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and Greece and now on the 25th March he is signing a pact with that country and his Foreign Minister is writing assurances of respect for her sovereignty and territorial integrity.

As a result of the signing of that Pact the anti-Nazi element in Yugoslavia immediately accomplished a coup d'etat and established a new Government. Thereupon the decision was taken to invade immediately and on the 27th March, two days after the 3-Power Pact had been signed by Yugoslavia, Hitler issued instructions that Yugoslavia was to be invaded and used as a base for the continuance of the combined German and Italian offensive against Greece. (C-127)

Following this, further deployment and other instructions for the action Marita were issued by Von Brauchitsch on the 30th March 1941. (R-95)

It is stated that "the orders issued with regard to the operation against Greece remain valid so far as not affected by this order. On the 5th April, weather permitting, the Air Forces are to attack troops in Yugoslavia, while simultaneously the attack of the 12th Army begins against both Yugoslavia and Greece" (R-95). As we now know, the invasion actually commenced in the early hours of the 6th April.

Treaties, Pacts, Assurances obligations of any kind brushed aside and ignored wherever the aggressive interests of Germany are concerned.

I turn now to the last act of aggression in Europe with which these Nazi conspirators are charged—the attack upon Russia. In August 1939 Germany although undoubtedly intending to attack Russia at some convenient opportunity, sufficiently deceived the Russian Government to secure a pact of non-aggression between them. It followed, therefore, that when Belgium and the Low Countries were occupied and France collapsed in June 1940, England-although with the inestimably valuable moral and economic support of the United States of America-was left alone as the sole representative of Democracy in the face of the forces of aggression. Only the British Empire stood between Germany and the achievement of her aim to dominate the Western world. Only the British Empire-only England as its citadel. But it was enough. The first, and possibly the decisive, military defeat which the enemy sustained was in the campaign against England, and that defeat had a profound influence on the future course of the war. On the 16th July 1940 Hitler issued to Keitel and Jodl a Directive for the invasion of England. It started off by stating—and Englishmen will be forever proud of it—that

"Since England, despite her militarily hopeless situation, shows no signs of willingness to come to terms, I have decided to prepare a landing operation against England and if

necessary to carry it out. The aim is

to eliminate the English homeland as a base for the carrying on of the war against Germany. The preparations for the entire opera

tion must be completed by mid-August.” (442-PS) But the first essential condition for that plan was "that the English Air Force must morally and actually be so far overcome that it does not any longer show any considerable aggressive force against the German attack.” (442-PS)

The German Air Force made the most strenuous efforts to realize that condition, but, in one of the most splendid pages of our history, it was decisively defeated. And although the bombardment of England's towns and villages was continued throughout that dark winter of 1940-41 the enemy decided in the end that England was not to be subjugated by these means, and cordingly Germany turned back to the East, the first major aim achieved.

On the 22d June 1941, German Armed Forces invaded Russiawithout warning, without declaration of war. It was a breach of the Hague Conventions; it was a violation of the Pact of Paris of 1928: it was in flagrant contradiction of the Treaty of nonaggression which Germany and Russia had signed on the 23d August 1939.

But that Treaty, perhaps more blatantly than any other, was made without any intention of being observed and only for the purpose of assisting the German Government to carry out their aggressive plans against the Western democracies before eventually turning east in their own good time.

Hitler himself in referring to the Agreement said agreements were only to be kept as long as they served a purpose. Ribbentrop was more explicit. In an interview with the Japanese Ambassador in Berlin on 23d February 1941 he made it clear that the object of the Agreement had merely been to avoid a two front war. (1834-PS)

In contrast to what Hitler and Ribbentrop were planning within the councils of Germany, we know what they were saying to the rest of the world. On the 19th July Hitler spoke in the Reichstag:

“In these circumstances I consider it proper to negotiate as
a first priority a sober definition of interests with Russia. It
would be made clear once and for all what Germany believes
she must regard as her sphere of interest to safeguard her
future and, on the other hand, what Russia considers impor-
tant for her existence.
"From the clear delineation of the sphere of interest on either


side, there followed the new regulation of Russo-German re-
lations. Any hope that now at the end of the term of the
agreement a new Russo-German tension could arise is child-
ish. Germany has taken no step which would lead her out-
side her sphere of interest, nor has Russia. But England's
hope, to achieve an amelioration of her own position through
the engineering of some new European crisis, is, in so far as
it is concerned with Russo-German relations, an illusion.
"British statesmen perceive everything somewhat slowly, but

they too will learn to understand this in course of time." Yet it was not many months after that that the arrangements for attacking Russia were put in hand. Raeder gives us the probable reasons for this sudden decision in a note to Admiral Assmann.

"The fear that control of the air over the Channel in the Autumn of 1940 could no longer be attained, a realization which the Fuehrer no doubt gained earlier than the Naval War Staff, who were not so fully informed of the true results of air raids on England (our own losses), surely caused the Fuehrer, as far back as August and September, to consider whether, even prior to victory in the West, an Eastern campaign would be feasible with the object of first eliminating our last serious opponent on the continent. The Fuehrer did not openly express this fear, however, until well into Sep

tember." He may not have told the Navy of his intentions until later in September, but by the beginning of that month he had undoubtedly spoken of them to Jodl.

Dated 6th September 1940 we have a directive of the OKW signed by Jodl: “Directions are given for the occupation forces in the east to be increased in the following weeks. For security reasons this should not create the impression in Russia that Germany is preparing for an Eastern offensive.” Directives are given to the German Intelligence Service pertaining to the answering of questions by the Russian Intelligence Service. "The total strength of the German troops in the East to be camouflaged by frequent changes in this area. The impression is to be created that the bulk of the troops in the south have moved whilst the occupation in the north is only very small.” (1229-PS)

Thus we see the beginning of the operations.

On the 12th November 1940 Hitler issued a directive signed by Jodl in which he stated that the political task to determine the attitude of Russia had begun, but without reference to the result of preparations against the East, which had been ordered orally before it could be carried out.

On the same day Molotov visited Berlin. At the conclusion of conversations between himself and the German Government a communique was issued in the following terms:

“The exchange of ideas took place in an atmosphere of mutual trust and led to a mutual understanding on all important

questions interesting Germany and the Soviet Union.” It is not to be supposed that the USSR would have taken part in those conversations or agreed to that communique if it had been realized that on the very day orders were being given for preparations to be made for the invasion of Russia and that the order for the operation “Barbarossa” was in preparation. Four days later that order was issued— "The German armed forces have to be ready to defeat Soviet Russia in a swift campaign before the end of the War against Great Britain” (446-PS). And later in the same instruction,

“All orders which shall be issued by the High Commanders in accordance with this instruction have to be clothed in such terms that they may be taken as measures of precaution in case Russia should change her present attitude to

wards ourselves.(4.46-PS) Keeping up the pretense of friendliness, on the 10th January, 1941-after the Plan Barbarossa for the invasion of Russia had been decided upon—the German-Russo frontier treaty was signed. On the 3d February 1941 Hitler held a conference, attended by Keitel and Jodl, at which it was provided that the whole operation was to be camouflaged as if it was part of the preparations for the "Seelowe" as the plan for invasion of England was called. By March 1941 the plans were sufficiently advanced to include provision for dividing the Russian territory into 9 separate States to be administered under Reich Commissars under the general control of Rosenberg. At the same time detailed plans for the economic exploitation of the country were made under the supervision of Goering, to whom the responsibility was delegated by Hitler. You will hear something of the details of these plans. It is significant that on the 2d May 1941 a conference of the State Secretaries on the Plan Barbarossa noted:

"1. The war can only be continued if all armed forces are
fed out of Russia in the third year of the war.
“2. There is no doubt that as a result many millions of
people will be starved to death if we take out of the country
the things necessary for us.”

But this apparently created no concern. The plan Oldenberg, as the scheme for economic organization was called, went on. By the 1st May the D date of the operation was fixed. By the 1st June preparations were virtually complete and an elaborate time table was issued. It was estimated that although there would be heavy frontier battles, lasting perhaps 4 weeks, after that no serious opposition was to be expected.

On the 22d June at 3.30 in the morning the German Armies marched again. As Hitler said in his Proclamation:

"I have decided to give the fate of the German People and of the Reich and of Europe again into the hands of our

soldiers." The usual false pretexts were of course given. Ribbentrop stated on the 28th June that the step was taken because of the threatening of the German frontiers by the Red Army. It was untrue and Ribbentrop knew it was untrue. On the 7th June his Ambassador in Moscow was reporting to him that "All observations show that Stalin and Molotov who are alone responsible for Russian foreign policy are doing everything to avoid a conflict with Germany". The staff records which you will see make it clear that the Russians were making no military preparations and that they were continuing their deliveries under the Trade Agreement to the very last day. The truth was, of course, that the elimination of Russia as a political opponent and the incorporation of the Russian territory in the German Lebensraum had long been one of the cardinal features of Nazi policy, subordinated latterly for what Jodl called diplomatic reasons.

And so, on the 22d June, the Nazi armies were flung against the Power with which Hitler had so recently sworn friendship and Germany embarked on that last act of aggression which, after long and bitter fighting, was eventually to result in Germany's own collapse.


This then is the case against these Defendants, as amongst the rulers of Germany, under Count 2 of this Indictment. It may be said that many of the documents which have been referred to were in Hitler's name, that the orders were Hitler's orders, that these men were mere instruments of Hitler's will. But they were the instruments without which Hitler's will could not be carried out. And they were more than that. These men were no mere willing tools, although they would be guilty enough if that had been their role. They are the men whose support

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