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  Concentration of the main effort of the Navy remains

  unequivocally against England also during an Eastern



  If occasion arises I will order the concentration of

  troops for action against Soviet Russia eight weeks

  before the intended beginning of operations.


  Preparations requiring more time to start are - if this

  has not yet been done - to begin presently and are to be

  completed by 15th May, 1941.


  Great caution has to be exercised that the intention of

  an attack will not be recognised.


  The Preparations of the High Command are to be made on

  the following basis:

  1. General Purpose:

  The mass of the Russian Army in Western Russia is to be

  destroyed in daring operations by driving forward deep

  wedges within ranks and the retreat of intact battle-

  ready troops into the wide spaces of Russia is to be



  In quick pursuit a line is to be reached from where the

  Russian Air Force will no longer be able to attack German

  Reich territory. The first goal of operations is the

  protection from Asiatic Russia of the general line Volga-

  Archangelsk. In

                                                  [Page 177]

  case of necessity, the last industrial area in the Urals

  left to Russia could be eliminated by the Luftwaffe.


  In the course of these operations the Russian Baltic Sea

  Fleet will quickly lose its bases and will no longer be

  ready to fight.


  Effective intervention by the Russian Air Force is to be

  prevented through powerful blows at the beginning of the


Another secret document, captured from the O.K.W. files--

THE PRESIDENT: Mr. Alderman, perhaps that would be a

convenient time to adjourn for ten minutes.

A recess was taken)

MR. ALDERMAN: If it please the Tribunal, another secret

document captured from the O.K.W. files, establishes, we

think, the motive for the attack on the Soviet Union. It

also establishes the full awareness of the Nazi conspirators

of the crimes against humanity which would result from their

attack. The document is a memorandum Of 2nd May, 1941,

concerning the result of a discussion on that day with the

State Secretaries concerning the "Case Barbarossa." The

document is initialled by a Major von Giessavet, a member of

the staff of General Thomas, set up to handle the economic

exploitations of the territory occupied by the Germans

during the course of the aggression against Russia. The

document is numbered 2718-PS, and our numbered series of

documents are offered in evidence as exhibit USA 32.

I shall simply read the first two paragraphs of this

document, including the introductory matter:

   "Matter for Chief; 2 copies; first copy to files 1a.


   Second copy to General Schubert, 2nd May, 1941.


   Memorandum about the result of today's discussion with

   the State Secretaries about Barbarossa.


   (1) The War can only be continued if all Armed Forces

   are fed by Russia in the third year of War.


   (2) There is no doubt that as a result many millions of

   people will be starved to death if we take out of the

   country the things necessary for us."

That document has already been commented on and quoted from

in Mr. Justice Jackson's opening statement. The staggering

implications of that document are hard to realise. In the

words of the document, the motive for the attack was that

the War which the Nazi conspirators had launched in

September 1939, could only be continued if all Armed Forces

were fed by Russia in the third year of the War. Perhaps

there never was a more sinister sentence written than the

sentence in this document which reads:-

"There is no doubt that as a result many millions of people

will be starved to death if we take out of the country the

things necessary for us."

The result is known to all of us.

I turn now to the Nazi collaboration with Italy and Japan

and the resulting, attack on the United States on 7th

December, 1941. With the unleashing of the German aggressive

war against the Soviet Union in June 1941, the Nazi

conspirators and, in particular, the defendant Ribbentrop,

called upon the Eastern co-architect of the New Order,

Japan, to attack in the rear. Our evidence will show that

they incited and kept in motion a force reasonably

calculated to result in an attack on the United States. For

a time, they maintained their preference that the United

States should not be involved in the conflict, realising the

military implication of an entry of the United States into

the War. However, their incitement did result in the attack

on Pearl Harbour, and long prior to that attack, they had

assured the Japanese that they would declare War on the

United States should

                                                  [Page 178]

a United States-Japanese conflict break out. It was in

reliance on those assurances that the Japanese struck at

Pearl Harbour.

On the present discussion of this phase of the case, I shall

offer only one document to prove this point. The document

was captured from the files of the German Foreign Office. It

consists of notes dated 4th April, 1941, signed by

"Schmidt," regarding discussions between the Fuehrer and the

Japanese Foreign Minister Matsuoka, in the presence of the

defendant Ribbentrop. The document is numbered 1881 PS in

our numbered series and I offer it in evidence as exhibit

USA 33. In the original, it is in very large, typewritten

form in German. I shall read what I deem to be the pertinent

parts of this document, beginning with the four paragraphs,

first reading the heading, the heading being:

    "Notes regarding the discussion between the Fuehrer and

    the Japanese Foreign Minister, Matsuoka, in the

    presence of the Reich Foreign Minister and the Reich

    Minister of State, Reissner, in Berlin, on the 4th

    April, 1941.


    Matsuoka then also expressed the request, that the

    Fuehrer should instruct the proper authorities in

    Germany to meet as broad-mindedly as possible the

    wishes of the Japanese Military Commission. Japan was

    in need of German help particularly concerning the U-

    boat warfare, which could be given by making available

    to them the latest experiences of the war is well as

    the latest technical improvements and inventions."

For the record, I am reading on what is page six of the

German original.

    "Japan would do her utmost to avoid a war with the

    United States. If Japan should decide to attack

    Singapore, the Japanese Navy, of course, had to be

    prepared for a fight with the United States, because in

    that case America probably would side with Great

    Britain. He (Matsuoka) personally believed that the

    United States could be restrained by diplomatic

    exertions from entering the war at the side of Great

    Britain. Army and Navy had, however, to count on the

    worst situation, that is on war against America. They

    were of the opinion that such a war would extend for

    five years or longer and would take the form of

    guerrilla warfare in the Pacific and would be fought

    out in the South Sea. For this reason the German

    experiences in her guerrilla warfare were of the

    greatest value to Japan. It was a question how such a

    war would best be conducted and how all the technical

    improvements of submarines, in all details such as

    periscopes and such like, could best be exploited by



    To sum up, Matsuoka requested that the Fuehrer would

    see to it that the proper German authorities would

    place at the disposal of the Japanese those

    developments and inventions concerning Navy and Army,

    which were needed by the Japanese.


    The Fuehrer promised this and pointed out that Germany

    too considered a conflict with the United States

    undesirable, but that it had already made allowances

    for such a contingency. In Germany one was of the

    opinion that America's contributions depended upon the

    possibilities of transportation, and that this again is

    conditioned by the available tonnage. Germany's war

    against tonnage, however, means a decisive weakening

    not merely against England, but also against America.

    Germany has made her preparations so that no American

    could land in Europe. She would conduct a most

    energetic fight against America with her boats and her

    'Luftwaffe,' and due to her superior experience, which

    would still have to be acquired by the United States,

    she would be vastly superior, and that quite apart from

    the fact that the German soldiers naturally rank high

    above the Americans.


    In the further course of the discussion, the Fuehrer

    pointed out that Germany, on her part, would

    immediately take the consequences if Japan would get

    involved with the United States. It did not matter with

    whom the United States would first get involved,

    whether Germany or Japan. They would always try to

    eliminate one country at a time, not to come to an

    understanding with the other country subsequently, but

    to liquidate this one just the same. Therefore Germany

    would strike, as already mentioned, without delay in

    case of a conflict between Japan


                                                  [Page 179]


    and America, because the strength of the tripartite

    powers lies in their joint action;  their weakness

    would be if they would let themselves be beaten



    Matsuoka once more repeated his request, that the

    Fuehrer might give the necessary instructions, in order

    that the proper German authorities would place at the

    disposal of the Japanese the latest improvements and

    inventions, which are of interest to them, because the

    Japanese Navy had to prepare immediately for a conflict

    with the United States.


    As regards Japanese-American relationship, Matsuoka

    explained further that he has always declared in his

    country, that sooner or later a war with the United

    States would be unavoidable, if Japan continued to

    drift along as at present. In his opinion this conflict

    would happen rather sooner than later. His argument

    went on, why should Japan, therefore, not strike

    decisively at the right moment and take the risk upon

    herself of a fight against America? Just thus would she

    perhaps avoid a war for generations, particularly if

    she gained predominance in the South Seas. There were,

    to be sure in his opinion, in Japan, many who would

    hesitate to follow those trends of thought. Matsuoka

    was considered in those circles a dangerous man with

    dangerous thoughts. He, however, stated that, if Japan

    continued to walk along her present path, one day she

    would have to fight anyway and that this would then be

    under less favourable circumstances than at present.


    The Fuehrer replied that he could well understand the

    situation of Matsuoka, because he himself had been in

    similar situations (the clearing of the Rhineland,

    declaration of Sovereignty of Armed Forces, etc.). He

    too was of the opinion that he had to exploit

    favourable conditions and accept the risk of an anyhow

    unavoidable fight at a time when be himself was still

    young and full of vigour. How right he was in his

    attitude was proven by events. Europe now was free. He

    would not hesitate a moment to reply instantly to any

    widening of the war, be it by Russia, be it by America.

    Providence favoured those who would not let dangers

    come to them, but who would bravely face them.


    Matsuoka replied, that the United States or rather

    their ruling politicians, had recently attempted a last

    manoeuvre towards Japan, by declaring that America

    would not fight Japan on account of China or the South

    Seas, provided that Japan gave free passage to the

    consignment of rubber and tin to America to their place

    of destination. However, America would fight against

    Japan the moment she felt that Japan entered the war

    with the intention of assisting in the destruction of

    Great Britain. Such an argument naturally did not miss

    its effect upon the Japanese, because of the education

    oriented on English lines which many of them had



    The Fuehrer commented on this, that this attitude of

    America did not mean anything but that the United

    States had the hope, that, as long as the British World

    Empire existed, one day they could advance against

    Japan together with Great Britain, whereas, in case of

    the collapse of the World Empire, they would be totally

    isolated and could not do anything against Japan.


    The Reich Foreign Minister interjected that the

    Americans definitely under all circumstances wanted to

    maintain the powerful position of England in East Asia,

    but that on the other hand it was proved by this

    attitude, to what extent she fears a joint action of

    Japan and Germany.


    Matsuoka continued that it seemed to him of importance

    to give to the Fuehrer an absolutely clear picture of

    the real attitude inside Japan. For this reason he also

    had to inform him regretfully of the fact that he,

    Matsuoka, in his capacity as Japanese Minister for

    Foreign Affairs could not utter in Japan a single word

    of all that he had expounded before the Fuehrer and the

    Reich Foreign Minister regarding his plans, as this

    would cause him serious damage in political and

    financial circles. Once before, he had committed the

    mistake, before he became Japanese Minister for Foreign

    Affairs, of telling a close friend something about his

    intentions. It seems that the latter had mentioned

    these things and thus brought about all sorts


                                                  [Page 180]


    of rumours, which he as Foreign Minister had to oppose

    energetically, though as a rule lie always tells the

    truth. Under these circumstances he also could not

    indicate how soon he could report on the questions

    discussed, to the Japanese Premier or to the Emperor.

    He would have to study exactly and carefully in the

    first place the development in Japan, so as to decide

    on a favourable moment, for making a clean breast of

    his proper plans to the Prince Konoye and the Emperor.

    That decision would have to be made within a few days,

    otherwise the plans would be spoiled by talk.


    Should he, Matsuoka, fill to carry out his intentions,

    that would be proof that he was lacking in influence,

    in power of conviction, and in tactical capabilities.

    However, should he succeed, it would prove that he had

    great influence in Japan. He himself felt confident

    that he would succeed.


    On his return, being questioned, be would indeed admit

    to the Emperor, the Premier and the Ministers for the

    Navy and the Army, that Singapore had been discussed;

    he would, however, state that it was only on a

    hypothetical basis.


    Besides this Matsuoka made the express decision not to

    cable in the matter of Singapore, because he had reason

    to fear that by cabling something might leak out. If

    necessary, he would send a courier.


    The Fuehrer agreed and assured him after all, that he

    could entirely rely on German reticence.


    Matsuoka replied he believed indeed in German

    reticence, but unfortunately could not say the same for



    The discussion was terminated after the exchange of

    some personal parting words.


    Berlin, the 4th of April, 1941

    (Signed) "Schmidt."

This completes the presentation of what I have called the

"handful of selected documents," offered not as a detailed

treatment of any of these wars of aggression but merely to

prove the deliberate planning, the deliberate premeditation

with which each of these aggressions was carried out.

I turn to a more detailed and more or less chronological

presentation of the various stages of the aggression.

THE PRESIDENT: The Tribunal will now adjourn until ten

o'clock tomorrow.

 (The Tribunal adjourned until 27th November, 1945, at 10.00


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