[Page 131]

Mr. President, Gentlemen, in regard to the participation of the defendant Goering in Crimes against Humanity, notably in connection with the concentration camps, I shall not dwell upon this, but I shall ask the Tribunal, when they have time, to refer to a few paragraphs in which I briefly outline this point. But this is a document which -- as far as I know -- has not been submitted to the Tribunal and which I should like to submit to-day. It concerns pseudo- medical experiments which I believe have not yet been discussed.

You have frequently been told of Dr. Rascher's experiments in the exposure of certain persons to alternate heat and cold, but there is a question which I treat on Page 17 of my brief and which concerns the document which I submit to-day as Exhibit RF 1427. This is a document which originally had the number 170-L. It is a report made by Major Leo Alexander of the British Army, on an institution known as the "Kaiser Wilhelm Institute." Major Leo Alexander, at the time of the defeat of Germany by the Allied Forces, had to conduct certain investigations. He conducted one in connection with experiments made by Dr. Rascher, and another in connection with these carried out in the "Kaiser Wilhelm Institute."

This report which I submit to the Tribunal is entitled "Neuropathology and Neurophysiology, including Electro- Encephalography, in Wartime Germany." This "Kaiser Wilhelm Institute" was an institute for cerebral research. It had formerly been in Berlin-Buch (Page 18 in my brief), and was subdivided into three establishments, the first in Munich, the third in Goettingen. The second, the one which interests me, was established at Dillenburg, in Hessen-Nassau, where there was a special department for pathology directed by Dr. Hallervorden. What is interesting, Mr. President...

THE PRESIDENT: Could we see the original?

M. MOUNIER: The original? Here it is, Mr. President.

(A document was handed to the President.)

THE PRESIDENT: Is the series "L" referred to in Major Coogan's affidavit?

M. MOUNIER: Mr. President, I would like to point out that this number 170-L refers to Major Leo Alexander's document book concerning the experiments of Dr. Rascher. It is the same number.

THE PRESIDENT: As this document has already been produced in evidence in the series "L" -- it is 170-L I think -- the Tribunal will treat it for the moment as being in evidence and will further consider its admissibility.

M. MOUNIER: Yes, sir. At all events, I should like to remind the President, who has certainly noticed it, that I reproduce in this brief which has already been communicated to the defence, the passage which I regard as relevant to my brief. The passage is quoted in full in my brief.

THE PRESIDENT: Which passage do you wish to refer to?

M. MOUNIER: Pages 20 and 21 in my brief.

THE PRESIDENT: Yes; do you wish to read them?

M. MOUNIER: I accept the decision of the Tribunal. If the Tribunal considers this reading superfluous, I shall limit myself to pointing out that what I find striking in this document is the manner in which Dr. Hallervorden ordered the delivery of brains for examination:

"I had heard that they were going to do that, that is, to say, to kill some men in different establishments by means of carbon monoxide," Dr. Hallervorden explained to his British interrogator, Major Alexander. "I went to them and I said, 'Listen, my friends, since you are going to kill all those people there, at least keep the brains so that we can use them.' Then they asked me 'How many can you examine?' 'An unlimited number, the more the better,' I told them. I gave them clips, jars, boxes and the necessary instructions for removing and fixing the brain."

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I call the attention of the Tribunal to the truly horrible nature of the measures taken in regard to the people who were to be killed merely to have their brains examined, for they were -- so he said -- picket out in the different establishments by an excessively simple and rapid method.

Most of the establishments did not have enough doctors, so either through excess of work or through indifference they had shifted the task of selecting the patients to be killed on to the nurses, both male and female. Whoever seemed tired or represented a "case" from the nurses' point of view, was entered on a list and taken to the Death Centre.

The worst of the matter was the brutality of the personnel. They selected those whom they disliked and put them on the list.

I shall stop my citation here, Mr. President, but what I should like to do subsequently, unless the Tribunal is going to call upon Dr. Stahmer to speak...

THE PRESIDENT: Yes, we are now going to hear what Dr. Stahmer wants to say.

DR. OTTO STAHMER (counsel for the defendant Goering): I am sorry that I must contradict what has just been said, for there is no proof that these things took place or that the defendant Goering is responsible. The defendant Goering states that he was quite unaware of these events and that he had nothing whatever to do with matters of that kind. As far as I know, the prosecution itself ...

THE PRESIDENT: I have to interrupt you, Dr. Stahmer. You will have a full opportunity of presenting arguments to us to show that the evidence which is adduced, which is brought forward now against the defendant Goering, has really no reference to him. You will have a full opportunity to do that at the appropriate stage when you present the defence.

The only question we are considering now, the technical question, is whether this document is a document which is admissible. We are considering it, of course, but it is not the appropriate time for you to present your argument that the document does not refer to Goering and that Goering had no knowledge of it. That will be your defense. It is not an objection to the admissibility of the document. It is an argument to show that Goering didn't know anything about the document and didn't know anything about the experiments. Do you understand what I mean?

DR. STAHMER: Yes, sir.

M. MOUNIER: Mr. President, I only wanted, by introducing...

THE PRESIDENT: M. Mounier, continue.

M. MOUNIER: I would like to tell you, Mr. President, in citing that short passage...

THE PRESIDENT: Perhaps the Tribunal had better keep the original document for the present.

M. MOUNIER: My aim, Mr. President, in citing this short passage, is to demonstrate the truly atrocious way in which they treated people in order to procure the necessary material for these so-called experiments. According to the prosecution this relates to Hermann Goering, for the Tribunal will take into account the fact that these experiments were made for the purpose of obtaining information of a scientific or pseudo-scientific nature concerning the effects upon the brains of airmen of all the accidents which might happen to them.

These experiments are connected with those of Dr. Rascher, concerning which some correspondence took place. The defendant Hermann Goering cannot have been ignorant of this correspondence, for it directly concerned the Air Force, which he commanded. I cite, for instance, a letter dated 24th October, 1942, which was addressed by Himmler to Dr. Rascher and which I submit to the Tribunal as Exhibit RF 1409. To save the time of the Tribunal I shall not read this letter. I shall simply refer to another document which

[Page 133]

has already been cited as Document 343-PS. It was submitted by the American prosecution as Exhibit USA 463 on 20th December 1945 (as Exhibit RF 1428), and it is a letter which proves that as early as 20th May, 1942, Field Marshal Milch was charged by the defendant Goering with the task of transmitting to the S.S., his special thanks for the aid which they had given the Luftwaffe with these pseudo-medical experiments.

Consequently, we consider that in this respect the responsibility of the defendant Hermann Goering is clearly established.

Mr. President and Gentlemen, I have concluded the points concerning the defendant Hermann Goering to which I wanted to draw the attention of the Tribunal. There is a conclusion in my brief against the defendant Hermann Goering. With the permission of the Tribunal I shall not read it. I shall say that this conclusion is an extract from an old book dating from 1669, which is certainly known to everyone in Germany at least. Its title is "Simplizius Simplizissimus" by Grimmelshausen. It is a work in which persons are seen invoking dreams. Unfortunately the realisation seems to have been achieved by the National Socialist regime.

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