I should like now to name these defendants and to indicate the positions they held in the Reichsregierung:
Martin Bormann, Leader of the Party Chancellery; Karl Dönitz, Commander-in-Chief of the Navy; Hans Frank, Reich Minister without Portfolio; Wilhelm Frick, Minister of the Interior, Plenipotentiary for Reich Administration; Walter Funk, Minister of Economics, Plenipotentiary for Economy; Hermann Göring, Minister for Air, Reich Forest Master; Rudolf Hess, Deputy of the Führer; Wilhelm Keitel, Chief of the OKW; Constantin H. K. von Neurath, Minister for Foreign Affairs, President of the Secret Cabinet Council; Franz von Papen, Vice-Chancellor; Erich Raeder, Commander-in-Chief of the Navy; Joachim von Ribbentrop, Minister for Foreign Affairs; Alfred Rosenberg, Minister of the Occupied Eastern Territories; Hjalmar Schacht, Acting Minister of Economics, Reich Minister without Portfolio, President of the Reichsbank, Plenipotentiary for War Economy; Baldur von Schirach, Reich Youth Leader; Arthur Seyss-Inquart, Reich Minister without Portfolio; and finally, Albert Speer, Minister for Armaments and War Production.
From the ordinary Cabinet there came not only the members of the Secret Cabinet Council and the Council of Ministers for Defense of the Reich, but also the members of the war planning group, the Nazi secret Reich Defense Council. When it was deemed essential for the purposes of the conspiracy to wage aggressive war, that power was concentrated in a few individuals. Again these individuals were drawn from the ordinary Cabinet. Thus the Plenipotentiaries for Economy and Administration were also Ministers of the ordinary Cabinet, and they were also members of the Reich Defense Council and Ministerial Council.
Under them were grouped practically all the ministers of the ordinary Cabinet.
Where political considerations of foreign policy required that another select group be chosen to act as advisors, the secret Cabinet was created and populated with members of the ordinary Cabinet.
The Reichsregierung was dominated by the Nazi Party through the control exercised over its legislation by the Deputy of the Führer, Hess, and later by the Leader of the Party Chancellery, Bormann. Party control was also effected through the individual membership of all members and the union of various key Cabinet and Party positions in one man. As a result of this fusion of the Party and State, an enormous concentration of political power was gathered into the Cabinet.
The laws enacted by the Cabinet established the framework within which the Nazi conspirators established their control of Germany, set forth in Count One of the Indictment, by virtue of which they were enabled to commit the crimes alleged in Counts One, Two, Three, and Four of the Indictment. The Cabinet enacted harsh penal laws, discriminatory laws, confiscatory laws, in violation of the principles of justice and humanity. Decrees enacted by the Ministerial Council during the war clothed the criminal acts of the Nazi conspirators with a semblance of legality. As an instrument of the Party, the Cabinet effectively implemented the notorious points of the Party program. Finally, the Cabinet, almost immediately upon the coming into power of Hitler, became a war-planning group through its establishment in 1933 of a Reich Defense Council and its active participation in the schemes and plans for waging aggressive war.
It is therefore most respectfully submitted that, by virtue of all of the foregoing, the Reichsregierung, as defined in Appendix D, Page 35, of the Indictment, should be declared a criminal group within the meaning of Article 9 of Section II of the Charter.
That concludes, if Your Honor pleases, this presentation, and the next subject is the SA. It will take just about a couple of minutes to be ready for that.
May it please the Tribunal, I passed up Document Book Y, which contains the English translations of the documents relied upon in this presentation.