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"He must give the order that in case foreign seamen could not be taken prisoner

U-boats were to surface after torpedoing and shoot up the lifeboats.”

The evidence shows constant pressure by Hitler from then on for the issue of this order. It is admitted that he demanded it at a meeting with both Doenitz and Raeder on the 14th May and that he raised the question again on the 5th September. Doenitz himself referred to pressure by Hitler during the “Laconia” incident. You have confirmation that the order issued on the 17th September was intended to bear the construction put upon it by the Prosecution in the evidence of the witness Heisig and that of Moehle. Is it conceivable that a senior officer would have been allowed to go on from the 17th September 1942 until the end of the war briefing the hundreds of U-boats which set out from Kiel that this was an order to annihilate unless that was what the Naval War Staff intended? You have the evidence that Doenitz himself saw every U-boat commander before and after his cruise, his own admissions with regard to the comments made by his staff officers at the time he drafted the order and his general attitude revealed by the order of October 1939, which he admits was a non-rescue order—an utterly indefensible order in itself in the submission of the Prosecution. There is further the coincidence that the very argument which Hitler advanced to Oshima, namely, the importance of preventing the Allies finding the crews for the immense American construction programme, was the argument Doenitz himself admits putting forward on the 14th May, was the argument which Heisig reports hearing, and is the reason given for the subsequent order to give priority in attacking convoys to sinking rescue ships. You have the instances of the "Antonice”, the “Noreen Mary", and the "Peleus” whilst the man who expressed horror at the idea that he should issue such an order admittedly saw the log of the U-boat which sank the "Sheaf Mead” with its brutal entry describing the sufferings of those left in the water. Doenitz' own statement was that “to issue such a directive could only be justified if a decisive military success could be achieved by it." Was it not because, as his own document shows, the percentage of ships being sunk outside convoys in September 1942, was so high that a decisive military success might have been gained that this order was issued, whereas in April 1943, when almost all sinkings were in convoy, it was not necessary to issue a further order yet more explicit in its terms?

The Prosecution firmly and strongly submit that the defendant Doenitz intended by that order to encourage and procure as many submarine commanders as possible to destroy the crews of torpedoed merchant ships but deliberately couched the order in its

present language so that he could argue the contrary if circumstances required it. On the evidence of Admiral Wagner that the Naval War Staff approved the order of 17th September 1942 with respect to survivors, Raeder cannot escape responsibility and, indeed, since he was present at the meeting with Hitler in May of that year and received the Fuehrer order of the 5th September 1942 to issue instructions to kill survivors, there can be little doubt that he was fully involved in his subordinate's Policy.

Although within a few months Allied air power made it impossible for U-boats in most areas to risk surfacing at all after they had discharged their torpedo, and the question became one of less importance, it is interesting to note that when the order against rescue ships was issued on the 7th of October the following year the same phrase "destruction of ship's crews" recurred (D-663, GB 200).

Despite the denial of Kapitan Leutnant Eck, there can really be no real doubt that, briefed by Hoehle, he did what his superior Officers intended him to do. Why should it be supposed that a man, who a month later received Hitler's Commando Order without protest, should shrink from ordering the destruction of seamen on rafts or clinging to wreckage, when Hitler had explained its military necessity. Eck, who obeyed the orders of Raeder and Doenitz, has paid the supreme penalty. Are they to escape with less ?

Belligerent Occupation

(a) SLAVE LABOR I turn now to yet another war crime—the use of slave labour. Its importance for the German war machine had been appreciated by these Defendants long before the outbreak of war. Hitler had mentioned it in "Mein Kampf" and emphasized it at the meeting in May 1939. A few weeks later in June the Reich Defense Council, Goering, Frick, Funk and Raeder and representatives of every other Ministry of State were planning to employ 20,000 concentration camp inmates and hundreds of thousands of workers from the Protectorate in the coming war (L-79, USA 27; 3387-PS, USA 566).

Hitler's plan for Poland, revealed to Schirach and Frank, was as follows (USSR 172):

“The ideal picture is this—a Pole may possess only small holdings in the Government General which will to a certain extent provide him and his family with food. The money required by him for clothes, etc., he must earn in Germany by work. The Government General must become a centre for supplying unskilled labour, particularly agricultural labour.

The subsistence of these workmen will be fully guaranteed because they can always be made use of for cheap labor.”

That policy, was, of course, a short-term policy, the real aim being the elimination of the Eastern peoples. Sauckel was appointed Plenipotentiary with the task of replacing two million German workers who had been called to service with the Wehrmacht, and he, himself says that after Hitler had emphasized that it was a war necessity he had no scruples and within a month of his appointment he had sent his first labour mobilization programme to Rosenberg (016-PS, USA 168).

“Should we not succeed in obtaining the necessary labour on a voluntary basis we must immediately institute conscription of forced labour

a gigantic number of new foreign slave workers

men and women an indisputable necessity.” This programme he was to carry out (017-PS, USA 180) "with every possible pressure and a ruthless commitment of all our resources.”

It is unnecessary to refer to the voluminous evidence of the execution of this policy for the recruitment of workers. It is sufficient to quote Sauckel again addressing the Central Planning Board in March of 1944 (R-124, USA 179):

“Trained male and female agents who shanghaied men for labour in Germany

Out of five million foreign workers who arrived in Germany not even 200,000 came voluntarily."

The methods employed in their forced deportations are hideous in their brutality and must have been known to every one of these defendants. In April of 1941 Himmler was addressing the officers of the SS Leibstandarte Adolf Hitler (1918-PS, USA 304):

"Very frequently a member of the Waffen SS thinks about the deportation of this people, here. These thoughts come to me today watching the very difficult work performed by the Security Police and supported by your men who help them a great deal. Exactly the same thing happened in Poland in weather 40 degrees below zero where we had to haul away thousands, tens of thousands, hundreds of thousands." And again (1919-PS, USA 170):

“Whether 10,000 Russian females fall down from exhaustion while digging an anti-tank ditch interests me only in so far as the anti-tank ditch for Germany is finished

*. When somebody comes to me and says, 'I can't dig the anti-tank ditch with women and children, it is inhuman, for it would kill

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them', then I have to say that you are a murderer of your own blood because if the anti-tank ditch is not dug, German soldiers will die and they are the sons of German mothers We must realize that we have 6-7 million foreigners in Germany. * *. Perhaps it is even eight million now. We have prisoners in Germany. They are none of them dangerous so long as we take severe measures at the merest trifle."

By August 1943 the need for workers was even greater. Himmler ordered (744-PS, USA 455):

“That all young female persons capable of work are to be sent to Germany for work through the agency of Reich Commissioner Sauckel. Children, old women and men are to be collected and employed in women's and children's camps."

The orders issued to Group Leaders of the SD, active in the Ukraine, showed the same urgency (3012-PS, USA 190): "The activity of the Labour Office

is to be supported to the greatest extent possible. It will not be possible always to refrain from using force

When searching villages, especially when it has become necessary to burn down a village, the whole population will be put at the disposal of the Commissioner by force. As a rule, no more children will be shot

If we limit our harsh measures through the above orders for the time being, it is only done for the following reason. The most important thing is the recruitment of workers."

Speer admitted—how could he deny it—the knowledge and approval of the way the workers were enrolled and brought to Germany against their will; there was Kaltenbrunner's letter to his friend Blaschke (3803-PS, USA 802):

"For special reasons I have in the meantime given orders to ship several evacuation transports to Vienna, at present four shipments with approximately 12,000 Jews are pending. They should reach Vienna within the next few days Women unable to work and children of those Jews who are all kept in readiness for special action and therefore one day will be removed again, have to stay in the guarded camp also during the day.”

That sinister phrase again—the meaning of which they all knew so well—“special treatment”, “special action”. Murder remains murder by whatever euphemism murderers may seek to describe it.

The need for labour became so urgent that not only were even Jews spared the gas chambers so long as they were fit for employment but children were seized and put to work.

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So much for their deportation to Germany. What was to be their lot on their arrival ? As early as March 1941 instructions had been issued to the Kreis Farmers Association on the treatment Polish farm workers were to receive. They were to have no rights to complain. They were forbidden to visit churches, all forms of entertainment, public transport were barred. Their employers were given the right to inflict corporal punishment and were “not to be held accountable in any case by any official agency(EC-68, USA 205). And lastly, it was ordered:

“Farm workers of Polish nationality should if possible be removed from the community of the home, they can be quartered in stables, etc. No remorse whatever should restrict such action."

The treatment of those employed in industry was even worse. You will remember the affidavit of the Polish doctor in Essen who did his best to attend to the Russian prisoners of war (D-313, USA 901):

“The men were thrown together in such a catastrophic manner that no medical treatment was possible

*. It seemed to me unworthy of human beings that people should find themselves in such a position

Every day at least ten men were brought to me whose bodies were covered with bruises on account of the continual beatings with rubber tubes, steel switches or sticks. The people were often writhing with agony and it was impossible for me to give them even a little medical aid

*. It was difficult for me to watch how such suffering people could be directed to do heavy work

* *. Dead people often lay for two or three days on the palliasses until their bodies stank so badly that fellow prisoners took them outside and buried them somewhere

*. I was a witness during a conversation with some Russian women, who told me personally that they were employed in Krupp's factory and that they were beaten daily in a most bestial manner

Beating was the order of the day." By the end of 1943 more than five million men, women and children were working in the Reich and if we include prisoners of war the total of those working in Germany was at this date just under 7,000,000. To these must be added the hundreds of thousands brought in during 1944. Millions of men and women taken from their homes by the most brutal methods, transported in all weathers in cattle-trucks from every quarter of Europe, employed on farms and in factories throughout the Reich, frequently under abominable conditions. Children taken from their parents, many to remain for their lives, orphans, not knowing their identity or true names; taken away before they were old enough to remem744400-47—10

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