2. The acts, conduct, plans, and enterprises charged in paragraph I of this count were carried out as part of a systematic program of genocide, aimed at the destruction of foreign nationals and ethnic groups by murderous extermination.

3. Beginning in May 1941, on the orders of Himmler, special task forces called "Einsatzgruppen" were formed from the personnel of the SS, the SD, the Gestapo, and other police units The primary purpose of these groups was to accompany the German Army into the eastern territories, and exterminate Jews gypsies, Soviet officials, and other elements of the civilian population regarded as racially "inferior" or "politically undesirable."

4. Initially four Einsatzgruppen were formed, each of which supervised the operation of a number of subordinate units called "Einsatzkommandos" or "Sonderkommandos." Some Einsatzgruppen had, in addition, other units for special purposes. Each Einsatzgruppe, together with its subordinate units consisted of about 500 to 800 persons. Einsatzgruppe A, operating mainly in the Baltic region, included Sonderkommandos la and lb and Einsatzkommandos 2 and 3. Einsatzgruppe B, operating mainly in the area towards Moscow, included Sonderkommandos 7a and 7b, Einsatzkommandos 8 and 9, and special units named Vorkommando Moscow (also known as Sonderkommando 7e) and Trupp Smolensk. Einsatzgruppe C, operating mainly in the area towardi Kiev, included Sonderkommandos 4a and 4b and Einsatzkommandos 5 and 6. Einsatzgruppe D, operating mainly in the area of southern Russia, included Sonderkommandos 10a and 10b andEinsatzkommandos 11a, 11b, and 12.

5. All of the defendants herein, as officers or staff members of

one or more Einsatzgruppen or their subordinate units, committed murders, atrocities, and other inhumane acts as more specifically set forth in paragraphs 6 to 9, inclusive, of this count.

6. Einsatzgruppe A and the units under its command committed murders and other crimes which included, but were not limited to, the following:

(A) During the period 22 June 1941 to 16 October 1941 in Lithuania, Latvia, Esthonia, and White Ruthenia, Einsatzgruppe A murdered 118,430 Jews and 3,398 Communists.

(B) On or about 4 July 1941 in the city of Riga, Sonderkommando la and Einsatzkommando 2, together with auxiliary police under their command, carried out pogroms in which all synagogues were destroyed and 400 Jews were murdered.

(C) During October 1941 in Esthonia, Einsatzkommando la, together with Esthonian units under their command, committed murders pursuant to a program for the extermination of all Jewish males over sixteen except doctors and Jewish elders.

(D) During the period 7 November 1941 to 11 November 1941 in Minsk, Sonderkommando lb murdered 6,624 Jews.

(E) During the period 22 June 1941 to 16 January 1942 in its operational areas, Einsatzkommando 2 murdered 33,970 persons.

(F) On 30 November 1941 in Riga, 20 men of Einsatzkommando 2 participated in the murder of 10,600 Jews.

(G) During the period 22 June 1941 to 19 September 1941 in Lithuania, Einsatzkommando 3 murdered 46,692 persons.

(H) During the period 22 June 1941 to 10 August 1941 in the area of Kovno [Kaunas] and Riga, Einsatzgruppe A murdered 29,000 persons.

(I) During the period 2 October 1941 to 10 October 1941 in the vicinity of Krasnogvardeisk, Einsatzgruppe A murdered 260 persons.

(J) During the period 15 October 1941 to 23 October 1941 in the vicinity of Krasnogvardeisk, Einsatzgruppe A murdered 156 persons.

(K) During the period 24 October 1941 to 5 November 1941 in the vicinity of Krasnogvardeisk, Ei-nsatzgruppe A murdered 118 persons.

(L) On 20 November 1941 in the vicinity of Krasnogvardeisk, Einsatzgruppe A murdered 855 persons.

(M) In about December 1941 in the ghetto in Vitebsk, units of Einsatzgruppe A murdered 4,090 Jews.

(N) On 22 December 1941 in Vilnyus (Vilna], units of Einsatz gruppe A murdered 402 persons including 385 Jews.

(O) On 1February 1942 in Loknya, units of Einsatzgruppe A murdered the 38 gypsies and Jews remaining there.

(P) On 2 and 3 March 1942 in Minsk, units of Einsatzgruppe A murdered 3,412 Jews.

(Q) On 2 and 3 March 1942 in Baranovichi, units of Einsatzgruppe A murdered 2,007 Jews.

(R) On 17 March 1942 in Ilya, east of Vileika, units of Einsatzgruppe A murdered 520 Jews.

(S) On or about 7 April 1942 in Kovno and Olita, Lithuania, units of Einsatzgruppe A murdered 44 persons.

(T) During the period 10 April 1942 to 24 April 1942 in Latvia, units of Einsatzgruppe A murdered 1,272 persons, including 983 Jews, 204 Communists and 71 gypsies.

7. Einsatzgruppe B and the units under its command committed murders and other crimes which included, but were not limited to, the following:

(A) In about July 1941 in the city of Minsk, units of Einsatzgruppe B murdered 1,050 Jews and liquidated political officials, "Asiatics" and others.

(B) During the period 22 June 1941 to 14 November 1941 in the vicinity of Minsk and Smolensk, Einsatzgruppe B murdered more than 45,467 persons.

(C) On 15 October 1941 in Mogilev, units of Einsatzgruppe B murdered 83 "Asiatics."

(D) On 19 October 1941 in Mogilev, units of Einsatzgruppe B participated in the murder of 3,726 Jews.

(E) On 23 October 1941 in the vicinity of Mogilev, units of Einsatzgruppe B murdered 279 Jews.

(F) During the period 22 June 1941 to 14 November 1941 in its operational areas, Sonderkomrnando 7a murdered 1,617 persons.

(G) In September or October 1941 in Sadrudubs, Sonderkommando 7a murdered 272 Jews.

(H) During the period 6 March 1942 to 30 March 1942 in the vicinity of Klintsy, Sonderkommando 7a murdered 1,585 Jews and 45 gypsies.

(I) During the period 22 June 1941 to 14 November 1941 in its operational areas, Sonderkommando 7b murdered 1,822 persons.

(J) During the period from September to October 1941 in Rechitsa, White Ruthenia, Sonderkomrnando 7b murdered 216 Jews.

(K) During the period 6 March 1942 to 30 March 1942 in the vicinity of Bryansk, Sonderkommando 7b murdered 82 persons, including 27 Jews.

(L) During the period 22 June 1941 to 14 November 1941 in its operational areas, Einsatzkommando 8 murdered 28,219 persons.

(M) In September or October 1941 in the area of Shklov, Einsatzkommando 8 murdered 627 Jews and 812 other persons.

(N) In September or October 1941 in Mogilev, Einsatzkommando 8 participated in the murder of 113 Jews.

(0) In September or October 1941 in Krupka, Einsatzkommando 8 murdered 912 Jews.

(P) In September or October 1941 in Sholopaniche, Einsatzkommando 8 murdered 822 Jews.

(Q)During the period 6 March 1942 to 30 March 1942 in the vicinity of Mogilev, Einsatzkommando 8 murdered 1,609 persons, including 1,551 Jews and 33 gypsies.

(R) On 8 October 1941 in the ghetto of Vitebsk, Einsatzkommando 9 began murdering Jews and by 25 October 1941, 3,000 Jews had been executed.

(S) During the period 6 March 1942 to 30 March 1942 in the vicinity of Vitebsk, Einsatzkommando 9 murdered 273 persons, including 170 Jews.

(T) During the period 22 June 1941 to 14 November 1941 in its operational areas, the group staff of Einsatzgruppe B and the Vorkommando Moscow murdered 2,457 persons.

(U) During the period 22 June 1941 to 20 August 1941 in the vicinity of Smolensk, the group staff of Binsatzgruppe B and the Vorkommando Moscow murdered 144 persons.

(V) In September or October 1941 in Tatarsk, the group staff of Einsatzgruppe B and the Vorkornmando Moscow murdered all rnale Jews.

(W) During the period 6 March to 30 March 1942 in the vicinity of Roslavl, Vorkommando Moscow murdered 52 persons.

(X) During the period 6 March 1942 to 30 March 1942 in the vicinity of Smolensk, Trupp Smolensk murdered 60 persons, inluding 18 Jews.

8. Einsatzgruppe C and the units under its command committed murders and other crimes which included, but were not limited to, the following:

(A) During the period 22 June 1941 to 3 November 1941 in the vicinity of Zhitomir, Novo Ukrainka and Kiev, Einsatzgruppe C murdered more than 75,000 Jews.

(B) On 19 September 1941 in Zhitomir, Einsatzgruppe C murdered 3,145 Jews and confiscated their clothing and valuables.

(C) During the period 22 June 1941 to 29 July 1941 in the vicinity of Zhitomir, Sonderkommando 4a murdered 2,531 persons.

(D) During the period 22 June 1941 to 12 October 1941 in its operational areas, Sonderkommando 4a murdered more than 61,000 persons.

(E) During the period from 27 June to 29 June 1941 in the

vicinity of Sokal and Lutsk, Sonderkommando 4a murdered 300 Jews and 317 Communists.

(F) In July or August 1941 in Fastov, Sonderkommando 4a murdered all the Jews between the ages of 12 and 60.

(G) In September or October 1941 in the vicinity of Vyrna and Dederev, Sonderkommando 4a murdered 32 gypsies.

(H) On 29 and 30 September 1941 in Kiev, Ensatzkommando 4a, together with the group staff and police units, murdered 83,771 Jews and confiscated their clothing and valuables.

(I) On 8 October 1941 in Jagotin, Sonderkommando 4a murdered 125 Jews.

(J) On 23 November 1941 in Poltava, Sonderkommando 4a murdered 1,538 Jews.

(K) In about July 1941 in Tarnopol, Sonderkommando 4b murdered 180 Jews.

(L) During the period from 13 September to 26 September 1941 in the vicinity of Kremenchug, Sonderkomrnando 4b murdered 125 Jews and 103 political officials.

(M) During the period 4 October 1941 to 10 October 1941 in Poltava, Sonderkommando 4b murdered 186 persons.

(N) From about 11 October 1941 to 30 October 1941 in the vicinity of Poltava, Sonderkommando 4b murdered 595 persons.

(0) During the period 14 January 1942 to 12 February 1942 in the vicinity of Kiev, Sonderkommando 4b murdered 861 persons, including 139 Jews and 649 political officials.

(P) During the period from February 1942 to March 1942 in the vicinity of Artemovsk, Sonderkommando 4b murdered 1,317 persons, including 1,224 Jews and 63 "political activists."

(Q) During the period from 22 June 1941 to 10 November 1941 in its operational areas, Einsatzkommando 5 murdered 29,644 persons.

(R) During July or August 1941 in Berdichev, Einsatzkommando 5 murdered 74 Jews.

(S) During the period 7 September 1941 to 5 October 1941 in the vicinity of Berdichev, Einsatzkommando 5 murdered 8,800 Jews and 207 political officials.

(T) On 22 and 23 September 1941 in Uman, Einsatzkommando 5 murdered 1,412 Jews.

(U) During the period 20 October 1941 to 26 October 1941 in the vicinity of Kiev, Einsatzkommando 5 murdered 4,372 Jews and 36 political officials.

(V) During the period from 23 November 1941 to 30 November 1941 in the vicinity of Rovno, Einsatzkommando 5 murdered 2,615 Jews and 64 political officials.

(W) During the period from 12 January 1942 to 24 January

1942 in the vicinity of Kiev, Einsatzkommando 5 murdered about 8,000 Jews and 104 political officials.

(X) During the period from 24 November 1941 to 30 November 1941 in the vicinity of Dnepropetrovsk, Einsatzkommando 6 murdered 226 Jews and 19 political officials.

(Y) From about 10 January 1942 to 6 February 1942 in the vicinity of Stalino, Einsatzkommando 6 murdered about 149 Jews and 173 political officials.

(Z) In about February 1942 in the vicinity of Stalino, Einsatzkommando 6 murdered 493 persons, including 80 "political activists" and 369 Jews.

9.Einsatzgruppe D and the units under its command committed murders and other crimes which included, but were not limited to, the following:

(A) During the period from 22 June 1941 to July 1943, Einsatzgruppe D, in the area of southern Russia, murdered more than 90,000 persons.

(B) On 15 July 1941 in the vicinity of Beltsy, Sonderkommando 10a murdered 45 persons, including the Counsel of Jewish Elders.

(C) In July 1941 in the vicinity of Chernovitsy, Sonderkommando 10b murdered 16 Communists and 682 Jews.

(D) During the period 22 June 1941 to 7 August 1941 in the vicinity of Kichinev, Einsatzkommando lla murdered 551 Jews.

(E) In about July 1941 in Tighina, Einsatzkommando llb murdered 151 Jews.

(F) In about December 1941 in the vicinity of Simferopol, Einsatzkommando 1lb murdered over 700 persons.

(G) During the period from 22 June 1941 to 23 August 1941 in Babehinzy, Einsatzkommando 12 murdered 94 Jews.

(H) During the period 15 July 1941 to 30 July 1941 in the vicinity of Khotin, Einsatzgruppe D murdered 150 Jews and Communists.

(I) During the period 19 August 1941 to 15 September 1941 in the vicinity of Nikolaev, Einsatzgruppe D murdered 8,890 Jews and Communists.

(J) During the period 16 September 1941 to 30 September 1941 in the vicinity of Nikolaev and Kherson, Einsatzgruppe D murdered 22,467 Jews.

(K) During the period 1 October 1941 to 15 October 1941 in the area east of the Dnepr, Einsatzgruppe D murdered 4,891 Jews and 46 Communists.

(L) During the period 15 January 1942 to 31 January 1942 within its operational areas, Einsatzgruppe D murdered 3,601 persons, including 3,286 Jews and 152 Communists.

(M) During the period 1 February 1942 to 15 February 1942

within its operational areas, Einsatzgruppe D murdered 1,451 persons, including 920 Jews and 468 Communists.

(N) During the period 16 February 1942 to 28 February 1942 within its operational areas, Einsatzgruppe D murdered 1,615 persons, including 729 Jews, 271 Communists and 421 gypsies and other persons.

(0) During the period I March 1942 to 15 March 1942 within its operational areas, Einsatzgruppe D murdered 2,010 persons, including 678 Jews, 359 Communists, and 810 gypsies and other persons.

(P) During the period 15 March 1942 to 30 March 1942 within its operational areas, Einsatzgruppe D murdered 1,501 persons, including 688 Jews, 405 Communists, and 261 gypsies and other persons.