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My British colleague has proved the guilt of defendants Carl Doenitz and Erich Raeder so convincingly and thoroughly that I see no need to dwell especially on these Grossadmirals of Hitlerite Germany, who have disgraced their admirals' uniforms with such infamous crimes.

In the course of his cross-examination Doenitz told the Soviet Prosecutor that he was unaware of the reasons for which Hitler nominated him as his successor. I don't think that Doenitz was quite sincere in making this statement. One has but to refer to the transcripts of the sessions beginning with the 8th May, in order to understand without his acknowledging it, why he become Hitler's successor, when the Hitlerite Reich went to the bottom. The important point is not the fact that an Admiral was needed at a moment like this, but the fact that only the Nazi Grossadmiral Doenitz, in the opinion of Hitler who was about to fade from the picture, could do anything to save the sinking ship.

Under Hitler, Doenitz commanded the submarine weapon of the German Reich. We know the role which the German Uboats played in this war. In this connection it is worthy of emphasis that Doenitz was proud of being the author of the socalled "wolf-pack tactics". Soviet people have not forgotten how Doenitz's submarines sunk in the Baltic and Black Seas hospital ships and steamers evacuating peaceful citizens-women and children.

The last head of the Hitlerite government should be one of the first to pay for all those crimes which led to the trial of the major war criminals before the International Military Tribunal.

The name of Raeder is linked with the sacrilegious directive for the destruction of Leningrad.

At the trial Raeder tried to play the part of an "honest soldier". But the mere fact that it was he, together with Hitler and Keitel, who conspired to "wipe Leningrad off the face of the earth" and to exterminate more than three million population of that great city, whose very name is indissolubly connected with the development of the culture and history of mankind, makes Raeder one of the major war criminals.

Raeder took part in working out all the most important plans of aggression of German Fascism. This participant in the criminal Fascist conspiracy must therefore bear punishment together with his associates.

The defendant Ernst Kaltenbrunner was considered by Himmler to be the most deserving successor to that henchman, Heydrich, executed by Czech patriots. On 30 January 1943, he was appointed Head of the Reich Main Security Office and Chief of the SD.

Numerous documents, and especially orders signed by Kaltenbrunner, for the mass deportation of people into concentration camps, the testimonies of his subordinates, including the depositions of Walter Schellenberg, the former Chief of the Interior, Security Service, fully convict Kaltenbrunner of heinous crimes. At the session of 12 April 1946 in the course of Kaltenbrunner's examination the testimonies of Johann Kandutor, ex-prisoner of Mauthausen, were read into the record. In his depositions, Kandutor describes as follows Kaltenbrunner's pasttime during one of his visits to the camp: "Laughing, Kaltenbrunner entered the gas chambers; then the prisoners were led from the barracks to the execution and all the three methods of execution were demonstrated-hanging, shooting into the nape and asphyxiation by gas." I shall not dwell upon the numerous proofs which are available, as they have been sufficiently clarified before the Tribunal.

There is only one point of the accusation against Kaltenbrunner, on which I deem it necessary to dwell. Together with other RSHA organizations, Kaltenbrunner took over from Heydrich five "Einsatzgruppen". The citizens of the Soviet Union remember well these criminal organizations of the German Fascism, headed by Kaltenbrunner. The "Einsatzgruppe A" reached the approaches to Leningrad. It created the "Fort of Death #9" near Kaunas, the secret points for mass extermination of human beings in Panarai; it carried out the executions by shooting in the woods of Salaspinsk and Bikerneksk near Riga; it erected gallows in the parks of one of Leningrad's suburbs, the Pushkino. (USSR7; USSR-41; USSR-39)

The Einsatzgruppe B" settled down in the vicinity of Smolensk. It burnt alive the peasants of Byelorussia; it shot down the victims of the awful Pinsk "action"; it drowned thousands of Byelorussian women and children in the Mosyr marshes; it operated with murder vans in Minsk; it liquidated the ghetto in the Upper Gardens district of Smolensk. (USSR-3; USSR-14; USSR-48) The "Einsatzgruppe C" was quartered in Kiev. This group carried out the mass "action" in Baby Yar near Kiev, an execution unmatched for its cruelty, when 100,000 Soviet citizens perished on a single day. (USSR-14; USSR-9) The "Einsatzgruppe D" operated in the southern regions of the temporarily occupied ter

ritories of the Soviet Union. This group was the first to experiment with the murder vans on the Soviet citizens in the district of Stavropol and in Krasnodar. (USSR-14; USSR-1; USSR42)

And when Kaltenbrunner's fate will be decided, all these human beings, asphyxiated in the "murder vans" near Stavropol, buried alive in the graves near Kiev and Riga, burnt alive in the Byelorussian villages, cannot be forgotten. All these innocent victims are on his dirty conscience. The successor of a hangman, Kaltenbrunner was a hangman himself, and he had the charge of the most horrible aspect in the common criminal plan of the Hitlerite gang.



I shall now summarize the evidence pertaining to the guilt and the responsibility of the defendant Rosenberg.

In spite of Rosenberg's efforts to minimize his role and importance, in spite of his efforts to juggle with historical facts and events, he cannot deny that he was the ideologist of the Nazi party, that already a quarter of a century ago, he laid the "theoretical" foundations of the Fascist Hitlerite State, and that during this whole period he corrupted morally millions of Germans, preparing them "ideologically" for the monstrous crimes committed by the Hitlerites, crimes unprecedented in history, and which are the subject of this trial.

When, at the trial, Rosenberg was asked: "Were you not one of Hitler's closest collaborators"?, he did not even speak-he shouted in reply: "that is not true, I never was". But however hard Rosenberg tried to renounce his "Fuehrer", he has not succeeded in washing away the stigma of "one of the oldest and the most faithful of Hitler's comrades-in-arms" (3559-PS, USA 600). For twenty-five years, Rosenberg, acting first as Hitler's collaborator and afterwards under his direction, worked out and assisted in the realization of the fantastic plans for world supremacy, having chosen for the justification of these criminal plans, the misanthropic theory of racism. The fact that Rosenberg utilized for his purposes the refuse of science and borrowed some of his theories from Karl Luger and Paul Lagarde, Count Gobino and Liapouch, Oswald Spengler and Arthur Meller, cannot influence the solution of the question on Rosenberg's responsibility and guilt.

The important fact is that Rosenberg, having assembled all these excrements of science, raised the racial theories to a degree of racial fanaticism, and educated in this spirit the members of the Nazi Party and the German youth. And when the representatives of the "master race" elaborated and committed acts of

aggression, when the German oppressors enslaved and exterminated nations and peoples, when the factories of death were created at Majdanek and Auschwitz, Rosenberg's share in all these crimes was great. All this was the outcome of the Fascist racial ideology, the essence of which consists in the idea that the "aryan", "north-germanic" race is a "master race", and that all other races and nations belong to "lower strata".

Rosenberg's counsel said: "the Tribunal must judge crimes and not theories". In Rosenberg's case such an argument is clearly unconvincing. For Rosenberg, not only confessed the Fascist racial theory, but he knowingly propagated it and instilled it into the conscience of the German people, this theory which became a direct menace to the existence of the democratic European states. The person who carries microbes must be isolated, but the person who willingly disseminates microbes, must be tried.

Rosenberg's criminal activity was not limited to the ideological preparation for aggression and to the propagation of misanthropic theories. His activity had many facets.

The criminal activity of the foreign-policy department of the NSDAP has already been sufficiently clarified at this process, this department which for many years was subordinated to the defendant Rosenberg, was in charge of the half-legal Nazi agencies abroad. The participation of this organization in the foreign policy measures undertaken by the Hitlerite Germany and in the initiation of aggressive wars, is very great.

One of the documents submitted by Neurath's Counsel and accepted by the Tribunal, reads as follows:

"*** at one time there existed in Berlin three sorts of ministries for foreign affairs; Rosenberg's ministry, Ribbentrop's ministry, and the official ministry on the Wilhelmstrasse." And finally, Rosenberg's letter to Hitler of 6.2.38 stressed his real influence on the foreign policy of Hitlerite Germany and his "merits" in this field, when he applied for a membership in the Secret Cabinet Council. (USSR-117)

I see no necessity to give an analysis of the entire criminal activity of Rosenberg, and I only intend to dwell very shortly on his activity as "Fuehrer's plenipotentiary" and, later, as the Reich Minister for the Occupied Eastern Territories. In these capacities, Rosenberg exercised his talents most actively, as a participant in criminal conspiracy.

Rosenberg declares that he was against war with the USSR and that he learned from Hitler about the preparations for an attack against the USSR, only when all the orders to military channels had already been given, and that he never really had

any influence on the foreign policy. of the Hitlerite Germany. I affirm, Your Honors, that all these declarations of Rosenberg are false. It is a commonly known fact that the plan for a German crusade against Soviet Russia is indeed the starting point of the National-Socialists foreign policy, as set out in the 1921 New-Year publication of the newspaper "Voelkischer Beobachter" and that the author of this policy is Alfred Rosenberg. It was Rosenberg, who inspired by Ludendorf and Rechberg, propagated -together with Hitler-a foreign policy directed towards the creation of an antisemitic, antibolshevik and antibritish Continental Europe. Rosenberg's speeches, setting out plans for the "exchange" of the Polish corridor against the Ukraine, his "diplomatic" journeys into certain countries after the seizure of power by the Fascists, his clumsy efforts to realize the foreign policy programme of the Nazis-were disclosed in detail in the press.

The submitted documents give a clear picture of Rosenberg's feverish activity in April 1941-during the period immediately preceding the attack of Germany on the USSR-when he was nominated "Fuehrer's plenipotentiary for the supreme control of the questions connected with the Eastern-European territories". (865-PS, USA 143) On 7 April 1941, two weeks prior to his nomination, Rosenberg sent to Hitler his proposals for the division of the Soviet Union into Reichskommissariats and for the nomination of Fascist governors for the occupied territories. Byelorussia and the Ukraine, Minsk and Kiev, Rostov and Tbilisi, Leningrad and Moscow were all enumerated in Rosenberg's proposals. For the post of the Reichskommissar of Moscow, Rosenberg recommended the notorious Erich Koch.

We have heard about Rosenberg's meetings with Brauchitsch and Raeder and of his conferences with Funk, General Thomas, state secretary Backe and others, on the questions of economical exploitation of the eastern territories, and about his negotiations with Ribbentrop, the SS Chief of Staff, the Chief of the German intelligence service, Admiral Canaris. Already six weeks prior to the attack on the USSR, he worked out directives for all the Reichskommissars of the occupied eastern territories, in which he provided for a "Reichskommissariat Russia" and the "Reichskommissariat Caucasus", while the Byelorussian republic was to form a part of the Reichskommissariat Ostland". (1030-PS, USA 144) Rosenberg's attempt to affirm that he did not share in the aggressive, predatory aims of the war against the USSR, and that, in his capacity of Minister for the occupied Eastern territories, he all but loaded with benefits the population of these territories. And this he dares to affirm, when the directive to the

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