MR. DODD: This affidavit was put in by the United States as an exhibit. I do not have the number handy, but I think it was submitted at the time Colonel Telford Taylor submitted the case on behalf of the Prosecution against the High Command and the OKW. This Halder “affidavit,” the first document which Doctor Nelte referred to, is not an affidavit. It was a paper submitted to the Tribunal and to the Defense by Colonel Taylor. It set out some of the basic principles of the organization of the High Command and the OKW wholly before he presented his part of the case. It is really just the work of our own staff here in Nuremberg.
THE PRESIDENT: Doctor Nelte, as the document you are referring to, not the Halder affidavit, appears to be a mere compilation, the Tribunal thinks it should not go in as an exhibit, but you can put a question to the witness upon it.
DR. NELTE: [Turning to the defendant.] In the essay which you have before you, the Prosecution asserted the following: After 1938 there were four divisions: The OKW (High Command of the Wehrmacht); the OKH (High Command of the Army); the OKL (High Command of the Air Force); the OKM (High Command of the Navy); and each had its own general staff. What can you tell us about that?
KEITEL: I can say only that this is not correct, and also contradicts the description which I have already given of the functions of the High Commands of the Wehrmacht branches and of the OKW. There were not four such departments. There were only three: The High Command of the Army, the High Command of the Navy, and the High Command of the Air Force.
As I have just stated, the High Command of the Wehrmacht as a personal, direct working staff, was in no way an independent authority in that sense. The commanders-in-chief of the Wehrmacht branches were commanders, had the authority to issue orders and exercised this power over troops which were subordinate to them. The OKW had neither the power to issue orders, nor subordinate troops to which orders could have been issued. It is also not correct, if I recall the speeches of the Prosecution, to use the expression “Keitel was Commander-in-Chief of the Wehrmacht.” I am mentioning it only to emphasize this point. Further, I would like, briefly, to call attention to the diagram on the last page of the document which has been shown to me.
DR. NELTE: This sketch is the diagram which is called “The Wehrmacht.” It is an exposition, a diagrammatic exposition of the entire Wehrmacht and its branches.
KEITEL: I believe I should point briefly to the fact that it is this diagram which was the basis for this erroneous conception, because in it the High Command of the Wehrmacht is designated as a special office or office of command, and that is incorrect.
DR. NELTE: What tasks had you in this military sector as the Chief of the OKW?
KEITEL: First of all, it was an essential task to secure for the Führer with and through the Wehrmacht Operational Staff, all the documents and all the numerous informations and reports which he desired. I dare say that the Wehrmacht Operational Staff had, in this connection, the function to one might say arrange and establish direct and close communication between Hitler and the general staffs of the branches of the Wehrmacht. In addition to securing a countless number of such documents which were demanded daily, there was a second function, namely to be regularly present at all conferences in which the commanders-in-chief of the Wehrmacht branches and the chiefs of their staffs participated as well as the Chief of the Wehrmacht Operational Staff. On those occasions as soon as a series of oral orders was given, these orders, in compliance with military principles, naturally had later to be confirmed in writing. Only in this way could we prevent mistakes or misunderstandings from arising, that is, by confirming these orders to those who had already received them orally the orders were made clear. That is the purpose and meaning of the order.
DR. NELTE: How did you sign the orders and documents which you drew up?