Archive/File: imt/tgmwc/tgmwc-03/tgmwc-03-22.08 Last-Modified: 1999/07/13 [Page 98] May it please the Tribunal, I passed up Document Book "Y," which contains the English translations of the documents relied upon in this presentation. The organisation which I shall now present for your consideration is the Sturmabteilung, the organisation which the world remembers as the "Brown Shirts" or "Storm Troops," the gangsters of the early days of Nazi terrorism. It came to be known in later years as the S.A., and I shall refer to it in that manner in the course of my presentation. The S.A. was the first of the organisations conceived and created by the Nazis as the instrument and weapon to effectuate their evil objectives, and it occupied a place of peculiar and significant importance in the scheme of the conspirators. Unlike some of the other organisations, the functions of the S.A. were not fixed or static. On the contrary, it was an agency adapted to many designs and purposes; and its role in the conspiracy changed from time to time -- always corresponding with the progression of the conspiracy through its various phases towards the final objective: abrogation of the Versailles Treaty and acquisition of the territory of other peoples and nations. If we might consider this conspiracy as a pattern, with its various parts fitting together like the pieces of a jigsaw puzzle, we would find that the piece representing the S.A. constituted a link in the pattern vitally necessary to the presentation and development of the entire picture. The S.A. participated in the conspiracy as a distinct and separate unit, having a legal character of its own. This is shown by Document 1725-PS, which is tabbed in the document book, of which the Court will take judicial notice. It is an Ordinance passed in March, 1935, Reichsgesetzblatt, Part I, Page 502. It declares that the S.A. and certain other agencies were thereafter to be considered "Components" of the Nazi Party. This Ordinance further provided in Article 5 -- and it is on the second page of the English translation, right after the word "Article 5" -- I quote:-- "The affiliated organisations can possess their own legal character." Similarly the organisation book of the Nazi Party characterised the S.A. as an "entity." Document 3220-PS, which I now offer, is an excerpt from the 1943 edition of the Organisation Book, Page 358 of the original, and I quote from the English translation. It is there declared:-- "The Fuehrer prescribes the law of conduct and commands its use. The Chief of Staff represents the S.A. as a complete entity on the mandate of the Fuehrer." I am sure the evidence will demonstrate and characterize the S.A. as an entity and organisation having a legal character of its own. This evidence will show that while the S.A. was composed of many individual members, these members acted collectively and cohesively as a unit. They were closely bound and associated together by many common factors, including: uniform membership standards and disciplinary regulations; a common and distinctive uniform; common aims and objectives; common activities, duties and responsibilities; and -- probably the most important factor of all -- [Page 99] a fanatical adherence to the philosophies and ideologies conceived by the Nazi conspirators. This is partially demonstrated by Document 2354-PS, which again is simply an excerpt from the Organisation Book of the Nazi Party. It is found on Page 7 of the English translation. It provides that membership in the S.A. was voluntary, but that the S.A. man should withdraw if "he can no longer agree with S.A. views or if he is not in a position to fulfill completely the duties imposed upon him as a member of the S.A." The S.A. man was well schooled in the philosophies, attitudes and activities which he was expected and required to adopt and reflect in his daily life. Cohesion of thought and uniformity of action with respect to such matters was in part obtained by the publication and distribution of a weekly periodical entitled Der S.A.-Mann (The S.A. Man). This publication was principally devoted to the creation and fostering of the various aspects of Nazi ideology which constituted the doctrinal motives of many of the conspirators. May I digress from my text and say to the Tribunal that we have here on the table all of these publications, beginning with the year 1934, up through and including the year 1939; the official weekly newspaper entitled Der S.A.-Mann, meaning the S.A. man, published in Munich, had wide distribution and was on sale at news stands and distributed throughout Germany and occupied countries. In addition, Der S.A.-Mann served to report upon and document the activities of the S.A. as an organisation and those of its constituent groups. I shall have occasion at a later point to refer to certain portions of this publication for the consideration of the Tribunal. The general organisational arrangement or plan of the S.A. will be demonstrated to the Tribunal by the documents which will subsequently appear. At this point I may say simply that this proof will show that the S.A. developed from scattered bands of street ruffians to a well-knit cohesive unit organised on a military basis, with military training and military functions, and, above all, with an aggressive, militaristic and warlike spirit and philosophy. It extended throughout the entire Reich territory and was formed vertically into local groups and divisions. Horizontally, there were special units including military cavalry, communications, engineer and medical units. Your Honours will observe the chart that I will introduce officially a little later in the Court. Co-ordination of these various groups and branches was strictly maintained by the S.A. Headquarters and operational offices, and those offices were located in Munich. The relationship between the S.A. and the N.S.D.A.P. is the next subject. The case against the S.A. is a strong one and its basis or foundation consists of its significant and peculiar relationship and affiliation with the Nazi Party and the principal conspirators. It is submitted that a relationship or association among the alleged conspirators constitutes important and convincing evidence of their joint participation in an established conspiracy; and this principle is particularly applicable because the affiliation between the S.A. and the Nazi leaders was closely maintained and adhered to and was adapted to the purpose of enabling the conspirators to employ the S.A. for any use or activity which might be necessary in the course of effectuating the objectives of the conspiracy. [Page 100] Thus we find that the S.A. was, in fact, conceived and created by Hitler himself in the year 1921 at the very inception of the conspiracy. Hitler retained direction of the S.A. throughout the period of the conspiracy, delegating the responsibility for its leadership to a Chief of Staff. Hitler, in fact, was often known throughout Germany as O.S.A.F., or "Oberster S.A. Fuehrer," or, translated, "the highest S.A. Fuehrer." The defendant Goering was an early member of the S.A. and he maintained a close affiliation with it throughout the course of the conspiracy. The defendant Hess participated in many of the early battles of the S.A. and was leader of an S.A. group in Munich. The defendants Frank, Streicher, von Schirach, and Sauckel each held a position of Obergruppenfuehrer in the S.A., a position corresponding to the rank of Lieutenant-General; and the defendant Bormann was a member of the Staff of the S.A. High Command. The close relationship between the S.A. and the leaders of the Nazi Party is demonstrated by the fact that the Hoheitstraeger of the Nazi Leadership Corps were authorised to call upon the S.A. for assistance in carrying out particular phases of the Party programme. This was established yesterday by Document 1893-PS, from which, your Honours will recall, I quoted from a number of times in connection with the presentation of the Leadership Corps. It was declared in that excerpt, Page 11 of the English translation, as your Honour will recall, that the Hoheitstraeger were empowered to call upon the S.A. for the execution of political missions connected with the movement. This responsibility of the S.A. to the Party is also shown by Document 2383-PS, which is an ordinance for the execution of the Hitler decree, which I now offer in evidence as Exhibit USA 410. I quote from Page 3 of the English translation. If your Honour will turn to Page 3 of the English translation, it is the fourth paragraph on that page:-- "The formations of the N.S.D.A.P., with exception of the S.S., for whom special provisions apply, are subordinated to the bearer of sovereignty (Hoheitstraeger) politically and in respect to commitments. Responsibility for the leadership of the units rests in the hands of the unit leader." It was in accordance with such authority, as proved yesterday in the Leadership Corps presentation, that the S.A. was used in the seizure of trade union properties. In addition the S.A. demonstrated its close affiliation to the Nazi Party by participating in various ways in election proceedings. This is shown in Document 2168-PS, which is a pamphlet entitled "The S.A.", which is Exhibit USA 411; and this pamphlet depicts the history and general activities of the S.A., written by an S.A. Sturmfuehrer named Bayer, upon orders from S.A. headquarters. In that pamphlet, and I quote on Page 4 of the English translation, down towards the bottom of the page, the last paragraph, beginning on line 3: "At the foremost front the labour and the struggle of the S.A. was not in vain. They stood at the foremost front of election fights." THE PRESIDENT: I am sorry, will you tell me which page? COLONEL STOREY: It is Page 4 of the English translation, down at the last paragraph, if your Honour pleases, beginning at the third line: "...the labour and the struggle of the S.A. was not in vain. They stood at the foremost front of election fights." [Page 101] Adolf Hitler, himself, on the 2nd September, 1930, took over the leadership of the S.A. as the Supreme S.A. Fuehrer. He himself guided his S.A. in the fateful election fight of the year 1930. Further evidence of the interest and participation of Nazi leaders in the activities of the S.A. is to be found in these five bound volumes, which consist of the issues of the S.A. newspaper, Der S.A.-Mann, from the year 1934 to 1939 inclusive; and I should like, at this time, to ask that each of these bound volumes be marked for identification, because each of them will be referred to from time to time during this presentation. They will begin with Exhibit USA 414, 415, 416, 417 and 418 and they are referred to by appropriate document numbers, which I will refer to when the quoted portions come in the English translation. Throughout these volumes there appear photographs portraying the participation of Nazi leaders in S.A. activities. I should like at this time to describe a few of the photographs, and I will indicate the page numbers upon which they appear. If your Honour pleases,we set out a number of these photographs, but I should like, at this time, to exhibit to the Tribunal and pass into evidence one of the photographs appearing in the January, 1937, issue. It is a photograph of Goering at the ceremonies held upon the occasion of his being made Obergruppenfuehrer of the Feldherrnhalle Regiment of the S.A. on the 23rd January, 1937, and we offer in evidence the photograph and the page of the newspaper. We will pass it up to your Honours if you would like to see it. We offer it in evidence. Here is another photograph of Goering, leading the Feldherrnhalle Regiment of the S.A. in parade on the 18th September, 1937, is shown at Page 3. The other photograph was at Page 3 of the January, 1937, edition of the S.A.- Mann. I call the attention of your Honour to a few of the other photographs that appear. Here is a photograph of Hitler greeting Huehnlein, bearing the caption: "The Fuehrer Greets Corps Fuehrer Huehnlein at the Opening of the International Automobile Fair -- 1935." That is dated the 23rd March, 1935, at Page 6. Here is another photograph of Himmler and Huehnlein, who was the Fuehrer of the N.S.K.K., and Lutze, who was Chief of Staff of the S.A., bearing the caption: "They lead the soldiers of National Socialism," on 15th June, 1935, Page 1. Another photograph shows Hitler at an S.A. ceremony, carrying the S.A. battle flag, and the picture bears the caption: "As in the fighting years the Fuehrer, on the Party Day of Freedom, dedicates the new regiments with the Blood Banner," 21st September, 1935, Page 4. I pass on. Here is a photograph of Goering in the S.A. uniform, reviewing S.A. marching troops, under the caption, "Honour Day of the S.A.," 21st September, 1935, Page 3. THE PRESIDENT: Colonel Storey, is there any doubt that Hitler and Goering were members of the S.A.? COL STOREY: No, Sir, but the purpose in showing those photographs, if your Honour pleases, was to show the militaristic character of the S.A. If there is no question about that and it is cumulative, then I will pass on. [Page 102] The work of the S.A. did not end with the seizure by the Nazis of the German Government, but affiliation between the S.A. and the Nazi leaders was continued after the acquisition by the Nazis of the control of the German State. The importance of the S.A. in connection with the Nazi Government and control of Germany is shown by the law of 1st. December, 1933. I have already referred to that, that is the union of Party and State. However, there is one paragraph that has not been quoted before, if your Honour pleases, and I would like to call your attention to it. It is our Document 1395-PS, and it appears in the English translation on Page 1, and I quote Article 2: "The Deputy of the Fuehrer and the Chief of Staff of the S.A. become members of the Reich Government in order to insure close co-operation of the offices of the Party and S.A. with the public authorities." Similarly, in Document 2383, which I referred to a moment ago -- I will merely refer to it again -- that is 2383-PS, Page 11, the last paragraph: "The Party and State offices must support the S.A. in this training effort and evaluate the certificate of possession of the S.A. defence insignia accordingly." That the Nazis at all times possessed complete control of the S.A. is shown by the so-called "Roehm Purge" of June, 1934. Evidence concerning this matter is to be found in the "Voelkischer Beobachter" of 1st July, 1934, at Page 1. I will not quote from that. Roehm had been Chief of Staff of the S.A. for several years and was responsible for the development of the S.A. into a powerful organisation with definite programmes and objectives. Members of the S.A. were required to take a personal oath of fidelity to him. But when his policies conflicted with those of the Nazi leaders, he was removed and murdered and replaced by Victor Lutze. This drastic action was accomplished without revolt or dissension in the ranks of the S.A. and with no change in the objectives or programme of the organisation. The S.A. remained -- I quote -- "a reliable and strong part of the National Socialist Movement" -- this is Document 2407-PS, Exhibit USA 412, the English translation of the "Voelkischer Beobachter." It is the last paragraph in the English translation, just above the name "Adolf Hitler." "... It is my wish that the S.A. be built up as a reliable and strong part of the National Socialist movement, full of obedience and blind discipline. They must help to create and form the new German citizens." The importance of the S.A. in the Nazi plan for the utilisation of the people of Germany is shown in Hitler's pronouncement: "The Course for the German Person," which appears in the issue of Der S.A.-Mann, of 5th September, 1936, at Page 22. It is our Document 3050-PS, Exhibits USA 414-418; and it is at Page 29 of the English translation; Page 29, of Document 3050-PS, the paragraph in the middle of the page; and I quote: "The boy, will enter the `Jungvolk,' and the lad, he will enter the Hitler Youth; the young man will go into the S.A., into the S.S., and into other units, and the S.A. and S.S. men will one day enter into the labour service and from there go to the Army, and the soldier of the `Volk' will return again into the organisation of the movement, the Party, in the S.A. and S.S., and never again will our `Volk' decay as it once decayed." [Page 103] And so we see that at all times during the conspiracy the relationship between the S.A. and the Nazi Party was such that the S.A. was constantly available to the conspirators as an instrument to further their aims. The S.A. was created by the conspirators at the inception of the Nazi movement. It was at all times subject to the direction of Adolf Hitler. Seven of the defendants held positions of leadership and responsibility in the organisation, and at all times the S.A. was subject to the call of the "Hoheitstraeger." The S.A. stood at the forefront of the election fights, and co- operation between the offices of the Party, of the S.A., and of the State was assured by law. So it was declared by Victor Lutze, the former Chief of Staff of the S.A., in a pamphlet entitled "The Nature and Tasks of the S.A." -- and it is our Document 2471-PS. We offer the original in evidence as Exhibit USA 413; and I quote from the top of Page 1 of the English translation. I believe I will read that whole paragraph, the first paragraph at the top of the page: "Before touching the real subject matter, I must tell you first, in order to clear up any uncertainty about my own position, that I never speak primarily as a member of the S.A., but as a National Socialist, since the S.A. cannot be independent of the National Socialist movement but can only exist as a part of it." I should next like to present to the Tribunal evidence which will demonstrate the principal functions and activities performed by the S.A. pursuant to the relationship which I have described above and in furtherance of the objectives of the conspiracy. These activities may be logically classified or divided into four distinct phases or aspects, each of which, I might add, corresponds with a particular phase in the progress of the conspiracy toward the objectives alleged in the Indictment. The first phase consists of the use of the S.A. and its members as the instrument for the dissemination of the ideology and fanaticism of the Nazis throughout Germany. The employment of the S.A. for this purpose continued throughout the entire period of the conspiracy, as will, I am sure, be apparent from the evidence. The second phase relates to the period prior to the Nazi seizure of power. During this period the S.A. was a militant and aggressive group of fighters or gangsters whose function was to combat, physically and violently, all opponents of the Party. The third phase relates to the period of several years following the Nazi seizure of power. During this period the S.A. participated in various measures designed to consolidate the control of the Nazis, including such Nazi- inspired programmes as the dissolution of the trade unions, the persecution of the Church, and the Jewish persecutions, to which I have already alluded. During this period they continued to serve as a force of political soldiers whose purpose was physically to combat members of political parties which were considered hostile or opposed to the Nazi Party. The fourth aspect of the S.A. activities consisted of its employment as an agency for the building up of an armed force in Germany in violation of the Treaty of Versailles, and for the preparation of the youth of Germany -- mentally and physically -- for the waging of an aggressive war. I should now like to discuss what I consider the highlights of the evidence relating to these four phases. [Page 104] The first phase is in connection with the dissemination of ideology. The first function of the S.A. consisted of its responsibility for disseminating the doctrines and ideologies, acceptance of which was necessary for the fulfilment of the Nazi objectives. From the very start the Nazi leaders emphasised the importance of this mission. During the course of the conspiracy the S.A. undertook many duties and responsibilities, but one responsibility which remained constant throughout was that of being propagandist of the National Socialist ideology. I now refer, your Honour, to the English translation of Document 2760-PS, Exhibit USA 256, which is an excerpt from Mein Kampf, and it is shown at Page 5 of the translation of the document. This is the third paragraph on Page 5 of the document, and I quote:-- "As the directing idea for the inner training of the Sturmabteilung, the dominant intention always was, aside from all physical education, to teach it to be the unshakeable convinced defender of the National Socialist idea." I might add that Hitler's pronouncement as to the function of the S.A. in this respect became, in effect, the guiding principle of S.A. members, for Mein Kampf was taken to express the basic philosophy of the S.A. In Document 2354-PS, which is an excerpt from the Organisation Book of the Party, at Page 1 of the English translation -- it is quoted in the text -- I quote Paragraph 1: "Education and training, according to the doctrine and aims of the Fuehrer as they are set down in Mein Kampf and in the Party programme, for all phases of our living and of our National Socialist ideology." This same document -- the Organisation Book of the Party -- refers to the SA's function as the propagandist of the Party. I believe the next one, if your Honour pleases, would merely be cumulative of what we have already referred to. THE PRESIDENT: Perhaps this would be a convenient time to break off. COLONEL STOREY: All right, Sir. The Tribunal adjourned until 19th December, 1945, at 1000 hours.
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