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speeches or anything of that sort. We simply cannot be put under that kind of a burden. I think it is - a citizen of the United States is expected to argue his case in the highest court of the land in one hour, and counsel's own clients here have openly scoffed at the amount of time that has been asked. This is not a sensible amount of time to give to this case, and I must protest against being expected to mimeograph 20 days of speeches. It really is not possible.

THE PRESIDENT: The Tribunal would like to know whether the Prosecution intend to let them have copies of their speeches at the time that they are delivered.

SIR DAVID MAXWELL-FYFE: As far as the closing speech of the Attorney General is concerned, we certainly did expect and hope to give the Tribunal copies of the speech.

THE PRESIDENT: And translations?

SIR DAVID MAXWELL-FYFE: Yes, that will be done. My Lord, I just wondered, out of optimism-it was Dr. Nelte who said that it would take a long time to translate. I know, as. far as translating into English is concerned, we had the problem of a 76-page speech the other day, and that was done by our own translators in one day. So I hope that perhaps Dr. Nelte has been a little pessimistic about that side of the problem.

THE PRESIDENT: The Tribunal will consider the matter. Now, the Tribunal will go on with the cross-examination. [The Defendant Speer resumed the stand.}

MR. JUSTICE JACKSON: I think perhaps, Your Honor, the photographs in evidence are left a little unintelligible, if the record does not show the description of them. I shall read it briefly.

"Torture cabinets which were used in the foreign workers' camp in the grounds of Number 4 Armor Shop and those in the dirty neglected Russian Camp were shown to us, and we depose the following on oath:

"Photograph 'A' shows an iron cupboard which was specially manufactured by the .firm of Krupp to torture Russian civilian workers to an extent that cannot possibly be described in words. Men and women were often locked into a compartment of the cupboard , in which hardly any man could stand up for long periods. The measurements of this compartment are: Height 1.52 meters; breadt h and dept h 40 to 50 centimeters each. Frequently even two people were kicked and pressed into one compartment. The Russian ... "

I will not read the rest of that.

"Photograph 'B' shows the same cupboard as it look when it is locked.




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"Photograph 'C' shows the cupboard open.

"In Photograph 'D' we see the camp that was selected by the Krupp Directorate to serve as living quarters for the Russian civilian workers. The individual rooms were 2 to 2 1 /1 meters wide, 5 meters long, and 2 meters high. In each room up to 16 persoas were accommodated in double tier bedl."(Document USA-B97)

I think that covers it.

THE PRESIDENT: Mr. Justice Jackson, one moment. I think you ought to read the last three lines of the second paragraph, beginning, "At the top of the cupboard ... "

MR. JUSTICE JACKSON: Oh yes, I am sorry.

"At the top of the cupboard there are a few sievelike air holes through which cold water was poured on the unfortunate victims during the ice-cold winter."

THE PRESIDENT: I think you should read the last three lines of the penultimate paragraph in view of what the defendant said about the evidence.

MR. JUSTICE JACKSON: "We are enclosing two letters which Camp Commandant LOwenkamp had smuggled out of prison in order to induce the undersigned Hofer to give evidence favorable to him."

And perhaps I should read the last:

"The undersigned Dahm "-one of the signers -"personally saw how three Russian civilian workers were locked into the cupboard two in one compartment after they had first been beaten on New Year's Eve 1945. Two of the Russians had to stay the whole of New Year's Eve locked in the cupboard, and cold water was poured on them as well."

I may say to the Tribunal that we have upwards of a hundred different statements and depositions relating to the investigation of this camp. I ain' not suggesting offering them, because I think they would be cumulative, and I shall be satisfied with one mote, D-313, which would become Exhibit USA-901, which is a statement by a doctor.

THE PRESIDENT: Mr. Justice Jackson, was this camp that you are referring to a concentration camp?

MR. JUSTICE JACKSON: Well, it was, as I understand it, a prisoner-of-war camp and a labor camp. There were labor camps and prisoner-of-war camps at Essen. I had not understood that it was a concentration camp, but I admit the distinction is a little thin at times.




(An objection from defendant Speer)

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before and after their work. Any expert in Germany can tell you that these are wardrobes and not some specIal cabinets, because they are mass-produced articles. This is also confirmed by the fact that there are air vents at the top, for every wardrobe has these ventilation holes at the top and bottom.

MR. JUSTICE JACKSON: As Production Minister, you were

IMT XVI - 561


SPEER: What is pictured here is quite a normal locker as was used in every factory. These photographs have absolutely no value as evidence.


IMT XVI - 546

(Note the manner in which an innocuous object is transformed into Holocaust "evidence" by means of an "affidavit" signed by a "witness" whose veracity. credibility and existence are left unproven. The "statement" may be entirely typewritten, including the signature. Typically, it is a "certified true copy" of an original whose whereabouts are unknown. even today.)