23 Nov. 45

"All the defendants, with divers other persons, during a period of years preceding 8th May 1945, participated as leaders, organizers, instigators, or accomplices in the formulation or execution of a Common Plan or Conspiracy to commit, or which involved the commission of, Crimes against Peace, as defined in the Charter of this Tribunal.... The Common Plan or Conspiracy embraced the commission of Crimes against Peace, in that the defendants planned, prepared, initiated, and waged wars of aggression, which were also wars in violation of international treaties, agreements,or assurances."

The statement of offense under Count Two of the Indictment is also relevant at this point. It must be obvious that essentially Counts One and Two interlock in this Indictment. The substance of the offense stated under Count Two, Paragraph V of the Indictment is this:

"All the defendants with divers other persons, during a period of years preceding 8 May 1945, participated in the planning, preparation, incitation, and waging of wars of aggression which were also wars in violation of international treaties,agreements, and assurances."

The emphasis in the statement of offense under Count One of the Indictment is on the Common Plan or Conspiracy. The emphasis under Count Two of the Indictment is on the substantive crimes to which the conspiracy related and which were committed in the course of and pursuant to that conspiracy.

I should hasten to add at this point that in the division of the case as between the Chief Prosecutors of the four Prosecuting Governments, primary responsibility for the presentation of evidence supporting Count One has been placed on the American prosecutor, and primary responsibility for the presentation of the evidence supporting Count Two of the Indictment has been placed ton the British prosecutor.

But as we shall show somewhat later, there will to some extent be a cooperative effort as between the two prosecutors to present certain phases of both counts together. In addition to the statement of offense relating to illegal war in Paragraph III under Count One of the Indictment, Count One also contains what amounts to a bill of particulars of that offense. In so far as those particulars relate to illegal war, they are contained in Paragraph IV (F) of the Indictment which is set out in the English text on Page 7 through the top of Page 10 under the general heading Utilization of Nazi Control for Foreign Aggression." The allegations of this bill of particulars have been read in open court,