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| G. Opening Statement for Defendant
Hoerlein* |
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DR. NELTE (counsel for defendant Hoerlein) : Dr. Nelte for the
defendant Professor Dr. Heinrich Hoerlein. Mr. President, Your Honors:
defendant Professor Hoerlein, together with ail the other defendants, is
charged with having participated in the planning, preparation, initiation, and
waging of wars of aggression, and invasions of other countries.
This
count of the indictment concerns the over-all responsibility which Professor
Hoerlein is held to have assumed as a member of Farben's Vorstand. In this
connection, it is essential to prove the extent to which Professor Hoerlein has
participated in decisions and measures which he knew had as their objective the
planning, preparation, initiation, and the waging of wars of aggression.
We reserve to ourselves to present at a later date the legal issues
arising from the problem of over-all responsibility and conspiracy.
Professor Hoerlein, in an affidavit, will explain his position, his
functions, and his competencies within Farben's administrative structure —
the Vorstand and the Central Committee. This will reveal a picture of a
decentralized business activity which, by virtue of Farben's immense size,
rendered it practically impossible for any individual member of the Vorstand to
be informed of details of the activities of other members of the Vorstand, at
least as to their motives and purposes.
Professor Hoerlein, who,
jointly with Professor Lautenschlaeger and Direktor Mann, represented the
pharmaceutical branch of Sparte II as well as the pharmaceutical plants and
laboratories in Elberfeld-Leverkusen, will, when called to the stand, testify
and introduce documentary evidence to the effect that the pharmaceutical branch
did not benefit from the National Socialist movement and regime, nor from the
Wehrmacht; that is, from rearmament.
The development of this branch of
Farben was not influenced by rearmament, but by developments in the
international field, namely, by export. These developments induced the leading
men, either from necessity or from conviction, to adopt an attitude of
conciliation and peace among nations. Moreover, proof will be submitted that
plans for the activities in France, decided upon in July 1939, and the plans
for Russia, discussed in October 1940, preclude the suspicion that the leading
men of the pharmaceutical branch — as, for instance, Professor Hoerlein
— believed in an im- […pending] |
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* Tr. pages 4760-4777, 18
December 1947. The final statement of the defendant Hoerlein to the Tribunal
appears in section XII B 4. volume VIII, this series.
244 |
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