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admirals of Hitler's making. These are men of special metal. They are Fascists in uniform, bound body and soul to the Nazi regime.

This is the only reason why Hitler gathered these men about him and collaborated with them for so long a period of time. This is the only way to explain why they collaborated with Hitler in committing such crimes unprecedented in history. They fitted and understood one another to perfection.


It is only natural that in speaking of the military group I would begin with defendant Keitel. Keitel held the leading post in Hitler's military machine from the very first years of its conception. Keitel's counsel admits that the decree (of February 4th 1938) gave Keitel the wonder title for his position—“Chief of the OKW". Further he goes on to say: "*** the factual significance of Keitel's activities was immense. It was a monstrous, extremely ungrateful job and its miserly remuneration was a brilliant position in the immediate proximity to the head of the state."


In the light of subsequent events it may be taken for granted that the primary stage of all the future wars of aggression included everything connected with the secret rearmament of Germany after the Versailles treaty. It is difficult to minimize the significance of all that was done at the time by Colonel Keitel in the Committee of Experts which painstakingly and consecutively sought and found means of circumventing or violating the treaty. It was none other than Colonel Keitel in particular who gave instructions to the effect that in Geneva it was possible to say what one pleased but care must be taken not to leave anything behind on paper. This cynical statement fully tallies with the role played by Keitel in the subsequent preparation and execution of aggressive wars.

During the negotiations between Hitler and Schuschnigg the living reminder of Germany's preparedness to resort to arms was the person of Keitel (C-102, USA 74). Keitel issued orders for troops to cross over into Czechoslovakia at the time when President Hacha was so treacherously called to Berlin "for continuing negotiations."

It was the OKW and no other organization which was fully prepared through the ABWEHR'S department to provoke an incident with Czechoslovakia in order to justify the invasion by the German hordes, ready to fall upon Czechoslovakia. (388-PS, USA 26)

In his strictly confidential memorandum Keitel demanded that

Hess and Himmler advise the OKW in advance of all measures taken by party organizations or police which were not included in the case Green "Fall Green". The declarations alleging that after the seizure of Czechoslovakia Germany had no more territorial aspirations in Europe were downright lies. This was but a link in the chain of aggressive wars.

I wish to emphasize the leading role of the OKW in the preparation and carrying out of aggression. The directive regarding the waging of war and invasion of Poland is known to us as Keitel's and Hitler's directive of 10 May 1939. It was forwarded to the command of the Air Forces, Navy and Land Forces. How is it possible after this to maintain that the OKW was not the driving power behind the armed forces of the Fascist Reich? If we once more peruse the documents pertaining to German aggression against Norway, Denmark, Belgium, Holland, Luxembourg, Yugoslavia and Greece we again come across the name of Keitel. He appears as a participant of the most important events as author of secret orders addressed to Raeder, Goering and the General Staff. (448-PS, GB 118) We find the initials of Keitel and Jodl entered in their own hand on the secret directive signed by Hitler regarding the "Operation Marita".

Much has been said here of the "Plan Barbarossa" and its authors. At present it is important to stress that this document took shape in the depths of the OKW at its initiative and that the planned methods of a treacherous attack on the USSR were also the work of the OKW. The significance of a military specialists visa on a document is clear to everybody. Some of the defendants attempted to portray the attack on the USSR as preventive war. This contention is to such a degree unconvincing and contradictory to the irrefutable evidence presented in court (German documents) that I see no need for occupying the Tribunal's time.

Keitel's defense counsel stated that the defense of this defendant is based on the point of view that Keitel "is fighting not for his head but to save his face." I wish to aid the Tribunal in seeing the true face of Keitel. For this I shall have to remind you of a number of Keitel's directives which may well lay claim to being among the foremost of all the infamous documents pointing to the barbarity of the German military clique, its baseness and extreme scorn for all conceptions of rules and customs of warfare.

Let us consider the documents dealing with the shooting of Political Officers. Keitel, the soldier, as he likes to call himself, ignoring his oath, shamelessly lied to the representatives of the American Prosecution at his preliminary investigation by avowing that to begin with this order was in the nature of a counter reprisal and that the political officers were separated from the

other prisoners of war at the request of the prisoners themselves. At the trial he was unmasked. Exhibit No. RF (v) −351, 884-PS proved that this directive had been issued before the war had broken out. We also submitted a document under Exhibit No. USSR-62 (the text of a letter of German Prisoners of War). This document makes it clear that even before the attack on the USSR the army in the field had been instructed to absolutely exterminate Soviet women in military service as well as political officers.


And what can be said of the following statement dreadful in its unlimited cynicism: "Human life in these countries concerned us absolutely of no account * a terrifying influence can be achieved only through unheard of brutality." (RF 271; R-98; 389-PS)

And what can be said of the directive of 13 May 1941 introducing court martial in the Barbarossa region? And of the order of 16 September 1941 calling for the execution of 80-100 communists for each German killed? (C-50, USA 554)

What could Keitel say about the document known as "Nacht und Nebel"? (L-90, USA 503)

These are sanguinary documents. No one can compute how many thousands of prisoners of war-soldiers and officers of the Red Army had been killed and tortured in the camps of Fascist Germany. You remember how on 21 January 1946 at the evening session witness Lamp testified that for the amusement of Himmler the shooting of 50 Soviet officers was organized in the Mauthausen camp. You remember witness Blaha testifying that in the spring of 1944, 94 Soviet senior military officers were tortured and then killed for refusing to give military information. (USSR-52)

I wish to mention the testimony of SS man Paul Waldman regarding the slaughter of 840 Russian prisoners of war. You remember the testimony of witness Kivelsh regarding the endless chain of torture and suffering to which Russians, taken prisoner by the Germans, were subjected to.

It is impossible to pass by Keitel's directive calling for the branding of Soviet prisoners of war. One cannot forget the Keitel directive of the 16 December 1942. It is entitled "measure to be taken against bands". Under the word "bands" defendant Keitel understood any resistance movement and demanded that his troops revert to harsh methods, stopping at nothing even in regards to women and children. (USSR-16; USSR-343)

The Soviet Prosecution submitted the testimony Lecourt under Exhibit No. USSR-162. Lecourt states that he shot and burned Soviet citizens, razing their houses. He alone had shot over 1,200 persons and for this achievement he was promoted to the

rank of Obergefreiter and awarded the medal for service in the East. He acted in accordance with the directives of Keitel.

Keitel's directive instituting court martials in the "Barbarossa" region freed such persons of all responsibility. Keitel's hands are stained with the blood of the victims of Lecourt and his like. It was in carrying out Keitel's directive stating that life in the Eastern regions was of no value, that the soldiers and officers of Hitlerite Germany committed their atrocities. (C-50, USA 554)

Exhibit number USSR-51 submitted by the prosecution shows how, on the 28 August 1941, attacking German troops drove a group of women, children and old men before their formations. In the village of Kolpino the Fascists shot the peasants who had been forced into digging trenches and bridges for them.

In Yugoslavia mass shootings of hostages became a daily feature with the military command and military administration. (USSR-261; USSR-391; USSR-392) In a secret report dated 15-2-1940 submitted to Goering the OKW justifies the practice of taking hostages.

I wish to conclude with document USSR-336 (EC-338), which your honors, of course, remember. In this document Admiral Canaris informs Keitel of the unbridled cruelty in the prisonerof-war camps, of the hunger, and mass shootings of Soviet prisoners of war. Even the out and out Fascist spy Canaris, fearing eventual responsibility could not ignore such unbridled cruelty and flagrant violation of accepted laws and customs of warfare. You will remember Keitel's notation on this report: "I approve of and back these measures".

On April 7, 1946, during the cross examination, I put the following question to Keitel: "You, Defendant Keitel, known as Fieldmarshal, repeatedly referred to yourself as a soldier before this Tribunal, and you, by your sanguinary notation, approved of and sanctioned the murder in cold blood of thousands of soldiers who had fallen prisoner. Do you confirm this?" Keitel was forced to admit this fact.

This one resolution alone unveils the true and real face of Fieldmarshal Keitel. The highly involved arguments of the defense cannot absolve Keitel of his responsibility for the bloodshed and innumerable human lives torn short by the hand of the Fascist military machine in carrying out orders and directives signed by his hand.


The defendant Alfred Jodl bears equal responsibility together with defendant Keitel as his assistant and as closest military adviser of Hitler's. All that is connected with preparation and

execution of the aggressive plans of Hitlerite Germany is inseparably linked with the name of Jodl as well as with that of Keitel. There is no need to repeat anew all those aggressive acts of Hitler's Germany which are already facts of common knowledge, each of which had been planned and executed with the direct participation of defendant Jodl.

As the representative of the Union of Soviet Socialist Republics, I should like to emphasize once more that the criminal plan of the perfidious attack on the Soviet Union, coded by the Hitler's gang under the name of the ill-fated conqueror Frederick Barbaross, is signed not only by Hitler and Keitel but by Jodl as well. But this is more than a mere signature.

As early as the summer of 1940 in Reichenhall, Jodl held the first conference of his staff-officers, at which the question of the possibility of an attack by Hitler Germany on Soviet Russia was discussed. (USSR-263) It was no one else but defendant Jodl who even before the attack against the USSR actually was carried out issued his well-known "Instructions on the use of propaganda in the region of 'Barbarossa'." In these instructions it is unequivocally stated that "as yet propaganda aimed at the partition of the Soviet Union should not be carried on." (C-26) Thus, defendant Jodl knew beforehand of the actual aims of Germany's attack on the USSR, knew of the piratical and predatory nature of the war which called for the dismembering of the Soviet Union.

It was Jodl who took part in the preparation and organization of the provocative incident on the Czechoslovak border with the aim of justifying this aggressive act of Hitler Germany against this peace loving nation. It was Jodl who signed the order of the 28 September 1938 regarding the uses of the so-called Heinlein Corps in case the "Case Green" was realized. (3061-PS, USA 126) How full of mockery sound the defendant Jodl's words of "soldier's honor" after reading his order on the destruction of Leningrad, Moscow and other cities of the Soviet Union. (C-123; USSR-114) It was this very same Jodl who with inimitable cynicism declared at a conference with Hitler on the 1 December 1941 that German troops could with impunity "hang, hang by the feet and quarter" Soviet patriots.

As the closest military adviser of Hitler's, having personally participated in the preparation and execution of all the sanguinary aggressive plans of Hitlerites Germany, defendant Jodl has been justly included in the ranks of the major German War Criminals.

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