This is, as I said, Document No. 57, Exhibit No. 56, an affidavit by Willi Haltenorth.
Document No. 58 which will be Exhibit No. 57 is an affidavit by Wilhelm Herth, which again speaks about the same topics. The same applies to Document 59, which will be exhibit No. 58. This is an affidavit of another fellow-soldier of Dr. Hohberg's, Hermann Goerke, who, on the whole, makes statements of a similar nature.
The three following documents were given by persons who belonged to that circle of resistance workers about whom Hohberg has been telling us. They belonged to different circles, actually. All three of them testify that in the house of Herr Passmann, who is himself one of the affiants, they met regularly, met Hohberg on those occasions, and that Hohberg, by what he told them about the incidents in concentration camps and the incidents connected with the slave labor program, considerably helped to undermine the National Socialist system.
This is Document No. 60, which will become Exhibit No, 59. This is an affidavit by Dr. Kurt Baum. Then there is Document No. 61, which will become Exhibit No. 60. This is a. statement given by Dr. Walter Jaenecke, who was a Rittmeister with the OKW in the Foreign Department.
The next document is No. 52, which will be Exhibit No. 61. It is an affidavit by the well-known Eugen Passmann who explains that in his house members of a number of resistance groups met regularly, and that Hohberg frequented his house, and that it was there that he informed the members of the resistance movement of relevant material.
I shall now come to the Appendix No. 1, to Document Book 2. Should the Court not have the English version in front of them, I have here three more copies. The first document in this book is Exhibit 63, which will be given Exhibit number 62. This is an affidavit of one Johann Stein, who was once upon a time an SS-Sturmbannfuehrer and an expert in the personnel office of the WVHA.
This affidavit shows that attempts were made as late as 1945 to get Hohberg into the Waffen-SS, that Hohberg, however, escaped this fate by running away.
Document No. 64 which will he Exhibit No. 63 is an affidavit of similar content. It was given by Karl Morgenthaler, who, incidentally has known Hohberg ever since 1934, and who has heard from Hohherg a number of details of the attempted transfered to the Waffen-SS.
The next document is Document 65, which will become Exhibit No. 64. It is an affidavit by Max Bodemer which proves that Hohberg, after his discharge from the Army, no longer entertained any relations with the SS, and that Hohberg did not accept an offer to act as a liaison officer between Keppler's staff and Pohl.
Document No. 66 has already been offered as Exhibit No. 41. Document No. 67 will be Exhibit No. 65.
I should like to draw the Court's attention to this particular affidavit because here we are concerned with an affidavit by Richard Ansorge, who, since 1941, acted as an auditor under Hohberg and then later on was a commercial employee of the DWB until February, 1945. He is, therefore, well informed about conditions in Staff-W.
I should like to read one brief sentence which, it seems to me, is an important one. It is contained on the first page of the affidavit, the next-to-the-last paragraph in the German document book. Ansorge says here: "At no time was Dr. Hohberg chief of Staff W."
The next document, Hohberg No. 68, which will become Exhibit No. 66, is also an affidavit by the same Richard Ansorge in which he gives additional statements to the previous statement. In particular, he says there that the position of Chief-W was unlike the position of that of the Chief of Staff-W. This, if Your Honors please, brings me to the conclusion of submitting my documents. I should like to add that I have a few documents left which are still with the Translation Section and which, I hope, will soon reach the Court within the course of this week.
I should like, therefore, to reserve the right of offering these few documents, the contents of which are extremely important, particularly because one of them is concerned with those Prosecution documents dealing with the Apolinaris affair.
MISS JOHNSON: On behalf of the Prosecution we desire to withdraw Exhibit 580 which was Document No. 4386, found in Document Book No. 24. Counsel for Defendant Hohberg made mention of that document this morning.
THE PRESIDENT: Five-eighty?
MISS JOHNSON: Five-eighty.
DR. MAAS (Counsel for defendant Hohberg): I am extremely sorry, Your Honor, I did not quite follow.
THE PRESIDENT: Prosecution has withdrawn the exhibit which you objected to, Number 580, in Document Book No. 24, because they had lost the original. We are therefore, striking it from the record.
DR. MAAS: Thank you very much, Your Honor.
THE PRESIDENT: Any documents to be offered by other Defense Counsel?
DR. PRACHT (Counsel for Dr. Froeschmann on behalf of Mummenthey):
If the Tribunal please, Dr. Froeschmann intended to submit Mummenthey Document Books I and II and II and Supplement I: but there was a technical hitch. Document Book III does not seem to be completed as yet - at least as far as the translation into English is concerned. Unhappily we had this delay, and I would like to ask the Court to have the recess a little earlier perhaps so that immediately after the recess Dr. Froeschmann could begin with the submission of his documents.
THE PRESIDENT: Well, why doesn't he begin with those that are ready?
DR. PRACHT: If Your Honors please, he is still waiting in vain for the last volume: Volume III - so that he can offer everything at once.
THE PRESIDENT: Why doesn't he begin with Volume I? By the time he finishes that, Volume III will be ready.
DR. PRACHT: Mr. President, he will certainly do this at once, only I have to inform him that he should come here and start on I and II. That was the reason why I asked the Court to have the recess now in order to give Dr. Froeschmann the opportunity.
THE PRESIDENT: Anyone else ready with documents?
We will take our regular recess until three o'clock.
THE MARSHAL: The Tribunal will recess until 1500.
(A recess was taken.)
THE MARSHAL: The Tribunal is again in session.
DR. MAAS: (Attorney for the Defendant Hohberg): Your Honor, it has been pointed out to me during the recess that when I presented my documents, there was a mistake in the translation. I would like to clarify this mistake now. Here we were dealing with Document Hohberg No. 65 in the First Supplement to Document Book No. 2. This is Exhibit 64, and when the affidavit of Max Bodemer was mentioned I talked about a Kessler and I have been informed that the translation was Keppler Staff. In reality, it should be Kessler. The difference is very important, because actually by Keppler Circle is understood the circle of friends of Himmler and this leads to a misunderstanding.
THE PRESIDENT: What exhibit number, please?
DR. MAAS: It is Exhibit No. 64, - 64.
THE PRESIDENT: It was only a mistake in the translation. The document is all right?
DR. MAAS: Yes, the document is all right.
THE PRESIDENT: All right, Dr. Froeschmann, will you proceed?
DR. FROESCHMANN (for the defendant Mummenthey): I beg your pardon, Your Honor, I attended an interrogation before, and it took up more time than I expected. That is why the Tribunal had to wait for me.
Your Honor, I shall now begin to submit my documents in the case of Mummenthey. I want to present Document Number 1 in my Document Book I. It is an affidavit by Dora Wagner of the 18th of June 1947. This will become Exhibit Number 1. She signed it on that date and I certified it. In this document, I want to draw the attention of the Tribunal, in particular, to Paragraph 2 in which the witness points out the fact that shortly after she took up her duties she was struck by the fact that Mummenthey was very much limited in his work, compared to other undertakings. She also points out the special position which Schondorff occupied.
In Paragraph 3 the witness mentions the decentralization of the works, and the defendant Mummenthey has already mentioned that. In Paragraph 4 the witness refers to the fact that Mummenthey had to comply with Pohl's orders in all affairs. In Paragraph 8 the witness states that Mummenthey tried to gain an insight into the actual conditions under which the inmates lived and worked. However, in this he was only partially successful because of the organization of the concentration camps and the strict concentration camp regulations.
In Paragraph 9 the witness points out that she did not know anything of a directive of Mummenthey according to which prisoners were to be driven to work. In Paragraph 11 the witness points out the efforts of Mummenthey to make life easier for the inmates in general. In Paragraph 15 it is pointed out that Mummenthey always stressed the fact that only people who were really fit for work should be employed in the factories. She further points out that Mummenthey's attitude on behalf of the inmates brought him difficulties; and he himself was exposed to the danger of persecution.
Paragraph 16 deals with a fact which has become known in the meantime, that Mummenthey tried in numerous cases to have concentration camp inmates released. However, these attempts were unsuccessful; and many difficulties were occasioned Mummenthey, among other thing also by the RSHA, not, as it states in the English text, by the Main Race and Settlement Office but the Reich Main Security Office.
I have discovered that there are numerous mistakes in the translation in these documents in my document book; and I have addressed a communication to the Tribunal in which I shall point out the translation mistakes which are contained in Document Book I and the supplement to Document Book I.
Then with regard to this document, I want to draw the Court's attention to Paragraph 21 according to which Mummenthey ordered the chief of the legal department, Dr. Schneider, to compile a collection of all the regulations and axioms of the German legal administration concerning penal administration. On the basis of this compilation Mummenthey submitted a report with suggestions and proposals regarding the labor allocation of concentration camp inmates to the competent agency.
Conclusive in I paragraph 22 the witness states that during her activity in the DEST she came to know Mummenthey as a very reliable man of social consciousness who was warmhearted towards his subordinates, and helped everyone whom he could help.
As Exhibit number 2 I want to submit Document Number 2, the affidavit of Karl Kaiser. He was a stone mason, a foreman, and he has been mentioned several times during the previous presentation of evidence. This affidavit bears the date of 12 July 1947; and it was signed on that day by Karl Kaiser, and I certified to this affidavit. It is not necessary for me to read this affidavit in detail and to deal with it in detail.
It describes the big training center which Mummenthey established during his activity in the DEST; and it deals in detail with the measures which Kaiser carried out by order of Mummenthey.
In Paragraph 3 the affiant points out that Mummenthey encountered many great difficulties in his attempts to alleviate the condition of the inmates and that the inmates liked him very much and were very efficient in their training.
In Paragraph 8 the affiant points out that Mummenthey, since he persistently stuck to his goal, carried, out many things which alleviated the condition of the inmates in the stone-cutting plant at Oranienburg. Then he shows how the conditions of the inmates were improved in detail. I ask the Tribunal to take judicial notice of these statements.
As Exhibit Number 3 I want to offer Document Number 3 by Rudolf Ronge, who was a plant manager in various enterprises. In the affidavit of Rudolf Ronge there is first the date of the 28th of June 1947. It was signed on that date by the affiant Ronge and certified by me. In this affidavit I want to draw the attention of the Tribual to Paragraph 4, in particular in which the purpose of the DEST is explained. This has already been mentioned in the presentation of evidence before.
Then I want to draw the Tribunal's attention to Paragraph 5 where the fact is mentioned that the DEST tried to have a number of specially skilled workers for the stone cutting and its work through adequate training.
In Paragraph 6 an explanation is given about the granite works at Flossenburg, and it is stated in 7 here that the mechanization of the enterprise, which was carried out by Mummenthey, carried with it quite a simplification of the work.
In Paragraph 8 I should like to point out that the affiant states that he could state with a good conscience that the working conditions of the civilian workers from private industry were not as favorable as conditions in the granite works Flossenburg after its industrialization.
It is also pointed out here that it was the purpose of the DEST to obtain skilled workers and that it would not have been reasonable if the people who worked in the plant had been worked to death. The plant management and the defendant Mummenthey did not have the slightest intention of doing that.
In Paragraph 11 the witness confirms what the witness Bickel has already stated here in detail, namely, that the camp commandants had little understanding for the needs of the industries; that it acted in an arbitrary manner; and that constantly there were differences between the plant management and the concentration camp commander. Here, as far as the witness was concerned, the dispute became so severe that he had himself transferred away from Flossenburg.
In Paragraph 13 the individual working conditions are described in detail. This also shows the contrary of what the prosecution has said or the prosecution witnesses have testified to here in a very confused form. It states here that sick inmates were not employed and that the plant management did not want them to work and would have objected to their working because they might have infected the other workers.
In Paragraph 15 the witness describes the local situation of the granite works at Flossenburg as well as the situation of the camp of Flossenburg. He points out in this respect that through the extension of the camp the camp itself came into the possession of some stone quarries.
In Paragraph 16 the punitive company is mentioned, over whose composition and organization the plant managers of the DEST did not have any influence. The affiant states that the commandant's office used and organized this punitive company according to its disposition.
The affiant further points out that the plant managers did not have the least thing to do with the punitive company and that the civilian plant administration would, not have been able to interfere against the authority of the concentration camp commanders. It seems to me of importance particularly that the plant management never employed punitive companies in their works; and I want to emphasize the word "plant" here as well as the fact that the affiant had never seen nor heard of ill-treatment of prisoners doing their work in the plant.
In Paragraph 19 the affiant mentions the privileges which resulted from Mummenthey's efforts, for which the commandant's office showed very little understanding. He also emphasizes that in view of the industrialization of the enterprise no extremely hard work had to be performed any longer.
In Paragraph 21 the affiant points out that all the efforts of the plant management in order to obtain privileges for the inmates were always supported by the defendant Mummenthey with greatest understanding. In Paragraph 23 the fact is stated that Mummenthey strongly supported the idea of releasing prisoners from concentration camp confinement by permitting them to work as civilian workers; and he frequently mentioned his intention of keeping the inmates at some later time as civilian workers in the DEST.
As Exhibit Number 4 I offer Document Number 4, which is on page 32 of the English document book. This is an affidavit by Max Schubert. It bears the date of the 27th of June 1947, signed by the affiant on that date and was certified by me. This affidavit also refers to the granite works at Flossenburg; and in general it deals with the same subject which Ronge had already mentioned in detail. In Particular in Paragraph 4 instates that the plant did not employ any inmates he were unfit for work and that members of the staff of the plant never maltreated any inmates. This affiant also refutes the claim of the prosecution that working conditions in the plant had been such that the inmates had worked themselves to death; and he refutes this statement as being incorrect.
In Paragraph 5-b this affiant confirms the fact that Mummenthey fully appreciated all suggestions which were made by the works management in this direction in order to alleviate the conditions of the inmates and says that he also added a few valuable suggestions of his own. He then mentions the individual privileges in detail here; and he fully confirms the statements made her by Mummenthey. He, futhermore, speaks of the difficulties in Paragraph 5-e which Mummenthey encountered from the camp commanders. They even went so far as to forbid the supply of additional items of food which Mummenthey wanted to obtain for the inmates.
Paragraph 6 deals with the fact that the Dest on its own initiative and with the consent of Mummenthey in the fall of 1939 and in 1940 procured winter gloves for the inmates after Mummenthey had previously received the permission of the camp commander.
As Exhibit Number 5 I want to offer Mummenthey Document Number 5 on page 38 of the my English Document Book. This is an affidavit by Hermann Franz Josef Pister of the 27th of June 1947, signed by the affiant and that date and certified by me. This affidavit refers to the conditions at Berlstedt. I want to ask the Tribunal for special consideration of Paragraph 1-c according to which the witness goes into detail with regard to the clay pit which was located next to the brick works and from which the clay was obtained.
For the brick works. He describes the conditions there in detail and emphasizes that here also technical measures were takein in order to drain the water from the lower levels in the clay pit. He also mentions the fat the a Dest issued high rubber boots to the inmates while they were working in the pit so that they could have some protection against the weather.
This witness also states in Paragraph 4 that he got to know Mummenthey to be a very social progressive and decent man. In Paragraph 5 the affiant points out that from conversations with Mummenthey he gained the impression that Mummenthey tried to have a first-rate output in the matter of quality which could only be accomplished with healthy and contented prisoner inmates in good state of nutrition.
In Paragraph 5-b the witness point out the social care of the inmates, which was very close to the heart of Mummenthey. Then in the following paragraphs he mentions the individual privileges, the procurement of fresh vegetables, meat, and so on. Then I have considered it appropriate the I have the witness give us information about the punitive company in Paragraph 7. I need not go into detail here. However the statement in Paragraph 7 seems of importance to me, according to which the Buchenwald quarry had nothing whatsoever to do with the plant or the management of Berlstedt. This quarry did not belong to the Dest and it was not located in the area of the Dest. This seems to be of importance to me in view of the testimony of the witness Morgen, who recently has mentioned this stone quarry at Berlstedt.
As my next exhibit, Number 6, I offer Document Number 6 on Page 44 of my Document Book, which is the affidavit of Otto Walther. It is dated the 10th of July 1947 and signed by him on that date and certified by me. This very extensive affidavit gives the Tribunal an insight into the conditions which the plant manager of Mauthuasen observed during his activity in that position.
I do not have to go into detail here with regard to the preliminary work which the witness describes in Paragraph 4 and 6 of his affidavit; I what to state that in Paragraph 11 the witness mentions the fact that since conditions had to be improved at Mauthausen, in order to stop these bad conditions the Dest had made efforts to organize a separate labor camp which was to be under the control and administration of the Dest. This was done in order to show the inspectorate of the concentration camps that it would be best to take the working inmates out of the concentration camps and put them into a labor camp which would be subordinated in the industrial enterprise.
In the following paragraphs the affiant points out that all attempts of the plant administration had contrary effect, that difficulties were placed in their path whenever it was possible and that Mummenthey's attempt met an enormous amount of resistance. I Paragraph 14 the witness deals with the allocation of the inmates, He mentions the punitive company. In Paragraph 17 the affiant refers to the various measures which Mummenthey made in order to improve the condition of the inmates working in the plants. He also points out Mummenthey's social of the strict administration of the WVHA and the manner in which the directives were issued from higher agencies.
Paragraph 18 deals with the danger of epidemics and the epidemic which actually broke out are Mauthausen. He mentions the measures which Mummenthey took as soon as the fact became known that as epidemic prevailed.
Paragraph 19 mentions the privileges which were obtained for the inmates by Mummenthey's intervention. Paragraph 20 mentions the difficulties which Mummenthey encountered in his attempts to have inmates released. This statement is especially interesting in view of the fact because in the affidavit of the witness Sanner the fact was mentioned, that from Berlin a directive had been issued, stating that inmates were not be released. This is a claim which apparently is based on a misunderstanding of the witness because the plant manager here must be best informed, and he has stated exactly the contrary of what the witness Sanner has testified to.
As my next exhibit I offer Exhibit Number 7. This is Document Number 7 on page 57 of the English text, and this is an affidavit of the merchant Adolf Riemer. It is dated the 11th of July 1947, signed by him on that date, and certified by me. This affidavit refers to the concentration camp Stutthef or the work near Stutthef. May I ask the Tribunal to pay particular attention in this affidavit to Paragraph 5? In the previous paragraphs the witness mentioned the fact that the works there were very old fashioned and that consequently when the works were taken over the works were first of all mechanized and industrialized so that the work for the inmates would be easier. However, it was necessary that in the place of one worker who worked up to that time, now for the same working process three or four inmates were occupied, form which it became evident on the one had that the work of each one of these inmates only amountes to one fourth of what this one civilian worker had to work before. On the other hand, we have the fact that the value of inmate labor only amounted at one fourth of the work a civilian worker carried out. From this it can be concluded that Mummenthey tried to convert these inmates to free workers when they were released for the concentration camp.
In paragraph 8 the conditions are described in detail; and it is also pointed out that Mummenthey procured again additional food for the inmates. In Paragraph 9 the witness mentions the fact that he did not hear anything about any maltreatment of inmates by the guards or by the workers at the plant and that the plant management also tried to treat the inmates will from the humane point of view. The witness gives us truthfully one exception here Paragraph 11 describes again in detail the authority which the camp commanders took upon themselves towards the plant management and the difficulties which Mummenthey encountered in the administration of his on terprise.
He concludes his affidavit with the words: Mummenthey was clean to the core and never had any thought of enriching himself. Aside from the fulfillment of the tasks of the works, he had at heart the welfare of the inmates whom he wanted to lead a free life with work after the war."
My next exhibit will be No. 8. This will be Mummenthey's Document No. 8, page 64 of my document book. This is an affidavit of Otto Georges, and it is dated 11 July 1947. It was signed on that day by the affiant and certified by me. This refers to concentration at Neuengamme. The witness describes in detail the conditions which prevailed there, and I don't need to go into detail here, because the witness Pickle did already describe it in detail, on the point of the bonus system, that point he points out of the treatment, and he also mentions the fact that he did not hear that during working hours at the plant mortality cases of inmates had occurred, and, that, however, the camp commanders had tried repeatedly to detail sick inmates for work but in view of their physical condition were rejected by the plant management, and sent back. He also confirms the witness Bickel's statement, that as result of this there were constant disputes between the plant management and the concentration camp commanders, and that Mummenthey intervened in order to alleviate the conditions of the inmates.
In paragraph 9 the affiant states that Mummenthey had a social attitude and he wanted to change the inmates into free civilian workers after the war, and he tried to do that by giving them training, which had been mentioned before. The social attitude and social consciousness of Mummenthey the witness said in paragraph 9 also was very evident at the annual discussions which took place at the plant. Mummenthey here particularly stressed the social expenses which were incurred by the plants in the interest of the inmates, and he again and again stressed the fact this expense should be increased for the benefit of the inmates. In the course of his activities, he learned to appreciate only the most correct of his superiors he ever had. He never boasted of his authority, and he always advised his colleagues in kind words, and he was not only popular in his own plant, because he was always ready to help but he was always highly respected by the way he carried out his work. This does not only apply to detailed workers, but also of prisoners. This will be also confirmed by the witness Bickel.
My next exhibit No. 9 is Mummenthey's document No. 10. It is the affidavit of Josef Opperbeck, which is dated 15 July 1947. It was signed by the affiant on the date indicated and certified by me. This affidavit refers to the taking over of the business management by Mummenthey as Deputy in the Fall of 1941. It described the manner and just what groups included in paragraph 6, and he again mentioned the fact that Mummenthey always insisted on decent and humane treatment of the inmates. The witness said that Mummenthey also procured tobacco constantly for the inmates, and aside from the he always gave the inmates privileges by having fresh vegetables and things of that sort.
From my document book No. 2 I now would like to come to Document 28 for reasons of better survey. It is on page 38 of my document book. This is a copy of the report of the president of the district court at Leipsig on 31 May 1937, which I want to submit as Exhibit No. 10. I shall point out its contents insofar as at that time the president of the district court there confirms Mummenthey's social consciousness.
As my next exhibit, which will be Exhibit No. 11, it will be document No. 29 on page 40 of my Document Book No. II. This is the affidavit of an inmate August Skladal. It bears the date of 15 July 1947, and Skaldal signed it on that date and I certified to it. Skaldal was, as becomes evident from paragraph 1, arrested by the Gestapo on suspicion for treason, and without any trial he was sent to the concentration camp Reichenau. Later on he came to Dachau and Flossenburg, and finally he came to Neurohlau; In paragraph 3 in the affidavit the affiant describes the activity of Bohemia at Neurohlau, its production, and the facilities which were established there for civilian employees as well as for the inmates. It deals with the food questions there, the work hours and the quite humane treatment of the inmates. It is in paragraph 5. He says he never heard of members or workers in the plant carrying out immoral treatments of inmates." However, I can recall several incidents when punitive measures ordered by the camp commander had to be prematurely discontinued as a result of intercession by the works management."
It would be interesting for the Tribunal to know the incidents which the affiant described in paragraph 7, according to which a camp commander wanted to strike inmates and to assault them, and accordint to which Mummenthey through his intervention prevented this. Furthermore, according to which he told the inmate in almost harsh tones that he was not to be saluted by them in a military manner. In paragraph 8 the witness mentions the fact that Mummenthey on this occasion asked for the name, the profession and the reason why Skaldal was in confinement and he made a statement that he was shocked at the fact of why so many people should be confined in concentration camps because of their political convictions; and were confined with criminals without having committed any crimes. At the time he asked him for his personal state of affairs, and he could in his own way tell him that he was doing well here when compared to the camp at Flossenburg. In this affidavit the witness also described also that the DEST still intervened on behalf of inmates during the last days of the war. I must have made a mistake here. The witness stated here, as the Tribunal can also determine, that he was doing well at Neurohlau compared to the camp at Flossenburg.
My next exhibit will be Exhibit No. 12, which is document No. 30 on page 46 of my Document Book II. This is an affidavit by Gerhard Schrameck, of 18 July 1947, and it was signed on that date by Schramack, and certified by me. This affidavit refers to conditions at Prambachkirchen, and to the foundry at Linz. That was the slack work at Linz. I want to draw the attention of the Tribunal particularly to paragraph it of this affidavit, in which working process is described in detail and to paragraph 6 in which this affiant states that in the other plants, or other industries, conditions were the same which prevailed at Linz, the only difference was here that in the free industry, as I have mentioned before, one civilian worker had to take care of one part of the work, while in the same working process the plant at Linz was carried out by several inmates.
In paragraph 7 the affiant deals with the working hours, and in paragraph 9 states that no abusive treatment much loss inhuman treatment occurred, so far as working employees and working management were concerned. In Linz among the working inmates, intelligent cooperation existed.
Of course, the witness already stated that his relations with the camp commander was very bad, this was the well known Zierreis, and, of course, he did not show any sympathic attitude towards the inmates, and enormous difficulties arose from this condition for the plant managers, and these incidents may have led to the fact that the architect Fischer, who came to the Tribunal and can still recall the fact a DEST employee in his plant was severely attacked by the camp administration, and that he was sent back to the concentration camp.
The next document which I will submit is Exhibit No. 1e, Document 31. This is the affidavit of a certain Sturm Kegel. It is on page 56 of the document book.
JUDGE PHILLIPS: Exhibit No. 13 I think it is, instead of 31.
DR. FREOSCHMANN: Yes, Your Honor, it is Exhibit No. 13. This affidavit refers to the clearing up of the debris at Essen carried out by DEST at war time, and it is not of importance to the trial, because actually we did not deal with that subject during the trial. However, it also proves that it was at Essen that DEST also tried to alleviate the conditions of the inmates, so far as DEST was able to do so. Mummenthey constantly tried to be successful here in this respect. Especially through the air attacks at the main works during the end of the war, which certainly was not easy. The witness confirms that the city officials who decided on the construction sites, reported that there were never any violation of laws of humanity, which might have been the source of complaints.
The next exhibit will be No. 14. This is document No. 32. It is an affidavit of Paul Zimmerman on 19 July 1947. It was signed on that date by the affiant, and certified by me. I included this affidavit in my document book because Salpeter, as the Tribunal will recall, had succeeded in being transferred to the front for one year from the DEST. It has been mentioned several times during the presentation of evidence that members of the DEST and the WVHA usually were not able to fight their way out.