The defendant declares that he has completely lost his memory since a long period of time, the period of which he can no longer determine.

The official Party declaration issued by the German Propaganda Ministry of 12 May 1941 even mentions "a disease which had been increasing over a period of years" and of "signs of mental derangement". English press reports also state that defendant's conduct after his landing in Scotland showed an absence of "mental clarity".

Those facts are important for the allegation of Defendant's irresponsibility as a result of morbid disorder of his mental capacity, and sufficient grounds for application numbered I. Those facts at the same time justify the examination of defendant's ability to plead. In the event of the Court's having already, on its own authority, entrusted a panel of experts with the preparation of a report, it would be fair to the defendant to concede the addition of several experts to be appointed by the Defense.

. . . .


Nuremberg, 7 November 1945