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civilized nations, the internal penal laws of the countries in which such crimes were committed, and Article 6 (b) of the Charter.

IX. Individual, Group and Organization Responsibility for the Crimes Stated in Count Three.

Reference is hereby made to Appendix A of this Indictment for a statement of the responsibility of the individual defendants for the charge set forth in Count Three of the Indictment.

Reference is hereby made to Appendix B of this Indictment for a statement of the responsibility of the groups and organizations named herein as criminal groups and organizations for the crime set forth in this part three of the Indictment.

THE PRESIDENT: I will now call upon the Chief Prosecutor for the Soviet Union.

LIEUTENANT COLONEL J. A. OZOL (Assistant Prosecutor for the U.S.S.R.): COUNT THREE--WAR CRIMES.

All the defendants committed War Crimes between 1 September 1939 and 8 May 1945 in Germany and in all those countries and territories occupied by the German Armed Forces since 1 September 1939, and in Austria, Czechoslovakia, Italy, and on the High Seas.

All the defendants, acting in concert with others, formulated and executed a Common Plan or Conspiracy to commit War Crimes as defined in Article 6 (b) of the Charter. This plan involved, among other things, the practice of `'total war" including methods of combat and of military occupation in direct conflict with the laws and customs of war, and the commission of crimes perpetrated on the field of battle during encounters with enemy armies, and against prisoners of war, and in occupied territories against the civilian population of such territories.

The said War Crimes were committed by the defendants and by other persons for whose acts the defendants are responsible (under Article 6 of the Charter) as such other persons when committing the said War Crimes performed their acts in execution of a common plan and conspiracy to commit the said War Crimes, in the formulation and execution of which plan and conspiracy all the defendants participated as leaders, organizers, instigators, and accomplices.

These methods and crimes constituted violations of international conventions, of internal penal laws, and of the general principles of criminal law as derived from the criminal law of all civilized nations, and were involved in and part of a systematic course of conduct.

(A) Murder and ill-treatment of civilian populations of or in occupied territory and on the High Seas.