Twenty-First Day: Monday, 17th December, 1945
[Page 13] [Page 14]
On the threshold of presenting the proof establishing the
criminality of the Leadership Corps of the Nazi Party it is
pertinent to restate the prosecution's theory of this case.
It is this. The Nazi Party was the central core of the
Common Plan or Conspiracy alleged in Count 1 of the
Indictment, a conspiracy which contemplated and embraced the
commission of Crimes against the Peace, War Crimes and
Crimes against Humanity as defined and denounced by the
Charter.
The Leadership Corps, upon the evidence, was responsible for
planning, directing and supervising the criminal measures
carried into execution by the Nazi Party in furtherance of
the conspiracy. More than this, as will be shown, the
members of the Leadership Corps themselves actively
participated in the commission of illegal measures in aid of
the conspiracy. In the light of the evidence to be offered
this Tribunal, the Leadership Corps may be fairly described
as the brain, the backbone, and the directive arms of the
Nazi Party. Its responsibilities are more massive and
comprehensive than those of the army of followers it led and
directed in the assault against the peace-loving peoples of
the world. Accordingly, upon the record made in this case
and now to be enlarged upon, the prosecution requests this
Tribunal to declare that the Leadership Corps of the Nazi
Party is a criminal group or organisation in accordance with
Article 9 of the Charter.
At this time I should like to submit to the Tribunal the
document book supporting the brief as Exhibit USA V.
If your Honour pleases -- diverting from the manuscript --
during the recess there was placed upon your bench the
document book, which has each document marked by tab and
each quoted portion embraced by red pencil marks for the
assistance of your Honours. In addition, we have handed up
two documents that have already been introduced in evidence:
an enlarged copy of this chart, more detailed, which your
Honours have before you, and another chart, in photostatic
form, with reference to the Leadership Corps; and both of
those will be identified later.
I now proceed to present the proof relating to the
composition, the functions, and the responsibilities and
powers of the Leadership Corps of the Nazi Party. First,
what was the Leadership Corps ---
DR. ROBERT SERVATIUS (Counsel for the Leadership Corps of
the N.S.D.A.P.): After the last meeting I received a
statement by Mr. Justice Jackson in which were proposals
about the taking of evidence and the time for the discussion
of certain questions which might arise. I cannot understand
the scope of these proposals, and must therefore ask that I
may at some time speak about these points again, if it is
necessary.
THE PRESIDENT: Of course, counsel will have the opportunity
of presenting a full argument in answer to the argument
presented on behalf of the prosecution.
What I understood from Mr. Justice Jackson on Friday was
that he proposed that the evidence on the question of
criminal organisations should be presented first, and the
argument presented afterwards.
Counsel for the organisations will, as I stated this
morning, have the opportunity of calling evidence in answer
to the evidence of the prosecution,
[Page 15]
COLONEL STOREY: First, what was the Leadership Corps of the
Nazi Party? What persons made up its membership? What was
its size and scope?
In considering the composition and organisational structure
of the Leadership Corps it will be convenient for the
Tribunal to refer to Document 2903-PS, which is this exhibit
on the wall and which was introduced by Mr. Albrecht at the
opening of the Trial. And, supplementing the chart on the
wall, I now offer in evidence Document 2833-PS, Exhibit USA
22, which is a chart of the Leadership Corps of the Nazi
Party, appearing at Page 9 of a magazine published by the
Chief Education Office of the Nazi Party, entitled 'The Face
of the Party.' It is this little photostatic copy that you
have.' Later on we expect to put the big one on the wall.
These charts and the evidence to follow show that the
Leadership Corps constituted the sum total of the officials
of the Nazi Party. It included the "Fuehrer" at the top; the
"Reichsleiter," on the horizontal line; the Reich office
holders, immediately below; the five categories of leaders
who were area commanders, called the "Hoheitstraeger" or
"bearers of sovereignty." They are in the red-lettered or
red-lined boxes at the bottom. They range all the way from
the 40 odd Gauleiter in charge of large districts, down
through the intermediate political leaders, the
"Kreisleiter," the "Ortsgruppenleiter," the "Zellenleiter",
and finally, to the "Blockleiter", who were charged with
looking after 40 to 60 households, and, what may be best
described as staff officers, attached to each of the five
levels of the "Hoheitstraeger".
Organised upon a hierarchical basis, forming a pyramidal
structure -- as appears from the chart which your Honour
holds in your hands -- the principal political leaders on a
scale of descending authority were:--
I now proceed to offer evidence on the make-up and powers of
the Reichsleitung or the Leadership Corps, which consisted
of the Reichsleiter or Reich
[Page 16]
The "Reichsleiter" of the Party were, next to Hitler, the
highest office holders in the Party hierarchy. All of the
Reichsleiter in the main office and office holders within
the Reichsleitung were appointed by Hitler and directly
responsible to him.
I quote from the first paragraph of Page 4, Document 1893-
PS:--
Reichsleiter and all political directors, to include
the Directors of the Womens Leagues, within the Reich
Directorate or Reichsleitung."
The Party manual puts it this way -- and I quote from the
fourth sentence of the third paragraph of Page 20 of that
document. You will find the page number at the bottom, Page
20; It is a very short quotation. I quote:
To prove----
THE PRESIDENT: Just a moment, please. It begins: "It is in
the Reich Directorate where the strings of the organisation
of the German people and of the German State merge." Is that
it?
COLONEL STOREY: Yes, Sir, that is it. This translation says,
"the arteries of the organisation of the German people and
of the German State merge."
THE PRESIDENT: Yes
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(Part 5 of 16)
The Fuehrer, at the top.
I now offer in evidence Document 1893-PS. This is Exhibit
USA 323. And this, if your Honour pleases, is the
Organisation Book of the N.S.D.A.P., the National Socialist
Party. It was edited by the defendant, Reich Organisation
Leader of the N.S.D.A.P. -- the late defendant -- Dr. Robert
Ley and it is the 1943 edition. A large part of the evidence
to be offered relating to the composition of the Leadership
Corps of the Nazi Party will be drawn from this primer of
the Nazi organisations, and I shall later quote from it, and
without so requesting the Tribunal each time to take
judicial notice, I shall assume, in the absence of
questions, that it is so understood. That is Document 1893,
the English translation, that we will refer to.
The Reichsleiter, as I have mentioned, and the main
office and officeholders.
The Gauleiter, who was the district leader, with his
staff officers.
The Kreisleiter, who was the county leader, and his
staff officers.
The Ortsgruppenleiter, the local chapter leader, and
his staff officers.
The Zellenleiter, who was the cell leader, and his
staff officers.
And then, finally, the Blockleiter with his staff
officers. "The Fuehrer appoints the following political
directors:
The significant fact to be grasped is that through the
Reichsleitung perfect co-ordination of the Party and State
machinery was guaranteed.
"In the Reichsleitung the arteries of the organisation
of the German people and of the German State merge."
If your Honour please, there is a little different
translation in that portion in your book.