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taminated and die. We have fulfilled this duty for the sake of our people. Our spirit and character have not suffered from it".

The conquest of vital space, i. e., of Territories emptied of their population by every method, extermination included, that was, gentlemen, the great idea of the Party, of the system, of the State and thus of all men who are at the head of the main administration both of the State and of the Party.

That is the great idea in the service of which they united, for which they have been working. To realize this all measures were good enough, violation of treaties, invasions and enslavement of weak and peaceful neighbors in peacetime, wars of aggression, total wars with all the atrocities the words imply. Goering and Ribbentrop cynically admitted that they participated in it spiritually and materially, and the generals and the admirals helped as hard as they could.

Speer exploited labor to starvation and to death, labor recruited for him by Sauckel, Kaltenbrunner, the regional leaders of the NSDAP (the Gauleiters), and the Generals. Kaltenbrunner exploited the gas chambers which Frick, Schirach, SeyssInquart, Frank, Jodl, Keitel and the others furnished with victims. But the creation of the gas chambers themselves had been made possible because a favorable political ideology had been developed and there each overlapping the other, you find the responsibility of all, of Goering, Hess, Rosenberg, Streicher, Frick, Frank, Fritzsche, even of Schacht himself, the pro-Jewish Schacht included. Did he not say to Hirschfeld:

"I want the greatness of Germany, and to accomplish it I am ready to ally myself with the devil himself."

He entered into this alliance with the devil and with hell. Papen included, who sees his secretaries and friends killed around him and continues to accept official missions in Ankara, in Vienna, because he believes he can appease Hitler by serving him.

Not all are there, there are those who are dead, and those who are living; for example the industrialists who exploited the workers of the enslaved countries after having carried Hitler and his system to power by prividing the money without which nothing could have been done; who carried them to power by nationalistic fanaticism as well because they expected from Nazidom the guarantee of their privileges.

Everything was connected, everything was indissolubly united because the totalitarianism policy, the total war, preparation and conduct of the plan of extermination of the peoples for the conquest of space, implied a co-ordination, a close liaison between


all government administrations: Police and Army, Foreign Affairs, and Police and Army, Justice and Police, economics and justice, Universities and Propaganda and Police. And now we come to the second proposition which we have to demonstrate. The Coordination of the various departments at the head of which these men stood, implies close cooperation between them. The Defense strives to establish watertight partitions between the different elements of the German state.

According to him, there is supposed to be a parallel without a horizontal bond between the various State and Party departments, between individual ministerial administrations and between individual National-Socialist organizations. The only connecting link would be the person of the Chief, at the head. According to the defense, the dominating principle of German structure would be personal union, not coordination and cooperation.

This is false. This is contrary to the principles of the Nazi State and requirements of a State in which every force strives toward the same goal and towards the actual reality of German life as revealed by the debates.

According to National Socialist conception, the Party must take the place of Democracy. The Party is the political expression of the Nation, which materialises in the political action of the State carried out by the activity of its administrations. The 1 December 1933 Act proclaims, for the purpose of ensuring the unity of the Party and State, that the Party is the exclusive support of the State conception, and indissolubly unites the Party and the State.

At the Party Congress in 1934, Hitler says:

"It is not the State that created us. We create the State for ourselves. To some it may appear as the Party, to others as an organization, for yet others as something different but actually we are what we are."

The aim pursued by the Party is therefore to achieve a more and more complete union between the State and the Party. This explains the legislation which makes it compulsory for the chief of the Party Chancery to be consulted in the appointment of ranking officials; which incorporates Party chiefs in municipal administration, integrates the SS into the Police, and assimilates the SS to police officers; makes the direction of the Hitler Youth a State department, integrates the direction of Party headquarters abroad into the Foreign Department and merges together to an increasing extent the military personnel of the Party and those of the State. General von Brodowsky's war diary, which we have submitted to the Tribunal, shows that this merger was a fact at


the time of the landing in France. Hitler, however, continued to maintain the system of parallel State and Party administration, because they control and supervise each other. But he compelled both parties to cooperate closely to be certain of the effectiveness of the control.

All the defendants moreover, excepting Hess, are representatives of State departments. They cannot hide behind the might of the Party, since Party and State shared the power. The Party expresses a doctrine which must direct the action of the State, but the State in its turn alters the Party doctrine to suit itself. Many items of the Party Program dated 24 February 1920, were never carried out and fell completely into oblivion after a certain experience of power. Income other than that from labor was not abolished (item II); the trusts were not nationalized (item 13); land reform was not carried out according to the provisions of item 17 (I); property interest and land speculations remained.

Ultimately, the whole of German life was subjected to the combined effect of State and Party forces. All the State departments and Party departments contributed to the creation of its components.

Examples are plentiful and are to be found in every State department.

Let us take Foreign Affairs. It is one of the State administrations which, in its correct conception, should remain the farthest removed from any political doctrine. Not so in Nazi Germany. For the purpose of the extermination of the Jews, headquarters abroad cooperate with the RSHA by the intermediary of the Wilhelmstrasse, as evidenced by Documents RF 1206, 1220, 1502, 1210 and USA 433. Wilhelmstrasse officials are called upon to advise the military police and Secret State Police (Document RF 1061). It is Best, Ribbentrop's representative in Denmark, who transmits the order for deportation of the Jews to the Chief of the German Police, Mildner (RF 1503). Document RF 1501 shows Ribbentrop vindicating anti-Semitism to Mussolini and requesting Italian cooperation.

Ribbentrop and Kaltenbrunner are implicated in all the terrorist measures against the elites; the SD and the Wilhelmstrasse are also involved in the organization of the aggression against the broadcast station of Gleixitz in order to furnish the pretext of a Polish attack. The report of the German military administration concerning the pillage of art treasures in France incriminates at the same time the special staff of Rosenberg and the German Embassy in Paris (RF 1505). The Wilhelmstrasse and the army are involved with the police in the question of hostages, reprisals, and deportations. The examples could be multiplied.



We do not pretend to exhaust the subject, but only to illustrate an opinion.

Let us now examine the activities of the organization Rosenberg. Rosenberg, by virtue of his function, already coordinates several branches of the German State. His service of foreign policy has been incorporated in the Ministry of Foreign Affairs. He is furthermore the philosopher of the regime, Minister for the Eastern Territories and chief of the special Staff entrusted with the control of art treasures. The SD and the secret police work in liaison with him (L-188 and 946-PS).

The same liaison, the same coordination must be noted in the order of the State machinery in matters concerning forced labor. All the Ministers and all the higher functionaries, like the Gauleiters, are involved in it, be it that they conceived or prepared the operation, or still more simply that they gave it a helping hand or that they benefited by it.

We remember the inter-ministerial meetings in Berlin on this subject, and the conference between Sauckel, Kaltenbrunner, Speer, Funk and the representatives of the OKW, which is the subject of document 3819-PS in the meeting in Paris presided over by Sauckel which was attended by representatives of the army, the police and the Embassy (RF 1517).

Economy is no longer independent. During the war there exists under Funk a close cooperation between the economic and administrative services of the army and those of economic affairs. The Ministry of Economy appeals to the police to develop plans for the germanization of economy, (RF 803 and 814). The Ministry of Finance subsidized the SS to carry out scientific research on the internees, involuntary subjects of abominable experiments (002-PS). Long before the war and under Schacht, the same bonds, first secret, later on public, and closer than any other country in the world, unite politics, finance and economy with the army. Schacht, in a speech on 29 November 1938 pronounced the following opinion on his achievement:

"It is possible that no other issuing bank has followed in peace time such an audacious credit policy as the Reichsbank since the assumption of power by National Socialism. With the aid of this policy, however, Germany has created an armament which is the first in the world, and this armament has made possible the results of our policy ***

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The judicial system is no longer independent. We find it associated with the police in the most criminal enterprises. Document 654-PS gives an account of a discussion between Thierack, Himmler and others, at the end of which it was decided that the antisocial elements and the internees of the concentration camps, the

Jews, Gypsies, Russians, Ukrainians, Poles sentenced to more than three years in prison should be turned over to Himmler by the administration, to be exterminated by work, and that in the future individuals belonging to the same categories should not be judged by ordinary tribunals but handed over immediately to Himmler's administration.

Finally during the war the terrorist activities of the army and the police, of the State and the Party merge together. Sometimes the police is made subordinate to the army, though acting with a certain autonomy according to the orders of the RSHA. This is the case in Belgium. In France, in spite of being detached from the army, the police maintains close cooperation with it. The army participates with the SIPO, (Security Police) and the SD in the Persecution of the Jews, in the administration of the internment camp of Compiegne and in the designation of hostages (RF 1212 and 1212 bis) and in their execution (RF 1244). As we have seen the army and the police were accomplices in the terrorist actions against the population. The navy and the Police are also accomplices in the massacre of the commandos, and it is the police which massacres certain categories of War Prisoners, although all the prisoners without exception come under the authority of the OKW (1165-PS).

One might multiply examples of the close association of Party machinery with the State services of their coordination which at times goes so far as to result in a symbiosis. Realization of the common political idea: the conquest of space by all possible · methods, is the path pursued by all, one way or another.

The cooperation of the defendants is an evident result. Apart from the definite facts of co-operation which we allege, what we know of the general functioning of this totalitarian State, bound to the destiny of the Party, its vigour against the heretics for whom camps with their gas chambers waited all that leads us to affirm that the defendants, be they Ministers or dignitaries or high functionaries with State or Party authority, together with others who are not there-dead or held for trial in other Courts, formed an entity. And this, taken altogether, was the Government of the Reich; this was the State Party or Party-State; an entity, perhaps, but a conscious and criminal entity which caused the massacre of millions of human beings in order to enlarge the Reich beyond all measure.

The acts of the defendants are not only the particular ones which we analysed just a minute ago in the light of the national penal codes of their and our countries, respectively. They comprise also in their entirety those of the German State for which they acted, of that German State to which they gave life, conscience, thought, will, and of which they must now assume the

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