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Concerning count two, it appears to me that the legal opinions set
forth by the prosecution are not suitable for justifying the charge of criminal
conduct by my client. I shall argue this aspect in my final pleadings. Today I
want to point out only one idea, namely the concept of a total European
economic area, which formerly gained weight in many leading economic circles of
Europe. An idea which, even today, though in a somewhat different form, is
proposed by many political and economic experts, including some in America.
These viewpoints shaped my client's aims to maintain, operate, and improve, as
far as possible, these foreign enterprises in the general interest of the
national economy as well as for the welfare of the employees and laborers.
My client took part in negotiations leading to the founding of
Francolor. The defense will prove that the founding of Francolor was based on
sound economic considerations. It was intended to promote mutually satisfactory
cooperation in the fields of dye-stuffs and organic products, and to eliminate
frictions which had persisted for decades. Farben put at the disposal of the
above-mentioned spheres of work its full treasure of technical experience. It
paid for the transfer of French participation rights, amounts equal to the
value of the plants and rights taken over.
I now finally turn to count
three, concerning slave labor. In this count, the prosecution made the most
serious charges, morally speaking. As far as these accusations are directed
against any of the defendants, they bear the wrong address. The defendants
cannot be charged as criminals because foreign workers and also
concentration-camp prisoners were employed against their will in Farben works.
The defense shall offer evidence that, in these instances, Farben merely
executed binding orders issued by competent authorities concerning the
allocation and employment of foreign workers, prisoners of war, and
concentration-camp inmates, in the same manner as all of German industry was
compelled to do. Any resistance to these orders was entirely impossible. It
would have been nipped in the bud immediately and punished by the most drastic
measures, as sabotage of production ordered by the state, without any prospect
whatever of changing the labor conditions of these workers.
Dr. ter
Meer shall tell you, himself, on the witness stand, what he knew about the
employment of foreign workers drafted for labor service, and about the
utilization of concentration-camp inmates. He emphatically refutes the charge
that he knew anything at all about ill-treatment. Your Honors, you have come
from America to pronounce a verdict in Europe. You are citizens of the United
States of North America, and you are to pronounce sentence upon these Germans.
Yours is the duty to sit in judg- [
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