THE MARSHALL: The Tribunal is again in session.
BY MR. ROBBINS:
Q. Witness, I should like to repeat a question to you just to see if I get the same answer the second time. I can't believe that I will. Did you ever hear the Jews were placed in concentration camps by the Reich just because they were Jews?
A. No, I never heard that.
JUDGE MUSMANNO: Was that the same answer as before?
Q. Yes, sir. Did you ever hear of the Nuernberg Laws, Witness?
A. Yes, I read about the Nuernberg Laws.
Q. Did you ever read any of the literature of the SS?
A. Occasionally I would read part of the SS literature.
Q. Did you ever read any of the literature of the Nazi Party?
A. I don't know of any Nazi literature which I read outside of the press.
Q. Well, did you ever read the Stuermer?
A. No, I never read that paper. I saw it on the newsstands but I would not even touch it.
Q. Did you ever read the Schwarzes Korps, the SS newspaper?
A. Yes, I read that.
Q. Did you read the pamphlet that Himmler put out for the SS men called the SS an Anti-bolshevist Fighting Organization?
A. No, it's unknown to me.
Q. Did you ever read the Organization Book of the Nazi Party?
A. No, I didn't read that either. It's completely unknown to me.
Q. Never even heard of the Organization Book of the Nazi Party, what?
A. No, the Organization Book of the Party never came to my attention, I never even heard of it.
BY JUDGE MUSMANNO: Do you know of Mein Kampf?
A. Mein Kampf ? I read the book, yes.
Q. You read the book?
A. Yes, it's a book which the Fuehrer wrote. Yes, I read it.
Q. What year did you read it in? You read it before the war?
A. Yes, before the war, I believe I read it in the year 1937. I am just trying to find the exact time. I believe that it was in 1937.
Q. Well, you knew what Hitler said about the Jews then?
A. I read it, yes.
BY MR. ROBBINS:
Q. Did you ever go to any of the Nazi Party rallies?
A. I never took part in a rally of the Nazi Party. I didn't have time for that.
Q. I didn't ask you that. I asked you if you attended.
A. I stated that I never attended one. I have never been there.
Q. You didn't see when you were reading the Schwarzes Korps that its policy was to promote the elimination of Jews from Germany? You didn't see that in the Schwarzes Korps?
A. I certainly did not read that in the Schwarzes Korps. I didn't see that elimination was being discussed there.
Q. Did you ever visit a concentration camp?
A. No, I never visited a concentration camp.
Q. You were never in a concentration camp in your life?
A. No.
Q. When you came to the WVHA you knew that Amtsgruppe C was to use inmate labor in its construction projects, did you not?
A. No, it was unknown to me at the time. I heard about that much later.
Q. How much later?
A. Let's say in the middle of 1942 or at the end of 1942.
Q. Had you ever heard that Amtsgruppe C used foreign labor in its construction projects?
A. Yes, I heard that, and also heard that there was an enterprise named Heinrich there. That was an establishment which, as far as I know , was copied from the allocation of foreign workers of the Organization Todt.
As far as I know, firms were used here which on their own initiative worked or employed and conscripted foreign workers.
Q. Did you hear that these were concentration camp inmates?
A. No, they were volunteers. They were workers which were given a contract on the free market or who had volunteered. They were used, employed by firms.
Q. You believe that they worked voluntarily?
A. Yes.
Q. Did you ever hear that anyone working on a construction project of Amtsgruppe C was worked to death?
A. No, I never heard anything of that sort.
Q. Not even one person?
A. No not in a single case.
Q. When you joined the WVHA you knew the nature of the tasks that Amtsgruppe W was to perform, did you not?
A. The task of the Office W were unknown to me during my entire activity and they were certainly unknown to me at the time.
Q. When you joined the WVHA you knew the nature of the task that Amtsgruppe W was to perform, did you not?
A. The task of Office W was rather unknown to me in my entire activity and with certainty not known to me at that time.
Q. Did you ever find out that they used concentration camp inmates in their industries?
A. In the W Plants? In the economic plants? No, I did not know that.
Q. Witness, where did you think these industries were located? You knew they were located in the concentration camps, didn't you?
A. I hardly believe -- Yes, I knew of it because I knew that at Oranienburg there were some brick works, and therefore I must assume that if there are some works at Oranienburg, as a W-plant, this must be in some connection with the labor that was available there.
Q. Just try to concentrate a little harder on your answers in the future then, will you? When Amtsgruppe D was put into the WVHA you knew what kind of an organization that was, didn't you? You knew that it was to administer concentration camp inmates, concentration camps, or did you think that it had nothing to do with inmate labor?
A. These W Plants were always described to us as private enterprises, and I always thought that they were private enterprises.
Q. I am talking about Amtsgruppe D, D for "Dog", and when Amtsgruppe D was placed into the WVHA you knew that it was to administer concentration camps, that it had been the concentration camp inspectorate; you knew that, didn't you?
A. Yes.
Q. You knew that there was a labor allocation office In Amtsgruppe D, didn't you?
A. I knew that from the organizational chart.
Q. Where did you think the inmates were allocated to by this labor allocation office?
A. I thought at that time--as far as I thought about these matters at all--that this was work which was connected with the camp itself or which was to be carried out in the immediate vicinity of the camp.
Q. But you did not give it very much thought?
A. No, certainly not. I did not have any reason to do so.
Q. Did you ever have a conversation with any one who worked for Amtsgruppe D?
A. Who worked for Amtsgruppe D? No, that is unknown to me.
Q. You never even spoke to any one in Amtsgruppe D?
A. No, I have never been in Oranienburg, and from Oranienburg nobody came to see me, and I don't know any member of Amtsgruppe D.
Q. You would not have known Gluecks if you had seen him, would you?
A. I would have recognized Gluecks because I had met him one time at a Christmas celebration at Berlin. I was introduced to him on that occasion.
Q. Is that the only time you ever talked to Gluecks?
A. Yes, as far as I can recall, this Christmas celebration was the only time. I did not talk to Gluecks. I was merely introduced to him.
Q. Did you know Maurer?
A. No.
Q. Did you ever have a conversation with anyone in Amtsgruppe W?
A. W? No.
Q. Did you ever speak to any of them? Did you know them if you saw them? They were in the same general location with you, the same building practically.
A. No, I think that the W Offices were located in different buildings and in different ends of Berlin. In part they were even located outside Berlin.
Q. Did you ever speak to anyone in Amtsgruppe W? Did you know them personally?
A. I would like to put it this way: Officially I did not have any contact with them, and I did not talk to them. It is quite possible, however, that on some occasion or other some of these officers were together with me and as it is usual I had a short discussion with them, but they were not official discussions.
Q. They were not business discussions? They did not have anything to do with the business in the WVHA?
A. Yes. I must limit this. I just recalled one particular case. In the field of the housing construction I also had to look after the facilities which were to be installed in the new housing program, and on this occasion I at one time tried to obtain the advice of a leader in the W Office. That was the W Office which had to do with the wood production matters and so forth. They produced furniture and at the time I tried to obtain some advice about various subjects.
Q. Which office was that in W?
A. As far as I can judge, that must have been Office W-IV. It is very hard for me to read it on the chart.
Q. Is that all you remember about the conversation?
A. Yes. I know what the subject we discussed on that occasion was. We were discussing the furniture to be put in a kitchen, or new basins, and I asked the man to tell me from his experience how these matters could be installed in the most appropriate manner; that is to say, the facilities which were to be installed in the kitchen.
He gave me some advice, and thus I was able to continue with my work. He showed me some sketches about these facilities that were to be installed.
Q. Where were they to be installed? What kitchen?
A. These were the ketchens for the construction and housing construction program which was to be carried out after the war.
Q. Is that the only conversation you had with anyone in Amtsgruppe W?
A. I did not understand.
Q. W.
A. As far as I can recall at the moment yes.
Q. Did you have any conversations with anyone in Amtsgruppe A?
A. No, I do not recall ever having had any discussions with any officer or leader in Office Group A in any matters whatsoever.
Q. You never even spoke to them? Did you know them personally?
A. I probably knew all members of Amtsgruppe A.personally because they were located in the same block.
Q. But you never had any business conference with any of them?
A. We did not have to discuss any official matters there.
Q. I did not ask you if you had to; I asked you if you did.
A. No.
Q. How about the people in Amtsgruppe B? Did you ever talk to them about business matters?
A. No, I did not discuss any official matters with them either.
Q. Did you know them?
A. Yes, I certainly knew them, at least a large number of them.
Q. Before we get too far away from Amtsgruppe W, do you recall having had conversations with anyone concerning the textile and leather industry under Amtsgruppe W?
A. No, I can't recall the leather industry at all.
Q. Textile and leather.
A. No.
Q. Do you recall designing or making sketches for any kind of buildings concerning mechanical weaving?
A. No, I did not design any sketches at all.
Q. Did you make any designs or sketches for any kind of hothouses, greenhouses, at any time?
A. No.
Q. You don't remember sketching plans for hothouses to be used at Ravensbruck concentration camp?
A. No, I cannot recall that at all.
Q. Would you recall it if it happened?
A. I hardly believe that I could remember, because a greenhouse is such a small matter which would be forgotten very quickly.
Q. So it is possible that you made such designs and have forgotten about them? Is that it?
A. I hardly think so. I hardly think that I would have forgotten them if I had sketched them.
Q. I thought you said you might have forgotten them. Is it your testimony that you have never made any sketches or plans whatsoever for use in concentration camp Ravensbruck?
A. No, I cannot recall it.
Q. Well, do you exclude that possibility?
A. I would have to exclude it because in my office I never sketched any plans for concentration camps.
Q. In your direct testimony you referred to the Fuehrer order for an increase in buildings, increase in dwellings. How many million dwelling houses did that program envisage?
A. I believe 5,000,000.
Q. You knew, didn't you, that concentration camp inmates were to be used in carrying out that program?
A. That matter was never discussed.
Q. I asked you if you knew about it.
A. I could not know it because exactly the contrary was the case. The question never arose whether these dwellings were to be constructed by inmates.
Q. You have seen from the documents, haven't you, that Pohl was given the job to have inmates trained for the postwar building program? You know that today, don't you?
A. I have seen from the documents that stone cutters had been trained, and so on. However, that had nothing to do with the program for the building of houses after the war.
Q: Now, you spoke about the army hospitals that were built, the plans that you designed for those hospitals and training centers for the Waffen-SS. Were those plans ever carried into completion, were the buildings erected?
A: As far as I know throughout the entire time of the war, no army hospitals were built within the territory of the Reich, but as far as the troop units receiving new army hospitals was concerned they were established in buildings which had already been previously constructed. However, that was not the task of the WVHA, but that of the Operational Main Office, and the Medical Office had to take care of that.
Q: I still don't know what your answer is to my question, were these army hospitals for which you drew the basic plans and the training centers for the Waffen-SS, were these things ever constructed?
A: I had nothing to do with the buildings in the training centers of the Waffen-SS. However, army hospitals within the territory of the Reich were never constructed.
Q: All right, the army hospitals were not constructed. Were the training centers for the Waffen-SS ever constructed? I didn't ask you if you constructed them. I asked you if they were ever constructed? You said you spent lots of time on it. You weren't doing anything else for months but working on the plan. You surely know about it.
A: The two training centers where I had to compose the drafts, no army hospitals were built. However, I know that the troops in the training centers had to use private hospitals.
Q: Witness, you told the Court that you worked for months on plans for two training centers for the Waffen-SS. I am asking you now for the fourth time, were those plans ever carried out. Were the buildings ever built?
A: No.
Q: So, as I understand your testimony, you worked at Berlin for three and a half years drawing plans and sketches, and not one single building that you ever sketched was ever built, that is right, isn't it?
A: That is not correct. Two army hospitals were established according to the plants. One was at Uluw, Finland, and the second one was established at Dnjepropetrowsk, Russia. One hospital had five hundred beds; the other one had a capacity of one thousand beds. Furthermore, the army hospital department at Wuerzburg was already established, which I have already discussed. The drafts which I had worked out were destined for the construction of hospitals in peacetime.
Q: So three buildings were erected. Is that all that were erected?
A: Three buildings were newly constructed. That is all I know about it. All the other facilities were established in buildings which had already been previously constructed.
Q: And do you know who carried out the actual construction of the hospital at Wuerzburg that you just mentioned? It was Wuerzburg, wasn't it?
A: Yes, it was Wuerzburg. The Construction Inspectorate in Munich had to give the orders for that because it was competent for Wuerzburg.
Q: Do you know whether concentration-camp inmates were used in the construction of the hospital?
A: No. I myself wasn't in Wuerzburg.
Q: You assume, don't you, that inmates were used?
A: No, no concentration camp was located in Wuerzburg or in the vicinity, and this hospital was located in the area of the university clinics.
Q: You believe then that no inmates were used?
A: Yes, I believe that.
Q: Who carried out the actual construction of the other two hospitals in the occupied territory in Finland and in Russia?
A: Well, I worked out the basic plans. The construction work in Finland was carried out by combat engineer untis, and in Russia, as far as I know, the same thing applied.
Q: In Dnjepropetrowsk?
A: Yes, in Dnjepropetrowsk.
Q: Referring to your field of task in C-II/1, food and clothing, you testified yesterday that your task wag to carry out the basic planning for a clothing office of the Waffen-SS, and that this order was given to you in 1942 by Kammler. Was this office ever constructor
A: No.
Q: You heard, did you not, about the so-called "A" projects under Kammler, A-1, A-2, and A-3, underground building projects?
A: I have heard of it only here in the course of this trial.
Q: You never heard of it before?
A: I never heard anything about this code name before.
Q: Did you hear about the "B" projects, the surface building projects under Kammler?
A: No.
Q: Did you ever hear about it?
A: No.
Q: You didn't see it in the documents.
A: No, I never saw it.
Q: Did you hear about the "S" projects, S-3 at Ohrdruff?
A: No, that also was completely unknown to me.
Q Did you hear about the V-weapon projects under Kammler at Dora, V-2 weapons, at Laura?
A No, both these code names were also unknown to me.
Q Did you hear about any of the armament conferences that officials in the WVHA had with Schreiber?
A No, it is completely unknown to me.
Q Did you hear about the carbine production at Buchenwald concentration camp?
A That Carbines were produced there I have seen here from the documents?
Q And you didn't know about it before you saw it in the documents in this case?
A No, I didn't know that.
Q You didn't know that pistols were being produced at Neuengamme concentration camp?
A Pistols at Neuengamme? Yes, as far as I can recall it did come to my knowledge, and I heard about the following incident there. A private architect from Hamburg, as far as I know, had made a contract with the factory, and when afterwards the contract by the architect was to be carried out some difficulties arose. This architect turned to me, and he requested me to give him my expert opinion so that he would be able to receive his pay. As far as I know I heard on this occasion that this was a contract between an architect, Hoeger, or a name of that sort, and the Walther Works which produced pistols.
Q He consulted you because under your supervision was a main section called arms and ammunition, is that correct?
A No, he turned to Dr. Kammler, and Dr. Kammler turned the matter over to me. That was in the Department ZV. That was legal in connection with construction matters.
Q: Kammler considered you an expert on arms and ammunition installations, didn't he?
A: He certainly did not. The reason is that I was not an expert.
Q: Why did he have an office under you, the only office in Amtsgruppe C which dealt with arms and ammunition? Why did he have this office under you?
A: I couldn't say. Dr. Kammler did that without notifying me or without asking my assistance, and he listed it in this way in his organizational chart.
Q: Well, it is true, isn't it, that Kammler consulted you very frequently on his arms and ammunition program?
A: Dr. Kammler did not inform me and did not ask my advice in any matter at all in his arms and ammunition program.
Q: Are you telling us that you never talked to Kammler about his munitions program?
A: No.
Q: No, you are not telling us that, or no, you didn't talk to him?
A: No, I answered the question with no, I didn't discuss the matter with him.
Q: Now this ZV or special task office under you was called general affairs relating to the building inspectorate, and you told us that this dealt with police matters, policing the buildings. It is true, isn't it, that it was the task of this office to make inspections after buildings were erected to see if they had complied with the local regulations, the county regulations, that you told us about yesterday?
A: No, this conception is completely wrong. These were fundamental building police matters. These were legal matters devoted to the construction in the area where the construction took place. I at the top level had nothing to do with construction - police certificate
Q: And the officials in this office never made any trips to inspect a building after it had actually been constructed, is that right?
A: That should be correct. I cannot recall a single instance that the only expert that was in this department, that was Obersturmfuehrer Fun* should ever have taken a trip in order to handle any police or construction legal matters in a building.
Q: You told us that Kammler insisted on personally signing all of the plans, personally approving the sketches of the construction inspectorate. Do you know whether or not he consulted with anyone before he approved these plans, did he have any discussions at all?
A: As far as my plans were concerned he only discussed them with me. I don't have any further knowledge on that.
Q: You told us he kept a very tight control, very tight personal control over Amtsgruppe C, is that right?
A: He could not carry out a personal control over Amtsgruppe C because he was absent from Berlin very frequently.
Q: Before he was absent? He started to be absent in 1943, you told us, when he moved his office out of Berlin. Prior to that time you told us that he insisted on doing everything himself.
A: Even up to the end he insisted on personally issuing all permissions and making all fundamental decisions, even after 1943.
Q: Then you said in 1943 when he move his office that he lost contact with Amtsgruppe C, is that right?
A: Well, his contact became very loose, yes.
Q: And that meant that his deputies, and at a certain time you were his deputy, had a good deal more responsibility and control over the office, didn't it?
A. I must correct that I never carried out any business as a deputy of Dr. Kammler. That was put on paper while he was away on leave, but at the time I was sick and I was unable to carry out any deputizing for him.
Q. Well, let me ask you the previous question, worded a bit differently. Since Kammler lost contact with C it is true, isn't it, that his deputy--whoever the deputy was--carried out most of the functions that Kammler had thereto performed?
A. No, that is not correct. Dr. Kammler himself took care of all his official business up to the end. The deputy only had a very limited authority in that respect, and I have described that already before.
Q. Then it is not true that Kammler lost touch with Amtsgruppe C, is it?
A. He certainly was not negligent. He maintained his contact to the best of his ability. I have already stated that the knowledge was the purpose of the discussion of the departmental specialists.
Q. Now, concerning the documents in Document Book No. 20 which you discussed, concerning the destruction of the Warsaw Ghetto, you realize, do you not, that this covered the exact period when you were Kammler's deputy? The first document which was signed by Kammler as chief of Amtsgruppe C was on the 6th of September, 1943--No, I am sorry, it is the 29th of September, 1943. And then there are five subsequent reports--four subsequent reports, five in all; the last one on the 29th of July, 1944, that Kammler was supervising the destruction of the Warsaw Ghetto at the same time that you were his deputy. Do you want us to believe that you knew nothing whatsoever of the activities that Kammler was carrying out in this respect?
A. I don't want to tell you that, but that is actually the truth. That is the way it was.
Q. You had no discussions whatsoever about this? You saw no correspondence about it?
A. No, I did not discuss this matter with Kammler, nor did I discuss it with anybody else. I only heard of the destruction of the Warsaw Ghetto and the removal of the debris here in the course of this trial.
Q. And this is the first time that you heard that this was carried out by Amtsgruppe C?
A. That is the only time that I could see a connection between Amtsgruppe C in any connection with this action. That was the only time I observed that.
JUDGE MUSMANNO: Mr. Robbins, did I understand you to say he did not know of the Warsaw action until he got to Nurnberg? Didn't know of it at all?
MR. ROBBINS: That is the way I understood the witness. (To the witness) Is that correct?
WITNESS: Yes, that is correct.
JUDGE MUSMANNO: It was in the newspapers, wasn't it?
WITNESS: No, I don't believe that anything was reported in the newspapers about this action because I cannot remember it.
BY MR. ROBBINS:
Q. You didn't see it in the newspapers? Is that what you are telling us?
A. I personally am of the opinion that only on one occasion a military action in the city of Warsaw was mentioned. However, that was not in 1943, but took place at a time when the Russians were already outside the gates of Warsaw. Therefore, that must have happened at the end of 1944. Reports were published then about an uprising at Warsaw which was eliminated by military force.
Q. But you didn't hear or read about an action in 1943 or the first part of 1944?
A. No, that action was completely unknown to me.
Q. I just have one question on this complex. Is it your contention, and you are testifying here under oath, that you never dealt with or saw or heard of any plan or any building or construction, any sketch or blueprint, or any building or construction of any kind in any concentration camp?
A. Yes, as far as I know, I never designed any sketch for a concentration camp.
Q. Did you ever see a sketch or did you ever discuss a sketch or a plan or a blueprint or a framework?
A. I can't recall that. I don't know in what connection that would have taken place.
Q. Well, you would remember it if you had done it, wouldn't you?
A. Yes, I would have to assume that I would have to recall it.
Q. And so it is your testimony that you had nothing whatever to do with any sketched or plans or blueprints or any kind of construction or building whatever that was eventually to be carried out in a concentration camp?
A. Yes, I cannot recall a single instance, and I cannot recall at all that on some occasion or somehow this should have taken place in my office.
Q. And this was never discussed in any of the Saturday meetings of the office chiefs? Never talked about any plans, any construction, the use of inmate labor in these weekly meetings.
A. No, in the conferences which I attended, as far as I believe and that I can remember with certainty-concrete construction matters and local construction matters were never discussed.
Q. The words "concentration camp" or "inmates" were never even mentioned?
A. No.
Q. I only have about five more minutes.. . I think I can finish.
How long did you work under Kammler, witness, before entering the WVHA?
A. From the first of September 1936 until approximately May or June of 1940.
Q. And then you worked for him from 1936 until the end of the war. He saw to it hat you joined him in the WVHA when he was transferred?
A. Yes, he personally told me that he initiated my transfer from the army to the Waffen-SS.
Q. He must have had a very high regard for your ability. Is that true?
A. Well, I don't want to say so myself--but it is quite possible.
Q. But still he didn't ever discuss the most important things that he was working on, namely, his munition program, with you?
A. He never discussed it with me, and in this connection I would like to say that the personal relationship between Kammler and myself was quite tense for a while. We were not friends even when we were together in the Luftwaffe.
Q. Witness, you knew, didn't you, that he was making efforts to obtain your transfer to the Waffen SS, and you had asked him to make those efforts?
A. I did not see Dr. Kammler since 1940, when he left the Reich Air Ministry and I saw him again when I reported to him.
Q. Didn't you tell him that you didn't want to go into the army, and that you thought you could get a higher rank in the Waffen-SS?
A. No. I just told you I didn't speak to Kammler during that entire period of time.
Q. When you heard that you were being transferred to the Waffen-SS, you didn't make any objections or make any efforts to prevent that transfer?
A. In my opinion I was unable to do that.
Q. You didn't tell anyone that you had already been called up as a lieutenant in the Luftwaffe?
A. I was not a lieutenant in the Luftwaffe.
Q. You told us yesterday that you had already been called up. Was it by the army or was it by the Luftwaffe?
A. I had been called up by the army.
Q. You didn't tell anyone that you already had been called up by the army, and that, therefore, you shouldn't be transferred to the Waffen-SS?
A. I only discussed the whole matter with my wife. I hardly believe that there was any reason for me to discuss this matter with any other persons.
Q. You didn't have any objection to your transfer to the Waffen-SS, did you? You were quite pleased with it?
A. I didn't care whether I was to be transferred to the Waffen-SS. However, when I heard that I was to be transferred to a construction agency of the Wehrmacht, I was very much in agreement with that.
Q. As a matter of fact, you wanted to be transferred to the Waffen-SS, didn't you? So you could carry out your career as an engineer rather than being taken into the army?
A. No, I didn't even think about the matter at the time. If the army had come first, or if Mr. Kammler had not had his influence, I would have remained with the army, and I would have been assigned to some unit or other.
Q. Well, when you received your orders to be transferred to the Waffen-SS, you received them as an SS-man, did you not?