Then the triangle gives the name of manager Pohl and his Deputy Loerner.
Then I should like to draw attention to the square which has two lines around it. That square included all those things which Pohl understood as Staff W in his own organizational chart.
Q. Who was in charge of the groups of firms which are listed outside that square, W-1, through "-7?
A. The subsidiary companies of the DWB were subdivided according to the various branches, which is well known; I need not talk about that anymore. They were immediately under Pohl during the time when I was auditor of the DWB. For that reason, this line goes direct from the manager Pohl down to the groups of firms which were called offices in the WVHA.
Q. Now, in order to explain the so-called Staff W, which is listed here inside the square with its two lines, tell us what was your position towards Staff W?
A. Staff W as such is not a very concrete term. It is simply a name for the organizational chart of Herr Pohl. In Staff W, firms, as well as spheres of task, are listed side by side, although they have no contact with each other. This is the reason why one cannot, as the Prosecution did, say for the time while I was auditor, i.e. until the middle of 1943, speak of tasks of Staff W. I was, myself, outside. I had two organizations which were above me. One was the professional organization, the Institute for Auditors, and the other was the Reich Ministry of Economic Affairs itself, or the Main Department for Public Auditors, which was for all practical purposes part of the Ministry for Economic Affairs.
THE PRESIDENT: Counsel, are not Documents 13-A and 13-B identical?
DR. HEIM: May it please the Court, these two document 13-A and 13-B are the same. If I had made a photostatic copy. I did that in order to have the chart which is Document 13-A become more clear to the Court.
THE PRESIDENT: But the information is the same on both 13-A and -B?
DR. HEIM: The information is the same, except that on Document 13-B, on the photostatic copy, there are one or two more names up on top. The information contained in both documents is identical.
BY DR. HEIM:
Q. Witness, from your person there are two lines, one going to the management of the DWB, and the other going into Staff W, to the square which says "auditors transferred by the WVHA". Will you please explain what those two lines represent?
A. The line which goes to the auditors, into Staff W in other words, signifies my contact with the auditors which were put at my disposal "by the VVHA or the Fain Office, Economy and Administration. The small square right up in the left hand corner is the fundamental organization of Staff W, the original one.
The second line which goes to Pohl direct is the official order to audit, and also the order to advise in professional matters. No other relations existed between myself and what was known as Staff W.
Q. Will you also please explain on the chart the position of Staff W both inside the DWB, as well as towards the organization of Staff W itself?
A. The square in the left-hand corner is the auditors. The three squares in the middle are the sub departments of DWB. Dr. Wenner, he is the taxation accountant. General office administration, statistics etc., there we had Ansorge in charge, and the third department was law, the legal department, and Dr. Volk was in charge. That was the second element of the Staff W which was added. Now, the development showed that these three people, Dr. Wenner, Ansorge, and Dr. Volk, were put in charge of various companies, uniting the various functions in their position. These are the five companies which I immediately listed in the middle underneath. The lines connecting them with the departments of the DWB does not signify that these companies were subordinate to the department, but it signifies connections between the man in charge of the department and the various firms in personal union. Finally, we find two companies at the bottom of the square which Pohl also listed in the organizational plan of Staff W, because otherwise he couldn't find any room for them anywhere else, the Deutsch Hulmmtrel, DHM GMBH in Prague, and the East Industry of Lublin. The orders reach these two companies from the manager, Pohl, through these lines. There is no connection between any person of Staff W and these two companies, nor is there any connection, for instance, between Dr. Wenner and The Estates Company GMBH (Hans - und Grundbesitz Guibk) of which was Dr. Volk, nor is there any connection between the employee, Dr. Volk, and the company to fight pests, (Gesellschaft fur Senchrenbebaupfing), nor is there any connection between the auditors and the German Home and Dwelling Places, Limited, (Gemienntzige Wohung-und Heinstaken). There is not the slightest connection, for instance, between myself and any of those companies or with the departments of DWB, with the exception of my activities as a tax consultant which, of course, brought me into daily contact, if I was in Berlin and with the enterprises, to audit.
The three departments of the DWB are listed here on the same level, but it is difficult to say whether they really were on the same level, because within the framework of the DWB Concern there were internal arrangements whereby the SS rank was the decisive factor.
Q. Did you have, therefore, as far as the departments of DWB were concerned, or the five companies within Staff W, any right to issue orders?
A. No, I did not, which is the reason why there is no line from me to those companies.
Q. Now, will you please look at Document Book II of the Prosecution, on Page 125 of the German text, which is probably Page 108 of the English text, it is Document NO-1016, Prosecution Exhibit 46, and it concerns a list of the organization and tasks of Staff W. The second paragraph says, and I quote: "In charge of these offices is staff W of Obergruppenfuehrer Pohl."
THE PRESIDENT: Exhibit 46 is the lecture material and runs from Page 105 to Page 112.
DR. HEIM: It should probably be on Page 108 of the English book, your Honor. It is in Document Book II of the Prosecution.
THE PRESIDENT: That is right. Page 108 is still a part of the lecture material. It runs up to Page 112.
DR. HEIM: Yes, it says within the frame of this document, "Staff W heads these offices, Obergruppenfuehrer Pohl is in charge. From the point of view of private economy it is the DWB".
THE INTERPRETER: The paragraph actually reads, your Honor, "At the head of these offices stands the W staff of the SS Obergruppenfuehrer Pohl, regarded from the point of view of private economic the German Wirtschaftsbetrieve G.m.b.H." It is the second paragraph on 108.
THE PRESIDENT: All right.
Q. (By Dr. Heim) Witness, does your testimony so far contradict this document?
A. Yes, it does. When I left in the middle of 1943 Staff W was completely changed and reorganized. What conditions were like later on I can only say from the business instructions which have become part of the documents, and which I have represented on my third organizational chart. At my time it was different. When I was there the authority to issue orders went from Pohl direct to all the companies. That Staff W was not a uniform organizational formation but merely a conglomeration of tasks and duties without any uniform direction. It was quite impossible to have the auditor and the manager of a company under one and the same orders, let alone have the auditor be the manager of the enterprises. I would, therefore, like to make another additional statement to the former question. When I drew up my organization Osti has been listed as a subsidiary company of the DWB. That fact is being disputed here in some cases. I personally am of the opinion that it does not matter very much whether Pohl had already founded the Osti and passed on the shares to DWB or whether he had not, because the authority to issue orders remained the same. I just wanted to mention that.
Q. If I have followed your testimony correctly, Witness, one could sum up and say that up to 30 June 1943 there was no office chief of Staff W, which is contrary to what the Prosecution has alleged, is that correct?
A. At my time there was no chief of Staff W, but I was appointed to that position once, but I declined the appointment, and Pohl shortly afterwards withdrew the appointment officially in a letter.
Q. This testimony you laid down also in your affidavit of 4 February 1947. This is Document NO-192, Exhibit 16, in Document Book I of the Prosecution on Page 101 of the German and on Page 83 of the English book.
You said that in 1942 you were appointed office chief by Pohl. Will you please describe briefly when and how the designation Office Chief Staff W was invented?
A. I believe it was roughly at the time when the two main offices, Economy and Administration and Construction and Budget, the WVHA, was formed. Pohl came and told me one day he wanted to distinguish me particularly and would therefore appoint me to what he called Office Chief of Staff W. I said to Pohl immediately that on the basis of my professional obligations it was impossible for me to accept a title or designation of that sort, because then one could easily conceive the idea that I would take the influence comparable to that of a director on these companies or one would come to take the position of a Government official.
Q What in your opinion were the reasons why this designation was coined?
A When the DWB was founded as a holding company there were centralized suddenly with Pohl a large number of new fields of tasks which, up to that time, had been looked after by the enterprises themselves. Pohl had no expert at his side, and he was looking for somebody whom he could appoint to that position. For that reason, Pohl on several occasions made me that offer to cease being an auditor and to join the management of DWB. This would not have been the position of the General Manager, but that of the deputy manager under Pohl's supervision.
Q What was your position?
A The result would have been that I would have discontinued my profession as an auditor completely, and therefore I took a negative attitude. Furthermore nothing could have been further from my mind than to enter a firm relationship with the WVHA because that would have meant that I would have under Pohl in disciplinary matters. That position had never existed actually. I was never under Pohl's disciplinary authority but many attempts have been made to achieve the position that I would be under Pohl's authority.
THE PRESIDENT: Did you leave the WVHA on the 30th of June, or the 30 of July, 1943?
WITNESS: On the 30th of June. Mr. President, I will produce another document later on-
BY JUDGE PHILLIPS:
Q Well, if you never did take the position as chief under Pohl of one of the "W" offices, why did you put it in your affidavit?
A I was appointed officially chief of staff W by Pohl, and that is what I mentioned.
Q Did you accept the appointment?
A No; I did not accept it.
Q In other words, you meant to say in your affidavit that you were appointed chief of this office by Pohl but did not accept the appointment? Is that what you mean to say?
A Yes, that is just what I wanted to express.
BY DR. HEIM: (Counsel for defendant Hohberg):
Q Witness, you said that you took up a negative attitude towards that appointment of Pohl's. Did you show your negative attitude also towards Pohl?
A Yes; I told Pohl that is was impossible for me to accept that appointment, from a professional point of view. Pohl didn't take the matter too tragically because he didn't have any clear idea about it. Pohl was sometimes very generous with titles and designations--but from a professional point of view, I could not accept it.
Q What was it that Pohl said when he talked to you? What expression did he use?
A I recall distinctly that Pohl used the expression: "Either you remain loyal, and then you will be well off--or you will lose your head,"
Q What did you understand from that? What did you think he meant?
A The expression meant that I did not bother about this designation any more. It became superfluous after Pohl's letter to the Institute of Auditors, and I let matters rest.
THE PRESIDENT: Counsel, please; what is the document reference to Pohl's letter to the Institute of Accountants? Do you have that handy?
The witness just mentioned Pohl's letter to the Institute of Public accounts....
DR. HEIM: Mr. President, a document is not available about that, but I shall submit various affidavits in my document book which are concerned with that problem.
BY DR. HEIM:
Q Witness, how was it that the designation Office Chief of Staff W is a completely ficticious one?
A The form Office Chief is not a rank in Germany; it is merely a position. The term Office Chief is something which has reference to governmental habits, a ministerial designation, or a military title; but it is not a title under commercial law. It is the same thing as though the manager of some commercial enterprise- would be given a ministerial title. I would be the same thing if you called the manager of Ford a State Secretary--the manager of that company surely would smile about that.
For the so-called Chief of Staff no official office existed. No document was drawn up. No official letter of appointment was written; nor where there any governmental functions connected with it, nor Party functions, nor SS functions.
Also I knew that the appointment expressed by Pohl was, from the point of view of official SS directives, an impossibility. In addition to that, there was the fact that as an auditor on the basis of legal regulations, I was not allowed to be an official or an employee as a sideline, automatically, I would have lost my qualifications as an auditor.
If the Tribunal please, I would like to have you understand it to the effect that I had my firm tasks for which I was paid, and it would have been stupid of me to avail myself of the appointment in order to have a new title without improving my financial background and my professional duties.
DR. HEIM: If the Tribunal please, I believe this would be an opportune moment for me to submit further documents from Hohberg Document Book No. 1 the document book is now available in the translation and is in the hands of the Court, the Prosecution and the interpreters.
I shall offer on page 35 of the Document Book, Hohberg Document 16 which will become Exhibit No. 5. This is an affidavit by Karl Wolff--the Court is familiar with that witness as he testified here as a witness on behalf of Pohl. In that affidavit Wolff says that it was quite impossible that somebody became an office chief without being written an official letter of appointment which would have to be signed by the Reichsfuehrer SS. I venture to read a few brief passages from that affidavit. I shall start with paragraph four of that document:
"The nominating of any chief of office was a definite privilege of the Reichsfuehrer-SS himself.
In the next paragraph--the last sentence, reads:
"A Chief-of-office appointment became effective only when it was signed by Himmler in person. My many years of practical experience up to 1943 led me to believe that it would have been impossible for anyone who was not a member of the SS and the Party to have received an appointment as Chief of Office of the WVHA."
Then, I beg to offer Hohberg Number 17, which is on page 37 of the German and English books, Hohberg No. 1. This will become Exhibit No. 6 and is an affidavit by Dr. Schmidt-Klevenow was a court officer in the WVHA, and, on the basis of his experiences and knowledge, he is in a position to comment on this. Again I would like to read two sentences from that document. I shall read from paragraph 3, in the middle:
"At the appointment as office chief, a document was handed over which was drawn up by the Main Personnel Office or by the Reichsfuehrer -SS. In my opinion, someone not belonging to the SS could not be appointed as office chief ina main office since only an SS-Fuehrer could become office chief."
On that subject I shall offer another document which is on page 39 of the document book, Hohberg No. I. It is Hohberg No. 18, and it will become Exhibit No. 7. It is an affidavit by Gottleb Berger.
With brief intervals, Berger was chief of the SS Main Office and, therefore, knows all about the terms "Office Chief". I will read, if I may, from this document, the fifth paragraph. It also has the figure "2" in front of it.
"Himmler himself appointed office chiefs either directly or at the suggestion of the Chief of the main Office; likewise their removal or their employment otherwise."
Finally I should like to offer Document Hohberg No. 19 as exhibit No. 8. It can be found on page 41 of the Document Book. Also I should like to offer Document Hohberg No. 20 as exhibit No. 9, which is on page 45 of the Document Book Hohberg No. I, and it is an additional affidavit to Hohberg Document No. 19. That Document is an affidavit by one Dr. Ferdinand Bodesheim, a lawyer by profession, and he is now working in the Hessian Ministry Economic Affairs, on personnel matters. His experience and knowledge is such that it enables Dr. Bodesheim to comment on the question of an office chief. I would like to read from that document on page 42 of the Document Book, just one brief paragraph. This is part of the first big paragraph, and roughly is in the middle of it. "Neither the concern nor the enterprise connected with it became administrative authorities or public corporations, but remained legally subject to civil law. As such, they were also subject to compulsory auditing, or to voluntary examination of their balance sheet. In Germany these examinations have to be carried out by professional independent auditors who act by virtue of an order to audit or advise. By this order, the auditor enters into a contractual relationship to the individual companies, similar to a relationship between two private firms, one of which commissions the other to do a certain job. This contractual relationship is not a dependant service relationship, but, in accordance with the nature of auditor's work, an independent, free contract, which may be compared somewhat to an attorney's assignment." Then I would like to ask the court to take judicial notice of the balance of this document. I shall not read, it now.
BY DR. HEIM:
Q Witness, when you were appointed Office Chief, you were not given an official document, were you?
A No, nothing was put on in writing of that nature. On the contrary, I could draw your own attention to the fact that in Pohl's organizational charts, and which is dated a few months later, that not one word is said about chief of Staff-W.
Q Witness, I shall speak about that later on. Your so-called appointment as office chief was that done through the SS Main Personnel Office? As the affidavit of Berger said, that would have been compulsory?
A No, the whole thing was done on the impulse on the part of Pohl, and I regarded it as a ballon d'essaye, as it were, to bring me into closer contact with the SS, somehow or other.
Q Was that appointment at all possible in accordance with regulations of the SS, which you know of?
A There were firm regulations issued by Himmler, and the membership to the SS and the Party were a matter of course. For that reason I really regarded the whole thing as sort of a joke.
Q Witness, did that designation "stick" to you, so to speak?
A No, Pohl would revoke it officially by informing the Institute of Auditors.
Q Please tell us briefly how that designation was officially canceled.
A Briefly, after the designation had been coined, a movement set in against me on the part of the SS leaders. There was an anonymous denouncement addressed to the auditors that I was now in office as Chief of Staff-W, and that, therefore, I was carrying out the function of a director, whereas, as an auditor I had to be independent. The letter suggested to deprive me of my qualifications as an auditor. Pohl succeeded in tracking down the man who had written the anonymous letter, and he was sent to one year in prison. I immediately informed Dr. SchmidtKlevenow, who was then the court officer, that the man whom I suspected was one of my auditors could not have been the writer of this letter. The sentence was done on the basis of circumstantial evidence, because three letters on the typewriter were identical with the one used in the anonymous denunciation. I insisted that Dr. Schmidt-Klevenow would at least have examined the other letters which were done on a typewriter, because then it would have become clear, that these letters were entirely different.
That Dr. Schmidt-Klevenow did not feel like doing that. He refused to have any further examinations. The attorney acting on behalf of the defendant had not been given the chance to acquaint himself with the indictment. He had just been shown it briefly during the trial, and the sentence of one years imprisonment was confirmed. I should like to mention that on Pohl's birthday, on the 13th of June 1942, photographs were taken of all office chiefs of the WVHA. These photographs were bought by a British Airforce Captain Walter at the Berlin photographer Binder. For that gift for Pohl's birthday I was not photographed. I remember exactly that at the time all the office chiefs went to the photographer in their solemn uniforms. I stood by and looked on. Nobody had the idea to tell me why don't you come along and have your picture taken as one of the office chiefs. By that I want to express that the other office chiefs also did not regard me as an office chief.
DR. HEIM: If the Tribunal please, I have attempted to get these photographs which the British occupational forces have confiscated. I was even in a position to give the name of the British officer who confiscated these pictures from the photographer Binder in Berlin. But unhappily I did not succeed in getting the photographs, because it would be extremely important in my case in order to prove that the defendant Hohberg was not regarded as an office chief, because his picture was not taken when all the other office chiefs had their pictures taken by the photographer Binder.
BY DR. HEIM:
Q Witness, in the chart kept by the Prosecutor of the WVHA of 1942, your name is not listed. This is Document NO-111, Exhibit No. 38, in Document Book II of the Prosecution. No staff-W is listed in this chart either. It only says under Pohl the words "Economic Auditors," and in addition there it says,"DWB". Does that refer to you?
AActually under the term "Economic Auditors" that document is concerned. By the way I should like to call to the court's attention the fact that it shows "auditor" and underneath it says, "Inspector," and then comes some brackets, and it says, "DWB, GMBH."
Actually by adding "DWB" here it is an attempt to show where each persons can be found. It is merely a local designation. The inspector of an enterprise, which is followed by "DWB" in this document, was at that time Maurer, who originally was chief of Office W-4, and who before he joined the Office Group-D, was temporarily employed in the DWB as so called inspector of the enterprise. He travelled from plant to plant, and reported to Pohl.
Q Is this subordination of you under Pohl correct as the chart shows it?
A I don't see here any subordination as referred to under the document, it is merely, so far as I am concerned, showing that I am mentioned there such as one might be mentioned on an organizational plan of a concern.
DR. HEIM: If the Court please, I believe this would be an opportune moment to have a recess, because I shall next speak about another document.
THE PRESIDENT: All right, the Court will call a recess.
THE MARSHAL: The Tribunal will recess until 1345 hours.
(A recess was taken until 1345 hours.)
AFTERNOON SESSION (The hearing reconvened at 1345 hours, 14 July 1947.)
DR. HEIM: May it please the Tribunal, on Friday in the examination of the witness. I could not offer the Hohberg document book which refers to the examination of the defendant as a witness in his own behalf. Now that Document Book 1 has been offered for the defendant Hohberg, I would like to ask whether the Tribunal desires that I should now offer these documents or whether I should offer them after the examination of the witness has been completed.
THE PRESIDENT: Unless there is something special and additional in the document book which has not been covered by the witness's testimony, we suggest that you simply offer the document book.
DR. HEIM: I didn't quite hear your statement, Your Honor, and I would like for you to repeat it, if you please.
THE PRESIDENT: Unless there is something new and special in your document book, I suggest that you simply offer the remaining documents in evidence.
DR. HEIM: Thank you, Your Honor. I now offer from Hohberg Document Book 1 on page 1 of both the German and English text Hohberg Document No. 1, as Exhibit 10. On page 2 of the document book I want to offer Hohberg Document Book No. 2 as Exhibit 11.
THE PRESIDENT: May I help you to go a little faster? Do you offer Documents 3 to 15 inclusive? To be numbered Exhibits 12, 13, and so on?
DR. HEIM: Your Honor, if I have understood you correctly, then you said whether in connection with Document Book No. 14, these documents have been offered by me. Up to now I have offered 9 documents and now Document Hohberg 1 was Exhibit No. 10.
THE PRESIDENT: Document 3 is Exhibit 12; Document 4, is Exhibit 13, and so on, to No. 11?
DR. HEIM: Yes, your Honor.
Your Honor, I would like to go into a little more detail, very briefly, with regard to these documents. Documents No. 1 and 2, Exhibits 10 and 11, contain the legal regulations about the public owned and state owned enterprises, and Document 1, Exhibit 10, contains the main law. In Document Hohberg, 2, Exhibit 11, we have excerpts from the exact auditing descriptions. In Document 2, Exhibit 11, paragraph 7, the following is stated, "Auditors in the sense of these regulations are publicly appointed certified public accounts."
In paragraph 9 of this document we have the extent to which the auditor is authorized to examine the books of all of the enterprises.
Hohberg Document 3 is Exhibit No. 12. It is located on page 6 of the Document book. It is an excerpt from the law about the joint stock companies and about the partnerships, limited by shares.
The document refers in particular to the auditing of the yearly balance sheet. In particular I would like to point out Article 137, paragraph 2 which is on page 6, at the bottom of page 6, in the English document book.
I will now read the second paragraph of Article 14 which is on page 7 at the top: "Members of the Vorstand or Board of Supervisors, as well as employees of the cor poration may not be elected or appointed auditors.
The same applies to members of the Vorstand or Board of Supervisors and employees of another corporation which controls or is controlled by the corporation to be audited, as well as to persons on whose conduct of business any one of the above corporations has any decisive influence."
Your Honor, this document shows that the defendant, Hohberg, could never be an employee of the DWB because in that case, he would have become prevented from carrying out his activities as an auditor.
Article 138, page 7 of his document book shows that the auditor may request the Vorstand for explanations.
Paragraph 140, contains the regulations about the confirmation, and the certification by the auditor.
Paragraph 142 states responsibility of the auditor.
In this case, he personally is liable to any sum up to 100,000 marks.
Document, Hohberg No. 4, page 9 of the document book, will become Exhibit 13. It is an excerpt from the Year Book of the official trustees for the year 1941. This excerpt tells us about the peculiarity of the profession of certified public accountants. It is a relatively short document, and I will take it upon myself, with the permission of the high Tribunal to read this one paragraph.
THE PRESIDENT: This is just what I meant. It is not necessary to read these. We have them in front of us. You offered them in evidence and that is the way we learn what is in them.
DR. HEIM: Very well, your Honor.
The next document is Hohberg No. 5, will become Exhibit 14. This document shows the subordination of the defendant, Hohberg, as an auditor under the Institute of the 35 Public Accountants as expert agents.
Hohberg Document No. 6 will become Exhibit 15.
THE PRESIDENT: Document 7 will become 16.
DR. HEIM: Yes.
THE PRESIDENT: And No. 8 will become Exhibit 17.
DR. HEIM: And document No. 9 will become Exhibit 18; Document 10 will become Exhibit 19, and Document No. 11 will become Exhibit 20.
THE PRESIDENT: And document No. 15 will become Exhibit 21.
DR. HEIM: 21, Your Honor. It is an affidavit, written by Dr. Hohberg, and it represents a detailed explanation. It is with regard to the 4 charts contained on the document book.
THE PRESIDENT: And that will be Exhibit 21.
DR. HEIM: It will become Exhibit 21, Your Honor. Your Honor I would like to stop here with the presentation of documents. Your Honor, I would like to continue in my examination of the witness. I am now coming to prosecution No. 2672, which was admitted as Exhibit No. 36 in Document Book 2 of the Prosecution.
It is an organizational chart of the WVHA. This chart was compiled by the prosecution and it was signed by the defendant, Pohl.
Witness, I would like to ask you, is this organizational chart correct so far as you are concerned?
A: It states here, "Business Manager Hohberg".
Pohl knew that neither Volk nor I was the business manager. Then here is another mistake here. It says Staff W. A special space would have to be left for me where I would have to be put down as an auditor. As it is indicated there, it is not correct.
Q: Does the chart on the wall correspond with the chart here, because this chart is supposed to be an enlardad reproduction of the document. I am not referring to any disagreement or agreement with you personally.
A: I have already stated once before, - I have made squares and I have compared these. Everything is correct in the chart except the part that refers to me.
The prosecution has added here, "Chief". However, that is not stated here.
Q: How do you explain the fact that Pohl left the designation of your person although at the time he expressly withdrew your appointment as office chief as you have described to us already in your course of your examination.
As Pohl has also said the same thing in his examination. He has stated that in reality my appointment as chief of staff W had no success because the legal prequisites were lacking.
Q: How do you explain the fact?
A: We must think from the beginning that he has been trained in military administration, and that he used exclusively military terms. That is to say, he was clearly accustomed to them. Pohl didn't use any commercial terms at all.
Q: Witness, please speak somewhat slower. Please explain to us just what position you actually occupied with the WVHA.
A: I did not occupy any position at all with the WVHA. I was an auditor of the Trade Association.
THE PRESIDENT: I think you have covered, very thoroughly and completely, the evidence of this position as indicated on the chart as Chief of Staff W. I think you have given us the entire story and I do not think you need question him further.