They denied everything because now they knew what was at stake because Woessner had been told that at his previous trial.
Well, there was gain an indictment filed and this time the indictment was for preparation of high treason, undermining of military morale under Article *V, Section I of the special war time penal law and Hapitual Criminal Law of 1941. The judges discussed the matter in detail; the facts were proved beyond all doubt. All facts of the case were discussed in relationship to the individual laws that might apply and the penal Senate in the case of Woessner, who had been twice previously sentenced for preparation of high treason, arrived at the conclusion that again it had been preparation of high treason; that he also had violated the undermining of military morale law and I remember quite clearly that it was rather doubtful whether one could assume that pamphlet, which naturally could be described as undermining and which was a very dangerous at the penitentiary, I remember it was very doubtful whether one could assume that this was undermining of military morale in public and after a long time the Penal Senate arrived at the conclusion that it was possible that prisoners, after their release, might possibly spread the text of this pamphlet to the public in general and also the prisoners went out to work and there they met other Germans who were not inmates of the prison and anyhow it was quite obvious that it was the intention of Woessner to spread the contents of that pamphlet because otherwise he would never have written that pamphlet. And that was why we arrived at the conviction after a very thorough examination of the case-that Woessner was a habitual criminal within the meaning of the law. And when we had agreed that he was a habitual criminal, of necessity the death sentence had to be passed.
In the case of Mattes it was similar. Mattes had already received a five year penitentiary term. The first offense of Mattes where I also was the reporting judge and where Cuhorst too was the presiding judge, had been so serious that at that time one allowed extenuating circum stances only because, after all, that was the first offense of preparation for high treason.
That was why he was only sentenced to five years in the penitentiary; but in the case of the second offense, after all one had to remember that it was a second offense and further it was found that he had tried to make his fiancee who was quite innocent, commit purgery which was a very nasty matter.
One also had to remember that he had been favoring the enemy and in the view of the court, after all angles had been discussed, one arrived at the conclusion that this was preparation for high treason and undermining of military morale. I am not so sure whether we did assume undermining of military morale --
THE PRESIDENT: Anyway you sentenced him to death; is that right?
THE WITNESS: Yes, yes, your Honor.
BY DR. BRIEGER:
Q. Did any of this happen before he had finished his penitentiary term, for instance, this business about making his fiancee commit perjury? Was that before?
A. Persuading his fiancee to commit perjury, I believe that was while he was in prison pending trial. I believe it was before he committed his first offense but I can't tell you for sure.
Q. Were both men sentenced to death on the basis of their Communist propaganda work at the penitentiary only or because those further aggravating elements had to be taken into consideration too?
THE PRESIDENT: The witness has explained that sufficiently and at great length.
BY DR. BRIEGER: In the District of Stuttgart did you hear of any extraordinary appeals or nullity pleas in favor of defendants?
A. No. I never heard of anything of the kind.
THE PRESIDENT: You have answered the question.
BY DR. BRIEGER:
Q. Did Cuhorst attend executions and, as a witness has said here, with a stop-watch in his hand? Please give us a general reply to that question to begin with.
A. As far as I know Cuhorst never attended any executions. I never heard that he did.
Q. Some people have said that Cuhorst lived rather well. What do you know about that so-called inclination of his to live well?
THE PRESIDENT: Did Cuhorst live well? We hope he did. Pass it by. Don't waste your time.
BY DR. BRIEGER:
Q. What was Cuhorst's attitude concerning the re-transfer of people, who had been acquitted, to the police?
A. As far as I know there was an order to that effect. However, I never saw it myself. A prisoner who had been acquitted by the courts -a political prisoner -- I believe there was an order that they had to be returned to the police to examine the question of protective custody. I never read that order myself, but I believe that was the custom. I think it was a custom and Cuhorst --- I have to explain this --contrary --
THE PRESIDENT: Wait a minute. Will you repeat the question? Let me hear your question and a brief answer.
DR. BRIEGER: I may assume that the Court is familiar with the word Rueckueberstellung", transfer, and I am now asking you, witness, what was Cuhorst's attitude concerning the question of retransferring defendants, who had been acquitted, to the police?
A. In cases where a defendant had been acquitted, who had been tried for a political offense, Cuhorst, contrary to an official instruction and contrary to the custom of other presiding judges, as far as I know and as far as I experienced it, regularly abstained from retransferring acquitted defendants to the Gestapo for the purpose of re-examing the question of protective custody.
BY DR. BRIEGER:
Q. Was Cuhorst the superior of the judges at the Senate and at the Special Court?
A. No, no. He was the presiding judge of the Penal Senate, but he was not a superior of the judges.
Q. Now, my last question, witness: There is a prosecution affidavit which you deposed. When you were interrogated at the time or before or after, were you told anything about the question as to whether Cuhorst had incriminated any other judges?
MR. LAFOLLETTE: Just a minute, witness. I object, Your Honor, to any examination which addresses itself to specific statements in this witness' affidavit for the reason that it should be essentially crossexamination and should have been disposed of prior to this time. This is a conduct of direct examination of this witness on behalf of the defendant. Any matters relating to the manner in which the affidavit was obtained or any facts therein set out should have been done by cross-examination.
THE PRESIDENT: The Tribunal is of the opinion that you should not report to the cross-examination which you had an opportunity to conduct earlier and did not conduct. You may ask direct questions as to facts from this witness without references to the affidavit.
BY DR. BRIEGER:
Q. Were you at any time told that Cuhorst had incriminated you or had incriminated other judges?
MR. LAFOLLETTE: I object, your Honor. That is exactly the same thing he is asking Mr. Cuhorst in connection with the first affidavit. He had ample opportunity to cross-examine and we let him bring anybody up here he wanted to.
DR. BRIEGER: I did not refer to the affidavit in that question. I ask the Tribunal to give its ruling.
MR. LAFOLLETTE: He was talking about who he was told by somebody to do something. It has nothing to do with this examination.
THE PRESIDENT: We haven't the affidavit before us.
DR. BRIEGER: That affidavit was submitted to the Tribunal and I can give you the number. I refer you to Exhibit 213, NG-464. The affidavit was deposed on the 23 November 1946.
THE PRESIDENT: We are not familiar with any rule of this Court nor any other Court which excludes from a direct examination all of the subject matter which could have been covered by some previous crossexamination and I have stated the ruling of the Tribunal once. He may ask concerning what is popularly called the objective facts without referring to the affidavit. If it be true that those facts may contradict something in the affidavit, this Tribunal can't stop now to examine that question and the witness may answer.
MR. LAFOLLETTE: If your Honor please, I don't think I have made myself clear. This last question was addressed to circumstances surrounding the taking of the first affidavit. I certainly do not think that was within the purview of any kind of examination.
THE PRESIDENT: You mean it relates to the circumstances under which the affidavit was taken?
MR. LAFOLLETTE: Exactly. He asked him: "Were you told by somebody when you gave this affidavit that Cuhorst had done something to you?" He is referring to the first affidavit and I am very insistent that I am correct in my objection to that kind of practice. The circumstances under which this first affidavit was given certainly should have been gone into on cross-examination and that is the basis of my objection and it will be applied to five or six affidavits which are going to be offered, which have the same attempt in there to bring up those matters.
DR. BRIEGER: I don't know whether and at what time the witness was asked, and I am not able to say whether there was any connection, and that is why I am asking quite generally whether at any time, witness, you were told that Cuhorst had incriminated Stuttgart judges? Please witness, answer my question.
THE PRESIDENT: Now just a moment. Your question -be still, witness, until you are instructed. Your question is whether anyone has ever told this witness that Cuhorst had incriminated other judges?
DR. BRIEGER: Yes.
THE PRESIDENT: What does that have to do with the circumstances under which the affidavit was taken? Do you mean does it show duress or anything of that sort?
DR. BRIEGER: In that case I have to specify my question a bit. Did the interrogator of the Prosecution told you anything about that?
HR. LAFOLLETTE: Now, if Your Honor please, I certainly think that goes to investigation of -
THE PRESIDENT: The objection is sustained.
HR. LAFOLLETTE: And I shall continue to offer the same objection to that kind of question.
THE PRESIDENT: The Court will continue to rule as it deems proper whenever you object. This last question appears to relate to statements made by an investigator to this witness at the time when the affidavit was taken, and the objection is sustained, and you will not go into the matter.
BY DR. BRIEGER:
Q: Quite a different matter. Did Cuhorst have a stopwatch?
A: As far as I know, he didn't have one.
THE PRESIDENT: You have asked that question before.
DR. BRIEGER: Thank you, witness.
CROSS EXAMINATION BY MR. LAFOLLETTE:
Q: Witness, will you tell me was it an accepted practice of the first Penal Senate that when the judges debated and arrived at their decision on the guild and the penalty, did they also at that same time agree as to what position should be taken on any clemency plea?
A: Well, this is how it was. In the case of death sentences the court in every case used to have to give its view. I believe that is how it was. I believe they had to give their own view on the clemency question, but later on that was changed and later on it was the presiding judge allne who had to give his view on the clemency plea, but as a rule the presiding judge asked the court, or at least the reporting judge, what their opinion was. Whether that was always done, I don't know.
Q: And the time of doing that was at the same time that the sentence was agreed upon or prepared for announcement in open court, is that right?
A: Yes. That was usually when the verdict was discussed.
Q: Yes. Now you discussed the defendant's attitude on the clemency matter and you discussed the relative severity of sentence, particularly in cases of undermining military morale in the first sentence and the second. I will ask you, do you know the defendant's customary attitude towards a clemency plea where a death sentence had been given? After a death sentence had been agreed upon, what was his attitude toward the clemency plea in the great number of cases?
A: Well, in cases where under the law the death sentence was mandatory and where, therefore, only the death sentence could be passed, in such cases as a rule the offense had been so serious that it was hardly a case of considering clemency. In cases where the law left it to the discretion of the court whether the death sentence was to be passed or not -- and I myself never handled such cases in the Penal Senate -- well -
Q: I am just asking you about the defendant Cuhorst's attitude in the cases in which you sat, if you remember. Was he often for clemency or more often against, or what was his attitude? All I want to know is the facts.
A: Well, that is difficult to say because I only worked as a judge with Cuhorst presiding only very rarely. In the Togni case he immediately was in favor of clemency. What his attitude was in other cases, I can't tell you because I don't remember any particulars.
Q: Now let me ask you another thing. You stated that in your opinion under the Indictment which was filed in the Togni case, alleging plundering, that the court had no alternative under that indictment but to find the defendant either guilty of plundering or not guilty. Isn't it a fact that a German court always had the right to disregard the indictment and find a defendant guilty of any lesser offense? Couldn't you have found this girl guilty of simple theft, notwithstanding the indictment?
A: Yes. Yes, naturally the court was never bound by the indictment, but the court was bound by the evidence, of course and by the facts which were estimated in the course of the trial, and according to those facts, according to the circumstances of the case it was not possible. It was simply impossible in the Togni case to pass any other sentence because the facts of plundering according to the legal practice of the time, such as it was known to others and myself, existed, and if a case of plundering had occurred, then the law did not allow for any other sentence but the death sentence.
Q: It did not? Weren't you permitted to find that goods had been stolen and to decide of your own power that you would not apply the plundering statute and find theft? Isn't that the law? Didn't you have the right to do it?
A: No. If the court according to the facts which had been established at the final and to which in this case the defendant had exploited the conditions of an air raid or immediately after such an air raid and had appropriated objects, that meant that she had plundered. If the court found that it was a case of plundering, then the court had to pass the death sentence. If in our conviction plundering had been committed, we could not ignore the law. He were bound by the law.
Q: Now, is "Deutsches Recht" a recognized publication containing decisions of the Reich Supreme Court?
A: I know "Deutsches Recht". Yes, I do.
Q: I wish you would look at a case which is marked in "Deutsches Recht" of the 2nd of September, 1944, at page 660.
A: Yes, thank you.
Q: That is an opinion of a judgment by the Reich Supreme Court on May 23, 1944. It is on page 660.
A: Yes.
Q: Now -- yes. The Roman figure II there.
A: Yes.
Q: And it reads: "The facts as established in the judgment -- "the court is speaking of the lower court judgment -
"are not sufficient for the decision that the defendant is guilty of a crime according to Section I of the Decree Against Public Enemies."
Then there is a little paragraph marked "a", a small "a", and a little paragraph marked a small "b". I direct your attention to small "b" now.
"For the conviction under the Decree Against Public Enemies, it is necessary that the offender have the characteristics of a public enemy." Is that a proper statement of the law?
A: Well, that isn't actually said in the law, but concerning the characteristics of a public enemy, well, under the National Socialist -- well, that was a much disputed question, that question of the personality of the offender, a question which was discussed a very great deal under the National Socialist regime.
Q: Yes. Now, well, let me ask you: there are two conditions laid down, one of them under "a" which I will ask you to read in a few minutes, but also "b" that for the conviction of a looter under Section I it is necessary that the offender have the characteristics of a public enemy. Tell me what facts were present from which you found that Louisa Togni had the characteristics of a public enemy? You tell me what facts you found.
A: Well, that was the very much disputed point in the legal practice of the Reich Supreme Court as to what one should understand by "personality", by "type of offender". The Reich Supreme Court for quite a long time had taken the view that the type of offense in itself might characterize a person as a public enemy. For example a person who during an air raid looted the property of people who had lost everything, by doing that proved to have characteristics of a public enemy.
Q: I understand. Now Louisa Togni was a young Italian girl who had not been long in Germany, and this was her only offense so far as the court knew. On those facts did you find, and the defendant Cuhorst, that she had the essential characteristics of a public enemy? "Yes" or "No"?
A: The act as such had to be regarded as the act of a public enemy, as plunder. She had looted and the defendant, in spite of her youth, having committed that offense, had thereby, according to the legal practice of the time -- there was nothing else left for us to do; but that we considered the sentence too severe and that we wanted to spare her all that is proved by the fact that afterwards we tried to have clemency granted. If we had been of a different view -
THE PRESIDENT: The Tribunal will recess at this time.
(A recess was taken).
THE MARSHAL: The Tribunal is again in session.
CROSS-EXAMINATION BY MR. LA FOLLETTE (CONTINUED):
Q I wish you would read slowly to the Tribunal the case which we have been discussing on page 660, from "Deutsches Recht," "Opinion of a Judgment by the Reich Supreme Court of 23 May 1944," beginning with Roman numeral II. And will you read slowly so that the interpreter can accurately interpret?
A "The facts as established by the judgment are not sufficient for the decision whether the defendant is guilty of a crime according to Section I of the Decree Against Public Enemies. Buildings after their destruction by an air attack...."
Q Excuse me, Witness. Isn't there a small "a" just before what you're reading?
A Yes.
Q This is point "a" now which you're reading?
A Yes, I'm reading point "a".
Q All right, proceed again; I'm sorry.
A "'a' If buildings after their destruction by an air attack are evacuated by their inhabitants, they are equal to 'the evacuated area' or the 'voluntary evacuated buildings or rooms' in the meaning of Section 1 of the Decree Against Public Enemies, provided that the evacuation results in the loss of protection of the articles left in the buildings. If the owners have not ceased to supervise their belongings or if other inhabitants of the house or the public order agencies, particularly the police have taken over the protection of the articles left in the evacuated building, the crime of looting is out of the question. The fact that the protective measures taken by the owner or other inhabitants of the house or of the public order agencies were not fully effective in an individual case, does not render applicable the provision of Section 1, Decree Against Public Enemies. It is just the purpose of this statute to constitute the missing safety protection by an extraordinary penalty." And. then shall I read the decision as well?
Q Would you read the second sentence, I think is all, "For the subjective side it is essential...."?
A "For the subjective side it is essential that the offender recognize or at least assume and take into account the possibility that a building evacuated by the inhabitants after enemy activity and the articles left in it are not longer 'protected' in the meaning of the above arguments."
Q Now, would you read after little "b"?
A "For the conviction of a looter under Section 1 of the Decree Against Public Enemies it is necessary that the offender has the characteristics of a public enemy, with similar reasons under 8 May 1944 "Deutsches Recht," 44-447, Section 20."
Q Thank you. Now, do I understand that it's your contention that under that section of the Reich Supreme Court that the mere finding of looting was enough to show that the particular defendant had the characteristics of a public enemy?
A I said before that the jurisdiction of the Supreme Court in the question of characteristics, or at least the view taken by publications, always was that the type of a public enemy is given in the case already of an individual which, according to this type and the characteristics in which it was carried out is sufficiently grave for the perpetrator, who by the way of committing that act stamps himself to the type of a public enemy.
Q That is your answer?
A Please?
Q That's your answer?
A Yes, providing I've understood your question.
Q Now, but you still had the right to find, notwithstanding the indictment, that this was a simple theft, if you found that the defendant did not have the characteristics of a public enemy?
A If the defendant, having committed this act....well, it's difficult for me to answer this. As the act was one committed during an air-raid and by taking advantage of the confusion, therefore, this illegal act, this theft under the conviction of the Court fell under this category and amounted to loot.
And this was so great that the act itself stamped the perpetrator to the type of a public enemy. That was the conviction of the Court at that time, and I can't say anything else.
Q Yes, all right. Now.....
THE PRESIDENT: Witness, may I a ask you, did you receive the judges' letters?
A Yes, I received the judges' letters.
THE PRESIDENT: Do you remember the statement in the judges' letters to the effect that the term "looting" had intentionally been left a very indefinite one so that the judges might exercise some discretion in determining whether the case should be deemed to be one of looting or not?
A Yes, that was so.
BY MR. LA FOLLETTE:
A May I ask you, can you remember in the trial of Louisa Togni, did not her counsel cite to the Defendant Cuhorst and you and the other presiding judge this case from the "Deutsches Recht" which you've just read?
A Of course I cannot remember that any more. It's entirely possible that the defense counsel pointed to this situation. All I can say is that in the case of Togni, as well as in all other cases, when the death sentence was involved I scrutinized everything in the law to find out how I could evade the application of this law and do without the death penalty in the Togni case. But, as reporting judge, I saw no possibility to deviate from this severe penalty because the defendant pleaded guilty; and according to the evidence another judgment was not possible. She would not leave been sentenced to death.....
Q All I asked you was whether you remember whether the defense counsel had cited this case, and I believe you said you're not sure.
That's all I want to know.
A I cannot remember. It's quite impossible for me to remember everything what the defense counsel said.
Q All right, all right, Now, you testified that the Defendant Cuhorst was in favor of clemency in this case. Will you describe to the Court the manner in which the Defendant Cuhorst, during the conference of the judges, acted on most suggestions of clemency? Do you remember the Kreutle-App Case? Now did he act on that case when the suggestion of clemency came up?
A Well, under Cuhorst's presidency in the Penalty Senate I was defense counsel only in a few cases. I couldn't say that.
Q I'm asking you just about the Kreutle and App Case. You said, now, that he was in favor of the clemency plea in that case.
A In this case he was ready to do so immediately; in the case of Togni he was immediately prepared.
DR. BRIEGER: The question has been asked of the Witness once before. I question that the Witness need not answer this question for a second time. That's been answered before.
MR. LA FOLLETTE: I haven't got an answer yet, Your Honor; I'm sorry.
THE PRESIDENT: Very well.
BY MR. LA FOLLETTE:
Q Now, listen to me, please. What was Cuhorst's attitude with reference to clemency in the Kreutle-App Case?
A Well, in the case of App and Kreutle I don't know how the clemency plea came about. I had nothing to do with the expression of the clemency plea; as far as I can recall.
Q Now, let me ask you something. All right, let me ask you another question. You said that in this case that the death penalty was given. Is that correct?
A In the case of App and Kreutle, yes. I was one of the associate judges.
Q All right. Now, didn't you, at that time when you pronounced the death sentence, further pass on the question of whether there would be a recommendation of clemency right at the time you decided on the death sentence?
A Well, there we have the question again -- whether this was part of the secrecy of the deliberations or whether I as German judge am still obliged to.....
MR. LA FOLLETTE: I ask that the Witness be advised, Your Honors, that he is not bound by any official secrecy which prohibits him from answering this question.
THE PRESIDENT: The Witness is so advised, and he is admonished to answer the question.
BY MR. LA FOLLETTE:
Q You will answer this question.
A I do not recall that during the consultations after the App and Kreutle Case, that the question of clemency was discussed at all. I heard nothing after it about the attitude taken by Cuhorst, the presiding judge.
Q Was Cuhorst, the presiding judge, in favor of clemency?
A I just don't know it. I think, however, that presumably he did not favor clemency in this case, but I do not know it.
Q Now, let me ask you just once more -- Isn't it true, and didn't you testify that it was the practice of the Special Court at Stuttgart and the Penal Senate Stuttgart as an accepted practice that when a death sentence was passed the members of the Court simultaneously decided the position upon a clemency plea? Isn't that light?
A Yes, that was usual. At least at that time it was a usual thing. We have experienced it sometimes. Sometimes it also happened that only afterwards we talked about clemency questions.
But to remember details is very difficult.
MR. LA FOLLETTE: That's all.
RE-DIRECT EXAMINATION BY DR. BRIEGER:
Q I have only a very few questions. Witness, may I open my redirect examination? As far as the method of processing clemency appeals was concerned, inasmuch as they were concerned with the findings of the court, were there any changes effected during the war?
A Well, all I can recall at this point is that formally under the clemency regulations the court would express its opinion about the clemency appeal which was usually done in the form of a ruling-"Present were such and such"--and that was decided upon. Later on that right of expressing comments on the clemency appeals were handed over to the Presiding judge, as I remember today. The presiding judge was obliged to hear the Court. That was partly the case; partly it was not.
Q Until the end of the war was it expected that the Presiding judge should give a clemency comment?
A Well, in cases where the death penalty was pronounced, of course, the Court had to express its opinion about clemency--certainly.
Q Did it happen that at the end of the war the Presiding judge had only the possibility to give its opinion on clemency, but not the duty?
A I cannot recall at this moment. There was so many clemency regulations, and repeated changes were given, executive orders, etc. I don't know.
Q Now, Mr. Lafollette has put to you a verdict by the Reich Supreme Court. Was the position underlying the case such that in differentiation to the Cuhorst case there we were concerned with matters which were not meant to be within the law, or do you know of any other differences between the case of the Reich Supreme Court, just put to you, and the Cuhorst case?
A Well, I cannot comment on the decision which Mr. Lafollette has put to me because the background was something completely different from the matters which we had to decide in the case of the Togni, and, therefore, it is not possible, in my opinion, to quote that in this connection.
Each case was a different one and we had to decide according to the evidence and truth after our own conviction whether that or the other law was to be applied or not. Nothing was ever done. At least nothing else was possible while I was present.
Q On the basis of the experience with this case do tou wish to say, Witness, that the verdict of the Reich Supreme Court was binding only in such cases where the evidence was exactly the same, or in a wider sense of this matter, where the evidence was more or less similar?
A The court as Special Courts were not bound by the decisions of the Reich Supreme Court. The decisions could only apply to cases which were of a similar nature and would give a general direction. The Court to decide others on opinion and conviction, and if it were necessary, I could deviate from the opinions of the Reich Supreme Court if the Reich Supreme Court seemed to have ruled not in the right way.
Q My final question: I believe that I have misunderstood the Tribunal just now. I asked the Witness! "Do you know that Cuhorst should have incriminated other judges?" Thereupon the presiding judge said, "What has that to do with the affidavit"? May I ask now whether this question was put to Mr. Lafollette or to me?
THE PRESIDENT: We have ruled on that matter, and we don't care to have it opened again.
DR. BRIEGER: I have finished my re-direct examination. Thank you very much, Mr. Witness. May I now ask for my next witness, please?
THE PRESIDENT: Call your next witness. This witness is excused.
DR. BRIEGER: If the Tribunal please, in order to clarify one point now as to whether the witness Azes dorfer has arrived or not. So far as I have found out that he has not arrived here yet. I told him Thursday evening that the Tribunal would probably not mind giving him leave until Monday morning, and Dr. Stuber told me that Azesdorfer had intended to return Sunday evening.
I have asked somebody to go to my office. I think that he'll be back in five minutes, and then I'll be able to make a definite statement. I assume that Mr. Azesdorfer is not yet present. He will be available only tomorrow. I ask the Court to wait five minutes.
THE PRESIDENT: Is this your last witness?
DR. BRIEGER: Yes, Your Honor.
THE PRESIDENT: The Court feels greatly relieved. Dr. Briger, you have finished with your documents have you now?
DR. BRIEGER: I have not yet started putting in my documents. I have returned this morning and have pushed matters so far that I hope to be able to submit them soon. I do not know how things stand at the moment, but I think I can tell the Court tomorrow morning. I would be very grateful if the Court permit me to delay putting in documents this afternoon in consideration of the special circumstances.
THE PRESIDENT: I think the special circumstances have been duly considered.
(To the Secretary General): Have you documents of Dr, Brieger there?
THE SECRETARY-GENERAL: Yes.
THE PRESIDENT: You may proceed with the introduction of documents.
DR. BRIEGER: I shall immediately fetch my documents.