Archive/File: imt/tgmwc/tgmwc-09/tgmwc-09-80.02
Last-Modified: 1999/12/6

Q. I am talking about the riots in which synagogues were
burned, which made Goering so very angry. Did you not hear
about that in 1938?

A. No, I did not hear anything about it.

Q. Where were you in 1938?

A. In 1938 I was in Dresden.

Q. In November?

A. In November I was in Berlin as Chief of the Air Force.

Q. In Berlin, and you never heard about the anti-Jewish
riots of the 9th and 10th November, 1938?

A. I have only heard about the so-called action "Mirror or
Glass Campaign" ("Spiegel-oder Glas-Campagne").

Q. What was that? I know of nothing by that name.

A. That was the smashing of shop windows and so on, which
assumed rather large proportions in Berlin.

Q. You did hear, then, about the anti-Jewish riots?

A. About those, yes.

Q. And did you hear that Hermann Goering issued a decree
confiscating the insurance that was to make reparations to
those Jews who owned shops? Did you hear about Goering's
action in that respect?

A. I did not quite understand. May I ask to have it
repeated?

Q. Did you hear about the decree passed by Hermann Goering a
few days later - 12th November, to be exact - confiscating
the insurance of the victims of those raids and fining the
Jewish community a billion Reichsmark?

A. It is possible that I heard about it at the time, but I
now have no certain recollection.

Q. But you did hear about it. You did not regard those
things as persecution?

A. Naturally, I must regard this "Glass Campaign" as an
atrocity against the Jews.

Q. You have made a statement, I believe, based on your
experience with Hitler, that it was permissible for officers
to differ with him in opinion so long as they obeyed his
orders. Is that what you want to be understood?

                                                   [Page 42]

A. I have to apologise, but I did not quite understand the
last half of that sentence.

Q. I have understood from your testimony this morning that
you felt perfectly free to disagree with Hitler and to make
suggestions to him and give him information, but that, after
his mind was made up and an order issued, it had to be
obeyed. That is to say -

A. Yes.

Q. That is to say, an officer was at all times at liberty to
go to Hitler and give him technical information, such as the
state of the preparedness of his branch of the Service?

A. Generally speaking, no. The commanders-in-chief of the
branches of the Armed Forces concerned were the only people
admitted for that purpose.

Q. So the only channel through which information as to the
state of the Air Force would reach Hitler was through
Hermann Goering, is that a fact?

A. Hermann Goering and, from time to time, Secretary of
State Milch, deputy of the Reichsmarschall.

Q. If Hitler was about to engage in a war for which the
Luftwaffe was unprepared, based on your information of the
situation, would it or would it not have been possible for
the Luftwaffe officers to have advised Hitler of that fact?

A. We had complete confidence in our Reichsmarschall and we
knew that he was the only person who had a decisive
influence upon Adolf Hitler. In that way we knew, since we
also knew his peaceful attitude, that we were perfectly
secure, and we relied on it.

Q. There came a time when you went into the East, did you
not, as a commander? You went into Poland and you went into
Soviet Russia, did you not?

A. Poland and Russia, yes.

Q. And was it not understood among the officers in those
Polish and Russian campaigns that The Hague regulations
would not be applied to Soviet Russia as to the treatment of
prisoners of war?

A. That was not known to me.

Q. You have testified that the Luftwaffe was purely a weapon
of defence. Is that your testimony?

A. Yes.

Q. What was the German strength in various types of planes
at the beginning of the Polish campaign?

A. As I was not a member of the Central Board I can only
give you an approximation on my own responsibility, without
guaranteeing the accuracy of the figures. All told, I would
say we must have had approximately 3,000 aircraft. All in
all, so far as I can remember now, there were between 30 and
40 bomber groups, the same number of fighters, and there
were 10 groups of dive bombers, fighters -
Q. Will you give me the number of each group?A. About 30
aircraft, which would drop to seven, six or five aircraft
during the course of the day. To continue, there were 10 to
12 groups of dive bombers, including close support planes
and twin-engine fighters. Also included in that figure were
reconnaissance planes and a certain number of naval
aircraft.

Q. And the proportion of bombers to fighters was
approximately 2 to 1, was it not?

A. The proportion of bombers to fighters was about 1 to 1 or
1-2, or 1-3 to 1. I said 30 to 40 and about 30 fighter
groups. If I include the twin-engine fighters, then the
figure would be about 1 to 1.

Q. That is the way you make up the total of about 3,000
units?

A. The reason why I can give you that figure is because
during these months of quiet reflection I made an estimate.

Q. Now, do you call the bomber a defensive or an offensive
weapon?

                                                   [Page 43]

A. I must call the bomber, like the dive bomber and the
fighter, both a defensive and an offensive weapon. I
explained yesterday that, no matter whether defensive or
offensive warfare is concerned, the task of the Air Force
must be carried out on the offensive, and the targets are
far and wide. I have also explained that an Air Force which
only has light aircraft is doomed to be destroyed, since it
cannot attack the enemy's aircraft production, his air
concentration areas, nor his movements in various sectors.

Q. In other words, the Luftwaffe was a defensive weapon if
you were on the defensive and an offensive weapon if you
were on attack?

A. I did not understand the last half of the sentence.

Q. The Luftwaffe would serve as a defensive weapon if you
were on the defensive and as an offensive weapon if you were
on attack, is not that true?

A. One could put it like that. I would express it
differently. As I say, the Air Force, because of its make-
up, is an offensive weapon, no matter whether it is being
used during defence or for attack.

Q. I think you have improved on my sentence. Now, in the
Netherlands, in Poland -

A. May I just say something else on the subject?

Q. Yes, yes.

A. Namely, what I said yesterday at the very end, that the
essential of an offensive Air Force is the long-distance
four-engine heavy bombers, and Germany had none of these.

Q. How did it come that Germany had none of those?

A. Firstly, because we were, in fact, unprepared, and were
confining ourselves only to the absolute essentials of a
defensive Air Force.

Secondly, because it was our plan, in keeping with our
characteristics, to achieve as much as possible by precision
bombing - in other words, by dive bombing, utilising the
minimum of war materials, and I am here thinking of the JU-
88 as a typical example of that.

Q. You were examined by the United States Strategic Bombing
Survey, were you not, on 28th June, 1945? Do you recall
that?

A. Yes, of course.

Q. Well, it is quite certain, is it not?

A. I have often been interrogated.

Q. Now, I ask you whether, on 26th June, 1945, you did not
say to the officer examining you on behalf of the United
States Strategic Bombing Survey this:

  "Everything had been done to make the German Air Force,
  from the point of view of airmanship, aircraft, flak, air
  corps signals and so forth, the most formidable in the
  world. The result was that at the beginning of the war,
  or in 1940 at the latest, from a fighter viewpoint, from
  a dive-bomber viewpoint, from a combat viewpoint, we had
  particularly good aircraft, even if the standard was not
  uniform entirely."

Did you state that?

A. That is still my view to-day, that as far as material,
pursuit planes, dive bombers and fighters were concerned, we
did, in fact, have a certain advantage over the other
Powers.

Q. Now, as to the failure to have the number of four-engine
bombers; that was because of your peaceful intentions, was
it, or was it because of mistake in judgement as to what the
requirements of war would be?

A. To that I must say the following. It would have been
insanity on the part of the Air Force leaders to consider
producing a complete Air Force within three to four years.
It was in 1940 at the earliest that it became possible to
build up an effective Air Force which would comply with all
requirements. For that reason, in my view, it was an amazing
achievement of organisation to have attained such
effectiveness with such limitations.

                                                   [Page 44]

Q. I understood you to mention as one of the indications of
your unaggressive intentions, the fact that you had not an
adequate number of four-engine bombers at the outset of the
war. Did I misunderstand you?

A. That is an excerpt from the whole story. The strength of
the Air Force could, when compared with those of the small
States, be regarded as sufficient; certainly not, however,
when compared with those of powerful opponents who were
fully
equipped in the air.

I have an example in mind; in a heated discussion with the
Reichsmarschall before the beginning of the Russian
campaign, I asked for a reinforcement of the fighters and
dive bombers. For certain reasons that was refused. The
certain reasons were, firstly, shortage of material, and
secondly - as I gathered from what he said - he was not in
favour of this campaign.

Q. Did you not testify to the Bomber Investigating
Commission of the United States that you intended to build a
long-range heavy bomber but -

A. We had developed the AG-111 and the JU-88 and they were
actually put into the fighting as long-range heavy bombers.
The JU-88 was then used in the French campaign and against
England.

Q. The JU-88 is not really a long-range bomber?

A. It was considered a long-range bomber at that time, but
unfortunately we had a low opinion of the four-engine
aircraft and one which proved later on to be mistaken.

Q. And the reason you did not build the four-engine aircraft
was your low opinion of it?

A. May I say the following: That was the conception of a
Service department; the decisions in all these questions
were made in the "Gremium," of the highest Service
department.

Q. That department made a mistake about the utility of the
four-engine bomber?

A. Well, looking at the situation retrospectively, I must
say that the absence of a four-engine bomber turned out
extremely awkward.

Q. The highest authority in aircraft production was Hermann
Goering - he was the head of the whole plan of aircraft
production, was he not?

A. Yes, that is correct, but it does not exclude the fact
that erroneous conceptions of certain measures for the
conduct of the war or organisational measures can exist
temporarily.

Q. You were in the Polish campaign, you have said?

A. Yes.

Q. Is it not a fact that the German Air Force made the
decisive contribution to that campaign as to the time taken
to conquer Poland?

A. From the point of view of the Air Force officers I must
agree with that absolutely, but the Army officers did not
quite share it.

Q. Well, you are testifying now as to your opinion. In that
campaign you developed the technique of low-level attacks by
fighters, light bombers and dive bombers against marching
columns, and the dive bomber, the light bomber and the
fighters all contributed to the success of that movement.

A. I must admit that. The foundations of the short-range
bombing technique were certainly laid during the Polish
campaign.

Q. I turn now to the French campaign. You were in the air in
the French campaign, were you not?

A. Yes.

Q. And the Air Force contributed decisively to the success
of that campaign, did it not?

A. From the point of view of an Air Force officer, I must
consider that view as correct.

Q. And you testified, did you not, that Dunkirk would not
have been such a catastrophe if the Luftwaffe had not been
there? That is true, is it not?

                                                   [Page 45]

A. Dunkirk, did you say? I did not quite understand.

Q. Yes, Dunkirk.
A. Yes. In my opinion, that is certain, and it would have
been even more so if bad weather had not considerably
hindered our operations.

Q. That is, the catastrophe would have increased for the
English except for bad weather. You had sufficient air force
to do a more complete job at Dunkirk than was actually the
case.
A. We were grounded for about two days.

Q. You were one of the principal advocates of the plan to
invade England, were you not?
A. Personally, I was of the opinion that, if the war against
England was to be brought to a successful end, this end
could  only be achieved for certain by invasion.

Q. You had an adequate air force after having defeated
Poland, defeated Holland, defeated Belgium, and defeated
France, so that you advocated proceeding with an invasion of
England, did you not?
A. I must give an explanation on that point.

Q. First tell me if that is true.

THE PRESIDENT: Witness, will you please understand that you
must answer the question first, and give an explanation
afterwards. Every question, or nearly every question, admits
of either an affirmative or negative answer, and you will
kindly give that answer and make your explanation
afterwards.

BY MR. JUSTICE JACKSON:

Q. Did you not advocate the invasion of England, and was not
the Air Force ready to invade England?

A. The Air Force was, subject to certain conditions, in view
of the existing air situation at that time, ready to fulfil
that task.

Q. You recommended very strongly to the Reichsmarschall that
the invasion take place immediately after Dunkirk, did you
not?

A. Yes, and I still advocated that view later on, too.

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