I don't know of anything else.
Q. Do you know that this branch office worked on the heating facilities of the camp, and water supply facilities?
A. Yes.
Q. Now, you also said that there was an office for judging and evaluating properties, real estate, that you were the real estate appraiser.
Q. Yes, there was such a small department there, and it had a collaborator also.
Q. Now, I am asking you if you at any time ever appraised or valued property that was to be purchased as a concentration camp, or in connection with any concentration camp?
Q. I cannot recall of any such case.
Q. Well, would you remember it if it happened? You say that it did not happen?
A. According to my opinion there was no such incident. In any case, I cannot recall any such incident.
Q. But you were the real estate expert there in the office. Why was it that you were asked about everything but about concentration camps?
A. I was not the expert for property. I stated in my affidavit explicitly that once in a while I carried out evaluations or appraisers, if my collaborator was not sufficient for all those tasks, because that man was over sixty years of age, and perhaps he went on a trip just once every two months, or something like that.
Q. What office in the WVHA carried out this work?
A. I don't know that. I don't know who did that.
Q. And you have told us yesterday in Main Department 2, your Office C-VI, that this department issued directives and compiled instructions.
This is your testimony yesterday there?
A. Yes.
Q. Do you recall how large heating plants should be operated, and how the electric -- I withdraw that question. I think it was answered earlier. I want to ask you if Office C, Office Group C, carried out any construction for Amtsgruppe W, W for "William"?
A. W? Well, I really can't recall any incident. Of course, I can't tell you just by heart, but as far as I saw from the documents, "W", and particularly the two "W's", first "W" offices, had their own construction administration, and what other things were constructed for "W" I don't know. I don't have any connection with offices "W", or with their construction departments in that respect.
Q. Your answer is you don't know?
A. No, I don't know; I can't tell you.
Q. Did Amtsgruppe C carry out any construction for Amtsgruppe A in any way, for their office buildings or any other buildings that they may have had?
A. For Amtsgruppe A? No. If they built anything they probably built it for the WVHA, but according to my knowledge Amtsgruppe A had no special construction projects of their own. I couldn't tell you anything about it authentically, however.
Q. They had buildings, and they had to evacuate and reconstruct buildings, and wasn't this done by Amtsgruppe C?
A. That was for the whole of the WVHA, but not for the Amtsgruppe.
Q. Did they carry out any construction whatever, that is Amtsgruppe C, for Amtsgruppe B?
A. Well, I assume that they carried out a few things for the clothing department.
Q. That is what I am asking.
A. But as I said, I can't give you an authentic report on that.
Q. You assume that is true?
A. Well, I can't give you any authentic reports on that, and I don't have any reasons to believe so. It is just an assumption on my part. I don't know to what extent they worked on the various clothing departments there, and at what period of time, and if Amtsgruppe C did anything, I don't know.
Q. Will you tell us if there were any points of contact whatever between your office and Amtsgruppe A?
A. I had nothing to do with Amtsgruppe A, apart from the fact that my files were with Amtsgruppe A. I can't recall any other contact with Amtsgruppe A.
Q. What do you mean, your files were with Amtsgruppe A?
A. I mean my personnel file, 201 file, let us say.
Q. Did you have any conversations with anyone at Amtsgruppe A?
A. No, I can't recall of any such incident.
Q. Were there any points of contact between your office or your subordinates and Amtsgruppe B?
A. No, it applies to that, I had nothing to do with Amtsgruppe D. I had no contacts with them.
Q. B?
A. Yes, B.
Q. You had no contacts either directly or indirectly?
A. No, I can't recall any connection, any relationship in that connection. I don't believe we had any contacts with that agency.
Q. And that is true for the entire Amtsgruppe C, that there were no contacts at all?
A. I can't give you any information whatsoever on that, because I don't know the activities of the other offices of Amtsgruppe C or I don't know it in sufficient extent.
Q. You told us all of the points of contact that your office had with Amtsgruppe D?
A. I didn't quite understand that question. Would you repeat, please?
Q. Are there any points of contact between your office and Amtsgruppe D, either directly or indirectly that you haven't told us about?
A. I didn't say anything about the contacts of Amtsgruppe D. In certain instances maybe I did have contents, namely, that Amtsgruppe D possibly channeled certain construction matters to me about any of the concentration camps, but I had no other connection with Amtsgruppe D.
Q. That is the extent of it, what you just told us, nothing else?
A. No, I had nothing further to do with Amtsgruppe D.
Q. And what about Amtsgruppe W, any contacts directly or indirectly between your office or your Office Group with W?
A. With W? Well, I can't recall any contacts with W for "William." I saw from a document here that he mentioned somewhere in "W" about the works in Linz, but I don't know what in the world I am supposed to have done with them. I don't know how my name came on the list, and it is not clear at all at the moment.
Q. Did you have any conversations at that time about rates?
A. No, I can't recall that. No, I can't recall the whole incident.
Q. Did you ever have any conversations with anyone in "W"?
A. Not of an official nature.
THE PRESIDENT: Recess.
THE MARSHAL: The Tribunal is in recess until 1345.
(A recess was taken until 1345 hours.)
THE MARSHAL: Take your seats, please. The Tribunal is again in session.
BY MR. ROBBINS:
Q. Witness, I at one point asked you one question about document NO 1292, which is in Document Book III. This is the letter that Kiefer discussed. Did you receive copy of this when it was circulated? It is Exhibit No. 56, Your Honor, found on page 46 of the English and page 51 of the German. It is written in Kammler's handwriting, I believe, to circulate, at the bottom of the letter?
A. It is addressed to Office Group-W for circulation. I cannot recall that document.
Q. It also circulated in Amtsgruppe-C, did it not. Kiefer told us of that yesterday, or day before yesterday. You don't remember having seen this letter in that office?
A. No, no, I don't think that this letter reached me.
Q. Do you exclude the possibility that you saw it, or just don't remember seeing it?
A. I had nothing to do with the other occasion of sending to Office Group-W for information. I cannot recall it, of any such occurrence.
Q. I would like to ask you now a question about the basic plan of Amtsgruppe-C, which is document NO 1288. I think you have it before you. It is Exhibit No. 44 of page 76 of the English and in Document Book II. Will you give this to the interpreter.
A. No, I have not got the document.
Q. I thought that was the document you borrowed from Kiefer, is that true?
A. No, that is only C-6.
Q. Will you turn to Division C-1, General Construction Tasks, and look at it.
Look at C-1-1, C-1-2, C-1-3, and C-1-4 and tell us what connection this office had with the concentration camps?
A. This document shows the field of tasks of Office C-1, but I cannot reach any conclusion as to how connections existed with the concentration camps. I never knew anything about Office C-1.
Q. Witness, you told us yesterday that you knew that Office C-1-2 built concentration camps to carry on the main construction work. Do you wish to change that testimony?
A. I cannot recall having made that statement, but the organizational chart shows that the construction of concentration camps and prisoner-of-war camps is listed here. I do not know any more. I had no connection with C-1.
Q. You knew at the time you were in Amtsgruppe C that c-1-2carried out construction in the concentration camps, didn't you?
A. All I knew was what the organizational chart showed me. I cannot recall the chart now -- whether I received it at the time -- but I didn't know anything beyond that.
Q. And you never talked to anybody? You didn't ask anybody: "What do our associates in C-1-2 do?" You didn't have any interest to find out whether C-1-2 carried out the purpose listed in the table of organization? You didn't talk to anybody about that?
A. No; I had no cause to do that.
BY THE PRESIDENT:
Q. Were your offices all together? The different divisions of Amt C?
A. Until 1944 we were together. After -- I was ill from May -I was no longer together with the other offices, I pointed out that I never entered Office C-1.
Q. Well, as long as you were there, the offices of the different "C" divisions were together; same building?
A. That was a very large building, Mr. President. You met at lunch but otherwise you didn't come across each other -
Q. Just answer my question. You were in the same building?
A. Yes, indeed.
Q. C-1,2,3, and 4?
A. Until Spring, 1943, we were together in one large building.
Q. That is when you were taken ill?
A. First we had this heavy air-raid in March when some offices moved away, and then in May I fell ill --- after which I had no contact with it at all. When I returned I had already been evacuated.
Q. Were you on the same floor of the building?
A. The agencies were on four floors, Mr. President.
Q. No, no. I am just talking about Amt C-1.
A. I am unable to say with certainty whether we were on the same floor, or different floors.
Q. Why are you unable to say?
A. Mr. President, these agencies moved from one place to another so often in this last building that it was quite impossible to remember where C-1 was -- at least to speak about it on oath, with any certainty.
Q. Well, didn't they keep the same departments of C-1 together.
A. I assume so, Mr. President. This table of organization is enormous.
Q. Now, wait a minute. It isn't so enormous because I am just talking about C-1 --- 1, 2, 3, and 4. And you have been telling us how few people you had in those offices, so it was not enormous at all. Were those four offices on the same floor of the same building?
A. You mean Office C-1, Your Honor.
Q. C-1, -2, -3, and -4.
A. As I remember it, they were together, because it was a very small office and one always comes across the same people on this organizational chart.
Q. All right. A long time ago you could have answered me, Yes, that those four offices were together on the same floor of the same building. Isn't that true?
A. I assume so. I cannot say with certainty whether one room or two, perhaps, were somewhere else because the department consisted of several rooms, and in this very large building we were placed all over the building. We were not immediately connected with one another.
Q. Well, there is no doubt they were on the same floor, is there?
A. I am unable to say that with certainty, Your Honor.
Q. You just did say it. Were they near each other?
A. We were in a fairly large building, and the various offices, from 1 to 6, were distributed over four floors. Where the single rooms were located, I am unable to say.
Q. Well, at any rate, I have got you in the same building. You were all in Berlin, were you?
A. Yes, Your Honor.
Q. And you were all in the same building?
A. Yes, Your Honor.
Q. Well, I guess that is as far as I can go.
BY MR. ROBBINS:
Q. And you told us yesterday that every Saturday Kammler had meetings of all the office chiefs, and you said that the purpose of these meetings was so that Kammler wouldn't lose touch with his office chiefs. And you also told us that each of them made a report of each meeting. Now, at none of those meetings, are you telling us, the purpose of this office was not discussed, the functions of it, what they did?
A. I never said anything about a record. No record was kept throughout this period.
Q. I think you must have misunderstood me. At any of these meetings of the office chiefs of Office C, do you wish to tell us that the purpose of Office C-1, the functions, the tasks, were never discussed?
A. I cannot recall any such occurrence. I don't know it.
Q. But you stick to the statement that these conferences were to keep Kammler informed of the progress of the offices?
A. May I point out one thing: After 1943 the chief of Office 1, after Karl, were in charge of Obersturmbannfuehrer Rall. He usually was not present when these meetings were held of the office chiefs.
I can recall only one or two or, at the most, three cases when Rall was present.
Q. Do you remember being interrogated on the 21st of December, 1946?
A. Yes, I recall that.
Q. And do you remember saying there under oath that at any typical meeting Kammler had every one of the six or eight persons present make a short report on some current matter for the purpose of keeping informed on what was being done by the section heads? Do you remember making that statement?
A. Whether I made that statement exactly in that manner, I do not recall. But I said -- and it is also contained in my affidavit -- that the participants reported and official notice was taken; the whole thing was for purely informative purposes. Details of these conferences I really cannot remember. I was not too interested, and when reports were made they were without any context so that the individual participant could not form an impression of these things.
Q. Do you wish to tell us that the chief of C-1 never attended any of these meetings?
A. I cannot recall any such occasion. I said he might have been there once, twice, or three times; but whether he reported anything is beyond me. I don't recall it.
Q. Will you look at Division C-2 and tell us if this division had any contact either directly or indirectly with concentration camps?
A. There again this goes beyond my knowledge. I know nothing beyond what the table of organization shows.
Q. As far as you know, it may have had something to do with concentration camps; you cannot say that it had nothing to do with concentration camps?
A. According to the organizational chart and its designations below the Main Departments, it cannot have anything to do with concen tration camps.
Q. Will you take a look at C-3? Will you tell us what contacts this branch had with the concentration camps? This concerned engineering, building, irrigation and drainage, engineering and electrical engineering, and survey.
A. The possibility exists ---
Q. But you can't say what that connection was?
A. No, I am unable to make any statements. I had no point of contact with C.3.
Q. What about C-4? Did it have any contact with the concentration camp?
A. I don't believe so because anything connected with artistic matters will hardly touch on concentration camps.
Q. And C-5? This is construction supervision, budget and cost of construction, construction allocation of labor ... Does this have anything to do with concentration camps?
A. Whether it was connected with concentration camps directly I cannot see from the chart. The department C-5-4-B, it says, "Inmates and building brigade." There must have been some kind of contact.
Q. This is the first time you ever saw that?
A. What did you assume that this meant when you saw it in your office?
A. If you please, Sir, I do not know whether I looked at these masses of paper which came from Kammler; unless I am very much mistaken, I took the whole document and put it right at the bottom of my drawer, because it was simply superfluous paper.
Q. And it is your belief, is it-- it is your statement is it, that you never looked at the whole plan for Amtsgruppe C?
A. I don't believe I did, I only looked at my Main Department or my office.
Q. Now, will you look at the last part of the document, Construction Inspectorates. Tell us what this was and where it fitted into the rest of the organization. Is this under your office? It comes right after C-VI. You see?
A. Directly behind my office?
Q. Yes.
A. You mean page 39?
Q. Page 36 of the original, the very last part of the document.
A. 39 of the German text?
Q. It must be on about page 104 of the German text. Is this a part of your office?
A. This is my main Department C-VI/3, my Auditing Department and that Auditing Department within my agency has been distributed to the various fields so that people knew to what spheres they were responsible. I would like to point out that distribution actually was never translated into practice and never had anything to do actually with the building inspectorates.
Q. Well, did you draw up this part of the chart that deals with C-VI?
A. Yes, I drew that up.
Q. Didn't you have any interest to see that Kammler -whether Kammler supported your proposal in the final table of organization or departed from it?
A. I know nothing of proposals.
Q. You said that you never had seen the organizational chart. I am asking you after you drew up this part of the plan, didn't you have any interest to see if Kammler approved it?
A. Mr. Prosecutor, as I remember I was asked by Kammler at that time to organize my office in such a way as we see it here now. It may well be that this proposal was passed on to me by Kammler's office and I merely added the people to it. In actual effect, this plan was never translated into practice in this form for my office, because the people mentioned thereon -
Q. Whether or not it was translated into practice, it was approved by Kammler. I am asking you if you still stand on your statement that you never saw this document in the office, never read it?
A. I said before that I assume that I studied everything that concerned my office, but the other offices didn't interest me at all.
Q. Now I want to ask you about the procedure when requests were submitted to you through Office C-VI/1 for funds to carry out maintenance in the concentration camps. You told the court yesterday that this was submitted in a lump sum and was not broken down. I am asking you if it wasn't true that in many instances these figures were broken down and requests were made for maintenance of a concentration camp wall and so forth. Isn't true that the requisition or request from the concentration camp sometimes, if not always, showed the purpose for which the money was to be used?
A. I cannot recall anything of the sort. The things which came in had been broken down first. I don't exclude the possibility, but speaking generally allocations were made in the form of lump sums.
Q. Don't you remember at any time getting a requisition during the course of the year, not for the yearly period, by supplemental requests for funds for construction in camps that showed what the purpose of the funds were to be used for?
A. I cannot recall any detail there. It is, of course, possible that some agencies submitted a single individual request and not ask for any credit allocation, but, as I mentioned before, requests of this sort were no longer necessary, because the agencies themselves were quite competent to do it on their own.
Q. Witness, except for the early period when you were visiting Dachau, I believe you said '36, '37, is that the only time you ever visited Dachau concentration camp?
A. I do not remember that after that time I went to Dachau concentration camp. I went, of course, quite often to the garrison office of Dachau, but that had nothing to do with the concentration camp. It was completely separate from it.
Q. When you went to the garrison you saw inmates working, did you not, outside the main part of the camp?
A. Yes, sometimes I saw them.
Q. And how many times did you visit the concentration camp at Sachsenhausen?
A. I said before I went to the Commandant's office quite often for personal reasons, but the actual concentration camp, Sachsenhausen, the protective custody camp, I never visited once.
Q. When you visited the Commandant's office you saw the inmates working outside the camp, didn't you?
A. I did not notice people doing my work. I don't think work was done; in the office perhaps I saw them in the office.
Q. You didn't see any on outside work details around Sachsenhausen Camp, the outer camp?
A. Outside? Oh yes. In the whole area Oranienburg I saw inmates working. I said so before.
Q. And Buchenwald -- how many times did you visit that camp?
A. The concentration camp I did not visit. Again I went to the Commandant's office and I believe I said before I visited a friend of mine who was with an anti-aircraft unit in Buchenwald. I did not enter the actual concentration camp.
Q. Is that the only time you ever went to Buchenwald?
A. I don't recall another visit.
Q. What date was that?
A. I believe that was in 1940 or 1941.
Q. You saw inmates working there when you visited?
A. I believe so.
Q. How often did you visit Flossenburg concentration camp?
A. I never visited Flossenbuerg.
Q. Were you ever in the area, in the outer part of the camp?
A. I don't recall anything of the sort.
Q. Are you certain, or are you saying you just don't remember?
A. I don't believe that I went to Flossenbuerg ever.
Q. How many times did you visit the camp at Ravensbrueck?
A. I didn't visit the concentration camp itself. I believe I once went to the clothing depot on which occasion I talked to Bester the construction manager. That is at least how I remember it. I might also have spoken to his successor.
Q. You told us this morning that you were there several times. Didn't you talk to Bester only once?
A. I don't believe so. I, of course, made many trips. Whether I went there frequently or not I am unable to say today.
Q. You saw inmates when you went there? You saw them working?
A. I cannot recall anything -- whether I saw anybody in the outside camp.
Q. Did you ever visit Mauthausen?
A. No, I never inspected Mauthausen.
Q. Were you ever there in the outer area of the camp?
A. I once went to Linz.
Q. But you said this morning you had no interest whatever in Linz.
A. I went to Linz once, I believe, in 1942, because of the bills of the Death Head Unit barracks there and that barrack was no longer used by the Death Head Units, but it was sold later to the Reichsbank.
Q. Witness, when you made the visits to these camps that we have been talking about you usually went on business, didn't you, that had something to do with your office affairs?
A. Yes.
Q. How often did you visit Auschwitz?
A. I went to Auschwitz once, as I said in my affidavit.
Q. That's the only time?
A. Yes.
Q. And what date was that?
A. I mentioned this yesterday. I am not quite clear if it was in 1943 or 1944.
Q. And what was your business in Auschwitz?
A. I had to look into the land business of the bakers shop and with the large armament plant.
Q. You saw inmates working when you were there?
A. I am not sure about the armament plant. Women were there who were all wearing long gray overcoats, so-called overalls. Whether they were inmates I am unable to say with certainty. One could not see from their appearance whether they were or not.
Q. You didn't see any inmates at all, anybody that you could be sure was an inmate, when you were in Auschwitz?
A. When I was there I do not remember that in the outside area inmates were working. The two plants were on the fringes of the whole complex.
Q. Did you see anyone in inmate clothing around Auschwitz, anyone that you assumed to be an inmate?
A. I don't recall any such occurrence.
Q. How often did you visit Neuengamme?
A. I was never in Neuengamme.
Q. Were you ever in the area; I mean the outer camp?
A. No, I don't remember having been there.
Q. What about Stutthof? How many times were you there?
A. I never went to stutthof.
Q. Did you ever visit Natzweiler?
A. No.
Q. Gross-Rosen?
A. No.
Q. Did you ever visit the camps or labor camps at Lublin?
A. No, I don't recall doing so.
Q. Did you ever go to Lublin?
A. I went to Lublin once, yes. With the garrison administration there we were discussing construction matters for the Waffen SS, the troops. This was in 1940 or 1941.
Q. You didn't see any inmate labor when you were there, laborers?
A. No, I didn't see anything of the sort.
Q. Did you ever visit Nordhausen?
A. No, I heard that name here for the first time.
Q. Did you ever go to Bergen-Belsen?
A. No.
Q. You knew, didn't you, Witness, from having seen these inmate laborers that there were a good many foreigners among them, non-Germans?
A. I had no opportunity for making such discoveries.
Q. You had no idea that any of these inmates that you saw were nonGermans? It never occurred to you?
A. You could not see by their appearance that they were non-Germans, and I did not talk to them.
THE PRESIDENT: Did they all look like Germans?
A. Their appearance, yes.
BY MR. ROBBINS:
Q. Did you know from any other source that foreigners were in the concentration camps, non-German nationals?
A. I did not work on the concentration camp problems nor on the inmates. I therefore took no interest in what sort of inmates would be in concentration camps.
Q. I don't mean just from official sources; I mean from the newspapers and from private conversations. You had no information whatsoever that there were any non-German nationals in German concentration camps?
A. No, I knew nothing about it.
Q. You didn't know that Jews were in concentration camps?
A. I assume that Jews were in concentration camps, but they were subject to the same laws when they had offended politically or against the laws of the state. I was unable to reach any other conclusions.
Q. You thought they were all German Jews? Is that right?
A. I mentioned before that I did not look at them so carefully. I wasn't interested.
Q. Did you know that prisoners of war were in concentration camps?
A. No, I did not know that.
Q. You knew, did you not, that the construction that was carried out by Amtsgruppe C in the concentration camps used inmate labor?
A. I was in a position to assume that, Yes.
Q. You knew that the industries in Amtsgruppe W used inmate labor?
A. I was not informed about that, as to what type of labor was used for their enterprises.
Q. You want us to believe that you did not know that Amtsgruppe W used concentration camp labor? Where did you think these industries were located? Didn't you know from the organization plan that they were located right in the concentration camps? You didn't know that?
Q. I could reach that assumption but I did not know anything about the allocation of inmate labor.
BY THE PRESIDENT: EXAMINATION
Q. That isn't what the question was; and you told us plainly yesterday that you did know that the W industries used prison labor, used concentration camp labor.
A. If your Honor please, I believe what I said was that Office Group C used labor, inmate labor; but I do not remember saying one word about W yesterday. W was not mentioned before.
Q. Do you remember Mr. Robbins asking you the same question--you knew that the industries were located right in the concentration camps? Don't you remember that?
A. I am afraid I didn't understand the question, your Honor.
Q. Yesterday Mr. Robbins asked you, didn't you know that many of the W industries were located right in the concentration camps? And you said, "Yes," didn't you?
MR. ROBBINS: I'm afraid, sir, that was the witness Kiefer.
THE PRESIDENT: Well, I remember the question. Was it another witness?
MR. ROBBINS: Yes, I believe it was.
THE PRESIDENT: For the first time in my life I'm wrong.