Archive/File: imt/tgmwc/tgmwc-03-22.06 Last-Modified: 1998/08/25 [Page 77] COLONEL STOREY: If the Tribunal please, the persons who held these posts in the ordinary Cabinet varied between the years 1933 and 1945. Although it is not encumbent upon us to prove who they were, since the group and not the individuals are under consideration, nevertheless their names are [Page 78] already before this Tribunal in the original governmental chart, Exhibit USA 3. Since it will be of interest to the Tribunal to see what persons -- and 17 of them are defendants here -- held any particular positions in the Cabinet, a table has been prepared which lists all the departments and posts I have mentioned, and the encumbents thereof, during the years 1933 to 1945. The German equivalents of the titles are also shown and, with the permission of the Tribunal, I will now distribute this table to its members. Copies have likewise been filed in the defendants' Information Centre. The table also is annotated with citations to sources verifying the facts shown -- all of which, however, were of common knowledge during the period in question. Diverting from the text: This is simply prepared for the convenience of the Tribunal in connection with the studying of the briefs and the documents. As I said at the outset, the proof will show that there was only an artificial distinction between the ordinary Cabinet, the Secret Cabinet Council, and the Council of Ministers for the Defence of the Reich. This is evident in the first instance by the unity of personnel between the three subdivisions. Thus on 4th February, 1938, Hitler created the Secret Cabinet Council. If your Honours will refer to this big chart, you will notice under 1938 there is a red line pointing down to the Secret Cabinet Council created during that year. This decree appears in the 1938 Reichgesetzblatt, Part I, at Page 112. It is in our document book as Document 2031-PS, and I should like to quote from it. THE PRESIDENT: It is not in Book X, is it? COLONEL STOREY: Yes, Sir; 2031-PS. THE PRESIDENT: 2031? COLONEL STORY: Yes, Sir; I beg your pardon, it is under the Laws and Decrees Section. "To advise me in conducting the foreign policy I am setting up a Secret Cabinet Council. As President of the Secret Cabinet Council I nominate: Reich Minister Baron von Neurath. As members of the Secret Cabinet Council I nominate: Reich Minister for Foreign Affairs Joachim von Ribbentrop; Prussian Prime Minister, Reich Minister of the Air, Supreme Commander of the Air Force, General Field Marshal Hermann Goering; the Fuehrer's Deputy, Reich Minister Rudolph Hess; Reich Minister for the Enlightenment of the People and Propaganda, Dr. Joseph Goebbels; Reich Minister and Chief of the Reich Chancellery, Dr. Lammers; Supreme Commander of the Army, General Walther von Brauchitsch; Supreme Commander of the Navy, Grand Admiral Dr. (honorary) Raeder; Chief of the Supreme Command of the Armed Forces, Lt.-Gen. Wilhelm Keitel." It will be noted that every member was either a Reich Minister or, as in the case of the Army, Navy, and O.K.W. heads, had the rank and authority of a Reich Minister. On 30th August, 1939, Hitler established the Council of Ministers for the Defence of the Reich, better known as the Ministerial Council. This was the so-called Cabinet. The decree appears in the 1933 Reichsgesetzblatt, Part I, at Page 1539. I now refer to Document 2018-PS of the Laws and Decrees, and I quote paragraph 1: "1. From members of the Reich Defence Council shall be set up a standing [Page 79] Committee to be known as the Ministerial Council for the Defence of the Reich. 2. The standing members of the Ministerial Council for Defence of the Reich shall be: General Field Marshal Goering as chairman; The Fuehrer's Deputy -- the defendant Hess; Commissioner General for Reich Administration -- the defendant Frick; Commissioner General for Economy -- the defendant Funk; Reich Minister and Chief of the Reich Chancellery -- Dr. Lammers; Chief of the High Command of the Armed Forces -- the defendant Keitel. 3. The chairman may draw on any other members of the Reich Defence Council including further personnel for advice." Again it will be seen that all were also members of the ordinary Cabinet. But this use of the Cabinet as a manpower reservoir, from whom the trusted collaborators were selected, becomes particularly poignant when we consider the actions of the Nazi conspirators which were not published in the Reichsgesetzblatt, which were concealed from the world and which were part and parcel of their conspiracy to wage aggressive war. It will have been noted that the decree setting up the Ministerial Council, one to which I have just referred ,contained this sentence: "Out of the Reich Defence Council a standing committee shall be set up as a A Ministerial Council for Defence of the Reich." There is evidence already before this Tribunal establishing the creation -- by the Cabinet -- on 4th April, 1933, of this really secret war-planning body. I refer the Tribunal to Exhibit USA 24, which appears in our document book as Document 2261-PS. That document contains the unpublished Reich Defence Law of 21st May, 1935. As to the membership of that Council when first created, I have here a copy of the second session of the working committee of those delegated for the Reich Defence, dated 22nd May, 1933, and signed by the defendant Keitel. It appears in our document book as EC- 177, Exhibit USA 390. The composition of the Reich Defence Council appears on Page 3 of the original and also on Page 3 of the translation: THE PRESIDENT: I thought you were going to refer to 2261-PS. COLONEL STOREY: If your Honour pleases, I just referred to it as being an exhibit already in evidence, and said that it was one of the unpublished Reich Defence Laws. That was the only purpose in referring to it. THE PRESIDENT: You were referring to EC-177. Where is it? COLONEL STOREY: In the document book, your Honour, just this side of the Laws and Decrees. The quotation is from the top of Page 3 of the translation: "Composition of the Reich Defence Council: President: Reich Chancellor Deputy: Reichswehr Minister Permanent Members: Minister of the Reichswehr Minister for Foreign Affairs Minister of the Interior [Page 80] Minister of Finance Minister of Economic Affairs Minister for Public Enlightenment and Propaganda Minister of Air Chief of the Army Command Staff Chief of the Navy Command Staff Depending on the case: the remaining members, further personnel, e.g. leading industrialists," etc. All but the Chiefs of the Army and Navy Command Staff were, then, component parts of the ordinary Cabinet. The composition of his Defence Council was changed in 1938. I refer the Tribunal to Exhibit USA 36, which appears in our Document Book as No. 2194-PS. This contains the unpublished Reich Defence Law of 4th, paragraph 10, 4th September, 1938. I now quote from paragraph 10, entitled "The Reich Defence Council," which is found at Page 4 of the copy of the law in the original, and I now quote from Page 6 of the English translation, the top of the page: "2. The Fuehrer and Reich Chancellor is chairman in the R.V.R. His permanent deputy is General Field Marshal Goering. He has the right to call conferences of the R.V.R. Permanent members of the R.V.R. are: Reich Minister of Air and Supreme Commander of the Air Force. Supreme Commander of the Army, Supreme Commander of the Navy, Chief of the O.K.W., Deputy of the Fuehrer, Reich Minister and Chief of the Reich Chancellery, President of the Secret Cabinet Council, General Plenipotentiary for the Reich Administration, General Plenipotentiary for Economics, Reich Minister for Foreign Affairs, Reich Minister of the Interior, Reich Finance Minister, Reich Minister for Public Enlightenment and Propaganda, President of the Reich Bank Directory, The other Reich Ministers and the Reich Offices directly subordinate to the Fuehrer and the Reich Chancellor will be consulted, if necessary. From time to time additional personages may be summoned as the case demands." THE PRESIDENT: Colonel Storey, it would help me, if you explained to me what conclusions you are asking us to draw from these documents. COLONEL STOREY: If your Honour pleases, we were trying to show the progressive domination of the Reich Cabinet by the defendants and the members of this group, so that, as your Honour will see as we proceed, they could pass laws and decrees secretly by circulatory process or, in effect, at their will. I realise it is a little detailed, but we are trying to show the composition and how it was set up, and the conclusions will be drawn later. By that time the Supreme Commanders of the Army and Navy had been given ministerial rank and authorised to participate in Cabinet meetings. I cite 1938 Reichsgesetzblatt, Part I, Page 215. May we at this time call the attention of the Tribunal to two members of the Defence Council who also appear in the Ministerial Council under the [Page 81] same title: the Plenipotentiary for Administration and the Plenipotentiary for Economy? The former post was held by the defendant Frick, while the latter was first held by the defendant Schacht and then by the defendant Funk, who signed the decree in that capacity. These facts are verified by the defendant Frick in Exhibit USA 3, which is the Nazi Governmental organisation chart previously referred to. As we will show later, these two posts had many of the other ministries subordinated to them for war-planning aims and purposes. They, together with the Chief of the O.K.W., formed a poverful triumvirate that is known as the "3-Man College" shown in the three boxes down from 1935-1938, which figured prominently, as the proof will disclose, in the plans and preparations to wage aggressive war. The holders of these positions vere Cabinet members: the defendants Frick, Funk and Keitel. This utilisation of the ordinary Cabinet as a supply centre fo other governmental agencies, and the cohesion between all of the groups, is perhaps quickly seen on the chart which is shown. The points I have been making are illustrated on the chart. We are not offering this chart in evidence, although all facts thereon already have been proved or will be proved. The chart is also designed to depict (to the left of the line running down the right centre) the chronological development of the offshoots of the ordinary Cabinet. Thus in the main box entitled "Reich Cabinet" (which appears directly under Hitler) certain dates appear. I think I will omit the part that describes those lines because it is self-evident. The Ministerial Council for the Defence of the Reich was created in 1944; the Delegate for Total War Effort was Goebbels. These agencies were, next to Hitler, the important Nazi functionary bodies. In every case, as the chart shows, they were occupied by persons taken from the ordinary Cabinet. The arrow running from the Reich Defence Council to the Ministerial Council for the Defence of the Reich, is intended to reflect the fact shown previously, that the latter was formed out of the former. We will, for other points of this presentation, refer again to the chart, especially to that portion to the right which relates to ministries. The unity, cohesion and inter-relationship of the subdivisions of the "Reichsregierung" was not the result of a co-mixture of personnel alone. It was also realised by the method in which it operated. The ordinary Cabinet consulted together both by meetings and through the so-called circulation procedure. Under this procedure, which was predominantly used when meetings were not held, drafts of laws prepared in the individual ministries were distributed to the other Cabinet members for approval or disapproval. The man primarily responsible for the circulation of drafts of laws under this procedure was Dr. Lammers, the Leader and Chief of the Reich Chancellery. I have here an affidavit executed by him concerning that technical device, which we offer in evidence as Exhibit USA 391, Document 2999-PS. It is short and I should like to quote all of it: "I, Hans Heinrich Lammers, being first duly sworn, depose and say: I was Leader of the Reich Chancellery from 30th January, 1933, until the end of the war. In this capacity I circulated drafts of proposed laws [Page 82] and decrees, submitted to me by the Minister who had drafted the law or decree, to all members of the Reich Cabinet. A period of time was allowed for objections, after the expiration of which the law was considered as having been duly accepted by the various members of the Cabinet. This procedure continued throughout the entire war. It was followed also in the Council of Ministers for the Defence of the Reich. Signed: `Dr. Lammers' -- and sworn to before Colonel Hinkel." As an illustration of how the circulation procedure worked I have here a memorandum dated 9th August, 1943, which bears the facsimile signature of the defendant Frick and is addressed to the Reich Minister and Chief of the Reich Chancellery. Attached to the memorandum is a draft of the law in question and a carbon copy of a letter dated 22nd December, 1943, from the defendant Rosenberg to the Reich Minister of the Interior, containing his comments on the draft. I now offer Document 1701-PS as Exhibit USA 392, and I call your Honour's attention to the big red border around the enclosure. The quoted portion is from Page 1 of the translation and Page 1 of the original. Quoting: "To the Reich Minister and Chief of the Reich Chancellery. For the information of the other Reich Ministers. Subject: Law on the Treatment of Asocial Elements of the Community. In addition to my letter of 19th March, 1942. After the draft of the Law on the Treatment of Asocial Elements of the Community has been completely re- written, I am sending the enclosed new draft with the consent of the Reich Minister of Justice, Dr. Thierack, and ask that the law be approved in the circulatory manner. The necessary number of prints is attached." The same procedure was followed in the Council of Ministers when that body was created. And the decrees of the Council of Ministers were also circulated to the members of the ordinary Cabinet. I have here a carbon copy of a memorandum found in the files of the Reich Chancellery by the Allied Armies, and addressed to the members of the Council of Ministers, dated 17th September, 1939, and bearing the typed signature of Dr. Lammers. It is Document 1141-PS, Exhibit USA 393, from the English translation, the last paragraph just above Dr. Lammers' signature, I quote: "Matters submitted to the Council of Ministers for the Reich Defence have heretofore been distributed only to the members of the Council. I have been requested by some of the Reich Ministers who are not permanent members of the Council to inform them of the drafts of the decrees which are being submitted to the Council, so as to enable them to check those drafts from the point of view of their respective offices. I shall follow this request so that all of the Reich Ministers will in future be informed of the drafts of decrees which are to be acted upon by the Council for the Reich Defence. I therefore request peermission to add forty- five additional copies of the drafts, as well as of the letters which usually contain the arguments for the drafts, to the folders submitted to the Council." Von Stutterheim, who was an official of the Reich Chancellery, comments [Page 83] on this procedure, at Page 34 of a pamphlet entitled "The Reich Chancellery," which I now offer in evidence, Document 2231-PS ... THE PRESIDENT: Colonel Storey, I do not understand what the importance of the last document is. COLONEL STOREY: The last document, if your Honour pleases, is in further evidence of the approval of the laws, and of the passing of laws by a circulatory process. THE PRESIDENT: We already have Dr. Lammers' affidavit. COLONEL STOREY: It might be considered strictly cumulative, if that is what your Honour has in mind. THE PRESIDENT: Well, if it is cumulative, we do not really want to hear it. COLONEL STOREY: Yes, Sir; I will ask then that it be stricken from the record. I really overlooked the fact that it was cumulative. Miss Boyd and Commander Kaplan tell me that the Document 2231-PS is probably also corroborative of the same process, and I will, therefore, not offer it. I have already stated that for a time the Cabinet consulted together through actual meetings. The Council of Ministers did likewise, but those members of the Cabinet who were not already members of the Council also attended the meetings of the Ministerial Council. And when they did not attend in person they were usually represented by State Secretaries of the Ministries. We have here minutes of six meetings of the Council of Ministers as of 1st, 4th, 8th and 19th September, 1939, also of 16th October and 15th November, 1939. These original documents were found in the files of the Reich Chancellery. I offer them in evidence as Document 2852-PS, Exhibit USA 395. It will only be necessary to point out for our purposes at this time a few of the minutes. I call the attention of the Tribunal to the meeting held on 1st September, 1939, which is probably the first meeting since the Council was created on the 30th August, 1939; and I read from that document which shows who was present, beginning at the top of the English translation: "Present were the permanent members of the Council of Ministers for Defence of the Reich: The Chairman, General Field Marshal Goering; the Deputy of the Fuehrer, Hess;" -- for some unknown reason a line appears through the name Hess -- "the Plenipotentiary for Reich Administration, Dr. Frick; the Plenipotentiary for Economy, Funk; the Reich Minister and Chief of the Reich Chancellery, Dr. Lammers; and the Chief of the High Command of the Armed Forces, Keitel, represented by Major-General Thomas." These were the regular members of the Council. Also present were the Reich Minister for Food and Agriculture, Darre; and seven State Secretaries: Koerner, Neumann, Stuckart, Posse, Landfried, Backe, Syrup. These State Secretaries were from the several ministries or other top Reich authorities, as, for example, to name a few: Koerner was the deputy of the defendant Goering in the Four Year Plan; Stuckart was in the Ministry of the Interior; Landfried was in the Ministry of Economics; Syrup was in the Ministry of Labour. These later positions appear on the government chart which is already in evidence. Now the meeting of the Council, I will omit that one. And then there came the names of nine State Secretaries... [Page 84] THE TRIBUNAL (MR. BIDDLE): Colonel Storey, the last document shows only that certain members of the Cabinet were at the Cabinet meeting. COLONEL STOREY: Yes, it shows no more than that. I am going on a little farther, to show that the S.S. Gruppenfuehrer was present also, and other people were present. THE TRIBUNAL (MR. BIDDLE): What does that show? COLONEL STOREY: In other words, that they called in these subordinate people, as in the meeting of the ministers. THE TRIBUNAL (Mr. Biddle): What would that show? COLONEL STOREY: Well, it just shows the permeation of the Party and the subordinate agencies, showing they could use the Reich Cabinet for whatever purpose they wanted and to devise laws any way they wanted. They called in these people, in subordinate positions, to sit with them when they were passing Cabinet measures. I can also call your Honour's attention to the Ministerial Council for Defence. The Cabinet was supposed to be a Ministerial-rank Cabinet meeting, and as I just started to show, they called in the S.S. Gruppenfuehrer Heydrich to this meeting. THE PRESIDENT: There could be no doubt, could there, that there was a Reich Cabinet? COLONEL STOREY: No, Sir. THE PRESIDENT: And that the Reich Cabinet made decrees by this circulatory method? There is no doubt about that. COLONEL STOREY: That is right, Sir. THE PRESIDENT: What does this document have to do with that? COLONEL STOREY: It shows who participated, and how they were there in their Party rank; and I will omit the rest, with reference to these other individuals. THE PRESIDENT: But we have had ample evidence before, haven't we, as to who formed the Reich Cabinet? COLONEL STOREY: Yes. Well, I will omit the rest with reference to other people who participated, and just skip over to Page 23 for the record. Before leaving these minutes, and as indicative of the activities of the Reichsregierung, I would like to call the attention of the Tribunal to some of the decrees passed and minutes discussed at these meetings. At the first meeting of 1st September, 1939, fourteen decrees were ratified by the Council. Of this group I call the attention of the Tribunal to Decree No. 6, appearing on Page 2 of the translation, and I quote: THE PRESIDENT: I do not think you gave us the number. COLONEL STOREY: I beg your pardon, Sir. It is the Reichsgesetzblatt No. 1, Page 1681, of which we ask the Tribunal to take judicial notice. That decree was about the organisation of the administration and about the German Security Police in the Protectorate of Bohemia and Moravia. That appears in the translation of 2852-PS. Another one that was passed is dated 19th September, 1938, on Page 6 of the translation, and I quote from the bottom of Page 6: "The Chairman of the Council, General Field Marshal Goering, made comments regarding the structure of civil administration in the occupied Polish territory. He expressed his intentions regarding the economic evacuation measures in this territory. Then the questions of decreasing wages, and the question of working hours and the support of members of families of drafted workers were discussed." [Page 85] There are a number of miscellaneous points of discussion appearing, and in paragraph 2 of the minutes I quote the following, as it appears on Page 7: "The chairman directed that all members of the Council should regularly receive the situation reports of the Reichsfuehrer S.S. Then the question of the population of the future Polish Protectorate was discussed and the housing of Jews living in Germany." Finally, I call the attention of the Tribunal to the minutes of the meeting of 15th November, 1939, Page 10 of the translation, where, among other things, the treatment of Polish prisoners of war was also discussed. We submit that this document not only establishes the close working union between agencies of the State and Party, especially with the notorious S.S., but also tends to establish, as charged in the Indictment, that the Reichsregierung was responsible for the policies adopted and put into effect by the government, including those which comprehended and involved the commission of crimes referred to in the Indictment. But a mere working alliance would be meaningless unless there were power. And the Reichsregierung had the power. Short of Hitler himself, it had practically all the power a government can exercise. The prosecution has already offered evidence on how Hitler's Cabinet and the other Nazi conspirators secured the passage by the Reichstag of the "Law for the Protection of the People and the Reich" of 24th March, 1933, which has been previously referred to in our Document 2001-PS, and which vested the Cabinet with legislative powers even to the extent of deviating from previously existing constitutional law; how such powers were retained even after the members of the Cabinet were changed; and how the several States, provinces, and municipalities, which had formerly exercised semi-autonomous powers, were transformed into the administrative organs of the Central Government. The ordinary Cabinet emerged all-powerful from this rapid succession of events. The words of the defendant Frick are eloquent upon that achievement. I have an article of his which he wrote for the 1935 National Socialist Year Book, Document 2380-PS, which I offer in evidence as Exhibit USA 396, and I quote from Page 213 of the original, and it is on Page 1 of the English translation, the second paragraph: "The relationship between the Reich and the States has been put on an entirely new basis never known in the history of the German people. It gives to the Reich Cabinet (Reichsregierung) unlimited power, it even makes it its duty to build a completely unified leadership and administration of the Reich. From now on there is only one national authority: that of the Reich. From now on, there is only one national authority: that of the Reich. Thus, the German Reich has become a unified State, and the entire administration in the States is carried out only by order of, or in the name of, the Reich. The State borders are now only administrative-technical boundaries, but no longer boundaries of sovereignty. In calm determination, the Reich Cabinet (Reichsregierung) realises step by step, supported by the confidence of the entire German people, the great longing of the Nation: the creation of the unified National Socialist German State." THE PRESIDENT: Colonel Storey. COLONEL STOREY: Yes, Sir? THE PRESIDENT: That document seems to me to be merely cumulative. You have established, and other counsel on behalf of the United States have [Page 86] established, that the Reich Ministers had power to make laws, and the question is whether you have given any evidence as to the criminal nature of the Reich Cabinet. COLONEL STOREY: If your Honour pleases, again it was included for the purpose of connecting one of the defendants here----- THE PRESIDENT: What I was pointing out was that it was merely cumulative. COLONEL STOREY: Yes, all right, Sir. It may be strictly cumulative. I will omit the next reference, which will probably also be cumulative and turn over to----- THE PRESIDENT: The same document, you mean? COLONEL STOREY: No, Sir. There is another document that I was going to offer, No. 2849. There is a quotation from another book; it probably bears on the same point. I will omit it also. The next is a reference to the Ministerial Council's being given legislative power. I do not believe this has been introduced before, that the Council itself was given legislative powers. That is in Article 2 of the decree of 30th August, 1939, Document 2018-PS; the ordinary Cabinet continued to legislate throughout the war. Obviously, because of the fusion of personnel between the Ministerial Council and the ordinary Cabinet, questions were bound to arise as to what form should lend its name to a particular law. Thus Dr. Lammers, the Chief of the Reich Chancellery and a member of both agencies, wrote a letter on 14th June, 1942, to the Plenipotentiary for Reich Administration about this question. This next document, if the Court please, it may not be necessary to read. It generally shows that both agencies continued to legislate side by side, and it would really be cumulative evidence. There were others that possessed legislative powers, besides the ones I have mentioned. Hitler, of course, had legislative power. Goering, as Deputy of the Four Year Plan, could and did issue decrees that had the effect of law, and the Cabinet delegated power to issue laws which could deviate from the existing ones, to the Plenipotentiaries of Economy and Administration and the Chief of the O.K.W., and to the so-called "3-Man College," the "3-Man College" having authority to legislate. This was done in the war-planning law, the Secret Defence Law of 1938, Document 2194-PS, Exhibit USA 36. These three officials, Frick, Funk and Keitel, however, were, as we have proved, also members of the Council of Ministers, as well as being part of the ordinary Cabinet. It can, therefore, be readily said, in the language of the Indictment, that the Reichsregierung possessed legislative powers of a very high order in the system of German government; and that they exercised such powers has in part already been demonstrated. I refer to that merely to show that it was a Secret Cabinet law -- without quoting -- that the executive and administrative powers of the Reich were concentrated in the Central Government primarily as the result of two basic Nazi laws that reduced the separate States (called Laender) to mere geographical divisions. If your Honour pleases, these laws are cited, and I believe it would be cumulative evidence if I undertook to chronicle them. I pass to the part at the bottom of Page 29. There were other steps taken towards centralisations. Let us see what powers the ordinary Cabinet would wield as a result. We have here a publication of 1934, which was edited by Dr. Wilhelm Stuckart, State Secretary in the Reich Ministry of the Interior, and Dr. Harry V. [Page 87] Rosen v. Hoewel, another official with the title of "Oberregierungsrat," in the Reich Ministry of the Interior. It is entitled "Administrative Law," Document 2959-PS, and I offer it as Exhibit USA 399. It details the powers and functions of all the ministers of the ordinary Cabinet, from which I will select but a few to illustrate the extent of control vested in the Reichsregierung. The quotation is from Page 2 of the translation and Page 66 of the original. "The Reich Ministers. There are at present twenty-seven Reich Ministers, namely...." May I say that the only purpose in offering this is to show over what each Minister had jurisdiction and to what his authority extended; for example, the Reich Minister for Foreign Affairs -- it details what he handles. The Reich Minister of the Interior follows in detail on the matters entrusted to his jurisdiction, and so on. THE PRESIDENT: Colonel Storey, may I ask you what has that to do with the criminality of the Reich Cabinet? COLONEL STOREY: The point, as I see it, again though it may be cumulative, your Honour, is to show how these defendants, and the others with them, formed a Cabinet, formed the Ministries, formed these councils, so that they could give semblance of legality to any action they determined to take, whether they were in session or not, and according to the dictates of the respective Ministers, in other words, showing a complete domination. THE PRESIDENT: I should have thought that was amply shown already.
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