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However, the prosecution has not produced any evidence whatever in
this
respect.
In
regard to this point I make the motion: that the Court quash proceedings as far
as they concern paragraphs 53 and 56 of the indictment.
By way of
precaution I offer to submit proof, by the introduction of documents and
affidavits and by an examination of the defendant Hoerlein on the witness
stand, that the assertion of the prosecution not only is not true, but that
through the discoveries made in Farben's Elberfeld works, which was organized
and managed by Professor Hoerlein, every year millions of human lives were
saved, and health can be restored to hundreds of millions of human beings if
the nations responsible for the territories concerned make use of these
discoveries. The number of deaths from malaria alone, against which atabrine
has proved to be the principal preventive, has been estimated by diverse
authorities to be between 3½ and 8 millions a year. The number of
persons suffering from malaria is estimated to be between 500 and 800 millions,
which corresponds to from one-quarter to one-third of the present world
population.
Count two, as far as it concerns "German plunder in the
West," will be dealt with in its entirety by other representatives of the
defense.
Professor Hoerlein is mentioned in connection with the second
contract concluded by Farben with Rhône-Poulenc.
It can be seen
from these documents and from correspondence to be submitted, that Hoerlein
recognized the interests of the French partners in the most loyal manner, and
that negotiations with representatives of Rhône-Poulenc were carried on
in a friendly atmosphere.*
In regard to this, the defendant Hoerlein
will make a statement on the witness stand. Moreover, I shall introduce an
affidavit by Dr. Mietzsch, who was the constant companion of Professor Hoerlein
during the various technical discussions. An affidavit of the Generaldirektor
of Rhône-Poulenc will show to you that Professor Hoerlein proved his
unconditional loyalty by his deeds.
Concerning paragraph 128 of the
indictment: The issues in regard to the procurement, employment, and treatment
of foreign workers in general will be dealt with by Dr. Hellmuth Dix.
No evidence has been offered by the prosecution in regard to
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* Document NI-8611,
Prosecution Exhibit 1275, not reproduced herein, is a letter from Bayer
confirming agreements with Rhône-Poulenc regarding "future collaboration"
between the two firms. It was signed by Hoerlein and Mann.
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