[Page 41]

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]

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]

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."

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]

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]

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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