THE PRESIDENT: If you can produce her we will hear her and if you cannot we will not take any adjournment. The Tribunal desires very much to finish this case to day.
MR. LAFOLLETTE: I Understand that. I did not ask the Court to take an adjournment. I only ask if she comes late I may use her after the respondents started their case if that is agreeable. With that exception we rest.
DR. NATH SCHREIBER: May I call to the attention of the Tribunal that I also asked to have the nurse Frau Ernst appear here as a witness.
THE PRESIDENT: If she can be produced we will hear her. Does the Prosecution rest?
MR. LAFOLLETTE: Yes, Your Honor.
THE PRESIDENT: Call your first witness for the defense, the respondent?
DR. ORTH: With the permission of the Tribunal I call the attorney Dr. Link as a witness.
BY JUDGE HARDING:
Hold up your right hand and repeat 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).
You may be seated.
BY DR. ORTH:
Q Witness please state your name?
A Heinrich Link, a married lawyer in Nuernberg. Thirty-five years old.
Q Are you an assistant to Dr. Marx in the Engert case?
A Yes.
Q When did you become Dr. Marx's assistant?
A During the last days of March 1947.
Q In what manner did your relationship with Dr. Marx develop?
AAs a Nuernberg colleague I knew Dr. Marx for several years and in accordance with this relationship of being an acquaintance and a colleague the cooperation in this case developed and on a basis if I may say so of mutual confidence.
Q Did you thus work on the entire Engert case always with Dr. Marx? Did you discuss it with him?
A Yes, I did.
Q You, therefore, know that the Tribunal ordered that medical expert opinions be given because Dr. Marx made an application for severing the case from the trial?
A Yes, I know that.
Q How did this application come about?
A I don't know.
MR. LAFOLLETTE: If your Honors please, I object for the reason that this evidence is repeated as it shows from the record of this Tribunal, the record speaks for itself and there is no need to go into this matter with this witness.
DR. ORTH: I did not say when and with whom did it come about but how did it come about.
THE PRESIDENT: We are not concerned with that. The Tribunal knows Dr. Link has been of counsel for the defendant Engert during the entire period to which he referred. How it came about is not pertinent to this inquiry. This inquiry must be limited to the charge against the two respondents.
BY DR. ORTH:
Q Since the Tribunal has made the ruling that medical expert opinions must be obtained what steps did Dr. Marx then take?
A May I ask you are referring to the application for the severing of the case?
THE PRESIDENT: We are not concerned with the application for severing the case. Counsel must understand that the application for severing the Engert case is not before the Tribunal on this contempt proceeding. Direct your questions to the matters which are relevant to the charge against your client and limit yourself to that field.
BY DR. ORTH:
Q What did Dr. Marx do after the ruling of the Tribunal?
A First Dr. Marx went with me to the American prison physician, Captain Martin, because we did not know with certainty which physician was to give this new expert opinion and because we wanted to ask this physician whether we should undertake anything because of the appointment of that physician. Dr. Martin told us that it was not necessary for us to do anything; that he had already given a new expert opinion himself and that the defendant Engert in the next few days would be transferred to the Garmisch Hospital and that would finish the case.
DR. LAFOLLETTE: Your Honor please, this obviously is covering a field long priors to the facts alleged in this --
THE PRESIDENT: The answer will be stricken and disregarded by the Tribunal. Counsel do you understand the ruling which the Tribunal has made?
Court No. III, Case No. 3.
DR. ORTH: Yes.
THE PRESIDENT: Will you follow it?
DR. ORTH: Yes.
THE PRESIDENT: You are directed to follow that ruling.
BY DR. ORTH:
Q What did Dr. Marx tell you about the appointment of Dr. Gerstacker as an expert?
AAfter this ruling by the Tribunal had been issued, that two German physicians should be named by the defense and two Americans by the Prosecution, Dr. Marx discussed with me what German physicians could be considered. We agreed that for the physiological expert opinion, the officiating chief physician-
THE PRESIDENT: Just a moment. The Tribunal has before it, in the record, the written stipulation entered into between the Prosecution and the counsel for the defendant Engert in which it is agreed as to who should be the physicians, American and German, for the purpose of making the physical examination. It is not necessary to go back of that stipulation. That stipulation is the basis on which the Tribunal made its order, and you may proceed from that point.
BY DR. ORTH:
Q What did Dr. Marx tell you about the discussion with Dr. Gerstacker on the 28th of June?
MR. LA FOLLETTE: To which I object, Your Honor. It is only evidence of his-- If he is talking about what Marx said, it is only evidence of Marx's impression of the conversation. I can't see how it is pertinent. If he wants to ask whether there was violent discussion, why he might ask it.
DR. ORTH: But is is very important. It is, after all, very important what Dr. Marx-
THE PRESIDENT: It is the ruling of the Tribunal that what Dr. Marx, after the conversation with Dr. Gerstacker, told the witness Link is not relevant to this case. Dr. Marx is here; he may tell us what the conversation with Dr. Gerstacker was, but we will not waste time by hear Court No. III, Case No. 3.ing what he told about that conversation to a third party witness.
BY DR. ORTH:
Q What course did the events of 10 July 1947 take after Dr. Marx had received the questionnaires?
AAfter Dr. Marx, as he told me, from Mr. Wartena, had been called-
MR. LA FOLLETTE: To which I object, Your Honor. This is absolutely pure hearsay. Dr. Marx may answer and respond himself. It is pure hearsay of this witness.
THE PRESIDENT: I don't understand what the question is at the moment.
MR. LA FOLLETTE: The question was, what happened after the 10th of July and what did Dr. Marx do after he got the Fragebogen?
THE PRESIDENT: Dr. Link, limit yourself to testimony as to your personal knowledge, if any, concerning the conduct of Dr. Marx with reference to his dealings with Dr. Gerstacker; what Dr. Marx told you is not admissible in evidence for the simple reason that he can tell us himself.
Do you know anything about the conversation between Marx and Gerstacker?
THE WITNESS: I was not a witness to that conversation. I do not know Dr. Gerstacker to this very day. However, immediately following the conversation, I did, through Dr. Marx, and then later also through Dr. Stem, hear about this discussion.
THE PRESIDENT: We don't want to know what you heard, as hearsay.
THE WITNESS: Yes. My own knowledge? That I also experienced it? I don't have that.
THE PRESIDENT: Then you need not testify concerning the matters that you don't know about.
BY DR. ORTH:
Q Witness, were you in the office of Dr. Marx, and were you present in his office on the 27th when he returned from Mr. Wartena's office?
Court No. III, Case No. 3.
A No, I was not.
Q When did you see Dr. Marx for the first time after that?
A I saw him the next day, or the day after that; but on the evening of the same day I spoke to him over the telephone.
Q Did Dr. Marx ever tell you that he wanted to get in touch with the physicians in order to achieve a change in their expert opinion?
MR. LA FOLLETTE: To which I object, Your Honor. Any statement that would be self-serving-
THE PRESIDENT: Well, we don't know whether the answer would be yes or no.
MR. LA FOLLETTE: I don't care, Your Honor, I don't think it is pertinent. It is what Dr. Marx might have told this man.
THE PRESIDENT: If he answers yes, it would be an admission against interest on the part of Dr. Marx.
MR. LA FOLLETTE: I agree with you. If he says no?
THE PRESIDENT: Then it is immaterial.
MR. LA FOLLETTE: Then it is a self-serving declaration.
THE PRESIDENT: He may answer.
THE WITNESS: After we heard that the German physicians had said that Engert was able to appear in the session, even if only to a limited extent, we both agreed that the worsening of the condition of his health which had occurred in the meantime, and which we had observed, would have to be pointed out. For that purpose, either myself or Dr. Marx, in our visits--as to Engert--wanted to talk with Dr. Kraetzer or with Dr. Stern, but not with Dr. Gerstacker, because Dr. Marx had expressly told me that he did not want to have anything to do with Dr. Gerstacker any more because during that discussion he had been so excited and belligerent and he had expressed himself so unacademically. He had described him as a stubbern Municher, if I may say that.
MR. LA FOLLETTE: If, Your Honor, please, I ask that this be stricken. It is not responsive to the questions. A simple question was asked of the witness, as a result of which we have had a long speech.
THE PRESIDENT: I understood the answer to have been "no".
Court No. III, Case No. 3.
We will take our recess until 1:30 this afternoon.
(A recess was taken until 1330 hours.)
AFTERNOON SESSION (The hearing reconvened at 1330 hours, 29 July 1947)
THE MARSHAL: The Tribunal is again is session.
DR. ORTH: I ask to be permitted to continue my examination of Dr. Link.
DIRECT EXAMINATION - Continued BY DR. ORTH:
Q. Dr. Link, was Frau Huppertz secretary for Dr. Marx?
A. No. When I had to do with the defense of the defendant Engert I inquired after a certain time who the lady might be who also at times was in the offices of the defense and talked to Dr. Marx and other colleagues and I was told that she had been a witness or had been intended to be a witness in the case of a doctor who was defended by Dr. Marx and in the meantime since she spoke English rather well and had certain medical background she was just helping out, but she was not definitely employed. Again she was absent for days and for weeks and I didn't concern myself with that. I never dictated anything to her. I considered her a person with whom I had not to take up any contact.
Q. Was Mrs. Huppertz an assistant of Dr. Marx?
A. No, she was not that, either, because I would have to know about her. I know who his assistants are in the doctors' case or otherwise. Once I think he pondered the idea. I think it was upon Frau Huppertz' initiative, but I cannot ---
THE PRESIDENT: You have answered the question. Go ahead.
DR. ORTH: I have no further questions to the witness then.
THE PRESIDENT: Does counsel for the defendant Huppertz desire to examine this witness?
DR. NATH: No, Your Honor.
THE PRESIDENT: Mr. LaFollette, do you have any further questions?
MR. LA FOLLETTE: No questions.
THE PRESIDENT: The witness is excused.
DR. ORTH: I call as my next witness Miss Bleckschmidt.
ANNEMARIE BLECKSCHMIDT, a witness, took the stand and testifies as follows:
JUDGE BLAIR: Hold up your right hand and repeat after me the following oath:
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)
JUDGE BLAIR: You may be seated.
DIRECT EXAMINATION BY DR. ORTH:
Q. Witness, will you please give your name to the Court?
A. Annemarie Bleckschmidt.
Q. What is your profession?
A. I am not working; I am in the home.
Q. You were present, weren't you, when Dr. Stern called Dr. Marx and asked him to come to the hospital?
A. Yes. I heard the calls from seven o'clock in the evening when Dr. Stern called for the first time and called for Dr. Marx and I said that -
Q. Will you please speak a little slower?
A. Yes. I said that at half past eight he would come home and then he said, Dr. Stern said he had to speak to him immediately, it was very urgent and where he could get in touch with him at the time, and I said that he was probably in the Palace of Justice, he should call there and ask for the number of the room where he was. And then he probably called the Palace of Justice -
THE PRESIDENT: Just a moment. Just limit yourself to telling what you know about it yourself.
THE WITNESS: I personally only know of the telephone calls. Then he called me and wasn't able to get Dr. Marx' telephone number.
He called again at halfpast eight, whether he had returned, and I said, no, he hadn't. He asked again whether he could call after 10:30 and whether he then would find him at home.
BY DR. ORTH:
Q. Did Dr. Stern talk to Dr. Marx that same evening?
A. Yes.
Q. Were you present?
A. Yes.
Q. During that conversation did Dr. Marx say that he did not want to go to the hospital to Dr. Gerstacker?
A. Yes. I was next to the telephone. I had been sitting next to the telephone when Dr. Stern at 10:30 called Dr. Marx. Dr. Stern urged Dr. Marx ---
THE PRESIDENT: Now just a moment. Rill you please tell us first did you hear both parties to the telephone conversation? In other words, were you listening in on the wire?
THE WITNESS: Unfortunately, I did not, because we have no second earphone. I can only confirm the answers which Dr. Marx had given, because I could only assume from these answers why Dr. Stern --
THE PRESIDENT: You don't need to assume. You may tell what you heard Dr. Marx say.
THE WITNESS: Yes. Dr. Marx always answered: Dr. Stern, but that is bad that this matter was mixed up as it was, since it is so urgent and you yourself wanted to deal with the matter, and it is quite impossible for me to go to the hospital myself tomorrow morning because early in the morning I have to interview my two clients in the Palace of Justice and I have to go there. Dr. Stern continued, apparently, to insist -
THE PRESIDENT: You don't need to tell what Dr. Stern apparently continued to do. Limit yourself strictly to what I have instructed you.
THE WITNESS: Yes. Dr. Marx from 10:30 to 11:00 talked to Dr. Stern, and in doing so explained to him three times that it is was quite impossible for him to go to the hospital the next morning and that Dr. Stern himself should try to straighten out the matter, since he had taken it upon himself to do so.
BY DR. ORTH:
Q. Did Dr. Marx finally agree to come to the hospital?
A. Yes.
Q. Shortly before eleven o'clock, shortly before the end of the conversation Dr. Marx said, all right, then tomorrow morning even before I go to the Palace of Justice I will go briefly to the hospital and will talk to Dr. Gerstacker.
DR. ORTH: I have no further questions to this witness.
THE PRESIDENT: Any cross examination? The witness is excused. Call your next witness.
Order will be maintained in the courtroom or the courtroom will be cleared.
DR. ORTH: I call as my next witness Dr. Marx to the witness box.
DR. HANS MARX, * witness, took the stand and testified as follows:
JUDGE HARDING: Hold up your right hand and repeat after me:
I swear by God, the Almighty and Onmiscient, that I will speak the pure truth and will withhold and add nothing.
(The witness repeated the oath)
JUDGE HARDING: You may be seated.
DIRECT EXAMINATION BY DR. ORTH:
Q. Dr. Marx, when did you take over the defense of the defendant Engert?
A. I cannot tell you the exact time right now, it may have been in January of 1947.
Q. Then, in the course of the trial, did you file the petition for the court; did you file that petition?
A. That petition was filed on 7 June 1947.
Q. Why?
A. The petition was filed on the basis of the observations made by my assistant Dr. Link and also on the basis of my own observations, as well as on the basis of the statements made to us by the physicians, telling the defendant Engert's condition did not improve and because possibility did not exist for the defense counsel to gain any basis for the defense from Engert himself.
Q. What caused you to nominate Dr. Gerstacker for the expert opinion, which was ordered to be obtained by the court?
A. I first had in mind the director of the University Neurological Clinic at Erlangen.
THE PRESIDENT: Just answer the question as to how you came to select him, it is not material, but I will permit you as one of the respondents to explain how you entered into a stipulation or an agreement for the appointment of the doctors.
THE WITNESS: Yes, yes.
THE PRESIDENT: That is all that is necessary.
BY DR. ORTH:
Q. What made you nominate Dr. Gerstacker?
A. Originally Dr. Gerstacker's name was quite unknown to me. On the occasion of a visit to the hospital, I met Dr. Stern and remarked to him that I needed a psychiatrist as an expert and he said he was well acquainted with the chief doctor, Dr. Gerstacker, who for a long time had made out expert opinions in the neurological department, that he would speak to that man and would notify him and I myself did no longer have to bother about it.
Q. On the 27th of June when you came home in the evening, Dr. Stern called you up; what did he tell you?
A. It was in the evening of 27 June at about 10:30, after I had been informed that three times before Dr. Stern had asked for me very urgently over the telephone, I thought nothing else about that something quite extraordinary had happened. Dr. Stern then reached me at that time on the telephone and stated to me immediately: "Dr. Marx, I am in a rather disgraceful situation, I forgot to notify Dr. Gerstacker that he had been designated at the expert, also Dr. Kraetzer, whom I asked to do so, failed to notify Dr. Gerstacker of that assignment." I answered: "Dr. Stern, that is a very disagreeable matter, I cannot really understand it that a thing like that should happen." Dr. Stern said then: "Dr. Marx, you have to come to the hospital, it is very urgent that you straighten this matter out." Thereupon, I answered: "That is quite out of the question, I have no time. Tomorrow considerable time before nine o'clock I have to be in the court house, because I have scheduled my two clients, the doctors, for an interview." However, Dr. Stern insisted most urgently by pointed out time and again that I myself had to straighten out the matter, whereas, I said that it was really his business to do so. Finally, I gave in to Dr. Stern's insistent demands and I decided the next morning, the 28th to go to the hospital.
Q. At the hospital you met Dr. Gerstacker. Would you please describe briefly that conversation and what you talked about?
A. Shortly after I arrived in the hospital, I met, in the part of the building where Engert is, Dr. Stern. Dr. Stern immediately offered to show me into the part of the building where Dr. Gerstacker worked.
Dr. Gerstacker was just making his morning visits to his patients. Dr. Stern approached him and told him that the defense counsel for Engert had come in order to explain something to him. Then Dr. Gerstacker stepped over to me, he did not invite me in any way to sit down and started the conversation in a definitely unfriendly manner. He immediately started to reproach me to the effect: "I am the chief physician, I have made out many expert opinions, but never before did anything like this occur to me. I was not even told that I was at all to render a medical opinion. I have a slip of paper here which is not even signed and only represents a copy of something or other."
I asked him whether he had taken pains at all to read that letter or whether he knew what the date was on that letter and what its contents were. I said I had only come to explain to him why he had not been informed in time of the fact that he was expected to be consulted as an expert. Dr. Gerstacker did not comment on that at all, but he continued to complain that he had not received any files such as he was used to and that the letter did not contain any details, any specific instructions whereas in German procedure specific points are usually listed. That caused me to tell him: "No, Dr. Gerstacker, you cannot apply the standards here of German procedure where you would have received all the details about evidence and the files and other specifications. Here you are confronted with an American Military Tribunal procedure. Moreover, I am of the opinion that it is here not a question of such an extensive psychiatric opinion as we are accustomed to in detail with German courts, with an extraordinary, extended case history, etc., but here the problem is to explain your impressions about the psychiatric condition of Engert and his capacity to take part in his defense, to clarify that and to offer your opinion as an expert." Moreover, in my opinion the essential thing was not really the psychiatric part of the case, because I did not believe that Engert could really depend on paragraph 51 being applied to him. I was of the opinion that the main weight was on the side of the physical condition of the patient, also that there was a certain inference exerted by his physical condition on his mental condition.
According to my knowledge, there were available already two American expert opinions, which as far as the physical condition was concerned, stated Engert was not capable of attending the trial.
Dr. Gerstacker got more and more excited. His attitude and behavior toward me was such as I had never experienced in my more than 35 years of practice as an attorney. One could clearly notice that Dr. Gerstacker felt insulted in his position as a chief physician and that he made me responsible for anything in this matter which seemed inexplicable to him. He expressed that it was my fault that he was not informed that he had been nominated. He said the letter that Dr. Krzetser had received had emanated from me or was caused by me. Consequently, he criticized the tone of the letter. Also he thought it was my fault that such a short time was given for the rendering of my expert opinion. And even in that he saw an intrigue on my part designed to force him to make rash decisions.
The behavior of Dr. Gerstacker finally made me tell him, "Now, chief Doctor, it is up to you either to refuse to render that expert opinion altogether or to ask that the time limit be extended." And he was not quite ready to do the first.
Now, as far as that was concerned, the conversation came to an end and we left in a somewhat charged atmosphere. And I have to state here that Dr. Gerstacker, as for his hostility and his attitude toward me, did not fail to express that by his tone and his behavior, whereas, I made great efforts to hold on to myself, although I was greatly excited and that excitement, of course, was increased by the attitude on the part of Dr. Gerstacker.
Q. Dr. Marx, in the course of the negotiations did you explain to Dr. Gerstacker that you had gained the impression that the Americans, with the aid of medical experts, wanted to drop the case Engert?
A. After examining my recollection very carefully, and after trying to reconstruct that conversation as carefully as possible, I cannot remember any remark of that kind made on my part. I want to state with full emphasis that the purpose of my contact was only to clarify matters, and the ultra-severe attitude of Dr. Gerstacker, which he displayed toward me from the very outset, made impossible any personal contact with that man.
It would have been definitely absurd on my part if, in recognition of the irritated state of mind of that man, I would have come to the thought to influence that man in favor of Engert.
Q. Dr. Marx, isn't it possible that, although you did not have the intention to influence the expert, without any such intention in the course of the conversation, you may have said something similar to the witness?
A. Dr. Stem and Dr. Gerstacker gave a talk once about the Americans, then about the Court and then about the Gerichtshof, the Tribunal. I, myself, never used that expression, Gerichtshof, Tribunal; and the expression Gericht Court was never mentioned during that entire conversation because there was no cause for that. I only mentioned that two expert opinions had been submitted by two official American doctors who considered the physical condition of Engert such that it made it impossible to bring him into the courtroom, and that may have led to that erroneous interpretation.
It was known to me, of course, that the Prosecution was strongly opposed to my petition and, as for the Bench, it was known to me that the expert opinions submitted by American doctors did not give cause to the judges to pronounce a decision, but that the judges considered it necessary to have a further expert opinion on a more entended bases in order to be able to form a definite decision.
Q. Is it possible that you have spoken, in the course of the conversation, about the severing of the case?
A. That could be possible. I consider it possibly certain that I mentioned such a petition, but in this connection I would like to state that in my opinion Dr. Stern was previously informed of that because he was all the time in contact with 1st Lt. Martin and for that reason alone is informed about the entire course of the trial, not only from the medical point of view.
Q. Dr. Marx, you brought the second questionnaire to your office. Would you please tell us what statements you made in your office?
A. Well, isn't it necessary first to discuss what happened before?
Q. Please answer my question.
A. May I ask you to repeat the question?
Q. You received the questionnaire later with the questions and brought it into your office. What did you say when you did so?
A. I was very angry and overworked because I had just finished dictating my plea in the case of Professor Schroeder. From the preceding conversation I could see how the German doctors had answered the questionnaire, and since I was aware of the fact that American expert opinions had been submitted to the contrary. How the questionnaire was answered by the American doctors, I never saw myself.
For these reasons I thought, how can the German doctors possibly answer all these questions in the affirmative since we frequently had, Dr. Link and myself heard different opinions, and since, according to our observations, the condition of the patient has not improved but deteriorated?
Of course, I had gained a certain impression from the preceding conference and I drew a conclusion that there was some reason for that difference. That led me to make the following statement: Is it so that the Germans are again more holy than the Pope? That really tops everything. And particularly I can't understand how anyone can answer the question No. 2 in the affirmative if one answers question No. 1 also in the affirmative without any reservation? That really would only tend to deceive the Court.
I further said: "Now I have an idea. I will step up before the Court and I will say, assuming that the American experts have answered the question as to whether Engert can stand trial in the negative, I will say that I consider these American expert opinions sufficient together with the fact that the German doctors answered question No. 2 in the affirmative, in order to have a sufficient basis for the decision to be made by the Court, concerning a severance of the case, I am going to say that I prefer the expert opinions made by the Americans to those prepared by the Germans because I consider the American expert opinions as unbiased and uninfluenced by any side.
Q: Did you give Frau Huppertz the order to go to the Hospital and talk to Dr. Karetzer and Dr. Gerstacker?
A: Excuse me, counsel. Something occurred before that. Then I really didn't want to have anything to do with the whole matter any more. I was busy with other things. But since I had been handed the questionnaire for the express purpose to copy them for my files, I told Mrs. Wieber to prepare copies of these questionnaires. Then I did not bother with the whole affair, that is to say to the extent that I devoted myself entirely to dictating my plea. Upon my remark that I would give preference to the expert opinions made by the Americans over the expert opinions rendered by the Germans, Frau Huppertz jumped up from her chair to her full height and told me: "But, Dr. Marx, now if you are defending German doctors before an American Military Tribunal you cannot step before another Military Tribunal and degrade the German doctors in comparison to American doctors." I was quite surprised about that momentary interruption, and I said, I believe, to Frau Huppertz:
"What came upon you to interfere with my affairs?" I may have made the remark also to the effect that I would really like to go to the hospital that night to ask Frau Dr. Kraetzer whether or not the condition of Engert in the meantime has changed for the worse because it was known to me that Dr. Kraetzer immediately afterwards was just about to go on a vacation. Unfortunately I did not stick to that idea and I said, I think it was after seven o'clock at that time already and tonight it would be too late, then I still had to go to see my client and that I would go tomorrow. My intention, however, in this connection was not -- and I don't think anybody would expect me to be so foolish - was not to go and ask Dr. Kraetzer now that she should make out a different questionnaire, but what I wanted to do was merely to ask whether the condition of Engert since the time when the last examination was made which formed the basis for the expert opinion, might or might not have deteriorated in the meantime, but I did not go out to the hospital neither on the same evening nor the next morning, but on the very same night I called Frau Dr. Kraetzer and inquired as to the condition of Engert. I believe I can remember almost with certainty that I said that it is possible that somebody might come who wanted to talk with her but that was no necessary, it was very superfluous and I think that may have been the reason that when Frau Huppertz the next morning went to the hospital in order to talk to the doctors, that this female doctor was not ready to listen to her.
Q: Witness, you mentioned Frau Huppertz, was Frau Huppertz ever your Secretary?
A: No.