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I shall now proceed to the second group of documents presented by the Soviet prosecution, which characterise the espionage measures undertaken by the Fascist conspirators in preparation for war against the Soviet Union.

Trend and task of espionage work in connection with Case "Barbarossa," were, as we know, determined by a directive from the Supreme Command of the German Armed Forces, addressed to Counter- Intelligence on 6th September, 1940, and signed by the defendant Jodl.

This document, presented by the American prosecution as Document 1229- PS; it is to be found on Pages 46 and 47 of our document book. I do not intend to quote from this document again, but I do consider it essential to remind you that in it the intelligence organisations demand that the regrouping of armies on Germany's Eastern front should be camouflaged in every possible way and

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that the Soviet Union should remain under the impression that action of some kind was brewing against the Balkans.

The activities of the intelligence organisations were strictly regulated. These activities included measures for concealing, as far as possible, the number of German forces in the East and of giving an impression of insignificant concentrations in the North of the Eastern provinces, at the same time conveying the impression of very considerable concentrations of forces in the Southern part, in the Protectorate and in Austria.

The necessity was pointed out of creating an exaggerated impression of the number of anti-aircraft units and of the insignificant extent of road-building activities, etc.

I here take the liberty of making two pertinent observations. According to Pieckenbrock's testimony, the intensification of the work of these intelligence organisations against the Soviet Union began prior to the appearance of this directive in August, 1940. And this work, of course, was not limited to the spreading of false information on the regrouping of forces from West to East.

I beg you, your Honours, to revert to the testimony which I have already presented, of the former Chief of Abwehr III of the Intelligence and Counter-Intelligence Services of the German Army, von Bentivegny.

On Pages 1, 2 and 3 of the Russian text of Bentivegny's deposition, it is said -- I quote the passage (underlined in blue pencil) beginning at the last paragraph, Page 1 of the document, which corresponds to Page 37 of the document book:

"As early as November, 1940, I received from Canaris orders to intensify the work for counter-intelligence in the localities where concentration of the German armies on the Soviet-German frontier was taking place."

"In accordance with this order, I immediately gave the branches of the German military intelligence and counter-intelligence, Abwehrstelle Koenigsberg, Cracow, Breslau, Vienna, Danzig, and Poznan, the task of intensifying the countere-intelligence work."

"In March, 1941, I received from Canaris the following directives for the preparations for the execution of the Plan "Barbarossa."

(a) Preparation of all links of 'Abwehr III' (Counter- Intelligence, Department III) for carrying out active counter- intelligence work against the Soviet Union, as, for instance the creation of the necessary counter-intelligence groups, their distribution among various fighting units intended for taking part in the operations on the Eastern front, and paralysing the activity of the Soviet intelligence and counter-intelligence organs.

(b) Spreading false information via their foreign intelligence agencies, partly by creating the semblance of an improvement in relations with the Soviet Union and of preparations for a blow against Great Britain.

(c) Counter-intelligence measures to keep secret the preparations being made for war with the Soviet Union and to ensure that the transfer of troops to the East be kept secret."

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for the realisation of Case "Barbarossa." I would refer you to Page 35 of the document book, the 2nd paragraph from the top. This corresponds to Page 2 of Pieckenbrock's testimony. Pieckenbrock states:

"In March, 1941, I was present at a conversation between 'Abwehr II,' Colonel Lahousen, about measures connected with Case 'Barbarossa.' During this conversation they kept referring to a written order on this subject, which Lahousen had.

I, personally, as head of Abwehr I, from February, 1941, to 22nd June, 1941, more than once had official talks with the head of the Foreign Armies Department of the General Staff, Lieutenant- General Tiepelskirch, and with the head of the detachment Foreign Armies East, Colonel Kienzl. These conversations dealt with the more precise definition of various tasks assigned to Abwehr, with regard to the Soviet Union, and in particular with the verification of old intelligence data about the Red Army, and also details about the dislocation of the Soviet armies during the period of preparation of the attack on the Soviet Union."

"The field offices of the 'Abwehrstelle,' which were working against Russia, were given the task of intensifying the dispatch of agents to the U.S.S.R. A similar task -- the intensification of espionage work against Russia -- was given to all intelligence agencies existing in the armies and army groups. For the most successful direction of all these 'Abwehr' agencies, a special intelligence staff was created in May, 1941, under the code name of 'Wally I.'

Major Baun, as the best specialist on work against Russia, was appointed to direct Operation 'Wally I.' Later, when following our example, 'Abwehr II' and 'Abwehr III' had also established staffs, 'Wally II' and 'Wally III,' these agencies became known as a whole staff , 'Wally,' and directed the entire intelligence, counter-intelligence, and diversionary work against the U.S.S.R. At the head of staff 'Wally' was Colonel Schmalschlaeger."

"From numerous reports given by Colonel Lahousen to Canaris, at which I was also present, I know that a great deal of preparatory work for the war with the Soviet Union was carried out by this department. In the period of February to May, 1941, many conferences of the leaders of 'Abwehr II' took place at the quarters of Jodl's deputy, General Warlimont. They were held in a cavalry school, in the small town of Krampnitz. One particular question settled at these conferences in accordance with the needs of the war with Russia, was that of increasing the special task units, 'Brandenburg 800,' and of distributing contingents of these units among the individual Army Groups."

These points are here clarified by the testimony of a former Colonel of the German Army, Erwin Stolze, who was Lahousen's deputy in Abwehr II of of the German Military Intelligence and Counter-Intelligence Services attached to the Supreme Command of the German Armed Forces. Stolze was taken prisoner by the Red Army. I wish to submit to the Tribunal as evidence

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Stolze's testimony of 25th December, 1945, which was given to Lieutenant-Colonel Burashnikov, of the Counter-Intelligence Service of the Red Army and which I submit to the Tribunal as Exhibit USSR 231 with the request that it be accepted as evidence. I will read into the record individual extracts from this testimony, which are underlined in red pencil. I begin the quotation from Page 48 of the document book. Stolze testified as follows:

"I received instructions from Lahousen to organise and to lead a special group under code name 'A,' which had to engage in the preparation of diversionary activities, and in the work of disintegration of the Soviet rearguard, in connection with the intended attack on the U.S.S.R.

At the same time, in order that I should become acquainted with it, and for my guidance, Lahousen gave me an order which came from the Operational Staff of the Armed Forces and was signed by Field Marshal Keitel and General Jodl -- or General Warlimont on Keitel's instructions, I do not quite remember which -- and which contained basic directives for the conduct of subversive activities in the territory of the U.S.S.R., after Germany's attack on the Soviet Union. The order in question was for the first time marked with the code name 'Barbarossa.'"

"It was pointed out in the order that for the purpose of delivering a lightning blow against the Soviet Union, 'Abwehr II,' in conducting subversive work against Russia, must use its agents for kindling national antagonism among the people of the Soviet Union."

"In carrying out the above-mentioned instructions of Keitel and Jodl, I contacted Ukrainian Nationalists who were in the German Intelligence Service and other members of the Nationalist Fascist groups, whom I enlisted in to carry out the tasks as set out above. In particular, instructions were given by me personally to the leaders of the Ukrainian Nationalists, the German Agents Myelnik (code name 'Consul I') and Bandara to organise, immediately upon Germany's attack on the Soviet Union, and to provoke demonstrations in the Ukraine, in order to disrupt the immediate rear of the Soviet Armies, and also to convince international public opinion of alleged disintegration of the Soviet rear. We also prepared special diversionist groups for subversive activities in the Baltic Soviet Republics."

"Apart from this, a special military unit was trained for subversive activities on Soviet territory, a special duty training regiment `Brandenburg 800,' under the immediate command of the head of `Abwehr II,' Lahousen. Among the objects of this special unit, created in 1940, was the seizure of operationally important points, such as bridges, tunnels and defence installations, and holding them till the arrival of the advance units of the German Army.

During the course of preparations for Germany's attack on the U.S.S.R., the command of the 'Brandenburg 800' regiment also collected

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supplies of Red Army uniforms, equipment and arms, and organised separate detachments of Germans acquainted with the Russian language."

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