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While undertaking strategic and diplomatic measures to prepare for its predatory attack against the U.S.S.R., the Hitlerite Government conceived and planned beforehand the commission of war crimes on the territory of the U.S.S.R. The so-called "Case Barbarossa" was a strategic plan. But this plan was supplemented by a number of instructions and orders, designed to embrace all the measures relative to the problems which would arise on the invasion of the Soviet Union. Among these measures we must mention, in the very first place, the instruction issued on 13th March, 1941, by the Headquarters of the German High Command.

This instruction deals with a series of organisational problems of a civilian nature and, in particular, with the problems relative to the organisation of administrative authorities. It is of importance to note that this instruction placed German troops stationed in East Prussia and the so-called Government General (that is to say, Poland) under the laws and regulations which were to be put in force in the zone of operations, at least four weeks prior to the opening of the campaign.

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By this instruction, the High Command of the German Armed Forces was authorised to assume executive power and to delegate it to the Commanding Generals of the Army Groups and Armies. Also one cannot overlook in this instruction sub- paragraph "B" which characterizes the tasks and objectives pursued by the conspirators.

In this sub-paragraph it states:

"In the theatre of army operations, in connection with the preparation of political administration, the Reichsfuehrer of the S.S., by order of the Fuehrer, has been given special tasks for the preparation of political administration, arising from the conclusive and decisive struggle between two opposing political systems. Within the limits of the set tasks, the Reichsfuehrer of the S.S. acts independently, upon his own responsibility."

This instruction deals, further, in a very specific way with such problems as the plundering and predatory exploitation of the areas occupied by the German troops. The directive is signed by the Defendant Keitel. In another instruction, issued in June, 1941, as a supplement to the "Plan Barbarossa," orders are issued which, in the guise of propaganda directives, prescribe the ruthless treatment of all those who oppose the German aggressors. As to actual propaganda, the directives frankly mention the usual dirty Hitlerite methods of calumny, lies and provocation, which were to be used by the so-called "propaganda companies."

Finally one cannot overlook another instruction, known under the name of "Orders Concerning Military Jurisdiction in the Barbarossa Area and special measures to be taken by the troops." These orders, while sanctioning a completely arbitrary action on the part of the German authorities and troops in regard to the civilian population in the territories seized by the German Armed Forces, begin with a demand made to the German troops to "protect" themselves ruthlessly against hostile actions of the civilian population.

In the rules prescribing the adoption of Draconian measures against peaceful populations and partisans, we find indications as to the brutal punishment to be imposed upon persons defined in those orders as "suspected elements."

With the permission of the Tribunal, I will read only two sub-paragraphs of these rules, Sub-paragraphs 4 and 5:

"4. In those places where it is too late to adopt these measures or where it had not been possible to do so immediately, suspected elements must be handed over to an officer without delay; he will decide whether or not they should be shot.

5. It is absolutely prohibited to hold these suspects for trial by courts, which at a later date will be instituted for the local population."

What heights of cynicism were reached by the German High Command in the application of sanguinary terror can be seen from the fact that this "order" freed the German soldiers, officers, and officials of any responsibility for the

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commission of crimes against the peaceful Soviet population. According to these "orders," the German troop commanders were entitled to confirm only those "sentences" which, as the said document states, were in accordance with the "political objectives of the leaders."

Consequently, long before 22nd June, 1941, the Hitlerite Government and the German High Command, whose representatives are now in the dock, planned and prepared in detail those war crimes which were subsequently committed in the territory of the U.S.S.R. These plans inexorably disclose that the defendants premeditated the monstrous crimes which were organised by them.

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