Chapter XXVIII: Book 11: , Page 26 of the German book. You remember this is the report (8)

“The camp inmates were mostly Jewish women and girls from
Hungary and Romania. The camp inmates were brought to Essen at
the beginning of 1944 and were put to work at Krupp’s. 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 floor and consisted of a
straw-filled sack and two blankets. 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. An
air-raid trench served as shelter, while the SS guards went to
the Humboldt shelter, which was bombproof. 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 shod, some without shoes, and covered with a blanket, in
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 10 or 11
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
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 with kicks, blows, and scarcely
repeatable 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 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. As long as it
existed there was never any inspection of the camp by the firm
of Krupp. On 13 March 1945 the camp prisoners were brought to
Buchenwald Concentration Camp, from there some were sent to
work. The camp commandant was SS Oberscharführer Rick. His
present whereabouts is unknown.”

The rest of it doesn’t matter. In your estimation that, I suppose, is also an exaggeration?

SPEER: From the document...

DR. FLÄCHSNER: Mr. President...

THE PRESIDENT: May I hear the answer. I thought the defendant said something.

DR. FLÄCHSNER; May I call the attention of the Court to the document itself, of which I have only a copy? It is headed “Sworn on oath before a military court,” and there is an ordinary signature under it. It does not say that it is an affidavit or a statement in lieu of oath, or any other such thing, it says only, “Further inquiries must be made,” and it is signed by Hubert Karden. That is apparently the name of the man who was making the statement. Then there is another signature, “Kriminalassistent Z. Pr.” That is a police official who is on probation and who may later have the chance of becoming a candidate in the criminal service. He has signed it. Then there is another signature, “C. E. Long, Major, President.” There is not a word in this document to the effect 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 used as an affidavit in that sense.

THE PRESIDENT: Yes, Mr. Justice Jackson? Do you wish to say anything?

MR. JUSTICE JACKSON: I—the document shows for itself. I am not—as I have pointed out to this witness, I am giving him the result of an investigation. I am not prosecuting him with personal responsibility for these conditions. I intend to ask him some questions about responsibility for conditions in the camp.

THE PRESIDENT: Well, there is a statement at the top of the copy that I have got, “Sworn on oath before a military court.”

MR. JUSTICE JACKSON: Yes, they were taken in Essen, in this investigation. And of course, if I were charging this particular defendant with the responsibility there might be some argument about it. They come under the head—they clearly come under the head of the Charter, which authorizes the receipt here of proceedings of other courts.

THE PRESIDENT: Have you got the original document here?

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 USA-896.

THE PRESIDENT: Yes.

MR. JUSTICE JACKSON: [_Turning to the defendant._] I now want to call your attention to Exhibit Number 382.

SPEER: I wanted to comment on the document.

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 now 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.

Yes?

SPEER: First I should like to say, as you have so often mentioned my nonresponsibility, that if in general these conditions had been true, on the basis of my statement yesterday I should consider myself responsible. I refuse to evade responsibility. But the conditions were not what they are said to have been here. There are only individual cases which are quoted.

As for this document I should only like to say from what I have seen of it that this seems to concern a concentration camp, one of the small concentration camps near the factories. The factories could not inspect these camps. That is why the sentence is quite true where it says that no factory representative ever saw the camp. The fact that there were SS guards also shows that it was a concentration camp.

If the question which you asked me before, as to whether the labor camps were guarded—those for foreign workers—if that refers to this document, then your conclusion was wrong. For 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 heads of plants from any injustice which might be done them. The head of a plant could not bother about the conditions in such a camp. I cannot say whether conditions were as described in this camp. We have seen so much material on conditions in concentration camps during the Trial.

MR. JUSTICE JACKSON: Now I will ask to have you shown Exhibit Number D-382—I should say Document D-382—which would be United States Exhibit 897. Now that is the statement of several persons as to one of those steel boxes which stood in the foreign workers’ camp in the grounds of Number 4 Armor Shop, and of those in the Russian camp. I do not know that it is necessary to read the complete descriptions.

Is that merely an individual instance, or what is your view of that circumstance?

SPEER: What is pictured here is quite a normal locker as was used in every factory. These photographs have absolutely no value as evidence.

MR. JUSTICE JACKSON: Very well. I will ask to have you shown Exhibit D-230. Together with D-230 is an interoffice record of the steel switches, and the steel switches which have been found in the camp will be shown to you. Eighty were distributed, according to the reports.

SPEER: Shall I comment on this?

MR. JUSTICE JACKSON: If you wish.

SPEER: Yes. Those are nothing but replacements for rubber truncheons. We had no rubber; and for that reason, the guards probably had something like this.

MR. JUSTICE JACKSON: That is the same inference that I drew from the document.

SPEER: Yes, but the guards did not immediately use these steel switches any more than your police use their rubber truncheons. But they had to have something in their hands. It is the same thing all over the world.

MR. JUSTICE JACKSON: Well, we won’t argue that point.

SPEER: 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: Did you give a number to that?

MR. JUSTICE JACKSON: 898, Your Honor.

Now, 899 would be our Document D-283, which is a 1943 report from the Krupp hospitals taken from the files of Krupp’s.

“The subject:

“Cases of Deaths of Eastern Workers.

“Fifty-four Eastern Workers have died in the hospital in
Lazarettstrasse, 4 of them as a result of external causes and 50
as a result of illness.

“The causes of death in the case of these 50 Eastern Workers who
died of illnesses were the following: Tuberculosis, 36
(including 2 women); malnutrition, 2; internal hemorrhage, 1;
disease of the bowels, 2; typhoid fever, 1 (female); pneumonia,
3; appendicitis, 1 (female); liver trouble, 1; abscess of the
brain, 1. This list therefore shows that four-fifths died of
tuberculosis and malnutrition.”

Now, did you have any reports from time to time as to the health conditions of the labor which was engaged in your production program?

SPEER: First I should like to comment on the document. The document does not show the total number of the workers to which the number of deaths refers, so that one cannot say whether that is an unnaturally high proportion of illness. At a session of the Central Planning Board which I read here again, I observed it was said that among the Russian workers there was a high rate of tuberculosis. I do not know whether you mean that. That was a remark which Weiger made to me. But presumably through the health offices we tried to alleviate these conditions.

MR. JUSTICE JACKSON: There was an abnormally high rate of deaths from tuberculosis; there is no doubt about that, is there?

SPEER: I do not know whether that was an abnormal death rate. But there was an abnormally high rate of tuberculosis at times.

MR. JUSTICE JACKSON: Well, the exhibit does not show whether the death rate itself was abnormally high, but it shows an abnormal proportion of deaths from tuberculosis among the total deaths, does it not? Eighty percent deaths from tuberculosis is a very high incidence of tuberculosis, is it not?

SPEER: That may be. I cannot say from my own knowledge.

MR. JUSTICE JACKSON: Now I would like to have you shown...

THE PRESIDENT: Did you give that a number? That would be 899, would it not?

MR. JUSTICE JACKSON: 899, Your Honor.

Now, let me ask you to be shown Document D-335. This is a report from the files of Krupp, dated at Essen on 12 June 1944, directed to the “Gau Camp Physician, Herr Dr. Jäger,” and signed by Stinnesbeck:

“In the middle of May I took over the medical supervision of the
PW Camp 1420 in the Nörggerathstrasse. The camp contains 644
French PW’s.

“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 Grunerstrasse on the
Essen-Mülheim railway line. This tunnel is damp and is not
suitable for continued accommodation of human beings. The rest
of the prisoners are accommodated in 10 different factories in
Krupp’s works.

“Medical attention is given by a French military doctor who
takes great pains with his fellow 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 accommodations 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 held in this small room. These are insufferable
conditions! There are no chairs, tables, cupboards, or water.
The keeping of a register of sick is impossible.

“Bandages and medical supplies are very scarce, although people
badly hurt in the works are often brought here for first aid and
have to be bandaged before being taken to the hospital. There
are many strong complaints about food, too, which the guard
personnel confirm as being justified.

“Illness and less 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 steps.

“(Signed) Stinnesbeck.”

SPEER: That is a document which shows what conditions can be after severe air raids. The conditions were the same in these cases for Germans and foreign workers. There were no beds, no cupboards, and so forth. That was because the camp in which these things had been provided had been burned down. That the food supply was often inadequate in the Ruhr district during this period was due to the fact that attacks from the air were centered on communication lines, so that food transports could not be brought into the Ruhr to the necessary extent. These were temporary conditions which we were able to improve when the air raids ceased for a time. When conditions became even worse after September or October of 1944, or rather after November of 1944, we made every effort to give food supplies the priority for the first time over armament needs, so that in view of these difficulties the workers would be fed first of all, while armaments had to stand back somewhat.

MR. JUSTICE JACKSON: Well, then you did make it your business to get food and to see to the conditions of these workers? Do I understand that you did it, that you took steps?

SPEER: It is true that I did so, and I am glad that I did, even if I am to be reproached for it. For it is a universal human obligation when one hears of such conditions to try to alleviate them, even if it is somebody else’s responsibility. But the witness Riecke testified here that the whole of the food question was under the direction of the Food Ministry.

MR. JUSTICE JACKSON: And it was an essential part of production, was it not, to keep workers in proper condition to produce? That is elementary, is it not?

SPEER: No. That is wrongly formulated.

MR. JUSTICE JACKSON: Well, you formulate it for me as to what the relation is between the nourishment of workers and the amount of production produced.

SPEER: I said yesterday that the responsibility for labor conditions was divided up between the Food Ministry, the Health Office in the Reich Ministry of the Interior, the Labor Trustee in the office of the Plenipotentiary General for the Allocation of Labor, and so on. There was no comprehensive authority in my hands. In the Reich, because of the way in which our state machine was built up, we lacked a comprehensive agency in the form of a Reich Chancellor, who would have gathered all these departments together and held joint discussions. But I, as the man responsible for production, had no responsibility in these matters. However, when I heard complaints from factory heads or from my deputies, I did everything to remove the cause of the complaints.

MR. JUSTICE JACKSON: The Krupp works...

THE PRESIDENT: Shall we break off now?

MR. JUSTICE JACKSON: Any time you say, Sir.

[_The Tribunal recessed until 1400 hours._]

_Afternoon Session_

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: I should like first of all to point out that the defendants’ counsel, with whom the Tribunal discussed the question of final defense speeches during an earlier closed session, did not inform the other defendants’ counsel, since they were under the impression that the Tribunal would not impose any restrictions on the Defense in this respect. I personally, when I raised my objections, had no knowledge of this discussion, as my colleagues who conferred with you earlier have authorized me to explain.

On the suggestion of the Tribunal, counsel for the individual defendants have discussed the decision announced in the session of 13 June 1946, and I am now submitting to the Tribunal the outcome of the discussion; in doing so, however, I shall have to make certain qualifications, since some of my colleagues are either not present or differ in their opinion on the apportionment of time.

The defendants’ counsel are of the opinion that only the conscientious judgment of each counsel can determine the form and length of the final defense pleas in this unusual Trial, notwithstanding the generally recognized right of the Tribunal, as part of its responsibility for guiding the proceedings, to prevent a possible misuse of the freedom of speech. They also believe that, in view of this fundamental consideration and in view of the usual practice of international courts, the Tribunal will understand and approve that the defendants’ counsel voice their objection to a preventive restriction of the freedom of speech, for a misuse on their part must not simply be taken as a foregone conclusion. This fundamental attitude is, of course, in accord with the readiness of the Defense to comply with the directives and the wishes of the Tribunal as far as is reconcilable with a proper conception of the defense in each case. Under this aspect the individual defendants’ counsel have been asked to make their own estimates of the probable duration of their final pleas. The result of these estimates shows that, despite the limitations counsel have imposed upon themselves, and with due respect to the wishes of the High Tribunal, a total duration of approximately 20 full days in court is required by the Defense.

THE PRESIDENT: Dr. Nelte, the Tribunal asked Defense Counsel for an apportionment of the 14 days between them.

DR. NELTE: I believe, Mr. President, my statement makes clear that it appears impossible to accept that principle. If the Tribunal consider these 14 full days as indisputable, then the entire Defense will submit to that decision. But so far as I know, it will be quite impossible, under such circumstances, to obtain agreement among Defense Counsel, and considerable danger therefore exists that counsel who make their pleas later will be under pressure of time.

THE PRESIDENT: Yes, I think the Tribunal probably fully understands that you think 14 days—you and your brethren consider that 14 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 14 days or of the 20 days which you propose.

DR. NELTE: The period of 20 days was arrived at when each defendant’s counsel had stated the presumed duration of his speech. It would, therefore, be perfectly possible to say that if the Tribunal would approve the duration of 20 days, then we could state our solution for the length of the individual speeches. But it is impossible, in practice, to apportion the time, if the total number of days is only 14. You can rest assured, Mr. President, that we have all gone into the question conscientiously and that we have also reflected on the manner in which individual subjects can be divided among individual defendants’ counsel; but the total number of about 20 days appears to us, without wanting to quote a maximum or minimum figure, to be absolutely essential for an apportionment. It is perfectly possible, Mr. President, that in the course of the speeches...

THE PRESIDENT: Dr. Nelte, as I have indicated to you, what the Tribunal wanted to know was the apportionment, and presumably you have some apportionment which adds up to the 20 days which you say is required; and the Tribunal would like, if you have such an apportionment, that you should let them see the apportionment, or if you have no such apportionment, then they would wish to hear from each individual counsel how long he thinks he is going to take. If you have got a list, it seems to the Tribunal that you could hand it in.

DR. NELTE: The figures are available and they will be handed to the Tribunal, but some of my colleagues have said that their estimates are only valid on the assumption that no more than a specific number of days was to be granted. That is the point of view of which I said earlier that it differed in some respect. But we all thought that the decision of the Tribunal was only a suggestion, and not a maximum to be apportioned. I hope, Mr. President, that your words now are also to be understood in that way, and that the Tribunal will still consider whether the proposed period of 14 days could not be extended to correspond with the time which we consider necessary.

THE PRESIDENT: What the Tribunal wants is an apportionment of the time as between the various counsel. That is what they asked for and that is what they want; and either we would ask you to give it to us in writing now, or we would ask you, each one of you, to state how long you anticipate you will take in your speech.

DR. NELTE: I think that I may speak on behalf of my colleagues and say that we shall submit our estimates to the Tribunal in writing.

THE PRESIDENT: Dr. Nelte, the Tribunal feels that it would like to have the apportionment now. It gave notice before, yesterday I think it was, that they were wishing to hear defendants’ counsel upon the question of the apportionment this afternoon at 2 o’clock; and they would, therefore, like to have that apportionment now.

DR. NELTE: In that case, I can only ask that the Tribunal hear each individual counsel, since naturally I cannot say from memory how each made his estimate.

THE PRESIDENT: You could have had it written down; but if you have not got it written down, no doubt you cannot remember. But perhaps you had better give us what you would take.

DR. NELTE: I estimated 7 hours. My colleague Horn, for Ribbentrop, just tells me he requires 6 hours.

THE PRESIDENT: We will take each counsel in turn, if you please.

Yes, Dr. Stahmer?

DR. OTTO STAHMER (Counsel for Defendant Göring): Seven hours.

THE PRESIDENT: Dr. Sauter?

DR. MARTIN HORN (Counsel for Defendant Von Ribbentrop): May I, on behalf of Dr. Siemers and Dr. Kranzbühler, ask to allot each of them 8 hours?

DR. SAUTER: For the case of Funk, 6 hours, and for the case of Von Schirach, 6 hours.

DR. SERVATIUS: For Sauckel, 5 hours.

THE PRESIDENT: Wait a minute. I cannot write as quickly as all this. Who was it that Dr. Horn wished to represent? Siemers and who else? And how many hours was it?

DR. HORN: Dr. Siemers and Dr. Kranzbühler, 8 hours each.

DR. SERVATIUS: For Sauckel, 5 hours.

DR. KAUFFMANN: For Kaltenbrunner, approximately 4 to 5 hours.

DR. HANNS MARX (Counsel for Defendant Streicher): For Streicher, 4 hours.

DR. SEIDL: For Hess and Frank, 11 hours together.

DR. OTTO PANNENBECKER (Counsel for Defendant Frick): For Frick, 5 hours. I remember from the list that Dr. Bergold wants 3 hours for Bormann. Dr. Bergold is not present, but I remember that the list said 3 hours.

DR. RUDOLF DIX (Counsel for Defendant Schacht): For Schacht, 5 hours.

PROFESSOR DR. FRANZ EXNER (Counsel for Defendant Jodl): For Jodl, 5 hours.

DR. KUBUSCHOK: For Papen, approximately 5 hours.

DR. STEINBAUER: For Dr. Seyss-Inquart, 5 hours.

DR. FLÄCHSNER: For Speer, 4 hours.

DR. VON LÜDINGHAUSEN: For myself, Mr. President, 8 hours. For Professor Jahrreiss, who before the final pleas will deal with a technical subject, 4 hours.

THE PRESIDENT: What will Professor Jahrreiss speak about?

DR. VON LÜDINGHAUSEN: About a subject approved by the Tribunal, namely the general question of international law.

DR. SEIDL: The defense counsel for the Defendant Rosenberg said that he would require 8 hours.

DR. FRITZ: Mr. President, I would ask the Tribunal to take into consideration that the case of Fritzsche has not yet been presented and that therefore I cannot give exact information; but I estimate approximately 4 hours.

THE PRESIDENT: Now, Dr. Nelte, the Tribunal would like to know first of all whether counsel propose to write down and then read their speeches.

DR. NELTE: As far as I have been informed, all defense counsel will write down their speeches before delivery. Whether they will actually read every word of the text, or whether they will read parts of it and submit other parts, is not yet certain.

THE PRESIDENT: Have they considered whether they will submit them for translation, because, as the Tribunal has already pointed out, it would be much more convenient for the members of the Tribunal who do not read German to have a translation before them. It would not only greatly assist the Tribunal, but the defendants themselves if they do that.

DR. NELTE: This question has not yet been settled. We discussed it, but have so far not come to a final conclusion. We think that the short time now available may perhaps make it impossible to translate the manuscripts into all four languages.

THE PRESIDENT: The defendants’ counsel, of course, understand that the speeches, if they are submitted for translation, will not be communicated to anybody until the speech is actually made. So they will not be given beforehand either to the Tribunal or the Prosecution or anything of that sort, so that the speech will remain entirely private until it is made. And the second thing is that, of course, a great number of the speeches will be delayed by the counsel who precede them and, therefore, there will be very considerable time during either the 14 days or some longer period, if such a longer period is given, which will enable the speeches to be translated, and Defense Counsel will appreciate that if their speeches are written down they can tell exactly how long they will take to deliver, or almost exactly.

And there is one other thing I want to bring to their attention. There are 20 or 21 defendants, and naturally, there are a variety of subjects which are common to them all; and there ought to be, therefore, an opportunity, as it appears to the Tribunal, for counsel to divide up the subjects to some extent between them and not each one to deal with subjects which have been dealt with already, any more than they ought to have been dealt with in evidence over and over again; and I do not know whether Counsel for Defense have fully considered that in making this estimate of the time they laid before us.

Anyway, the Tribunal hopes that they will address their minds to these three matters: First of all, as to whether they can submit their speeches for translation in order to help the Tribunal; secondly, whether they will be able, when they have got their speeches written down, to assess the time accurately; and thirdly, whether they cannot apportion the subjects to some extent among them so that we shall not have to listen to the same subjects over and over again.

I do not know whether the Prosecution would wish to say anything. The Tribunal has said, I think, in the order which we made with reference to this question of limitation of time, that they anticipated, that the Prosecution would take only 3 days. Perhaps it would be convenient to hear from the Prosecution whether that is an accurate estimate.

SIR DAVID MAXWELL-FYFE: Yes, My Lord, the Prosecution do not ask for any more than the 3 days. It might conceivably be a little less, but we do not ask for any more than the 3 days.

MR. JUSTICE JACKSON: I should like, Your Honor, to call your attention to this. I hope it is not expected that we will mimeograph and run off on our mimeograph machines, 20 days of speeches or anything of that sort. We simply cannot be put under that kind of a burden. I think it is—a citizen of the United States is expected to argue his case in the highest court of the land in one hour, and counsel’s own clients here have openly scoffed at the amount of time that has been asked. This is not a sensible amount of time to give to this case, and I must protest against being expected to mimeograph 20 days of speeches. It really is not possible.

THE PRESIDENT: The Tribunal would like to know whether the Prosecution intend to let them have copies of their speeches at the time that they are delivered.

SIR DAVID MAXWELL-FYFE: As far as the closing speech of the Attorney General is concerned, we certainly did expect and hope to give the Tribunal copies of the speech.

THE PRESIDENT: And translations?

SIR DAVID MAXWELL-FYFE: Yes, that will be done. My Lord, I just wondered, out of optimism—it was Dr. Nelte who said that it would take a long time to translate. I know, as far as translating into English is concerned, we had the problem of a 76-page speech the other day, and that was done by our own translators in one day. So I hope that perhaps Dr. Nelte has been a little pessimistic about that side of the problem.

THE PRESIDENT: The Tribunal will consider the matter.

Now, the Tribunal will go on with the cross-examination.

[_The Defendant Speer resumed the stand._]

MR. JUSTICE JACKSON: I think perhaps, Your Honor, the photographs in evidence are left a little unintelligible, if the record does not show the description of them. I shall read it briefly.

“Torture cabinets which were used in the foreign workers’ camp
in the grounds of Number 4 Armor Shop and those in the dirty
neglected Russian Camp were shown to us, and we depose the
following on oath:

“Photograph ‘A’ shows an iron cupboard which was specially
manufactured by the firm of Krupp to torture Russian civilian
workers to an extent that cannot possibly be described by words.
Men and women were often locked into a compartment of the
cupboard, in which hardly any man could stand up for long
periods. The measurements of this compartment are: Height 1.52
meters; breadth and depth 40 to 50 centimeters each. Frequently
even two people were kicked and pressed into one compartment.
The Russian....”

I will not read the rest of that.

“Photograph ‘B’ shows the same cupboard as it looks when it is
locked.

“Photograph ‘C’ shows the cupboard open.

“In Photograph ‘D’ we see the camp that was selected by the
Krupp Directorate to serve as living quarters for the Russian
civilian workers. The individual rooms were 2 to 2½ meters wide,
5 meters long, and 2 meters high. In each room up to 16 persons
were accommodated in double tier beds.” (Document USA-897)

I think that covers it.

THE PRESIDENT: Mr. Justice Jackson, one moment. I think you ought to read the last three lines of the second paragraph, beginning, “At the top of the cupboard....”

MR. JUSTICE JACKSON: Oh yes, I am sorry.

“At the top of the cupboard there are a few sievelike air holes
through which cold water was poured on the unfortunate victims
during the ice-cold winter.”

THE PRESIDENT: I think you should read the last three lines of the penultimate paragraph in view of what the defendant said about the evidence.

MR. JUSTICE JACKSON: “We are enclosing two letters which Camp
Commandant Löwenkamp had smuggled out of prison in order to
induce the undersigned Höfer to give evidence favorable to him.”

And perhaps I should read the last:

“The undersigned, Dahm,”—one of the signers—“personally saw
how three Russian civilian workers were locked into the
cupboard, two in one compartment, after they had first been
beaten on New Year’s Eve 1945. Two of the Russians had to stay
the whole of New Year’s Eve locked in the cupboard, and cold
water was poured on them as well.”

I may say to the Tribunal that we have upwards of a hundred different statements and depositions relating to the investigation of this camp. I am not suggesting offering them, because I think they would be cumulative, and I shall be satisfied with one more, D-313, which would become Exhibit USA-901, which is a statement by a doctor.

THE PRESIDENT: Mr. Justice Jackson, was this camp that you are referring to a concentration camp?

MR. JUSTICE JACKSON: Well, it was, as I understand it, a prisoner-of-war camp and a labor camp. There were labor camps and prisoner-of-war camps at Essen. I had not understood that it was a concentration camp, but I admit the distinction is a little thin at times.

This document reads:

“I, the undersigned, Dr. Apolinary Gotowicki, a physician in the
Polish Army, was taken prisoner by the Germans on 3 January 1941
and remained as such until the entry of the Americans. I gave
medical attention to the Russian, Polish, and French prisoners
of war who were forced to work in various places of Krupp’s
factories. I personally visited the Russian PW camp in the
Raumastrasse in Essen, which contained about 1,800 men. There
was a big hall in the camp which could house about 200 men
comfortably, in which 300 to 400 men were thrown together in
such a catastrophic manner that no medical treatment was
possible. The floor was cement and the mattresses on which the
people slept Were full of lice and bugs. Even on cold days the
room was never heated and it seemed to me, as a doctor, unworthy
of human beings that people should find themselves in such a
position. It was impossible to keep the place clean because of
the overcrowding of these men who had hardly room to move about
normally. Every day at least 10 people were brought to me whose
bodies were covered with bruises on account of the continual
beatings with rubber tubes, steel switches, or sticks. The
people were often writhing with agony and it was impossible for
me to give them even a little medical aid. In spite of the fact
that I protested, made complaints and petitions, it was
impossible for me to protect the people or see that they got a
day off from work. It was difficult for me to watch how such
suffering people could be dragged to do heavy work. I visited
personally, with danger to myself, gentlemen of the Krupp
administration, as well as gentlemen from the Krupp Directorate,
to try to get help. It was strictly forbidden, as the camp was
under the direction of the SS and Gestapo; and according to
well-known directives I had to keep silent, otherwise I might
have been sent to a concentration camp. I have brought my own
bread innumerable times to the camp in order to give it to the
prisoners, as far as it was possible, although bread was scarce
enough for me. From the beginning in 1941 conditions did not get
better, but worse. The food consisted of a watery soup which was
dirty and sandy, and often the prisoners of war had to eat
cabbage which was bad and stank. I could notice people daily
who, on account of hunger or ill-treatment, were slowly dying.
Dead people often lay for 2 or 3 days on the beds until their
bodies stank so badly that fellow prisoners took them outside
and buried them somewhere. The dishes out of which they ate were
also used as toilets because they were too tired or too weak
from hunger to get up and go outside. At 3 o’clock they were
wakened. The same dishes were then used to wash in and later for
eating out of. This matter was generally known. In spite of this
it was impossible for me to get even elementary help or
facilities in order to get rid of these epidemics, illnesses, or
cases of starvation. There can be no mention of medical aid for
the prisoners. I never received any medical supplies myself. In
1941 I alone had to look after these people from a medical point
of view; but it is quite understandable that it was impossible
for me as the only one to look after all of these people, and
apart from that, I had scarcely any medical supplies. I could
not think what to do with a number of 1,800 people who came to
me daily crying and complaining. I myself often collapsed daily,
and in spite of this I had to take everything upon myself and
watch how people perished and died. A report was never made as
to how the prisoners of war died.

“I have seen with my own eyes the prisoners coming back from
Krupp’s and how they collapsed on the march and had to be
wheeled back on barrows or carried by their comrades. It was in
such a manner that the people came back to the camp. The work
which they had to perform was very heavy and dangerous and many
cases happened where people had cut their fingers, hands or
legs. These accidents were very serious and the people came to
me and asked me for medical help. But it was not even possible
for me to keep them from work for a day or two, although I had
been to the Krupp Directorate and asked for permission to do so.
At the end of 1941, two people died daily, and in 1942 the
deaths increased to three and four per day.

“I was under Dr. May and I was often successful in getting him
to come to the camp to see the terrible conditions and listen to
the complaints, but it was not possible for him to get medical
aid from the Medical Department of the Armed Forces or Krupp’s,
or to get better conditions, treatment, or food. I was a witness
during a conversation with some Russian women who told me
personally that they were employed in Krupp’s factory and that
they were beaten daily in the most bestial manner. The food
consisted of watery soup which was dirty and inedible and its
terrible smell could be perceived from a distance. The clothing
was ragged and torn and on their feet they had rags and wooden
shoes. Their treatment, as far as I could make out, was the same
as that of the prisoners of war. Beating was the order of the
day. The conditions lasted for years, from the very beginning
until the day the American troops entered. The people lived in
great anxiety and it was dangerous for them to describe to
anyone anywhere the conditions which reigned in their camps. The
directions were such that they could have been murdered by any
one of the guards, the SS, or Gestapo if they noticed it. It was
possible for me as a doctor to talk to these people; they
trusted me and knew that I was a Pole and would never betray
them to anyone.

“Signed: Dr. Apolinary Gotowicki.”

[_Turning to the defendant._] Now you have explained that some of these conditions were due, in your judgment, to the fact that bombing took place and the billets of the prisoners and workers were destroyed.

SPEER: That is true, but I should like to point out that the conditions described in this affidavit cannot be considered as general; apart from that, I do not believe that this description is correct, but I cannot speak about these things since you will not expect me to be intimately acquainted with what happened in the camps of the firm of Krupp.

MR. JUSTICE JACKSON: Well, in the first place, was it considered proper by you to billet forced workers and prisoners of war so close to military targets as these prisoners were?

SPEER: I would rather not tell you here things which every German has at heart. No military targets were attacked, and the camps, therefore, could not be near military targets.

MR. JUSTICE JACKSON: You would not consider the Krupp plants proper targets?

SPEER: The camps were not in the Krupp works, they were near the city of Essen. On principle, we did not construct camps near the works which we expected would be bombed; and we did not want the camps to be destroyed.

MR. JUSTICE JACKSON: Did you notice that one of the photographs in evidence shows the camp directly against the works?

SPEER: May I see it again, please?

[_A photograph was shown to the defendant._]

Some large factory is recognizable in the background of this photograph, but that does not affect my statement that in almost all cases we constructed the camps outside the cities. I do not know why this particular instance is different, and I cannot even say whether this is a camp or just a hut for changing clothes, or anything which had to be near the camp. I still believe that these cabinets were cabinets for clothes, and this is one of the many huts which were necessary so that the workers could change clothes before and after their work. Any expert in Germany can tell you that these are wardrobes and not some special cabinets, because they are mass-produced articles; this is also confirmed by the fact that there are air vents at the top, for every wardrobe has these ventilation holes at the top and bottom.

MR. JUSTICE JACKSON: As production Minister, you were vitally interested in reducing the sickness rate among workers, were you not?

SPEER: I was interested in a high output of work, that is obvious; and in addition, in special cases...

MR. JUSTICE JACKSON: Well, special cases—part of production is in all cases, is it not, dependent upon the sickness rate of your labor force, and is it not a fact—as a man engaged in production you will know this—that the two greatest difficulties in manpower and production are sickness and rapid turnover, and that those factors reduce production?

SPEER: These two factors were disturbing for us, but not as extensively as your words might suggest. Cases of sickness made up a very small percentage which in my opinion was normal. However, propaganda pamphlets dropped from aircraft were telling the workers to feign illness, and detailed instructions were given to them on how to do it. And to prevent that, the authorities concerned introduced certain measures, which I considered proper.

MR. JUSTICE JACKSON: What were those measures?

SPEER: I cannot tell you in detail, because I myself did not institute these penalties, nor did I have the power to do so; but as far as I know, they were ordered by the Plenipotentiary General for the Allocation of Labor in collaboration with the Police or State authorities; but the jurisdiction in this connection was with the authorities responsible for legal action.

MR. JUSTICE JACKSON: Now, if you did not know what they were, how can you tell us that you approved of them? We always get to this blank wall that nobody knew what was being done. You knew that they were at least penalties of great severity, did you not?

SPEER: When I say that I approved I am only expressing my wish not to dodge my responsibility in this respect. But you must understand that a minister of production, particularly in view of the air attacks, had a tremendous task before him and that I could only take care of matters outside my own field if some particularly important factor forced me to do so. Otherwise, I was glad if I could finish my own work and, after all, my task was by no means a small one.

I think that if during the German air attacks on England you had asked the British Minister of Production whether he shared the worries of the Minister of Labor and whether he was dealing with them, then he would with justification have told you that he had something else to do at that time, that he had to keep up his production and that he expected the Minister of Labor to manage affairs in his sector; and no one would have raised a direct accusation against the British Minister of Production on that account.

MR. JUSTICE JACKSON: Well, production was your enterprise, and do you mean to tell me that you did not have any records or reports on the condition of the manpower which was engaged in production, which would tell you if there was anything wrong in the sick rate or anything wrong in the general conditions of the labor?

SPEER: What I knew is contained in the reports of the Central Planning Board; there you will get a picture of what I was told. Although there were many other meetings I cannot tell you in detail what I knew, because these were things outside my sphere of activity. Naturally, it is a matter of course that anyone closely concerned with the affairs of State will also hear of matters not immediately connected with his own sphere, and of unsatisfactory conditions existing in other sectors; but one is not obliged to deal with these conditions and later on one will not remember them in detail. You cannot expect that of me. But if you have any particular passage, I shall be glad to give you information on it.

MR. JUSTICE JACKSON: All right; assume that these conditions had been called to your attention and that they existed. With whom would you have taken it up to have them corrected? What officer of the Government?

SPEER: Normally, a minister would send a document to the Government authorities responsible for such conditions. I must claim for myself that when I heard of such deficiencies I tried to remedy them by establishing direct contact with the authority responsible, in some cases the German Labor Front, where I had a liaison officer, or in other cases my letter was transmitted to Sauckel through my office of manpower deployment. My practice in this respect was that if I did not receive a return report I considered the matter settled; for I could not then again pursue those things and make further inquiries whether they had been dealt with or not.

MR. JUSTICE JACKSON: With Krupp’s, then, you would not have taken it up? You think they had no responsibility for these conditions?

SPEER: During visits to Krupp’s discussions certainly took place on the conditions which generally existed for workers after air attacks; this was a source of great worry for us, particularly with regard to Krupp. I knew this well, but the reports from Krupp were not different from—I cannot remember ever being told that foreign workers or prisoners of war were in a particularly bad position. Temporarily they all lived under very primitive conditions; German workers lived in cellars during those days, and six or eight people were often quartered in a small basement room.

MR. JUSTICE JACKSON: Your statement some time ago that you had a certain responsibility as a Minister of the Government for the conditions—I should like to have you explain what responsibility you referred to when you say you assume a responsibility as a member of the Government.

SPEER: Do you mean the declaration I made yesterday that I...

MR. JUSTICE JACKSON: Your common responsibility, what do you mean by your common responsibility along with others?

SPEER: Oh, yes. In my opinion, a state functionary has two types of responsibility. One is the responsibility for his own sector and for that, of course, he is fully responsible. But above that I think that in decisive matters there is, and must be, among the leaders a common responsibility, for who is to bear responsibility for developments, if not the close associates of the head of State?

This common responsibility, however, can only be applied to fundamental matters, it cannot be applied to details connected with other ministries or other responsible departments, for otherwise the entire discipline in the life of the State would be quite confused, and no one would ever know who is individually responsible in a particular sphere. This individual responsibility in one’s own sphere must, at all events, be kept clear and distinct.

MR. JUSTICE JACKSON: Well, your point is, I take it, that you as a member of the Government and a leader in this period of time acknowledge a responsibility for its large policies, but not for all the details that occurred in their execution. Is that a fair statement of your position?

SPEER: Yes, indeed.

MR. JUSTICE JACKSON: I think that concludes the cross-examination.

THE PRESIDENT: Do any of the other prosecutors wish to cross-examine?

STATE COUNSELLOR OF JUSTICE M. Y. RAGINSKY (Assistant Prosecutor for the U.S.S.R.): Defendant Speer, when you told your biography to the Tribunal and answered the questions of Justice Jackson, I think you omitted some substantial matters. I would like to ask you a few questions.

SPEER: I left out such points as I did not wish to contest, since they are, at any rate, contained here in the documents; I would have a tremendous task if I were to go into all these points in detail.

MR. COUNSELLOR RAGINSKY: I would like to recall these points, and I would like to ask you to answer them briefly.

Did I understand you correctly that, in addition to your ministerial position, you were also the personal architect of Hitler after the death of Professor Todt? Did you hold this position?

SPEER: Yes.

MR. COUNSELLOR RAGINSKY: Were you Inspector General of Roads?

SPEER: Only after Dr. Todt’s death.

MR. COUNSELLOR RAGINSKY: Yes, of course. Were you Inspector General of Waterpower and Power Plants?

SPEER: Yes.

MR. COUNSELLOR RAGINSKY: Plenipotentiary for Building in the Central Administration of the Four Year Plan?

SPEER: Yes.

MR. COUNSELLOR RAGINSKY: Director of the Organization Todt?

SPEER: Yes.

MR. COUNSELLOR RAGINSKY: You were associated with the Technological Office of the National Socialist Party? You were the leader of the Union of National Socialist Technicians?

SPEER: Yes.

MR. COUNSELLOR RAGINSKY: And in addition to these posts, did you have any other leading positions?

SPEER: Oh, I had 10 or 12 positions. I cannot give you a list of them all now.

MR. COUNSELLOR RAGINSKY: Were you not one of the leaders of the Reich Chamber of Culture?

SPEER: No, no, that is not correct. I cannot tell you for certain, but I think I was a senator there or something like that.

MR. COUNSELLOR RAGINSKY: Were you a member of the presidency of the academy of culture? Were you a member of the presidency of the Academy of Arts?

SPEER: Yes, that also.

MR. COUNSELLOR RAGINSKY: I shall not mention the other posts you have held, in order to shorten the cross-examination. Do you remember your statements during the interrogation by Colonel Rosenblith on 14 November 1945?

SPEER: No, not in detail.

MR. COUNSELLOR RAGINSKY: I will remind you of one question, and will you tell me whether or not your answer was put down correctly. It was the question whether you acknowledged that in his book _Mein Kampf_ Hitler stated bluntly his aggressive plans for the countries of the East and West and, in particular, for the Soviet Union. You answered, “Yes, I acknowledge it.” Do you remember that?

SPEER: Yes, that is perfectly possible.

MR. COUNSELLOR RAGINSKY: And do you confirm that now?

SPEER: No.

MR. COUNSELLOR RAGINSKY: You do not confirm that now?

SPEER: I shall have to tell you that at the time I was ashamed to say that I had not read the whole of Mein Kampf. I thought that would sound rather absurd.

MR. COUNSELLOR RAGINSKY: All right, we shall not waste time. You were ashamed to admit that, or are you ashamed now? Let us go on to another question.

SPEER: Yes, I cheated at that time.

MR. COUNSELLOR RAGINSKY: You cheated at that time; maybe you are cheating now?

SPEER: No.

MR. COUNSELLOR RAGINSKY: It does not matter. You worked on the staff of Hess, did you not?

SPEER: Yes.

MR. COUNSELLOR RAGINSKY: You worked with Ley?

SPEER: Yes, in the Labor Front.

MR. COUNSELLOR RAGINSKY: Yes, the German Labor Front. You had a high rank in the Nazi Party, as you stated here today; you said that today in Court, did you not?

SPEER: No, it was not a high rank; it did not in any way correspond to the position which I occupied in the State.