M. MOUNIER: Very well, Mr. President, to meet the wishes of the Tribunal, I shall limit myself, as concerns the Defendant Sauckel, to referring to figures which, it seems to me, do not admit of argument, since they are the figures given by the Defendant Sauckel himself under interrogation. This does not seem to me to infringe upon the rule which the President has just drawn to my attention.
The figures stated are the following: In 1942 there were already a million foreign workers in Germany. In one year Sauckel incorporated into the economy of the Reich some 1,600,000 war prisoners to meet the needs of war economy.
I beg to refer the Tribunal to Exhibit Number RF-1411 in my document book. This is an interrogation of the Defendant Speer under the date of 18 October 1945, which has already been submitted by the United States Prosecution on 12 December 1945, under Exhibit Number USA-220 (Document Number 3720-PS). In this interrogation the Defendant Speer states that 40 percent of all prisoners of war were employed in the production of arms and munitions and in related industries.
I likewise offer under Exhibit Number RF-1412 (Document Number 1292-PS) of 13 December 1945, a memorandum signed by Lammers, Secretary of the Reich Chancellery, giving an account of the discussion which occurred at a conference held on 4 January 1944. On that date, 4 January 1944, in the course of a conference, at which, in addition to the Defendant Sauckel, the Führer himself, Himmler, Speer, Keitel, Field Marshal Milch, and others were present, the number of new workers to be furnished by Sauckel was fixed at four million.
I must mention in this connection that in the course of this meeting, Sauckel expressed doubts as to the possibility of furnishing this number of workers unless he were given sufficient police forces. Himmler replied that he would try to help Sauckel to achieve this objective by means of increased pressure.
Consequently, when the Defendant Sauckel claims, as he probably will do, that he had absolutely nothing to do with the institution now spurned by everyone, known as the Gestapo, we may answer him by official German documents showing that for the recruitment of labor he really did employ the police with all the more or less condemned means already pointed out to you.
As for France alone, the demand for workers at the beginning of 1944 amounted to one million; and this figure was over and above the number of men and women workers already sent to Germany, who in June 1944 numbered one million to one and a half million.
The Defendant Sauckel, therefore, committed the offenses already known to the Court. We have an old adage, an old slogan we may say, according to which “The court is the law”; and it is proper to present only the facts. I shall, therefore, abstain from reading the passage on Page 9 of my presentation dealing with those articles of the law under which the activities of the accused, Sauckel, are punishable.
Mr. President, Your Honors, I should like now to summarize the activity of the Defendant Speer, for as regards France and the western countries the Defendant Speer incurs responsibilities of the same nature as those of the Defendant Sauckel. Like the defendant of whom I have just spoken, he permitted violations of the laws of war, violations of the laws of humanity, in working towards the drafting and carrying out of a vast program of forced deportation and enslavement of the occupied countries.
Speer, Mr. President, first took part in working out the program of forced labor and collaborated in its adoption. In the course of his interrogatory, he stated under oath: First, that he took part in the discussion at which the decision to use forced labor was made; second, that he collaborated in the execution of this plan; third, that the basis of this program was the removal to Germany by force of foreign workers on the authority of Sauckel, Plenipotentiary for Allocation of Labor under the Four Year Plan. The Tribunal will kindly refer to Document Number 3720-PS, submitted by the United States Delegation on 12 December 1945, which I quote under Exhibit Number RF-1411 of our documentation.