18 Dec. 45

objectives, and it occupied a place of peculiar and significant importance in the scheme of the conspirators. Unlike some of the other organizations, the functions of the SA were not fixed or static. On the contrary, it was an agency adapted to many designs and purposes, and its role in the conspiracy changed from time to time — always corresponding with the progression of the conspiracy through its various phases towards the final objective: abrogation of the Versailles Treaty and acquisition of the territory of other peoples and nations. If we might consider this conspiracy as a pattern, with its various parts fitting together like the pieces of a jigsaw puzzle, we would find that the piece representing the SA constituted a link in the pattern vitally necessary to the presentation and development of the entire picture.

The SA participated in the conspiracy as a distinct and separate unit having a legal character of its own. This is shown by Document 1725-PS, which is tabbed in the document book, of which the Court will take judicial notice. It is an ordinance passed in March 1935, Reichsgesetzblatt, Part I, Page 502. It declares that the SA and certain other agencies were thereafter to be considered "components" of the Nazi Party. This ordinance further provided in Article 5 — and it is on the second page of the English translation, right after the word "Article 5" — I quote, "The affiliated organizations can have their own corporate identity."

Similarly the Organization Book of the Nazi Party characterizes the SA as an "entity." Document 3220-PS, which I now offer, is an excerpt from the 1943 edition of the Organization Book, Page 358 of the original, and I quote from the English translation. It is there declared:
"The Führer prescribes the law of conduct and commands its use. The Chief of Staff represents the SA as a complete entity on the mandate of the Führer.
I am sure the evidence will demonstrate and characterize the SA as an entity and organization having a legal character of its own. This evidence will show that, while the SA was composed of many individual members, these members acted collectively and cohesively as a unit. They were closely bound and associated together by many common factors, including: uniform membership standards and disciplinary regulations; a common and distinctive uniform; common aims and objectives; common activities, duties, and responsibilities; and — probably the most important factor of all — a fanatical adherence to the philosophies and ideologies conceived by the Nazi conspirators.

This is partially demonstrated by Document Number 2354-PS, which again is simply an excerpt from the Organization Book; and it is found on Page 7 of the English translation. It provides that