camp at Krupp's, and then I am going to ask you some questions about it. I am not attempting to say that you was a personally responsible for these conditions. I merely give you the indications as to what the regime was doing and I am going to ask you certain questions as to the effect of this sort of thing on your work of production. the affidavit of Dr. Jaeger who was later brought here as a witness?
Q You don't accept that?
Q You have no personal knowledge of the condition. What is the basis of your information that Dr. Jaeger's statement is exaggerated? Of course, in visits to concerns, the head of the concern came to me with his most important problems. Those important problems were primarily after air raids when, for example, the German workers and foreign workers had no proper shelter any more, and this matter was described to no. cannot have been a permanent condition. That could only have been a condition caused perhaps by air raids, a temporary condition, for a week or two, which was improved later. It is clear that after a sever air raid in a city, all the hygienic installations, the water supply, gas supply, electricity, and so forth, were severely damaged so that temporarily there were very difficult conditions.
Q I remind you that Dr. Jaeger's affidavit relatesto the time of October 1942, and that he was a witness here. Of course, you are familiar with his testimony. would become United States of America Exhibit 893. It is a document signed by the office chief of the Locomotive Construction Works, describing conditions of his labor supply, foreign labor.
I repeat I am not suggesting that this was your responsibility. I am suggesting it is the responsibility of the regime. I should like to read this despite its considerable length. This is dated at the Boiler Making Shop, the 25th of February 1942, addressee to Hupe by way of Winters and Schmidt.
"I received the enclosed letter of the 18th of this month from the German Labor Front, sent to my private address, inviting no to the Office of the German Labor Front" -- giving its address and the date. "I tried to complete the business which I did not know about by telephone. The answer from the German Labor Front was that the matter was very important and demanded by personal appearance. Thereupon I asked Mr. Jungerich of the Department for Social Labor Hatters whether I had to go. He answered, 'You probably don't have to, but it would be better if you wont'. About 9:50 I went round to room 20 at this place and met Herr Prior.
"The following event provided the cause for this conversation, which Herr Prior carried on in a very lively manner, and which lasted about half an hour:
"On the 10th, 23 Russian prisoners of war were assigned to No. 23 Boiler Shop. The people came in the morning without broad and tools. During both breaks the prisoners of war crept up to the German workers and begged for bread, pitifully pointing out their hunger. At the first midday, the works had the opportunity of distributing the food which remained over from the French PW's amongst the Russians. In order to alleviate these conditions, I went to the Weidkamp kitchen on the 17th, on instructions from Herr Theile, and talked to the head of the kitchen, Fraulein Block, about the prevision of the midday meal. Fraulein Blocks promised me the food immediately and also lent me the 22 sets of eating utensils which I asked for.
"At the some time I asked Fraulein Block to give any food left over by the Leo Dutchmen messing there to our Russian PW's at midday until further notice. Fraulein Block promised to do this too, and the following midday she sent down a container of milk soup as an extra. The following midday the ration was short in quantity. Since a few Russians had collapsed already, I telephoned Fraulein Block and asked for an increase in the food as the special ration had ceased iron the second day onwards.
As my telephone conversation was unsuccessful, I again visited Fraulein Block personally. Fraulein Block refused in a very abrupt manner to give upon further special ration.
"Now, regarding the discussion in detail, Herr Prior, two other gentlemen of the DAF and Fraulein Block, head of the Weidkamp Kitchen, were present in the room. Herr Prior commenced and accused me, gesticulating in a very insulting manner, saying that I had taken the part of the Bolsheviks in too apparent a way. He referred to the law paragraphs of the Reich Government which spoke against it. I was unfortunately not clear about the legal position, otherwise I would have left the conference room immediately. I then tried to make it clear to Herr Prior, with special emphasis, that the Russian PW's were assigned to us as workers and not as Bolsheviks; the people were starved and were not in a position to perform the heavy work with us in boiler making which they were supposed to do; sick people are a liability to us and not a help to production. To this remark Herr Prior stated that if one was worth nothing, then another was, that the Bolsheviks were soulless people, and if 100,000 of them die , another 100,000 would replace them. On my remarking that with such a coming and going we would not attain our goal, namely the delivery of locomotives to the Reich railways which were continually cutting down the time limit, Herr Prior said, 'Deliveries are only of secondary importance here.'
"My attempts to get Herr Prior to understand our economic needs were now successful. In closing, I can only say that as a German I know our relations to the Russian prisoners of war exactly, and in the a/m case I dealt only on behalf of my superiors and in the sense of the increase in production which is demanded from us."
It is signed, "Soehling, Office Chief, Locomotive Construction Works."
by Theile:
" I have the following to add to the above letter; After the Russian P.W.'s had been assigned to as on the 16th of this month by Labour Supply, I got into touch with Dr. Lehmann immediately about their food. I learned from him that the prisoners received 300 gr. of bread each between 4 a.m. and 5 a.m. I pointed out that it was impossible to lost until 1800 hours on this ration of bread, whereupon Dr. Lehmann said that the Russians must not be allowed to get used to the Western European feeding. I replied that the P.W.'s could not do the work required of them inthe Boiler Construction Shop on that food and that it was not practical for us to have these people in the works any longer under such conditions. At the same time I demanded that if the Russians continued to be employed, they should be given a hot midday meal and that if possible the bread ration should be split so that one half was distributed early in the morning and the second half during our breakfast break. My suggestion has already been carried out by us with the French P.W.'s and has proved to be very practical and good.
"Unfortunately, however, Dr. Lehmann took no notice of my suggestion and on this account I naturally had to take matters into my own hands and therefore told Herr Sohling to get the feeding of the Russian P.W.'s organized on exactly the same lines asFrench P.W.'s so that the Russians could as soon as possible carry out the work they were supposed to do. For the whole thing concerns an increase in production such as is demanded from us by the Minister of Munitions and Armaments and by the D.A.F." of the locomotive construction works was not entirely a necessary position in the interests of production? achieve good production. I said yesterday that every head of a concern and I, as theleader, were interested in having well-fed and satisfied workers, because badly fed, dissatisfied workers make more mistakes.
I should like to comment on this document. The document is dated 25 February 1942.
At that time there were official instructions that the Russian prisoners of war and the Russian foreign workers who came to the Reich were treated worse than the Western workers. I learned of this through complaints from the heads of concerns. In my document bock, from the middle of March 1942--three or four weeks after this document--thereis a Fuehrer protocol in which I called Hitler's attention to the fact that the feeding of Russian workers was absolutely inadequate and that they would have to be given an adequate diet and that, moreover, the Russian workers were being kept behind barbed wire like prisoners of war and that that would have to be stopped also. The protocol shows thatin both cases that I succeeded with Hitler in having conditions improved, and they were changed. Sauckel that he fought against thelack of understanding and did everything so that the foregin workers and prisoners of war would be treated better and receive decent food. I am going to ask you, if you are not responsible and Sauckel is not responsible, who is responsible for these conditions, and you can keep in mind that is the question that we are coming up to here. would be Exhibit USA-394-A--a statement taken by the British-American team in the investigation of this work camp at Krupp's.
Well, D-321. I can use that just as well. We will use Document D-321, which becomes 894.
THE PRESIDENT: 894 was the last number you gave us.
MR. JUSTICE JACKSON: 398 was 894. 321 will be 895. BY MR. JUSTICE JACKSON: None of these investigations, I may say, is based upon the statements of the prisoners themselves.
"I, the undersigned, Adam Schmidt, employed as Betriebswart in the Essen-West Railway Station and residing--" He states his residence-
--"make the following statement voluntarily and on oath.
"I have been employed by the Reichs Railway since 1918 and have been at Essen West Station since 1935. In the middle of 1941 the first workers arrived fromPoland, Galicia and Polish Ukraine. They came to Essen in goodswaggons in which potatoes, building materials and also cattle have been transported, were brought to perform work at Krupp.
The tracks were jammed full with people. My personal view was that it was inhuman to transport people in such a matter. The people were squashed closely together and they had no room for free movement. The Krupp overseers laid special value on the speed the slave workers got in and out of the train. It was enraging to every decent German who had to watch this, to see how the people were beaten and kicked and generally maltreated in a brutal manner. In the very beginning as the first transports arrived, we could see how inhumanly these people were treated. Every waggon was so overfilled that it was incredible that such a number could be jammed into one waggon. I could see with my own eyes that sick people who could scarcely walk (they were mostly people with foot trouble, injured and also people with internal trouble) were taken to work. One could see that it was sometimes difficult for them to move themselves. The same can be said for the Eastern workers and P.W.'s who came to Essen in the middle of 1942."
He then describes their clothing and then describes their food. In the interests of time, I will not attempt to read the entire thing.
Do you consider that that, too, is an exaggerated statement? doubtlessly bad, but I know from Sauckel that during the time of his activity, much was done to clothe these workers better, and in Germany many of the Russian workers were put in a considerably better condition than they had been previously in Russia. The Russian workers were quite satisfied in Germany. If they arrived here in rags, that does not mean that that was our fault. We could not use ragged workers with poor shoes in industry, so conditions were improved.
THE PRESIDENT: Well, before you pass from that, what do you say about the conditions of the transports? The question you were asked was whether this was an exaggerated account. You have not answered that except in reference to clothing.
THE WITNESS: Mr. President, I can not give any information about this transport matter. I received no reports about it.
BY MR. JUSTICE JACKSON:
Q Well, I will ask you about Exhibit 398, which becomes 894. I mean Document 398, which becomes Exhibit 894, a statement by Alors Hoefer, living in Essen:
"I worked with Lowenkamp in armour building shop No. 4 since April 1943. Lowenkamp was very brutal to the foreigners. He confiscated food which belonged to the P.W.'s and took it home. Every day he mishandled Eastern workers, Russian P.W.'s, French, Italian, and other foreign civilian persons. He had a steel box built which was so snail that one could hardly stand in it. He locked foreigners in the box, also females, up to 48 hours without giving the people food. They were not released in order to relieve nature. It was forbidden for other people either to give any help to the persons locked in, or release then. Whilst clearing an unofficial camp, he fired on fleeing Russian civilians without hitting any of then.
"One day, whilst distributing food, I saw how he hit a French civilian in the face with a ladle and made his face bleed. Further, he delivered Russian girls without bothering about the children afterwards. There was never any milk for them so the Russians had fro nourish the children with sugar water. When Lowenkamp was arrested he wrote two letters and sent them to me via his wife. He tried to make out that he never hit people." it into the record.
Is it your view that that is exaggerated?
A I consider this affidavit a lie. I should like to say that in the German people such a thing does not exist, and if such individual cases occurred they were punished. It is not possible to drag the German people through the dirt in this way. The heads of concerns were also decent people who worried about their work. If the head of the Krupp concern had heard about that, he would have taken steps immediately.
Q Well, what about the steel boxes? The steel boxes couldn't have been built? Or don't you believe the steel-box story?
A No, I don't believe it; I don't believe it. After the collapse in 1945 a lot of affidavits were drawn up, certainly, which do not correspond to the truth. That is not your fault. However, after a defeat, it is quite possible that people do things like this.
Q Well, I would like to have you examine document 258. I attach importance to this as establishing the SS as being the guards;
"The camp inmates were mostly Jewish women and girls from Hungary and Roumania. The camp inmates were brought to Essen at the beginning of 1944 and were put to work at Krupps. The accommodation and feeding of the camp prisoners was beneath all dignity. At first the prisoners were accommodated in simple wooden huts. These huts were burned down during an air raid and from that time on the prisoners had to sleep in a damp cellar. Their beds were made on the fleer and consisted of a straw-filled sack and two blankers. In most cases it was not possible for the prisoners to wash themselves daily, as there was no water. There was no possibility of having a bath.
"I could often observe from the Krupp factory, during the lunch break, how the prisoners boiled their under-clothing in an old bucket or container over a wood fire, and cleaned themselves.
A slit trench served as an airraid shelter, whilst the SS guards went to the Humboldt shelter, which was bomb-proof.
"Reveille was at 5 a.m. There was no coffee or any food served in the morning. They marched off to the factory at 5.15.a.m. They marched for three quarters of an hour to the factory, poorly clothed and badly shed, some without shoes, and covered with a blanker, by rain or snow. Work began at 6.a.m The lunch break was from 12 to 12.30. Only during the break was it at all possible for the prisoners to cook something for themselves from potato peelings and other garbage.
"The daily working period was one of ten to eleven hours. Although the prisoners were completely undernourished, their work was very heavy physically. The prisoners were often maltreated at their work benches by Nazi overseers and female SS guards. At 5 or 6 in the afternoon they were marched back to the camp. The accompanying guards consisted of female SS who, in spite of protests from the civil population, often maltreated the prisoners on the way back by kicks, blows and scarcely repeatabl words. It often happened that individual women or girls had to be carried back to the camp by their comrades owing to exhaustion. At 6 or 7 p.m. these exhausted people arrived back in camp. Then the real midday meal was distributed. This consisted of cabbage soup. This was followed by the evening meal of water.
soup and a piece of bread which was for the following day. Occasionally the food on Sundays was better. An inspection of the coup as long as it existed was never undertaken by the firm of Krupp. On 13 March 1943, the camp prisoners were brought to Buchenwald Concentration Camp and from there some were sent to work. The camp commandant was SS O berscharfuehrer Rick."
The rest of it doesn't matter.
That, I suppose, in your estimation, is also an exaggeration?
DR. FLAECHSNER: Mr. P resident.
THE PRESIDENT: M ay I hear the answer? I thought the defendant said something.
DR. FLAECHSNER: M ay I call the attention of the Court to the document itself, of which I have only a copy? It is headed "Before a Military Court, under oath ", and there is simply a signature under it. It does not say that it is an affidavit or a statement in lieu of oath, or any such thing, it says only " Further inquiries must be instigated", and it is signed by Hubert Harden. That is apparently the name of the man who was making the statement. "Kriminalassistent on probation", police official. That is a man who might later become a candidate in the criminal service. He has signed it. Then there is another signature, "C. E..Long, Major President." that any of these three people want to vouch for the contents of this as an affidavit. I do not believe this document can be considered an affidavit in that sense, or can be used as such.
THE PRESIDENT: Yes, Mr. Justice J ackson? Do you wish to say anything?
MR. JUSTICE JACKSON: The document speaks for itself. As I have pointed out to this witness, I am giving him the result of an investigation. I am not charging him with personal 21 June M LJG 10-2a Daniels responsibility for these conditions.
I intend to ask him some questions about responsibility for conditions in the camp.
THE PRESIDENT: Well, where is a statement at the top of the copy that I have got, "Sworn on oath before a Military Court."
MR. JUSTICE JACKSON: Y es, they were taken in Essen, in this investigation. Of course, if I were charging this particular defendant with the responsibility there might be some argument about it. They clearly come under the head of the Charter, which authorizes the receipt here of proceedings of other courts.
THE PRESIDENT: H ave you got the original document?
MR. JUSTICE JACKSON: Yes.
(A document was submitted to the Tribunal.)
THE PRESIDENT: The Tribunal sees no objection to the document being used in cross examination.
Did you give it an exhibit number?
MR. JUSTICE JACKSON: I should have; it is 896.
THE PRESIDENT: Yes. BY MR. JUSTICE JACKSON:
Q I now want to call your attention to Exhibit No. 382 .
THE PRESIDENT: Mr. Justice Jackson, there are some photographs which have been put before us. Are they identified and do they form part of an exhibit?
MR. JUSTICE JACKSON: They form part of the exhibit which I am new offering.
THE PRESIDENT: I see.
MR. JUSTICE JACKSON: But the witness desires to comment on the last document, and I will listen to that before we go ahead. BY MR. Justice JACKSON:
Q Yes?
responsibility, in case those conditions were generally true, on the basis of my judgment yesterday, I would consider myself responsible. I do not want to evade responsibility. But the conditions were not such. These are only individual cases. from the document, it seems to be a concentration camp, one of the small concentration camps near the concerns. The concerns could not inspect these camps. That is why it is quite true where it says that the representatives of the concern never saw the camp. for foreign workers were guarded, refers to this document, then your conclusion wa s false. As far as I know, the other labor camps were not guarded by SS or by any other organizations. My position is such that I feel it is my duty to protect the head concerns from an injustice which might be done then. They could not concern themselves with conditions in such a camp.
I cannot say whether conditions were as described in this camp. We have seen much material on conditions in concentration cases here during the trial.
Q Now I will ask to have you shown Exhibit No. D-382 -- I should say Document D-382 -- which would be United States Exhibit 897. That is the statement of several as to one of these steel boxes which stood in the foreign workers' camp in the grounds of Number 4 Armor Shop, and those of the Russian cap. I do not know that it is necessary to read the complete descriptions. circumstance? every type of work. These photographs have no value as evidence.
Q Very well. I will ask to have you shown Exhibit D-230. D-230 is an inter-office record, and the steel switches which have been found in the camp will be shown to you, 80 of them, distributed, according to the reports.
A Shall I comment on this?
Those are nothing but replacements for rubber truncheons. We had no rubber; and for that reason, the guards probably had something like this. (Indicating") any more than your police. They did not use these steel rods any more than your police use their rubber truncheons, but they had to have something in their hands. That is the way it is everywhere in the world.
Q Well, we won't argue that point.
A I am not an expert. I only assume that that is the case. I cannot testify on oath that that was the case. That was only an argument.
THE PRESIDENT: Mr. Justice Jackson, did you give a number to that?
MR. JUSTICE JACKSON: 898, your Honor. BY MR. JUSTICE JACKSON: the Krupp hospitals. The subject is: "Cases of Deaths of Eastern Workers."
"Fifty-four Eastern workers have died in the hospital in Lazarettstrasse, four of them as the result of external causes and fifty as a result of illnesses.
"The causes of death in the case of these fifty Eastern workers who died of illnesses were the following:
"Tuberculosis: 38 "Malnutrition:
2 "Internal hemorrhage:
1 "Disease of the bowels:
2 "Typhus:
1 "Pneumonia:
3 "Appendicitis:
1 "Liver trouble:
1 "Abscess of the brain:
1 "This list therefore shows that four-fifths died of tuberculosis and malnutrition."
conditions of the labor which was engaged in your production program?
A First I should like to comment on the document. The document does not show that the total number of the deaths of workers was to due to that which these figures refer to, so that one cannot say whether that is an unnaturally high proportion of illness. At the session of the Central Planning Board which I read here, I observed it was said that the Russian workers had a high tuberculosis rate. I do not know whether you mean that. That was a remark which Weiger made to me. But presumably we tried through the health offices to alleviate these conditions. tuberculosis; there is no doubt about that, is there?
A I do not know whether that was an abnormal death rate. But there was an abnormally high rate of tuberculosis at times. abnormally high, but it shows an abnormal proportion of deaths from tuberculosis among the total deaths, does it not? Eighty per cent of deaths from tuberculosis is a very high incidence of tuberculosis, is it not?
A That may be. I cannot say from my own knowledge.
THE PRESIDENT: Did you give that a number? That would be 899, would it not?
MR. JUSTICE JACKSON: That is 899, your Honor. BY MR. JUSTICE JACKSON:
Q Now, let me ask you to be shown Document 335. That is a report from the files of Krupp dated at Essen, the 12th of June, 1944, directed to the "Gau Camp Doctor Herr Dr. Jaeger", and signed by Stinnesbeck:
"In the middle of May I took over the medical supervision of the P.W. Camp 1420 in the Noeggerathstrasse. The camp contains 644 French P.Ws.
"During the air raid on 27 April of this year the camp was largely destroyed and at the moment conditions are intolerable.
"315 prisoners are still accommodated in the camp. 170 of these are no longer in huts but in the tunnel in Grunertstrasse on the EssenNeuhlheim railway line. This tunnel is damp and is not suitable for continued accommodation of human being. The rest of theprisoners are accommodated in 10 different factories in Krupp's works.
"The first medical attention is given by a French military doctor who takes great pains with his follow countrymen. Sick people from Krupp's factories must be brought to the sick parade, too. This parade is held in the lavatory of a burned out public house outside the camp. The sleeping accomodations of the four French medical orderlies is in what was the urinal room. There is a double tier wooden bed available for sick bay patients. In general, treatment takes place in the open. In rainy weather it has to be hold in the small room. These are insufferable conditions. There are no chairs, tables, cupboard or water. The keeping of a register of sick people is impossible. Bandages and medical supplies are very scarce, although people badly hurt in the works are very often brought here for first aid and have to be bandaged here before being transported to the hospital. There are many strong complaints about food, too, which the guard personnel confirm as being justified.
"Illness and loss of manpower must be reckoned with under these circumstances.
"The construction of huts for the accommodation of the prisoners and the building of sick quarters for the proper treatment of the sick persons is urgently necessary.
"Please take the necessary stops.
"Signed. STINNESBECK". severe air raid. The conditions were the same in those cases for Germans and foreign workers. There were no beds, no cupboards, and so forth. That was because the camp in whichthese things had been provided had burned down. That the food supply was often inadequate during this period in the Ruhr District was due to the fact that the air-borne supplies, transportation, and food transports could not be brought in to the Ruhr to the necessary extent.
time, could be improved. We made every effort when conditions became worse after September or October of 1944, or rather after November of 1944, to give food supply priority over armament needs, so as to see to it that in view of these difficulties the workers would be fed, and the armament would have to be placed in the background. conditions of these workers? Do I understand that youdid it, that you took the steps? so. That is a general humane obligation. If one hears of such conditions, he tries to alleviate then, even if it is not his own responsibility. But the witness Riecke testified here that the whole food question was under the direction of the Food Ministry. proper condition to produce? That is elementary, is it not?
A No. That is wrongly formulated. nourishment of workers and the amount of production produced is. was distributed between the Food ministry, the health office in theReich Ministry of the Interior, the labor agencies, and so on and so forth. There was no comprehensive authority in my hands. In the Reich, in our state construction, we lacked a comprehensive agency, in the form of a Reich Chancellor, who would have directed all these departments and held joint discussions. these matters. However, when I learned from factory heads or from my deputies, I did everything to remove the cause for complaints.
THE PRESIDENT: Shall we break off now?
MR. JUSTICE JACKSON: Any time you say, sir, (A recess was taken until 1400 hours, the same day.)
(The hearing reconvened at 1400 hours, 21 June 1946.)
THE PRESIDENT: The Tribunal wish to hear from defendants' counsel what arrangements they have found it possible to make with reference to the apportionment of time for their speeches.
DR. NELTE: First of all, I should like to make it clear with reference to this question that the defendants' counsel with whom the Tribunal had spoken during an earlier closed session, having discussed the question of pleadings, have not made general reports to the remainder of the defendants' counsel since they had been under the impression that the Tribunal would not impose any limitation upon the defense. I personally, when I raised my objections, had no knowledge of this discussion and, as I may explain on behalf of my colleagues who have spoken to you earlier, that was the situation at the time. dant's counsel for the individual defendants have now discussed the resolution announced on the 14th of June 1946 and I am now submitting to the Tribunal the outcome of the discussion in connection with which I shall have to make certain limitations with reference to certain individual colleagues of mine who are partly not present and partly with reference to the estimate of time are of a different opinion.
The defendants' counsel are of the opinion that the decision regarding the shaping and length of their cases should entirely be left to the sense of duty of the individual defendants' counsel in this unusual trial, apart from the generally recognized rights and privileges of the Tribunal with regard to the steering of the procedure and the prevention of any possible misuse of the freedom of speech. Furthermore, the defendants' counsel are of the opinion that based on this principle consideration and also based on the usual practice before International Tribunals, it should be understood and approved by the Tribunal if the defense consider that they have objections to the prohylactic limitation of the freedom of speech since a misuse must not be taken as a foregone conclusion, this principal attitude of ours does not of course exclude the preparedness on the part of the defense, that the directive of the Tribunal and the wishes of the Tribunal should be obeyed as far as that can be carried with the proper conception of the defense of their duties.
Under this consideration, the individual defendants' counsel had been asked to make their own estimates of the duration of their probable verbal case which they wish to state. The outcome of these estimates is as follows, or rather, has shown that with due respect to the first discipline on the part of the defendants' counsel and with consideration of the wishes of the High Tribunal, a total duration of approximately twenty full days must be expected.
THE PRESIDENT: Dr. Nelte, the Tribunal asked Defense Counsel for an apportionment of the fourteen days between them.
DR. NELTE: I believe, Mr. President, that the statement which I have just made should express that it is apparently impossible that that principle can be accepted. If the Tribunal considers that the stated number of days is the indisputable period of time, then the entire defense will, of course, submit to that decision. But so far as I can see, it will be quite impossible that, under such circumstances, an agreement amongst the Defense Counsel could be brought about, and considerable danger therefore exists that the Counsel who come later with their cases will be under pressure of tier.
THE PRESIDENT: Yes, I think the Tribunal probably fully understands that you and your brothern consider that fourteen days is too short, but, as I say, what the Tribunal asked for was an apportionment of the time, and there is nothing in what you have said to indicate that you have made any apportionment at all, either of the fourteen days or of the twenty days which you propose.
DR. NELTE: The peiod of twenty days was arrived at because the individual defendants' counsel have stated the duration of their cases. It would, therefore, be perfectly possible for us to say that if the Tribunal would approve of the length of twenty days, then the expected length of the individual cases could be stated by us; but it is impossible, in practice, to do this if the total duration of time for the defense is fourteen days. You can rest assured, Mr. President, that we have all conscientiously gone into the question and that we have reflected on the manner in which the individual subjects can be divided up between the individual defendants' counsel; but the total duration of about twenty days appears to us, without wanting to quote a maximum or minimum in this connection, to be absolutely essential for apportionment. It is perfectly possible, Mr. President -