I will not deal at any length with the details of the political turmoil that plagued Romania during the ensuing period.

THE PRESIDENT: Mr. Brudno, I think the Tribunal are satisfied that Rosenberg—I mean satisfied, subject to what Rosenberg himself or his counsel may say—that Rosenberg tried to spread his ideology abroad, and we don’t require any further detailed proof of that, and we are also satisfied that we have heard enough of the activities of the APA.

MR. BRUDNO: Certainly, Your Honor. We feel that if the Tribunal is satisfied, we can pass on.

THE PRESIDENT: Subject, as I said, to anything that Rosenberg may prove.

MR. BRUDNO: Surely. I would merely like to conclude with the statement that the activities of the APA were, as indicated in this Document 007-PS, primarily responsible for Romania’s joining the Axis. It was a vital link in Germany’s chain of military strategy.

I would further like to call to Your Honor’s attention the evidence which has already been submitted on the activities of the APA in Norway, activities which led to the treason of Quisling and Hagelin, for which they have been condemned.

I come now to the final phase of the case against the Defendant Rosenberg. We have seen how he aided the Nazi rise to power and directed the psychological preparation of the German people for waging of aggressive war. I will now offer proof of his responsibility for the planning and execution of War Crimes and Crimes against Humanity committed in the vast areas of the occupied East, which he administered for over 3 years. These areas included the Baltic States, White Ruthenia, the Ukraine, and the eastern portion of Poland.

I will not endeavor here to chronicle again the tale of mass murder, spoliation, and brutality. We feel that that has already been sufficiently evidenced, and further evidence on this point will be presented by the Prosecution for the U.S.S.R. and for the Republic of France.

We anticipate, however, that Rosenberg will contend that some of these crimes were committed against his wishes, and, indeed, there is some evidence that he protested on occasion—not out of humanitarian reasons but on grounds of political expediency.

We also anticipate that Rosenberg will attempt to place the blame for these crimes on other agencies and on other defendants. The evidence will prove, however, that he himself formulated the harsh policies, in the execution of which the crimes were committed; that the crimes were committed for the most part by persons and agencies within his jurisdiction and control; that any other agencies which participated in the commission of these crimes were invited by Rosenberg to co-operate in the administration of the East, although the brutal methods customarily employed by them were common knowledge; and, finally, his Ministry lent full co-operation to their activities, despite the criminal methods that were employed.