The Nizkor Project: Remembering the Holocaust (Shoah)

Shofar FTP Archive File: imt/tgmwc/tgmwc-03/tgmwc-03-22.08

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

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

     "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
                                                  [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.-

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

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

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

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

     "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

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

Home ·  Site Map ·  What's New? ·  Search Nizkor

© The Nizkor Project, 1991-2012

This site is intended for educational purposes to teach about the Holocaust and to combat hatred. Any statements or excerpts found on this site are for educational purposes only.

As part of these educational purposes, Nizkor may include on this website materials, such as excerpts from the writings of racists and antisemites. Far from approving these writings, Nizkor condemns them and provides them so that its readers can learn the nature and extent of hate and antisemitic discourse. Nizkor urges the readers of these pages to condemn racist and hate speech in all of its forms and manifestations.