The extent of his activity, which is of an executive nature, is announced usually in the newspapers. For example, in the I.G. Farben Industry, there were prokurists who were only exclusively allowed to represent the company at Auschwitz; however, they were not allowed to represent the corporation at Leverkusen and Merseburg. A business manager, however, represents the corporation fundamentally. He has no limitation towards the outside. That, of course, does not change the fact that within the internal administration certain fields of tasks are subdivided. However, he is not limited with his actions towards the outside. The prokurist consequently is always the subordinate of a business manager.
THE PRESIDENT: How is the prokurist appointed?
THE WITNESS: A prokurist is appointed by the business manager. While the business manager is either appointed by the stock holders meeting, or, if the charter prescribes it differently, he can be appointed by the supervisory board, should there be one. I am now referring exclusively to the G.M.B.H.
Q. Does the AG also have a prokurist?
A. Yes, the AG also has a prokurist.
Q. And does he act in the same capacity in the AG as he does in the G.M.B.H.?
A. He has approximately the same function. He is also appointed by the Board of Directors, while the Board of Directors in the AG is appointed by the Board of Supervisors, which is a permanent body.
Q. The German term for the word "manager" in the second column is "Geschaeftsfuehrer", is that correct, just for the record?
A. In the case of the G.M.B.H. The Board of Directors has exactly the same functions in the case of the AG.
Q. We were speaking about Mummenthey's position as manager or "Geschaeftsfuehrer" of the DEST. He was also chief of Amtsgruppe I, which was in charge of the DEST. Will you explain his position, the relation between his position as chief of Amt W-I, and manager of the DEST?
A. Mummenthey was not the sole business manager of the DEST. Schondorf was also a business manager in the DEST. Whether Schwarc was a business manager or prokurist I cannot recall at the moment. From the point of view of commercial law, Mummenthey was the primus inter pares. Mummenthey's actual functions extend to the commercial and the financial direction of this company, which included these many enterprises, while the actual plant leadership and the technical administration were carried out by Schondorf. Within the scope of the administration and the management of the whole, the special position of Schondorf played a very important part, because gradually it became customary that Schondorf either on his own initiatiye or according to an agreement with Pohl issued orders to the enterprises of the DEST, which previously were not discussed with the other plant managers, including Mummenthey.
Q. Also under W-I was the porcelain factory, Allach-Munich. Would you say that Mummenthey was the chief or the leader in the control of this plant?
A. I don't know for certain, but I think that Mummenthey had general plenipotentiary powers in order to have any influence according to commercial law. Normally he was not allowed to exert any influence there, because he was not appointed as business manager or a prokurist.
Q. He exercised his influence as chief of Amt W-I, is that correct?
A. Yes, that is correct?
Q. And was the same also true of the Bohemia Ceramic Works under Mummenthey?
A. That is not quite the case and I believe that here -- and that is possible according to stockholder law -- he had been delegated by the Board of Supervisors to be working in the Board of Directors. The position of the Board of Directors, according to German stockholders law, is extremely strong. Normally they can act according to their own judgment and can do as they want, up to the moment they are dismissed again by the Board of Supervisors. I know that the relationship of Mummenthey to the Board of Directors was such that when Mummenthey was consulted for decisions these were always reached on a friendly basis. It was never done by any authority he had on the part of the government. The position of Hechtfischer as business manager was much too strong for that.
Q. Mummenthey, you say, was a member of the Vorstand of the Bohemia Ceramic Works?
A. Yes, I believe that he had been delegated to the Board of Directors by the Board of Supervisors. However, I cannot recall that with one hundred percent certainty.
Q. And both the porcelain factory, Allach-Munich, and the Bohemia Ceramic Works employed inmate labor, did they not?
A. The Bohemia must have employed inmates as labor at a later period of time. I only heard about this later on. However, I believe that it was just before I left. The Allach employed inmates from the very beginning. They employed skilled people, or specialists, or artists, and for them, of course, it was a pleasure to carry out this work.
Q. From what camps did the porcelain factory at Allach-Munich draw their inmates?
A. I can only give an assumption. I can only assume they came from Dachau.
Q. Was there a camp at Allach?
A. I don't know whether there was a camp at Allach. I have never been there.
Q. And the DEST drew its inmates from the concentration camp nearest which the plant was located, did it not?
A. Yes, that can be assumed.
Q. And isn't it also true that in a number of cases--- Witness, do you know that in a number of cases concentration camps were erected near stone quarries in order to supply inmate labor to DEST industries?
A. I can't answer this question in this way, because I don't know what was there first. I don't know whether the camp was there first or whether there was the plant to establish a stone plant there. These granite works were already established before I came. I didn't see any there.
Q. It is quite likely that the granite location was there before the concentration camp, isn't it?
A. It is quite possible that the plan was there at the time to employ inmates. Probably otherwise this work would have been established elsewhere.
Q. Was Mummenthey a manager or prokurist or did he hold any other position in any other SS industry than the ones we have just mentioned?
A. I don't want to state this with certainty, but I believe that Mummenthey before was a prokurist with the Public Utility and Housing Company, G.M.B.H. However, I think it is better if you ask Mummenthey about that personally, because he might be able to give you more information about it.
Q. Referring again to Document NO-2116, which is before you, you see under W-II that Bobermin, the defendant Bobermin, is listed as the manager or "Geschaeftsfuehrer" of the Klinker Cement Company. Can you confirm that for your period of time?
A. Yes, I know that.
Q. Did I understand you to say on your direct examination that this industry did not employ concentration camp inmates?
A. Yes, that is correct.
Q. Do you know that from your own knowledge?
A. I have never been there. However, I know it from the necessary documents.
Q. What kind of labor did this cement company use?
A. Have I misunderstood you? Are you now talking about the cement works? I am referring to the Klinker Cement Works. The name is misleading. The Klinker Cement Works never actually produced cement.
Q. I am sorry. I am referring to the Klinker Cement Company. What kind of labor did this industry use?
A. Bobermin should be able to give you very detailed information about that. As far as I can recall from the various documents, and I hardly had an opportunity to see such documents, exclusively free civilian labor was used there.
Court No. II, Case No. 4.
Q These industries were all located in the Government General, is that correct?
A Well, they were located in what formerly was Poland. At the time there were certain territories which were incorporated into the German Reich. They were not part of the Government General.
Q It is your opinion that this industry used free labor?
A Yes.
Q The next industry listed under W-II in this document is the Golleschauer Portland Cement Company. Bobermin is also listed as manager. Could you confirm that fact for your period of time?
A The Golleschauer Portland Cement Factory is an AG, and the German owner here was the director.
Q And who was that?
A The director there was Dr. Bobermin together with another man.
Q And this industry employed concentration camp inmates, did it not?
A This plant must have employed concentration camp labor later on.
Q And from what camp did they draw their inmates?
A Mr. Robbins, that is something which I only heard here.
Q You don't know from your own experience with the WVHA that the Golleschauer Portland Cement Company employed inmates?
A Yes, I know that, but I don't know where they came from. I know now they came from Auschwitz.
Q But they did use inmate labor during your period of time, and you knew that at the time?
A It was approximately at the end. It must have been a short time before I left, because I heard about it.
Q Did Bobermin occupy the position of manager or prokurist, or any other position with any other industry of the SS?
A I don't know whether this was already at my time or not. But in my case afterwards he was with the Prager Bau, and, furthermore, the Court No. II, Case No. 4.Prague Construction Company, and, furthermore, he was business manager of the Eastern German Construction Works GMBH.
However, this company later on was sold to the Reich. I believe it was sold to the Reich Commissioner for the strengthening of the German Folkdown abroad. However, Dr. Bobermin should be able to give you more authentic information about that.
Q Do you know whether any of the property used by W-II, or the plants under W-II were confiscated from citizens of Poland, or Nationals of Poland?
A The state of affairs so far as I can recall, was the following. These enterprises by order and by law, which was in use by the German Reich, these enterprises were confiscated, and they were administered by the so-called Trusteeship for the East. Oberbauergermeister Winkler was in charge of it. I believe that he is located in the same jail here in Nuernberg. After this had already happened, Pohl was appointed under Herr Winkler was a second trustee for the administration of this brick plant. The executive person who worked in this plant under Pohl was Bobermin. In order to organize this in a reasonable form, a so-called plant administration company was established. This was not a lease company, and it was not a company which owned property, but it only was in charge of administering enterprises.
Q Now which of the industries under W-II are you referring to or were you referring to them, all of them, or just part of them?
A That applies to the enterprises which were administered by the so-called Eastern German Construction Material Works. That is the enterprises which later on were sold to the Reich. Several of these enterprises which originally were administered by the Eastern German Construction Material enterprise, were later on leased to the so-called Klinker Cement Company GMBH, which I have already mentioned. I would like to emphasize that I was not an auditor there, and I only know that from hearsay, and it would be better if Dr. Bobermin would be questioned along these lines.
Q You say that this property was confiscated. Do you know Court No. II, Case No. 4.whether the owners were given anything for their property?
Any compensation?
A I don't think so. I consider that out of question. However, you must make a basic difference between confiscation and seizure. Whether these plants were already confiscated, I don't know. However, I don't think that any compensation was paid. I consider that impossible.
Q You have just mentioned the properties which belonged to the Eastern German Construction Works for building materials, the Ostdeutsche Baustoffwerke; doesn't the same also apply to property operated by the Golleschauer Portland Cement Factory, and the Klinker Cement Company, Ltd.?
A The Golleschauer Portland Cement Factory is the result of negotiations between Dr. Bobermin, and a Swiss bank. It was purchased this way, that is to say, it was a regular sale, as the Swiss bank was afraid for its money which was invested here. That is the reason this enterprise was sold. The Golleschauer Portland Cement Factory, as a result of this, had nothing to do with the other enterprises.
Q And what about the Klinker Cement Company, didn't it operate confiscated companies and confiscated properties?
A No, in contract to the Eastern German Building Material Works, GMBH, which practically only administered enterprises on a trusteeship basis, the Klinker Cement Company, GMBH, had a lease on plants. They paid a certain amount of money for that lease, but nothing changed in the ownership status of these plants.
Q You say that you know the information which you have just given us purely from hearsay. What do you mean by that? That you know if from official conversations with people in the offices, and also from seeing the documents in the office, is that correct?
A Yes, that is correct. I even heard it from conversations with Dr. Bobermin, and I heard that from conversation with Dr. Volk, who participated in the negotiations with regard to operations of the Golleschauer Portland Cement Factory, or for example, that I have seen it from letters which I read incidentally. I never had the opportunity Court No. II, Case No. 4.to see the auditing reports of these enterprises.
Q Will you turn to the last page of this document, to page 116, under W-VIII. The first industry listed there -- what is the first industry listed there?
A Is the Convalescent Home, GMBH.
Q And the defendant Klein was the manager of that firm, was he, at your time?
A Mr. Robbins, this plant was established after my activity had already been concluded. I, therefore, can only confirm that from what I saw in the documents. Therefore, my confirmation will have little value as evidence.
Q Very well, in the memorandum that you prepared for Pohl, which is NO-1039, in Book 14, which we discussed yesterday, Exhibit No. 384, on page 16 of the German Text, and page 19 of the English text, there are listed there under W-VIII three different enterprises.
THE PRESIDENT: Is that W-VIII, Mr. Robbins?
MR. ROBBINS: Yes, Your Honor, it is on page 10 of the document.
THE PRESIDENT: Our document stops at W-VII.
MR. ROBBINS: I think it is past that place in the document by several pages. It is on page 27 of the English Document Book. No, I am sorry, it is on page 28.
BY MR. ROBBINS:
Q Do you know whether any of these industries listed under W-VIII employed inmate labor?
A In order to avoid making a mistake, Mr. Robbins, that was, for example, the company for the care for German Cultural monuments, and which are the Externsteine-Stiftung, the Koenig Heinrich Memorial Stiftung, and the Convalescent Home, is that correct?
Q That is it.
A Mr. Robbins, I can not give you any answer to that question, because these were not enterprises. But the first one was simply the Externsteine-Stiftung, that is an organization, so to say, a club or Court No. II, Case No. 4.league, it just happens to have the same name "Gesellschaft" or company.
In reality, however, it is a society. It does not have any title according to Commercial Law. The second is a donation. It does not have any legal character either, according to Commercial Law. The third one is a donation also. The fourth one consists of convalescent homes, which apparently, as was shown to me later on, were converted into a company according to the Commercial Law. However, at that time it did not have any legal personality, and I never had the opportunity to take an insight into the business circle of the defendant Klein. I don't know whether and where the inmates were employed there, aside from the knowledge I have gained from the documents here.
Q You knew from your position that Klein was Chief of W-VIII, did you not?
A Yes.
Q Did Klein hold any position in any other industry in the SS, either as manager, prokurist, or any position?
A Yes. However, that was at an earlier time. He was Prokurist in some enterprises, but I don't know which ones. At my time he had already been released, or he was replaced a little later. It is possible that for instance the Sudetenquell may be part of the enterprises. However, Mr. Klein will be able to tell you that in more detail.
Q Can you tell us what influence Georg Loerner exercised on the industries in Amtsgruppe W as Deputy Chief of the Office and as the manager of the DWB? First, will you tell us what his legal position was, what influence he could exercise?
A The legal position of Loerner was that he was the second business manager of the DWB. By virtue of his status, according to commercial law, he could have occupied himself to a very extent, and he could have applied his influence to the affiliated companies of the DWB. As a result of the fact that he was the subordinate of Pohl, he was unable to do that because Pohl had reserved the right to himself exclusively to deal with this branch. I can not recall any incident wherein Loerner would ever have personally exercised his influence on any affiliated company. It is possible that he accompanied Pohl on some trip or other. However, I don't know that. In the holding company DWB he was consulted in several cases, when, for example, a now foundation was discussed, or something of that nature.
Q You don't mean to say that Pohl took care of every detail of the operation of these hundreds of plants?
A No, to the contrary. The state of affairs was the following: The actual managers of the works were really themselves the firm group leaders. Pohl could interfere on the basis of some official order which he had issued before the DWB was established. The firm group leaders -
the Firmengruppenleiters -- reported to him whenever, for example, purchases were made exceeding RM 50,000. Furthermore, Pohl went into the plants, and he just issued orders there. For example, he told them that this was to be done in such and such a way, that such and such a machine had to be purchased, that such and such a machine was unnecessary, and so on. That is to say, he interfered to a very great extent, and Pohl did all this himself in the affiliated companies. However, in any other way they administered themselves.
Q You said yesterday that as far as you knew, Volk was never an office or chief of Staff W. Is that correct?
A I have seen a letter here where Volk calls himself an office chief. However, I don't think that we can take this letter too seriously. After all, Volk was never appointed. He certainly was not given any document to that effect, and I am convinced that if any appointment was made, it cannot have been cancelled again.
Q Prior to 1944, you never saw Volk referred to as chief of office or as chief of Staff W in any papers in your office?
A Could you repeat this question please?
Q Prior to 1944, you never saw on any of the papers in your office that Volk was referred to as chief of an office or chief of Staff W?
A Mr. Robbins, I did not have any opportunity to see that because I was not there. However, I consider it impossible.
Q Prior to 1944.
A I didn't see it. Mr. Robbins, I left and, I believe two months later, Baier became chief of W, and in the meantime they had a vacancy and I was not there. Nobody occupied that position. I was not there, and consequently I do not have any information about it.
THE PRESIDENT: I don't think the witness understands the word "prior". Any time before 1944.
Q Let us say any time before July 1944. You left in June -- '43, rather. Any time before 30 June 1943.
A Neither before 30 June 1943 nor afterwards. Afterwards I was unable to see it anyway, but I did not have any knowledge of it before either.
Q And you say that Baier later became chief of Staff W?
A Yes, I have seen that here in the documents. I know that as a result of several visits which I paid later on to Dr. Wenner or to my former secretary, who later on was taken over by Pohl.
Q And it is your contention, is it, that prior to his appointment as chief of Staff W, there was no chief of Staff W?
A That is my claim. That is my allegation.
Q I would like to ask you another question with regard to Volk. You told us just a little about the acquisition of property near Stutthof and the site of the concentration camp Stutthof. Do you know what part Volk played in this acquisition?
A No, Mr. Robbins, I can not give you any information about it. I know only that Volk took a trip on one occasion on this matter, together with other people. This matter was never discussed with anybody. It was never discussed with Ansorge or Wenner, or with one of my auditors. I heard from the details only here from the documents.
Q You never heard during you time with Amtsgruppe W, prior to 30 June 1943, anything about the acquisition of property in or about Stutthof?
A Yes, I did. I knew that the subject was being discussed. However, I was not internally concerned with this matter. After all, if Volk went to Stutthof, then somebody was bound to say, "What's going on there?", and that an acquisition of property was concerned here we knew, but for what purpose this property was to be purchased was not discussed.
Q You didn't know that it was for the site of a concentration camp?
A I doubt that very much. However, I don't know it.
Q Do you know who handled the negotiations in Amtsgruppe W?
A I personally am of the opinion that the title "Amtsgruppe W" is a false concept. If it is that it included all the enterprises, then it was always Pohl.
Q Didn't you see during your time the letter that Mauer wrote, which is Document NO 2133 in Book XIV, page 35 of the German, page 41 of the English, Exhibit 387, which says that, "Negotiations are being conducted by Volk?" Didn't this letter come to your attention?
A I have Document Book 14 before me. Could you please tell me the number of the page once more?
Q Page 35 in the German text, it is addressed to Staff W, and in the second paragraph Mauer says that, "Negotiations are being conducted by Dr. Volk and me," and in the third paragraph he says, "Negotiations about the sale are conducted by Dr. Volk".
A Well, we had a mutual discussion about the mail that had arrived, and the following took place on that occasion: All auditing matters and all taxation matters were mutually discussed, because I practically was concerned with all taxation matters. This was very difficult at the beginning for Dr. Volk and Dr. Wenner. Whenever such letters arrived, then Ansorge, who looked through the mail, either passed them on directly to Volk or whenever such a letter was discussed in the discussion of the mail which was addressed directly to Volk, it was immediately passed on. However, we would never discuss such things. I can not recall this letter either. It is possible that I may have looked into it by accident. However, I certainly did not acknowledge this letter, and I don't recall it at all.
Q Will you turn to Document Book 15, to page 48 of the German, page 37 of the English text. It is Document NO 515, Exhibit 413. This is the document which we mentioned yesterday. Will you look at this document and tell us if there were any other industries associated with Amtsgruppe W which employed concentration camp inmates that are not listed in this document?
A. I know that temporarily when cementing a well for the Mattoni A.G. inmates were used for that purpose. However, that was not for that plant but this was done by order of Office Group C for the construction of the wall. I believe that we can say that Office Group C was the employer in this case. I cannot recall any other company which employed inmates outside of the one which I have just mentioned and the ones which are contained in this list.
Q. Can you tell us what kind of labor was employed in the other SS industries within the German Reich? Were those laborers so-called "free laborers from the East?"
A. As far as I am informed they were exclusively free German workers, or they were free Chech workers, with the execution of one plant which I have already mentioned. That was the Apollinaris Plant GMBH, where female Eastern workers with small children were employed there to do very light work.
Q. And with this exception it is your opinion that none of the SS industries used Eastern workers, except for the concentration camp inmates?
A. I am just looking over the list. It is possible that in the course of one of the last firms which were founded however, it was not during my time but at the end of 1944 -- inmates were used in the Oil Slate GMBH. However, I am not informed about that. Baier may know something about the matter.
Q. Before we leave this subject lot me ask you ... Was it permitted for an auditor under commercial law to be a member of the Vorstand or Aufsichtsrat of the corporation?
A. Yes, he was permitted to hold that position. However, he then immediately lost his qualifications as an auditor.
That was very unpleasant because the examination is so difficult.
Q. I should like to turn to another subject. You have told us that you were opposed to National Socialism. Can you tell us briefly upon what your opposition was based?
A. This was on the basis of my personal attitude that is, as far as my ethical principles were concerned.
Q. Excuse me. Will you tell us what principles or practices or activities of the NSDAP you disagreed with, rather than explaining your own personal ideology. What was it in the Party you disagreed with?
A. I did not agree with the ideology of the Party and I did not agree with the economic principles of the Party. With regard to the economic principles the situation was such the National Socialist administration during the entire time of its activity only used up the substances of properties. Everybody can do that. If I use up my bank account I can live very easily for a few years - that is to say, as far as my account is sufficient. Whenever my account has become exhausted then, of course, I am confronted by catastrophy. The economic development of the Reich under National Socialism was inevitable. This trend of thought was clear from the beginning already at the HighSchool at which I studied at Cologne.
Q. Let me for a moment direct your attention to the National Social ideology of the Party. You say you opposed that. What principles of the Party did you oppose in that regard?
A. I didn't agree with the racial principles. I didn't believe in a dictatorship and a world philosophy at that time. After all, Germany for hundreds of years was the land of liberty.
After all, in Germany the spiritual liberty was brought about by the Reformation. Now, for the first time, we had a movement which demanded of every person that he should think exclusively only in one direction. This was also shown in the field of the ideas of history; but not here alone - but also in other fields, for example in physics, in geography. If somebody published a book which some leader of the Party did not approve of, then this man was impossible for the National Socialism, and this spirit - this lack of liberty which was a principle of National Socialism does not agree with German ideology at all. After all, German culture is based on independent and free thinking.
Q. You also told us that you opposed the principles of the SS. Will you tell us briefly what principles of the SS you disagreed with and opposed?
A. I am thinking of the principles of the SS as the executor of the trend of thought which I have just expressed. In the case of the SS it was a principle that whoever thought differently than was prescribed by the Leadership, then this person was actually guilty of disloyalty. I would like to be able to give you the following example. In the Experimental station for food I once complained as an auditor that the business manager had carried out a transfer of foreign exchange to Russia, which had not been approved by the agency in charge of foreign exchange. However, as it was explained to me later on, this had been ordered by Himmler personally. This was a transfer of horses and machinery. When I opposed this because it was contrary to the German laws this business manager saw to it - his name was Vogel and many sides expressed the opinion that I was daring to maintain a derogatory attitude towards the orders of the Reichsfuehrer.
This is how you have to consider the ideology of the SS. If the Reichsfuehrer issued a directive or policy, and somebody deviated from that policy, then he had to be declared disloyal and was to be exterminated. That was the most un-German principle which ever existed.
Q. Did you at any time obtain knowledge, or see any violence, of the SS with which you disagreed -- any violent activities?
A. I never saw anything at all. I heard of them on several occasions and for this reason I felt the obligation within me to ascertain these facts for myself. I asked several SS officers about these things. Most of them were silent because they were obliged to secrecy in these matters. Some others, however, talked. And they informed me precisely about several things, and that is how I got my information. This was not my own assumption; I received my information from sources that were authentic. Therefore, I was not able to be mistaken in this matter.
Q. What kind of violence did you hear about in this way?
A. In this way I heard about shootings which were carried out, and gassing of people.
Q. Then it wasn't completely impossible for someone in Germany to find out about these things if he really wanted to.... Is that correct?
A. I don't know that. I cannot tell you that. I noticed the following: I asked a friend of mine, who had closer contact with some SS officer, and in that connection a complete picture --- I asked him to come to my apartment and he informed me quite precisely.
Q. And what did you hear in particular about the gassings and shootings.
A. I only heard the fact that constantly gassing was being carried out, and before that I heard when these socalled Sonder Kommandos with special detachments were working in the East, I also heard that people were being shot en masse.
Q. In what concentration camp did you hear that gassings were carried out?
A. I only heard about Auschwitz.
Q. Did you hear of any other kind of violence or mistreatment of concentration camp inmates in your contact with the resistance groups, or in any other way?
A. I heard about the fact that guards in the camps were treating the inmates very roughly. I never saw anything of the kind.
Q. Did you hear that foreigners were incarcerated in the concentration camps?
A. Well, most people in the concentration camps were foreigners. After all, French Jews were sent there; Belgian Jews were sent there.
Court No. II, Case No. 4.
Q Isn't it true that it wasn't very difficult to find out that foreigners were in concentration camps?
A It depended on how close you were, you would get to these people. After all one was able to hear the language they talked, but it was a question of the distance. If I was directly before these people, of course, I could know that they were talking a foreign language.
Q You could see them, couldn't you, working in railway stations and around on the highways in Germany and in public places?
A I never saw them there actually. I only saw, for example, that after the WVHA was destroyed by bombs these inmates were used to clear up the rubble, and inmates were frequently used for such work. Otherwise I only saw them when I inspected plants, or, for example, in Auschwitz I saw them march in the street.
Q Would you say that it was common knowledge in Germany that non-Germans were in concentration camps?
A I believe, Mr. Robbins, that I am unable to give you the required information about that. Your question goes too far. The knowledge which I could obtain, it was quite probable that not everyone could obtain the same knowledge. Just to what extent these things were known actually, I don't know. However, it is certain that there are a number of people who today deny any knowledge of these things. Here I am above all thinking of high party leaders or government agencies.
Q Would you say that persons in high positions in the party and the government had, generally speaking, an opportunity to find out about conditions in concentration camps?
DR. HEIM: Dr. Heim for the Defendant Hohberg.
Your Honor, I object to this question. The defendant cannot state from his own knowledge whether these agencies actually had knowledge of these things. He has just stated that his knowledge is only based on assumptions.
MR. ROBBINS: Your Honor, I didn't ask if they had knowledge. I asked if upon the basis of his experience he could say that they had an opportunity to learn about these things.