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Mr. President, your Honours, I should like now to summarise 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 drafting and carrying out of a vast programme of deportation and enslavement of the occupied countries.

Speer, Mr. President, first took part in working out the programme of forced labor and collaborated in its adoption. In the course of his interrogation and, 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 programme 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 Exhibit USA 220, submitted by the United States delegation on 12th December, 1945, which I quote as Exhibit RF 1411 of our documentation.

As regards France in particular, Hitler and the defendant Speer held a conference on 4th January, 1943, in the course of which it was decided that more severe measures should be taken to expedite the recruiting of French civilian workers without discrimination between skilled and unskilled workers. This is made clear by a note to which I would ask the Tribunal to refer. That is a note signed by Fritz Sauckel himself. It has already been presented by the American prosecution as Document 556-PS, and I submit it as Exhibit RF 1412.

The defendant Speer knew that the levies for forced labor in the occupied territories were obtained by violence and terror. He approved the continuation of these methods from September, 1942, onward. He knew, for instance, that

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workers were deported by force from the Ukraine to work in the Reich. He knew, likewise, that the great majority of workers in the occupied regions of the West were sent to Germany against their will. He even declared before the American magistrate who was questioning him that he considered these methods regular and legal.

The defendant Speer, knowing that the foreign workers were recruited and deported for forced labor in Germany, made specific demands for foreign workers and provided for their employment in the various branches of activity placed under his direction.

The preceding paragraphs summarise all the declarations made by the defendant in the course of the interrogation already mentioned and to which I have just referred.

I beg to remind you that Speer, in addition, was a member of the Central Planning Board. On account of this, and in common with Field Marshal Milch, only Hitler and Goering were superior to him as far as demands for labor were concerned. He likewise took part, in this capacity, in discussions which took place with Hitler to settle the numbers of foreign workers required. He knew that most of these were obtained by means of deportation, through coercion and enslavement of the occupied countries. Proof of this is furnished by various passages of the minutes of the Central Planning Board and from Speer's conferences with Hitler.

I refer to Documents 124R and 125R which have been submitted as Exhibit USA 179 on 12th December, 1945 (Exhibit RF 1414).

Speer did not hesitate to resort to methods of terrorism and brutality as a means of achieving a peak output from this forced labour. He found justification for the action of the S.S. and of the police and for the use of concentration camps to subdue recalcitrants.

I beg to recall to the Tribunal Document 124R, relating to the minutes of the 21st meeting of the Central Planning Board, 30th October, 1942, Page 1059, already quoted. This is the document quoted previously, Exhibit USA 179, on 12th December, 1945.

The defendant Speer likewise bears responsibility for the use of prisoners of war in military operations directed against their countries, for in his capacity as chief of the Todt Organisation, he forced citizens of the Allied nations to work for this organisation, particularly, in the building of fortifications and, among other things, the famous West Wall. He likewise forced Frenchmen, Belgians, Luxembourgers, Dutchmen, Norwegians, and Danes to manufacture arms to be utilized against the allies of the countries to which they themselves belonged.

Finally -- and this is a very important point regarding the responsibility of the defendant Speer -- he participated directly in the use of prisoners from the concentration camps. He proposed the use of prisoners from the concentration camps in the armament factories. Now, in view of the wretched physical condition of the prisoners, no profit, but only the extermination of the prisoners could be expected from this measure. The use of prisoners from concentration camps in the factories had the effect of increasing the demand for this type of labor; and this demand was satisfied in part, at least, by sending to the concentration camps persons who, in ordinary times, would never have been sent there.

Speer went so far as to establish, near the factories, concentration camps which served solely to provide labor.

He knew the Mauthausen Camp. The Spanish witness, Boix, whom the Tribunal heard a few days ago, attested under oath that he had with his own eyes seen the defendant Speer visit the camp at Mauthausen and congratulate the leaders of this camp. Boix even declared that he had worked on the preparation of photographs of this scene. Consequently this visit to the camp

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cannot be questioned. Speer, therefore, saw for himself the barbarous conditions in which the prisoners lived. Nevertheless, he persisted in utilising labor from the Camp of Mauthausen in the factories under his authority.

I have concluded the case against Speer. I am at the disposal of the Tribunal to continue.

THE PRESIDENT: We will adjourn now for 10 minutes.

(A recess was taken.)

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