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expediency, also deal with all pertinent questions concerning the
local assignment to plants of civilian foreign workers and concentration camp
inmates. Avoiding all principal issues, I shall restrict myself exclusively to
contesting the individual charges made by the prosecution and I shall attempt
to present the Tribunal with a true and exhaustive picture of conditions at the
Essen Gusstahlfabrik, this oldest and most important enterprise of the firm of
Krupp, inasmuch as it was brought into the public eye by the prosecution in
connection with the assignment of prisoners of war, civilian foreign workers,
and in one case also concentration camp inmates.
I am afraid it will be
unavoidable to go into that part of the defense at greater length than would
have been necessary, had the argumentation of the prosecution been more precise
and to the point.
Dr. Behringer will supplement the discussion of that
subject and deal with the questions of camps and food for foreign workers and
welfare outside of their place of work. Other gentlemen will discuss the local
problems of the other Krupp plants.
I am firmly convinced that in
conjunction with my colleague, I shall be able to prove to the Tribunal that in
connection with the assignment of prisoners of war and foreign workers, none of
these defendants bears any personal guilt which, according to the principles of
criminal law of your country and that of all other civilized nations and
according to the practice of the Nuernberg Military Tribunals, alone could
provide the necessary prerequisite for their conviction.
Up to now I
have restricted my remarks to my task of presenting the general case of the
defense. If I mention the name of my client, Dr. Heinrich Lehmann, only at the
end, this is done so as to draw a clear dividing line by its mere
position on the paper between the problems under discussion and the
person of the defendant Dr. Lehmann, who knows himself free from any guilt. I
openly admit that, up to this day, I have not been able to understand why this
man, whose position in the firm did not endow him with any executive power,
should be in the dock as a defendant, as the only one apart from his
codefendant Kupke out of the number of his numerous colleagues in identical or
similar positions. In all the Nuernberg trials up to now only such persons were
indicted who either were personally charged with a serious crime or who, owing
to their special position within the State, the army, the Party, or industry
were held responsible for certain conditions or incidents, which constituted
crimes according to the definitions of Control Council Law No. 10. As the
defendant Dr. Lehmann is not even alleged to have personally committed
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