THE PRESIDENT: Well, if they have, I must confess that I have forgotten. It seems to me and the Tribunal generally that you are taking up far too long on this topic. You have got many other topics which are of very great importance to the defendant, and you have already been speaking for several hours, and you occupied a large number of pages in order to try and define what Keitel’s position was. I thought you might be able to cut it down.
DR. NELTE: I shall try.
I have explained that Defendant Keitel did not belong to Group 1; that is to say, that he was not a minister.
He was neither chief of a Government department, nor a Reich minister without portfolio, nor a state minister having the functions of a Reich minister, nor an official who was entitled to attend Cabinet sessions.
In the hearing of evidence it was proved that despite the Führer Decree of 4 February 1938 there never existed a Secret Cabinet Council; that such council was never set up; that it never held a session; and that no persons involved ever received a commission. Thus, it is proved that the defendant was also never a member of the Secret Cabinet Council.
It is true that Keitel was a member of the Ministerial Council for the Defense of the Reich. Witness Dr. Lammers has confirmed that the fact of his becoming a member of the Ministerial Council for the Defense of the Reich did not change Keitel’s official position, and especially did not make him a minister. In his affidavit of 25 November 1945, Codefendant Dr. Frick says that Keitel worked in the Ministerial Council for the Defense of the Reich as “liaison man.”
Although he is not listed among the members of the Reich Cabinet, Keitel’s capacities as a member of the so-called “Dreimänner-Kollegium” (Three Man College) and as a member of the Reich Defense Council have been mentioned by the Prosecution. I believe I may refer to the result of the hearing of evidence. It was shown that a Three Man College as a Government committee never existed, and that the Reich Defense Council, after the unpublished Reich Defense Law of 1938, never held sessions, or in any case that it never held conferences, or passed resolutions.
In order to clarify the Defendant Keitel’s responsibility and competence it is necessary to analyze the concept of OKW. I ask that this statement be not considered a theoretical and therefore superfluous discussion. The very fact that the Prosecution makes a sweeping and fundamental assertion...
THE PRESIDENT: Dr. Nelte, may I ask what you have been doing if you have not been analyzing the concept of the OKW?
DR. NELTE: Up to now I have explained Keitel’s position as Chief of the OKW. In statements on Page 74 and the following pages I wanted to explain to you that the Prosecution, and others as well, have talked about the OKW: and “OKW” is a word which has three different types of significance.