1. I was born in Berlin on 27 August 1914. 1 went to school at Eisenberg (Thuringia) and at Berlin-Lichterfelde, including a trade school. In March 1931 I left school having obtained my school certificate [Obersekundareife].

2. From April 1931 to August 1933 1 worked for a lawyer. Later on I became a civilian employee in the Bremen office of the Reich Chancellery.

3. On 10 October 1934 1 became a civilian employee with the SD and remained there until the end of the war. On 1 May 1934 I was taken over from the Hitler Youth into the Party and held membership card No. 3,474,350. On 10 October 1934 I became a member of the SS with the membership No. 107,326.

4. In October 1941 I was assigned to the Einsatzgruppe D. I did not take part in the courses and setup of the Einsatzgruppe in Dueben which took place previously, neither did I take part in the beginning of the Russian campaign.

5. When arriving at Nikolaev in October 1941 1 was ordered to a conference with gruppenfuehrer Otto Ohlendorf, who at that time was the chief of Einsatzgruppe D. Ten more men who had arrived in a transport together with me attended this conference. The purpose of this conference was that Ohlendorf wanted to find out for which post a man was suited and could be used. None of us was meant to be leader of an Einsatzkommando. We were delegated to different units, most of them went to an Einsatzkommando, while I stayed with the staff. We only got acquainted with the work of the Einsatzgruppen, Einsatz- and Sonderkommandos after having joined these units. When leaving Berlin we were not told about the activities of these units. I became Ohlendorf's adjutant.

6. During this period I learned that two new leaders came to Ohlendorf who later on received an Einsatzkommando each. After their arrival they had a lengthy conversation with Ohlendorf; I was not present. Based on my own experiences, I can say for certain that these two leaders during their conversation with Ohlendorf received instructions regarding their services. The reports of these leaders arriving at our headquarters were written in the manner prescribed by Ohlendorf and also contained information as to the number of Russians and Jews executed.

*Defendant Schubert testifled on 54 January 1948 (Tr. pp. 4560-4788).

7. The Einsatzgruppe reported in two ways to the Reich Security Main Office, once through radio, then in writing. The radio reports were kept strictly secret and, apart from Ohlendorf, his deputy Standartenfuehrer Willy Seibert and the head telegraphist Fritsch, nobody, with the exception of the radio perisonnel, was allowed to enter the radio station. This is the reason why only the above-mentioned persons had knowledge of the exact contents of these radio reports. The reports were dictated directly to Fritsch by Ohlendorf or Seibert. After the report had been sent off by Fritsch, I received it for filing. In cases in which numbers of executions were reported a space was left open, so that I never knew the total amount of persons killed. The written reports were sent to Berlin by courier. These reports contained exalt details and descriptions of the places in which the actions had taken place, the course of the operations, losses, number of places destroyed and persons killed, arrest of agents, reports on interrogations, reports on the civilian sector, etc.

8. When Ohlendorf was absent from the staff of the Einsatzgruppe, no reports were sent to Berlin. As a rule his deputy Seibert accompanied him on his journeys of inspection and I was ordered "to look after the house", without, however, being allowed to solve any problems which might occur. I was never initiated into secret orders and when Ohlendorf and Seibert were absent from the staff, no decisions could be made. I do not know whether Ohlendorf had any secret files or whether he had statements as to the total number of executions.

9. I do not know whether the Einsatzgruppen or the Einsatzkommandos received orders concerning the execution of Russian prisoners of war. If these orders had come in through the normal channels, I would have seen them. This, however, does not exclude that Ohlendorf had them as secret files in his office.

10. From summer 1942 until the end of 1944 1 was Ohlendorf's adjutant in office III of the Reich Security Main Office and later on I worked under Dr. Hans Ehlich in office III B of the Reich Security Main Office. It is known to me that both of them received the compiled reports of the Einsatzgruppen which were issued as reports on the situation from the occupied eastern territories.

I have read the foregoing deposition consisting of 4 pages in the German language, and declare that it is the full truth to the best of my knowledge and belief. I have had the opportunity to make alterations and corrections in the above statement. I made this declaration voluntarily without any promise of reward and I was not subjected to any duress or threat whatsoever.

Nuernberg, Germany, 4 February 1947.