2 Jan. 46

They arrested, tried, and punished citizens of occupied countries under special criminal procedures, which did not accord fair trials, and by summary methods.

They murdered or sent to concentration camps the relatives of persons who had allegedly committed crimes.

They ordered the murder of prisoners in Sipo and SD prisons to prevent their release by Allied armies.

They participated in the seizure and spoliation of public and private property.

They were primary agencies for the persecution of the Jews and churches.

In carrying out these crimes the Gestapo operated as an organization closely centralized and controlled from Berlin headquarters. Reports were submitted to Berlin and all important decisions emanated from Berlin. The regional offices had only limited power to commit persons to concentration camps. All cases, other than short of duration, had to be submitted to Berlin for approval.

The Gestapo was organized on a functional basis. Its principal divisions dealt with groups and institutions against which it committed the worst crimes — which I have enumerated.

Thus, in perpetrating these crimes, the Gestapo acted as an entity, each section performing its parts in the general criminal Enterprises ordered by Berlin. The Secret State Police should be held responsible as an organization for the vast crimes in which it participated.

The SD was at all times a department of the SS. Its criminality directly concerns and contributes to the criminality of the SS.

And as to the Gestapo, it is submitted that it was an organization in the sense in which that term is used in Article 9 of the Charter, that the Defendants Göring and Kaltenbrunner committed the crimes defined in Article 6 of the Charter in their capacity as members and leaders of the Gestapo, and that the Gestapo, as an organization, participated in and aided the conspiracy which contemplated and involved the commission of the crimes defined in Article 6 of the Charter.

And finally, I have in my hand here a brochure published in honor of the famous Heydrich, the former Chief of the Security Police and SD; and I quote from a speech delivered by Heydrich on German Police Day, 1941, of which I ask the Tribunal to take judicial notice:
"Secret State Police, Criminal Police, and SD are still adorned with the furtive and whispered secrecy of a political detective story. In a mixture of fear and shuddering — and