 |
took a second domicile in Berlin and practically limited himself from
there on to the supervision of the department "M," which erroneously has been
interpreted by the prosecution as meaning "metals," and to odd jobs in the
metal field.
Turning now to count one of the indictment, I may refer to
the motion of the defense filed with this Tribunal during the morning session
of December 17th, in which the defense submitted that the prosecution have
failed to make out a prima facie case because, according to the grounds
of the IMT judgment, the responsibility for crimes against peace is limited to
a small group of leading personalities who had a special knowledge of certain
secret plans of Hitler.
Apart from this, the defense will introduce
evidence that Paul Haefliger had no knowledge whatsoever of any aggressive war
being aimed at by the German Government and that, in view of his actual
position, he never was asked about nor was concerned with any question relating
to technical problems of planning and erecting Mob-plants.
Moreover, it
is submitted that Paul Haefliger is a Swiss citizen and, for the time from 1934
up to 1938, was the Swiss Consul in Frankfurt. Therefore his collaborators,
insofar as they were under pledge of secrecy by regulations, had to withhold
from him information about such matters.
As to the stock-piling of
nickel, it will be shown that this, in view of the prevailing conditions, was a
natural precaution which by no means meant a preparation for an aggressive war.
Apart from this, evidence will be introduced on Paul Haefliger's
attitude towards the various foreign business partners, showing that he always
conducted negotiations on a purely businesslike and friendly basis, never
pursuing any aims of weakening the potential and development of non-German
industries, not to speak of making use of such opportunities for Nazi
propaganda. In addition, the defense will introduce extracts from speeches
which Paul Haefliger held in his capacity as Swiss Consul before the Swiss
colony in Frankfurt, showing his democratic spirit and his love for peace. For
completeness' sake, I submit that Paul Haefliger never was a member of the Nazi
Party nor of any of its affiliations, nor did he hold any position in the
government or the semi-official economic group "Chemical Industry"
(Reichsgruppe Chemie).
Turning now to count two of the indictment, the
cases of alleged spoliation in Austria and Sudetenland-Czechoslovakia have been
already dealt with from a legal point of view in the motion filed by the
defense with this Tribunal during the morning session of December 17th.
|
292 |
. 
