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| COUNT ONE |
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1. Between September 1939 and May 1945 all
the defendants committed war crimes and crimes against humanity, as defined by
Article II of Control Council Law No. 10, in that they were principals in,
accessories to, ordered, abetted, took a consenting part in, were connected
with plans and enterprises involving, and were members of organizations or
groups connected with: enslavement and deportation to slave labor on a gigantic
scale of members of the civilian populations of countries and territories under
the belligerent occupation of, or otherwise controlled by Germany; enslavement
of concentration camp inmates, including German nationals; and the use of
prisoners of war in war operations and work having a direct relation with war
operations, including the manufacture and transportation of armaments and
munitions. In the course of these activities hundreds of thousands of persons
were enslaved, deported, ill-treated, terrorized, tortured, and murdered.
2. The acts, conduct, plans, and enterprises charged in paragraph 1 of
this count were carried out as part of the slave-labor program of the Third
Reich, in the course of which millions of persons, including women and
children, were subjected to forced labor under cruel and inhumane conditions
which resulted in widespread suffering and many deaths. At least 5,000,000
workers were deported to Germany. The conscription of labor was accomplished in
many cases by drastic and violent methods. Workers destined for the Reich were
sent under guard to Germany, often packed in trains without adequate heat,
food, clothing, or sanitary facilities. Other inhabitants of occupied countries
were conscripted and compelled to work in their own countries to assist the
German war economy. The resources and needs of the occupied countries were
completely disregarded in the execution of the said plans and enterprises, as
were the family honor and rights of the civilian populations involved.
Prisoners of war were assigned to work directly related to war operations,
including work in armament factories. The treatment of slave laborers and
prisoners of war was based on the principle that they should be fed, sheltered,
and treated in such a way as to exploit them to the greatest possible extent at
the lowest expenditure.
3. During the period from approximately May
1942 to 1945, the defendant Flick was a member of the Praesidium (governing
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