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I should also like to call the attention of the Tribunal to
this paragraph, which is quoted on the same page. It is the
fourth paragraph down, after the small number 2, and it
begins with the words:-

   "The authority of the Plenipotentiary General for the
   Arbeitseinsatz to empower the members of his staff and
   the presidents of the State employment offices to get
   direct information on the conditions regarding the
   employment of foreigners in the factories and camps,
   will remain untouched."

We have already offered to the Court, proof that the
defendant Sauckel was responsible for compelling citizens of
the occupied countries, against their will, to manufacture
arms and munitions and to construct military fortifications
for use in war operations against their own country and its
allies. He was, moreover, responsible for compelling
prisoners of war to produce arms and munitions for use
against their own countries and their actively resisting
allies.

The decree appointing Sauckel indicated that he was
appointed Plenipotentiary General for Manpower for the
express purpose, among others, of integrating prisoners of
war into the German war industry; and in a series of reports
to Hitler, Sauckel described how successful he had been in
carrying out that programme. One such report states that in
a single year, the defendant Sauckel had incorporated
1,622,829 prisoners of war into the German economy.

I refer to Document 407-V-PS, which is Exhibit USA 228. It
is a letter from the defendant Sauckel to Hitler, on 14th
April, 1943. Although the figures in the document have been
contained in another one, this is the first introduction of
this particular one. Quoting from Paragraphs 1 and 2 of the
English text, it begins:-

                                                  [Page 352]
                                                            
   "My Fuehrer,
   
   After having been active as Plenipotentiary for
   Arbeitseinsatz for one year, I have the honour to report
   to you that 3,638,056 new foreign workers have been
   added to the German war economy between 1st April of the
   last year and 31st March of this year."

THE PRESIDENT: Are you reading Paragraph I?

MR. DODD: Yes, your Honour.

THE PRESIDENT: It says 5,000,000, not three.

MR. DODD: I think it is 3,000,000, if your Honour pleases.

THE PRESIDENT: It should be three?

MR. DODD: I think so. The original looks to us like three.

Passing on a little bit, with particular reference to the
prisoners of war, we find this statement:-

   "Besides the foreign civilian workers another 1,622,829
   prisoners of war are employed in the German economy."

A later report states that 846,511 additional foreign
labourers and prisoners of war were incorporated into the
German war industry, and quoting from Document 407-IX-PS,
Exhibit USA 229, which is also a letter from the defendant
Sauckel to Hitler, I read in part from Page I, Paragraphs 1
and 2:-

   "My Fuehrer,
   
   I beg to be permitted to report to you on the situation
   of the Arbeitseinsatz for the first five months of 1943.
   For the first time the following number of new foreign
   labourers and prisoners of war were employed in the
   German war industry: Total, 846,511."

This use of prisoners of war in the manufacture of armaments
allocated by the defendant Sauckel was confirmed by the
defendant Speer, who stated that 40 per cent. of all
prisoners of war were employed in the production of weapons
and munitions and in subsidiary industries. I wish to refer
briefly to Paragraphs 6, 7 and 8, on Page 15 of the English
text of an interrogation of the defendant Speer on 18th
October, 1945, which was offered and referred to yesterday
Exhibit USA 220.
Quoting from Paragraphs 6, 7 and 8, on Page 15, Paragraph 1,
on Page 2 of the German text. There are three questions
which will establish the background for this answer:-

   "Q. Let me understand, when you wanted labour from
   prisoners of war did you requisition prisoners of war
   separately, or did you ask for a total number of
   workers?
   
   A. Only Schmelter can answer that directly. As far as
   the commitment of prisoners of war for labour goes, it
   was effected through employment offices of the Stalags.
   I tried several times to increase the total number of
   prisoners of war that were occupied in the production at
   the expense of the other demand factors.
   
   Q. Will you explain that a little more?
   
   A. In the last phase of production, that is, in the year
   1944, when everything collapsed, I had 40 per cent. of
   all prisoners of war employed in the production. I
   wanted to have this percentage increased.
   
   Q. And when you say 'employed in the production', you
   mean in these subsidiary industries that you have
   discussed, and also in the production of weapons and
   munitions, is that right?
   
   A. Yes. That was the total extent of my task."

                                                  [Page 353]

THE TRIBUNAL (Mr. Biddle): What do you mean by "subsidiary
industries", Mr. Dodd? Is that war industries?

MR. DODD: Yes, sir; war industries, as we understand it. It
was referred to many times by these defendants as the
component parts of the plans.

I also would like to call the attention of the Tribunal
again to the "Minutes of the 36th Meeting of the Central
Planning Board", Document R-124, from which we read a number
of excerpts yesterday, and remind the Tribunal that in the
report of the minutes of that meeting the defendant Speer
stated that:-

   "90,000 Russian prisoners of war employed in the whole
   of the armament industry are for the greatest part
   skilled men."

We should like, at this point, to turn to the special
responsibility of the defendant Speer, and to discuss the
evidence of the various crimes committed by, the defendant
Speer in planning and participating in the vast programme of
forcible deportation of the citizens of occupied countries.
He was the Reich Minister of Armaments and Munitions and
Chief of the Organisation Todt, both of which positions he
acquired on 15th February, 1942, and by virtue of his later
acquisition of control over the armament offices of the
Army, Navy and Air Force and the production offices of the
Ministry of Economics, the defendant Speer was responsible
for the entire war production of the Reich, as well as for
the construction of fortifications and installations for the
Wehrmacht. Proof of the positions held by him is supplied in
his own statement, as contained in Document 2980-PS, which
has already been offered to the Tribunal and which is
Exhibit USA 18.

The industries under the defendant Speer's control were
really the most important users of manpower in Germany; and
thus, according to the defendant Sauckel, Speer's labour
requirements received unconditional priority over all other
demands for labour. We refer to the transcript of the
interrogation of the defendant Sauckel on 22nd September,
1945, It is Exhibit USA 230. It is next to the last document
in the document book. I wish to refer to Page 1 of that
document, Paragraph 4. It is a brief reference, the last
answer on the page. The question was asked of the defendant
Sauckel:-

   "Q. Except for Speer, they would give the requirements
   in general for the broad field, but in Speer's work he
   would get them allocated to industry, and so on; is that
   right?
   
   A. The others only got whatever was left. Because Speer
   told me once in the presence of the Fuehrer that I was
   there to work for Speer and that mainly I was his man."

The defendant Speer has admitted under oath that he
participated in the discussions, during which the decision
to use foreign forced labour was made. He has also said that
he concurred in the decision and that it was the basis for
the programme of bringing foreign workers into Germany by
compulsion. I make reference to the interrogation of this
defendant of 18th October, 1945. It is Exhibit USA 220. We
have already read from it; and I particularly refer to the
bottom of Page 12 and the top of Page 13 of the English
text:-

   "Q. But is it clear to you, Herr Speer, that in 1942
   when the decisions were being made concerning the use of
   forced foreign labour you participated in the
   discussions yourself?
   
   A. Yes.

                                                  [Page 354]

   Q. So that I take it that the execution of the programme
   of bringing foreign workers into Germany by compulsion
   under Sauckel was based on earlier decisions that had
   been made with your agreement?
   
   A. Yes, but I must point out that only a very small part
   of the manpower that Sauckel brought into Germany was
   made available to me; a far larger part of it was
   allocated to other departments that demanded it."

This admission is confirmed by the minutes of Speer's
conference with Hitler on 10th, 11th and 12th August, 1942,
in Document R-124, which has been offered here and from
which excerpts have been read. Page 34 of that document,
Paragraph 1 of the English text, has already been quoted,
and those excerpts were read before the Tribunal yesterday.
The Tribunal will recall that the defendant Speer related
the outcome of his negotiations concerning the forcible
recruitment of 1,000,000 Russian labourers for the German
armaments industry, and this use of force was again
discussed by Hitler and Speer on 4th January, 1943, as shown
by the excerpts read from the Document 556-PS-13, where it
was decided that stronger measures were to be used to
accelerate the conscription of French civilian workers.

We say the defendant Speer demanded foreign workers for the
industries under his control and used those workers with the
knowledge that they had been deported by force and were
being compelled to work. Speer has stated under oath in his
interrogation of 18th October, 1945, Page 5, Paragraph 9 of
the English text, quoting it directly:-

   "I do not wish to give the impression that I want to
   deny the fact that I demanded manpower and foreign
   manpower from Sauckel very energetically."

He has admitted that he knew he was obtaining foreign
labour, a large part of which was forced labour; and
referring again to that same interrogation of 18th October,
1945, and to Pages 8 and 9 of the English text and Page 10
of the German text:-

   "Q. So that during the period when you were asking for
   labour, it seems clear, does it not, that you knew you
   were obtaining foreign labour as well as domestic labour
   in response to your requests, and that a large part of
   the foreign labour was forced labour.
   
   A. Yes.
   
   Q. So that, simply by way of illustration, suppose that
   on 1st January, 1944, you require 50,000 workers for a
   given purpose, would you put in a requisition for 50,000
   workers, knowing that in that 50,000 there would be
   forced foreign workers?
   
   A. Yes."

The defendant Speer has also stated under oath that he knew
at least as early as September, 1942, that workers from the
Ukraine were being forcibly deported for labour into
Germany. Likewise he knew that the great majority of the
workers of the Western occupied countries were slave
labourers, forced against their will to come to Germany; and
again referring to his interrogation of this 18th day of
October, 1945, and beginning with the fourth paragraph from
the bottom of Page 5 of the English text, Paragraph 10 on
Page 6 of the German text, we find this series of questions
and answers:

   "Q. When did you first find out then that some of the
   manpower from the Ukraine was not coming voluntarily?
   
                                                  [Page 355]
   
   A. It is rather difficult to answer this here, that is,
   to name a certain date to you. However, it is certain
   that I knew that at some particular point of time that
   the manpower from the Ukraine did not come voluntarily.
   
   Q. And does that apply also to the manpower from other
   occupied countries; that is, did there come a time when
   you knew that they were not coming voluntarily?
   
   A. Yes.
   
   Q. When in general, would you say that time was, without
   naming a particular month of the year?
   
   A. As far as the Ukraine situation goes, I believe that
   they did not come voluntarily any more after a few
   months, because immense mistakes were made in their
   treatment by us. I should say off-hand that this time
   was either in July, August or September, 1942."

Turning to Paragraph 11 on Page 6 of the English text of
this same interrogation and Page 7 and Paragraph 8 of the
German text, we find this series of questions and answers -
and I am quoting:-

   "Q. But many workers did come from the West, did they
   not, to Germany?
   
   A. Yes.
   
   Q. That means, then, that the great majority of the
   workers that came from the Western countries, the
   Western occupied countries, came against their will to
   Germany?
   
   A. Yes."

These admissions are borne out, of course, by other
evidence, for, as Document R-124 shows, and as we have shown
by the readings from it, in all countries conscription for
work in Germany could be carried out only with the active
assistance of the police, and the prevailing methods of
recruitment had provoked such violence that many German
recruiting agents had been killed.

And again, at a meeting with Hitler to discuss the manpower
requirements for 1944, which is reported in Document 1292-
PS, Speer was informed by the defendant Sauckel that the
requirements - including Speer's requirement for 1,300,000
additional labourers - could be met only if German
enforcement agents were furnished to carry out the
enslavement programme in the occupied countries.

Now we say that, notwithstanding his knowledge that these
workers were conscripted and deported to Germany against
their will, Speer nevertheless continued to formulate
requirements for the foreign workers and requested their
allocation to those industries which were subject to his
control. This is borne out by the minutes of the Central
Planning Board, as contained in Document R-124, and
particularly Page 13, Paragraph 4 of the English text; and
that is Page 6 and Paragraph 4 of the German text.

Speer speaking:-

   "Now, to the labour problem in Germany. I believe it is
   still possible to transfer some workers from the Western
   territories. The Fuehrer stated only recently that he
   wished to dissolve these foreign volunteers as he had
   the impression that the army groups were carting around
   with them a lot of ballast. Therefore, if we cannot
   settle this matter ourselves, we shall have to call a
   meeting with the Fuehrer to clear up the coal situation.
   Keitel and Keitzler will be invited to attend in order
   to

                                                  [Page 356]


   determine the number of Russians from the rear army
   territories that can be sent to us. However, I see
   another possibility: We might organise another drive to
   screen out workers for the mines from the Russian
   Prisoners of War in the Reich. But this possibility is
   none too promising."

At another meeting of the Central Planning Board the
defendant Speer rejected a suggestion that labour for
industries under his control be furnished from German
sources instead of from foreign sources. And again, in this
Document R-124, on Page 16, Paragraphs 3, 4 and 5 of the
English text, and Page 12, Paragraphs 6 and 7 of the German
text - I quote Speer:-

   "We do it this way: Kehrl collects the demands for
   labour necessary to complete the coal-and-iron plan and
   communicates the numbers to Sauckel. Probably there will
   be a conference at the Reich Marshal's next week, and an
   answer from Sauckel should have arrived by then. The
   question of recruitment for the armaments industry will
   be solved together with Weger."

Then Kehrl speaking:-

   "I wish to urge that the allotments to the mines should
   not be made dependent on the recruitment of men abroad.
   We were completely frustrated these last three months
   because this principle had been applied. We ended
   December with a deficit of 25,000 and we never get
   replacements.
   
   The number must be made up by men from Germany.
   
   Speer: No, nothing doing."


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