On the 15th October, 1939, the defendant Keitel wrote a most secret letter concerning "Fall Gelb," which was the code name for the operation against the Low Countries. In it he stated:

"The protection of the Ruhr area by moving A./C. reporting service and the air defence as far forward as possible in the area of Holland is significant for the whole conduct of the war. The more Dutch territory we occupy, the more effective can the defence of the Ruhr area be made. This point of view must determine the choice of objectives of the army, even if the army and navy are not directly interested in such territorial gain. It must be the object of the army's preparations, therefore, to occupy, on receipt of a special order, the territory of Holland, in the first instance in the area of the Grebbe-Marse line. It will depend on the military and political attitude of the Dutch, as well as on the effectiveness of their flooding, whether objectives can and must be further extended."

The "Fall Gelb" operation had apparently been planned to take place at the beginning of November, 1939. We have in our possession a series of seventeen letters, dated from 7th November until the 9th May, postponing almost from day to day, the D-day of the operation, so that by the beginning of November, all the major plans and preparations had been made.

On the 10th January, 1940, a German aeroplane force-landed in Belgium. In it was found the remains of an operation order which the pilot had attempted to burn, setting out considerable details of the Belgian landing grounds that were to be captured by the Air Force. Many other documents have been found which illustrate the planning and preparation for this invasion in the latter half Of 1939 and early 1940, but they carry the matter no further, and they show no more clearly than the evidence to which I have already referred, the plans and intention of the German Government and its Armed Forces.

On the 10th May, 1940, at about 0500 hours in the morning, the German invasion of Belgium, Holland and Luxembourg began.

And so once more the forces of aggression marched on. Treaties, assurances, the rights of Sovereign States meant nothing. Brutal force, covered by as great an element of surprise as the Nazis could secure, was to seize that which was deemed necessary for striking the mortal blow against England, the main enemy. The only fault of these three unhappy countries was that they stood in the path of the German invader in his designs against England and France. That was enough, and they were invaded.

(A recess was taken.)

[Page 79]

On the 6th April, 1941, German Armed Forces invaded Greece and Yugoslavia. Again the blow was struck without warning and with the cowardice and deceit which the world now fully expected from the self-styled "Herrenvolk." It was a breach of the Hague Convention. It was a breach of the Pact of Paris. It was a breach of a specific assurance given by Hitler on the 6th October, 1939.

He had then said this:

"Immediately after the completion of the Anschluss, I informed Yugoslavia that, from now on, the frontier with this country will also be an unalterable one and that we only desire to live in peace and friendship with her."

But the plan for aggression against Yugoslavia had, of course, been in hand well before that. In the aggressive action Eastward towards the Ukraine and the Soviet territories, security of the Southern flank and the lines of communication had already been considered by the Germans.

The history of the events leading up to the invasion of Yugoslavia by Germany is well known. At three o'clock in the morning of the 28th October, 1940, a three-hour ultimatum had been presented by the Italian Government to the Greek Government, and the presentation of that ultimatum was immediately followed by the aerial bombardment of Greek provincial towns and the advance of Italian troops into Greek territory. The Greeks were not prepared. They were at first forced to withdraw. But later the Italian advance was first checked, then driven towards the Albanian frontier and, by the end of 1940, the Italian Army had suffered severe reverses at Greek hands.

Of the German position in the matter there is, of course, the evidence of what occurred when, on the 12th August, 1939, Hitler held his meeting with Ciano.

You will remember that Hitler said then:

"Generally speaking, the best thing to happen would be for the neutrals to be liquidated one after the other. This process could be carried out more easily if, on every occasion, one partner of the Axis covered the other while it was dealing with an uncertain neutral. Italy might well regard Yugoslavia as a neutral of this kind."

Then the conference went on with other matters and when it met again on the 13th August, in the course of lengthy discussions, Hitler said this:

"In general, however, after success by one of the Axis partners, not only strategical but also psychological strengthening of the other partner and also of the whole Axis would ensue. Italy carried through a number of successful operations in Abyssinia, Spain and Albania, and each time against the wishes of the democratic entente. These individual actions have not only strengthened Italian local interests, but have also reinforced her general position. The same was the case with German action in Austria and Czechoslovakia. The strengthening of the Axis by these individual operations was of the greatest importance for the unavoidable clash with the Western Powers."

And so once again we see the same procedure being followed. That meeting had taken place on the 12th and the 13th August, 1939. Less than two months later, Hitler was giving his assurance to Yugoslavia that

[Page 80]

Germany only desired to live in peace and friendship with her, with the State the liquidation of which by his Axis partner he had himself so recently suggested.

Then came the Italian ultimatum to Greece and war against Greece, and the eventual Italian reverse.

We have found, amongst the captured documents, an undated letter from Hitler to Mussolini which must have been written about the time of the Italian aggression against Greece.

"Permit me," Hitler said, "at the beginning of this letter to assure you that within the last 14 days my heart and my thoughts have been more than ever with you. Moreover, Duce, be assured of my determination to do everything on your behalf which might ease the present situation for you. ... When I asked you to receive me in Florence, I undertook the trip in the hope of being able to express my views prior to the beginning of the threatening conflict with Greece, about which I had only received general information. First, I wanted to request you to postpone the action, if at all possible, until a more favourable time of the year, at all events until after the American Presidential election. But in any case I wanted to request you, Duce, not to undertake this action without a previous lightning-like occupation of Crete, and for this purpose, I also wanted to submit to you some practical suggestions in regard to the employment of a German parachute division and a further airborne division .... Yugoslavia must become disinterested, if possible; however, from our point of view, interested in co-operating in the liquidation of the Greek question. Without assurances from Yugoslavia, it is useless to risk any successful operation in the Balkans. Unfortunately, I must stress the fact that waging a war in the Balkans before March is impossible. Hence it would also serve to make any threatening influence upon Yugoslavia of no, purpose, since the Serbian General Staff is well aware of the fact that no practical action could follow such a threat before March. Hence, Yugoslavia must, if at all possible, be won over by other means and other ways."

On the 12th November, 1939, in his top secret order, Hitler ordered the O.K.H. to make preparations to occupy Greece and Bulgaria, if necessary. Apparently ten divisions were to be used in order to prevent Turkish intervention. I think I said 1939; it should, of course, have been the 12th November, 1940. And to shorten the time, the German divisions in Roumania were to be increased.

On the 13th December Hitler issued an order to O.K.W., O.K.L., O.K.H., O.K.M. and the General Staff on the operation "Marita," as the invasion of Greece was to be called. In that order it was stated that the invasion of Greece was planned and was to commence as soon as the weather was advantageous. A further order was issued on the 11th January, 1941.

On the 28th January, 1941, Hitler saw Mussolini. The defendants Jodl, Keitel and Ribbentrop were present at the meeting. We know about it from Jodl's notes of what took place. We know that Hitler stated that one of the purposes of German troop concentrations in Roumania was for use in the plan "Marita" against Greece.

On the 1st March, 1941, German troops entered Bulgaria and moved towards the Greek frontier. In the face of this threat of an attack on Greece

[Page 81]

by German as well as Italian forces, British troops were landed in Greece on the 3rd March, in accordance with the declaration which had been given by the British Government on the 13th April, 1939, that Britain would feel bound to give Greece and Roumania, respectively, all the support in her power, in the event of either country becoming the victim of aggression and resisting such aggression. Already, of course, the Italian operations had made that pledge operative.

On the 25th March, 1941, Yugoslavia, partly won over by the "other means and other ways" to which Hitler had referred, signed the Three-power Pact which had already been signed by Germany, Italy and Japan. The preamble of the pact stated that the three powers would stand side by side and work together.

On the same day the defendant Ribbentrop wrote two notes to the Yugoslav Prime Minister, assuring him of Germany's full intention to respect the sovereignty and independence of his country. That declaration was just another example of the treachery employed by German diplomacy. We have already seen the preparations that had been made. We have seen Hitler's attempts to tempt the Italians into an aggression against Yugoslavia. We have seen, in January, his own orders for preparations to invade Yugoslavia and then 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, an anti-Nazi element in Yugoslavia immediately accomplished a coup d'etat and established a new government, and thereupon, no longer prepared to respect the territorial integrity and sovereignty of her ally, Germany immediately took the decision to invade. On the 27th March, two days after the Three-power Pact had been signed, Hitler issued instructions that Yugoslavia was to be invaded, and used as a base for the continuance of the combined German and Italian operation against Greece.

Following that, further deployment and other instructions for the action "Marita" were issued by von Brauchitsch on the 30th March, 1941.

It was stated - and I quote - 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."

As we now know, the invasion actually commenced in the early hours of the 6th April.

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

I turn now to the last act of aggression in Europe-my American colleagues will deal with the position in relation to Japan - 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, concluded a treaty of non-aggression with the Union of Soviet Socialist Republics. 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

[Page 82]

United States of America - was left alone in the field as the sole representative of democracy in the face of the forces of aggression. At that moment only the British Empire stood between Germany and the achievement of her aim to dominate the Western World. Only the British Empire - and 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 the defendants Keitel and Jodl a directive - which they found themselves unable to obey - for the invasion of England. It started off - and Englishmen will forever be proud of it - by saying 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 operation must be completed by mid-August."

But the first essential condition for that plan was - and I quote -

"that the British 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."

The defendant Goering and his Air Force, no doubt made the most strenuous efforts to realise that condition, but, in one of the most splendid pages of our Empire's history, it was decisively defeated. And although the bombardment of England's towns and villages was continued throughout that dark winter of 1940-1941, the enemy decided in the end that England was not to be subjugated by these means, and, accordingly, Germany turned back to the East, the first major aim unachieved.

On the 22nd June, 1941, German Armed Forces invaded Russia, without warning, without declaration of war. It was, of course, a breach of the usual series of treaties; they meant no more in this case than they had meant in the other cases. It was a violation of the Pact of Paris; it was a flagrant contradiction of the Treaty of Non-Aggression which Germany and Russia had signed on the 23rd August a year before.

Hitler himself said, in referring to that agreement, that "agreements were only to be kept as long as they served a purpose".

The defendant Ribbentrop was more explicit. In an interview with the Japanese Ambassador in Berlin on the 2nd February, 1941, he made it clear that the object of the agreement had merely been, so far as Germany was concerned, to avoid a two- front war.

In contrast to what Hitler and Ribbentrop and the rest of them were planning within the secret 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," he said, "I considered it proper to negotiate as a first priority a sober definition of interests with Russia. It would make 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 important for her existence.

[Page 83]

From this clear delineation of the sphere of interest there followed the new regulation of Russo-German relations.

Any hope that now, at the end of the term of the agreement, a new Russo-German tension could arise is childish. Germany has taken no step which would lead her outside 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.

English statesmen perceive everything somewhat slowly, but they too will learn to understand this in the course of time."

The whole statement was, of course, a tissue of lies. It was not many months after it had been made that the arrangements for attacking Russia were put into hand. The defendant Raeder gives us the probable reasons for it, in a note which he sent to Admiral Assmann:

"The fear that control of the air over the Channel in the autumn of 1940 could no longer be attained, a realisation 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 him, as far back as August and September" - this was August and September of 1940 - "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 September."

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

Dated the 6th September, 1940, we have a directive of the O.K.W. signed by the defendant Jodl; and I quote:

"Directions are given for the occupation forces in the East to be increased in the following weeks. For security reasons" - and I quote - "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, and I quote:

"The total strength of the German troops in the East is 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."

And so we see the beginning of the operations.

On the 12th November, 1940, Hitler issued a directive, signed by the defendant Jodl, in which it was 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.

It is not to be supposed that the U.S.S.R. would have taken part in ally conversations at that time if it had been realised 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, which was called the "Plan Barbarossa", was in active preparation. On the 16th November the order was issued, and I quote:

[Page 84]

"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."

And later, in the same instruction - and I quote again:

"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 towards ourselves."

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