A I told you yesterday that the Amtsgruppe Chief was responsible for that, because he signed those things. After all, I don't have the right to control him all the time, and tell him that this and that is wrong. As far as Amtsgruppen A, B, and C were concerned, I was assigned to help them directly, but it did not apply to D, Mr. Prosecutor.
Q But from your technical knowledge and from the papers in your office, you could have, if you had wanted to, found out the normal needs of Amtsgruppe D in the items of motor maintenance, couldn't you?
A I told you yesterday that those were supply trucks, of Amtsgruppe D. As far as we could, we helped them. As far as I could see, I knew that they had to supply the camps. That is why we had to see to it that they were always in good maintenance. This does not mean that I had to look after it personally, but the technical leader in Amtsgruppe D had to see to it.
Q But the papers existed in your office where you could have informed yourself of the normal needs for Amtsgruppe D in the items of fuel, tires, spare parts, etc., didn't they?
A Yes, indeed, of course.
Q Now, you could have thus learned, if you had so desired, since you could have found out the normal needs of Amtsgruppe D, you could have also learned what work the concentration camps performed for the Reich, couldn't you?
A You see, those request slips were not quite detailed. They were consolidated for Amtsgruppe D for so and so many vehicles. You are getting the whole thing out of context, Mr. Prosecutor. If I take everything and if I know everything about the concentration camps and if I am present in every conference, then I would be able to answer your question up to 100 per cent. Unfortunately, now I can not tell you anything because 90% of all the answers you want me to give you, I can't give.
Court No. II, Case No. 4.
Q If you had wanted to, you could have learned in general terms what type of work the concentration camps were doing from these papers in your office, couldn't you?
A No, I could not have done that. It is absolutely impossible.
Q Well, if these facts were known to you, it would follow that you would have some knowledge of the part that your office B-V had, either directly or indirectly, in the WVHA concentration camp system, would it not?
A If that had been known to me, but it was not known to me.
Q Did requisitions for the items of motor maintenance that we are speaking of this morning come to your office from Division W?
A Generally speaking, no. Amtsgruppe W had a few SS vehicles which had been assigned to them by the Operational Main Office. They were reported to us, indeed. However, what purposes they served I could not tell you. The way I think it was, was that those vehicles had only an SS registration number so that they could be driven during the war. In other words, I would like to assume that they were the property of various firms.
Q Did requisitions for motor transports or rail transports come to your office from Division W?
A Neither for truck transports nor for rail transports. They were private firms, as far as I was concerned, and I could not possibly put any government property at their disposal for transportation, because they would have had to pay for it. In other words, they simply had to apply to the railroad transports.
Q Now, did I understand you to say that you do not remember consolidating any requests from Division W for such things as fuel, oil, tires, and spare parts?
A The Operational Main Office had a small monthly quote of fuel for the economic enterprises, a small amount for the various economic industries. It amounted to probably 500 to 600 liters of gasoline. Now, when I established the office, it worked that way already. They Court No. II, Case No. 4.would run and see Obergruppenfuehrer Pohl, and I really could not tell you what the background was about it at all, because I don't know anything about it.
Q Wasn't it a little strange, where transportation got very soon to be a critical item, that you had to consolidate a few requests, even from firms that you considered as private firms? Why did you not suggest that these firms apply to the civilian ministry in control of such items?
A Mr. Prosecutor, I can tell you the following: There was no greater opponent of the economic enterprises with the WVHA than I was, not because I knew the work of those economic enterprises, but simply because I looked upon them as private enterprises, and in the WVHA I had to represent the interests of my office.
Q It never occurred to you to question why any private firms were calling upon the WVHA for such items as we are speaking of now?
A I knew that Obergruppenfuehrer Pohl was the chief of those economic enterprises. During my entire activity in the WVHA I did not see any of those firms personally. I do not know of a single enterprise, and I heard about the installations and the machines in the economic enterprises here for the first time. Nobody in the WVHA thought it important to inform me on those things.
Q And you supplied these items in a small way, even, to firms which were known as SS economic enterprises?
A I personally only carried out the order of the Operational Main Office, and I gave them that small amount of fuel per month, and there is no question about material.
Q According to your testimony, all the rifles in your charge, which amounted to some 15,000, were distributed to the guard teams of the concentration camps. Can you explain why this was necessary that they channeled through your office, since Amtsgruppe D was the sole recipient of these weapons?
A I did not quite get that question.
Court No. II, Case No. 4.
Q You testified yesterday that some 15,000 rifles were in your charge.
A I stated the following: Amtsgruppe D--No, I am going to correct myself, the entire WVHA, including Amtsgruppe D, had reported 15,000 rifles. In other words, those 15,000 rifles were contained in our books which we kept by order of the WVHA. The rifles were sent to the concentration camps directly from the WVHA through the Quartermaster Stores already in earlier times.
Q Now, these 15,000 rifles were shown in the books of Office B-V?
A Yes.
Q And after they were distributed, that is, after they were in the hands of those people who actually used them, they came under the supervision of Amtsgruppe D?
A What do you mean, "under the supervision?" How am I to understand that, Mr. Prosecutor?
Q You had them on the books of Office B-V, but the concentration camp guards who used these rifles were under Amtsgruppe D.
A Yes.
Q Therefore, while you carried them on your books, the actual control and supervision of these rifles were under Amtsgruppe D?
A Yes.
Q.- Why wasn't it the logical channel for Amtsgruppe D to make their request for weapons directly to the operational main office since your office apparently had little part in the matter, according to your statement?
A.- It was an order by the operational main office that all requests for weapons which came from WVHA should be consolidated in one office. The operational main office no longer wanted receive all requests from all the agencies of WVHA. As I told you before all those things are stated in the order concerning the establishment of the WVHA.
Q.- After your rather disagreeable experiences with Gluecks, particularly in the matter of weapons, did you ever think of asking for relief from such a disagreeable task concerning these weapons.
A.- Did I do something about it?
Q.- Did you ask to be excused from having anything to do with weapons for concentration camps after your unpleasant experience with Gluecks which you have related?
A.- There was no reason because one has a disagreement to throw everything in their face.
Q.- I believe in your interrogation you relate that you accuse Gluecks of embezzling arms and you came back and reported it to your chief, Loerner; now, don't you feel if Gluecks would embezzle weapons it would be hard for you to assume the responsibility for weapons you knew nothing about?
A.- Yes, that is quite correct. It wasn't quite that way, that I wanted to renounce my responsibility for that. That was my duty and I did so because in this case Amtsgruppe D gypped us. We were gypped by them, but the main office was too.
Q.- You could not ask to be relieved since you could not control these weapons?
A.- After all I didn't have to control the weapons. That is why things continued that way. In one of my documents, for instance, it is stated quite clearly that the control of the weapons in the concentration camp, all the inspections etc, etc.
were carried out by the main office directly and all we had to do was assemble all the reports monthly, and I informed the main office about Amtsgruppe D. It couldn't have been my business to tell the General what was right, but it would have been the business of the main office to stop these things.
Q.- In your interrogation of 24 November 1946 you stated in addition to 15,000 rifles you had about 30 machine guns which you carried on your books; do you wish to amend your direct testimony yesterday to include these machine guns?
A.- Yes, I imagine they were in there.
Q.- From your experience in the WVHA you knew that these weapons would be used in concentration camps, didn't you?
A.- How am I to understand that, would be used?
Q.- You knew that the weapons which went to Amtsgruppe D would in return be redistributed to concentration camp guard teams, did you not?
A.- That the guards had the weapons was known to me, of course.
Q.- And as a reasonable man you could conceive the idea that there was a strong possibility that in the course of time these weapons would be used for extermination in the concentration camps, couldn't you?
A.- Mr. Prosecutor, my opinion about a soldier is to high that I would think a soldier would do such a thing, and never in my life would I have thought that mass extermination or similar things would be carried out with these weapons, because if I would have thought such a thing I would have jumped out of that boat immediately.
Q.- It never occurred to you that these rifles could be used illegally?
A.- Absolutely impossible.
Q.- When Pohl signed this order in July 1942 requiring all arms of all Amtsgruppen D to be reported to you, didn't you interpret that order to give you the necessary authority to enforce it?
A.- Would you repeat the question, please?
Q.- I speak now of the order Pohl signed in 1942 requiring all of the weapons to be reported to you. Did you also interpret this order to give you the necessary authority to demand those reports from all Amtsgruppen?
A.- Of course, because that was the order issued by the operational main office to.
Q.- When Gluecks refused to cooperate in the matter of arms for Amtsgruppe D when you interviewed him, why didn't you report him to Pohl his superior, as well as yours?
A.- It was reported to Pohl through Gruppenfuehrer Loerner. However, I thought it much better to report it also to the Chief of the Operational Main Office by going through Office VII in the operational main office.
Q.- Did your relationship clear up with Gluecks after this incident was reported to the Chief Pohl?
A.- That is something that occurred on one occasion. When it occurred Mr. Prosecutor, I simply couldn't tell you today. I had nothing else to do with Gluecks personally. The reports arrived monthly on special forms, and our activities ceased there, our prints of contact.
Q.- Why was it when arms were furnished by the skyer firm, for example to Amtsgruppe D, these same weapons did not become WVHA property as well as Amtsgrupp D property?
A.- I simply couldn't tell you that, Mr. Prosecutor, I don't know anything about that field of tasks.
Q.- You stated that Gluecks told you that he would get weapons whereever you could find them, and that the Steyer firm supplied you with these weapons; what I want to know is why these weapons that were supplied by the Steyer firm didn't go on your books as part of the weapons which you were keeping an account of?
A.- After all they didn't come from the operational main office. Af ter all I couldn't answer for weapons which came from any place, which did not come through regular channels, and keep them on my books.
That is out of the question and quite impossible with a normal procedure. That was a task of Amtsgruppe D, as before. Is was not my task.
Q.- Did you refuse to take cognizance of anything except the rifles which was directly issued by the operational main office?
A.- Yes, of the ones which were sent by the operational main office in a regular way.
Q.- Even though these weapons were with Gluecks in Amtsgruppe D could not Pohl have ordered them all reported to you as WVHA property?
A.- Yes, maybe he could have given that order. However, I did not receive such an order.
Q.- Witness, I put it to you as a matter of logic; this Tribunal from the evidence in your case could conclude in part at least that you saw to it that the concentration camps had motor equipment with which to work?
A.- Yes.
Q.- That you supplied all the necessary items for maintenance for this equipment, so that the highest efficiency under the circumstances was constantly maintained?
A.- I stated before that one cannot speak of any efficiency in this particular case, for the reason that these vehicles which were in the homeland were old vehicles, they were mostly driven with wood gas. All the vehicles of the WVHA were simply to be looked upon as supply vehicles. No one could possibly speak of a support of industrial enterprises in similar things, or maybe I don't know anything any more about vehicles.
Q.- But you supplied what you could to see that these trucks and cars ran as best they could under the circumstances at that time, didn't you?
A.- According to my orders from the operational main office I did my duty.
Q.- You were concerned chiefly with supplying the means whereby all concentration camp inmates could be liquidated if they failed to work in a satisfactory manner; could not this tribunal so conclude these three facts?
A.- No, it is not quite possible, Mr. Prosecutor, because first of all one has to know about the liquidation of human beings.
Q.- On direct examination yesterday, according to my memory, you categorically denied ever having anything to do with the transport of human beings; however, you knew, did you not, that concentration camp inmates were being transported by rail?
A.- That also was unknown to me.
Q.- Let's get to the example -
THE PRESIDENT: Wait a minute. You did know that were being transported somehow?
A.- Yes, of course, I did. I knew that.
Q.- And how did you think they were being transported?
A.- You mean that the concentration camp inmates were transported? I know those things now, Your Honor. I never dealt with that stuff before, because I didn't have to.
Q.- In 1944 didn't you know inmates were moved from one camp to another?
A.- No, it was not known to me, Your Honor. It really was not known to me.
Q.- You knew they were moved into the camp?
A Even that was not known to me, Your Honor. However, I can imagine that they were transferred to the camps in vehicles. I can imagine it, but I never did have anything to do with it.
Q You don't have to imagine it. They couldn't get into the camps without being transported, could they?
A Would you repeat that, please?
Q The inmates couldn't get into the camps without being transported?
A Of course not, Your Honor.
Q That is very simple, isn't it?
A Yes, of course it is simple, Your Honor.
Q How did you think they got into the camps; how were they transported there?
A Your Honor, I really don't know the extent of the concentration camp inmate transports. I simply can't imagine it. Of course, I do realize that when major transports were carried out they had to be transported by rail.
Q Sure.
A There is no other possibility.
Q That is right. You knew they didn't come in by boat?
A Yes, of course.
Q And they didn't walk?
A That I really couldn't tell you, Your Honor. I don't know. It is only today that I can imagine something about it due to the documents I saw. Prior to that no requests, no requisition slips came to me, nor did I ever see any marches, long columns of inmates who were walking to the concentration camps. Of course I do know that inmates were in the concentration camps and they didn't walk the whole distance, and they were transported, that is correct, yes.
Q Transported in railway cars and wagons?
A Yes, presumably, Your Honor.
Q Or by truck, by motor truck?
A I think that is hardly possible, Your Honor, to have them transported by vehicles, because we didn't have enough fuel in Germany.
THE PRESIDENT: Well, all right.
BY MR. WALTON:
Q Witness, let's consider another example. Suppose that the Operational Main Office or some agency had allotted you railway cars and for a short time you had more railway cars than you needed. Let's suppose further that at this precise time the staff of Amtsgruppe D needed rail transportation for concentration camp inmates and knew that you had these railway cars available. My question is, could Amtsgruppe D then apply to you for the reassignment of these railroad cars?
A It is not thus that the WVHA gave me a certain allocation of space for transportation, but rather we applied for the transport with the Operational Main Office, and the operational office passed on the request to the Army, and the Army passed it on to the railroads, and the railroads placed this space at our disposal. It would have had to go vice versa.
Q You mean to state if you had a surplus of railroad transportation you had to turn it back to the Army rather than loan it out to Amtsgruppe D?
A We didn't have any superfluous wagons, railroad wagons, nor did we have any vehicles.
Q I am not asking you about a fact. I am trying to give you an example, to pose a hypothetical question, that if a surplus of railway space occurred in your office and Amtsgruppe D needed this space and knew that you had such a space available, could they have requested the loan of this space which had already been assigned to you?
A That example is absolutely wrong, Mr. Prosecutor. If I may use one word, it doesn't quite make sense.
It couldn't have been that way. It simply couldn't have been that way. It is absolutely impossible. If you want me to tell you how it could have been, well, I can tell you that clearly.
Q We will skip that for the present. I believe you have stated in previous investigations that the man who handled your transportation matters was an Unterscharfuehrer. Was not his name Stopp?
A It was an Oberscharfuehrer.
Q Oberscharfuehrer Stopp, S-t-o-p-p?
A Yes.
Q Suppose that Stopp had received a request for railway space from Amtsgruppe D for the concentration camp inmates. What would he have done with this; would he have shown it to you?
A Yes, I imagine he would have because it would have been unusual then.
Q Would he have made a report immediately of this or would he have waited until his regular fortnightly period to report it?
A No, in such case he could have come and seen me immediately.
Q Did this ever happen while you were in Office B-V?
A No, I can't recall ever having received a request for inmates.
Q Did it ever happen that Amtsgruppe D requested railway transportation from your office while you were Amt Chief of B-V?
A No, I know of no such case.
Q Did Stopp ever report to you that he had supplied railway transportation to Division W?
A No.
Q Let me refresh your memory. In your interrogation of 2 December, 1946, the question was asked, "Did Division W ever requisition railway carriages through you or through Stopp," and your answer: "I can not say for certain, but I consider it possible. Will you please question Stopp on this point?" Now, which is correct, the interroga tion or the statement you made today that Division W never requested transportation from you?
THE PRESIDENT: No, no, he didn't say that, and your two answers are not contradictory. He says this morning he can not recall any such instance, and that is exactly what he said in the interrogation isn't it?
MR. WALTON: I am sorry, I missed that. I didn't get that translation. I misunderstood it.
THE PRESIDENT: As I got it he said he can not recall any such instance.
MR. WALTON: Thank you, Mr. President, for calling it to my attention. That escaped me.
THE PRESIDENT: All right.
Q (By Mr. Walton): Now, would you say that such a thing was possible, that Division W would call on you for railway space?
A No, I can't quite tell you for sure. That they tried to do so, just as they tried to do it with vehicles - maybe to receive rail transportation - I am quite convinced of that. That they succeeded in doing so, however, is an entirely different question.
Q Didn't you leave a large part of the decision on matters up to your railway expert, Oberscharfuehrer Stopp?
A Here is the way it worked. An Oberscharfuehrer sticks to his orders, and as he came to me from the Operational Main Office, from the rail transportation there, the order of the Operational Main Office was the only ones which was valid for him. The Army rail transportation's regulations had become so severe in the meantime that a deviation was no longer possible, or at least almost impossible.
Q Do you know, or have you learned where Division W got its railroad transportation?
A I couldn't tell you that. At least I couldn't answer that question for quite sure.
They probably requested it with the railroads directly.
Q But you knew they didn't get it from your office?
A Yes, that was known to me.
Q How, from your knowledge, your general knowledge of the WVHA, would you say that it was an efficient organization?
A What do you mean by that?
Q Efficient.
A Mr. Prosecutor, I really can not judge that question because I am not an administrative officer. If you ask me about my field of task then I can give you information, as much as you want, but I simply won't even try to tell you something about the entire WVHA concerning its efficiency.
Q You never did hear that it was an inefficient organization, did you, while you were there?
AAn inefficient organization? Well, I can't judge anything about that either.
Q Everything seemed to you to be working smoothly, in proper order as far as you could tell, is that correct?
A For me it was nothing but an administrational organization for the Army.
Q It looked to you like it was running all right when you saw it last, is that not right?
A Yes.
Q Now, in order to obtain this smooth-running organization, it was necessary for all people in the WVHA to cooperate, wasn't it?
A I assume that. However, they didn't necessarily have to collaborate with me.
Q Did you cooperate with your office chief, Loerner?
A Let me explain to you this whole thing, Mr. Prosecutor.
Q Merely answer the question, did you cooperate with your office chief, Loerner?
A Yes, of course I did.
Q Did you cooperate with the colleague in Amt B?
A How am I to understand that, Mr. Prosecutor? What do you mean by cooperate in this particular sense? Are not our fields of task entirely different? After all what does the transportation have to do with food, unless, of course, they pass a request through our office? I knew, for instance, that Tschentscher was working on food. That there was a cooperation is absolutely sure. After all we were all in the same building, and we simply had to work together.
Q And in order to have this cooperation it was necessary for the office chiefs, such as yourself, to know the task and responsibilities generally of the other office chiefs, wasn't it?
A Yes, the large outlines of their tasks, yes.
Q Outside of the purely secret matters which concerned particular offices, an official of your rank and your position in the WVHA either knew or could find out what activities were being daily carried out in the WVHA, couldn't he?
A No, that is not possible. It is absolutely impossible, because our fields of task were too different from each other.
Q You considered the WVHA an essential organization to the Reich effort, didn't you?
A No, I did not look upon it that way. For me it was nothing but an Army matter, mainly the supply, the administrative supplying of the Army. If you mean the war industries of which I heard for the first time in those documents, I can only tell you there is only one person who can give you information on that, and that is Obergruppenfuehrer Pohl.
Q Wasn't it your ambition while you were in WVHA to perform your task with all the intelligence and efficiency that you had?
A. Well, there are two interpretations of this - that of the ambition and the other one is the normal interpretation of duties. I carried out the orders without any ambition.
Q. Didn't you feel that you deserved your promotion while you were in the WVHA because you had done a good job?
A. Let me explain that, too. Now, if one has an expert and wants to keep that expert - and experts were rather rare in Germany at that time - then I can't hold it against them if they promoted me.
Q. On the other hand having done a good job, having been trained you would have felt badly if Loerner and Pohl had not recognized your work and had failed to promote you, wouldn't you?
A. If Pohl and Loerner hadn't promoted me then the chief of the Operational Main Office would have promoted me. I am quite sure about that.
Q. You do appreciate the fact that they recognized your work and promoted you, don't you?
A. Of course.
Q. Now you have submitted an affidavit in your own behalf by Konrad Morgen, M-o-r-g-e-n. Do you consider Morgen an honest man?
A. I don't know Morgan personally.
Q. You consider his affidavit as being worthwhile and true, and applicable to your case, do you not?
A. As far as I know that affidavit hasn't been introduced. Would you please leave that question to my defense counsel.
Q. It is in Document Book Scheide No. II, is it not?
A. Yes.
THE PRESIDENT: Of course, he has you there. It hasn't been introduced.
MR. WALTON: I am sorry. My notes showed that they talked about Document Book II yesterday but I don't know which document was introduced.
THE PRESIDENT: Document No. 35 and it has not been offered or marked as an exhibit.
MR. WALTON: Thank you, sir.
Q. Now I direct your attention to the character affidavits which you introduced yesterday in your own behalf, one of which was signed by Wilhelm Moehle, M-o-e-h-l-e. Moehle was formerly Police Commissar of your home town, was he not?
A. Yes.
Q. And an old comrade in arms of your father?
A. I really don't know the man who sent this affidavit. He apparently sent it of his own accord.
Q. Do you state now that you do not know Wilhelm Moehle?
A. No, I don't know him.
Q. You would expect a man who was friendly to your father to be friendly to his son, would you not?
A. I think that is absolutely impossible. There are still people around in this world who have got honor.
Q. Now, his statement, and I quote: "I never noticed during my official activity that Herr Rudolf Scheide was an especially active member of the SS", is not precisely correct when you consider your direct testimony concerning the years you served in the SS, is it?
A. That applies to the time up to 1933 which is stated in the affidavit.
Q. But you were in the SS from 1930 on, were you not?
A. Yes.
Q. And you served continuously during the time from 1930 to 1945, did you not?
A. I served in the SS from 1933 on and up to 1933 I was a member of some union, that was not a military formation.
Q. All your time from 1933 on the 1945 was taken up with your SS duties, was it not?
A. Yes, quite so.
Q. Then you were continuously active in the SS during that time?
A. Let us say in the German Army.
Q. In 1933 you considered the SS as a part of the Army?
A. Yes, definitely so. It was a part of the Army. Otherwise we wouldn't have had any officers in our organization for training and as inspectors.
Q. As an old friend of your father's, isn't it reasonable to suppose that his loyalty to him would cause him to become a bit prejudiced in your behalf?
THE PRESIDENT: I think that is a very good question to ask the Tribunal on argument.
MR. WALTON: Would the Tribunal allow me to withdraw it, Your Honor?
THE PRESIDENT: We would not only allow you but insist that you do.
Q. I next direct your attention to a statement of Wilhelm Ehlers. When you were the commanding officer of Ehlers you considered him an efficient member of your command, didn't you?
DR. HOFFMAN: May it please Your Honor, I would like to ask the Prosecutor to state at the same time where that document is so the Tribunal can find it in a minute. I see your Honors have to look at all times.
THE PRESIDENT: I have it, it is Exhibit 17.
Q. Shall I repeat the question, witness?
A. Yes, please do.
Q. When you were the commanding officer of Ehlers you considered him an efficient member of your command, didn't you?
A. That's the way it was, Mr. Prosecutor. He was such a small painter in a small workshop. He was a worker who according to my opinion was honest and decent and who told his opinion freely about his former superior. I didn't ask him for that affidavit but was glad to receive it.
Q. As a good worker who always did what was expected of him during the time he worked for you, you reciprocated by seeing that he received such awards as leave and promotion while working under you; and did you not?
DR. HOFFMAN: Mr. President, would you not permit the Prosecution to introduce that question because the same applies to this as to the question stated before. Whether the man who wrote the affidavit was his friend or not - that doesn't play any part here.
THE PRESIDENT: No, it is proper to ask him whether he gave the person who made the affidavit special favors by way of leave and otherwise. That is a matter effecting the credibility of the person who made the affidavit. That is all right, Dr. Hoffman.
Q. Shall I repeat the question?
A. Please do, yes.
Q. Now Ehlers was a good workman who did what was expected of him, wasn't he?
A. Yes, indeed.
Q. And because he was a good workman you saw that he received such awards as his regular leave and any promotion that you could get him while he was working for you, didn't you?
A. As far as leave was concerned I could not decide for the simple reason those were State workshops and State workshops leave was regulated according to Civil Service regulations. I had no right to give him special privileges nor was he paid by me but by the administration of the Army. I was not a member of the Army administration but an expert concerning technical matters in the Motor Pool.
Q. In so far as you could, you got all for that man as you thought he was justly entitled to?
A. Let me explain that to you, Mr. Prosecutor. If one employs workers then one has to see to it that the personal welfare is taken care of. I consider it the duty of the superior. That is what I did.
Q. Now you always maintained such friendly relations with him as any superior would to an efficient junior?
A. Yes.
Q. And you would have been quite surprised and hurt if he had not given you a good affidavit in light of the former associations with him, wouldn't you?
A. That's the way it was, Mr. Prosecutor, yes.
Q. Now, the other character affidavits which you submitted are all from your friends of many years standing, were they not?
A. Well, there should be a small difference between a friend and a co-worker, shouldn't there, Mr. Prosecutor.
Q. Some are from your neighbors back home, are they not?
A. However, neighbors can pass judgment on human beings because they know how you behave.
JUDGE MUSMANNO: Mr. Walton, don't all friendly and support affidavits usually come from those who are well disposed toward the individual, certainly not from his enemies.
MR. WALTON: That is right, sir. I just want that in the record.
THE PRESIDENT: We will take judicial notice of that from many years of experience. Also, we will take a recess.