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The identity and membership of the groups or
organizations referred to in the foregoing titles are hereinafter in
Appendix B more particularly defined
COUNT ONE THE
COMMON PLAN OR CONSPIRACY
(Charter, Article 6, especially 6 (a) ) III.
Statement of the Offense
All the defendants, with divers other persons, during a
period of years preceding 8 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, War Crimes, and Crimes against
Humanity, as defined in the Charter of this Tribunal, and, in accordance
with the provisions of the Charter, are individually responsible for
their own acts and for all acts committed by any persons in the
execution of such plan or conspiracy. 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. In the development and course of the common plan or
conspiracy it came to embrace the commission of War Crimes, in that it
contemplated, and the defendants determined upon and carried out,
ruthless wars against countries and populations, in violation of the
rules and customs of war, including as typical and systematic means by
which the wars were prosecuted, murder, ill-treatment, deportation for
slave labor and for other purposes of civilian populations of occupied
territories, murder and ill-treatment of prisoners of war and of persons
on the high seas, the taking and killing of hostages, the plunder of
public and private property, the indiscriminate destruction of cities,
towns, and villages, and devastation not justified by military
necessity. The common plan or conspiracy contemplated and came to
embrace as typical and systematic means, and the defendants determined
upon and committed, Crimes against Humanity, both within Germany and
within occupied territories, including murder, extermination,
enslavement, deportation, and other inhumane acts committed against
civilian populations before and during the war, and persecutions on
political, racial, or religious grounds, in execution of the plan for
preparing and prosecuting aggressive or illegal wars, many of such acts
and persecutions being violations of the domestic laws of the countries
where perpetrated.
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