11 Dec. 45

that it would be easier for the Tribunal to locate the documents. Unfortunately, we did not have a sufficient number of tabs to do the work completely, and that would account for tabs which are missing on some of the document books.

It may illuminate the specific items of evidence which will be offered later if we first describe in rather general terms the elements of the Nazi foreign labor policy. It was a policy of mass deportation and mass enslavement, as I said a minute ago, and it was also carried out by force, by fraud, by terror, by arson, by means unrestrained by the laws of war and laws of humanity, or the considerations of mercy. This labor policy was a policy as well of underfeeding and overworking foreign laborers, of subjecting them to every form of degradation, brutality, and inhumanity. It was a policy which compelled foreign workers and prisoners of war to manufacture armaments and to engage in other operations of war directed against their own countries. It was a policy, as we propose to establish, which constituted a flagrant violation of the laws of war and of the laws of humanity.

We shall show that the Defendants Sauckel and Speer are principally responsible for the formulation of the policy and for its execution: that the Defendant Sauckel, the Nazis' Plenipotentiary General for Manpower, directed the recruitment, deportation, and the allocation of foreign civilian labor, that he sanctioned and directed the use of force as the instrument of recruitment, and that he was responsible for the care and the treatment of the enslaved millions; that the Defendant Speer, as Reich Minister for Armament and Munitions, Director of the Organization Todt, and member of the Central Planning Board, bears responsibility for the determination of the numbers of foreign slaves required by the German war machine, was responsible for the decision to recruit by force and for the use under brutal, inhumane, and degrading conditions of foreign civilians and prisoners of war in the manufacture of armaments and munitions, the construction of fortifications, and in active military operations.

We shall also show in this presentation that the Defendant Göring, as Plenipotentiary General for the Four Year Plan, is responsible for all of the crimes involved in the Nazi slave labor program. Finally, we propose to show that the Defendant Rosenberg, as Reich Minister for the Occupied Eastern Territories, and the Defendant Frank, as Governor of the Government General of Poland, and the Defendant Seyss-Inquart, as Reich Commissar for the occupied Netherlands, and the Defendant Keitel, as Chief of the OKW, share responsibility for the recruitment by force and terror and for the deportation to Germany of the citizens of the areas overrun or subjugated by the Wehrmacht.