Morning Session
DR. FRITZ SAUTER (Counsel for the Defendant Von Schirach): Mr. President, yesterday a table depicting the construction of the Reich Cabinet, one of the accused organizations, was shown on the screen here. On this chart the Defendant Von Schirach was also listed under the heading, “Other participants in the meetings of the Cabinet.” The Defendant Von Schirach has explained to me and asked me to inform the Tribunal that he never took part in any meeting of the Reich Cabinet, that he was never named a member of the Reich Cabinet, and that he never had a part in any decision of the Reich Cabinet.
THE PRESIDENT: The point that you are taking seems to the Tribunal to be premature. This is not the stage at which you are to argue the question whether your client is a member of the Reich Cabinet or not. The argument upon the whole question will take place after the evidence and after the Prosecution have had the opportunity of putting forward their arguments as to the criminal nature of the Reich Cabinet. You or other counsel on behalf of those concerned will be able to put forward your arguments. We do not desire to hear arguments now about the criminal nature, but to hear the evidence. Is that clear?
DR. SAUTER: Yes. I shall then return to this point during the examination of witnesses, and prove that the Defendant Von Schirach was never a member of the Reich Cabinet. Thank you.
COL. STOREY: If the Tribunal please, yesterday afternoon we had just started on the participation of the SA in the first point—the dissemination of ideology or propaganda. In an article which appeared in Der SA-Mann, at Page 1 of the issue of January 1934, which is Document 3050-PS; and I refer to Page 25 of the English translation, if Your Honor pleases, the portion shown in red brackets—it is dated the 6th of January 1934:
“The new Germany would not have been without the SA man; and the new Germany would not go on existing if the SA man would now, with the feeling of having fulfilled his duty, quietly, unselfishly, and modestly step aside, or if the new State would send him home much like the Moor who has done his duty. On the contrary, the SA man, following the will of the Führer, stands as a guarantor of the National Socialist revolution before the gates of power and will remain standing there at all times. For gigantic missions still await fulfillment which would not be thinkable without the presence and the active co-operation of the SA.
“What has been accomplished up till now, the taking over of the power in the State and the ejection of those elements which are responsible for the pernicious developments of the postwar years as bearers of Marxism, liberalism, and Capitalism, are only the preliminaries, the springboard, for the real aims of National Socialism.
“Being conscious of the fact that the real National Socialist construction work would be building in an empty space without the seizure of power by Adolf Hitler, the Movement and the SA man as the fighting bearer of its will, primarily have directed all of their efforts thereupon, to achieve the platform of continued striving and to obtain the foundation or the realization of our desires. . . .
“Out of this comes the further mission of the SA for the completion of the German revolution: First, to be the guarantor of the power of the National Socialist State against all attacks from without as well as from within; second, to be the high institute of education of the people for the living National Socialism.”
The function of SA as the propagandist of the Party was more than a responsibility which SA took unto itself. It was the responsibility recognized by the law of Germany. From Document 1395-PS, which is the copy of the law entitled, “Law on Securing the Unity of Party and State,” which I have referred to before—and it was promulgated by the Reich Cabinet in 1933—I desire to read Article 3, on Page 1 of the English translation:
“The members of the National Socialist German Labor Party and the SA, including their subordinate organizations, as the leading and driving force of the National Socialist State, will bear greater responsibility toward the Führer, people, and State. In case they violate these duties they will be subject to special jurisdiction by Party and SA. The Führer may extend these regulations in order to include members of other organizations.”
Thus were the SA members the ideology bearers of the Nazi Party—the soldiers of an idea—to use the expression employed by the Nazi writers. And permit me to emphasize that the SA was the propagandist agency, the principal agency employed by the conspirators to disseminate their fanaticism among the people of Germany.
I need hardly point out the importance of this function to the successful effectuation of the conspiracy, for it is self-evident that the Nazis could not have carried their conspiracy to the stages which they did, had not the minds of the people of Germany been cruelly and viciously influenced and infected with their evil ideologies.
I now proceed to the other functions of the SA which I mentioned previously. The next is its use in the early stages of the conspiracy as the “strong-arm” of the NSDAP. In the early stages of the Nazi movement, the employment of the SA as the propagandist instrument of the Party, involved and was combined with the exercise of physical violence and brutality.
As said by Hitler in Mein Kampf—and this excerpt appears at Page 4 of Document 2760-PS, Page 4 of the English translation, Exhibit Number USA-256:
“The young Movement, from the first day, espoused the stand-point that its idea must be put forward spiritually, but that the defense of this spiritual platform must, if necessary, be secured by strong-arm means.”
I will read the rest of that paragraph:
“Faithful to its belief in the enormous significance of the new doctrine, it seems obvious to the Movement that for the attainment of its goal no sacrifice can be too great.”
And so, in the early days of the Nazi movement, so that the Nazis might better spread their fanatical philosophies, the SA was employed as a terroristic group, in order to gain for the Nazis possession and control of the streets. That is another way of saying that it was a function of the SA to beat up and terrorize all political opponents. The importance of this function is indicated in Document 2168-PS, Exhibit Number USA-411, which was written by SA Sturmführer Bayer on orders from SA headquarters. I refer to Page 3 of the English translation of Document 2168-PS, the third paragraph from the bottom:
“Possession of the streets is the key to power in the State—for this reason the SA marched and fought. The public would never have received knowledge of the agitative speeches of the little Reichstag faction and its propagandists or of the desires and aims of the Party if the martial tread and battle song of the SA companies had not beat the measures for the truth of a relentless criticism of the state of affairs in the governmental system. They wanted the young Movement to keep silent. Nothing was to be read in the press about the labor of the National Socialists, not to mention the basic aims of its platform. They simply did not want to awaken any interest in it. However, the martial tread of the SA took care that even the drowsiest citizens had to see at least the existence of a fighting troop.”
The importance of the work of the SA in the early days of the Movement was indicated by Goebbels in a speech which appeared in Das Archiv, October 1935. This is our Document 3211-PS, Exhibit Number USA-419. It is on the first page of the English translation:
“The inner-political opponents did not disappear due to mysterious unknown reasons, but because the Movement possessed a strong arm within its organization; and the strongest arm of the movement is the SA. The Jewish question will not be solved separately but by laws which we enact, for we are an anti-Jewish government.”
Specific evidence of the activities of the SA during the early period of the Nazi movement, from 1922 to 1931, is found in a series of articles appearing in Der SA-Mann entitled, “SA Battle Experiences Which We Will Never Forget.” Each of these articles is an account of a street or a meeting-hall battle waged by the SA against a group of political opponents in the early days of the Nazi struggle for power. These articles demonstrate that during this period it was the function of the SA to employ physical violence in order to destroy and subvert all forms of thought and expression which might be considered hostile to the Nazi aims or philosophy.
A number of such articles have been translated, and the titles are sufficiently descriptive to constitute evidence of the activities of the SA in the early stages of the movement. I should like to quote from a few of these titles by giving the page reference of this big newspaper volume.
Here is one of 24 February 1934, Page 4—the title: “We Subdue the Red Terror.” From the 8th of September 1934, Page 12; the article is entitled: “Nightly Street Battles on the Czech Border.” From 6th of October 1934, Page 5: “Street Battle in Chemnitz.” Another one of 20 October 1934, Page 7—the title: “Victorious SA.” I will skip several of them. Here is one of 26 January 1935, Page 7—the title: “The SA Conquers Rastenburg.” Another on 23 February 1935, Page 5: “Company 88 Receives Its Baptism of Fire.” One of 20 October 1934, Page 7—the article is: “SA against Sub-humanity.” Finally, I mention the one of 10 August 1935, Page 10—the title is: “The Blood Sunday of Berlin.” And then there is a portrait in the article of 11 September 1937, Page 1, which symbolizes the SA man as the master of the streets.
For an example of the nature of these articles, one appeared in the Franken edition of the SA-Mann for 30 October 1937, Page 3. It is entitled: “9 November 1923 in Nuremberg,” and I should like to quote from Pages 14 and 15 of Document 3050-PS, which is an English translation of this article:
“We stayed overnight in the Colosseum (that means Nuremberg). Then in the morning we found out what had happened in Munich. ‘Now a revolution will also be made in Nuremberg’, we said. All of a sudden the police came from the Maxtor police station and told us that we should go home, that the Putsch in Munich had failed. We did not believe that and we did not go home. Then came the State Police with fixed bayonets and drove us out of the hall. One of us then shouted: ‘Let’s go to the Cafe Habsburg!’ By the time we arrived, however, the police again had everything surrounded. Some shouted then, ‘The Jewish place will be stormed. . . . Out with the Jews!’ Then the police started to beat us up. Then we divided into small groups and roamed through the town, and wherever we caught a Red or a Jew we knew, blows ensued.
“Then in the evening we marched, although the police had forbidden it, to a meeting in Fürth. In the Hornschuch promenade the police again attempted to stop us. It was all the same to us. In the next moment we attacked the police in our anger so that they were forced to flee. We marched on to Geissmann Hall. There again they tried to stop us. But the Landsturm, which was also there, attacked the policemen like persons possessed and drove them from the streets. After the meeting we dissolved and went to the edge of town. From there we marched in close column back to Nuremberg. In Willstrasse, at the Plärrer, the police came again. We simply shoved them aside. They did not trust themselves to attack, for that would have meant a blood bath. We decided beforehand not to take anything from anyone. In Fürth, too, they had already noticed that we were up to no good. A large mass of people accompanied us on the march. We marched with unrolled flags and sang so that the streets resounded: Comrade reach me your hand; we want to stand together; even though they have false impressions, the spirit must not die; swastika on the steel helmet, black-white-red armband; we are known as Storm Troop (SA) Hitler!”
I now skip to the use of the SA to consolidate the power of the Party. The third function of the SA was to carry out various programs designed to consolidate Nazi control of the German State, including particularly the dissolution of the trade unions and the Jewish persecutions.
The SA groups were employed to destroy political opposition by force and brutality wherever necessary. An example of this is shown in Document Number 3221-PS, Exhibit Number USA-422; and that is an original affidavit made in the State of Pennsylvania, in the United States of America, by William F. Sollman, which we now quote in its entirety:
“William F. Sollman, Pendle Hill School, Wallingford, Pennsylvania, being duly sworn according to law, deposes and says: From 1919 until 1933 I was a Social Democrat and a member of the German Reichstag. Prior to March 11th, 1933, I was editor-in-chief of a chain of daily newspapers with my office in Cologne, Germany, which led the fight against the Nazi Party.
“On March 9th, 1933, members of the SS and SA came to my home in Cologne and destroyed the furniture and my personal records. At that time I was taken to the Brown House in Cologne, where I was tortured, being beaten and kicked for several hours. I was then taken to the regular government prison in Cologne, where I was treated by two medical doctors and released the next day. On March 11th, 1933, I left Germany. (Signed and sworn to).”
Prior to the organization of the Gestapo on a national scale, local SA meeting-places were designated as arrest points; and the SA members were employed in the taking into custody of Communists and other persons who were actually or supposedly hostile to the Nazi Party. This activity is described in Document Number 1759-PS, Exhibit Number USA-420, which is an original affidavit made by Raymond H. Geist. Mr. Geist was formerly United States Consul in Berlin. He is now in Mexico City. I should like to quote from a portion of his affidavit, the first being on Page 5 of the English translation, about the middle of the page, starting:
“At the beginning of the Hitler regime, the only organization which had meeting-places throughout the country was the SA (Storm Trooper). Until the Gestapo could be organized on a national scale, the thousands of local SA meeting-places became the arrest points. There were at least 50 of these in Berlin. Communists, Jews, and other known enemies of the Nazi Party were taken to these points, and if they were enemies of sufficient importance they were immediately transferred to the Gestapo headquarters. During 1933 and 1934, when the Gestapo became universally organized, the SA were gradually eliminated as arresting agents, and the SS were incorporated as administrative and executive officials into the Gestapo. By the end of 1934, the SA had been fairly well eliminated and the SS, the members of which wore elegant black suits and were therefore called Elite Guards, became almost identical as functionaries with the Gestapo.”
I now pass to Page 7 of this same document, Page 7 of the English translation. It begins . . .
THE PRESIDENT: Colonel Storey, does that mean that the SA were eliminated for the purpose of arrest or for other purposes too?
COL. STOREY: No, Sir. As I understand, Sir, the SA reached its height of popularity in 1934 and immediately after the Röhm purge began to decline. In the meantime, the SS, which originated out of the SA, was growing and became really the strong part and grew and prospered after that. So I think the evidence will show that after 1934 the SA started a rapid decline in its importance.
Now, on Page 7 of the English translation I should like to quote a part of the consul’s report, beginning in the middle of the page:
“Another American, Herman I. Roseman, made an affidavit which stated:
“ ‘Yesterday, March 10th, 1933, in the afternoon about 4:30, I came out of KDW with my fiancée, Fräulein Else Schwarzlose, residing in Wilmersdorf (giving the address). A man in SA uniform stepped on my toe purposely, obviously offended me and said “Pardon.” I said “Bitte,” and walked ahead. He then followed me and kicked me saying, “Na und?” A policeman saw this and walked ahead, paying no attention to attacks made on me. Then I took my passport out of my pocket, showed it to the second policeman, and said that I was an American citizen, but he walked ahead, obviously not able to afford me protection, or at least being unwilling. The SA man continued to attack me, struck me in the face, wounded me over the eye, and continued to do me bodily harm. During this attack, all the time my walking along, we reached another policeman, and I applied to him, showing my passport and said, “I am an American and am entitled to protection.” He shrugged his shoulders and said “What can I do?” By this time the SA man had obviously inflicted enough attack upon me and walked away.
“ ‘Upon my appeal, the policeman brought my fiancée and me to the station house at 13 Bayreutherstrasse. My fiancée and I reported to the officer in charge. He heard the story and said that he was sorry, but that there was nothing to do. My face was bleeding. The policeman said that he had orders not to interfere in any affair in which an SA man took part. I then asked him what I could do to protect myself. He said that there was nothing to do but to wait until the situation was better. He added that the police were absolutely powerless, and were under the direction of the SA, and that there were SA Sturm Abteilungen in the police itself. Thereupon I departed. . . .’ ”
Now on the next page, on Page 8, is another American, Mrs. Jean Klauber, and I quote from her affidavit:
“Oh the night of Friday, March 10, 1933, she and her husband had retired for the night when they were awakened by a prolonged ringing of their apartment bell. They heard pounding upon the street door and a demand for immediate entry and a concurrent threat to break the door down. The street door was opened by the janitor’s wife; and a party of four or five men entered and went at once to the apartment of the deponent, where they again rang and pounded on the door. Mr. Klauber asked who was there and was answered, ‘The police.’ He opened the door and a party of four or five men in brown uniforms, one wearing a dark overcoat and carrying a rifle, pushed in, jostling Mr. and Mrs. Klauber aside. One asked Mrs. Klauber where the telephone was and she indicated the room where it was to be found and started to go there. Thereupon, she was knocked down by one of them. They went on to the bedroom where Mr. and Mrs. Klauber followed them, and there they demanded their passports. Mr. Klauber went to the wardrobe to get his and was stopped, being asked by the intruders whether he was carrying any weapons. Being clothed only in pajamas, his denial was accompanied by a gesture indicating his garb. He then turned to the wardrobe, opened it, and reached for one of his four suits hanging therein where he thought the passport was, and was immediately attacked from behind by all but one of the intruders, who beat him severely with police clubs, the one with the overcoat and rifle standing by. Remarks were shouted such as, ‘look! Four suits, while for 14 years we have been starving!’ Mrs. Klauber tried to inquire the reason for their actions, and was answered, ‘Jews. We hate you. For 14 years we have been waiting for this, and tonight we will hang many of you.’
“When the intruders stopped beating Mr. Klauber he was unconscious, and they again demanded the passports of Mrs. Klauber. Mrs. Klauber found her American passport and her German passport (required by local authorities as the wife of a German citizen and issued by the police at Munich after her arrival here); and the intruders took both in spite of Mrs. Klauber’s protests that she was American. She then searched for her husband’s passport, laid hold of his pocketbook, and in her excitement offered it to them. Though full of money they refused it, and again demanded the passport. Mrs. Klauber then found it and handed it over.
“Then the intruders returned to the unconscious Mr. Klauber, saying, ‘He hasn’t had enough yet,’ and beat him further. Then they left, saying, ‘We are not yet finished,’ and just as they departed, one of them said to Mrs. Klauber, ‘Why did you marry a Jew? I hate them,’ and struck her on the jaw with his police club. . . .”
That is the end of the affidavit.
Now continuing, the next paragraph is the statement of the U.S. Consul:
“I personally can verify that the police had been instructed not to interfere; and that is, that there was official sanction for these activities. Affidavits taken from numerous victims attest this fact. I had become acquainted with the two police officers stationed at the corner of Bellevuestrasse and Tiergartenstrasse near where the Consulate General was located; these officers told me that they and all the other police officers had received definite instructions not to interfere with the SA, the SS, or the Hitler Youth.”
In addition, SA members served as guards at concentration camps during this consolidating period and participated in the persecution and mistreatment of persons imprisoned therein. I now refer to Document 2824-PS, which is a book entitled, Concentration Camp at Oranienburg. It is Exhibit Number USA-423. This was by an SA-Sturmbannführer named Schäfer, who was the commander of the concentration camp at Oranienburg. I quote the excerpt on the first page of the English translation, reading:
“The most trusted SA men of long service were selected in order to give them homes in the camp, since they were the permanent camp guards, and in such a manner we created a cadre of experienced guardsmen who were constantly prepared to be employed.”
Further evidence concerning the operation of the concentration camps by the SA is found in Document 787-PS, Exhibit Number USA-421. This is a report to Hitler from the public prosecutor of Dresden concerning the nolle-prossing of one Vogel, who was accused of mistreatment of persons imprisoned in the concentration camp. I quote from that report:
“On 14 March 1935 the prosecuting authority in Dresden has indicted . . . Oberregierungsrat Erich Vogel in Dresden on account of inflicting bodily injury while in office. The following subject matter is the basis of the process:
“Vogel belongs to the Gestapo office of the state of Saxony since its foundation and is chief of Main Section II, which formerly bore the title ZUB (central section for combatting subversive movements). In the process of combatting efforts inimical to the State, Vogel carried out several so-called ‘borderland actions’ in the year 1933 in which a large number of politically unreliable persons and persons who had become political prisoners in the border territories were taken into protective custody and brought to the Hohnstein protective custody camp. In the camp unusually severe ill-treatment of the prisoners has been going on at least since the summer of 1933. The prisoners were not only, as in the protective custody camp Bredow near Stettin, beaten into a state of unconsciousness for no reasons with whips and other tools, but were also tortured in other ways, as for instance with a drip-apparatus, especially constructed for the purpose, under which the prisoners had to stand so long that they came away with serious purulent wounds on the scalp. The guilty SA leaders and SA men were sentenced to punishments of 6 years to 9 months of imprisonment by the main criminal court of the provincial court in Dresden on 15 May 1935 . . . Vogel, whose duties frequently brought him to the camp, took part in this mistreatment, insofar as it happened in the reception room of the camp during completion of the reception formalities and in the supply room, during issuing of the blankets. In this respect it should be pointed out that Vogel was generally known to the personnel of the camp—exactly because of his function as head of the ZUB—and his conduct became at least partly a standard for the above-named conduct of the SA leaders and men.”
I want to read the remainder of that quotation. I am sorry, I don’t have it here. That is a little portion there that should be read immediately following my statement, and then I started—I will skip to the quotation just below there:
“Vogel stayed in the reception room a long time and watched these proceedings without doing anything about them. In his presence for instance, the SA man Mutze dealt such blows to one man, without provocation, that he turned around on himself. As already stated, Vogel not only took no steps against this treatment of the prisoners, but he even made jokes about it and stated that it amused him the way things were popping here.
“In the supply room, Vogel himself took a hand in the beating amid the general severe mistreatment. The SA men there employed whips and other articles and beat the prisoners in such a manner that serious injuries were produced, the prisoners became partly unconscious and had to lie in the hospital a long time. Vogel was often present in the supply room during the mistreatment. At least in the following cases he personally participated actively in these mistreatments.”
And then skipping down:
“. . . the prisoner was laid across the counter in the usual manner, held fast by the head and arms, and then beaten for a considerable time by the SA men with whips and other articles. Along with these, Vogel himself took part in the beating for a time, and after this mistreatment slapped him again, so that the prisoner appeared green and blue in the face. The prisoner is the tinsmith Hans Kühitz, who bore the nickname ‘Johnny.’ Upon his departure, Vogel gave the head of the supply room, Truppführer Meier from 5 to 6 Reichsmark with the stated reason that the SA men ‘had sweated so.’ The money was then distributed by Meier to those SA comrades who had taken part in the mistreatment.”
Another activity of the SA during the days just following the Nazi seizure of power was to act as auxiliary police. This is shown in Document 3252-PS, Exhibit Number USA-424. This publication is a book written about Hermann Göring.
THE PRESIDENT: Colonel Storey, is that a document which shows on its face that the man was punished for this conduct?
COL. STOREY: I think it does; yes, Sir. I think it does.
THE PRESIDENT: I think that fact ought to be stated.
COL. STOREY: I believe it is stated, Sir. You see in the beginning it says that the prosecuting authority in Dresden had indicted Vogel on account of bodily injury, and I thought it stated that he had been punished.
THE PRESIDENT: The document does appear to state it, but I think you ought to state it in court. The document ends up with—Paragraph 3.
COL. STOREY: It does state that he was punished. The purpose of introducing it was to show what actually took place.
I now turn to Document 3252-PS. As I have just mentioned, the book is entitled, Hermann Göring, the Man and His Work by Erich Gritzbach, in which it is declared that the ranks of the Security Police were strengthened by the SA and which was characterized as the most reliable instrument of the Movement. I should like to quote on the first page of Document 3252-PS, the English translation—it is the fourth paragraph:
“The present reorganization of the Protection Police is hardly noticed by the public. Its ranks are strengthened by the SA, the most reliable instrument of the Movement. The auxiliary police has given effective aid by its fighting spirit in the struggle against the Communists and other enemies of the State, not only to Göring but has, driven by its National Socialist desire for a new spirit within the executive police, assisted in the rigid organization.”
I now skip to the SA participation in the Jewish pogrom of 10-11 November 1938 shown by Document 1721-PS, Exhibit Number USA-425. This is a confidential report of the SA-Brigadeführer to his group commander, dated 29 November 1938. In the English translation, starting at the beginning without reading the addresses, it is to SA Group Electoral Palatinate (Kurpfalz) Mannheim:
“The following order reached me at 3 o’clock on 10 November 1938.
“On the order of the Gruppenführer, all Jewish synagogues within the 50th Brigade are to be blown up or set on fire immediately.
“Neighboring houses occupied by Aryans are not to be damaged. The action is to be carried out in civilian clothes. Rioting and plundering are to be prevented. Report of execution of orders to reach the brigade Führer or office by 8:30.
“I immediately alerted the Standartenführer and gave them the most exact instructions; the execution of the order began at once. I hereby report that the following were destroyed in the area of. . . .”
Then there follows a list of 35 synagogues that were destroyed. I just refer to a few of them:
“1) The synagogue at Darmstadt, Bleichstrasse, destroyed by fire. . . . 4) The synagogue at Gräfenhausen, interior and furnishings wrecked.”—And then under “Standarte 145”—“The synagogue at Bensheim, destroyed by fire.”
And then the next four items are synagogues destroyed by fire. In Standarte 168 eight synagogues are shown to have been destroyed by fire. In Standarte 86 the synagogue in Beerfelden was blown up; and then follow several others where the furnishings were wrecked. In Standarte 221 the synagogue and chapel in Gross-Gerau was destroyed by fire, and the next one torn down and the furnishings destroyed. And then it is signed by the Führer of Brigade 50, by the signature which is illegible, “Brigadeführer.”
In connection with the persecution of the Jews, we again find the SA performing its function of propaganda agency for the Nazis. In this connection it was the function of the SA to create and foster among the people an anti-Jewish spirit and sentiment without which the terrifying Crimes against Humanity perpetrated against the Jewish race certainly would not have been tolerated by any civilized peoples. Substantial and convincing evidence of this function is to be found in these bound volumes of Der SA-Mann. Throughout the period covered by these volumes, there appeared in this publication article after article consisting of the most cruel and vicious sort of anti-religious propaganda designed to engender and foster hatred and hostility toward the Jewish race.
I will simply refer to a few of the titles appearing. On 27 July 1935, at Page 4, the title is “Finish up with the Jew.” That is shown, if Your Honor pleases, in Document 3050-PS, Pages 16 to 18 there listed. In the issue of 2 February 1935, Page 5, “The Jewish World Danger”; on 20 July 1935, Page 4, “Jewish Worries”; on 1 June 1935, Page 1, “Jews Are Not Wanted Here.” And then follows a statement:
“Then, also, outside of the last German village the sign will stand, ‘Jews Are Not Wanted Here’; and then, finally, no German citizen will again cross the threshold of a Jewish store. To achieve this goal is, among others, the mission of the SA man as the political soldier of the Führer. Next to his word and his explanations shall stand his example.”
Then further on, 17 August 1935, Page 1, “God Save the Jews.” Then another, of 5 October 1935, Page 6, the title “The Face of the Jew” (with a portrait of a Jew holding the hammer and sickle).
I will just refer to one or two more of them. Here is one on 23 November 1935, Page 2, the title, “The Camouflaged Benjamin—Jewish Cultural Bolshevism in German Music.” Here is one of 2 January 1937, Page 6—a hideous-looking picture—the title being “Romania to the Jews?” I give the final quotation, the last one, 3 February 1939, Page 14, the title being “Friends of World Jewry: Roosevelt and Ickes.”
The impressive thing about all these articles is the fact that it was not intended that the philosophies expressed in them should be confined to members of the SA; on the contrary, the plan was to educate the members of the SA with this iniquitous philosophy, and for the SA in turn to be employed for its dissemination into the minds of the German people. This fact is demonstrated in the introduction to a series of anti-Jewish articles in the paper of 5 December 1936, at Page 6. I will just read the title. It is found on Page 28 of the same document and the title is as follows: “Gravediggers of World Culture.” Also on that same Page, 28, I quote this statement:
“We suggest that the comrades especially take notice of this series of articles and see that they are further circulated.”
In addition, intensive campaigns were conducted to persuade the public to purchase and read Der SA-Mann and the various issues were posted in public places so that the general public might read them. Der SA-Mann itself contained several photographs which show particular issues posted upon street bulletin boards; and there are several photographs showing advertising displays, one of which, for example, reads as follows—this is in the issue of 31 October 1936: “Der SA-Mann belongs in every house, every hotel, every inn, every waiting room, and every store.” Also in the issue of 24 August 1935, at Page 3, there was a group picture of SA men on trucks and in front of the trucks were large signs, one of which read, “Read Der Stürmer and you will know the Jew.” On the same page of the publication I mentioned there is a photograph of what appears to be a public rally, at which there is displayed a large poster reading, “He who knows the Jew, knows the devil!”
THE PRESIDENT: Colonel Storey, the Tribunal expressed their view yesterday that they did not desire to hear cumulative evidence. Isn’t this rather cumulative?
COL. STOREY: I agree with Your Honor that possibly it is. I am trying to draw the line on it. I will omit the rest of them.
Now we will pass to the final phase of the function of the SA in the conspiracy.
THE PRESIDENT: Perhaps we had better adjourn now for 10 minutes.
[A recess was taken.]
COL. STOREY: If Your Honor pleases, I have just started into the function of the SA in the conspiracy, that of its participation in the program for preparation for warfare.
In this connection, Your Honors asked this morning a question about the arresting and police activities of the SA, and I mentioned that they had declined after 1934. For fear there was some misapprehension, I would like to state that as a police organization and as an arresting agency they declined steadily after 1934.
We go now into the phase where they went into military preparations, the next phase; and that is the phase with which I deal now. If Your Honor pleases, I have here all official government publication issued by the British Government in 1943, the title being, The Nazi Party and Organizations; and I should like to quote as to the organization and membership of the SA from that publication. It is the most authoritative that I have been able to find, and I would like to quote briefly from it:
“The SA was founded in 1921 as a para-military organization to protect Nazi meetings and leaders, to throw out interrupters and hecklers, to fight political enemies, and to provide pre-military training at a time when the legal ‘Reichswehr’ was limited to 100,000 men. Their highest leader is Hitler himself; his deputy is called the Stabschef (Chief of Staff) of the SA; from 1930 till June 1934 it was Röhm; from then onwards till his death in May 1943, Victor Lutze; since August 1943, Wilhelm Schepmann. In January 1933 the SA had only 300,000 members. After the seizure of power, its strength increased quickly; at present it has a membership of 1,500,000 to 2,000,000.” (JN-4)
Now, the date of this is 1943. We again find the SA employed to inculcate a particular Nazi ideology into the minds of the people of Germany. At this point it was the function of the SA to prepare Germany mentally for the waging of a vicious and aggressive war.
At all times, and especially during the period from 1933 to 1939, SA leaders emphasized to SA members the duty and responsibility of creating and fostering a militaristic spirit throughout Germany. In 1933 Hitler established the so-called SA sports program; and at that time, according to Sturmführer Bayer, in his pamphlet which I have previously introduced in evidence as 2168-PS—on Page 6 of the English translation—it is just one sentence, and I quote:
“. . . commissioned to increase and to preserve the warlike power and the fighting spirit as the expression of the soldier-like attitude of a people.”
In 1937 Hitler renewed the so-called sports program and, as recited in Document 3050-PS, which is the English translation of these newspaper articles, on Page 12, he made a statement “for the fostering of a military spirit.”
The Organization Book of the Party is to the same effect, in Document 3220-PS, which is Exhibit Number USA-323. I quote from a portion of that document—Paragraphs 1 to 3 on Page 1 of the English translation, beginning at the first paragraph:
“While the political organization of the NSDAP has to carry out the political leadership, the SA is the training and education instrument of the Party for the realization of an ideologically soldier-like attitude.
“In conformity with the directives of the Führer given at the Reich Party meeting of freedom, the SA is, as the voluntary political soldiery, the guarantor of the National Socialist movement, of the National Socialist revolution, and of the resurgence of the German people.
“Consequently, the young German in the SA is being inculcated in the first instance from the standpoint of ideology and character, and trained as the bearer of the National Socialist ideas.
“Equally significant is a suitable education and training which the SA members have accomplished within the yearly classes which have completed their military service. This prevails until the age they and all their spiritual, mental, and physical powers are ready for use in maintaining the Movement, the people, and the State. They should find their best home in the SA. All that which could divide them economically, culturally, professionally, or because of origin is being overcome in the SA by the spirit of comradeship and manly dignity.
“In that manner the SA is developing a decisive factor on the path to a popular community. Its spirit should radiate with soldierly tradition and the possibility of application on all existing units outside of the movement. Their guardianship is thus an important mission of the SA.”
A number of articles which were obviously designed to serve as war propaganda material have been translated, in other cases only the titles, the titles themselves being so comprehensive that they disclose the nature and substance of the articles. I should like to refer to a few of these titles on this subject. They are shown on the English translation of 3050-PS and they are listed on Page 1.
On the question of the Nazi Lebensraum philosophy: The issue of 5 January 1935, Page 13, the article “The German Living Space”; the issue of 10 October 1936, Page 15, “Our Right, Our Colonies”; another, of 14 October 1938, Page 3, the title “Space and Folk”; “Colonies for Germany,” 2 January 1937, Page 4. I should like to quote briefly from that article. I believe that it is on Page 2 of the English translation, 3050-PS:
“The German Ambassador in London, Herr Von Ribbentrop recently, on occasion of a reception in the Anglo-German Fellowship . . . has renewed, in a speech which dealt with all problems from a high level, the indubitable claim of Germany for the restitution of its colonies which had been snatched away.
“Shortly thereafter the Reich Bank president and Reich Minister of Economics, Dr. Schacht, published in the English magazine, Foreign Affairs, a detailed article on the German colonial problem.”
That is on Page 2, I believe, of the English translation.
“For the rest Dr. Schacht laid out the categorical demand that Germany must, in order to solve the problem of its raw materials, get colonies which must be administered by Germany and in which the German standard currency must be in circulation.”
Now, the next group are articles dealing with the Versailles Treaty, and I will quote only from a few of them on Page 3 of that same translation. Here is one of 7 April 1934, Page 14, “What is the Situation Regarding Our Battle for Equal Rights?”. Another is entitled, “The Dictate of Versailles,” 30 June 1934, Page 15. The article reads in part:
“The dictate of Versailles established the political, economical, and financial destruction of Germany in 440 artfully—one could also say devilishly—devised paragraphs; this work of ignominy is a sample of endless and partly contradictory repetitions in constantly new forms. Not too many have occupied themselves with this thick book to a great extent, for one could only do it with abomination.”
Another title is 7 July 1934, Page 15, “The Unbearable Limitations on our Fleet.” Another one: 19 January 1935, Page 13, “Versailles after 15 Years.” This article reads in part:
“This terrible word ‘Versailles’, since a blind nation ratified it, has become a word of profanity for all those who are infatuated with the spirit of this enormous production of hatred. The Versailles dictate is German fate in the fullest sense of the word. Every German bore up under the operation of this fate during the past 15 years. Therefore, every last German must also grasp the contents of this dictate so that one single desire of its absolute destruction fills the whole German Volk.”
I shall omit the other quotation. The last one I shall refer to is February 1937, quoting “Versailles Will Be Liquidated”; and that, if Your Honor pleases, is the last paragraph on Page 4 of the English translation:
“The National Socialist movement has again achieved a victory, for upon its flag since the beginning of the fight stands: The liquidation of the Versailles Treaty. For this fight the SA marched year after year.”
A third group of articles describing preparations for war, purportedly being carried on by other nations, are found on Page 5 of that same document, and I shall refer to just a few of them:
The issue of January 26, 1935, Page 14, “Military Training of English Youth,” showing pictures of Eton students wearing the traditional Eton dress—tall hats and frock coats—marching with rifles; another one is “The Army of the Soviet Union,” dated 16 March 1935, Page 14; another one, 4 April 1936, Page 13, “The Red Danger in the East”; another one, 29 August 1936, Page 10, “Russia Prepared for World War”; another one, 19 June 1937, Page 7, “Red Terrorism Nailed Down.”
I shall pass the rest of them.
Now, the next is the SA participation in the aggressive war phase of the conspiracy—the preparation by SA of the youth of Germany for participation in aggressive warfare. I hardly think I need emphasize that one of the most important steps in carrying out the conspiracy was the training of the youth of Germany in the technique of war and their preparation physically and spiritually for the waging of aggressive war. To the SA was delegated this most important responsibility. I have here Document Number 3215-PS, Exhibit Number USA-426, which I offer in evidence; and it is an excerpt from Das Archiv and contains Hitler’s characterization of the task of the SA in this respect. It is on Page 1 of the English translation of 3215-PS. I start the reading where it says:
“Already in 1920 by the founding of the National Socialist Sports Section (SA) the Führer established the extensive mission of this SA at that time by declaring in the protocol of its charter. . . . ‘The Sports Section (SA) shall one day be the bearer of the military thought of a free people.’ ”
In the same sense the Führer said in his book, Mein Kampf:
“Give the German nation 6 million bodies perfectly trained in sport, all fanatically inspired with the love of the fatherland and trained to the highest offensive spirit, and a national state will, if necessary, have created an army out of them in less than 2 years. . . .”
The military character of the SA is demonstrated by its organizational composition. I refer to the chart on the wall, which is our Document Number 2168-PS. It is taken from this book, being the pamphlet of the SA Sturmführer; and the chart is taken from the official book. I simply refer to the chart and call to the attention of Your Honor that it was organized into units closely corresponding to those of the German Army. As the Tribunal will see, the organizational scheme consisted of divisions; at the top in that pyramidal structure the division, next the brigade, the regiment, the battalion, the company, the platoon, and the squad.
In addition, there were special units and branches, over to the right as Your Honor will notice, including cavalry, signal corps, engineer corps, and medical corps. There were also, as Bayer pointed out in his pamphlet, three officer training schools. Similarly, SA members wore distinctive uniforms adapted to military functions, bore arms, and engaged in training, forced marches, and other military exercises.
SA members, moreover, were governed by general regulations which closely resembled service regulations of an armed force. They are contained in Document Number 2820-PS, Exhibit Number USA-427, which I offer in evidence. If Your Honor pleases, they are found at Page 3 of the translation. I will simply refer to a few of them. These regulations provide for punishment, designating them as penal regulations, for disobedience of orders and infractions of regulations. The punishments which are provided demonstrate the militaristic character of the SA and include the following: Reprimand in private; reprimand in presence of superiors and announcement thereof at formations; prohibition of the right to wear service uniform; house arrest, et cetera.
Preparation for war through the SA training program was commenced in Germany as early as 1933, but the scope of this program was not made public because of the fact that it actually constituted a violation of the Treaty of Versailles. The strict secrecy with which the program was surrounded is shown in Document D-44, Exhibit Number USA-428, which I offer in evidence.
On Page 1 of the English translation—this is from the Supreme Command of the SA, Chief of Staff—and it has to do with publications on the SA:
“Further to my instruction Z II 1351/33 dated 11 July 33, I find cause to ask all SA authorities to exercise the greatest caution with regard to any publicity given to the SA service not only in the press but also in the information and news sheets of the individual SA units.
“Only during the last few days the Reich Ministry of the Interior at the request of the Foreign Office has given strict instructions to all Reich authorities according to which the most severe control is to be exercised on all publications which might give other countries an occasion to construe German infringements of the terms of the Versailles Treaty.
“As is known from the Geneva negotiations, our opponents have piled up material, collected in Germany and submitted to them, which they use against us on every occasion during the conferences.
“From this point of view, the information sheets circulating among the subordinate SA units cause the liveliest concern. I hold all higher SA leaders responsible that any such internal information sheets appearing in the district of their command are submitted to the most stringent control before they go into print; and I feel compelled to draw attention to the liability to prosecution for treason, as pronounced in official instructions issued in the last few days, in cases where such reports, printed no doubt in good faith, are published and therefore exposed to the danger of falling into the wrong hands.
“On principle, pictures of the special technical units of the SA and SS, in particular of the motorized, signal, and possibly also of the air squads which now exist outside these formations, are forbidden, such pictures enabling other countries to prove the alleged formation of technical troop units.”
Similarly, secrecy was provided for in the order assigning a Wehrmacht officer to the SA in January 1934 to assist in the SA training program. This Document, 2823-PS, Exhibit Number USA-429, which is a copy of a memorandum of SA headquarters dated January 1934, designates an officer of the Wehrmacht to assist in the military training of SA members, and it goes on to provide—and I quote from Paragraph 7 of the English translation:
“For the purpose of camouflage, Lieutenant Colonel Auleb will wear SA uniform with the insignia of rank according to more detailed regulations of the Supreme SA leader.”
The military training program of the SA was for many years conducted under the guise of a sports program. This plan was created by Hitler as early as 1920 by the founding of what he called the sports program. The fact that the so-called sports program was in reality closely associated with, and in fact a means of providing, military training for the German youth is shown by the following characterization of the program by Lutze, the Chief of Staff of the SA, in an article written in 1939. I now refer to Document 3215-PS, Exhibit Number USA-426; and I quote excerpts of the English translation on Page 2:
“The decrees issued by the Führer to the SA in 1935 about the renewal, in 1936 regarding the bestowal of the diploma and in 1937 about the repetition of the yearly exercises of the SA sport badge, all served this goal. Parallel to this decree of the Führer for physical strengthening and military indoctrination, adequate measures were taken within the SA, regarding organization and drilling. Out of the idea that the preservation and the advancement of the military power of our people must be specially fostered by military and physical exercises, resulted a particular and systematic training in these fields.
“In 25 troop schools and in three Reichsführer schools of the SA 22,000 to 25,000 officers and noncommissioned officers were trained yearly since 1934 in special educational courses until they possessed the education and examination certificates. In clearly outlined training directives, the training goals which had to be achieved yearly were given and at the same time the yearly Reich competitive contests were established. Hand in hand the training of the Führer Corps and the corresponding organizational measures and the training at the front proceeded on the broadest basis.”
In connection with the military training of the sports program, I refer to Document 2354-PS, Exhibit Number USA-430, which demonstrates the tests and standards required for obtaining the sports award—Page 2 of the English translation. I am not going to read all of it, if Your Honor pleases, but just refer to a few of them:
“Group II: Military sports; 25-kilometer march with pack; firing of small-caliber arms; aimed throwing of hand grenades, 200-meter cross-country race with gas masks over four obstacles; swimming or bicycle riding; basic knowledge of first aid in case of accidents.”
I will pass the others.
In 1939 the SA sports program was formally recognized in a decree issued by Hitler as a military training program, and the SA was openly declared to be an agency for pre- and post-military training, that is, for military training prior to and following service in the Wehrmacht. I have Document Number 2383-PS . . .
THE PRESIDENT: Colonel Storey, you have just drawn our attention to a Document Number 3215-PS, which shows that from 1934 onwards, 25,000 officers and noncommissioned officers were trained by the SA.
COL. STOREY: Yes, Sir.
THE PRESIDENT: Isn’t that sufficient to show the military nature of the organization?
COL. STOREY: I think so. This was just the decree of Hitler. May I just refer to it by reference for the record? I will not read the decree.
THE PRESIDENT: Go on; what are you referring to?
COL. STOREY: Document 2383-PS, Page 11 of the English translation, contains a copy of the decree legalizing the training program for pre- and post-military training.
It would have been one thing for the SA to conduct a military training program for its members, but the SA program was not confined to its members. The entire youth of Germany was enlisted into a feverish program of military training.
I refer to a quotation in Document 2354-PS from the same organization book, which is at Page 2 of the English translation, in which the Chief of Staff Lutze said, and I quote briefly:
“In order to give conscious expression to the fostering of a valiant spirit in all parts of the German people, I further decide that this SA sports badge can also be earned and worn by persons who are not members of the movement insofar as they comply racially and ideologically with the National Socialist requirements.”
Document 2168-PS shows that responsibility for conducting this nation-wide program was lodged in the operational main office of the SA. Page 8 of the English translation says, and I quote:
“The latter has, on the basis of the SA sport badge, to prepare a thorough physical training of the bodies of all Germans capable of bearing arms. In order to reach this goal, it has to organize body exercises and sporting advancement so that the masses of the people will be included by it and will be kept fit to bear arms until old age. This martial preparedness must not be achieved only by physical and mental training but also with regard to character and ideology.”
I pass from that phase now.
Document 3215-PS is an excerpt from Das Archiv, and I refer to Pages 2 to 3 of the English translation beginning at the bottom of Page 2, and I quote:
“Next to the companies of the SA were the SA sport badge associations, in which entered all the nationals who were capable of bearing arms and who were prepared to voluntarily answer the call of the SA for the preservation of military proficiency. Up till now about 800,000 nationals outside the SA could successfully undergo the physical betterment as well as the political-military indoctrination of the SA on the basis of the SA badge.”
The military program of the SA was not that of a mere marching and drill society; it embraced every phase of the technique of modern warfare. This is particularly demonstrated by consideration of the articles on military training which appeared publicly throughout the issues of the SA-Mann. I should like to refer to only a few of the titles, and they are set out on Pages 8 and 10 of Document 3050-PS. It is a great, long list, and I will only refer to five or six.
There is one of them, 17 February 1934, Page 7, “Pistol Shooting”; 21 April 1934, Page 13, “What Every SA Man Must Know about Aviation”; 19 May 1934, Page 13, “Chemical Warfare”; 2 June 1934, Page 14, “Modern Battle Methods in the View of the SA Man”; 4 August 1934, Page 13, “The Significance of Tanks and Motors in the Modern War.” I will omit references to the remainder.
Similarly, the issues of the SA-Mann contain many photographs and articles demonstrating and portraying SA participation in military exercises, including forced marching, battle maneuvers, obstacle runs, small-caliber firing, and so on. I simply refer these to Your Honors, and they are shown on Pages 11 to 13 of Document Number 3050-PS. Just one or two titles: 24 August 1935, Page 2, “The SA Is and Remains the Shock Troop of the Third Reich.” Here is one showing the connection with the Wehrmacht: 2 September 1938, Page 1, “The SA and the Wehrmacht,” with pictures of SA men on field maneuvers throwing hand grenades. I will omit the rest of those.
Convincing evidence demonstrating the participation of the SA in the conspiracy is found in the fact that care was taken at all times to co-ordinate the military training of the SA with the requirements of the Wehrmacht. This is shown by Document 2821-PS, Exhibit Number USA-431, Page 1 of the English translation, quoting:
“Permanent liaison between the Reich Defense Ministry and the Supreme Commander of the SA . . . has been assured.”
Another document, 3215-PS, which is an excerpt from Das Archiv, sets forth the co-operation and collaboration with the Wehrmacht and specialized military training; and it was stated in a speech of the Chief of Staff of the SA, Document 3215-PS, Page 2 of the English translation, Exhibit Number USA-426:
“In the course of this development also, special missions for military training were placed on the SA. The Führer gave the SA the cavalry and motor training and appointed SA Obergruppenführer Litzmann as Reich Inspector with the mission of securing the cavalry recruits and the requirements of the German Wehrmacht through the SA. In close co-operation with parts of the Wehrmacht, special certificates were created for the communications, engineer, and medical units which, like the cavalry certificate of the SA, are valued as a statement of preference for employment in said units.”
Your Honor, we have two or three more quotations about co-operation with the Wehrmacht, but I believe they would be cumulative, and I will omit them. I will refer only to Document 2383-PS, Exhibit Number USA-410, Page 11. I will read a portion of the decree:
“The Führer: In amplification of my decrees of 15 February 1935 and of 18 March 1937 regarding the acquisition of the SA sports insignia and the yearly repetitive exercises, I elevate the SA sports badge to the level of the SA military badge and make it a basis for pre- and post-military training. I designate the SA as the standard bearer of this training.”
I skip now to Page 48 for the record.
The specialized training given SA members, in accordance with the requirements of the technical branches of the Wehrmacht, is described by SA Sturmführer Bayer, in Document Number 2168-PS, Exhibit Number USA-411; and it is Page 13 of the English translation:
“On one side, the young SA man who enters the Armed Forces”—Wehrmacht—“from his branch comes prepared with a multitude of prerequisites which facilitate and speed up training in technical respect; while on the other side, those very soldiers who, having served, return out of the Armed Forces into the SA keep themselves, by constant practice, in a trained condition physically and mentally and impart their knowledge to their fellows.
“Thus they contribute a considerable portion to the enhancement of the armed strength and fighting spirit of the German people.”
And then skipping down: “The SA each year is able to furnish many thousands of young trained cavalrymen to our Wehrmacht.” I will omit the rest of that.
I simply call attention now to an issue of the SA-Mann dated 3 February 1939, at Page 3, which contains a photograph of Chief of Staff Lutze addressing a group of SA men. This photograph bears the caption, “We will be the Bridge between the Party and the Wehrmacht.”
The second reference shows a photograph of General Brauchitsch and Chief of Staff Lutze reviewing an SA unit.
Now, I pass to Document 3214-PS, which is Exhibit Number USA-432. There is only one page of it. Quoting:
“It was announced that SA men and Hitler Youths liable to military service can fulfill their military duties in the SA Regiment Feldherrnhalle, whose commander is General Field Marshal, SA Obergruppenführer Göring. The regiment, for the first time, was employed as Regiment of the Luftwaffe in the occupation of the Sudetenland . . . under its leader and regimental commander, SA Gruppenführer Reimann.”
THE PRESIDENT: Up to now you have brought evidence to our notice showing that the SA was voluntary. This shows it was conscripted. When did it become conscripted?
COL. STOREY: As I understand, Your Honor, if you joined the SA you got out of conscription, but once you were in it they could use you as desired. In other words, the SA was a voluntary organization.
THE PRESIDENT: That is the evidence you have given up to date.
COL. STOREY: Yes, Sir.
THE PRESIDENT: Well, when did it become liable to conscription or used as a substitute for conscription?
COL. STOREY: If Your Honor pleases, may I ask Mr. Burdell to answer that question? He has been working on it.
MR. CHARLES S. BURDELL (Assistant Trial Counsel for the United States): If Your Honor pleases, there never was conscription in the SA. As this document shows—Document 3214-PS—service in the Feldherrnhalle Regiment of the SA took the place of conscription. This first sentence in Document 3214-PS, which reads, “It was announced that SA men and Hitler Youths liable to military service can fulfill their military conscription in the SA Regiment Feldherrnhalle . . .” means, as I understand it, that SA men who are conscripted, that is SA men who are drafted after they have joined the SA, may serve their conscription by remaining in the SA or by transferring to the Feldherrnhalle Regiment of the SA.
The next paragraph of Document Number 3214-PS designates the requirements that must be fulfilled before the SA man can join this Feldherrnhalle Regiment, but if he fulfills those requirements he may join that regiment, and having done so, that serves the purpose or serves the function of conscription in the Wehrmacht.
I hope that answers Your Honor’s question.
COL. STOREY: In view of the above we would expect the SA to have been used as a striking force in the first steps of the aggressive war launched by Germany and as a basis for so-called commando groups, and such was the case. SA units were among the first of the Nazi military machine to invade Austria in the spring of 1938, as was proudly announced in an article appearing in the SA-Mann of 19 March 1938, Page 10, the article entitled, “We Were There First.”
The SA participation in the occupation of the Sudetenland is also shown by Document Number 3036-PS, Exhibit Number USA-102; and that is an affidavit by Gottlob Berger, a former officeholder in the SS, who was assigned to the Sudeten German Free Corps. I quote Paragraphs 1 and 2 of the affidavit:
“1. In the fall of 1938 I held the rank and title of Oberführer in the SS. In mid-September I was assigned as SS liaison officer with Konrad Henlein’s Sudeten German Free Corps at their headquarters in the castle at Donndorf outside Bayreuth. In this position I was responsible for all liaison between the Reichsführer SS Himmler and Henlein”—Your Honors will recall Henlein was the leader in the Sudetenland—“and in particular, I was delegated to select from the Sudeten Germans those who appeared to be eligible for membership in the SS or VT (Verfügungstruppe). In addition to myself, liaison officers stationed with Henlein included an Obergruppenführer from the NSKK, whose name I have forgotten, and SA Obergruppenführer Max Jüttner, from the SA. In addition, Admiral Canaris, who was head of the OKW Abwehr, appeared at Donndorf nearly every 2 days and conferred with Henlein.”
Your Honors will recall that the Abwehr was the intelligence organization.
“2. In the course of my official duties at Henlein’s headquarters I became familiar with the composition and activities of the Free Corps. Three groups were being formed under Henlein’s direction: One in the Eisenstein area, Bavaria; one in the Bayreuth area; one in the Dresden area; and possibly a fourth in Silesia. These groups should be composed only of refugees from the Sudetenland who had crossed the border into Germany, but they actually contained Germans with previous service in the SA and the NSKK (Nazi Motor Corps) as well. These Germans formed the backbone of the Free Corps. On paper the Free Corps had a strength of 40,000 men . . . . Part of the equipment furnished to Henlein, mostly haversacks, cooking utensils, and blankets, was supplied by the SA.”
The adaptability of the SA to whatever purpose was required of it is demonstrated by its activities subsequent to the outbreak of the war. During the war the SA continued to carry out its military training program, but it also engaged in other functions. Its wartime activities are set out in Document 3219-PS, which is Exhibit Number USA-433, and Document 3216-PS, Exhibit Number USA-434, which are excerpts from Das Archiv.
I quote first, briefly, from Document 3219-PS, the whole text exclusive of the heading:
“The Chief of Staff of the SA, Wilhelm Schepmann, gave further orders to increase the employment of the SA in the homeland war territories, according to the requirements of total war. This was done in numerous business conferences with leaders of the SA divisions.
“As a result of these conferences as well as of measures already carried out earlier for the totalization of the war employment, the SA has placed 86 percent of its professional leader corps at the disposal of the front, even though the war missions of the SA have increased in the fields of pre-military training, the SA penetration into new territorial parts of the Reich, the air-war employment, the city and country guard, et cetera, during wartime.
“The SA as a whole has given at present 70 percent of its millions of members to the Wehrmacht.”
I call attention of Your Honors to the statement of the membership of August 26, 1944. I quote briefly from Document Number 3216-PS, the English translation, just one sentence:
“By command of the Chief of Staff of the SA, the SA unit ‘General Government’ was established, the command of which was taken over by Governor General, SA Obergruppenführer Dr. Frank.”
I next offer in evidence an affidavit, being Document Number 3232-PS, Exhibit Number USA-435, by Walter Schellenberg:
“From the beginning of 1944 on, the SA also participated in many of the functions which had previously been entrusted only to the SS, the Sipo, and Army—for instance, the guarding of concentration camps, of prisoner-of-war camps, supervision of forced laborers in Germany and occupied areas. This co-operation of the SA was planned and arranged for by high officials in Berlin as early as the middle of 1943.”
This concludes my presentation of the principal points of evidence concerning the participation of the SA in the conspiracy, but before I conclude, I should like to present to the Tribunal a few points which establish the participation in the conspiracy by Defendant Göring in his capacity as an SA member or leader.
In 1923 Göring became commander of the entire SA. This is shown in the pamphlet, The SA, which is already in evidence, and the notation concerning Göring’s command appears at Page 2 of the translation, which I do not intend to quote but simply refer to.
Göring’s intention to employ the SA as a terroristic force to destroy political opponents is shown by a speech made by him on 3 March 1933, at a Nazi demonstration in Frankfurt. It is Document Number 1856-PS, Exhibit Number USA-437. It is an excerpt from a book entitled, Hermann Göring, Speeches and Essays. I quote what Göring said:
“Certainly I shall use the power of the State and the police to the utmost, my dear Communists, so you won’t draw any false conclusions; but the struggle to the death, in which my fist will grasp your necks, I shall lead with those down there who are the Brown Shirts.”
The importance of the SA under Göring in the early stages of the Nazi movement is shown by Document Number 3259-PS, Exhibit USA-424; and it is an English translation from the same document book. This is a letter written to Göring by Hitler, and I quote the letter:
“My dear Göring:
“When in November 1923, the Party tried for the first time to conquer the power of the State, you, as commander of the SA, created within an extraordinarily short time that instrument with which I could dare that struggle. Most pressing necessity had forced us to act, but by a wise providence at that time we were denied success. After receiving a grave wound, you again entered the ranks as soon as circumstances permitted as my most loyal comrade in the battle for power. You contributed essentially to creating the basis for the 30th of January. Therefore, at the end of the year of the National Socialist revolution, I desire to thank you wholeheartedly, my dear Party comrade Göring, for the great services you have rendered to the National Socialist revolution and consequently to the German people.
“In cordial friendship and grateful appreciation, yours, Adolf Hitler.”
Although Göring did not retain command of the SA, he at all times maintained close affiliation with the organization. This is shown by the photographs of Göring participating in the activities which I have already introduced in evidence. Similarly, in 1937 Göring became the commander of the Feldherrnhalle Regiment of the SA. The Tribunal will recall, also, my reference to the participation of that regiment in the occupation of the Sudetenland.
Now, finally, the evidence considered in the foregoing sections of this brief demonstrates the participation of the SA as an organization in the conspiracy alleged in Count One. Thus, the SA was first employed by the conspirators to destroy, by force and brutality, all opponents of National Socialism and to gain possession of the streets. Thereafter, upon the seizure of control by the NSDAP, the SA was used to consolidate and to strengthen Nazi power, and cruelly to persecute and destroy all so-called “enemies of the state,” including Jewry and the Church. During the period from 1934 to 1939, the SA was employed for the actual preparation and training of the German people for war and participated in aggressive warfare.
The SA was at all times employed by the conspirators to promote and disseminate the ideology of the Nazi Government throughout Germany, and particularly, to perform the function of disseminating anti-Jewish propaganda and creating and fostering a militaristic and warlike spirit among the people of Germany.
Thus, at all times during the course of its existence, the functions of the SA corresponded to, and were designated to promote, the progression of the conspiracy through its various phases; and the conclusion, we think, is irresistible, that the SA was an organization devoted exclusively to the task of assisting the defendants and their co-conspirators in carrying out the objectives in the conspiracy.
Thus, in this sense, SA, as well as its members, were in fact co-conspirators and participants in a conspiracy which contemplated and involved Crimes against the Peace and Crimes against Humanity and War Crimes.
That concludes the presentation of the SA, Your Honor, and the next is the SS, by Major Farr.
Do Your Honors want to go ahead with that now?
THE PRESIDENT: Perhaps we had better adjourn then, until 2 o’clock.