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My Lords I pass now to the 4th February, 1938, when the O.K.W. was formed. Shortly after its formation there was issued a handbook which is a new exhibit, from which I want to read short passages. The number of the document is L-211. It is GB 161.

Now, this is dated 19th April, 1938, "Top Secret for Commanders only. Direction of War as a Problem of Organisation." I read only from the appendix which is entitled, "What is the War of the Future?" and if the Court will kindly turn over to the second page, I am going to read 12 lines from the bottom of the page, the line beginning "Surprise."

"Surprise which must be the premise for quick initial success will often require hostilities to begin before mobilisation has been completed or the armies are fully in position.

A declaration of war is no longer necessarily the first step at the start of a war.

The normal rules of war towards neutral nations may be considered to apply only on the basis of whether the operation of these rules will create greater advantages or disadvantages for the warring nation."

But, my Lord, I emphasise that passage because I submit it so clearly envisages exactly the way in which Germany did make war in 1939 and in the subsequent years.

My Lord, I now start to tread the road which has been trodden many times already, and which will be trodden so many times again, the road from 1938 and 1941 to the final act of aggression. But I believe that I can treat this period, so far as Keitel and Jodl are concerned, in a very few sentences because I submit that the documents which are already in, which have been read and re-read into the record, demonstrate quite clearly that Keitel, as would only be expected, he being Chief of the Supreme Command of all the Armed Forces, and Jodl, as would only be expected also, he being Chief of the Operations Staff, were vitally and intimately concerned with every single act of aggression which took place successively against the various victims of Nazi aggression.

My Lord, you should have in front of you the document book and the trial brief in which those documents are set out under the heading. If I might take first the aggression against Austria, your Lordship will remember in Jodl's diary on the 12th February, 1938, how Keitel, who was something more than a mere soldier, put heavy pressure upon Schuschnigg - that is Document 1780-PS, Jodl's diary-how on the following day, Keitel wrote to Hitler - Document 1775- PS, Exhibit USA 73 - suggesting the shamming of military action and the spreading of false but quite credible news.

Then, the actual operation orders for Operation Otto, Exhibits USA 74, 75 and 77, all of the 11th March, 1938, are O.K.W. orders for which Keitel is responsible.

THE PRESIDENT: What are the numbers of them?

MR. ROBERTS: My Lord, C-102, C-103 and C-182. One of them is actually signed or initialled by Keitel, and two are initialled by Jodl. Those are the operation orders for the advance into Austria, the injunction, if the Tribunal remembers, to treat Czech soldiers as hostile and to treat the Italians as friends.

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THE PRESIDENT: Well, perhaps if you are going on to another, we had better adjourn now until two o'clock.

(A recess was taken until 14.00 hours.)

MR. ROBERTS: May it please the Tribunal: I had got to the commencement of the aggression against Czechoslovakia, and the Tribunal will remember that the leading exhibit on that matter is the file 388-PS, USA 26, the "Fall Grun" file. My Lords, that file, in my submission, contains copious evidence against both Keitel and Jodl, showing that they were doing the normal work of the Chief of the Supreme Command of the Armed Forces and the head of the Operations Staff.

May I remind the Tribunal of Item 2 - I do not want to read any of it. I might just refer to the notes of a meeting on the 21st April, 1938. The important thing to notice is that Keitel and the Fuehrer met alone, showing the intimate connection between the two. And it was at that meeting that preliminary plans were discussed, including the possibility of an incident, namely, the murder of the German Ambassador at Prague.

Item 5 in that file, dated the 20th May, 1938, shows the plans for the political and the military campaign against Czechoslovakia, issued by Keitel.

Item 11, dated the 30th May, 1938, is the directive signed by Keitel for the invasion of Czechoslovakia, with the date given as the 1st October, 1938.

There are many items which are initialled by Jodl; Item 14 and Item 17, to mention only two.

Perhaps, for the purposes of the note, I should mention the others, Items 24, 36 and 37.

There is the directive, Items 31 and 32, dated 27th September, 1938, signed by Keitel, enclosing orders for secret mobilisation.

Jodl's diary, 1780-PS, contains many references to the forthcoming aggression, particularly the 13th May and the 8th September, and there is a very revealing entry on the 11th September in Jodl's diary - Document 1780-PS-in which he says:

"In the afternoon, conference with the Secretary of State."

MR. ROBERTS: I beg your Lordship's pardon; 11th September, 1938.

"In the afternoon, conference with Secretary of State Jahnke, from the Ministry of Public Enlightenment and Propaganda, on the imminent common tasks. The joint preparations for refutation of our own violations of International Law and the exploitation of its violations by the enemy were considered particularly important."

My Lord, as a result of that conference, the Document C-2, which was referred to by my learned leader, Sir David, was prepared, which the Tribunal win remember has in parallel columns the possible breach of International Law and the excuse which is then going to be given for it. It was referred to so recently that I need not refer to it again.

My Lord, I respectfully submit, on that branch of the matter, that there is an overwhelming case that Keitel and Jodl played an important, indeed, a vital part, in the aggression against Czechoslovakia, which led up to the Pact of Munich.

After the Pact of Munich was signed, as has been pointed out many times, the Nazi conspirators at once set about preparations for annexing the remainder of Czechoslovakia.

My Lord, at this point Jodl disappears from the scene for a time, because he goes to do some regimental soldiering as artillery general in Austria-artillery

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So far as Keitel is concerned, on the 21st October, 1938, less than a month after the Munich Pact, he countersigned Hitler's order to liquidate the rest of Czechoslovakia and to occupy Memel - Document C-136, Exhibit USA 104.

On the 24th November, 1938, Document C-137, Exhibit GB 33,. Keitel issued a memorandum about the surprise occupation of Danzig.

On the 17th December, 1939, Document C-138, Exhibit USA 105, he signed an order to the lower formations, "prepare for the liquidation of Czechoslovakia." These preparations were made.

On the 15th March, 1939, Keitel, who, I again repeat, was more than a mere soldier, was present at the midnight conference between the Fuehrer and Hacha, President of Czechoslovakia, when, under a threat of Prague being bombed, Hacha surrendered the rest of his country to the Germans. I refrain from referring to the contents of the minutes, which have been read many times already.

My Lord, so that milestone is past! And again I submit, in all that aggression, it is clear that Keitel was playing a vital part as Hitler's right-hand man, commanding all the Armed Forces under him.

I now pass to the Polish aggression. Keitel was present at the meeting at the Chancellery on 23rd May, 1939, Document L- 79, Exhibit USA 27, when it was said, quoting just a few words, so familiar: that Danzig was not the subject of the dispute; Poland was to be attacked at the first suitable opportunity; Dutch and Belgian air bases must be occupied; declarations of neutrality were to be ignored.

The directive for "Fall Weiss," the invasion of Poland, is Document C-120A, Exhibit GB 41. The date is the 3rd April, 1939. The Tribunal will remember, the plans were to be submitted to O.K.W. by the 1st May, and the forces were to be ready for invasion by the 1st September. And that directive is signed by Keitel.

Document C-126, Exhibit GB 45, is a follow-up of that previous directive, It is dated the 22nd June, 1939. The need for camouflage is emphasised, and it is stated: "Do not disquiet the population." That is signed by Keitel.

On the l7th August, 1939 - Document 795-PS, Exhibit GB 54 - Keitel had a conference with Admiral Canaris about the supplying of Polish uniforms to Heydrich, and it will be noticed in the last paragraph of the note that Admiral Canaris was against the war, and Keitel argued in favour of it. And Keitel made the prophecy that Great Britain would not enter the war.

I submit that Keitel's vital part, again, in the preparation for the aggression against Poland, is clearly established beyond the possibility of dispute.

Jodl, as I have said to the Tribunal, was recalled on the 23rd August, as seen in his diary entry, 1780-PS, where he says that he is recalled to take charge of the Operations Staff. He says:

"Received order from Armed Forces High Command to proceed to Berlin and take over position of Chief of Armed Forces Executive Office."

"11.00 hours to 13.30 hours - discussion with Chief of Armed Forces High Command. X-Day has been announced for the 26th August. Y-Time has been announced for 04.30 hours."

So Poland was invaded, and before I pass to the next aggression may I just point out that, according to the evidence of General Lahousen, if the Tribunal

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My Lord, I pass now to Norway and Denmark. So far as both are concerned, we see from Document C-54, Exhibit GB 86, that on the 12th December, 1939, Keitel and Jodl were both present at Hitler's conference with Raeder, when the invasion of Norway was discussed, and Keitel's direct responsibility to those operations is shown, in my submission, by Document C-63, Exhibit GB 87, in which Keitel says that the operations against Norway will be "under my direct and personal guidance." And he sets up a planning staff of O.K.W. for the carrying out of those operations.

Jodl's knowledge and complicity, in my submission, are clearly shown also from the entries in his own diary- Document 1809-PS. That is the second part of his diary. And the Tribunal will remember the entry of the 13th March, 1940, in which he records that the Fuehrer was still looking for an excuse for the "Weser" operations. That is the 13th March, my Lord, 1809-PS.

THE PRESIDENT: Yes. The date I have got is the 3rd.

MR. ROBERTS: Page 5 of that actual exhibit, the 13th March, according to my copy.

THE PRESIDENT: Yes, I see.

MR. ROBERTS: "The Fuehrer does not give the order yet for 'Weser.' He is still looking for an excuse."

And then, on the 14th March, "Fuehrer has not yet decided what reason to give for 'Weser' exercise," - which, in my submission, if I may be allowed to make a short comment, shows up in a lurid light the code of honour of the military leaders of Germany - still looking for an excuse.

My Lord, then, as we know, Norway was attacked unawares, and lying excuses were given.

My Lord, the invasion of the Low Countries and Luxembourg, in my submission, is equally clearly shown by the documents to have been controlled and directed by Keitel with Jodl's assistance. The Tribunal already have a note of the conference in May of the lands to be occupied, Documents L- 79. C-62, Exhibit GB 106 is a directive, signed Hitler, on the 9th October, 1939, and another directive, signed Keitel, on the 15th October. C-62 comprises two documents, the 9th October and 15th October, two directives, one signed Hitler, and one signed Keitel, both giving orders for the occupation of Holland and Belgium.

My Lord, Document C-10, Exhibit GB 108, dated the 8th November, is Keitel's operation orders for the 7th Parachute Division to make an airborne landing in the middle of The Hague.

Document 440-PS, Exhibit GB 107, dated the 20th November, 1939, signed Keitel, is a further directive for the invasion of Holland and Belgium.

Document C-72, Exhibit GB 109, 7th November, 1939, the 10th May, 1940, 18 letters, 11 signed by Keitel, 7 signed by Jodl: The Fuehrer is postponing A-Day because of the weather.

My Lord, Jodl's diary is also eloquent on that subject. That is Document 1809-PS. Several entries, perhaps I need not refer to them again, relating to these forthcoming operations, culminating with the one on the 8th May, which perhaps the Tribunal will remember, when Jodl says: "Alarming information from Holland," and he expresses righteous indignation that the wicked Dutchmen should erect roadblocks and make mobilisation preparations.

So those three neutral countries were invaded, and I submit there is copious and overwhelming evidence that these two men were in charge of the military organisations which made those invasions possible.

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Document 448-PS, Exhibit GB 118, 11thJanuary, 1941, Keitel initialled a Hitler order for the Greek operation.

Document C-134, Exhibit GB 119, 20th January, 1941, both Keitel and Jodl are present at the conference with Hitler, Mussolini and others when the operations against Greece and Yugoslavia are discussed.

Document C-59, Exhibit GB 121, 19th February, 1941, the dates of the operations against "Marita" are filled in by Keitel.

Document 1746-PS, Exhibit GB 120, 27th March, 1941, a conference with Hitler, Keitel and Jodl present, the decision to attack and destroy Yugoslavia is announced, and the Fuehrer said: "I am determined to destroy Yugoslavia. I shall use unmerciful harshness to frighten other neutrals"; and these two soldiers were present when that was said.

My Lord, I submit that on that, the complicity of these two men for that aggression is amply proved.

My Lord, I pass to "Barbarossa." Document 446-PS, Exhibit USA 31, dated 18th December, 1940, Hitler's order for the "Barbarossa" operation, initiated by Keitel and Jodl. Hitler says, the Tribunal will remember, that he intends to overthrow Russia in a single rapid campaign.

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