An organization for all economic requirements and intended to supersede the former organization was created for Russia on the basis of experiences in the West by Reich Marshal Göring by virtue of a general delegation of authority by the Führer.

The chief of the Economic Armament Office together with State Secretary Körner drew up this organization for Reich Marshal Göring without participation by the Chief of the OKW. The Chief of the OKW for this purpose put General Thomas at the disposal of Reich Marshal Göring. The Chief of the OKW did not acquire any influence at all on this organization, and severed his own and the OKW’s connection with it after Reich Marshal Göring had received full powers and the OKW had put General Thomas at his disposal. General Thomas thus acted solely on instructions by Reich Marshal Göring. The OKW and the Defendant Keitel were never under Reich Marshal Göring’s orders nor were they bound by his instructions. The Defendant Keitel was not represented in Göring’s Economic Staff and had nothing to do with the Eastern Economic Staff (See Thomas book, Page 366).

The execution of the work was centrally directed by the Economic Operations Staff in Berlin as part of the Four Year Plan. The local higher command in the Eastern district was under the Eastern Economic Staff. To this organization was also attached the troops’ supply department. The OKW, and the Defendant Keitel as Chief of the OKW, never issued orders concerning the exploitation, administration, or confiscation of economic property in occupied territory. This is revealed in the book submitted by the Prosecution, Document 2353-PS. On Page 386 of this document, Thomas, in summarizing, correctly stated as follows:

“The Eastern Economic Operations Staff under the Reich Marshal or State Secretary Körner was responsible for the whole economic direction of the Eastern area; the state secretaries were responsible for departmental instructions; the Economic Armament Office was responsible for the reconstruction of the economic organization; the Eastern Economic Operations Staff was responsible for the execution of all measures.”

The same is shown by Document USSR-10:

“Directives (of Reich Marshal Göring) for the unified conduct of economic management in the zone of operations and in political administrative areas to be subsequently established.”

This ought to prove that the OKW and Keitel are clear of any responsibility for the consequences attendant upon carrying out the measures within the scope of the Barbarossa-Oldenburg operation.

I now come to Page 143 and following pages, where I refer to the assertion made by the French Prosecution regarding the participation of the OKW and Keitel in the cases of Oradour and Tulle.

The French Prosecution have charged the Defendant Keitel in person with the commission of war crimes and crimes against humanity. The accusation concerns in particular the execution of French civilians without a trial. In this connection the cases of Oradour and Tulle received special emphasis. They are recorded in a report made by the French Government—Document F-236. The French Prosecution stated: “Keitel’s guilt in all these things is certain.”

In this connection it is not my task to discuss the frightful events of Oradour and Tulle. As defense counsel for the Defendant Keitel I have to examine whether the Prosecution’s assertion that the Defendant Keitel bears any guilt or responsibility for these atrocious happenings has any foundation.