility of material proof. extremely grateful.
THE PRESIDENT: You can go on, General.
GENERAL ZORYA: I think the testimony of Paulus can be of great help to us. I shall now read that part of Paulus' testimony which refers to the history of the preparation of Plan Barbarossa. Request you to read page 27, the portions which are underlined in red pencil, which I intend to read now.
THE PRESIDENT: Perhaps, General, since it is now 12:45, you had better to begin this document before the adjournment.
GENERAL ZORYA: Yes, sir.
(A recess was taken until 1400 hours.)
MAJ. GENERAL ZORYA: Mr. President, following the statement made by the Russian Delegation, I will ask for permission to cross-examine the former Field Marshal of the German Army, Paulus, who will be cross-examined by the Chief Prosecutor of the U.S.S.R., General Rudenko.
THE PRESIDENT: Very well; the witness may be brought in.
(The witness took his place in the box) BY THE PRESIDENTS:
Q Will you please tell me your name?
Q Will you repeat this oath after me? "I swear by God, the Almighty and Omniscient, that I will speak the pure truth and will withhold and add nothing?"
(The witness repeated the oath)
Would you like to sit down? BY GENERAL RUDENKO:
Q Your name is Friedrich Paulus?
Q You were born in 1890?
Q You were born in the village of Breitenau, in Kassel?
Q By nationality you are a German?
Q You are a former Field Marshal of the German Army? Leningrad?
to the Government of the Soviet Socialist Republics?
Q You are confirming such statement? by the German High Command of the armed attack on the Soviet Union.
A Fran personal experience, I can state the following: the General Staff. I was a General Quartermaster and as such I was deputy to the Chief of the General Staff, and in addition carried out the instructions of an operational nature which he delegated to me. other things, a still uncompleted operational plan which concerned itself with an attack on the Soviet Union. This operational work or scheme had been carried through by the then General Major, Marx, Chief of the General Staff of the 18th Army, who for this purpose temporarily had been taken over to the Chief of Staff of the Army. The Chief of the Army, Halder, gave the development of this plan into my hands and on the following basis: Soviet Union, covering the territory, or terrain, the strength of the attack, the manpower to be needed, and so forth. For this purpose there was also mentioned that about 130 to 140 German divisions would be available for this operation. In addition, from the beginning we were to keep in mind taking Roumania into consideration as far as this operation was concerned. The north wing was to include Finland, but this was problematical and was not included in the general plan. the intention of the OKW -- the purpose of this operation was to be first the destruction of the Russian Army in the West, Russia, and to prevent them from getting into Russia Proper.
could not effectively attack Germany. the beginning of November through two attacks with which I was concerned. The officers of the General Staff entrusted with this work, as a basis for the attacks, assumed that to the south one army was to be redeployed from the South of Poland and from Roumania, with the idea of reaching the Dnieper River. To the north of this area there was to be one army group and the strongest around Warsaw; and to the north, to reach Minsk, Smolensk and later to push through to Moscow. from the area of East Prussia to push through the Baltic regions toward Leningrad. Dnieper was to be reached and Smolensk and Leningrad, and then the operation was to be carried on according to developments, and to plan accordingly. of all victories, there were to be several conferences through the General Staff Chief of the Army, that of the Army Groups which had been planned for the East. And further, in connection with this conference, through the Chief of that time, Colonel Kinsel, there was a speech about Russia, describing the geographic and economic situation, about the Red Army, and so forth. And the significant point of this speech was that some preparations for an attack by Russia was not known. With these maneuvers and conferences as I have just described there were theoretical discussions and plans for this offensive and after the conclusion of these conferences, the scheme of the attack was considered concluded and ready. Commander gave our Directive No. 20, and this directive as issued was the basis for all military and economic preparations. And these directions or instructions were to be carried out in such a way that deployment of troops was made ready and developed. These first directives for the deployment of troops in February, 1941, were confirmed by Hitler and they concerned themselves with all these measures and were made known to the troops.
Then several supplementary directives were issued. period of time which would make it possible to carry large movements of troops in Russia, and all preparations were concluded. Then at the end of March Hitler decided to make a change because of his desire to attack Yugoslavia. Then orders as of the 1st of April were set after that time -
THE PRESIDENT : I am afraid you are a little too fast.
THE WITNESS: Where shall I begin?
THE PRESIDENT: I think you better begin where you said that at the end Hitler made a change in the plan.
A (continuing): Because of his decision to attack Yugoslavia, the date for the beginning of the attack had to be changed by about five weeks. That meant postponement to the last half of June. And indeed, this attack actually took place on the 22nd of June, as planned. this attack on the Soviet Union which actually took place on the 22nd of June had been prepared.
THE PRESIDENT: One moment. Did the witness give the date? He said that preparations for this attack had been made, and what I want to know is, did he give the date from which it had been prepared? BY THE PRESIDENT:
Q Did you give the date from which the preparations went forward? and my observations refer back to that point. BY GENERAL RUDENKO: aggression on Soviet Russia ushered in by the participation of Roumania?
A From personal observation, I can say the following: operational workings or preparations for the attack on Russia, and from the beginning, the using of Roumania was envisaged for the marching in, that is the right or south wing of the German Army and that was taken into consideration right from the beginning.
Then a military mission at that time headed by Cavalry Leader Hansen was sent to Roumania. Then a whole Panzer Division, the Thirteenth, was transferred to Roumania. For those who knew about the future plans it was obvious that this step could only serve to make ready the future partner in the war for the future plans and steps which we had to take now regarding Hungary. Army at Zossen, to the headquarters of the Chief of the Hungarian Operational Group. He asked for a conference regarding questions of organization. changing over its units into divisions and also with the setting up of motorized groups such as Panzer groups. The chief of the Organization and myself advised Colonel Laslow at the same time because several Hungarian commissions were in Berlin. The Hungarian Minister of War was also present at the same time, and we discussed the exchange of supplies or the sending of supplies -- German supplies -- to Hungary. these measures with regard to supplying arms to other armies was only possible at that time when these armies could be used for war, for Germany.
Regarding Hungary, there is a further point I should like to ention: With the development of events in Yugoslavia, Hitler at the end of March, 1941, decided to attack Yugoslavia. On the 27th or 28th of March I was called to the Reichschancellery in Berlin where at that time there was going on a conference between Hitler, Keitel and Jodl and on which the Chief of the Army had been active. This conference had just been concluded. When I arrived I was advised by the General Staff of the Army, General Halder, that Hitler had decided to attack Yugoslavia and for once to eliminat a flanking movement from the direction of Greece, because there was a rail line leading to the South, and to get this rail line, and then also for the future -- for the case "Barbarossa" t keep the right flank clear for this plan, for the carrying out of this plan.
officers to go to Vienna to give certain orders to the appropriate officers and then after that to travel on to Budapest to the Hungarian General Staff and to carry out the same mission there and to agree with them on the deployment of German troops in Austrian territory and the participating of Hungarian troops in the attack against Yugoslavia. a conference with General Wert, then with the Chief of the Operational Group of the Hungarian General Staff, Colonel Laslow. These conferences went along in good order and ended very quickly and the desired result was achieved. The result was then written down on a card, and on the card that I received from the General Staff of Hungary was contained the deployment against Yugoslavia, the deployment as Yugoslavia as envisaged, and also the manpower in the Carpathian sector was discussed. This was to protect the rear against the Soviet Union and the fact was a sign that even on the side of Hungary the realization was that an attack by Germany against Yugoslavia would be considered as an aggressive action by the Soviet Union. preparation of these plans and later on into the carrying out of these plans as far as that is concerned at that time I received the attitude of Hitler and it was as follows: the areas which she had lost in the First World War. And in addition, they were afraid that Roumania, which was an Ally of Germany and might push them into the background. As far as this attitude was concerned, Hitler thought Hungary in line with his ideas. But he was, as we could see from various examples, very cautions toward Hungary, and for two reasons: For one, he did not believe Hungary; and secondly, he did not want to make Hungary too many promises at too early a stage, and I can cite one example: The question of the oil regions. Later when the attack was begun that is the attack against Russia, the Seventeenth Army which was fighting at that point had the emphatic order at all costs to take this before the arrival of the Hungarians.
of Hitler was such that as far as certain participation was concerned he counted on it and sent armaments and help but he was not certain when he went to make all his plans and did not set a certain time when to initiate Hungary into his plans.
Then we come to the Finnish question. In December, 1940, the first visit of the Finnish General Staff Chief took place at Zossen. General Heinrichs had a conference with the General Chief of the Army, but I can't remember the contents of the speech out of this conference. But he did make a speech about the Finno-Russian War of 1939-1940. He gave this speech before the officers of the General Staff of the Army and told his officers who were present at the time -- that is in connection with the discussion of the Eastern plans -- this speech before these officers had quite a significance at that time, because it coincided in time with the directive issued in December. were made clear and a judgment of the Finnish troops -- that is, for future plans by the Germans -- could be made known. That was at Zossen at the headquarters, and it was perhaps in the second half of March, 1941. The Chief of Staff of Finland arrived from Salzburg where he had had conferences with the High Command of the Wehrmacht. The contents of these conferences with the Chief of Staff was the cooperation of the Southern Finnish Manpower with the Operation Barbarossa, and working together with the Army Group North which was to come from East Prussia towards Leningrad. At that time the agreement was reached that the Finnish troops were to be determined according to the pushing forward of the German Army Group North and the later command pushing forward toward Leningrad. That was to depend on later agreements according to the development of events.
and the drawing together of the analysis into a common action. under the High Command?
A Will you please repeat the question. I did not quite get it. USSR carried out, the attack which was prepared by the Hitlerite government and the High Command of the German Army? had been prepared much in advance and had been prepared very carefully. The troops involved in this attack had been assembled, and only on special instructions were they taken group by group into the line of future deployment and then, on this whole long front, from Rumania to Eastern Prussia, they were to be ready. Of course, Finland was excluded from this. and the operational plan on a large scale, as I described in the beginning, was tried out mentally, so to speak. Then, the deployment, and marching up of troops in detail, in groups, corps, divisions, was discussed in detail and was put in order in the smallest detail, much before the beginning of the war. Everything was ready. of France. The purpose of a landing in England in June 1941 was to be pretended, and attention was to be diverted from the East through this pretense.
Not only the operational carrying out, but the tactical surprise was planned well in advance. For instance, the prohibition of the boundaries before the beginning of the war meant possible losse and the loss was to be a sacrifice for the element of surprise. On the other hand, the element of surprise across the boundary from the enemy was not expected.
Q. In what way did you determine the aims which were pursued by Germany in attacking Soviet Russia?
A. The purpose of attacking the Volga Line, which was far beyond German strength, is characteristic of the boundless ambition of Hitler and of the nationalist regime. As far as strategy is concerned, the reaching of these aim would have been the destruction of the manpower of the Soviet Union, the fighting forces of the Soviet Union. with the winning of this line there would have been conquered the chief areas of Soviet Russia, with the capital, Moscow, and the political and economic center, the focal point of the Soviet Union! It would have meant the possession of the most important nutritional areas, the most important natural resources, including the oil wells of the Caucasus and the main centers of production of Russia, and also the communications not of Russia, that is, European Russia.
Hitler was very strong on the winning of economic aims in this war. Just how strongly he felt on this point I can cite through a personal axample that I describe. In June of 1943, the first of June, at a conference regarding the army group south in Poltawa, Hitler declared:
"If I do not get the oil of Maikob and Prosnia, then I must quit this war. conquered, economic and administrative organs had been envisaged before the beginning of the war, and everything had been placed in readiness. the aims as mentioned meant the conquering, for the purpose of colonization, o Russian areas and territories, and through their use and spoliation, and through the means gained therefrom, the war in the West was to be concluded win the setting up of German domination of Europe.
Q. And the last question: Whom do you consider as guilty of the initiation of the criminal war against Soviet Russia?
A. May I please have the question repeated?
GENERAL RUDENKO: May I repeat the question?
THE PRESIDENT: The Tribunal is about to address an observation to General Rudenko. The Tribunal thinks that a question such as you have just put, as to who was guilty for the aggression upon Soviet territory, is one of the main questions which the Tribunal has to decide, and therefore is not a question upon which the witness ought to give his opinion.
Is that what counsel for the defense wish to object to?
DR. LATERNSER(Counsel for the General Staff): Yes, Mr. President, that was to be the observation. BY GENERAL RUDENKO:
Q. Then perhaps the Tribunal will permit me to put this question in another way. against the Soviet Union?
A. As far as the defendants are concerned, I would say the most important military advisors to Hitler. That would be Chief of Staff Keitel, Chief of the Operational Branch Jodl, and Goering, in his duty as Reichsmarshal, as Commander of the Air Forces, and as Plenipotentiary for Armament Measures.
Q. In conclusion, I will summarize what I concluded from your testimony, that long before the 22nd of June the Hitlerite Government and the High Command were planning an aggressive war against the Soviet Union for the purpose of colonizing the territory of the Soviot Union.
A. I have no doubt of that according to the developments as I pictured them, and also in connection with all the directives as they were contained in the well-known Green file.
GENERAL RUDENKO: I have no more questions, Mr. President.
THE PRESIDENT: Does any member of the French Prosecution wish to ask any questions?
FRENCH PROSECUTION: No.
THE PRESIDENT: The British?
BRITISH PROSECUTION: No.
THE PRESIDENT: The United States?
UNITED STATES PROSECUTION: No.
THE PRESIDENT: Any member of the defendants' counsel?
DR. LATERNSER: Mr. President, I beg, as the defender for the General Staff, that the Tribunal afford me the opportunity to put the questions which I would like to put tomorrow forenoon. The witness is quite a surprise for the defense counsel, as far as questions which have to be put, especially because of the importance of the testimony, and I would live to have the privelege of postponing my cross examination untill tomorrow mornings' session
THE PRESIDENT: General Rudenko, if the Prosecution has no objection, the Tribunal thinks that this application ought to be granted.
GENERAL RUDENKO: If the Tribunal so wishes, the Prosecution will not object.
THE PRESIDENT: Yes, very well. I don't know whether any other member of the defendants' counsel would prefer to cross examine now.
DR. NELTE: (Counsel for defendant Keitel): Mr. President, I assume that all of us defense counsel may conduct our cross examiniation in the morning.
THE PRESIDENT: Yes, certainly. I was only asking whether any other member of the defendants' counsel would prefer to cross examine now.
DR. NETLE: I personally would like to be able to put my questions after the recess.
THE PRESIDENT: Very well. Then, General Rudenko, the witness can retire and the case will go on. He will be recalled tomorrow morning, and in the meantime you will go on with your case.
General, you won't, I presume, think it necessary to read any more of Field Marshal Paulus' statement, will you?
GENERAL RUDENKO: No.
THE PRESIDENT: Very well, go on, then,
GENERAL ZORYA: Referring to the report concerning the beginning of the attack on the Soviet Union, I would like to remind the Tribunal that in the morning session of the Tribunal on November 30, 1945, the witness Lahousen w testifying and gave testimony which is interest to our case, identifying the persons who were participating in the counter-espionage service.
Section I of the German Military Intelligence and Counter-Intelligence Services Lieutenant-General Hans Pickenbrock, Lahousen's former colleague. The witness deposed this testimony on November 19, 1945, and the the present I would like to read only the following lines from Pickenbrock's testimony, which are on page 1 of the Russian text and on page 334 of the document book.
"I must say," said Pickenbrock, "that already since August and September 1940 the Foreign Army's Section of the General Staff began to increase considerably its intelligence assignments to the Abwehr (Counter-intelligence) concerning the USSR. These assignments were unquestionably connected with the preparation of war against Russia.
"The more precies dates for Germany's attack on the Soveit Union I learned in January 1941 from Canaris. I do not know what sources Canaris used, but he told me that the attack on the Soviet Union was fixed for the 15th May." er chief of Department III of the German Military Intelligence and CounterIntelligence Service, Lieutenant General Franz von Bentivegni of the German Army, which was given by him on December 28, 1945. I present those documents under No. USSR.-230.
I shall at the moment also read only those parts of Bentivegni's testimony question of the commencement of preparations for war against the Soviet Union. Those two excerpts are on page 37 in the document book which was submitted to the Military Tribunal.
"I learned first of Germany's preparations for a military attack on the Soviet Union in August 1940, from the head of the German Intelligence and Counter-Intelligence Service, Admiral Canaris. In an unofficial conversation which took place in Canaris' office, he told me that Hitler had started to take measures for an Eastern campaign, which he had spoken about as early as 1938 in his speech at a meeting of Gauleiters in Berlin.
"Canaris said to me that these plans of Hitler's had now begun to take concrete form.
This was evident from the fact that divisions of the German army were being forwarded in large numbers from the West to the Eastern frontiers and, in accordance with a special order by Hitler, were taking up positions from which to start the coming invasion of Russia." which Fascist Germany's military preparations for the treacherous attack on the Soviet Union took place, I should like to pause at the testimony of General Mueller of the former German Army. This testimony, dated January 8, 1946, I will present to the Tribunal as USSR 149.
THE PRESIDENT (Interposing): General, on this document of General Mueller, does it appear where that document was made and where General Mueller is now?
GENERAL ZORYA: At the end of the first sheet of his testimony there is a date which was written in handwriting, January 8, 1946.
THE PRESIDENT: Where?
GENERAL ZORYA: If I might have a look at the photostatic copy which I just presented to the Tribunal, I would be able to tell where that took place.
THE PRESIDENT: Yes, but there are many prisoner of war camps. We want to know which one and where it is.
GENERAL ZORYA: In a camp located near Moscow.
THE PRESIDENT: Has this document got any authenticating signature on it at all? So far as we are concerned, isn't it simply a photostatic copy of a writing by somebody?
GENERAL ZORYA: Mr. President, this document, like all other documents which have been submitted so far by the Soviet delegation, and those which we intend to present furhter, is a certified photostatic copy. undertook to take steps to comply with it, and the originals of these documents will be certified and they will be presented to the Secretary General.
THE PRESIDENT: Can you tell us where the writer of the document is now?
GENERAL ZORYA: I hardly will be able to tell mare than what I have already said. Perhaps, if the Tribunal will permit me, I can consult my colleagues and report to the Tribunal very shortly where General Mueller is at present.
THE PRESIDENT: Well, we will adjourn now. That will enable you to consult your colleagues.
(A recess was taken.)
DR. NELTE (Counsel for Defendant Keitel): Mr. President, I regret that I also have to say about the document of the Prosecutor under USSR 149, which has been presented under that number--I have to make the same objection and the some request which I made this morning. As much as I know that the Tribunal in regard to this question has not yet made a decision -
THE PRESIDENT: I beg your pardon, Dr. Nelte. The Tribunal has already made a decision.
I think it would be better if, when Defendants' Counsel go to the place from which they wish to speak, they would arrange these earphones before they speak. They pointed out the other day to Counsel for the Soviet Union that documents which were not identified as authentic documents must be identified as authentic, and the Soviet Prosecutor at that time undertook to certify that all documents which he made use of were certified as authentic documents. If they are not so certified, they will be struck out of the record. That ruling applies to this document. report, to the Government of the Soviet Union, but it doesn't contain on its face any certification showing that it is an authentic document. The Counsel for the Soviet Union said before we adjourned that he undertook, as he had already undertaken--that he undertook to produce a certificate that the document was an authentic document; that is to say, that it was prepared, written, by the person who purported to write it, and in those circumstances, the Tribunal accepts the document provisionally. from the record.
Dr. NELTE: If I understand you correctly, Mr. President, then, with regard to this letter that is sent to the Government of the USSR, or a statement, this will be a document or a proof for the content of the statement.
THE PRESIDENT: Certainly. I have already said provided that it is certified as an authentic document. I have said that more than once.
DR. NELTE: In this way, each letter which would be sent to the Prosecution or the Government of the Soviet Union or any other Prosecution, any letter, by certification that it had been written in fact by the writer, that would make it documentary proof which would make it impossible for the Defense to call for the witness for cross examination of the witness.
THE PRESIDENT: That depends where the witness is. We are dealing with witnesses who are scattered all over the globe, and, as we are informed, it is not practical in the Soviet Union for affidavits to be made in such cases, and, therefore, the Tribunal considers that such a document as this falls within Article 19, provided it is an authentic document. witnesses to this Court, but we can not undertake to bring witnesses from all over the world, upon questions which are very often of very little importance.
DR. NELTE: I understand quite the difficulties, and I am grateful to the Tribunal for intending to help us. I only ask in each of these cases to ascertain where the person is who has made that statement, where his residence is, so that the Defense could at least make the attempt to reach him.
THE PRESIDENT: Yes. If the witness is in, or in the immediate vicinity of, Nurnberg, the Tribunal would think that it was only fair if such a document as this were to be put in evidence, that he should be produced for examination, or cross-examination by the Defendants' Counsel, but we do not understand that the man who worte this letter is in the vicinity of Nurnberg. We have no reason to think he is, and I am reminding that the Defendants' Counsel can always apply, if they think right, to issue interrogatories which would be put to any such person as this who has written such a document as this.
DR. NELTE: Thank you.
GENERAL ZORYA: I have made inquiries during the adjournment about General Mueller. General Mueller is in a prisoner of war camp, Numver 27, in Krosnergov.
Can I continue my statement?
THE PRESIDENT: Where did you say he was?
GENERAL ZORYA: Krosnegov. It is in the neighborhood of Moscow. Can I continue now?
THE PRESIDENT: Certainly.
GENERAL ZORYA: The materials which up to now I have produced were produced from the high-ranking command of the German Army. General Mueller belongs, if one can express it thus, to the central link of the body of German generals. He was the Chief of Staff of the Army and commanded an Army Corps. His testimony reflects a series of events which can be acknowledged as deserving attention. I shall read the first pages of this testimony. The preparation for the attack on the Soviet Union is described by him. I shall draw your attention to Page 40 in the document book. On the first page you will see about General Mueller. The third paragraph is marked in red pencil, and now I shall read it:
"The preparation for the attack on the Soviet Union began as early as July 1940. At that time I was chief of staff of "C" Army Group at Dijon in France. General Field Marshal von Leeb was in command. This army group consisted of the 1st, 2nd and 7th armies, which were occupation armies in France. Besides this, army group "A" (Rundstedt), whose task was to prepare operation 'Sealion' (the invasion of England) and army group 'B' was transferred to the East (Poznan). The staff of army group 'B' was given the following forces, transferred from France (part of the armies of occupation): The 12th, 4th and 18th Armies, plus some other corps and about 30 divisions. Of this number, same of the divisions were taken from army group 'B'.
"Directly after the campaign in the West, the OKH gave the order for the demobilization of 20 divisions. This order was cancelled, and the 20 divisions were not demobilized. Instead of this, after their return to Germany, they were sent on leave, and thus kept ready for "Both measures, the transfer of about 500,000 men to the "The next order which gives evidence of Germany's preparations (the 11th), several army corps and about 40 infantry divisions.
The by the Commander of the reserve army (Colonel General Fromm), partly in France, but mainly in Germany.
Towards the end of September 1940 the OKH called me to Fontainebleau.
The Quartermaster General of (afterwards Field Marshal) Paulus, informed me, at first orally, of the order that my staff (the staff of Army Group C.) was to be (Colonel General Weichs), which formed part of this Army Group, to Munich (also by November 1.""In accordance with this order, confirmed later on by a written these units was carried out on time."
THE PRESIDENT: General, I don't think it is necessary to read
GENERAL ZORYA: I am not reading it. I am just referring to has occupied the whole army.
It is to carry out this plan, preparatory to an attack on the Soviet Union.
These plans were and I am now referring to it.
The excerpts which I am reading are underlined in blue pencil, page 2 and 3 of the Russian text.
The "Towards the end of January 1941 I received telegraphic orders exercises at St. Germain (near Paris) of Rundstedt's army group.
South Poland in the direction of Kiev. The plan had in mind the intention also of the participation of Rumanian troops.
In the main refer later.
The director of the military exercises was the Chief of Staff of the Rundstedt army group.
There were present: Rundstedt, Halder, the Chiefs of Staff; of the 6th Army, Colonel Heim; of the 11the Army, Colonel Weler, and of Kleist's tank group, Colonel Zwickler and several Generals of the armoured forces.
The military exercises were held at the place occupied by Rundstedt's army group, approximately between the 31st January and 2nd February, 1941.
The tank forces."
Plan Barbarossa, had appeared. I shall now pass on to the second Union.
I have in mind the measures of field intelligence according number 1229-PS.
In our five documents it is offered under pages of the armies on Germany's eastern frontier should be concealed in regulated.
These activities consisted of taking measures to conceal, According to Pickenbrock's testimony, the intensification of the work On pages 1, 2 and 3 of the Russian text of Bentivegni's deposition, it states as follows (underlined in blue pencil): this "As early as November 1940 I received from Canaris orders to taking place."