13 Dec. 45

after the sentence has been served. Should a transfer into concentration camp immediately after the serving of the sentence not be possible, Bibelforscher will be detained in police prisons."

The labor unions, of which I think it is safe to say the majority are traditionally opposed to wars of aggression, also felt the full force of Nazi terror. A member of the American staff, Major Wallis, has already submitted evidence before this Tribunal concerning the conspirators' campaign against the trade unions. But the concentration camp was an important weapon in this campaign; and the Tribunal will recall that in Document Number 2324-PS, to which I made reference this morning, the Defendant Göring made it plain that members of the Social Democratic Party were to be confined in concentration camps. Now labor leaders were very largely members of that party, and they soon learned the horrors of protective custody. We refer to Document Number 2330-PS (Exhibit USA-237), which has already been received as part of USA Exhibit G, which consists of an order that one Joseph Simon should be placed in protective custody. We refer to the middle of the first page of the English translation of that order, beginning with the material under the word "reasons."

THE PRESIDENT: I think you should read the sentence before that — the two lines before it. The words are, "The arrestee has no right to appeal against the decree of protective custody."

MR. DODD: "The arrestee has no right to appeal against the application of protective custody." Then comes a title: "Reasons":

"Simon was for many years a member of the Socialist Party and temporarily a member of the Union Socialiste Populaire. From 1907 to 1918 he was Landtag deputy of the Socialist Party; from 1908 to 1930 Social Democratic City Counsellor (Stadtrat) in Nuremberg. In view of the decisive role which Simon played in the international trade unions and in regard to his connection with international Marxist leaders and central agencies, which he continued after the national recovery, he was placed under protective custody on the 3rd day of May 1933 and was kept, until 25 January 1934, in the Dachau Concentration Camp. Simon is under the grave suspicion that even after this date he played an active part in the illegal continuation of the Socialist Party. He took part in meetings which aimed at the illegal continuation of the Socialist Party and propagation of illegal Marxist printed matter in Germany. Through this radical attitude, which is hostile to the State, Simon directly endangers public security and order."

We do not wish to burden these proceedings with a multiplication of such instances, but we refer the Tribunal to documents