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| 1. INDICTMENT¹
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The United States of America, by the
undersigned Telford Taylor, Chief of Counsel for War Crimes, duly appointed to
represent said Government in the prosecution of war criminals, charges that the
defendants herein committed war crimes and crimes against humanity, as defined
in Control Council Law No. 10, duly enacted by the Allied Control Council on 20
December 1945. These crimes included murders, brutalities, cruelties, tortures,
atrocities, deportation, enslavement, plunder of public and private property,
persecutions, and other inhumane acts as set forth in counts one, two, three,
and four of this indictment.
The persons accused as guilty of these
crimes and accordingly named as defendants in this case are
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FRIEDRICH FLICK The
principal proprietor, dominating influence, and active head of a large group of
industrial enterprises (the most important of which are described in appendix A
hereof) including coal and iron mines and steel producing and fabricating
plants, sometimes collectively referred to herein as the "Flick Concern";²
member of the Aufsichtsrat (supervisory board) of numerous other large
industrial and financial companies; Wehrwirtschaftsfuehrer (military economy
leader); member of the Praesidium of Reichsvereinigung Kohle and of
Reichsvereinigung Eisen (official bodies for regulation of the coal and iron
and steel industries); member of the Kleine Kreis ("Small Circle"), a small
group of leaders of the iron, coal, and steel industry which exercised great
influence over the industry for many years before and during the war; member of
the Verwaltungsrat (administrative board) of the Bergund Huettenwerke Ost
G.m.b.H. (BHO), a government-sponsored company for exploitation of the Russian
mining and smelting industries; member of the Beirat (advisory council) of the
Wirtschaftsgruppe Eisenschaffende Industrie (Economic Group of the Iron
Producing Industry) ; member of the "Circle of Friends" of Himmler, which gave
financial and other support to the Schutzstaffeln der Nationalsozialistischen
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__________ ¹ This indictment, dated
18 March 1947, was sometimes referred to as the "amended indictment" since the
initial indictment in the Flick Case was dated 6 February 1947. The indictment
of 18 March 1947 superseded and replaced the initial indictment. Amendments to
the indictment of 18 March 1947 made pursuant to Tribunal orders upon motion of
the prosecution daring the course of the trial are indicated hereinafter by
footnotes. ² The German word "Konzern" is sometimes used in place of
"Concern" throughout this case.
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