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this opposition: the first, by imprisoning or terrorizing their opponents; the second, by declaring illegal all elements of tolerance and liberalism, outlawing trade unions and opposition parties, reducing the democratic assembly to a farce and controlling elections; the third, by systematic discouragement and persecution of religion, by replacing the ethics of Christianity with the idolatry of the Fuehrer and the cult of the blood and by rigidly controlling education and youth. Youth was systematically prepared for war and taught to hate and persecute the Jews; the plans for aggression required a nation trained in brutality and taught that it was both necessary and heroic to invade the peoples of other countries.

It is a measure of the wickedness and effectiveness of this domestic policy that, after six years of rule, the Nazis found little difficulty in leading a perverted nation into the greatest criminal enterprise in history. It is perhaps, worth considering from the evidence, a few examples of how this policy developed during these six years. They are examples of what was happening in every German town and village. It must be remembered here, that in the need to avoid cumulative evidence you have, in the result, been deprived of its cumulative effect.

First then, the elimination of political opponents. Within six weeks of the Nazis coming to power in January 1933, the German newspapers were quoting official sources for the statement that 18,000 Communists had been imprisoned whilst the 10,000 prisoners in the gaols of Prussia included many Socialists and intellectuals. The fate of many of these men was described by Severing, who estimated that at least 1,500 Social Democrats and a similar number of Communists were murdered in the concentration camps recently established by Goering as Chief of the Gestapo. (D-911, GB 512)

These camps, controlled by the Party organizations, were deliberately so run as to strike terror throughout the country. In the words of the witness Severing, the concentration camps represented for the people “the incarnation of all the terrible”. Goering has said

"We found it necessary that we should permit no opposition to us."

and he admitted that there were arrested and taken into protective custody people who had committed no crime.

It might have been well, if at that time, they had read the maxim of which they spoke yesterday, nulla poena sine lege.

“if everyone knows that if he acts against the state he will end up in a concentration camp * * * that is to our advantage”.

The camps were at first run indiscriminately by the SA and the SS and according to Goering were created

"as an instrument which at all times was the inner political instrument of power."

Gisevius, who at that time had recently joined the Gestapo, you remember, gave the following description:

"I was hardly more than two days in that new police office when I had discovered already that incredible conditions existed there. There was no police which interfered against crimes, against murder, against arrests, against burglary. There was a police organization which protected just those who committed such crimes. Those arrested were not those who were guilty of such crimes, they arrested those who sent their cries for help to the police. It was not a police which interfered for protection but a police whose task, it seemed, was, in fact, to hide, to cover up, and to sponsor crimes, those commandos of the SA and SS who played police were encouraged by that so-called Secret State Police and all possible aid was given to them * * *

“Special concentration camps for the Gestapo were installed and their names will remain for a terrible shame in history. They were Oranienburg and the private prison of the Gestapo, in the Papenstrasse, the Columbia House, or, as it was called cynically, the "Columbia Diele" * * * I asked one of my colleagues, who was also a professional civil servant * * * "Tell me, please, am I here in a police office or in a robber's cave?' The answer that I received was: “You are in a burglar's cave and you can expect that you will see much more yeť' ”.

Gisevius went on to describe Goering's order to murder the National Socialist Strasser and how he gave "blank authority” for murder to the political police by signing a form granting amnesty to the policeman, leaving a blank space for the name of the murdered person in respect of whom the amnesty had been granted.

If confirmation of the evidence of these defense witnesses were required, it is to be found in the period of reports dated May and June 1933 from the Munich Public Prosecutor to the Minister of Justice which are in evidence recording a succession of murders by SS officials in the concentration camp at Dachau (641-PS,

USA 450; 642-PS, USA 451; 644-PS, USA 452; 645-PS, USA 453).

In 1935, the Reich Minister of Justice in writing to Frick his protesting against numerous instances of ill treatment in concentration camps including (3751-PS, USA 828)

“Beating as a disciplinary punishment * ill-treatment mostly of political internees in order to make them talk * * * and ill-treatment of internees arising out of sheer fun or sadistic motives"

went on to complain that

“the beating of the Communists held in custody is regarded as an indispensable police measure for a more effective suppression of Communist activities".

And after citing instances of torture, he concludes:

“These few examples show a degree of cruelty which is an insult to every German sensibility".

Frick's sensibility was apparently not so tender—the very next year he received a similar protest from one of his own subordinates and shortly afterwards he issued a decree making all police forces subordinate to Himmler, the very man whom he knew to be responsible for these atrocities. (775-PS)

These brutalities, well known to Ministers, as we suggest they were, were not confined to the privacy of concentration camps. It is perhaps worth quoting one instance from the thousands who suffered from the policy which was being pursued.

The Tribunal will remember the account by Sollman, a Social Democrat, and member of the Reichstag from 1919 to 1933. He spoke of the incident on March 9th of 1933 when, to quote his own words (3221-PS, USA 422):

Members of the SS and SA came to my home in Cologne and destroyed the furniture and my personal records. At that time I was taken to the Brown House in Cologne, where I was tortured, being beaten and kicked for several hours. I was then taken to the regular Government Prison in Cologne where I was treated by two medical doctors and released the next day. On March 11, 1933, I left Germany".

The second object, the suppression of all democratic institutions, was comparatively simple. The necessary laws were passed to outlaw trade unions: the Reichstag became a farce directly the opposition parties had been dissolved and their members had been put in concentration camps. The witness Severing has spoken of the treatment of the Reichstag members. In 1932, on

von Papen's order he, who was chief of the Prussian Ministry of the Interior, was forcibly removed from his office. It was not long after the 30th of January 1933, that the Communist and Social Democratic parties were decreed illegal and all form of public expression, other than by the Nazis, was prevented. This action resulted from deliberate planning. Frick had said as long before as 1927 (2513-PS, USA 235):

“The National Socialists longed for the day when they could put an inglorious but well deserved end to this infernal sham of a Parliament and open the way for a racial dictatorship".

At this time when democratic Government is seeking to reestablish itself throughout the world, the Nazi attitude to elections is not to be forgotten. Free elections could not, of course, be permitted. Goering had told Schacht in February 1933 when seeking money for the Party from industry (D-203, USA 767):

"The sacrifices asked for will surely be so much easier for industry to bear if it is realized that the election of March 5th will be the last one for the next ten years, probably for the next 100 years.”

able. *

In these circumstances it is not surprising to find that thereafter, as the evidence such as the SD report on the conduct of the plebiscite at Kappel makes clear, the occasional votes of the people, always announced as triumphs for the Nazis, were conducted dishonestly. (R-142, USA 481)

I turn to the third class of opposition, the Churches. Bormann's memorandum sent in December 1941 to all Gauleiters and distributed to the SS sums up the Nazi attitude to Christianity (D-75, USA 348): "National Socialist and Christian concepts are irreconcil

* If therefore in the future our youth knows nothing more of this Christianity whose doctrines are far below ours, Christianity will disappear by itself. ** * All influences which might impair or damage the leadership of the people exercised by the Fuehrer with the aid of NSDAP must be eliminated. More and more the people must be separated from the

churches and their organs, the pastors." The persecution of the churches makes a melancholy story. From the abundance of evidence which has been submitted to the Tribunal it is perhaps permissible to quote from a complaint to Frick made early in 1936 (775-PS):

“Lately half the political police reports concern clerical matters. We have untold petitions from all kinds of cardinals,

bishops, and dignitaries of the Church. Most of these complaints concern matters under the jurisdiction of the Reich Ministry of the Interior, although the respective rules were not decreed by it *

And then after referring to the chaos resulting from the division of authority between the various police forces, the report goes on to refer to the results of the religious struggle:

"Instances of gross disturbances of congregations are mounting terribly fast lately, often necessitating the intervention of the emergency squad. * * After discarding the rubber truncheon, the idea of exposing executive officials to situations in which, during gross interruption of meetings they may be forced to use cold steel, is unbearable."

The diary of the Minister of Justice for 1935 provides ample instances of the sort of behaviour which was being encouraged by the Hitler Youth under the defendant Schirach and the Defendant Rosenberg. The Hitler Jugend, whose membership increased from just under 10,000 in 1932 to nearly 8,000,000 in 1939 was organized on a military basis. The close collaboration between Keitel and Schirach in their military education has been described; the special arrangement between Schirach and Himmler by which the Hitler Jugend became the recruiting organization for the SS is in evidence. You will not have forgotten the words of Schirach's deputy (3751-PS, USA 858; 2435--PS; 2396PS, USA 673; 1992-PS, USA 439):

“In the course of years we want to insure that a run feels just as natural in the hands of a German boy as a pen.” What a horrible doctrine.

The terrorization, murder, and persecution of political opponents, the dissolution of all organizations affording opportunity for opposition, criticism or even free speech, the systematic perversion of youth and training for war would not, however, have sufficed without persecution of the Jews. Let no one be misled by the metaphysical explanations which are put forward for this most frightful crime. What Hitler himself in this very town described as the fanatical combat against the Jews was part and parcel of the policy of establishing Ein Herrenvolk, which would dominate Europe and the world, and so persecution of the Jews was popularized throughout the regime. It gave the youths a butt to bully and so to acquire practical schooling in brutality.

With the accession to power the persecution of the Jews increased in violence. The final solution of mass murder had then been conceived. In Mein Kampf of Hitler, the Bible of the Nazis,

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