But it was quite clear from the beginning that I was not to become Chief of W. This document, incidentally, is a copy. The original is certainly signed with I.V., which means as deputy, because in that month I signed the letters which I had written making it quite clear that I was only deputizing. That this document is a copy becomes quite clear from the document, because it says there D.V. My name is not fully written out. I think probably I corrected the original, but not the copy. This was on the first day of my new duties. That becomes clear from the date, 1 July 1943. Moreover, the letter was taken by the secretary of Dr. Hohberg, who was later taken over by Oberfuehrer Baier, which becomes clear from the dictation mark, "KUE". That is Fraulein Kuehl, who was not my secretary.
Q. Were you at any time office chief?
A. No. Dr. Hohberg on cross-examination was shown a document where he signed in his handwriting, "Chief of Staff W, Dr. Volk." Of that document I have never had the slightest inkling. I never saw that document. It was only here in the dock that I heard first about this document. I did not know anything about this document and I can't understand to this day why Dr. Hohberg called me an office chief. If I may say something about the document, in Volume XIV, Dr. Hohberg has interpreted the document as follows: That there the term of Chief of Staff was introduced for the first time. That is not correct, because other documents have shown that. Moreover, if I had become Chief of Staff W I would not have said, I quote: "By order of the Obergruppenfuehrer I have taken over the tasks of Dr. Hohberg as Chief of W, as of today," but I would have said, "By order of the Obergruppenfuehrer, I have become Chief of Staff W, as of today." That is how one would put it in German. The term "task" shows that I was not Chief of W, which I couldn't be. I was far too low in rank.
Q. What activity did you do in that transition period after Hohberg had left and before Baier started?
A. As I said before, my activity was of a temporary nature and on the whole I was only a stand-in and it did not make any difference to the work I had been doing before. I did not actually fulfill the function of the Office Chief. I did not do that for the reason that in order not to anticipate the new man's wishes, in that brief period of time in this enormous complexity of financial entanglements between various offices, I could not get used to it in a short time.
This also becomes clear from document NO-1039 in Book 14, which is Exhibit 384, and is on page 19 of the English Document Book. I don't think Your Honors need look at this document. We have been discussing it before. It is called, "Unfinished Work of Staff-W". This paper has been signed by Dr. Hohberg, and Pohl, and was given by Pohl to Baier immediately on the 1st day of August. Baier's entry into the office was delayed a few days, I believe. He started only on 9 August. I never saw this paper before. It shows the work which was to be done by the office chief, and I would have been given this paper in order to complete the work which had not been finished.
Q. The Prosecution has submitted that Hohberg had been the first Chief of Staff-W, and then after him, Baier. That is page 1009 of the German transcript, is that correct?
A. That is entirely correct.
Q. How many companies were there in the DWB concern?
A. How many companies formed the DWB concern? I am not able to tell you at the moment. Perhaps I should say under the supervision of WVHA there were about fifty companies.
Q. Please take the document, it is on page 6, of volume 14. It is NO-551, and it is Exhibit No. 382, and there you have the list of the companies. Is that list complete?
A. No.
Q. What companies are missing?
A. I have made a rough list of the companies, because I have been allowed to reflect on this medium for six months. Those that are missing are the companies - for the Combatting of Epidemics, the German Company for Advertisement on Letter Boxes, the Meat and Sausage Factory AG, at Koditz, Apaunia A.G., Milano; Prague Bau, A.G.; Appollinaris Betriebs GmbH; Kumerle, Prague. The German Furniture Works. The German Company for Recreation Homes in Berlin. Lumbeck Forschungs-und Versuchsanstalt GmbH. German Company for furnishing of German Homes.
MR. FULKERSON: I don't want to quibble, but it seems to me we can go on with this list all afternoon. He seems to me now to have named enough to prove his point.
THE PRESIDENT: I think so. Exhibit No. 382 does not contain all of the names of companies in Staff-W, that is the point, is it?
DR. GAWLIK: I am afraid I did not quite follow Your Honor. It did not come through.
THE PRESIDENT: You are trying to say or show that Exhibit 382 is not a complete list of all the companies?
DR. GAWLIK: Yes, exactly.
THE PRESIDENT: Let it go at that without telling us the names of all the companies that are omitted. We will assume that this is not a complete list.
DR. GAWLIK: But it seems to me important, Your Honor, that the names of the companies, particularly of the type of factories, that they should be named, because the Prosecution is obviously aiming at describing the DWB as a holding company for enterprises, the purposes of which were to exploit concentration camp inmates. However, the reason this list has been submitted, it only names concentration camp enterprises. I want to show that was not the purpose of the DWB as a holding office group.
THE PRESIDENT: You want to show that there were a number of companies which did not use concentration camp inmates.
DR. GAWLIK: And also there are types of companies which do research work or publishing which could not employ concentration camp inmates, and would have no reason to do so. I could not explain the practice.
THE PRESIDENT: And advertising on mail boxes, for example?
DR. GAWLIK: These companies never employed inmates.
THE PRESIDENT: That is what I mean.
DR. GAWLIK: But if the witness only told there were a few other enterprises which did not employ inmates, this is not sufficient pro bative value if he does not name the purposes, and also give the names of these enterprises; that the DWB did not have these enterprises in order to employ inmates.
THE PRESIDENT: We can shorten this if you will just have him tell what kind of companies they were. We do not understand the names, anyway, but he can tell what kind of work the companies did.
DR. GAWLIK: Yes. Perhaps we can, certainly.
BY DR. GAWLIK:
Q. Give us a few examples of the type of these enterprises which were not contained in the Prosecution's list?
A. The Company for the Fighting of Epidemics. They introduced a new type of drug against the food and mouth disease.
Q. What about addresses on some letter boxes?
THE PRESIDENT: We understand those. Are there any others, new? Of those that he has not mentioned?
THE WITNESS: Appolinaris, GmbH, has never employed a single inmate. Appolinaris produced soda water. This is a well known British firm, Appolinaris, and it is situated on the Rhine. I shall speak about it and tell you more about that company towards the end of my direct examination.
BY DR. GAWLIK:
Q. Go on.
A. It is an English firm. Then Apaunia, Milano -
JUDGE MUSMANNO: Kindly don't retrace your steps. We already heard about this company.
DR. GAWLIK: I have understood the President to the effect that he wanted to know what type of companies they were, and what they were doing?
THE PRESIDENT: I just mean for the rest, that is, what he is going to talk about from now on.
BY DR. GAWLIK:
Q. Please describe the type of companies?
A. The Company for Furnishing Homes had the task of selling furniture to the SS, and to bombed-out people. Then we had the Settlement in Sehlendorf, and had the Settlement which leased homes; those were the only two companies which were still missing.
Q. Now the question I want to put to you concerns the time up to the foundation of the WVHA until the time when the Inspectorate of Concentration Camps were put under Pohl's charge. Did you during that time as a member of Staff-W, or as a Prokurist of the DWB, have the task of dealing with concentration camps, or handle labor allocation of inmates?
A. I did not have anything to do with that as a member of StaffW.
Q. Did the DWB itself employ inmates?
A. You mean the DWB GMBH? The DWB, GMBH, did not employ inmates, because it was only a holding company.
Q. Were inmates used in the enterprise's subsidiary companies?
A. Yes.
Q. Did you know at that time about the extent to which inmates were employed by subsidiary companies?
A. I knew that the DEST, and the German Equipment Works employed inmates in the majority. I could not give you the exact figures, because I was not connected with anything relating to inmates. Also the German Testing Station for Food employed inmates in four or five big country estates, which were situated near concentration camps. I don't know those estates, but from the fact that they were situated near concentration camps, I would deduce that they would employ inmates.
Q. Did you have any influence on the management of these subsidiary companies?
A. No. I could not give them any orders. I only handled the legal matters of the DWB, and of those companies which had no legal experts.
They were usually the small companies. The large companies, such as the DEST, and the Experimental Food Station, as well as the DAW, had their own legal departments. For the DEST this becomes clear from Document NO-1032, which is in volume 16 on page 11, Exhibit No. 427.
Q. Exhibit 427.
A. Document NO-1032. It is the file plan of the legal department - a contract - real estate, insurance, taxation, and all other tasks usually connected with the legal department.
THE PRESIDENT: That's the DEST you are talking about?
A. Yes, the DEST. The DAW also had its own legal department. So did the Experimental Food Station. As I had no influence either with the companies nor the legal department and since I could not give them orders, the legal departments of these subsidiary companies were under the office chief. The office chief received his orders from Pohl. He reported to him directly. I myself received no knowledge of the affairs which he would discuss with Pohl. Any right to issue orders to the office chiefs was not possible because I was lower in rank, much lower than the office chiefs themselves. Any questions of business management were dealt with by office chiefs or managers in conversations with Pohl. When any factual matters had to be discussed in the way of business management not a legal expert was called in but a commercial expert. And the legal department was my competency. In questions of business management Pohl had his own specialist.
Q. Did you have any influence on the allocation of the inmates and the conditions under which they worked in the subsidiary companies?
A. As far as allocation was concerned and the conditions under which they worked I had nothing to do with these things. All those questions were handled by Pohl because there were no legal questions involved. Therefore, my presence was not required as far as labor conditions of inmates had nothing to do with that either. It becomes clear from the document frequently mentioned before, which is the business order, paragraph 10, where it says expressly under B that all conditions had to be discussed with the Public Trustee which had anything to do with labor conditions. Employees were always free civilian workers and not inmates.
Q. Would you have been in a position to prevent inmates from working in the enterprise?
A. No, my position was far too low for that. In order to give Pohl orders for instance, nor would I ever hear anything about it because I was not called in on conferences about that.
Q. Did you know at the time how such orders concerning allocation of inmates came about?
A. No, I didn't know that. I was never told about that. Nor did I bother about it, nor did I have the chance to do anything because the legal work kept me very busy.
Q. Were you familiar with conditions under which inmates worked?
A. I did not know anything about that. All I knew was the order from Pohl that inmates were to work 11 hours. I do know from occasional stories, I heard that several managers at their own risk let them work shorter hours.
Q. The Prosecution has submitted that you as a member of W were largely active in the participation of building up a big economic enterprise which employed inmates. I should, therefore, like to ask you what firms of the DWB you were participating in and what did you do?
A. When firms were being built up I never took any part.
Q. Were you participating in the foundation of DEST?
A. No. The contract of the DEST was signed in 1938. The company was formed on 10 June 1938 and entered into the Commercial Registry. This becomes clear from Document NO-1273, which is on page 22 of Document Book 16. It is Exhibit 430.
Q. It is, if Your Honors please, on page 21 of the English Document Book.
A. Would you like me to quote this, Your Honors? Would you like me to quote from this document?
Q. Please continue.
THE PRESIDENT: That's the document which shows when the DEST was organized. Isn't that right?
A. Yes, it is the document which shows who made the contract, that it was not I who made it but some other legal expert.
THE PRESIDENT: Well, so long as it wasn't you, you needn't refer to it then.
A. Mr. President, I am not quite clear. I have been reproached that I have been the head of the legal department and that I was connected with enterprises employing inmates. If I cannot justify myself from the documents submitted by the Prosecution I don't know how I am to defend myself because the Prosecution has been kind enough to give me so many document books they allege to be about the Party.
THE PRESIDENT: Well, your difficulty is you are trying to defend yourself against a lot of accusations which haven't been made. Nobody claims you signed a contract with DEST. Nobody says you did.
A. Yes, the Indictment, if Your Honors please, says expressly that I had been head of the legal department of the DWB and therefore had a hand in the organization and foundation of such companies which from the beginning aimed at employing inmates. But, I am only a German legal expert. Under German law you would call me a man who has abetted these enterprises. I wish to contradict these accusations by showing that in my legal matters I did not have anything to do with organizing of such companies.
THE PRESIDENT: I don't think I can make you understand the difference between Indictment and the proof. You only have to meet and contradict the proof that is offered against you - the evidence. Go ahead I don't want to restrict you in any way from presenting anything that you think is material in your defense. So, go ahead and do it whatever way you think it ought to be done.
You see, under American law, you don't pay any attention to the Indictment. You just meet the evidence that is produced against you and no matter what they say in the Indictment if it isn't proved you have nothing to worry about and you don't have to defend yourself.
Well, go ahead and do it your way.
BY DR. GAWLIK:
Q. Did you take part in the foundation of DAW?
A. Yes, that becomes also clear from Document NO-678 which is Exhibit -- I don't know what the Exhibit is. That company was founded on 3 May 1939 but at that time I was not yet with the Main Office for Economy and Administration. I was only called into that office later on.
Q. Did you take part in the foundation of the German Experimental Food Station?
A. This becomes also clear from Book 17 and I shall quote "The German Experimental Food Station GMBH which was founded on 9 February 1939 and entered in the Commercial Registry of the District Court". I was at that time not yet with the Main Office Economy and Administration.
Q. When the contract for Textile and Leather Works was signed did you have any part in that?
A. No, that again becomes clear from Document 1001. The company was formed 21 June 1940. In paragraph 6 of this contract the managers are named. One of them was a legal expert and he advised that company from the legal point of view.
Q. When the foundation contracts of companies were drawn up the purpose of which was to employ inmates, did you have any part in it?
A. In each contract, according to German law, with the GMBH matters, the purpose of the contract is also to show what enterprise wishes to do. In no contract which I ever prepared did it state that the purpose of the company was to employ inmates during my time. I do not remember that companies were formed for the purpose of employing inmates.
Q The Prosecution has also said that you, as a member of Staff W, had taken part in the management of economic enterprises which employed inmates. What connections were there between Staff W or DWB and those firms, particularly DEST or DAW?
A I never directed companies or took part in the direction of companies which employed inmates. The firms of the concern, particularly DEST and DAW, were not directed by Staff W. They were directed by managers who received their orders most strictly from Pohl. These managers had to do what Pohl told them to do.
Q What connections were there between you and DEST and DAW?
A No connections at all.
Q Do you know whether, in those enterprises, other forced workers were used apart from concentration camp inmates?
A No, I don't know about that. When Dr. Hohberg was on the witness stand I heard that some forced labor - Jewish women - was used for Appolinaris of which I knew nothing.
Q Did you know at that time whether prisoners of war were employed in these enterprises?
A No, I didn't hear anything about that. As I had never been in a protective custody camp and I knew also that prisoners of war camps were under the Wehrmacht, therefore, it did not occur to me at all that prisoners of war could possibly be in concentration camps, especially as I was aware of the decrees of the International Red Cross.
Q Did Staff W have the task to select sites for concentration camps? This refers to page 84 of the opening statement of the prosecution.
A No.
Q Who was in charge of that task when the WVHA was founded?
A Before the WVHA was founded that task was looked after by the Inspectorate of Concentration Camps by arrangement with the Main Office Budget and Building.
The Main Office Budget and Building had a legal department which regulated the purchase of such sites as would be suitable for concentration camps. That becomes clear from Document NO-019 in Book 2, Page 46 of the German Book. It is Exhibit 46. I quote:
"In addition to my letter, referred to above, I wish to report that, after today's discussion, the chief of the Budget and Buildings Main Office, SS Gruppenfuehrer Pohl, would welcome if the Prisoners' Camp Stutthof near Danzig and its places of work would be taken over as a State concentration camp."
This shows quite clearly that Pohl, who was then Chief of the Main Office for Budget and Building and the Main Office for Economy and Administration, is being addressed as the Chief of the Main Office Budget and Building.
Q Who was responsible for the order to establish a concentration camp?
A Himmler himself. That becomes clear from the document which is on page 44 of Book 2. It is Exhibit 24. I shall quote: "Concentration camps can be established only by my permission. "Signed Reichsfuehrer SS H.H., which stands for Heinrich Himmler.
Q The Prosecution has said that to purchase sites for concentration camps was a typical task for Staff W. Is that correct?
A No, the purchasing of sites for concentration camps was always done by the Legal Department. Before the WVHA was founded, it was done by the Main Office Budget and Building, an office, in other words, of the German Reich. This, as I have quoted before, becomes clear from Document NO-019. After the foundation of the WVHA, the purchase was carried out by the Legal Office A/III, the main department 2 thereof. This becomes clear from Document PS-1643, Exhibit 466. It's in book 18 on Page 36 of the German book. The English document book I'm afraid I haven't got. This is concerned with something we have discussed before in this trial. It's a document con cerning the enlarging of Auschwitz Concentration Camp.
That document says:
"The tasks put by the Reichsfuehrer SS demand that Concentration Camp A Auschwitz must be enlarged to the extent which has been put down on a map."
Yesterday on cross examination the Prosecution obligingly has submitted two documents, one document received the number 588 and the other received Exhibit #591. Document 588 is addressed to the Legal Department A/III. It says there in the second paragraph, last sentence:
"I informed the company of the fact that negotiations concerning the purchase of real estate for the Reich sector of the SS Economic and Administrative Main Office can be concluded by you."
The second document which was submitted, #591, says in its second paragraph concerning the question whether sites for the inmates' camp is to be purchased or leased:
"The Legal Office of Office Group A is the competent office for the purchase of real estate for the Reich has to decide on the question whether the area for the prison camp is to be bought or leased. I informed the Legal Office about your inquiry. You will hear details in the near future."
This shows clearly that the Legal Department A/III was competent for the purchase of sites for concentration camps.
I should like to add:
INTERPRETER: (Interrupting): Your Honor, the sound system is very faint.
THE PRESIDENT: The Tribunal will recess until Monday morning at 9:30.
(A recess was taken until 0930 hours, 28 July 1947).
Official Transcript of the American Military Tribunal in the matter of the United States of America against Oswald Pohl, et al, defendants, sitting at Nurnberg, Germany, on 28 July 1947, 0930, Justice Toms, presiding.
THE MARSHAL: The Honorable, the Judges of Military Tribunal No. 2.
Military Tribunal No. 2 is now in session. God save the United States of America and this Honorable Tribunal.
There will be order in the Court.
DR. LEO VOLK -- Resumed DIRECT EXAMINATION -- Continued BY DR. GAWLIK:
Q On Friday I asked about the tasks and duties of Staff W. The Prosecution have asserted that Staff W had the function of leading negotiations about the purchase of sites for concentration camps, is that correct?
A No, that is not correct. A task of that sort was not part of Staff W.
Q The Prosecution had referred to the documents concerned with Stutthof. When were you in Stutthof?
A I went there on the 9th of January, 1942; then on another occasion I went to a place near Stutthof.
Q Will you please describe to the Tribunal the purpose of your visit to Stutthof?
A In Stutthof there was a camp for civilian prisoners. Himmler had ordered that this camp must be converted into a concentration camp. Outside that protective custody camp there was a piece of land which belonged to the Reich Forestry Administration. On that site the Sector had established a school, and for that purpose they had spent 600,000 Reich Marks. In connection with the conversion of the camp into a concentration camp, the idea was to have this land bought by the Reich. The amount of 600,000 Reich Marks which because of the sale of the piece of land became free was to be used for a settlement which was to be located 60 kilometers from Stutthof at a place called Oliva near Danzig. That land for the settlement was to be bought by the Public Utility Housing and Property, GmbH, went to Stutthof in order to take cafe of the interests of the settlement.
I had nothing to do with the conversion of the camp into a concentration camp. For that reason did I not take part in the negotiations about the protective custody camp.
Q Why did you take part in the negotiations at all?
A Only in my capacity as the manager of the Public Utility Housing and Property, GmbH., I took part.
Q Who ordered that Stutthof was to become a concentration camp?
A The conversion of the camp into a concentration camp was ordered by Himmler.
Q Will you please look at Document NO-2147, which is Exhibit 30. It is in Document Book II on page 59 of the German and page 48 of the English Document Book. Is this document correct in its essential features?
A The document is correct in its essential features. It shows in particular that the sites were correct, namely, that the civilian camp was to be converted into an official concentration camp on Himmler's orders.
Q Now please look at Document NO-2147, which is Exhibit 30 in Book II, pages 57 to 58 and gives us your comment about that document.
A The contents of that document are also correct. From paragraph 3 of that document it becomes clear that I went there only in order to establish the settlement near Danzig. I quote paragraph 3: "About the question of the Settlement, the Main Office said that this is to become an important settlement at the suggestion and for the purpose of the SS Main Sector Vistula and thus within the Allgemeine SS. The Reich Treasurer need not come into this at all, but for this purpose the existing enterprises, namely the Public Utility Housing and Property, GmbH., of Dachau, was to be interpolated. SS Oberfuehrer Dr. Kammler, and SS Obersturmfuehrer Dr. Volk are to go there early in January, 1942, together. The Main Office Chief expects me to report to him until the 15th of January 1942.
Q. Now please take the same document, the letter of 6 JanUary 1942, which is on pages 52 of the German and 42 of the English Document Books. Is that document correct?
A. By that document my statements are born out, which shows unequivocally that the land for the settlement was concerned. The purpose of the trip was, therefore, to regulate the questions concerned with the settlement were at Danzig. Only inorder to clear up that point I went up there, as I had said before.
Q. Now, please, take Document No. 2150. This is Exhibit No.31 in Book II, on page 51 of the English Document Book. Is that document correct?
A. This document confirms my statements, which shows there, and I quote: "The planning of the SS Settlement will be submitted to you. Your wish to have funds at your disposal for the purchase of the land near Stutthof, I shall take into consideration as much as possible, as soon as I have the instructions you will hear from me again." A letter from SS-Obergruppenfuehrer Pohl to SS-Gruppen fuehrer Hildebrandt shows that here again it becomes clear that the purpose of my contract was purely and simply to purchase the site for a settlement near Danzig, as I have said before, at a distance of seventy kilometers from Stutthof, and therefore the funds are to come from the sale of the land with the school to the German Reich.
Q. Now, please take Document NO 2133, which is Exhibit No. 387, in Book 14, on page 41 of the English Document Book. Is that document correct?
A. Paragraph two of the document is not very precise, but for anybody who knows it is the same complicated matter, but it is not a doubtful formulation. You used and built up that of the land belonging to the Reich Forestry Administration outside the Protective Custody Camp upon which the school was standing. I, representing the Public Utility Housing and Property, GMbH, was interested in the money coming from the purchase, and, was, therefore, taking part in the negotiations.
After the land had been purchased by DWB, this piece of land was to be sold to the Reich. These negotiations were to be led by me. I emphasized already that the piece of land was never actually purchased, and, therefore, I did not take part in any further negotiations.
Q. Now, please take Document NO-2133, which is exhibit No. 387, in Book XIV, on page 36 of the German Document Book. Did you purchase the Brick Works at the Estate of Werderhof?
A. No. Those enterprises were either bought by the Reich Offices A-3 and Main Office II. My testimony concerning the Brick Works at Stutthof is born out by Document 1041, which is in Volume XVI, on page 44 of the German Document Book. I shall quote: "The Stutthof plant is contained in the business report by the DEST, and was established on 10 April 1941, by Office B-3 which is the Reich Office, the Billetting Administration, by Obersturmfuehrer Dr. Leube. I should explain this so that the Tribunal will know the organization of the offices of the Reich sector. If the Reich buys a piece of land --
THE PRESIDENT: What document are you talking about in volume XVI? What document?
THE WITNESS: It is Document NO-1049, which is on page 44 of the German text, No-1049.
DR. GAWLIK: It is Exhibit No 436.
THE PRESIDENT: All right.
THE WITNESS: It is a business report by the DEST, and it shows under Stutthof, "A-Stutthof"; the word Stutthof, which is the Brick Works, was leased on 10 April 1941, by Office A-III, by Obersturmfuehrer Leube. This shows that the Reich took over the Stutthof Works as its own property.
In order that the Tribunal will understand the organization, and particularly why Office B-III was interpolated here, I should like to give a brief explanation. If the Reich bought a plant with commercial negotiations, then the legal contract was carried out by the legal office, which is Office A-3. If that plant was sold to a private firm, which in this case was the DEST on a leased space, then Office B-III had to become active as the accommodations office. That office had the task of drawing up the list of inventory, so that it was clear in the future what things were being handed over when the lease was signed. So that, therefore, this is what this mark is about, and this shows quite logically that I, as the representative of the DWB did not buy the Brick Works at Stutthof, but the German Reich did. As far as the Werderhof is concerned, on that estate unhappily I have no document at my disposal and I know for a certainty today that this estate was not bought by the DWB, but again by the Reich. The commercial negotiations were lead by one Dr. Ast.
Q. Now, please take Document 2159, which is Exhibit No. 388, in Volume XIV, on page 43 of the English Document Book. Why was this document submitted to you?
A. This document was submitted to my by the legal department in my capacity as head of what was called Staff-W. The purchase of this piece of land on which the school building, and later on the commandant's office stood had to be effected by the DWB. The Public Utility Housing and Property, GMbH, was not in a position to carry out the negotiations, because according to the regulations or orders concerning dwellings and houses, such legal matters could not be dealt with by them.
Q. Witness, you just mentioned that the letter had been submitted to you as head of the so called Staff-W. Didn't you make a mistake there, or did you have a slip showing you as head of the so called legal department?
A. As the head of the legal department of what was called Staff-W.
Q. Now please take Document No. 2117, which is Exhibit No. 78 in Volume IV, on page 3 of the English Document Book. This is a letter by Loerner to the German Court of Audits. Why was that letter submitted to you for your information?
A. That letter was submitted to me, because when the school was being transformed into the commandant's offices, the 100,000 Reich marks were used up by the Chief of the Regular Police, and he thought they ought to be repaid. Unless the transaction, that is to say, the purchase of pieces of land to sell to the Reich by the DWB had been carried out, the DWB was to pay back those 300,000 marks to the Chief of the Regular Police. The DWB, therefore, was interpolated purely to disentangle this matter financially for money which had been invested into the piece of land which was not yet the property of the German Reich. It belonged to the Reich Forestry Administration. That is the reason why this letter was submitted to me.