Nuremberg Trial – The Twenty-third Day

Twenty-Third Day:

Wednesday, 19th December, 1945

 

DOCTOR SAUTER (Counsel for the defendant von Schirach): Mr. President, yesterday a table was shown on the screen, in which the construction of the Reich Cabinet was exposed, which is under accusation as an organisation. And on this chart, under the heading “Other Participants in the Meetings of the Cabinet,” the defendant von Schirach was also mentioned. The defendant von Schirach has explained to me and asked me to inform the Court that he never took part in any meeting of the Reich Cabinet; that he was never named a member of the Reich Cabinet; that he never took part in any resolution passed by the Reich Cabinet.

THE PRESIDENT: The point that the defendant is taking seems to me to be premature. This is not the stage for you to argue the question whether your client is a member of the Reich Cabinet or not. The argument upon the whole question will take place after the evidence and after the prosecution have had the opportunity of putting forward their arguments as to the criminal nature of the Reich Cabinet. You or other counsel on behalf of those concerned will be able to put forward your arguments. We do not desire to hear arguments now about the criminal nature, but to hear the evidence. Is that clear?

DOCTOR SAUTER: Yes. I shall then return to this point while the witnesses are being heard, and shall then bring witnesses to prove that the defendant von Schirach was never a member of the Reich Cabinet.

COLONEL STOREY: If the Tribunal please, yesterday afternoon we had just started on the participation of the S.A. in the first point – the dissemination of ideology or propaganda. In an article which appeared in Der S.A.-Mann, at Page 1 of the issue of January, 1934, which is Document 3050-PS, and I refer to Page 25 of the English translation – Document 3050-PS, Page 25, if your Honour pleases – the portion shown in red brackets. It is dated the 6th January, 1934:

“The new Germany would not have come into existence without Der S.A.-Mann, and the new Germany would continue to exist if Der S.A.-Mann would now, with the feeling of having fulfilled his duty, quietly and unselfishly and modestly step aside, or if the new State would send him home, much like the Moor who has done his duty. On the contrary, Der S.A.-Mann, following the will of the Fuehrer, stands as a guarantor of the National Socialist revolution before the gates of power, and will remain standing there at all times. For there are still gigantic missions awaiting fulfillment which would not be thinkable without the presence and the active co-operation of the S.A. What has been accomplished up till now, the taking over of the power in the State, and the ejection of those elements which are responsible for the pernicious developments of the postwar years, as bearers of Marxism, Liberalism, and Capitalism, are only the preliminaries, the spring-board, for the real aims of National Socialism. Being conscious of the fact that the real National Socialist construction work would be building in an empty space, without the taking over of power by Adolf Hitler, the Movement and Der S.A.-Mann as the aggressive bearer of its will, primarily have directed all of their efforts to achieve the goal by continued striving, and to obtain the foundation or the realisation of their desires in the State by force. Out of this comes the further mission of the S.A. for the completion of the German revolution: first, to be the guarantor of the power of the National Socialist State against all attacks from without as well as from within: second, to be the high institute of education of the people for the living National Socialism.”

The function of S.A. as the propagandist of the Party was more than a responsibility which S.A. took unto itself. It was the responsibility recognised by the law of Germany. Document 1395-PS, is a copy of the law entitled, “Law on Securing the Unity of Party and State,” which I have referred to before – and it was promulgated by the Reich Cabinet in 1933 – I desire to read Article 3, on Page 1 of the English translation:

“The members of the National Socialist German Party and the S.A., including their subordinate organisations, as the leading and driving force of the National Socialist State, will bear greater responsibility toward the Fuehrer, People, and State. In case they violate these duties they will be subject to special jurisdiction by Party and State. The Fuehrer may extend these regulations in order to include members of other organisations.”

Thus were the S.A. members the ideology bearers of the Nazi Party – the soldiers of an idea – to use the expression employed by the Nazi writers. And permit me to emphasize that the S.A. was the propagandist agency, the principal agency employed by the conspirators to disseminate their fanaticism among the people of Germany.

If your Honour pleases, I had ended the quotation. I am sorry if I did not refer to it.

I need hardly point out the importance of this function to the successful carrying out of the conspiracy, for it is self-evident that the Nazis could not have carried their conspiracy to the stages which they did, had not the minds of the people of Germany been cruelly and viciously influenced and infected with their evil ideologies.

I now proceed to the other functions of the S.A. which I mentioned previously. The next is its use in the early stages of the conspiracy, as the “strong-arm” of the N.S.D.A.P. In the early stages of the Nazi movement, the employment of the S.A. as the propagandist instrument of the Party, involved, and was combined, with the exercise of physical violence and brutality.

As said by Hitler in Mein Kampf – and this excerpt appears at Page 4 of Document 2760-PS, Page 4 of the English translation, Exhibit USA 256 – I quote:

“The young Movement from the first day, espoused the standpoint that its idea must be put forward spiritually, but that the defence of this spiritual platform must, if necessary, be secured by strong-arm means.”

I will read the rest of that paragraph:

“Faithful to its belief in the enormous significance of the new doctrine, it seems obvious to the movement that, for the attainment of its goal, no sacrifice can be too great.”

So, in the early days of the Nazi movement, in order that the Nazis might better spread their fanatical philosophies, the S.A. was employed as a terroristic group, so as to gain for the Nazis possession and control of the streets. That is another way of saying that it was a function of the S.A. to beat up and terrorize all political opponents. The importance of this function is indicated in Document 2168- PS, Exhibit USA 411, which was written by S.A. Sturmfuehrer Bayer on orders from S.A. headquarters. I refer to Page 3 of the English translation of that document, the third paragraph from the bottom:

“Possession of the streets is the key to power in the State – for this reason the S.A. marched and fought. The public would never have received knowledge of the agitative speeches of the little Reichstag faction and its propaganda, or of the desires and aims of the Party, if the martial tread and battle song of the S.A. Companies had not beat the measures for the truth of a relentless criticism of the state of affairs in the governmental system. They wanted the Young Movement to keep silent. Nothing was to be read in the Press about the labour of the National Socialists, not to mention the basic aims of its platform. They simply did not want to awaken any interest in it. However, the martial tread of the S.A. took care that even the drowsiest citizens had to see at least the existence of a fighting troop.”

The importance of the work of the S.A. in the early days of the movement was indicated by Goebbels in a speech which appeared in Das Archiv, October, 1935. This is our Document 3211-PS, Exhibit USA 419. It is on the first page of the English translation, No. 3211, quoting:-

“The inner-political opponents did not disappear due to mysterious unknown reasons, but because the Movement possessed a strong arm within its organisation, and the strongest arm of the Movement is the S.A. The Jewish question will not be solved separately, but by laws which we enact, for we are the anti-Jewish Government.”

Specific evidence of the activities of the S.A. during the early period of the Nazi movement, from 1922 to 1931, is found in a series of articles appearing in Der S.A.-Mann, entitled “S.A. Battle Experiences Which We Will Never Forget.” Each of these articles an account of a street or a meeting-hall battle waged by the S.A. against a group of political opponents in the early days of the Nazi struggle for power. These articles demonstrate that during this period it was the function of the SA to employ physical violence in order to destroy and subvert all forms of thought and expression which might be considered hostile to the Nazi aims or philosophy.

A number of such articles have been translated, and the titles are sufficiently descriptive to constitute evidence of the activities the S.A. in the early stages of the Nazi movement. I should like to quote from a few of these titles by giving the page reference of this big newspaper volume.

Here is one of 24th February, 1934, Page 4. The title: “We Subdue the Red Terror.”

The 8th September, 1934, Page 12. The article is entitled: “Nightly Street Battles on the Czech Border.”

The 6th October, 1934, Page 5: “Street Battle in Chemnitz.”

Another one of the 20th October, 1934, Page 7. The title: “Victorious S.A.”

I will skip several of them. Here is one of 26th January, 1935, Page 7. The title: The S.A. Conquers Rastenburg.”

Another on 23rd February, 1935, Page 5: “Company 88 Receives Its Baptism of Fire.”

One of 20th October, 1934, Page 7. The article is: “S.A. Against Sub-Humanity.”

Finally, I mention the one of 10th August, 1935, Page 10. The title is, “The Blood Sunday of Berlin.”

And then there is a portrait in the article of 11th September, 1937, Page 1, which symbolises the S.A.-Mann as the “Master of the Streets.”

For an example of the nature of these articles, one appeared the Franken edition of the S.A.-Mann for 30th October, 1937, Page 3. It is entitled, “9th November, 1923, in Nuernberg,” and I should like to quote from Pages 14 and 15 of Document 3050-PS, which is an English translation of this article:-

“We stayed overnight in the Colosseum (that means Nuernberg). Then in the morning we found out what had happened in Munich. ‘Now a revolution will also be made in Nuernberg’, we said. All of a sudden the Police came from the Master Guard and told us that we should go home, that the ‘putsch’ in Munich had failed. We did not believe that and we did not go home. Then came the State Police with fixed bayonets and drove us out of the hall. One of us then shouted: ‘Let’s go to the Cafe Habsburg!’ By the time we arrived, however, the Police again had everything surrounded. Some shouted then, ‘The Jewish place will be stormed…. Out with the Jews!’ Then the police started to beat us up. Then we divided into small groups and roamed through the town, and wherever we caught a Red or a Jew we knew, a fist fight ensued.

Then in the evening we marched, although the Police had forbidden it, to a meeting in Fuerth. On our way the police again attempted to stop us. It was all the same to us. In the next moment in our anger we attacked the police so that they were forced to flee. We marched on to Geissmann Hall. There again they tried to stop us. But the Landsturm, which was also there, attacked the protection forces like persons possessed and drove them from the streets. After the meeting we dissolved and went to the edge of town. From there we marched in close column back to Nuernberg. In Will Street near Plaerrer the police came again. We simply shoved them aside. They did not dare to attack, for this would have meant a blood bath. We decided beforehand not to take anything from anyone. In Fuerth they had already noticed that we were up to no good. A mass of people accompanied us on the march. We marched with unrolled flags and sang so that the streets resounded: ‘Comrade give me your hand; we want to stand together firmly; even if they misunderstand the S.A., the spirit must not die; Swastika on the steel helmet, black-white-red armband; we are known as Storm Troop (S.A.) Hitler!”

I now skip to the use of the S.A. to consolidate the power of the Party.

The third function of the S.A. was to carry out various programmes designed to consolidate Nazi control of the German State, including particularly the dissolution of the trade unions and the Jewish persecutions.

The S.A. groups were employed to destroy political opposition by force and brutality wherever necessary. An example of this is shown in Document 3221-PS, Exhibit USA 422, and that is an original affidavit made in the State of Pennsylvania, in the United States of America, by William F. Sollman, which we now quote in its entirety:-

“William F. Sollman, Pendle Hill School, Wallingford, Pennsylvania, being duly sworn according to law, deposes and says: From 1919 until 1933 I was a Social- Democrat and a member of the German Reichstag. Prior to 11th March, 1933, I was Editor-in-Chief of a chain of daily newspapers with my office in Cologne, Germany, which led the fight against the Nazi Party. On 9th March, 1933, members of the S.S. and S.A. 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 11th March, 1933, I left Germany.

Signed and sworn to.”

Prior to the organisation of the Gestapo on a national scale, local S.A. meeting places were designated as arrest points, and the S.A. members were employed in the taking into custody of Communists and other persons who were actually or supposedly hostile to the Nazi Party. This activity is described in Document 1759-PS, Exhibit USA 420, which is an original affidavit made by Raymond H. Geist. Mr. Geist was formerly United States Consul in Berlin. He is now in Mexico City. I should like to quote from a portion of his affidavit, the first being on Page 5 of the English translation, about the middle of the page, starting:-

“At the beginning of the Hitler regime, the only organisation which had meeting-places throughout the country was the S.A. (Storm Troopers). Until the Gestapo could be organised on a national scale, the thousands of local S.A. meeting-places became the arrest points. There were at least 50 of these in Berlin. Communists, Jews, and other known enemies of the Nazi Party were taken to these points, and if they were enemies of sufficient importance they were immediately transferred to the Gestapo Headquarters. During 1933 and 1934, when the Gestapo became universally organised, the S.A. were gradually eliminated as arresting agents, and the S.S. were incorporated as administrative and executive officials into the Gestapo. By the end of 1934, the S.A. had been fairly well eliminated and the S.S., the members of which wore elegant black suits and were therefore called Elite Guards, became almost identical as functionaries with the Gestapo.”

I now pass to Page 7 of this same Document, Page 7 of the English translation. It begins:-

THE PRESIDENT: Colonel Storey, does that mean that the S.A. were eliminated for the purpose of arrest or for other purposes too?

COLONEL STOREY: No, Sir. As I understand, Sir, the S.A. reached its height of popularity in 1934, and immediately after the Roehm purge began to decline. In the meantime, the S.S., which originated out of the S.A., was growing and became really the strong part, and grew and prospered after that. So I think the evidence will show that after 1934 the S.A. started a rapid decline in its importance.

Now, on Page 7 of the English translation I should like to quote a part of the Consul’s report, beginning in the middle of the page. Another American, Herman I. Roseman, made an affidavit which stated:-

“‘Yesterday, 10th March, 1933, in the afternoon about 4:30, I came out of K.D.W. with my fiancee, Fraulein Else Schwarzlose, residing in Wilmersdorf (giving the address). A man in S.A. uniform stepped on my toe purposely, obviously offended me and said ‘Pardon.’ I said ‘Bitte,’ and walked ahead. He then followed me and kicked me saying, “Na und?” A police man saw this and walked ahead, paying no attention to attacks made on me. Then I took my passport out of my pocket, showed it to the second policeman, and said that I was an American citizen, but he walked ahead, obviously not able to afford me protection, or at least being unwilling to do so. The S.A. man continued to attack me, struck me in the face, wounded me over the eye, and continued to do me bodily harm. During this attack, all the time my walking along, we reached another policeman, and I applied to him, showing my passport and said: ‘I am an American and am entitled to protection.’ He shrugged his shoulders and said ‘What can I do?’ By this time the S.A. man had obviously attacked me enough and walked away.

Upon my appeal, the policeman brought my fiancee and me to the station house at 13 Bayreuther Strasse. My fiancee and I reported to the officer in charge. He heard the story and said that he was sorry, but that there was nothing to do. My face was bleeding. The policeman said that he had orders not to interfere in any affair in which an S.A. man took part. I then asked him what I could do to protect myself. He said that there was nothing to do but to wait until the situation was better. He added that the police were absolutely powerless, and were under the direction of the S.A., and that there were S.A. Sturm Abteilungen in the police itself. Thereupon I departed….”

Now on the next page, on Page 8, is another American, Mrs. Jean Klauber, and I quote from her affidavit.

“On the night of Friday, 10th March, 1933, she and her husband had retired for the night when they were awakened by a prolonged ringing of their apartment bell. They heard pounding upon the street door and a demand for immediate entry, and at the same time a threat to break the door down. The street door was opened by the janitor’s wife, and a party of four or five men entered and went at once to the apartment of the deponent, where they again rang and pounded on the door. Mr. Klauber asked who was there and was answered – ‘The police.’ He opened the door and a party of four or five men in brown uniforms, one wearing a dark overcoat and carrying a rifle, pushed in, jostling Mr. and Mrs. Klauber aside. One asked Mrs. Klauber where the telephone was and she indicated the room where it was to be found, and started to go there. Thereupon, she was knocked down by one of them. They went on to the bedroom where Mr. and Mrs. Klauber followed them, and there they demanded their passports.

Mr. Klauber went to the wardrobe to get his, and was stopped, being asked by the intruders whether he was carrying any weapons. Being clothed only in pajamas, his denial was accompanied by a gesture indicating his garb. He then turned to the wardrobe, opened it, and reached for one of his four suits hanging therein where he thought the passport was, and was immediately attacked from behind by all but one of the intruders, who beat him severely with police clubs, the one with the overcoat and rifle standing by. Remarks were shouted such as, ‘Look! Four suits, while for fourteen years we have been starving.’ Mrs. Klauber tried to inquire the reason for their actions, and was answered- ‘Jews. We hate you. For fourteen years we have been waiting for this, and tonight we will hang many of you.’

When the intruders stopped beating Mr. Klauber he was unconscious, and they again demanded the passports of Mrs. Klauber. Mrs. Klauber found her American passport and her German passport (required by local authorities as the wife of a German citizen and issued by the police at Munich after her arrival here), and the intruders took both in spite of Mrs. Klaubers protests that she was American. She then searched for her husbands passport, laid hold of his pocket-book, and in her excitement offered it to them. Though full of money they refused it, and again demanded the passport. Mrs. Klauber then found it and handed it over.

Then the intruders returned to the unconscious Mr. Klauber saying: ‘He hasn’t had enough yet,’ and beat him further. Then they left, saying, ‘We are not yet finished,’ and just as they departed, one of them said to Mrs. Klauber, ‘Why did you marry a Jew? I hate them’ and struck her on the jaw with his police club….”

That is the end of the affidavit. Now continuing, the next paragraph is the statement of the Consul:

“I personally can verify that the police had been instructed not to interfere; and that is, that there was official sanction for these activities. Affidavits taken from numerous victims attest this fact. I had become acquainted with the two police officers stationed at the corner of Bellevuestrasse and Tiergartenstrasse near where the Consulate General was located; these officers told me that they and all the other police officers had received definite instructions not to interfere with the S.A., the S.S., or the Hitler Youth.”

In addition, S.A. members served as guards at concentration camps during this consolidating period, and participated in the persecution and mistreatment of persons imprisoned therein. I now refer to Document 2824-PS, which is a book entitled, Concentration Camp at Oranienburg. It is Exhibit USA 423. This was by an S.A.-Sturmbannfuehrer named Schaefer, who was the commander of the concentration camp at Oranienburg. I quote the excerpt on the first page of the English translation, reading:-

“The most trusted, boldest S.A. men were selected in order to give them homes in the camp, since they were the permanent camp guards, and in such a manner we created a cadre of experienced guardsmen who were constantly prepared to be employed.”

Further evidence concerning the operation of the concentration camps by the S.A. is found in Document 787-PS, Exhibit USA 421. This is a report to Hitler from the public prosecutor of Dresden concerning the nolle-prosequi of one Vogel, who was accused of mistreatment of persons imprisoned in the concentration camp. I quote from that report:

“The prosecuting authority in Dresden has indicted Oberregierungsrat Erich Vogel in Dresden on account of bodily injury while in office. The following subject matter is the basis of the process:

Vogel has belonged to the Gestapo office of the State of Saxon since its foundation and is chief of Main section II, which formerly bore the title ZUB. In the process of combating efforts inimical to the State, Vogel carried out several so-called ‘borderland actions’ in the year 1933, in which a large number of politically unreliable persons and persons who had become political prisoners in the border territories, were taken into ‘protective custody and brought to the Hohnstain protective custody camp.

In the camp serious mistreatment of the prisoners has been going on at least since the summer of 1933. The prisoners were not only, as in the protective custody camp Bredow near Stettin, beaten into a state of unconsciousness for no reason, with whips and other tools, but were also tortured in other ways, as for instance with a drip- apparatus especially constructed for the purpose, under which the prisoners had to stand so long that they came away with serious purulent wounds on the scalp. The guilty S.A.-leaders and S.A.-men were sentenced to punishments of six years to nine months of imprisonment by the main criminal Court of the provincial court in Dresden on 15th May, 1935. Vogel, whose duties frequently brought him to the camp, took part in this mistreatment, in so far as it happened in the reception room of the camp during completion of the reception formalities, and in the supply room, during issuing of the blankets. In this respect it should be pointed out that Vogel was generally known to the personnel of the camp – because of his function as head of the ZUB – and his conduct became at least partly a standard for the above-named conduct of the S.A. leaders and men.”

I want to read the remainder of that quotation. I am sorry, I have not got it here. There is a little portion there that should be read immediately following my statement – I will skip to the quotation just below:

“Vogel stayed in the reception room a long time and watched these proceedings without doing anything about them. In his presence for instance, the S.A.-man Mutze dealt such blows to one man, without provocation, that he turned on him. As already stated, Vogel not only took no steps against this treatment of the prisoners, but he even made jokes about it and stated that it amused him the way ‘things were popping’ here.

In the supply room, Vogel himself took a hand in the beating amid the general severe mistreatment. The S.A. men there employed whips and other articles and beat the prisoners in such a manner that serious injuries were produced, the prisoners partly became unconscious and had to lie in the dispensary a long time. Vogel was often present in the supply room during the illtreatment. At least in the following cases he personally laid violent hands upon prisoners.”

And then skipping down:

– “the prisoner was laid across the counter in the usual manner, held fast by the head and arms, and then beaten for a considerable time by the S.A. men with whips and other articles. Along with this Vogel himself took part in the beating for a time, and after this mistreatment slapped him again, so that the prisoner appeared green and blue in the face. The prisoner is the tinsmith Hans Kuehitz, who bore the nickname ‘Johnny.’ Upon his departure, Vogel gave the head of the supply room, Truppfuehrer Meier from five to six reichsmarks with the stated reason that the S.A. men ‘had sweated so.’ The money was then distributed by Meier to those S.A. comrades who had taken part in the ill treatment.”

Another activity of the S.A. during the days just following the Nazi seizure of power was to act as auxiliary police. This is shown in Document 3252-PS, Exhibit USA 424. This publication is a book written about Hermann Goering.

THE PRESIDENT: Colonel Storey, is that a document which shows on its face that the man was punished for this conduct?

COLONEL STOREY: I think it does; yes, Sir. I think it does.

THE PRESIDENT: I think that fact ought to be stated.

COLONEL STOREY: I believe it is stated, Sir. You see in the beginning it says that the prosecuting authority in Dresden had indicted Vogel on account of bodily injury, and I thought it stated that he had been punished.

THE PRESIDENT: The document does appear to state it, but I think you ought to state it in Court. The document ends up with – paragraph three –

COLONEL STOREY: It does state that he was punished. The purpose of introducing it was to show what actually took place.

I now turn to Document 3252-PS. As I have just mentioned, the book is entitled, “Hermann Goering, the Man and His Work,” by Erich Gritzbach, in which it is declared that the ranks of the Security Police were strengthened by the S.A. and which was characterised as the most reliable instrument of the movement. I should like to quote on the first page of Document 3252-PS, the English translation – it is the fourth paragraph:

“The present reorganisation of the Security Police is hardly noticed by the public. Their ranks are strengthened by the S.A., the most reliable instrument of the movement. The Auxiliary Police have given effective aid by their fighting spirit, in the struggle against the Communists and other enemies of the State, not only to Goering, but have, driven by their National Socialist desire for a new spirit within the executive police, assisted in their rigid organisation.”

I now skip to the S.A. participation in the Jewish pogrom of 10th – 11th November, 1938, shown by Document 1721-PS, Exhibit USA 425. This is a confidential report of the S.A.- Brigadefuehrer to his Group Commander, dated 29th November, 1938, in the English translation, starting at the beginning. Without reading the addresses, it is to S.A. Group Electoral Palatinate (Kurpfalz) Mannheim.

“The following order reached me at 3 o’clock on 10th November, 1938.

On the order of the Gruppenfuehrer, all Jewish synagogues within the 50th Brigade are to be blown up or set on fire immediately.

Neighboring houses occupied by Aryans are not to be damaged. The action is to be carried out in civilian clothes. Rioting and plundering are to be prevented. Report of execution of orders to reach the brigade Fuehrer or office by 8.30.

I immediately alerted the Standartenfuehrer and gave them the most exact instructions; the execution of the order began at once.

I hereby report that the following were destroyed in the area of:” –

Then there follows a list of 35 synagogues that were destroyed.

I just refer to a few of them:-

“No. 1. The Synagogue at Darmstadt, Bleichstrasse, destroyed by fire.

No. 4. The Synagogue at Graefenhausen, interior and furnishings wrecked.”

And then under “Standarte 145”:-

“The synagogue at Bensheim, destroyed by fire.”

And then the next four items are synagogues destroyed by fire. In Standarte 168, eight synagogues are shown to have been destroyed by fire.

In Standarte 168, the synagogue in Beerfelden was blown up, and then follow several others where the furnishings were wrecked. In Standarte 221, the synagogue and chapel in Gross- Gerau was destroyed by fire, and the next one torn down and the furnishings destroyed. And then it is signed by the Fuehrer of Brigade 50, by the signature which is illegible, “Brigadefuehrer.”

In connection with the persecution of the Jews, we again find the S.A. performing its function of propaganda agency for the Nazis. In this connection it was the function of the S.A. to create and foster among the people an anti-Jewish spirit and sentiment, without which the terrifying Crimes against Humanity perpetrated against the Jewish race certainly would not have been tolerated by any civilised peoples. Substantial and convincing evidence of this function is to be found in these bound volumes of Der S.A.- Mann. Throughout the period covered by these volumes there appeared in this publication article after article consisting of the most cruel and vicious sort of anti- religious propaganda, designed to engender and foster hatred and hostility toward the Jewish race.

I will refer to only a few of the titles appearing. On 27th July, 1935, at Page 4, the title is “Finish up with the Jew.” That is shown, if your Honour pleases, in Document 3030, Pages 16 to 18 there listed. In the issue of 2nd February, 1935, Page 5, “The Jewish World Danger”; on 20th July, 1935, Page 4, “Jewish Worries”; on 1st June, 1935, Page 1, “Jews Are Not Wanted Here.” And then follows a statement: “Then, also, outside of the last German village the sign will stand, ‘Jews Are Not Wanted Here’; and then, finally, “no German citizen will again cross the threshold of a Jewish store. To achieve this goal is the mission of the S.A. man as the political soldier of the Fuehrer. Next to his word and his explanations stands his example.”

Then further on 17th August, 1935, Page 1, “God Save the Jew.” Then another under 5th October, 1935, Page 6, the title “The Face of the Jew” (with a portrait of a Jew holding the hammer and sickle).

I will just refer to one or two more of them. Here is one on 23rd November, 1935, Page 2. The title, “The Camouflaged Benjamin – Jewish Cultural Bolshevism in German Music.”

Here is one of 2nd January, 1937, Page 6, a hideous-looking picture, the title being “Roumania to the Jews?”

I give the final quotation, the last one, 3rd February, 1939, Page 14, the title being “Friends of World Jewry – Roosevelt and Ickes.”

The impressive thing about all these articles is the fact that it was not intended that the philosophies expressed in them should be confined to members of the S.A.; on the contrary, the plan was to educate the members of the S.A. with this iniquitous philosophy, and for the S.A., in turn, to be employed for its dissemination into the minds of the German people. This fact is demonstrated in the introduction to a series of anti-Jewish articles in the paper of 5th December, 1936, at Page 6. I will just read the title. It is found on Page 28 of the same document and the title is as follows: “Grave-Diggers of World Culture.” Also on that same page, 28, I quote this statement:-

“We suggest that the comrades especially take notice of this series of articles and see that they are further circulated.”

In addition, intensive campaigns were conducted to persuade the public to purchase and read Der S.A.-Mann and the various issues were posted in public places so that the general public might read them. Der S.A.-Mann itself contained several photographs which show particular issues posted upon street bulletin boards; and there are several photographs showing advertising displays, one of which, for example, reads as follows – this is in the issue of 31st October, 1936:-

“Der S.A.-Mann belongs in every house, every hotel, every inn, every waiting room, and every store.”

Also in the issue of 24th August, 1935, at Page 3, there was a group picture of S.A. men on trucks and in front of the trucks were large signs, one of which read:-

“Read the ‘Stuermer’ and you will know the Jew.”

On the same page of the publication I mentioned there is a photograph of what appears be a public rally, at which there is displayed a large poster reading: “He who knows the Jew, knows the Devil!”

THE PRESIDENT: Colonel Storey, the Tribunal expressed its view yesterday that they did not desire to hear cumulative evidence. Is this not rather cumulative?

COLONEL STOREY: I agree with your Honour that possibly it is. I am trying to draw the line on it. I will omit the rest of them.

Now we will pass to the final phase of the function of the S.A. in the conspiracy.

THE PRESIDENT: Perhaps we had better adjourn now for 10 minutes.

(A recess was taken.)

COLONEL STOREY: If your Honour pleases, I have just started on the function of the S.A. in the conspiracy, that is its participation the programme for preparation for warfare.

In this connection, your Honour asked this morning a question about the arresting and police activities of the S.A., and I mentioned that they had declined after 1934. For fear there was some misapprehension, I would like to state that as a police organisation and as an arresting agency they declined steadily after 1934.

We go now into the phase where they went into military preparations, the next phase, and that is the phase with which I deal now. If your Honour pleases, I have here an official government publication issued by the British Government in 1943, the title being, “The Nazi Party and Organisations,” and I should like to quote as to the organisation and membership of the S.A. from that publication. It is the most authoritative that I have been able to find, and I would like to quote briefly from it:-

“The S.A. was founded in 1921 as a para-military organisation to protect Nazi meetings and leaders, to throw out interrupters and hecklers, to fight political enemies, and to provide pre-military training at a time when the legal ‘Reichswehr’ vas limited to 100,000 men. Their highest leader is Hitler himself; his deputy is called the Stabschef (Chief of Staff of the S.A.; from 1930 to June, 1934, it was Roehm; from then onwards till his death in May, 1943, Victor Lutze; since August, 1943, Wilhelm Schepmann.) In January, 1933, the S.A. had only 300,000 members. After the seizure of power, its strength increased quickly; at present it has a membership of 1,500,000 to 2,000,000” Now, the date of this is 1943.

We again find the S.A. employed to inculcate a particular Nazi ideology into the minds of the people of Germany. At this point it was the function of the S.A. to prepare Germany – mentally – for the waging of a vicious and aggressive war.

At all times, and especially during the period from 1933 to 1939, S.A. leaders emphasised to S.A. members the duty and responsibility of creating and fostering a militaristic spirit throughout Germany. In 1933 Hitler established the so- called S.A. sports programme, and at that time, according to Sturmfuehrer Bayer, in his pamphlet “The S.A.,” which I have previously introduced in evidence as Document 2168-PS, the S.A. at that time was “commissioned to obtain and increase the preservation of a warlike power and a warlike spirit as the expression of an aggressive attitude.”

In 1937 Hitler renewed the so-called sports programme and, as recited in Document 3050-PS, which is the English translation of these newspaper articles, on Page 12, he made a statement: “for the fostering of a military spirit.”

The Organisation Book of the Party is to the same effect, in Document 3220-PS, which is Exhibit USA 323. I quote from a portion of that document – paragraphs 1 to 3 on Page 1 of the English translation, beginning at the first paragraph:-

“While the political organisation of the N.S.D.A.P. has carried out the political leadership, the S.A. is the training and education instrument of the Party for the realisation of the world philosophical soldier-like attitude.

In conformity with the directives of the Fuehrer given at the time of the Reich Party Meeting of Freedom, the S.A. is, as the voluntary political soldiery, the guarantor of the National Socialist Movement, of the National Socialist Revolution, and of the resurgence of the German people.

Consequently, the young German in the S.A. is being inculcated in the first instance from the standpoint of world philosophy and character, and trained as the bearer of the National Socialist armed will.

Equally important is a suitable education and training of the yearly age groups which the S.A. has to accomplish after they have served their time in the Army. It is the task to keep them for their lifetime in all their spiritual, mental and physical powers on the alert to work for the Movement, the People and the State. They should find their best home in the S.A. All that which could divide them economically, culturally, professionally, or socially is being overcome in the S.A. by the spirit of comradeship and manly dignity.

In that manner the S.A. is forming a decisive factor on the path to a popular community. Its spirit should radiate with soldierly tradition and the possibility of application on all existing units outside the movement. To guard them is thus an important mission of the S.A.”

A number of the articles which were obviously designed to serve as war propaganda material have been translated; in other cases it has been deemed sufficient to translate merely the titles of articles, the titles in themselves being so descriptive that they disclose the nature and substance of the articles. I should like to refer to a few of these titles on this subject. They are shown on the English translation – Document 3050-PS, and they are listed on Page 1.

On the question of the Nazi “Lebensraum” philosophy: there is, first, in the issue Of 5th January, 1935, Page 13, the article “The German Living Space.” The issue of 10th October, 1936, Page 15, “Our Right, Our Colonies.” Another, of 14th October, 1938, Page 3, the title “Space and Folk”; “Colonies for Germany,” 2nd January, 1937, Page 4. I should like to quote briefly from that article. I believe that it is on Page 1 of the English translation, Document 3050-PS:-

“The German Ambassador in London, Herr von Ribbentrop, recently, on occasion of a reception in the ‘Anglo- German Fellowship’ has renewed, in a speech which aroused great interest, the indubitable claim of Germany for the restitution of its colonies which had been snatched away.

Shortly thereafter the Reichsbank president and Reich Minister of Economics, Dr. Schacht, published in the English magazine, ‘Foreign Affairs’ a detailed article on the German colonial problem.”

That is on Page 2, I believe, of the English translation.

“For the rest, Dr. Schacht laid out the categorical demand that Germany must, in order to solve the problem of its raw materials, get colonies, which must be administered by Germany, and in which the German standard currency must be in circulation.”

Now, the next group are articles dealing with the Versailles Treaty, and I will only quote from a few of them on Page 3 of that same translation. Here is one of 7th April, 1934, Page 14, “What is the Situation regarding our battle for Equal Rights?” Another is entitled “The Dictate of Versailles,” 30th June, 1934, Page 15. Here is a part of it:- –

“The Dictate of Versailles established the political, economical, and financial destruction of Germany in 440 artfully – one could also say devilishly – devised paragraphs; this work of ignominy is a sample of endless and partly contradictory repetitions in constantly new forms. Not too many have occupied themselves with this thick book to any great extent, for one could only do it with abomination.”

Another title is 7th July, 1934, Page 15, “The Unbearable Limitations on our Fleet.” Another one: 19th January, 1935, Page 13, “Versailles after 15 Years.” I read a part of it:-

“This terrible word ‘Versailles’, since a blind nation ratified it, has become a curse for all those who have comprehended the gist of this monstrous product of hatred. The Versailles dictate is Germany’s fate in the fullest sense of the word. Every German has been affected by this fate during the past 15 years. Therefore, every German down to the last man must also grasp the contents of this dictate so that one single desire, that for its absolute destruction, fills the whole German ‘Volk’.”

I shall omit the other quotation. The last one I shall refer to is “Versailles Will be Liquidated,” 13th February, 1937. If your Honour pleases this is the last paragraph on Page 4 of the English translation. I quote:-

“The National Socialist Movement has again achieved a victory, for since the beginning of the fight there was written on their flags: The liquidation of the Versailles Treaty. For this fight the S.A. marched year after year.”

A third group consists of articles describing preparations for war, purportedly being carried on by other nations, found on Page 5 of the same document and I shall refer to just a few of them:

The issue of 26th January, 1935, Page 14, “Military Training of English Youth,” showing pictures of Eton students wearing the traditional Eton dress – tall hats and frock coats – marching with rifles.

Another one is “The Army of the Soviet Union,” dated 16th March, 1935, Page 14.

Another one, 4th April, 1936, Page 15, “The Red Danger in the East.”

Another one, 29th August, 1936, Page 10, “Russia Prepares for World War.”

Another one, 19th June, 1937, Page 7, “Red Terrorism Nailed Down.”

I shall omit the rest of them.

Now, the next is the S.A. participation in the aggressive war phase of the conspiracy – the preparation by S.A. of the youth of Germany for participation in aggressive warfare. I hardly think I need emphasize that one of the most important steps in carrying out the conspiracy was the training of the youth of Germany in the technique of war, and their preparation physically and spiritually for the waging of aggressive war. To the S.A. was delegated this most important responsibility. I have here Document 3215-PS, Exhibit USA 426, which I offer in evidence, and it is an excerpt from Das Archiv which contains Hitler’s characterisation of the task of the S.A. in this respect. It is on Page 1 of the English translation of 3215-PS. I start the reading where it says, “Already in 1920-“:

“Already in 1920 by the founding of the National Socialist Sports Troop (S.A.) the Fuehrer established the extensive mission of this S.A. at that time in which he declared in the protocol of its charter:

The Sports Troop (S.A.) shall be the bearer of the military thought of a free people.”

In the same sense the Fuehrer said in his book, Mein Kampf:

“Give the German Nation six million bodies perfectly trained in sport, all fanatically inspired by the love of the Fatherland and trained to the highest offensive spirit, and a National Socialist State will, if necessary, have created an army out of them in less than two years.”

The military character of the S.A. is demonstrated by its organisational composition. I refer to the chart on the wall, which is our Document 2168-PS, and it is taken from this book, being the pamphlet of the S.A.-Sturmfuehrer, and the chart is taken from the official book. I refer merely to the chart and call to the attention your Honour that it was organised into units closely corresponding to those of the German Army. As the Tribunal will see, the organisational scheme consisted of divisions. Going from the top in that pyramidal structure, we see at the top the division; next the brigade, then the regiment, the battalion, the company, the platoon and at the bottom, the squad.

In addition, there were special units and branches, including cavalry, signal corps, engineer corps, and medical corps. There were also, as Bayer pointed out in his pamphlet, three officer training schools. Similarly, S.A. members wore distinctive uniforms adapted to military functions, bore arms, and engaged in training, forced marches, and other military exercises.

S.A. members, moreover, were governed by general service regulations, which closely resembled service regulations of an armed force. They are contained in Document 2820-PS, Exhibit USA 427, which I offer in evidence. If your Honour pleases, they are found at Page 3 of the translation of Document 2820. I will merely refer to a few of them. They provide for punishment, designating them as penal regulations, for disobedience of orders and infractions. The punishments which are provided demonstrate the militaristic character of the S.A. and include the following:

Reprimand in private; reprimand in presence of superiors and announcement thereof at formations; prohibition of the right to wear service uniform; house arrest, arrest and confinement in gaol; demotion in rank, prohibition of right to carry weapons.

Preparation for war through the S.A. training programme was begun in Germany as early as 1933, but the scope of this programme was not made public because of the fact that it actually constituted a violation of the Treaty of Versailles. The strict secrecy with which the programme was surrounded is shown in Document D-44, Exhibit USA 428, which I offer in evidence.

On Page 1 of the English translation – this is from the Supreme Command of the S.A., Chief of Staff, and it has to do with publications on the S.A., is the following:

“Further to my instruction Z II 1351Z33 dated 11th July 33, I find cause to ask all S.A. authorities to exercise the greatest caution with regard to any publicity given to the S.A. service, not only in the Press, but also in the information and news sheets of the individual S.A. units.

Only during the last few days, the Reich Ministry of the Interior, at the request of the Foreign Office, has given strict instructions to all Reich authorities according to which the most severe control is to be exercised on all publications which might give other countries an occasion to allege German infringements of the terms of the Versailles Treaty.

As is known from the Geneva negotiations, our opponents have piled up material collected in Germany and submitted to them, which they use against us on every occasion during the conferences.

From this point of view, the information sheets circulating among the subordinate S.A. units cause the liveliest concern. I hold all higher S.A. leaders responsible that any such internal information sheets, appearing in the district of their command, are submitted to the most stringent control before they go into print, and I feel compelled to draw attention to the liability to prosecution for treason as pronounced in official instructions issued in the last few days in cases where such reports, printed no doubt in good faith, are published and therefore exposed to the danger of falling into the wrong hands.

On principle, pictures of the special technical units of the S.A. and S.S., in particular of the motorised signals, and possibly also of the air squads which now exist outside these formations, are forbidden, such pictures enabling other countries to prove the alleged formation of technical troop units.”

Similarly, secrecy was provided for in the order assigning a Wehrmacht officer to the S.A. in January, 1934, to assist in the S.A. training programme. This Document, 2823-PS, Exhibit USA 429, which is a copy of a memorandum of S.A. Headquarters dated 20th January, 1934, designates an officer of the Wehrmacht to assist the military training of S.A. members. and it goes on to provide, and I quote from paragraph 7 of the English translation of Document 2823-PS:-

“For the purpose of camouflage, Lt. Col. Auleb will wear S.A. uniform with the insignia of rank according to more detailed regulations of the Supreme S.A. Leaders.”

The military training programme of the S.A. was for many years conducted under the guise of a sports programme. This plan was created by Hitler as early as 1920 by the founding of what he called the Sports Programme. The fact that the so-called Sports Programme was in reality closely associated with, and, in fact, a means of providing military training for the German youth is shown by the following characterisation it by Lutze, the Chief of Staff of the S.A., in an article written in 1939. I now refer to Document 3215-PS, Exhibit USA 426, and I quote excerpts of the English translation on Page 2:

“This goal was also served by the decrees of the Fuehrer to the S.A. in 1935 regarding the renewing of, in 1936 regarding the charter of, and in 1937 regarding the yearly repetitive exercises required for the S.A. sport badge. Parallel to this decree of the Fuehrer for the betterment and military indoctrination, organisational and training measures were taken within the S.A. Based on the conception that the preservation and intensification of the military power of our people must especially be promoted by military and physical exercises, a systematic training was carried out especially in these schools.

In twenty-five ‘group schools’ and in three ‘Reichsfuehrer’ schools of the S.A., 22,000 to 25,000 officers and non-coms have been trained yearly since 1934 in special educational courses until they earned the education and examination certificates. In clearly outlined directives the training goal which had to be achieved yearly was stepped up, and at the same time annual Reich competitive contacts of the S.A. were established. Hand in hand with the training of the Fuehrer Corps and the organisations belonging to it went the training for the front on the broadest basis.”

In connection with the military training of the sports programme, I refer to Document 2354, Exhibit USA 430, which demonstrates the tests and standards required for obtaining the sports award, on Page 2 of the English translation. I am not going read all of it, if your Honour pleases, but just refer to a few of them:

“Group II: Military sports; 25-kilometer march with pack; firing of small-caliber arms; aimed throwing of hand grenades, 200 meter cross-country race over four obstacles with gas masks; swimming or bicycling; basic knowledge of first aid in case of accidents-”

I will pass the others.

In 1939 the S.A. Sports Programme was formally recognised in a decree issued by Hitler as a military training programme and the S.A. was openly declared to be an agency for pre-and post-military training, that is, for military training prior to and following service in the Wehrmacht. I have Document 2383-PS-

THE PRESIDENT: Colonel Storey, you have just drawn our attention to a Document 3215-PS, which shows that from 1934 onwards, 25,000 officers and non-commissioned officers were trained by the S.A.

COLONEL STOREY: Yes, Sir.

THE PRESIDENT: Isn’t that sufficient to show the military nature of the organisation?

COLONEL STOREY: I think so. This was just the decree of Hitler. May I just refer to it by reference for the record? I will not read the decree.

THE PRESIDENT: Go on; what are you referring to?

COLONEL STOREY: Document 2383-PS, Page 11 of the English translation contains a copy of the decree legalising the training programme for pre-and post-military training.

It would have been one thing for the S.A. to conduct a military training programme for its members, but the S.A. programme was not confined to its members. The entire youth of Germany was enlisted into a feverish programme of military training.

I refer to a quotation in Document 2354-PS, from the same organisation book, which is at Page 2 of the English translation, in which the Chief of Staff Lutze said, and I quote briefly:

“In order to give expression to the fostering of a valiant spirit in all classes of the German people, I further decree that this S.A. Sports Insignia can also be earned by persons who are not members of the movement, provided they comply racially and ideologically with the National Socialist requirements.”

Document 2168-PS shows that responsibility for conducting the nation-wide programme was lodged in the operational main office of the SA. Page 8 of the English translation says, and I quote:

“Prepare the physical military training of all Germans capable of bearing arms, and as a preparation therefor organise physical exercises and sports, so that the widest strata of the population are reached and will be kept in a militarily active condition both physically and spiritually, as well as in respect to character and ideology up until the last years of their lives.”

I pass from that phase now.

Document 3215-PS is an excerpt from Das Archiv, and I refer to Pages 2 to 3 of the English translation beginning at the bottom of Page 2, and I quote:

“Next to the companies of the S.A. were the S.A. Sport Badge Associations, in which all the militaristic nationals entered who were prepared to answer the call of the S.A. for the preservation of military proficiency. Up until now about 800,000 nationals outside the S.A. could successfully undergo the physical training as well as the political-military training of the S.A. on the basis of the S.A. sport badge.”

The military programme of the S.A. was not that of a mere marching and drill society. It embraced every phase of the technique of modern warfare. This is particularly demonstrated by consideration of the articles on military training which appeared publicly throughout the issues of the S.A.-Mann. I should like to refer to only a few of the titles, and they are set out on Pages 8 and 10 of Document 3050. It is a very long list, and I will only refer to five or six.

There is one of them, 17th February, 1934, Page 7, “Pistol Shooting”; 21st April, 1934, Page 13, “What every S.A. man must now about Aviation”; 19th May, 1934, Page 13, “Chemical Warfare”; 2nd June, 1934, Page 14, “Modern Battle Methods in the View of the S.A. Man”; 4th August, 1934, Page 13, “The Significance of Tanks and Motors in the Modern War.”

I will omit references to the remainder.

Similarly, the issues of the S.A.-Mann contain many photographs and articles demonstrating and portraying S.A. participation in military exercises, including forced marching, battle maneuvers, obstacle runs, small-caliber firing, and so on. I merely refer these to your Honour, and they are shown on Pages 11 to 13 of Document 3050. Just one or two titles: 24th August, 1935, Page 2, “The S.A. Is and remains the Shock Troop of the Third Reich.” Here is one showing the connection with the Wehrmacht: 2nd September, 1938, Page 1, “The S.A. and the Wehrmacht,” with pictures of S.A. men on field maneuvers throwing hand grenades.

I will omit the rest of those.

Convincing evidence demonstrating the participation of the S.A. in the conspiracy is found in the fact that care was taken at all times to co-ordinate the military training of the S.A. with the requirements of the Wehrmacht. This is shown by Document 2821-PS, Exhibit USA 431, Page 1 of the English translation, quoting:

“Permanent liaison between the Reich Defence Ministry and the Supreme Commander of the S.A… has been assured.”

Another document, 3215-PS, which is an excerpt from Das Archiv, sets forth the co-operation and collaboration with the Wehrmacht, and specialised military training, and it was stated in a speech of the Chief of Staff of the S.A., Document 32l5-PS, Page 2 of the English translation, Exhibit USA 426:

“In the course of this development also special missions for military betterment were set for the S.A. The Fuehrer charged the S.A. with the cavalry and motor training and appointed S.A. Obergruppenfuehrer Litzmann as Reich Inspector with the mission of securing, through the S.A., cavalry recruits for the requirements of the German Wehrmacht. In close co-operation with parts of the Wehrmacht, special certificates were created for the signal, engineer and medical units which, like the cavalry certificate of the S.A., are valued as a statement of preference for employment in these units.”

Your Honour, we have two or three more quotations about co- operation with the Wehrmacht, but I believe they would be cumulative, and I will omit them. I will refer only to Document 2383-PS, Exhibit USA 410. I will read a portion of the decree:

“The Fuehrer: In amplification of my decrees of 15th February, 1935, and of 18th March, 1937 regarding the award of the S.A. Sports Insignia and the yearly repetitive exercises, I raise the S.A. Sports Insignia to the S.A. Military Insignia and make it a basis for pre- and post-military training. I designate the S.A. as the Standard Bearer of this training.”

I pass now to Page 48 for the record.

The specialised training given S.A. members, in accordance with the requirements of the technical branches of the Wehrmacht, is described in Document 2168 by S.A. Sturmfuehrer Bayer, Exhibit USA 411, and it is Page 13 of the English translation:

“On the one hand, the young S.A. man who from his branch in the S.A. enters the Armed Forces (Wehrmacht) already has many abilities which facilitate and speed up technical training; while on the other hand those very soldiers, who, having served their time in the Armed Forces return to the S.A., keep themselves, by constant training, physically and mentally fit, and impart their knowledge to their fellows.

Thus they contribute a considerable portion to the increase of the armed strength and armed spirit of the German people.”

And then passing down: “The S.A. each year is able to furnish many thousands of trained young men to our Wehrmacht.” I will omit the rest of that.

I simply call attention now to Page 3 of an issue of Der S.A.-Mann dated 3rd February, 1939, which contains a photograph of Chief of Staff Lutze addressing a group of his men. This photograph bears the caption, “We will be the Bridge between the Party and the Wehrmacht.”

The second reference shows a photograph of General Brauchitsch and Chief of Staff Lutze reviewing an S.A. unit.

Now, I pass to Document 3214-PS, which is Exhibit USA 432. There is only one page of it. Quoting:

“It was announced that S.A. men and Hitler Youths liable to military service can fulfil their military duty in the S.A. Regiment ‘Feldherrnhalle,’ the Commander of which is General Field Marshal, S.A. Obergruppenfuehrer Goering. The regiment for the first time was employed in the occupation of the Sudetenland as Regiment of the Luftwaffe, with special tasks under its Fuehrer and Regimental Commander, S.A. Gruppenfuehrer Reimann.”

THE PRESIDENT: Up to now you have brought evidence to our notice showing that the S.A. was voluntary. This shows it was conscripted. When did it become conscripted?

COLONEL STOREY: As I understand it, your Honour, if you joined the S.A. you got out of conscription, but once you were in it they could use you as desired. In other words, the S.A. was a voluntary organisation.

THE PRESIDENT: That is the evidence you have given up to date.

COLONEL STOREY: Yes, Sir.

THE PRESIDENT: Well, when did it become liable to conscription or used as a substitute for conscription?

COLONEL STOREY: May I ask Mr. Burdell, who has been working on it, to answer that question?

MR. BURDELL: If your Honour pleases, there never was conscription in the S.A. As this document shows, document 3214, service in the Feldherrnhalle Regiment of the S.A. took the place of conscription. This first sentence in Document 3214, which reads, “It was announced that S.A. men and Hitler Youths liable to military service can fulfill their military conscription in the S.A. Regiment ‘Feldherrnhalle,'” means, as I understand it, that S.A. men who are conscripted, that is S.A. men who are drafted after they have joined the S.A., may serve their conscription by remaining in the S.A. or by transferring to the Feldherrnhalle Regiment of the S.A.

The next paragraph of Document 3214 designates the requirements that must be fulfilled before the S.A. man can join this Feldherrnhalle Regiment, but if he fulfills those requirements he may join that regiment, and having done so, that serves the purpose or serves the function of conscription in the Wehrmacht.

I hope that answers your Honour’s question.

COLONEL STOREY: In view of the above we would accept the S.A. to have been used as a striking force in the first steps of the aggressive war launched by Germany and as a basis for so-called Commando Groups, and such was the case. S.A. units were among the first Nazi military machine to invade Austria in the spring of 1938, as was proudly announced in an article appearing in Der S.A.-Mann, 19th March, 1938, Page 10, the article entitled, “We Were There First.”

The S.A. participation in the occupation of the Sudetenland is also shown by Document 3036, Exhibit USA 102, and that is an affidavit by Gottlieb Berger, a former office holder in the S.S., who was assigned to the Sudeten-German Free Corps. I quote paragraphs 1 and 2 of the affidavit.

“1. In the fall of 1938 I held the rank and title of Oberfuehrer in the S.S. In mid-September I was assigned as S.S. Liaison Officer with Konrad Henlein’s Sudeten German Free Corps at their headquarters in the castle at Dorndorf outside Bayreuth. In this position I was responsible for all liaison between the Reichsfuehrer S.S. Himmler and Henlein” – your Honour will recall Henlein was the leader in the Sudetenland – “and in particular, I was delegated to select from the Sudeten Germans those who appeared to be eligible for membership in the S.S. or V.T. (Verfuegungstruppe). In addition to myself, Liaison Officers stationed with Henlein included an Obergruppenfuehrer from the N.S.K.K., whose name I have forgotten, and S.A. Obergruppenfuehrer Max Juettmer, from the S.A. In addition, Admiral Canaris, who was head of the O.K.W. Abwehr, appeared at Dorndorf nearly every two days and conferred with Henlein.”

Your Honours will recall that the “Abwehr” was the Intelligence Organisation.

2. In the course of my official duties at Henlein’s Headquarters I became familiar with the composition and activities of the Free Corps. Three groups were being formed under Henlein’s direction: One in the Eisenstein area, Bavaria; one in the Bayreuth area; one in the Dresden area; and possibly a fourth in Silesia. These groups were supposedly composed of refugees from the Sudetenland who had crossed the border into Germany, but they contain Germans with previous service in the S.A. and the N.S.K.K. (Nazi Motor Corps) as well. These Germans formed the backbone of the Free Corps.

On paper the Free Corps had a strength of 40,000 men. Part of the equipment furnished to Henlein, mostly haversacks, cooking utensils and blankets, was supplied by the S.A.”

The adaptability of the S.A. to whatever purpose was required of it is demonstrated by its activities subsequent to the outbreak of the war. During the war the S.A. continued to carry out its military training programme, but it also engaged in other functions. Its wartime activities are set out in Document 3219-PS, which is Exhibit USA 433, and Document 3216-PS, Exhibit USA 434, which excerpts from Das Archiv.

I quote first, briefly, from Document 3219, the whole text, exclusive of the heading:

“The Chief of Staff of the S.A., Wilhelm Schepmann, gave further orders to increase the employment of the S.A. in the homeland war areas, because of the requirements of total war employment. This was done in numerous conferences with leaders of the S.A. divisions.

As a result of these conferences, as well as of measures already carried out earlier for the totalisation of the war employment, the S.A. has placed 86 per cent. of its main professional Fuehrer Corps at the disposal of the Front, even though the war missions of the S.A. have increased in the fields of pre- military training, the S.A. penetration into new parts of the Reich, the air war employment, the State and national guard, etc., during wartime.

The S.A. as a whole has given at present 70 per cent. of its some million members to the Wehrmacht.”

I call the attention of your Honours to the statement of the membership of 26th August, 1944. I quote briefly from Document 3216, the English translation, just one sentence:

“By order of the Chief of Staff of the S.A., the S.A. unit Government-General was established, the command of which was taken over by Governor General S.A. Obergruppenfuehrer Dr. Frank.”

I next offer in evidence an affidavit, being Document 3232- PS, Exhibit USA 435, by Walter Schellenberg:

“From the beginning of 1944 the S.A. also participated in many of the functions which had previously been entrusted only to the S.S., the Sipo and Army; for instance, the guarding of concentration camps and of prisoner-of-war camps, the supervision of forced laborers in Germany and occupied territories. This co- operation of the S.A. was planned and arranged for by high officials in Berlin as early as the middle of 1943.”

This concludes my presentation of the principal points of evidence concerning the participation of the S.A. in the conspiracy, but before I leave the subject, I should like to present to the Tribunal a few facts which establish the participation in the conspiracy by defendant Goering, in his capacity as an S.A. member or leader.

In 1923, Goering became commander of the entire S.A. This is shown in the pamphlet, “The S.A.,” which is already in evidence, and the notation concerning Goering’s command appears at Page 2 of the translation, which I do not intend to quote but will merely refer to.

Goering’s intention to employ the S.A. as a terroristic force to destroy political opponents is shown by a speech made by him on 3rd March, 1933, at a Nazi demonstration in Frankfurt. It is Document 1856-PS, Exhibit USA 437. It is an excerpt from a book entitled, “Hermann Goering, Speeches and Essays.” I quote: Goering said-

“Certainly I shall use the power of the State and the police to the utmost, my dear Communists, so draw no false conclusions. It will be a fight to the death, in which my fist will knuckle your neck; I shall lead with those down there the Brown Shirts.”

The importance of the S.A. under Goering in the early stages of the Nazi movement is shown by Document 3259-PS, Exhibit USA 424, and it is an English translation from the same book, 3259-PS. This is a letter written to Goering by Hitler and I quote it:

“My dear Goering,

“When in November, 1923, the Party tried for the first time to conquer the power of the State, you, as Commander of the S.A., created, within an extraordinarily short time, that instrument with which I could dare struggle. Highest necessity had forced us to act, but by a wise providence at that time we were denied success. After receiving a grave wound, you again entered the ranks, as soon as circumstances permitted, as my most loyal comrade in the battle for power. You contributed essentially to creating the basis for the 30th January. Therefore, at the end of the year of the National Socialist Revolution, I desire to thank you wholeheartedly, my dear Party Comrade Goering, for the great services you have rendered to the National Socialist Revolution and consequently to the German people.

“In cordial friendship and grateful appreciation,

Yours,

Adolf Hitler.”

Although Goering did not retain command of the S.A., he at all times maintained close affiliation with the Organisation. This is shown by the the photographs of him participating in the activities which I have already introduced in evidence. Similarly, in 1937, he became the Commander of the Feldherrnhalle Regiment of the S.A. The Tribunal will recall, also my reference to the participation of that regiment in the occupation of the Sudetenland.

Now, finally, the evidence considered in the foregoing section of this brief, demonstrates the participation of the S.A. as an Organisation in the conspiracy alleged in Count One. Thus, the S.A. was first employed by the conspirators to destroy, by force and brutality, all opponents of National Socialism and to gain possession of the streets. Thereafter, upon the seizure of control by the N.S.D.A.P., the S.A. was used to consolidate and to strengthen Nazi power, and to persecute cruelly and destroy all so-called “enemies” of the State, including Jewry and the Church. During the period 1934 to 1939, the S.A. was employed for the actual preparation and training of the German people for war, and participated in aggressive warfare.

The S.A. was at all times employed by the conspirators to promote and disseminate the ideology of the Nazi Movement throughout Germany, and particularly, to perform the function of disseminating anti-Jewish propaganda and creating and fostering a militaristic and warlike spirit among the people of Germany

Conspiracy through its various phases ; and the conclusion, we think, is irresistible, that the S.A. was an Organisation devoted exclusively to the task.of assisting the defendants and their co-conspirators in carrying out the objectives of the Conspiracy.

Thus, in this sense, the S.A., as well as its members, were in fact co-conspirators and participants in a conspiracy which contemplated and involved Crimes Against Peace and Crimes Against Humanity and War Crimes.

That concludes the presentation of the S.A., your Honour, and the next is the S.S., by Major Farr.

Do your Honours want to go ahead with that now ?

THE PRESIDENT: Perhaps we had better adjourn then, until 2 o’clock.

(A recess was taken until 1400 hours.)

MAJOR FARR: May it please the Tribunal, the next organisation to be dealt with is the S.S. The document books in this case are lettered ” Z.” For convenience in handling the books, because of the bulk of documents, we have divided them into two volumes. I shall in referring to a document number, refer to the volume in which that document appears.

About a week or ten days ago there appeared in a newspaper, circulated in Nuremberg, an account of a visit by that paper’s correspondent to a camp in which S.S. prisoners-of-war were confined. The thing which particularly struck the correspondent was the one question asked by the S.S. prisoners. Why are we charged as war criminals ? What have we done except our normal duty?

The evidence now to be presented to the Tribunal will, we expect, answer that question. It will show that just as the Nazi Party was the very heart – the core – of the conspiracy, so the S.S. was the very essence of Nazism. For the S.S. was the elite group of the Party, composed of the most thoroughgoing adherents of the Nazi cause, pledged to blind devotion to Nazi principles, and prepared to carry them out without any question and at any cost-a group in which every ordinary value has been so subverted that its members can ask ” What is there unlawful about the things we have done?”

During the past weeks the Tribunal has heard evidence of the conspirators’ criminal programme for aggressive war, for concentration camps, for the extermination of the Jews, for enslavement of foreign labour and illegal use of prisoners-of-war, for deportation and Germanisation of inhabitants of conquered territories. Through all this evidence the name of the S.S. ran like a thread. Again and again that organisation and its components were referred to. It is my purpose to show why it performed a responsible role in every one of these criminal activities, why it was – and, indeed, had to be – a criminal organisation.

The creation and development of such an organisation was, indeed, essential for the execution of the conspirators’ plans. Their sweeping programme and the measures they were prepared to use and did use, could be fully accomplished neither through the machinery of the Government nor of the Party. Things had to be done for which no agency of government and no political party-even the Nazi Party-would openly take full responsibility. A specialised type of apparatus was needed, an apparatus which was to some extent connected with the Government and given official support but which, at the same time, could maintain a quasi-independent status, so that it acts could be attributed neither to the Government nor to the Party as a whole. The S.S. was that apparatus.

Like the S.A., it was one of the seven components or formations of the Nazi Party, referred to in the Decree on the Enforcement of the Law for Securing the Unity of Party and State, Of 29th March, 1935, published in the Reichsgesetzblatt for that year, Part I, Page 503. That decree will be found in our Document 1725-PS. I shall not read it. I assume that the Court will take judicial notice of it. The status of the S.S., however, was above that of the other formations. As the plans of the conspirators progressed, it acquired new functions, new responsibilities, and an increasingly more important place in the regime. It developed during the course of the conspiracy into a highly complex machine, the most powerful in the Nazi State, spreading its tentacles into every field of Nazi activity.

The evidence which I shall present will be directed, first, towards showing very briefly the origin and early development of the S.S. ; second, how it was organised-that is, its structure and its component parts ; third, the basic principles governing the selection of its members and the obligations they undertook; and finally, its aims and the means used to accomplish them, the manner in which it carried out the purposes of the conspirators, and thus was a responsible participant in the crimes alleged in the Indictment.

The history, Organisation and publicly announced functions of the S.S. are not controversial matters. They are not matters to be learned only from secret files and captured documents. They were recounted in many publications, circulated widely throughout Germany and the worldofficial books of the Nazi Party itself and books, pamphlets and speeches by S.S. and State officials published with S.S. and Party approval. Throughout the presentation of the case I shall frequently refer to five or six such publications, translations of which-in whole or in part-appear in the document books. Although I shall quote portions of them, I shall not attempt to read them all in full, since I assume that the contents of such authoritative publications may be judicially noticed by the Tribunal.

Now to take up the origin of the S.S. The first aim of the conspirators – as the evidence already presented to the Court has shown – was to gain a foothold in politically hostile territory, to acquire mastery of the streets and to combat any and all opponents with force. For that purpose they needed their own private, personal police Organisation. Evidence has just been introduced in the case against the S.A.-showing how that Organisation was created to fill such a role. But the S.A. was outlawed in 1923. When Nazi Party activity was again resumed in 1925, the S.A. remained outlawed. To fill its place and to play the part of Hitler’s own personal police, small mobile groups known as protective squadrons (Schutzstaffel) were created. This was the origin of the S.S. in 1925. With the reinstatement of the S.A. in 1926, the S.S. for the next few years ceased to play a major role. But it continued to exist as an Organisation within the S.A. – under its own leader, however – the Reichsfuehrer S.S. This early history of the S.S. is related in two of the authoritative publications to which I have referred: the first is a book by S.S. Standartenfuehrer Gunter d’Alquen, entitled ‘Die S.S.’ This book – a pamphlet of some 30 pages – is an authoritative account of the history, mission and Organisation of the S.S., published in 1939. As indicated on its frontispiece, it was written at the direction of the Reichsfuehrer S.S., Heinrich Himmler. Its author, S.S. Standartenfuehrer Gunter d’Alquen, was the editor of the official S.S. publication ‘Das Schwarze Korps.’ This book is our Document 2284-PS, I offer it in evidence Exhibit USA 438. The passage to which I refer will be found on Pages and 7 of the original, and on Page i of the translation.

I shall not now read that passage.

The second publication is an article by Himmler, entitled ” Organisation and Obligations of the S.S. and the Police.” It was published in 1937 in booklet containing a series of speeches or essays by important officials of Party and the State – known as “National Political Course for the Arm Forces from 15th to 23rd January, 1937.” The article by Himmler, which I refer, appears on Pages 137-161 of that pamphlet. Large extra from it make up our Document 1992-A-PS. I offer the essay by Himml as Exhibit USA 439. The passage to which I referred appears on Page 137 of the original and Page 1 of the translation, our Document. 1992-A-PS. I shall have occasion to quote from both these publications, but with respect to this matter of history, I assume that these references to the pertinent passages in them are enough.

As early as 1929 the conspirators recognised that their plans required organisation in which the main principles of the Nazi system, specifically the racial principles, would not only be jealously guarded but would carried to such extremes as to inspire or intimidate the rest of the population – an organisation in which, also, there would be assured complete freedom on the part of the leaders and blind obedience on the part of the members. The S.S. was built up to meet this need. I quote from d’Alquen’s book ‘Die S.S.’, at Page 7 – this passage appears in our Document 2284-PS, at Page 4 of the translation, paragraph 4:

“On 16th January, 1929, Adolf Hitler appointed his tested comrade of long standing, Heinrich Himmler, as Reichsfuehrer S.S. Heinrich Himmler assumed charge therewith of the entire Schutzstaffel, totalling at the time 280 men, with the express and particular commission of the Fuehrer to form this organisation into an elite troop of the Party, a troop dependable in every circumstance. With this day the real history of the S.S. begins as it stands before us today in all its deeper essential features, firmly anchored in the National Socialist movement. For the S.S. and its Reichsfuehrer, Heinrich Himmler, its first S.S. men, have become inseparable in the course of these battle-filled years.”

Carrying out Hitler’s directive, Himmler proceeded to build up out of this small force of men an elite organisation – to use d’Alquen’s words: ” composed of the best physically, the most dependable, and the most faithful men in the Nazi movement.” I read another passage from d’Alquen, at Page 12 of the original, Page 6 of the translation, paragraph 5:

“When the day of seizure of power had finally come, there were 52,000 S.S. men, who in this spirit bore the revolution in the van, marched into the new State which they began to help to form everywhere, in their stations and positions, in profession and in science, and in all their essential tasks.”

The conspirators now had the machinery of government in their hands. The initial function of the S.S. – that of acting as private army and personal police force – was thus completed. But its mission had in fact really just begun. That mission is described in the Organisation Book of the N.S.D.A.P. for 1943. The pages from that book dealing with the S.S. – Pages 417 to 428 – are translated in out Document 2040-PS. The organisation’s book has already been offered in evidence as Exhibit USA 303. The passage to which I refer appears on Page 417 of the original, and on Page 1, paragraph 2, of the translation, our Document 2640-PS:

“Missions

The most original and most eminent duty of the S.S. is to serve as the protectors of the Fuehrer.

By decree of the Fuehrer, the sphere of duties has been enlarged to include the internal security of the Reich.”

This new mission – protecting the internal security of the regime – was somewhat more colourfully defined by Himmler in his pamphlet “The S.S. as an Anti-Bolshevist Fighting Organisation,” published in 1936. It is our Document 185I-PS. I offer this document in evidence as Exhibit USA 440. The definition to which I refer appears at the bottom of Page 29 of the original, on the third page of the translation, middle of the paragraph:

“We shall unremittingly fulfil our task, the guaranty of the, security of Germany from the interior, just as the Wehrmacht guarantees the safety of the honour, the greatness, and the peace of the Reich from the exterior. We shall take care that never again in Germany, the heart of Europe, will the Jewish-Bolshevistic revolution of subhumans be able to be kindled either from within or through emissaries from without. Without pity we shall be a merciless sword of justice for all those forces whose existence and activity we know, on the day of the slightest attempt, may it be today, may it be in decades or may it be in centuries.”

This conception necessarily required an extension of the duties of the S.S. into many fields. It involved, of course, the performance of police functions. But it involved more. It required participation in the suppres sion and extermination of all internal opponents of the regime. It meant participation in extending the regime beyond the borders of Germany, and, therefore, came to mean eventually participation in every type of activity designed to secure a hold over those territories and populations which, through military conquest, had come under German domination.

The expansion of S.S. duties and activities resulted in the creation of several branches and numerous departments and the eventual development of a highly complex machinery. Those various branches and departments cannot be adequately described out of the context of their history. That description I hope will emerge fully as evidence of the activities of the S.S. is presented. But it may be appropriate to anticipate, and at this point to say a word about the structure of the S.S.

For this purpose, a glance at a chart depicting the organisation of the S.S. as it appeared in 1945 may be helpful. There are being handed to the Tribunal small copies of this chart, two in English, one in French and one in Russian. In addition, there are handed eight larger copies of the chart in the original German, which bears on it the photostat of the affidavit of Gottlieb Berger, formerly Chief of the S.S. Main Office, who examined the chart, and stated that it correctly represented the organisation of the S.S.

I now offer in evidence the chart of the Supreme and Regional Command of the S.S. as Exhibit USA 445.

At the very top of the chart is Himmler, the Reichsfuehrer S.S., who commanded the entire organisation. Immediately below – running across the chart and down the right-hand side, embraced within the heavy line – are the twelve main departments constituting the Supreme Command of the S.S. Some of these departments have been broken down into the several offices of which they were composed, as indicated by the boxes beneath them. Other departments have not been so broken down. It is not intended to indicate that there were not subdivisions of these latter departments as well. The breakdown is shown only in those cases where the constituent offices of some department may have a particular significance in this case.

These departments and their functions are described in two official Nazi publications: the first is the Organisation Book of the N.S.D.A.P. for 1943 (our Document 2640-PS) already introduced in evidence as Exhibit USA 323. The description, which I shall not now read, appears on Pages 419-420 of the original and Pages 2 to 4 of the translation. The second is an S.S. manual, which bears the title: “The Soldier Friend – Pocket Diary for the German Armed Forces – Edition D: Waffen S.S.” It was prepared at the direction of the Reichsfuehrer S.S. and issued by the S . S. Main Office for the year ending 1942. It is our Document 2825-PS. I offer it in evidence as Exhibit USA 441. The description to which I refer appears on Pages 20 to 22 of the original, and Pages 1 and 2 of the translation. I will later have occasion to read the description of the functions of some of the departments in full. But I assume that the Court will take judicial notice of the entire passages to which I have referred. In addition, the departments are listed in a directory of the S.S., published by one of the main departments of the S.S. This document was found in the files of the Personal Staff of the Reichsfuehrer S.S., the first department on the left of the chart. It is entitled “Directory for the Schutzstaffel of the N.S.D.A.P., 1st November, 1944.” It is marked “Restricted ” and bears the notation “Published by S.S. Fuehrungshauptamt, Kommandant of the General S.S.,” which is the fifth box from the left. It is our Document 2769-PS. I offer it in evidence as Exhibit USA 442. It is simply a list of the names of the departments and offices with their addresses and telephone numbers, and corroborates the statements in the two earlier publications to which I referred.

Returning now to the chart – following down the central spine from the Reichsfuehrer S.S. to the regional level, we come to the Higher S.S. and Police Leader, commonly known as H.S.S.P.F., the Supreme S.S. Commander in each region. I shall refer to his functions at a later point. Immediately below him is the breakdown of the organisation of the Allgemeine or General S.S. To the left are indicated two other branches of the S.S. – the Death Head Units (Totenkopf Verbaende) and the Waffen S.S. To the right, under the H.S.S.P.F., is the S.D. All of these components, together with the S.S. Police Regiments, are specifically named in the Indictment – Appendix B, Page 36 – as being included in the S.S.

Now a word as to these components. Up to 1933, there were no such specially designated branches. The S.S. was a single group – a group of 44 “volunteer political soldiers.” It was out of this original nucleus that the new units developed.

The “Allgemeine ” – that is, General S.S. – was the common basis, the main stem out of which the various branches grew. It was composed of all members of the S.S. who did not belong to any of the special branches.

It was the backbone of the entire organisation. The personnel and officers of the main departments of the S.S. Supreme Command were members of this branch. Except for high-ranking officers and those in staff capacities in the main offices of the S.S. Supreme Command, its members were part-time volunteers. As the evidence will show, its members were utilised in about every phase of S.S. activity. They were called upon in the anti-Jewish pogroms of 1938 ; they took over the task of guarding concentration camps during the war; they participated in the colonisation and resettlement programme. In short, the term “S.S.” normally meant the General S.S.

It was organised on military lines, as will be seen from the chart, ranging from district (Oberabschnitt) and sub-district (Abschnitt) down through the regiment, battalion, company, to the platoon. Until after the beginning of the war it constituted numerically the largest branch of the S.S. In 1939 d’Alquen, the official S.S. spokesman, said, and I quote from his book, our Document 2284-PS, Page 9, paragraph 3, of the English translation, and Page 18 of the original document:

“The strength of the General S.S., 240,000 men, is sub-divided today into 14 corps, 38 divisions, 140 infantry regiments, 19 mounted regiments, 14 communication battalions and 19 engineer battalions as well as motorised and medical units. This General S.S. stands fully and wholly on call as in the fighting years . . .”

Similar reference to the military organisation of the General S.S. will be found in Himmler’s speech “Organisation and Obligations of the S.S, and the Police,” our Document 1992-A-PS, at Page 4 of the translation. and in the Organisation Book of the N.S.D.A.P. for 1943, our Document 2460-PS, at Pages 4 and 5 of the translation.

Members of this branch, however, with the exception of certain staff personnel – were subject to compulsory military service. As the result of the draft of members of the General S.S. of military age into the Army, the numerical strength of active members considerably declined during the war. Older S.S. men and those working in or holding high positions in the main departments of the Supreme Command of the S.S. remained. Its entire strength during the war was probably not in excess of 40,000 men.

The second component to be mentioned is the Security Service of the Reichsfuehrer S.S., almost always referred to as the S.D. Himmler described it in his speech, “Organisation and Obligations of the S.S. and the Police ” – our Document 1992-A-PS. I quote a passage from Page 8, last paragraph of the translation, Page 151 of the original, paragraph 3:

“I now come to the Security Service (S.D.) ; it is the great ideological Intelligence Service of the Party, and, in the long run, also that of the State, During the time of struggle for power it was only the Intelligence Service of the S. S. At that time we had, for quite natural reasons, an Intelligence Service with the regiments, battalions and companies.” – He refers there to the regiments, battalions and companies of the General S. S. – ” We had to know what was going on on the opponents’ side, whether the Communists intended to hold a meeting today or not, whether our people were to be suddenly attacked or not, and similar things. I had already separated this service in 1931 from the troops ” (I note that it appears in the mimeographed translation as 1941, but, as will appear from a passage on the next pages of the translation, it was 1931 to which he was referring) “from the units of the General S.S., because I considered it to be wrong not to do so. For one thing, secrecy is endangered, then the individual men, or even the companies, are too likely to discuss everyday problems.”

Although, as Himmler put it, the S.D. was only the Intelligence Service of the S.S. during the years preceding the accession of the Nazis to power, it became a much more important organisation shortly thereafter. It had been developed into such a powerful scientific espionage system under its chief, Reinhard Heydrich, that on 9th June, 1934, just a few weeks before the blood purge of the S.A., it was made, by decree of the defendant Hess, the sole Intelligence and Counter-intelligence agency of the entire Nazi Party. I refer in support of that statement to d’Alquen’s book, Die S.S., our Document 2284-PS, at Page 11 of the translation. I shall not pause to quote that passage. The Organisation and numbers of the S.D., as they stood in 1937, were thus described by Himmler -I quote again from his article “Organisation and Obligations of the S.S. and the Police,” our Document 1992-A-PS, at Page 9 of the translation, second paragraph, Page 151 of the original, paragraph 4:

“The Security Service had already been separated from the troop in 1931 and separately organised. Its higher headquarters coincide today with the Oberabschnitte and Abschnitte ” (I refer to the “Abschnitte” and “Oberabschnitte” indicated on the chart) “and it has also field offices, its own organisation of officials, and a great many command posts, and is approximately three to four thousand men strong, or at least it will be when it is built up.”

Up to 1939, its headquarters was the S.S. Main Security Office (Sicherheitshauptamt), which, as I shall shortly show, became amalgamated in 1939 in the Reich Main Security Office (R.S.H.A.) one of the S.S. main departments shown on the chart before you – the sixth box from the left. The closer and closer collaboration of the S.D. with the Gestapo and Criminal Police – which eventually resulted in the creation of this R.S.H.A. – and the activities in which the S.D. engaged in partnership with the Gestapo, will be taken up in the presentation of the case against the Gestapo. The S.D. was, of course, at all times an integral and important component of the S.S. But it is more practicable to deal with it in connection with the activities of the whole repressive police system with which it functioned.

The third component to be mentioned is the “Waffen S.S.” – the combat arm of the S.S. – created, trained and finally utilised for purposes of aggressive war. The reason underlying the creation of this combat branch was described in our Document 2640-PS, the Organisation Book of the Nazi Party for 1943. It appears on Page 427A of the original Page 5, paragraph 7 of the translation:

“The Armed S.S. originated out of the thought: to create for the Fuehrer a selected long-service troop for the fulfilment of special missions. It should make it possible for members of the General S.S., as well as for volunteers who fulfil the special requirements of the S.S., to fight in the battle for the evolution of the National Socialist idea, with weapon in hand, in unified groups, partly within the framework of the Army.”

The term “Waffen S.S.” did not come into use until after the beginning of the war. Up to that time there were two branches of the S.S. composed of full-time, professional, well-trained soldiers – the so-called “S.S. Verfuegungstruppe ” – translatable perhaps as S.S. Emergency Troops – and the ” S.S. Totenkopf Verbaende ” -The, Death Head Units. After the beginning of the war, the units of the S.S. Verfuegungstruppe were brought up to division strength, and new divisions were added to them. Parts of the S.S. Death Head Units were formed into a division – the ” S.S. Totenkopf Division.” All these divisions then came to be known collectively as the Waffen S.S.”

Let me now trace that development. I quote again from the Organisation Book of the Nazi Party for 1943, our Document 2640-PS, Page 427B of the original, Page 5, last paragraph of the translation:

“The origin of the Waffen S.S. goes back to the decree Of 17th March, 1933, establishing the ‘ Stabswache’ with the original strength Of 120 men. Out of this small group developed the later-named ‘ S.S. Verfuegungstruppe’ (S.S. Emergency Force), and the ‘Leibstandarte S.S. Adolf Hitler.’ In the course of the war these groups grew into divisions.”

THE PRESIDENT: Major Farr, is it necessary to go into this degree of detail about the Organisation of the S.S.?

MAJOR FARR: Sir, it seemed to me that it is highly important to know exactly what is the organisation with which we are dealing. There has been, I understand, a suggestion made to the Court that certain portions of this organisation are not criminal. It is contended by some that the part they played was a perfectly innocuous one, and it seems to me that before we can determine whether the organisation as a whole is criminal, whether any portion of it is severable, then we must know what the organisation is.

THE PRESIDENT: Would it not be possible to leave that question to evidence in rebuttal, if the defendants are setting up that any particular branch of the S.S. is not criminal?

MAJOR FARR: If we adequately lay the basis for our case now, it may not be necessary for us to make any rebuttal. We may satisfy the defendants that there is nothing in the contention that any portion of the S.S. is a lawful portion. The point I am particularly trying to make now is: there has been a good deal of contention that the ” Waffen S.S. ” is severable ; that whatever may be said, for example, about the S.D. or the Death Head Units, the ” Waffen S.S.” is something different-the ” Waffen S.S. ” is part of the Army. I think it is important to establish at the outset that the “Waffen S.S.” is as much a part of the S.S., as integral a part of the whole Organisation, as any of the other branches. I propose, therefore, to show the development of the ” Waffen S.S.,” growing out of the S.S. Emergency Troop, and to call to the attention of the Tribunal evidence showing how the ” Waffen S.S.” is an integral part of the S.S. as a whole.

THE PRESIDENT: Well, you must take your own course.

MAJOR FARR: The “S.S. Verfuegungstruppe” were described in a top secret Hitler order, dated the 17th August, 1938. It is our Document No. 647-PS. I offer it in evidence as Exhibit USA 443. That document will be found in Volume I of the document book. I quote from Section II of that order, which appears on Page 2 of the translation, at the top of the page, and also on Page 2 of the original.

“II. The Armed Units of the S.S.

A. (The S.S. Verfuegungstruppe)

i. The S.S. Verfuegungstruppe is neither a part.of the Wehr macht nor a part of the Police. It is a standing armed unit exclusively at my disposal. As such and as a unit of the N.S.D.A.P. its members are to be selected by the Reichsfuehrer S.S. according to the philosophical and political standards which I have ordered for the N.S.D.A.P. and for the Schutzstaffe. Its members are to be trained and its ranks filled with volunteers from those who are liable to serve in the army having finished their duties in the compulsory labour service. The service period for volunteers is 4 years. It may be prolonged for S.S. Unterfuehrer. Such regulations are in force for S.S. leaders. The regular compulsory military service (para. 8 of the law relating to military service) is fulfilled by service of the same amount of time in the S.S. Verfuegungstruppe.”

I want to quote a further short passage from that decree which will be found on Page 3 of the translation, in the middle of the page, and on Page 4 of the original order:

III. Orders in Case of Mobilisation A. The employment of the S.S. Verfuegungstruppe in case of mobilisation is a double one.

I. By the Supreme Commander of the Army within the wartime army. In that case it comes completely under military laws and regulations, but remains a unit of the N.S.D.A.P. politically.

2. In case of necessity, in the interior according to my orders, in that case it is under the Reichsfuehrer S.S. and Chief of the German Police.

In case of mobilisation, I myself will make the decision about the time, strength and manner of the incorporation of the S.S. Verfuegungstruppe into the war-time army; these things will depend on the inner-political situation at that time.”

Immediately after the issuance of this decree, and the Court will recall it was issued in August of 1938, this militarised force was employed with the Army for aggressive purposes-the taking over of the Sudetenland. Following this action, feverish preparation to motorise the force and to organise new units such as anti-tank, machine gun and reconnaissance battalions were undertaken pursuant to further directives of the Fuehrer. By September, 1939, the force was fully motorised, its units had been increased to division strength and it was prepared for combat. These steps are described in the Nationalist Socialist Yearbook for the years 1940 and 1941. I offer in evidence Pages 365 to 371 of the 1940 Yearbook. It is our Document 2164-PS. It will be Exhibit USA 255. I offer Pages 191 to 193 of the 1941 Yearbook – which is our Document 2163-PS – as Exhibit USA 444. Since the Yearbook is an official publication of the Nazi Party, edited by Reichsleiter Robert Ley and published by the Nazi Party publishing company, I assume that the Court will take judicial notice of the contents of these exhibits.

After the launching of the Polish invasion and as the war progressed, still further divisions were added. The Organisation Book of the Nazi Party for 1943 – our Document 2640-PS – lists some eight divisions and two infantry brigades as existing at the end of 1942. I refer to Page 427b of the original, Page 5, last paragraph of the translation. This was no longer an emergency force. it was an S.S. army and hence came to be designated as the Waffen S.S. Himmler referred to this spectacular development of this S.S. combat branch in his speech at Posen on 4th October, 1943, to S.S. Gruppenfuehrers. That speech has already been introduced in evidence at an earlier stage in the case, as Exhibit USA 170 – It is our Document 1919-PS.

I shall quote from that speech, Page 51 of the original, Page 2 of the translation, second paragraph, headed “The S.S. in War-Time.”

“Now I come to our own development, to that of the S.S. in the past months. Looking back on the whole war, this development was fantastic. It took place at an absolutely terrific speed. Let us look back a little to 1939. At that time we were a few regiments, guard units, 8,000 to 9,000 strong – that is, not even a division, all in all 25,000 to 28,000 men at the outside. True, we were armed, but we really only got our artillery regiment as our heavy arm two months before the war began.”

I continue, quoting from the same speech a passage found on Page 8 of the English translation and on Page 103 of the original. The passage in the translation appears at about the middle of the page.

“In the hard battles of this year, the Waffen S.S. has been welded together in the bitterest hours from the most varied divisions and sections, and from these it formed: body-guard units (Leibstandarte), military S.S. (Verfuegungstruppe), Death Head Units, and then the Germanic S.S.”

Although tactically under the command of the Wehrmacht while in the field, it remained as much a part of the S.S. as any other branch of the organisation. Throughout the war it was recruited, trained, administered and supplied by the main offices of the S.S. Supreme Command. Ideologically and racially, its members were selected in conformity with S.S. standards.

I shall read a passage relating to the recruiting standards of the Waffen S.S. published in the S.S. Manual, “The Soldier Friend,” our Document 2825-PS, which appears on Page 7 of the English translation, first paragraph on Page 36, paragraph 2, of the the original. I quote:

“Today at last is the longed for day of the entrance examinations where the examiners and physicians decide whether or not the candidate is ideologically and physically qualified to do service in the Waffen S.S.

Everyone has acquainted himself with the comprehensive Manual for the Waffen S.S., of which the principal points are as follows:

I. Service in the Waffen S.S. counts as military service. Only volunteers are accepted.”

THE TRIBUNAL (MR. BIDDLE): What is the purpose of reading all this evidence ? What has what you just read got to do with what you are presenting ?

MAJOR FARR: Sir, I want to prove, as I said a moment ago, one thing first; that the Waffen S.S. is an integral, component part of the S.S. I want to establish that it is completely administered and controlled by the Supreme Command of the S.S. That is one thing.

The second thing I want to prove is this; that service in the Waffen S.S. is voluntary service, just as membership in the Allgemeine S.S. or Death Head Units is voluntary service. It is true that there were some instances towards the close of the war when a few men were conscripted into the Waffen S.S., but that was the exception and not the rule. In quoting from the Recruiting Standards of the Waffen S.S., appearing in this booklet which was published in 1942, and which indicates that at that time service in the Waffen S.S. was open only to volunteers, I think I am serving the purpose of proving one of the two points which I think ought to be estab lished.

I want to read, if I may, one further paragraph from that translation. I shall read the paragraph indicating that service is voluntary. Now I want to read the third requirement, which shows that service was open only to persons who could meet the ideological and other standards of the S.S. as a whole.

If the Tribunal is satisfied on the point that service in the Waffen S.S. is essentially voluntary and that the Waffen S.S. is an integral part of the S.S., I do not want to impose further by reading further evidence.

THE PRESIDENT: I think the Tribunal is satisfied on both those points, up to the present time, that it is voluntary and is an integral part of the S.S.

MAJOR FARR: If the Court is satisfied on both those points, I shall not pursue, any further, the introduction of this particular evidence.

THE PRESIDENT: It may, as you say, be possible to show that there were some members conscripted into it at a later date, but we have not had that evidence yet.

MAJOR FARR: No, your Honour, you have not.

All I want to show is that it is, normally, voluntary, and that the Waffen S.S. is an integral part of the whole organisation. If the Court is completely satisfied on that point I shall proceed no further with the description of the Waffen S.S.

I shall pass on now, therefore, to a description of the “S.S. Totenkopf Verbaende”, the Death Head Units, which is the fourth component to be mentioned.

The origin and purpose of the Totenkopf Verbaende were succinctly described by d’Alquen in his book, “The S.S.”, our Document 2284-PS, and I shall read from Page 10 of the English translation, paragraph 5, a passage that appears on Page 20 of the original, paragraph 3.

“The S.S. Death Head Units form one part of the barracked S.S They arose from volunteers of the General S.S. who were recruite for the guarding of concentration camps in 1933.

Their mission, apart from the indoctrination of the armed political soldier, is to guard enemies of the States who are held in concentration camps.

The S.S. Death Head Units enforce on their members 12 years’ service. They are composed mainly of men who have already fulfilled their duty to serve in the Wehrmacht. This time of service is counted in full.”

Since the Death Head Units – like the “S.S. Verfuegungstruppe” – were composed of well-trained professional soldiers, they were also a valuable nucleus for the Waffen S.S. The secret Hitler order of 17th August, 1938, Document 647-PS, which has already been introduced in evidence, provided for the tasks of the “S.S. Totenkopf Verbaende” in the event of mobilisation. The Toterikopf Verbaende were to be relieved from the duty of guarding concentration camps and transferred as a skeleton corps to the “S.S. Verfuegungstruppe”. I quote from that order, a passage found on Page 5 of the translation, paragraph 4, Page 9 of the original:

“5. Regulations in case of Mobilisation:-

The S.S. Totenkopf Verbaende form the skeleton corps for the reinforcement of the S.S. Verfuegungstruppe (police reinforcement) and will be replaced in the guarding of the concentration camps by members of the General S.S. who are over 45 years of age and have had military training.”

If I may point out to the Court, the purpose in offering that bit of evidence is to show that the foundation was laid for the “Allgemeine S.S.”, the General S.S., to take over the duties of guarding concentration camps after the war had started. The Totenkopf Verbaende were originally created for that purpose. When the war came they went into the Waffen S.S. and their duties were taken over by members of the General S.S.

The final component, which was specifically referred to in the Indictment, is the S.S. Police Regiments. I shall very shortly turn to the steps by which the S.S. assumed control over the entire Reich Police. Out of the police, special militarised forces were formed, originally known as S.S. Police Battalions and later expanded to S.S. Police Regiments.

I quote from Himmler’s Posen speech, our Document 1919-PS, Page 3 of the translation, next to the last paragraph, Page 58 of the original.

“Now to deal briefly with the tasks of the regular uniformed police and the Sipo – they still cover the same field. I can see that great things have been achieved. We have formed roughly 30 police regiments from police reservists and former members of the police – police officials, as they used to be called. The average age in our police battalions is not lower than that of the security battalions of the Armed Forces. Their achievements are beyond all praise. In addition, we have formed Police Rifle Regiments by merging the police battalions of the ‘savage peoples’. Thus, we did not leave these police battalions untouched but blended them in the ratio of about 1 to 3.”

The results of this blend of militarised S.S. police and “savage peoples” will be seen in the evidence which I shall later introduce, relating to extermination actions, conducted by them in the Eastern territories – exterminations which were so eminently successful and so ruthlessly conducted that even Himmler could find no words adequate for their eulogy.

THE PRESIDENT: We will adjourn now for 10 minutes.

(A recess was taken.)

MAJOR FARR: Each of the various components which I have described played its part in carrying out one or more functions of the S.S. The personnel composing each differed. Some were part-time volunteers ; others, professionals, enlisted for different periods of time. But every branch, every department, every member, was an integral part of the whole organisa tion. Each performed his assigned role in the manifold tasks for which the organisation had been created. No better witness to this fact could be called upon than the Reichsfuehrer S.S., whose every effort was to insure the complete unity of the organisation. I quote his words, taken from his Posen speech, our Document igig-PS, Exhibit USA 170- 1 read from Page 104 of the original, fourth line from the top of the page, from the English translation, Page 8.

“It would be an evil day if the main offices, in performing. their tasks with the best, but mistaken intentions, made themselves independent by each having a downward chain of command. I really think that the day of my overthrow would be the end of the S.S. It must be, that this S.S. organisation with all its branches-the General S.S. which is the common basis of all of them, the Waffen S.S., the regular uniformed police, the Sipo, with the whole economic administration, schooling, ideological training, the whole question of kindred, is, even under the tenth Reichsfuehrer S.S., one block, one body, one Organisation.”

And continuing, about the middle of Page 8 of the translation, and at the bottom of Page 104 of the original speech:

“The regular uniformed police and Sipo, General S.S. and Waffen S.S. must now gradually be amalgamated too, just as this is and must be the case within the Waffen S.S. This applies to matters concerning filling of posts, recruiting, schooling, economic organisation, and medical services. I am always doing something towards this end, a bond is constantly being drawn around these actions of the whole to cause them to grow together. Alas, if these bonds should ever be loosened-then everything-you may be sure of this-would sink back into its old insignificance within one generation, and in a short space of time.”

I now turn to the underlying philosophy of the S.S., the principles by which its members were selected and the obligations imposed upon them. To understand this organisation, the theories upon which it was based must be kept clearly in mind. They furnish the key to all its activities. It is necessary, therefore, to consider them in some detail.

The fundamental principle of selection was what Himmler called that of Blood and Elite. The S.S. was to be the living embodiment of the Nazi doctrine of the superiority of Nordic blood-the carrying into effect of the Nazi conception of a master race. To put it in Himmler’s own words, the S.S. was to be a ” National Socialist Soldier Order of Nordic Men “. In describing to the Wehrmacht the reasons behind his emphasis on’racial standards of selection and the manner in which they were carried out he said-and I quote from our Document 1992-A-PS, Page I of the translation, last paragraph, Page 138, paragraph I of the original:

“Accordingly, only good blood, blood which history has proved to be leading and creative and the foundation of every State and of all military activities, only Nordic blood, can be considered. I said to myself that, should I succeed in selecting from the German people for this organisation as many people as possible a majority of whom possess this desired blood, in teaching them military discipline and, in time, the understanding of the value of blood and the entire ideology which results from it, then it will be possible actually to create such an elite organisation as would successfully hold its own in all cases of emergency.”

Further on, on Page 5 of the translation-I beg your pardon, on Page 4 of the translation, first line, Page 140 of the original, bottom paragraph, he says, referring to the method by which applicants were selected:

“They are very thoroughly examined and checked. Of ioo men we can use on the average 10 or 15, no more. We ask for the political record of his parents, brothers and sisters, the record of his ancestry as far back as 1750, and naturally the physical examination and his record from the Hitler Youth. Further, we ask for a eugenic record showing that no hereditary disease exists in his parents or in his family.”

THE PRESIDENT: (interposing) I do not seem to get the point of this. We have already been told that the S.S. was a Corps d’Elite, and all this is showing the details of the choice.

MAJOR FARR: That is correct; it is showing the details of the choice.

THE PRESIDENT: But that has nothing to do with its being a criminal organisation, has it ?

MAJOR FARR: I think it has, your Honour. I want to make again, if I may, two points. The very essence of this organisation was that of race. Its racial standards of selection had two purposes: One, to make it an organisation which would be an aristocracy not only for Germany, but which would be in a position to dominate all of Europe. For that purpose, not only were strict racial standards imposed for selection, but a great drive was made to perpetuate the S.S. stock, to build up a group of men who would be in a position to take over Europe when it was conquered.

There was nothing questionable about that aim. Himmler explicitly said time and time again: ” What we are after is to make ourselves the super-class which will be able to dominate Europe for centuries.” That was one of the fundamental purposes of the S.S., and it was a purpose which was not kept by Himmler to himself, but a purpose which was explained and publicly announced again and again.

THE PRESIDENT: You have npt yet shown us where it was announced, have you ?

MAJOR FARR: I have not, Sir, and I am coming to that very shortly, but I wanted first to show your Honour what the racial basis of selection was. That is one aspect of the racial selective process.

The second was this: The negative side of the racialism. Not only did Himmler intend to build up an elite which would be able to take over Europe, but he indoctrinated that elite with hatred for all ” inferior “-to use his words-races.

Now, I think unless it is clearly understood that that is the basis of the S.S., we cannot understand the organisation. I am quite prepared, if the Tribunal desires, not to go further into a discussionof the detail of the process of selection. I do think it important that I quote to the Tribunal the publicly announced basis for selection.

With the Tribunal’s permission then, I would like to quote one passage from the Organisation Book for the Nazi Party, which explains the racial basis on which the S.S. was founded. That is our Document 2640-PS, which has already been introduced in evidence as Exhibit USA 323- 1 quote from Page V7 of the German text and from Page i of the translation, fourth paragraph, entitled “Selection of Members.” And I quote this because this is not a hidden pronouncement. This is what the official Nazi Party publication said the S. S. was:

“Selection of Members.

For the fulfilment of these missions a homogeneous, firmly welded fighting force has been created bound by ideological oaths, whose fighters are selected out of the best Aryan humanity.

The conception of the value of the blood and soil serves as directive for the selection for the S.S. Every S.S. man must be deeply imbued with the sense and essence of the National Socialist Movement. He will be ideologically and physically trained so that he can be employed individually or in groups in the decisive battle for the National Socialist ideology.

Only the best and thoroughbred Germans are suited for commitment in this battle. Therefore it is necessary that an uninterrupted selection is maintained within the ranks of the S.S., first superficially, then more and more thoroughly.”

Now, I would like to proceed to quote a paragrapb on the same page, three paragraphs down, with respect to obedience. It appears on Page 418 of the original, second paragraph. It runs:

“Obedience is unconditionally demanded. It arises from the conviction that the National Socialist ideology must reign. He who possesses it and passionately supports it, submits himself voluntarily to the compulsion of obedience. Therefore, the S.S. man is prepared to carry out blindly every order which comes from the Fuehrer or is given by one of his superiors, even if it demands the greatest sacrifice of himself.”

There are stated the two fundamental principles of the S.S. (i) Racial selection; (2) Blind obedience.

Now, let me state what Himmler conceived that this organisation was to be used for. I quote from his address to the officers of the S.S. Leib standarte “Adolf Hitler” on the ” Day of Metz,” our Document 19i8-PS, Exhibit USA 304. I quote from Page 12 of the original document, the middle of the page; from the translation Page 3, last paragraph. I will begin the translation with the third sentence of that paragraph:

“The ultimate aim for these 11 years during which I have been the Reichsfuehrer S.S. has been invariably the same. To create an order of good blood which is able to serve Germany, which unfailingly and without sparing itself can be made use of because the greatest losses can do no harm to the vitality of this order, the vitality of these men, because they will always be replaced. To create an order which will spread the idea of Nordic blood so far that we will attract all Nordic blood in the world, take away the blood from our adversaries, absorb it so that never again, looking at it from the viewpoint of the grand policy, Nordic blood in great quantities and to an extent worth mentioning will fight against us. We must get it and the others cannot have it. We never gave up the ideas and the aim, conceived so many years ago. Everything we have done has taken us some distance further on the way. Everything we are going to do will lead us further on the way.”

Now, one further quotation from the same document, which shows very explicitly why there was the building up of this order of Nordic blood, appears on Page 3 of the translation, the same document from which I have just quoted, about the middle of the first paragraph. It appears on Page 11 of the original speech, about the middle of the page. That is the speech to the officers of the S.S. Leibstandarte “Adolf Hitler.”

“Please understand we would not be able to hold the great Germanic Reich which is about to take shape. I am convinced that we can hold it, but we have to prepare for that. If once we have not enough sons, those who come after us will have to become cowards. A nation which has an average of four sons per family can venture a war; if two of them die, two transmit the name. The leadership of a nation having one or two sons per family will have to be faint-hearted in any decision, on account of their own experience because they will have to tell themselves: We cannot afford it. Look at France, which is the best example. France had to accept from us a dictate.”

Domination of Europe through a Nazi elite required more, however, than a positive side of racialism.

THE TRIBUNAL (Mr. BIDDLE): Is that one of the crimes you allege, domination of Europe through an elite ?

MAJOR FARR: One of the crimes alleged is a ‘conspiracy to dominate Europe, preparation for aggressive war, leading to the ultimate colonisation of Europe for the benefit of the conspirators. One of the instruments, we submit, used for carrying out that policy, was the S.S. The conspirators began, at the very beginning, the creation of the S.S., to build it up so that it would be the elite through which Germany would be able to dominate and rule the conquered territories.

We think that this conception of the S.S. has played a vital part in the conspiracy. It has bearing on the whole programme of the conspirators. Now, this certainly, in itself-

THE PRESIDENT: Yes, but, Major Farr, what you have to show is not the criminality of the people who used the weapon; the criminality of the people who composed the weapon.

MAJOR FARR: I think I have to show two things, certainly the criminality of the persons who composed the weapons, but it seems to me I must also show that that weapon played a part in the conspiracy because the Indictment alleges-

THE PRESIDENT: I should have thought you had shown that over and over again, that the S.S. were a part of the weapon. If there was a criminal conspiracy, then the S.S. were one of the weapons which were used by the conspirators. But what you have got to show in this part of the case is that the persons who formed that weapon were criminal and knew of the criminal objects of the S.S.

MAJOR FARR: I quite agree I have to show that. I suppose I have to show, before showing that the persons involved knew of the criminal aims of the Organisation, what those criminal aims were. I was simply attempting to show the Tribunal that one of those aims which I submit as criminal was a plan to dominate Europe, and that the S.S. was one of the means by which that was to be done.

Now, this is just one aspect of the S.S. criminality. I am quite ready not to proceed any further with the point if the Court already has the point, and thinks that the evidence of that aspect of its criminality is sufficient. I certainly do not want to labour the point too hard.

I will now proceed further with the point as to the building up of the S.S. as a racial elite to take over ; but I do think one other thing is important, and that is the negative side of that racialism: the hatred of other races. Himmler made some very striking points along that line as to what the S.S. was to be in relation to it. I quote from his Posen speech, that is, our document 1919-PS. The passage in question appears on Page 23 of the original speech, middle of the page, and will be found on Page I of the English translation, third paragraph.

I quote:

“One basic principle must be the absolute rule for the S.S. man. We must be honest, decent, loyal, and comradely to members of our own blood and to nobody else. What happens to a Russian, to a Czech, does not interest me in the slightest.”

The next few sentences from that same paragraph have already been read into evidence, and I shall not repeat them. But I do want to quote, in the same paragraph, the conclusion that Himmler draws from what he just said. This sentence is about seven lines from the bottom of the paragraph, beginning:-

“That is what I want to instil into this S.S. and what I believe I have instilled in them as- one of the most sacred laws of the future.”

Now these principles-that is, the concepfion of being an elite which was to take over Europe, and the conception of hatred toward inferior races, which was instilled in the S.S.-these were principles which were publicly reiterated over and over again so that the newest recruit was thoroughly steeped in them.

I quote from Himmler’s Kharkov speech, which appears in the same document 1919-PS.

THE TRIBUNAL (Mr. BIDDLE): Can you not just give us the meaning of the speech without quoting from it; can you just refer to it ? I

MAJOR FARR: I will be very glad to do that, if the Court will take judicial notice of it. I will refer you to the passage I have in mind. The passage in question appears on Page 14 of the translation, about fifteen lines from the bottom of the page; it appears on Page 17 of the original, at about the middle of the page.

In that passage, after having talked at great length about the racial struggle, Himmler tells his commanding officers-and be is’making this speech to the commanding officers of three divisions of the Waffen S.S.-he tells his officers that the thing which he wants so thoroughly instilled into every recruit in the Organisation, so that he becomes saturated with it, is the necessity of the S.S. standing firm and carrying on the racial struggle without mercy.

On the same point one further quotation-if the Tribunal will bear with me-and I think this is important because this, again, is a public quotation, found in the Organisation Book of the Party. That is our document 2640-PS. It is a very short passage, appearing on Page V8 of the original, and Page i of the English translation, the third paragraph from the end of the page in the translation:

“He openly and unrelentingly fights the most dangerous enemies of the State: Jews, Freemasons, Jesuits, and political clergymen.”

Now these were the fundamental principles of the S.S.: racial superiority and blind obedience. A necessary corollary of these two principles was ruthlessness. The evidence that we will introduce on these activities will show how successfully the S.S. learned the lesson it was taught.

The S.S. had to, and did, develop a reputation for terror which was Farefully cultivated. Himmler himself publicly attested it as early as 1936 in his pamphlet, ” The S.S. as an Anti-Bolshevist Fighting Organisation ” our document 185I-PS, which has already been introduced into evidence as exhibit USA 44o. I quote two sentences which appear at page 29 Of the original pamphlet, and on page 4 of the translation, the first two sentences:

“I know that there are some people in Germany who become sick when they see these black coats. We understand the reason for this and do not expect that we shall be loved by too many.”

The role which the S.S. was required to play demanded that it remain constantly the essence of Nazism and that its elite quality should never be diluted.

As evidence that even in 1943 the S.S. standards were still being main tained, I offer in evidence a letter written to the defendant Kaltenbrunner by Himmler. This letter is our Document 2768-PS. It is a letter from the Reiclisfuehrer S.S., written at his field command post and bearing the date 24th April, 1943, 1 offer it as Exhibit USA 447. 1 quote from the first paragraph of that letter:

“Referring again to the matter which we discussed some time agothat is, the admission of Sipo officials into the S.S.-I wish to clarify again: I want an admission only if the following conditions are fulfilled:

I. If the man applies freely and voluntarily.

2. If, by applying strict and peace-time standards, the applicant fits racially and ideologically into the S.S., guarantees according to the number of his children a really healthy S.S. stock, and is neither in, degenerate, nor worthless.”

Then, continuing with the third paragraph:

“I beg not only that you will act accordingly in the future, but especially also that numerous admissions into the ranks of the S.S. in the past be re-examined and revised according to these instructions.”

Now I have appended this, to indicate to the Tribunal the normal manner in which a man became a member of the S.S. This is discussed by Himmler in our Document 1992-A-PS, at Page 142 of the original, and Page 5 Of the translation. If the Court thinks that it can take judicial notice of that passage, I shall not trouble to read it. What it does is to describe how a young man comes into the S.S. normally, at the age of 18, serves an appren ticeship and receives his instructions in S.S. ideology, takes the S.S. oath, receives the S.S dagger, and how long he remains in the General S.S. I will not trouble to read that paragraph, since I assume that the Court will take judicial notice of it.

I do think it may be worth quoting the very brief oath which the S.S. man takes. That oath is quoted in the Waffen S.S. recruiting pamphlet, entitled, “The S.S. Calls You,” our Document 3429-PS, which I offer in evidence as Exhibit USA 446. The oath appears on Page 18 of that pamphlet, and on Page 2 of the translation, in the middle of the page. I quote the oath

The Oath of the S.S. Man:

“I swear to you, Adolf Hitler, as Fuehrer and Reichschancellor, loyalty and bravery, I vow to you, and to those you have named to command me, obedience unto death, so help me God.”

I turn now to a consideration of the activities of the S.S., the manner in which it carried out the purposes of the conspirators and performed its function of guarding the internal security of the Nazi regime. The proof of the elite Nazi quality and thorough reliability of the S.S.-the test by which it won its spurs-occurred on the 30th of June, 1934, when it participated in the purge of the S.A. and other opponents or potential opponents of the Nazi regime. That was the first real occasion for the use of this specialised Organisation, which could operate with the blessing of the Nazi State, but outside the law.

I offer in evidence an affidavit by the defendant Wilhelm Frick, signed and sworn to herein Nuremberg on the i 9th of November, 1945 – It is our Document 2950-PS- I offer it as Exhibit USA 448. 1 shall quote a portion of that affidavit, beginning about the middle of the first paragraph of the affidavit, the tenth line in the original.

“Many people were killed – I do not know how many – who actually did not have anything to do with the ‘putsch.’ People who just were not liked very well, as for instance, Schleicher, the former Reich Chancellor, were killed. Schleicher’s wife was also killed, as was Gregor Strasser, who had been the Reich Organisation Leader and second man in the Party after Hitler. Strasser, at the time he was murdered, was not active in political affairs any more. However, he had separated himself from the Fuehrer in November or December of 1932. The S.S. was used by Himmler for the execution of these orders to suppress the ‘putsch’.”

It was in recognition of its services in this respect that the S.S. was raised to the status of a component of the Party equal in rank to the S.A., and other similar ranking. I ask the Court to take judicial notice of a passage which appears on Page i of the V614scher Beobachter of z6th July, 1934- It is our Document 1857-PS, Exhibit USA 412. 1 shall read the translation of that passage, which is very brief:

“The Reich Press Office announces the following Order of the Fuehrer. In consideration of the greatly meritorious service of the S.S., especially in connection with the events Of 3oth June, 1934, 1 raise it to the standing of an independent Organisation within the N.S.D.A.P. The Reiclisfuehrer S.S., like the Chief of Staff, is, therefore, directly subordinate to the highest S.A. leader.”

By its action on 30th June, the S.S. proved itself. It was, therefore, the type of Organisation which the conspirators wanted for the first necessary step in their programme, the acquisition of control over the police, because one of the first steps essential to the security of any regime is control of the police. The aim of the conspirators was to fuse the S.S. and the police, to merge them into a single, unified repressive force.

I turn now to the consideration of the development whereby the S.S. and the police became intermingled. Shortly after the seizure of power the conspirators began to develop, as a part of the State machinery, secret political police forces, originating in Prussia in the Gestapo established by decree of the defendant Goering in 1933, and this development will be dealt with in the case against the’Gestapo. By 1934, the Reichsfuehrer S.S. had become the chief of these secret political police forces in all the States of Germany except Prussia, and deputy chief of the Prussian Gestapo. In that capacity he infiltrated these forces with members of the S.S. until a virtual identity of membership of the S.S. and the Gestapo was achieved.

On 17th June, 1936, by the Decree on the Establishment of a Chief of the German Police, published in the Reichsgesetzblatt for 1936, Part 1, Pages 487 and 488, our Document 2073-PS, of which I assume the Court will take judicial notice, the new post of Chief of the German Police was created in the Ministry of the Interior. Under the terms of the decree Himmler was appointed to this post with the title of “Reiclisfuehrer S. S., and Chief of the German Police in the Ministry of the Interior.”

The combination of these two positions, that of leader of the S.S., and head of all the police forces in the Reich, was no accident, but was intended to establish a permanent relation between the two bodies, and not a mere 44 transitory fusion of personnel.” The significance of this combination of these two positions was referred to by Hitler in his secret order of 17th August, 1938, on the organisation and mobilisation of the S.S., our Document 647-PS, which I introduce in evidence as Exhibit USA 443, from which I will now quote just the preamble, which will be found on the first page of our Document 647-PS, and at the beginning of the original order. I quote:

“By means of the nomination of the Reichsfuehrer S.S. and Chief of the German Police in the Ministry of the Interior on June 17th, 1936, (Reichsgesetzblatt I, Page 487), 1 have created the basis for the unification and reorganisation of the German Police. With this step, the Schutzstaffeln of the N.S.D.A.P., which have been under the Reichs fuehrer S.S. and Chief of the German Police up to now, have entered into close connection with the duties of the German Police.”

Upon his appointment, Himmler immediately proceeded to reorganise the entire police force, designating two separate branches. (i) The regular uniformed police force (Ordnungspolizei or Orpo as they were called by their abbreviated title) ; and (2) the so-called Security Police, or as they became to be known by their abbreviated title Sipo. The Security Police was composed of all the Criminal Police in the Reich and all the Gestapo. This reorganisation was achieved by the decree assigning functions to the Office of the Chief of the German Police, published in the Reichsministerialblatt for 1936, Pages 946-948, our Document 155I-PS- Of that decree I assume the Court will take judicial notice.

To be head of the Sipo, that is, of the Criminal Police and the Gestapo, Himmler appointed Reinhard Heydrich, who was at that time the Chief of the S.D., the S.S. Intelligence Agency to which I have already referred. Thus, through Himmler’s dual capacity as Reichsfuehrer S.S. and as Chief of the German Police, and through Heydrich’s dual capacity as head of the S.D. and of the Security Police, a unified personal command of the S.S. and Security Police Forces was achieved.

.But further steps towards unification were taken. In 1939 the Security Police and the S.D., which up to that time had been only an agency of the S.S., were both combined in a single department: the Reich Security Main Office, commonly referred to as R.S.H.A. An important point to be observed is this: This newly created department, R.S.H.A., was not a mere department of the Government. It was a dual thing. It was simultaneously an agency of the Government, organisationally placed in the Ministry of the Interior, and, at the same time, one of the principal departments of the S.S., organisationally placed in the Supreme Command of the S.S. This division in the S.S. is shown by the chart before you, R.S.H.A. being indicated by the sixth block from the left of the chart. But it was not merely the Gestapo and Criminal Police which came under the sway of the S.S. The regular uniformed police as well were affected. Like the R.S.H.A., the department of the Regular Police, the Ordnungspolizei, was also not merely a department in the Ministry of the Interior, but also simultaneously in the Supreme Command of the S.S. Its position in the S.S. is indicated by the seventh block on the chart, on the left.

Now this unity of command between S.S. and Police was not a mere matter of the highest headquarters. It extended down to the operating level. The Court will observe from the chart that the Higher S.S. and Police Leader in each region, who was directly subordinate to Himmler, had under his command both the Security Police, Sipo, and the regular uniformed police, Ordnungspolizei; and also that these forces, Sipo and Orpo, were not only under the command of the Higher S.S. and the Police Leader, but as indicated by the blue line, were also under the command of the R.S.H.A., and the Department of the Ordnungspolizei and the S.S. Thus, you have organisationally, a unity of command over the S.S. and the Police. This organisation was not the only way by which unity was achieved. Unity of personnel was also achieved. Vacancies occurring in the police forces were filled by S.S. members. Police officials who were in the force were able to join the S.S., and schools were operated by the S.S. for the police, as well as for the S.S. officials.

These measures are described in Himmler’s article ” Organisation and Obligations of the S.S. and the Police,” our Document 1992-A-PS. They are also described in an authoritative book on the Police, entitled, ” The German Police,” the book published in 1940, written by Dr. Werner Best, Ministerial Director in the Ministry of the Interior, and a department head in the Security Police. It bears on its fly-leaf the imprimatur of the Nazi Party, and the book is listed in the official list of National Socialist bibliography. Chapter 7 from that book is our Document 1852-PS. I offer this book in evidence as Exhibit USA 449.

Through this unity of organisation and personnel, the S.S. and the Police became identified in structure and in activity. The resulting situation was described in Best’s book, which I have just offered in evidence, our Document 1852-PS, as follows. I quote from Page 7 of that document, paragraph 5 ; from the original book, Page 95, paragraph 3:

“Thus the S.S. and the Police form one unit, both in their structure and in their activity, although their individual organisations have not lost their true individuality and their position in the larger units of the Party and State administration which are concerned with other points of view.”

Through the Police, the S.S. was in a position to carry out a large part of the functions assigned to it. The working partnership between the Gestapo, the Criminal Police and the S.D. under the direction of the Reichsfuehrer S.S. resulted in the end in repressive and unrestrained police activity. That will be dealt with in the case against the Gestapo. In considering that evidence, the Tribunal will bear in mind that the Police activities there shown were one aspect of S.S. functions, one part of the whole criminal S.S. scheme. I shall not, therefore, consider here evidence relating strictly to the police functions of the S.S.

Control over the police was not enough. Potential sources of opposition could be tracked down by.the S.D. Suspects could be seized by the Criminal Police and the Gestapo, but these means alone would not assure the complete suppression of all opponents and potential opponents of the regime. For this purpose, concentration camps were invented. The evidence already presented to the Tribunal has shown what the concentration camp system involved, and the final result of that system was graphically illustrated in the moving pictures shown about io, days ago. The responsibility of the S.S. in that system is a topic to which I now turn.

The first requirement for the camps was guard and administrative personnel. Part-time volunteer members of the Allgerneine S.S. were originally utilised as guards; but part-time volunteers could not adequately serve the needs of the extensive, long-range programme that was planned. So beginning in 1933 full-time professional guards units, the Death Head Units which I have already described, were organised. During the war, members of the General S.S. resumed the function of guarding camps, which they had initially undertaken when the camps were created. The Tribunal will recall the provisions of the Hitler order which I read a few moments ago, directing the replacement of Death Head Units by General S.S. members in the event of mobilisation. It is unnecessary to repeat the evidence of wholesale brutality, torture and murder committed by S.S. guards. They were not the sporadic crimes committed by irresponsible individuals, but a part of a definite and calculated policy, a policy necessarily resulting from S.S. philosophy, a policy which was carried out from the initial creation of the camps.

Himmler bluntly stated the S.S. view as to the inmates of the camps in his article, ” Organisation and Obligations of the S.S. and the Police,” Exhibit USA 439, our Document 1992-A-PS. I quote from Page 7 of the translation, last paragraph; from Page 148 of the original, third paragraph.

THE PRESIDENT: Did you say 439?

MAJOR FARR: It was Exhibit 439- It is our Document 1992-A-PS. I quote from Page 7 of the translation, last paragraph:

“It would be extremely instructive for everyone-some members of the Wehrmacht had already been able to do so-to inspect such a concentration camp. Once they have seen it, they are convinced of the fact that no one has been sent there unjustly ; that it is the offal of criminals and freaks. No better demonstration of the laws of in heritance and race, as set forth by Doctor Guett, exists than such a concentration camp. There you can find people with hydrocephalus, people who are cross-eyed, deformed, half-Jewish, and a number of racially inferior products. All that is assembled there. Of course, we distinguish between those inmates who are only there for a few months for the purpose of education, and those who are to stay for a very long time. On the whole, education consists of discipline, never of any kind of instruction on an ideological basis, for the prisoners have, for the most part, slave-like souls; and only very few people of real character can be found there.”

Then, omitting the next two sentences, he continues with this striking remark:

“The discipline thus means order. The order begins with these people living in clean barracks. Such a thing can really only be accomplished by us Germans, hardly another nation would be as human as we are. The laundry is frequently changed. The people are taught to wash themselves twice daily, and to use a toothbrush, a thing with which most of them have been unfamiliar.”

Having heard the evidence and seen the pictures as to conditions in concentration camps, this Tribunal can appreciate how grim and savage that callous jest was. He made no such pretence in his speech to his own Grupperifuehrers at Posen, our Document 1919-PS, Exhibit USA 170. I quote from Page 43 of the original, last paragraph; from Page 2 of the translation, the first full paragraph. That is 1919-PS.

“I do not believe the Communists could attempt any action, for their leading elements, like most criminals, are in our concentration camps. And here I must say this: that we shall bp able to see after the war what a blessing it was for Germany that, in spite of all the silly talk about humanitarianism, we imprisoned all this criminal sub stratum of the German people in concentration camps. I will answer for that.”

But he is not here to answer.

Certainly there was no ” silly humanitarianism ” in the manner in which S.S. men performed their tasks. Just as an illustration, I should like to examine their conduct, not in 1944 or 1945, but in 1933- 1 have four reports, relating to the deaths of four different inmates of the concentration camp Dachau between 16th and 27th May, 1933. Each report is signed by the Public Prosecutor of the District Court in Munich and is addressed to the Public Prosecutor of the Supreme Court in Munich. These four reports show that during that two-week period in 1933, at the time when the concentration camps had barely started, S.S. men had murdered – a different guard each time – an inmate of the camp.

Now, I do not want to take the time of the Tribunal to read that evidence if it feels that it is a minor point. The significance of it is this: It is just an illustration of the sort of thing that happened in the concentration camps at the earliest possible date, in 1933. I am prepared to offer those four reports in evidence and to quote from them, if the Tribunal thinks that the point is not too insignificant.

THE PRESIDENT: Where are they?

MAJOR FARR: I have them here. I will offer them in evidence. The first is our Document 641-PS. It is a report dated 1st June, 1933, and relates to the death of Dr. Alfred Strauss, a prisoner in protective custody, in Dachau. I offer it in evidence as Exhibit USA 450. I shall read a few paragraphs from that report, beginning with paragraph one:

“On 24th May, 1933, the 30-year-old, single, attomey-at-law, Dr. Alfred Strauss from Munich, who was in the concentration camp Dachau as a prisoner under protective custody, was killed by two pistol shots from S.S. man Johann Kantschuster who escorted him on a walk prescribed to him by the camp doctor, outside the fence part of the camp.

Kantschuster gives the following report: ‘He himself had to urinate; Strauss proceeded on his way. Suddenly Strauss broke away towards the bushes located at a distance of about 6 m. from the line. When he (Kantschuster) noticed it, he fired two shots at the fugitive from a distance of about 8 m.; whereupon Strauss collapsed dead.’

On the same day, 24th May, 1933, a judicial inspection of the locality took place. The corpse of Strauss was lying at the edge of the wood. Leather slippers were on his feet. He wore a sock on one foot, while the other foot was bare, obviously because of an injury to it. Subsequently an autopsy was performed. Two bullets had entered the back of the head. Besides, the body showed several black and blue spots and also open wounds.”

Passing now to the last paragraph of that report:

“I have charged Kantschuster to-day with murder and have made application for the opening and execution of a judicial preliminary investigation as well as for the issuance of a warrant of arrest against him.”

That is the first of the four reports. The significance is that you have four murders one after the other, committed within a short space of time, and in each instance, an official report by the camp commander or the guard as to the cause of death, which was completely disproved by the facts.

The second report, a report dated 1st June, 1933, relates to the death of Leonhard Hausmann, another prisoner in Dachau. It is our Document 642-PS, and I offer it in evidence as Exhibit USA 451.

THE PRESIDENT: I do not think you need read the details.

MAJOR FARR: I will offer it without reading it.

The third report which I shall offer is dated 22nd May, 1933. It relates to the death of Louis Schloss, an inmate of Dachau, and is our Document 644-PS. I offer it in evidence as Exhibit USA 452.

The fourth document, our Document 645-PS, dated ist June, 1933, relates to the death of Sebastian Nefzger, ‘another Dachau prisoner. I offer this in evidence as Exhibit USA 453.

These four murders, committed within the short space of two weeks in the spring of 1933, each by a different S.S. guard, are merely examples of S.S. activities in the camps at that very early date. Many similar examples from that period and later periods could be produced.

Indeed, that sort of thing was officially encouraged. I call the Tribunal’s attention to the Disciplinary Regulation for the Dachau Concentration Camp, our Document 778-PS, which has already been introduced in evidence as Exhibit USA 247- 1 want to read the fourth paragraph of the introduction to those rules, a passage which was not read when the document was originally introduced. The fourth paragraph on the first page of the translation and of the original is as follows:

“Tolerance means weakness. In the light of this conception, punishment will be mercilessly handed out whenever the interests of the Fatherland warrant it. The fellow countryman who is decent but misled will never be affected by these regulations. But let it be a warning to the agitating politicians and intellectuals, regardless of which kind: Be on guard not to be caught, for otherwise it will be your neck and you will be hoist with your own petard.”

Those regulations were issued in 1933 by S.S.-Fuehrer Eich, who, it is to be noted, was the Commandant of the S.S.-Totenkopfverbinde.

Furnishing guard and administrative personnel was not the only function of the S.S. with relation to the camps. The entire internal management of the camps, including the use of prisoners, their housing, clothing, sanitary conditions, the determination of their very right to live and the disposal of their remains, was controlled by the S.S. Such management was first vested in the Leader of the S.S. Death Head Units who had the title of Inspector of the Concentration Camps. This official was originally in the S.S. Hauptamt-represented on the chart by the second box from the left. During the course of the war – in March 1942 – Control of concentration camps was transferred to another of the departments of the S.S. Supreme Command – the S.S. Economic and Administration Department – commonly known as W.V.H.A. That department is indicated on the chart by the third box from the left. The Court will note under the top box the break down into ” Concentration Camps ” which in turn is broken down into ” Prison, Labour, Medical and Administration.”

That change was announced in a letter to Himmler dated 3oth April, 1942, from the Chief of W.V.H.A. The letter is our Document R-129 and it has already been received in evidence as Exhibit USA 217. 1 shall not quote from that letter now.

This shift of control to WN.H.A., the economic department of the S.S., coincided with a change in the basic purposes of the concentration camps. Political and security reasons, which previously had been the ground for confinement, were abandoned, and the camps were frankly made to serve the slave-labour programme. The Tribunal will recall the evidence relating to that programme which was presented last week by Mr. Dodd. I shall not deal at any length with the matter again, except to summarise the principal facts bearing on S.S. responsibility which were demonstrated by that evidence.

To satisfy the increased demands for manpower it was not enough to work the inmates of the camp harder. More inmates had to be obtained. The S.S., through its police arm, was prepared to satisfy this demand, as through the W.N.H.A. it was prepared to work those who were already in the camp.

THE PRESIDENT: Have you got any figures you can give the Tribunal as to the total numbers in the S.S. and the total numbers who were employed on concentration camps ? If you gave us the total number of the S.S. and the total number employed in concentration camps, we should see what the proportion was.

MAJOR FARR: I think I can only give you the following figures. I earlier quoted some figures from d’Alquen in his book published in 1939, in which he said that the total strength of the General S.S. was about 240,000. That is the General S.S., which was not at that time engaged in the guarding of concentration camps. The Totenkopfverbiinde, the Death Head Units, at that time, consisted of somethree or four regiments at the most. They were the guards; so that of the personnel who were employed in actual guard duty there were, in 1939, about three or four regiments.

The Court will recall that after the war had started, the TotenkopfverbInde were no longer employed in that duty and that the members of the General S.S. took it up. How many were employed is something that is difficult to estimate. The concentration camp programme was constantly expanding and, of course, as more camps were added more personnel was needed. I cannot give the Tribunal the figures of the number of persons involved in guarding the camps, but one of the matters I think significant is this: we have not only guards, we have administrative personnel, we have the whole of the WN.H.A. which, as I want to show by evidence, had complete control of the management of the concentration camps. The members of the staff office, WN.H.A., were derived from the General S.S. ; so you have on the one hand the guard personnel, Death Head Units, up to 1939, and then you have after 1939 more guards from the Allgemeine S.S. You have, after 1939, more guards from the General S.S. and also administrative personnel from W.V.H.A.

I have no figures showing how many persons were engaged. in one or another phase of the concentration camp activities. You have, of course, the S.D. and Security Police involved in it, in so far as they went out and seized victims. You have W.V.H.A., the entire administrative personnel of that section involved in it, in so far as they handled, administrative matters.

Some conception of the number of persons who must have been engaged in the activity may be gained from noting the number of persons involved in a camp. I have a document, a report by W.V.H.A., in August 1944, which reports the number of prisoners who were then on hand in the camps and the recent arrivals who were expected. That document is our Document I I 66-PS, which I will now offer in evidence as Exhibit USA 458.

THE PRESIDENT: I do not think we had better go into that to-night. What will you be dealing with to-morrow ?

MAJOR FARR: To-morrow, Sir, I intend to offer evidence showing how. W.V.H.A. and other S.S. personnel were involved in the control of every phase of the concentration camp programme. That is the first thing. The second thing is to point out the role that the S.S. played in the persecution of the Jews and their extermination, not with a view to repeating the substantive evidence to show that such acts took place, but to show how many components, how many parts of the organisation were involved in that programme.

Then I shall consider the role of the S.S. with respect to Preparations for Aggressive War and the Crimes Against Peace-a relatively brief dis cussion-and then pass on to the role that the S.S. played in War Crimes and Crimes Against Humanity, set out in Counts 3 and 4 of the Indictment, and finally, the role of the S.S. in the colonisation programme.

THE PRESIDENT: Colonisation ?

MAJOR FARR: That may be an unfortunate word. Perhaps I should have said Germanisation programme, a programme of resettlement, evacuation, colonisation, and exploitation of the conquered territories.

Those, I think, are the four main functions of the S.S. which remain to be considered, and I shall endeavour not to go again into substantive crimes which have already been shown to the Tribunal, but to try to show how almost every department-in fact, every department of the S.S. and every component-was involved in one or more, and mostly more, of these crimes.

THE PRESIDENT: The Tribunal hopes that you will be able to confine yourself to the reading of evidence which is not cumulative.

MAJOR FARR: I have that in mind and I do not intend to do anything more than to show the figures and components of the S.S. which were involved in various programmes.

THE PRESIDENT: Very well.

(The Tribunal adjourned until 1000 hours on 20th December, 1945)

 

 

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