13 Dec.
45
"A: Of course, yes. I didn't mean to
imply anything like that."
And on Page 15 of this same interrogation, beginning with the 13th
Paragraph of the English text and Page 20 in the German text, we find
this question:
"Q: Did you ever discuss, by the way,
the requirements of Krupp for foreign labor?
"A: It is certain that it was reported to me what lack Krupp had
in foreign workers.
"Q: Did you ever discuss it with any of the members of the Krupp
firm?
"A: I cannot say that exactly; but during the time of my
activities I visited the Krupp factory more than once and it is
certain that this was discussed, that is, the lack of manpower."
Before closing I should like to take 2 minutes of the time of the
Tribunal to refer to what we consider to be some of the applicable laws
of the case for the assistance of the Tribunal in considering these
documents which we have offered.
We refer, of course, first of all, to Sections 6 (b) and 6 (c) of the
Charter of this Tribunal. We also say that the acts of the conspirators
constituted a flagrant violation of Articles 46 and 52 of the
Regulations annexed to the Hague Convention Number IV of 1907.
Article 46 seeks to safeguard the family honor, the rights and the
lives of persons in areas under belligerent occupation.
Article 52 provides in part that:
"Requisitions in kind and services
shall not be demanded from municipalities or inhabitants except for
the needs of the army of occupation. They shall be in proportion to
the resources of the country."
We say that these conspirators violated this article because the labor
which they conscripted was not used to satisfy the needs of the army of
occupation, but on the contrary, was forcibly removed from the occupied
areas and exploited in the interest of the German war effort.
Finally, we say that these conspirators and particularly the
Defendants Sauckel and Speer by virtue of their planning, of
their execution, and of their approval of this program, which we have
been describing yesterday and today, the enslavement and the misuse of
the forced labor of prisoners of war that for this they bear a
special responsibility for their Crimes against Humanity and their War
Crimes.
THE PRESIDENT: Are you finishing, Mr. Dodd?