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the war for the reception of nonlocal workers. The necessity for this
was created by the fact that the industrial area of Central Germany, because of
its rich lignite deposits, had developed especially rapidly since the First
World War, so that soon there occurred a shortage of labor, and housing for the
influx of workers could not quickly enough be provided. In consequence, it was
found necessary to establish a camp, which before the war was especially
carefully and especially comfortably equipped. The foreign workers were then
later on placed in this camp, which consequently had to undergo some
extensions.
Concerning the manifold legal questions which resulted from
the employment of foreign workers, one of my colleagues has already indicated
and explained the position taken up by the defense. I do not wish to tire the
Court with further legal statements on this point. I should like, however, to
establish in principle that the serious charge of the utilization of slave
labor requires substantial argument, and merely to establish that the workers
were being used against their will is not sufficient. In that case, every
employer in Germany would have rendered himself liable to punishment, since
all, even the smallest undertaking and enterprises had foreign workers. Every
farmer, every housewife who employed Polish or Ukrainian domestic helpers,
would thus be a war criminal, a consequence which has not so far been drawn
either by the Allies or by the German authorities occupied with the punishment
of war criminals. Here again, therefore, some sensible limitation must be made,
of which the prosecution too, is apparently not unaware, since it is
endeavoring to prove inhuman conditions in the camps, in the treatment, and in
the working conditions of the foreign workers. In this respect, the material
submitted by the prosecution regarding the plants of the Works Combine Central
Germany (Betriebsgemeinschaft Mitteldeutschland) is scanty. It consists solely
of the affidavit of a French worker, who has so far not even been put up for
cross-examination. Should this not subsequently be done, I shall object to the
admission of this affidavit.
I myself, however, am in the position to
prove that it was my client in particular who, with an understanding based on
extensive experience abroad and a warm feeling for the workers who had come
into a strange land, recognized what had to be done to lighten the burden of
the foreign workers; who constantly, in works and departmental discussions,
gave directives, suggestions, and orders to this end; who saw where the most
energetic help could be rendered; and who finally, also, had the satisfaction
to see that the American administration officers |
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