Chapter X: Part I: , Page 713 (2)

THE PRESIDENT: Colonel Storey, does that mean that the SA were eliminated for the purpose of arrest or for other purposes too?

COL. STOREY: No, Sir. As I understand, Sir, the SA reached its height of popularity in 1934 and immediately after the Röhm purge began to decline. In the meantime, the SS, which originated out of the SA, was growing and became really the strong part and grew and prospered after that. So I think the evidence will show that after 1934 the SA started a rapid decline in its importance.

Now, on Page 7 of the English translation I should like to quote a part of the consul’s report, beginning in the middle of the page:

“Another American, Herman I. Roseman, made an affidavit which
stated:

“‘Yesterday, March 10th, 1933, in the afternoon about 4:30, I
came out of KDW with my fiancée, Fräulein Else Schwarzlose,
residing in Wilmersdorf (giving the address). A man in SA
uniform stepped on my toe purposely, obviously offended me and
said “Pardon.” I said “Bitte,” and walked ahead. He then
followed me and kicked me saying, “Na und?” A policeman saw this
and walked ahead, paying no attention to attacks made on me.
Then I took my passport out of my pocket, showed it to the
second policeman, and said that I was an American citizen, but
he walked ahead, obviously not able to afford me protection, or
at least being unwilling. The SA man continued to attack me,
struck me in the face, wounded me over the eye, and continued to
do me bodily harm. During this attack, all the time my walking
along, we reached another policeman, and I applied to him,
showing my passport and said, “I am an American and am entitled
to protection.” He shrugged his shoulders and said “What can I
do?” By this time the SA man had obviously inflicted enough
attack upon me and walked away.

“‘Upon my appeal, the policeman brought my fiancée and me to the
station house at 13 Bayreutherstrasse. My fiancée and I reported
to the officer in charge. He heard the story and said that he
was sorry, but that there was nothing to do. My face was
bleeding. The policeman said that he had orders not to interfere
in any affair in which an SA man took part. I then asked him
what I could do to protect myself. He said that there was
nothing to do but to wait until the situation was better. He
added that the police were absolutely powerless, and were under
the direction of the SA, and that there were SA Sturm
Abteilungen in the police itself. Thereupon I departed. . . .’”

Now on the next page, on Page 8, is another American, Mrs. Jean Klauber, and I quote from her affidavit:

“Oh the night of Friday, March 10, 1933, she and her husband had
retired for the night when they were awakened by a prolonged
ringing of their apartment bell. They heard pounding upon the
street door and a demand for immediate entry and a concurrent
threat to break the door down. The street door was opened by the
janitor’s wife; and a party of four or five men entered and went
at once to the apartment of the deponent, where they again rang
and pounded on the door. Mr. Klauber asked who was there and was
answered, ‘The police.’ He opened the door and a party of four
or five men in brown uniforms, one wearing a dark overcoat and
carrying a rifle, pushed in, jostling Mr. and Mrs. Klauber
aside. One asked Mrs. Klauber where the telephone was and she
indicated the room where it was to be found and started to go
there. Thereupon, she was knocked down by one of them. They went
on to the bedroom where Mr. and Mrs. Klauber followed them, and
there they demanded their passports. Mr. Klauber went to the
wardrobe to get his and was stopped, being asked by the
intruders whether he was carrying any weapons. Being clothed
only in pajamas, his denial was accompanied by a gesture
indicating his garb. He then turned to the wardrobe, opened it,
and reached for one of his four suits hanging therein where he
thought the passport was, and was immediately attacked from
behind by all but one of the intruders, who beat him severely
with police clubs, the one with the overcoat and rifle standing
by. Remarks were shouted such as, ‘look! Four suits, while for
14 years we have been starving!’ Mrs. Klauber tried to inquire
the reason for their actions, and was answered, ‘Jews. We hate
you. For 14 years we have been waiting for this, and tonight we
will hang many of you.’

“When the intruders stopped beating Mr. Klauber he was
unconscious, and they again demanded the passports of Mrs.
Klauber. Mrs. Klauber found her American passport and her German
passport (required by local authorities as the wife of a German
citizen and issued by the police at Munich after her arrival
here); and the intruders took both in spite of Mrs. Klauber’s
protests that she was American. She then searched for her
husband’s passport, laid hold of his pocketbook, and in her
excitement offered it to them. Though full of money they refused
it, and again demanded the passport. Mrs. Klauber then found it
and handed it over.

“Then the intruders returned to the unconscious Mr. Klauber,
saying, ‘He hasn’t had enough yet,’ and beat him further. Then
they left, saying, ‘We are not yet finished,’ and just as they
departed, one of them said to Mrs. Klauber, ‘Why did you marry a
Jew? I hate them,’ and struck her on the jaw with his police
club. . . .”

That is the end of the affidavit.

Now continuing, the next paragraph is the statement of the U.S. Consul:

“I personally can verify that the police had been instructed not
to interfere; and that is, that there was official sanction for
these activities. Affidavits taken from numerous victims attest
this fact. I had become acquainted with the two police officers
stationed at the corner of Bellevuestrasse and Tiergartenstrasse
near where the Consulate General was located; these officers
told me that they and all the other police officers had received
definite instructions not to interfere with the SA, the SS, or
the Hitler Youth.”

In addition, SA members served as guards at concentration camps during this consolidating period and participated in the persecution and mistreatment of persons imprisoned therein. I now refer to Document 2824-PS, which is a book entitled, _Concentration Camp at Oranienburg_. It is Exhibit Number USA-423. This was by an SA-Sturmbannführer named Schäfer, who was the commander of the concentration camp at Oranienburg. I quote the excerpt on the first page of the English translation, reading:

“The most trusted SA men of long service were selected in order
to give them homes in the camp, since they were the permanent
camp guards, and in such a manner we created a cadre of
experienced guardsmen who were constantly prepared to be
employed.”

Further evidence concerning the operation of the concentration camps by the SA is found in Document 787-PS, Exhibit Number USA-421. This is a report to Hitler from the public prosecutor of Dresden concerning the _nolle-prossing_ of one Vogel, who was accused of mistreatment of persons imprisoned in the concentration camp. I quote from that report:

“On 14 March 1935 the prosecuting authority in Dresden has
indicted . . . Oberregierungsrat Erich Vogel in Dresden on
account of inflicting bodily injury while in office. The
following subject matter is the basis of the process:

“Vogel belongs to the Gestapo office of the state of Saxony
since its foundation and is chief of Main Section II, which
formerly bore the title ZUB (central section for combatting
subversive movements). In the process of combatting efforts
inimical to the State, Vogel carried out several so-called
‘borderland actions’ in the year 1933 in which a large number of
politically unreliable persons and persons who had become
political prisoners in the border territories were taken into
protective custody and brought to the Hohnstein protective
custody camp. In the camp unusually severe ill-treatment of the
prisoners has been going on at least since the summer of 1933.
The prisoners were not only, as in the protective custody camp
Bredow near Stettin, beaten into a state of unconsciousness for
no reasons with whips and other tools, but were also tortured in
other ways, as for instance with a drip-apparatus, especially
constructed for the purpose, under which the prisoners had to
stand so long that they came away with serious purulent wounds
on the scalp. The guilty SA leaders and SA men were sentenced to
punishments of 6 years to 9 months of imprisonment by the main
criminal court of the provincial court in Dresden on 15 May 1935
. . . Vogel, whose duties frequently brought him to the camp,
took part in this mistreatment, insofar as it happened in the
reception room of the camp during completion of the reception
formalities and in the supply room, during issuing of the
blankets. In this respect it should be pointed out that Vogel
was generally known to the personnel of the camp—exactly
because of his function as head of the ZUB—and his conduct
became at least partly a standard for the above-named conduct of
the SA leaders and men.”

I want to read the remainder of that quotation. I am sorry, I don’t have it here. That is a little portion there that should be read immediately following my statement, and then I started—I will skip to the quotation just below there:

“Vogel stayed in the reception room a long time and watched
these proceedings without doing anything about them. In his
presence for instance, the SA man Mutze dealt such blows to one
man, without provocation, that he turned around on himself. As
already stated, Vogel not only took no steps against this
treatment of the prisoners, but he even made jokes about it and
stated that it amused him the way things were popping here.

“In the supply room, Vogel himself took a hand in the beating
amid the general severe mistreatment. The SA men there employed
whips and other articles and beat the prisoners in such a manner
that serious injuries were produced, the prisoners became partly
unconscious and had to lie in the hospital a long time. Vogel
was often present in the supply room during the mistreatment. At
least in the following cases he personally participated actively
in these mistreatments.”

And then skipping down:

“. . . the prisoner was laid across the counter in the usual
manner, held fast by the head and arms, and then beaten for a
considerable time by the SA men with whips and other articles.
Along with these, Vogel himself took part in the beating for a
time, and after this mistreatment slapped him again, so that the
prisoner appeared green and blue in the face. The prisoner is
the tinsmith Hans Kühitz, who bore the nickname ‘Johnny.’ Upon
his departure, Vogel gave the head of the supply room,
Truppführer Meier from 5 to 6 Reichsmark with the stated reason
that the SA men ‘had sweated so.’ The money was then distributed
by Meier to those SA comrades who had taken part in the
mistreatment.”

Another activity of the SA during the days just following the Nazi seizure of power was to act as auxiliary police. This is shown in Document 3252-PS, Exhibit Number USA-424. This publication is a book written about Hermann Göring.

THE PRESIDENT: Colonel Storey, is that a document which shows on its face that the man was punished for this conduct?

COL. STOREY: I think it does; yes, Sir. I think it does.

THE PRESIDENT: I think that fact ought to be stated.

COL. STOREY: I believe it is stated, Sir. You see in the beginning it says that the prosecuting authority in Dresden had indicted Vogel on account of bodily injury, and I thought it stated that he had been punished.

THE PRESIDENT: The document does appear to state it, but I think you ought to state it in court. The document ends up with—Paragraph 3.

COL. STOREY: It does state that he was punished. The purpose of introducing it was to show what actually took place.

I now turn to Document 3252-PS. As I have just mentioned, the book is entitled, _Hermann Göring, the Man and His Work_ by Erich Gritzbach, in which it is declared that the ranks of the Security Police were strengthened by the SA and which was characterized as the most reliable instrument of the Movement. I should like to quote on the first page of Document 3252-PS, the English translation—it is the fourth paragraph:

“The present reorganization of the Protection Police is hardly
noticed by the public. Its ranks are strengthened by the SA, the
most reliable instrument of the Movement. The auxiliary police
has given effective aid by its fighting spirit in the struggle
against the Communists and other enemies of the State, not only
to Göring but has, driven by its National Socialist desire for a
new spirit within the executive police, assisted in the rigid
organization.”

I now skip to the SA participation in the Jewish pogrom of 10-11 November 1938 shown by Document 1721-PS, Exhibit Number USA-425. This is a confidential report of the SA-Brigadeführer to his group commander, dated 29 November 1938. In the English translation, starting at the beginning without reading the addresses, it is to SA Group Electoral Palatinate (Kurpfalz) Mannheim:

“The following order reached me at 3 o’clock on 10 November
1938.

“On the order of the Gruppenführer, all Jewish synagogues within
the 50th Brigade are to be blown up or set on fire immediately.

“Neighboring houses occupied by Aryans are not to be damaged.
The action is to be carried out in civilian clothes. Rioting and
plundering are to be prevented. Report of execution of orders to
reach the brigade Führer or office by 8:30.

“I immediately alerted the Standartenführer and gave them the
most exact instructions; the execution of the order began at
once. I hereby report that the following were destroyed in the
area of. . . .”

Then there follows a list of 35 synagogues that were destroyed. I just refer to a few of them:

“1) The synagogue at Darmstadt, Bleichstrasse, destroyed by
fire. . . . 4) The synagogue at Gräfenhausen, interior and
furnishings wrecked.”—And then under “Standarte 145”—“The
synagogue at Bensheim, destroyed by fire.”

And then the next four items are synagogues destroyed by fire. In Standarte 168 eight synagogues are shown to have been destroyed by fire. In Standarte 86 the synagogue in Beerfelden was blown up; and then follow several others where the furnishings were wrecked. In Standarte 221 the synagogue and chapel in Gross-Gerau was destroyed by fire, and the next one torn down and the furnishings destroyed. And then it is signed by the Führer of Brigade 50, by the signature which is illegible, “Brigadeführer.”

In connection with the persecution of the Jews, we again find the SA performing its function of propaganda agency for the Nazis. In this connection it was the function of the SA to create and foster among the people an anti-Jewish spirit and sentiment without which the terrifying Crimes against Humanity perpetrated against the Jewish race certainly would not have been tolerated by any civilized peoples. Substantial and convincing evidence of this function is to be found in these bound volumes of _Der SA-Mann_. Throughout the period covered by these volumes, there appeared in this publication article after article consisting of the most cruel and vicious sort of anti-religious propaganda designed to engender and foster hatred and hostility toward the Jewish race.

I will simply refer to a few of the titles appearing. On 27 July 1935, at Page 4, the title is “Finish up with the Jew.” That is shown, if Your Honor pleases, in Document 3050-PS, Pages 16 to 18 there listed. In the issue of 2 February 1935, Page 5, “The Jewish World Danger”; on 20 July 1935, Page 4, “Jewish Worries”; on 1 June 1935, Page 1, “Jews Are Not Wanted Here.” And then follows a statement:

“Then, also, outside of the last German village the sign will
stand, ‘Jews Are Not Wanted Here’; and then, finally, no German
citizen will again cross the threshold of a Jewish store. To
achieve this goal is, among others, the mission of the SA man as
the political soldier of the Führer. Next to his word and his
explanations shall stand his example.”

Then further on, 17 August 1935, Page 1, “God Save the Jews.” Then another, of 5 October 1935, Page 6, the title “The Face of the Jew” (with a portrait of a Jew holding the hammer and sickle).

I will just refer to one or two more of them. Here is one on 23 November 1935, Page 2, the title, “The Camouflaged Benjamin—Jewish Cultural Bolshevism in German Music.” Here is one of 2 January 1937, Page 6—a hideous-looking picture—the title being “Romania to the Jews?” I give the final quotation, the last one, 3 February 1939, Page 14, the title being “Friends of World Jewry: Roosevelt and Ickes.”

The impressive thing about all these articles is the fact that it was not intended that the philosophies expressed in them should be confined to members of the SA; on the contrary, the plan was to educate the members of the SA with this iniquitous philosophy, and for the SA in turn to be employed for its dissemination into the minds of the German people. This fact is demonstrated in the introduction to a series of anti-Jewish articles in the paper of 5 December 1936, at Page 6. I will just read the title. It is found on Page 28 of the same document and the title is as follows: “Gravediggers of World Culture.” Also on that same Page, 28, I quote this statement:

“We suggest that the comrades especially take notice of this
series of articles and see that they are further circulated.”

In addition, intensive campaigns were conducted to persuade the public to purchase and read _Der SA-Mann_ and the various issues were posted in public places so that the general public might read them. _Der SA-Mann_ itself contained several photographs which show particular issues posted upon street bulletin boards; and there are several photographs showing advertising displays, one of which, for example, reads as follows—this is in the issue of 31 October 1936: “_Der SA-Mann_ belongs in every house, every hotel, every inn, every waiting room, and every store.” Also in the issue of 24 August 1935, at Page 3, there was a group picture of SA men on trucks and in front of the trucks were large signs, one of which read, “Read _Der Stürmer_ and you will know the Jew.” On the same page of the publication I mentioned there is a photograph of what appears to be a public rally, at which there is displayed a large poster reading, “He who knows the Jew, knows the devil!”

THE PRESIDENT: Colonel Storey, the Tribunal expressed their view yesterday that they did not desire to hear cumulative evidence. Isn’t this rather cumulative?

COL. STOREY: I agree with Your Honor that possibly it is. I am trying to draw the line on it. I will omit the rest of them.

Now we will pass to the final phase of the function of the SA in the conspiracy.

THE PRESIDENT: Perhaps we had better adjourn now for 10 minutes.

[_A recess was taken._]

COL. STOREY: If Your Honor pleases, I have just started into the function of the SA in the conspiracy, that of its participation in the program for preparation for warfare.

In this connection, Your Honors asked this morning a question about the arresting and police activities of the SA, and I mentioned that they had declined after 1934. For fear there was some misapprehension, I would like to state that as a police organization and as an arresting agency they declined steadily after 1934.

We go now into the phase where they went into military preparations, the next phase; and that is the phase with which I deal now. If Your Honor pleases, I have here all official government publication issued by the British Government in 1943, the title being, _The Nazi Party and Organizations_; and I should like to quote as to the organization and membership of the SA from that publication. It is the most authoritative that I have been able to find, and I would like to quote briefly from it:

“The SA was founded in 1921 as a para-military organization to
protect Nazi meetings and leaders, to throw out interrupters and
hecklers, to fight political enemies, and to provide
pre-military training at a time when the legal ‘Reichswehr’ was
limited to 100,000 men. Their highest leader is Hitler himself;
his deputy is called the Stabschef (Chief of Staff) of the SA;
from 1930 till June 1934 it was Röhm; from then onwards till his
death in May 1943, Victor Lutze; since August 1943, Wilhelm
Schepmann. In January 1933 the SA had only 300,000 members.
After the seizure of power, its strength increased quickly; at
present it has a membership of 1,500,000 to 2,000,000.” (JN-4)

Now, the date of this is 1943. We again find the SA employed to inculcate a particular Nazi ideology into the minds of the people of Germany. At this point it was the function of the SA to prepare Germany mentally for the waging of a vicious and aggressive war.

At all times, and especially during the period from 1933 to 1939, SA leaders emphasized to SA members the duty and responsibility of creating and fostering a militaristic spirit throughout Germany. In 1933 Hitler established the so-called SA sports program; and at that time, according to Sturmführer Bayer, in his pamphlet which I have previously introduced in evidence as 2168-PS—on Page 6 of the English translation—it is just one sentence, and I quote:

“. . . commissioned to increase and to preserve the warlike
power and the fighting spirit as the expression of the
soldier-like attitude of a people.”

In 1937 Hitler renewed the so-called sports program and, as recited in Document 3050-PS, which is the English translation of these newspaper articles, on Page 12, he made a statement “for the fostering of a military spirit.”

The _Organization Book_ of the Party is to the same effect, in Document 3220-PS, which is Exhibit Number USA-323. I quote from a portion of that document—Paragraphs 1 to 3 on Page 1 of the English translation, beginning at the first paragraph:

“While the political organization of the NSDAP has to carry out
the political leadership, the SA is the training and education
instrument of the Party for the realization of an ideologically
soldier-like attitude.

“In conformity with the directives of the Führer given at the
Reich Party meeting of freedom, the SA is, as the voluntary
political soldiery, the guarantor of the National Socialist
movement, of the National Socialist revolution, and of the
resurgence of the German people.

“Consequently, the young German in the SA is being inculcated in
the first instance from the standpoint of ideology and
character, and trained as the bearer of the National Socialist
ideas.

“Equally significant is a suitable education and training which
the SA members have accomplished within the yearly classes which
have completed their military service. This prevails until the
age they and all their spiritual, mental, and physical powers
are ready for use in maintaining the Movement, the people, and
the State. They should find their best home in the SA. All that
which could divide them economically, culturally,
professionally, or because of origin is being overcome in the SA
by the spirit of comradeship and manly dignity.

“In that manner the SA is developing a decisive factor on the
path to a popular community. Its spirit should radiate with
soldierly tradition and the possibility of application on all
existing units outside of the movement. Their guardianship is
thus an important mission of the SA.”

A number of articles which were obviously designed to serve as war propaganda material have been translated, in other cases only the titles, the titles themselves being so comprehensive that they disclose the nature and substance of the articles. I should like to refer to a few of these titles on this subject. They are shown on the English translation of 3050-PS and they are listed on Page 1.

On the question of the Nazi Lebensraum philosophy: The issue of 5 January 1935, Page 13, the article “The German Living Space”; the issue of 10 October 1936, Page 15, “Our Right, Our Colonies”; another, of 14 October 1938, Page 3, the title “Space and Folk”; “Colonies for Germany,” 2 January 1937, Page 4. I should like to quote briefly from that article. I believe that it is on Page 2 of the English translation, 3050-PS:

“The German Ambassador in London, Herr Von Ribbentrop recently,
on occasion of a reception in the Anglo-German Fellowship . . .
has renewed, in a speech which dealt with all problems from a
high level, the indubitable claim of Germany for the restitution
of its colonies which had been snatched away.

“Shortly thereafter the Reich Bank president and Reich Minister
of Economics, Dr. Schacht, published in the English magazine,
_Foreign Affairs_, a detailed article on the German colonial
problem.”

That is on Page 2, I believe, of the English translation.

“For the rest Dr. Schacht laid out the categorical demand that
Germany must, in order to solve the problem of its raw
materials, get colonies which must be administered by Germany
and in which the German standard currency must be in
circulation.”

Now, the next group are articles dealing with the Versailles Treaty, and I will quote only from a few of them on Page 3 of that same translation. Here is one of 7 April 1934, Page 14, “What is the Situation Regarding Our Battle for Equal Rights?”. Another is entitled, “The Dictate of Versailles,” 30 June 1934, Page 15. The article reads in part:

“The dictate of Versailles established the political,
economical, and financial destruction of Germany in 440
artfully—one could also say devilishly—devised paragraphs;
this work of ignominy is a sample of endless and partly
contradictory repetitions in constantly new forms. Not too many
have occupied themselves with this thick book to a great extent,
for one could only do it with abomination.”

Another title is 7 July 1934, Page 15, “The Unbearable Limitations on our Fleet.” Another one: 19 January 1935, Page 13, “Versailles after 15 Years.” This article reads in part:

“This terrible word ‘Versailles’, since a blind nation ratified
it, has become a word of profanity for all those who are
infatuated with the spirit of this enormous production of
hatred. The Versailles dictate is German fate in the fullest
sense of the word. Every German bore up under the operation of
this fate during the past 15 years. Therefore, every last German
must also grasp the contents of this dictate so that one single
desire of its absolute destruction fills the whole German Volk.”

I shall omit the other quotation. The last one I shall refer to is February 1937, quoting “Versailles Will Be Liquidated”; and that, if Your Honor pleases, is the last paragraph on Page 4 of the English translation:

“The National Socialist movement has again achieved a victory,
for upon its flag since the beginning of the fight stands: The
liquidation of the Versailles Treaty. For this fight the SA
marched year after year.”

A third group of articles describing preparations for war, purportedly being carried on by other nations, are found on Page 5 of that same document, and I shall refer to just a few of them:

The issue of January 26, 1935, Page 14, “Military Training of English Youth,” showing pictures of Eton students wearing the traditional Eton dress—tall hats and frock coats—marching with rifles; another one is “The Army of the Soviet Union,” dated 16 March 1935, Page 14; another one, 4 April 1936, Page 13, “The Red Danger in the East”; another one, 29 August 1936, Page 10, “Russia Prepared for World War”; another one, 19 June 1937, Page 7, “Red Terrorism Nailed Down.”

I shall pass the rest of them.

Now, the next is the SA participation in the aggressive war phase of the conspiracy—the preparation by SA of the youth of Germany for participation in aggressive warfare. I hardly think I need emphasize that one of the most important steps in carrying out the conspiracy was the training of the youth of Germany in the technique of war and their preparation physically and spiritually for the waging of aggressive war. To the SA was delegated this most important responsibility. I have here Document Number 3215-PS, Exhibit Number USA-426, which I offer in evidence; and it is an excerpt from _Das Archiv_ and contains Hitler’s characterization of the task of the SA in this respect. It is on Page 1 of the English translation of 3215-PS. I start the reading where it says:

“Already in 1920 by the founding of the National Socialist
Sports Section (SA) the Führer established the extensive mission
of this SA at that time by declaring in the protocol of its
charter. . . . ‘The Sports Section (SA) shall one day be the
bearer of the military thought of a free people.’”

In the same sense the Führer said in his book, _Mein Kampf_:

“Give the German nation 6 million bodies perfectly trained in
sport, all fanatically inspired with the love of the fatherland
and trained to the highest offensive spirit, and a national
state will, if necessary, have created an army out of them in
less than 2 years. . . .”

The military character of the SA is demonstrated by its organizational composition. I refer to the chart on the wall, which is our Document Number 2168-PS. It is taken from this book, being the pamphlet of the SA Sturmführer; and the chart is taken from the official book. I simply refer to the chart and call to the attention of Your Honor that it was organized into units closely corresponding to those of the German Army. As the Tribunal will see, the organizational scheme consisted of divisions; at the top in that pyramidal structure the division, next the brigade, the regiment, the battalion, the company, the platoon, and the squad.

In addition, there were special units and branches, over to the right as Your Honor will notice, including cavalry, signal corps, engineer corps, and medical corps. There were also, as Bayer pointed out in his pamphlet, three officer training schools. Similarly, SA members wore distinctive uniforms adapted to military functions, bore arms, and engaged in training, forced marches, and other military exercises.

SA members, moreover, were governed by general regulations which closely resembled service regulations of an armed force. They are contained in Document Number 2820-PS, Exhibit Number USA-427, which I offer in evidence. If Your Honor pleases, they are found at Page 3 of the translation. I will simply refer to a few of them. These regulations provide for punishment, designating them as penal regulations, for disobedience of orders and infractions of regulations. The punishments which are provided demonstrate the militaristic character of the SA and include the following: Reprimand in private; reprimand in presence of superiors and announcement thereof at formations; prohibition of the right to wear service uniform; house arrest, _et cetera_.

Preparation for war through the SA training program was commenced in Germany as early as 1933, but the scope of this program was not made public because of the fact that it actually constituted a violation of the Treaty of Versailles. The strict secrecy with which the program was surrounded is shown in Document D-44, Exhibit Number USA-428, which I offer in evidence.

On Page 1 of the English translation—this is from the Supreme Command of the SA, Chief of Staff—and it has to do with publications on the SA:

“Further to my instruction Z II 1351/33 dated 11 July 33, I find
cause to ask all SA authorities to exercise the greatest caution
with regard to any publicity given to the SA service not only in
the press but also in the information and news sheets of the
individual SA units.

“Only during the last few days the Reich Ministry of the
Interior at the request of the Foreign Office has given strict
instructions to all Reich authorities according to which the
most severe control is to be exercised on all publications which
might give other countries an occasion to construe German
infringements of the terms of the Versailles Treaty.

“As is known from the Geneva negotiations, our opponents have
piled up material, collected in Germany and submitted to them,
which they use against us on every occasion during the
conferences.

“From this point of view, the information sheets circulating
among the subordinate SA units cause the liveliest concern. I
hold all higher SA leaders responsible that any such internal
information sheets appearing in the district of their command
are submitted to the most stringent control before they go into
print; and I feel compelled to draw attention to the liability
to prosecution for treason, as pronounced in official
instructions issued in the last few days, in cases where such
reports, printed no doubt in good faith, are published and
therefore exposed to the danger of falling into the wrong hands.

“On principle, pictures of the special technical units of the SA
and SS, in particular of the motorized, signal, and possibly
also of the air squads which now exist outside these formations,
are forbidden, such pictures enabling other countries to prove
the alleged formation of technical troop units.”

Similarly, secrecy was provided for in the order assigning a Wehrmacht officer to the SA in January 1934 to assist in the SA training program. This Document, 2823-PS, Exhibit Number USA-429, which is a copy of a memorandum of SA headquarters dated January 1934, designates an officer of the Wehrmacht to assist in the military training of SA members, and it goes on to provide—and I quote from Paragraph 7 of the English translation:

“For the purpose of camouflage, Lieutenant Colonel Auleb will
wear SA uniform with the insignia of rank according to more
detailed regulations of the Supreme SA leader.”

The military training program of the SA was for many years conducted under the guise of a sports program. This plan was created by Hitler as early as 1920 by the founding of what he called the sports program. The fact that the so-called sports program was in reality closely associated with, and in fact a means of providing, military training for the German youth is shown by the following characterization of the program by Lutze, the Chief of Staff of the SA, in an article written in 1939. I now refer to Document 3215-PS, Exhibit Number USA-426; and I quote excerpts of the English translation on Page 2:

“The decrees issued by the Führer to the SA in 1935 about the
renewal, in 1936 regarding the bestowal of the diploma and in
1937 about the repetition of the yearly exercises of the SA
sport badge, all served this goal. Parallel to this decree of
the Führer for physical strengthening and military
indoctrination, adequate measures were taken within the SA,
regarding organization and drilling. Out of the idea that the
preservation and the advancement of the military power of our
people must be specially fostered by military and physical
exercises, resulted a particular and systematic training in
these fields.

“In 25 troop schools and in three Reichsführer schools of the SA
22,000 to 25,000 officers and noncommissioned officers were
trained yearly since 1934 in special educational courses until
they possessed the education and examination certificates. In
clearly outlined training directives, the training goals which
had to be achieved yearly were given and at the same time the
yearly Reich competitive contests were established. Hand in hand
the training of the Führer Corps and the corresponding
organizational measures and the training at the front proceeded
on the broadest basis.”

In connection with the military training of the sports program, I refer to Document 2354-PS, Exhibit Number USA-430, which demonstrates the tests and standards required for obtaining the sports award—Page 2 of the English translation. I am not going to read all of it, if Your Honor pleases, but just refer to a few of them:

“Group II: Military sports; 25-kilometer march with pack; firing
of small-caliber arms; aimed throwing of hand grenades,
200-meter cross-country race with gas masks over four obstacles;
swimming or bicycle riding; basic knowledge of first aid in case
of accidents.”

I will pass the others.

In 1939 the SA sports program was formally recognized in a decree issued by Hitler as a military training program, and the SA was openly declared to be an agency for pre- and post-military training, that is, for military training prior to and following service in the Wehrmacht. I have Document Number 2383-PS . . .

THE PRESIDENT: Colonel Storey, you have just drawn our attention to a Document Number 3215-PS, which shows that from 1934 onwards, 25,000 officers and noncommissioned officers were trained by the SA.

COL. STOREY: Yes, Sir.

THE PRESIDENT: Isn’t that sufficient to show the military nature of the organization?

COL. STOREY: I think so. This was just the decree of Hitler. May I just refer to it by reference for the record? I will not read the decree.

THE PRESIDENT: Go on; what are you referring to?

COL. STOREY: Document 2383-PS, Page 11 of the English translation, contains a copy of the decree legalizing the training program for pre- and post-military training.

It would have been one thing for the SA to conduct a military training program for its members, but the SA program was not confined to its members. The entire youth of Germany was enlisted into a feverish program of military training.

I refer to a quotation in Document 2354-PS from the same organization book, which is at Page 2 of the English translation, in which the Chief of Staff Lutze said, and I quote briefly:

“In order to give conscious expression to the fostering of a
valiant spirit in all parts of the German people, I further
decide that this SA sports badge can also be earned and worn by
persons who are not members of the movement insofar as they
comply racially and ideologically with the National Socialist
requirements.”

Document 2168-PS shows that responsibility for conducting this nation-wide program was lodged in the operational main office of the SA. Page 8 of the English translation says, and I quote:

“The latter has, on the basis of the SA sport badge, to prepare
a thorough physical training of the bodies of all Germans
capable of bearing arms. In order to reach this goal, it has to
organize body exercises and sporting advancement so that the
masses of the people will be included by it and will be kept fit
to bear arms until old age. This martial preparedness must not
be achieved only by physical and mental training but also with
regard to character and ideology.”

I pass from that phase now.

Document 3215-PS is an excerpt from Das Archiv, and I refer to Pages 2 to 3 of the English translation beginning at the bottom of Page 2, and I quote:

“Next to the companies of the SA were the SA sport badge
associations, in which entered all the nationals who were
capable of bearing arms and who were prepared to voluntarily
answer the call of the SA for the preservation of military
proficiency. Up till now about 800,000 nationals outside the SA
could successfully undergo the physical betterment as well as
the political-military indoctrination of the SA on the basis of
the SA badge.”

The military program of the SA was not that of a mere marching and drill society; it embraced every phase of the technique of modern warfare. This is particularly demonstrated by consideration of the articles on military training which appeared publicly throughout the issues of the _SA-Mann_. I should like to refer to only a few of the titles, and they are set out on Pages 8 and 10 of Document 3050-PS. It is a great, long list, and I will only refer to five or six.

There is one of them, 17 February 1934, Page 7, “Pistol Shooting”; 21 April 1934, Page 13, “What Every SA Man Must Know about Aviation”; 19 May 1934, Page 13, “Chemical Warfare”; 2 June 1934, Page 14, “Modern Battle Methods in the View of the SA Man”; 4 August 1934, Page 13, “The Significance of Tanks and Motors in the Modern War.” I will omit references to the remainder.

Similarly, the issues of the _SA-Mann_ contain many photographs and articles demonstrating and portraying SA participation in military exercises, including forced marching, battle maneuvers, obstacle runs, small-caliber firing, and so on. I simply refer these to Your Honors, and they are shown on Pages 11 to 13 of Document Number 3050-PS. Just one or two titles: 24 August 1935, Page 2, “The SA Is and Remains the Shock Troop of the Third Reich.” Here is one showing the connection with the Wehrmacht: 2 September 1938, Page 1, “The SA and the Wehrmacht,” with pictures of SA men on field maneuvers throwing hand grenades. I will omit the rest of those.

Convincing evidence demonstrating the participation of the SA in the conspiracy is found in the fact that care was taken at all times to co-ordinate the military training of the SA with the requirements of the Wehrmacht. This is shown by Document 2821-PS, Exhibit Number USA-431, Page 1 of the English translation, quoting:

“Permanent liaison between the Reich Defense Ministry and the
Supreme Commander of the SA . . . has been assured.”

Another document, 3215-PS, which is an excerpt from _Das Archiv_, sets forth the co-operation and collaboration with the Wehrmacht and specialized military training; and it was stated in a speech of the Chief of Staff of the SA, Document 3215-PS, Page 2 of the English translation, Exhibit Number USA-426:

“In the course of this development also, special missions for
military training were placed on the SA. The Führer gave the SA
the cavalry and motor training and appointed SA
Obergruppenführer Litzmann as Reich Inspector with the mission
of securing the cavalry recruits and the requirements of the
German Wehrmacht through the SA. In close co-operation with
parts of the Wehrmacht, special certificates were created for
the communications, engineer, and medical units which, like the
cavalry certificate of the SA, are valued as a statement of
preference for employment in said units.”

Your Honor, we have two or three more quotations about co-operation with the Wehrmacht, but I believe they would be cumulative, and I will omit them. I will refer only to Document 2383-PS, Exhibit Number USA-410, Page 11. I will read a portion of the decree:

“The Führer: In amplification of my decrees of 15 February 1935
and of 18 March 1937 regarding the acquisition of the SA sports
insignia and the yearly repetitive exercises, I elevate the SA
sports badge to the level of the SA military badge and make it a
basis for pre- and post-military training. I designate the SA as
the standard bearer of this training.”

I skip now to Page 48 for the record.

The specialized training given SA members, in accordance with the requirements of the technical branches of the Wehrmacht, is described by SA Sturmführer Bayer, in Document Number 2168-PS, Exhibit Number USA-411; and it is Page 13 of the English translation:

“On one side, the young SA man who enters the Armed
Forces”—Wehrmacht—“from his branch comes prepared with a
multitude of prerequisites which facilitate and speed up
training in technical respect; while on the other side, those
very soldiers who, having served, return out of the Armed Forces
into the SA keep themselves, by constant practice, in a trained
condition physically and mentally and impart their knowledge to
their fellows.

“Thus they contribute a considerable portion to the enhancement
of the armed strength and fighting spirit of the German people.”

And then skipping down: “The SA each year is able to furnish many thousands of young trained cavalrymen to our Wehrmacht.” I will omit the rest of that.

I simply call attention now to an issue of the _SA-Mann_ dated 3 February 1939, at Page 3, which contains a photograph of Chief of Staff Lutze addressing a group of SA men. This photograph bears the caption, “We will be the Bridge between the Party and the Wehrmacht.”

The second reference shows a photograph of General Brauchitsch and Chief of Staff Lutze reviewing an SA unit.

Now, I pass to Document 3214-PS, which is Exhibit Number USA-432. There is only one page of it. Quoting:

“It was announced that SA men and Hitler Youths liable to
military service can fulfill their military duties in the SA
Regiment Feldherrnhalle, whose commander is General Field
Marshal, SA Obergruppenführer Göring. The regiment, for the
first time, was employed as Regiment of the Luftwaffe in the
occupation of the Sudetenland . . . under its leader and
regimental commander, SA Gruppenführer Reimann.”

THE PRESIDENT: Up to now you have brought evidence to our notice showing that the SA was voluntary. This shows it was conscripted. When did it become conscripted?

COL. STOREY: As I understand, Your Honor, if you joined the SA you got out of conscription, but once you were in it they could use you as desired. In other words, the SA was a voluntary organization.

THE PRESIDENT: That is the evidence you have given up to date.

COL. STOREY: Yes, Sir.

THE PRESIDENT: Well, when did it become liable to conscription or used as a substitute for conscription?

COL. STOREY: If Your Honor pleases, may I ask Mr. Burdell to answer that question? He has been working on it.

MR. CHARLES S. BURDELL (Assistant Trial Counsel for the United States): If Your Honor pleases, there never was conscription in the SA. As this document shows—Document 3214-PS—service in the Feldherrnhalle Regiment of the SA took the place of conscription. This first sentence in Document 3214-PS, which reads, “It was announced that SA men and Hitler Youths liable to military service can fulfill their military conscription in the SA Regiment Feldherrnhalle . . .” means, as I understand it, that SA men who are conscripted, that is SA men who are drafted after they have joined the SA, may serve their conscription by remaining in the SA or by transferring to the Feldherrnhalle Regiment of the SA.

The next paragraph of Document Number 3214-PS designates the requirements that must be fulfilled before the SA man can join this Feldherrnhalle Regiment, but if he fulfills those requirements he may join that regiment, and having done so, that serves the purpose or serves the function of conscription in the Wehrmacht.

I hope that answers Your Honor’s question.

COL. STOREY: In view of the above we would expect the SA to have been used as a striking force in the first steps of the aggressive war launched by Germany and as a basis for so-called commando groups, and such was the case. SA units were among the first of the Nazi military machine to invade Austria in the spring of 1938, as was proudly announced in an article appearing in the _SA-Mann_ of 19 March 1938, Page 10, the article entitled, “We Were There First.”

The SA participation in the occupation of the Sudetenland is also shown by Document Number 3036-PS, Exhibit Number USA-102; and that is an affidavit by Gottlob Berger, a former officeholder in the SS, who was assigned to the Sudeten German Free Corps. I quote Paragraphs 1 and 2 of the affidavit:

“1. In the fall of 1938 I held the rank and title of Oberführer
in the SS. In mid-September I was assigned as SS liaison officer
with Konrad Henlein’s Sudeten German Free Corps at their
headquarters in the castle at Donndorf outside Bayreuth. In this
position I was responsible for all liaison between the
Reichsführer SS Himmler and Henlein”—Your Honors will recall
Henlein was the leader in the Sudetenland—“and in particular, I
was delegated to select from the Sudeten Germans those who
appeared to be eligible for membership in the SS or VT
(Verfügungstruppe). In addition to myself, liaison officers
stationed with Henlein included an Obergruppenführer from the
NSKK, whose name I have forgotten, and SA Obergruppenführer Max
Jüttner, from the SA. In addition, Admiral Canaris, who was head
of the OKW Abwehr, appeared at Donndorf nearly every 2 days and
conferred with Henlein.”

Your Honors will recall that the Abwehr was the intelligence organization.

“2. In the course of my official duties at Henlein’s
headquarters I became familiar with the composition and
activities of the Free Corps. Three groups were being formed
under Henlein’s direction: One in the Eisenstein area, Bavaria;
one in the Bayreuth area; one in the Dresden area; and possibly
a fourth in Silesia. These groups should be composed only of
refugees from the Sudetenland who had crossed the border into
Germany, but they actually contained Germans with previous
service in the SA and the NSKK (Nazi Motor Corps) as well. These
Germans formed the backbone of the Free Corps. On paper the Free
Corps had a strength of 40,000 men . . . . Part of the equipment
furnished to Henlein, mostly haversacks, cooking utensils, and
blankets, was supplied by the SA.”

The adaptability of the SA to whatever purpose was required of it is demonstrated by its activities subsequent to the outbreak of the war. During the war the SA continued to carry out its military training program, but it also engaged in other functions. Its wartime activities are set out in Document 3219-PS, which is Exhibit Number USA-433, and Document 3216-PS, Exhibit Number USA-434, which are excerpts from _Das Archiv_.

I quote first, briefly, from Document 3219-PS, the whole text exclusive of the heading:

“The Chief of Staff of the SA, Wilhelm Schepmann, gave further
orders to increase the employment of the SA in the homeland war
territories, according to the requirements of total war. This
was done in numerous business conferences with leaders of the SA
divisions.

“As a result of these conferences as well as of measures already
carried out earlier for the totalization of the war employment,
the SA has placed 86 percent of its professional leader corps at
the disposal of the front, even though the war missions of the
SA have increased in the fields of pre-military training, the SA
penetration into new territorial parts of the Reich, the air-war
employment, the city and country guard, _et cetera_, during
wartime.

“The SA as a whole has given at present 70 percent of its
millions of members to the Wehrmacht.”

I call attention of Your Honors to the statement of the membership of August 26, 1944. I quote briefly from Document Number 3216-PS, the English translation, just one sentence:

“By command of the Chief of Staff of the SA, the SA unit
‘General Government’ was established, the command of which was
taken over by Governor General, SA Obergruppenführer Dr. Frank.”

I next offer in evidence an affidavit, being Document Number 3232-PS, Exhibit Number USA-435, by Walter Schellenberg:

“From the beginning of 1944 on, the SA also participated in many
of the functions which had previously been entrusted only to the
SS, the Sipo, and Army—for instance, the guarding of
concentration camps, of prisoner-of-war camps, supervision of
forced laborers in Germany and occupied areas. This co-operation
of the SA was planned and arranged for by high officials in
Berlin as early as the middle of 1943.”

This concludes my presentation of the principal points of evidence concerning the participation of the SA in the conspiracy, but before I conclude, I should like to present to the Tribunal a few points which establish the participation in the conspiracy by Defendant Göring in his capacity as an SA member or leader.

In 1923 Göring became commander of the entire SA. This is shown in the pamphlet, _The SA_, which is already in evidence, and the notation concerning Göring’s command appears at Page 2 of the translation, which I do not intend to quote but simply refer to.

Göring’s intention to employ the SA as a terroristic force to destroy political opponents is shown by a speech made by him on 3 March 1933, at a Nazi demonstration in Frankfurt. It is Document Number 1856-PS, Exhibit Number USA-437. It is an excerpt from a book entitled, _Hermann Göring, Speeches and Essays_. I quote what Göring said:

“Certainly I shall use the power of the State and the police to
the utmost, my dear Communists, so you won’t draw any false
conclusions; but the struggle to the death, in which my fist
will grasp your necks, I shall lead with those down there who
are the Brown Shirts.”

The importance of the SA under Göring in the early stages of the Nazi movement is shown by Document Number 3259-PS, Exhibit USA-424; and it is an English translation from the same document book. This is a letter written to Göring by Hitler, and I quote the letter:

“My dear Göring: