13 Dec. 45

"A: Of course, yes. I didn't mean to imply anything like that."
And on Page 15 of this same interrogation, beginning with the 13th Paragraph of the English text and Page 20 in the German text, we find this question:

"Q: Did you ever discuss, by the way, the requirements of Krupp for foreign labor?

"A: It is certain that it was reported to me what lack Krupp had in foreign workers.

"Q: Did you ever discuss it with any of the members of the Krupp firm?

"A: I cannot say that exactly; but during the time of my activities I visited the Krupp factory more than once and it is certain that this was discussed, that is, the lack of manpower."
Before closing I should like to take 2 minutes of the time of the Tribunal to refer to what we consider to be some of the applicable laws of the case for the assistance of the Tribunal in considering these documents which we have offered.

We refer, of course, first of all, to Sections 6 (b) and 6 (c) of the Charter of this Tribunal. We also say that the acts of the conspirators constituted a flagrant violation of Articles 46 and 52 of the Regulations annexed to the Hague Convention Number IV of 1907.

Article 46 seeks to safeguard the family honor, the rights and the lives of persons in areas under belligerent occupation.

Article 52 provides in part that:

"Requisitions in kind and services shall not be demanded from municipalities or inhabitants except for the needs of the army of occupation. They shall be in proportion to the resources of the country."
We say that these conspirators violated this article because the labor which they conscripted was not used to satisfy the needs of the army of occupation, but on the contrary, was forcibly removed from the occupied areas and exploited in the interest of the German war effort.

Finally, we say that these conspirators — and particularly the Defendants Sauckel and Speer — by virtue of their planning, of their execution, and of their approval of this program, which we have been describing yesterday and today, the enslavement and the misuse of the forced labor of prisoners of war — that for this they bear a special responsibility for their Crimes against Humanity and their War Crimes.

THE PRESIDENT: Are you finishing, Mr. Dodd?