Now, that will come up each time proof is put in about an experiment made in the United States, or in Franco, or elsewhere. The Prosecution will be put to the burden of investigating through its sources as to precisely what went on, or the Defense Counsel will be raising doubts in the mind of the Tribunal that the same thing happened in the instance which they cite as happened in the Dachau Concentration camp. We will have to come in and prove that it did not happen that way, that the experimental subjects were given a certain form to complete, that they voluntarily underwent the experiment, that it was fully explained to them beforehand, that the whole purpose of the experiment was laid out to them -- all those matters.
As a practical matter, I think that would be the burden that would be heaped upon the Prosecution, or we would find this record spread full of little short extracts from this or that medical journal, making reference to a freezing experiment here, a malaria experiment there, or a yellow fever experiment in the Panama Canal Zone. We would then have to come forward and explain those experiments because I think Defense Counsel is undoubtedly not in a position to show that in any one of those instances was the experiment carried out on involuntary subjects or in any way tainted with criminality.
The Prosecution here is willing to accept the burden of proving that the experiments here charged were carried out on non-volunteers in every sense of the word, and I mean by that going greatly beyond any concept of duress which may be drawn from mere incarceration in a prison, so I think that it is a matter of some consideration for the Court as to how these matters are to be treated, because there is every reason to believe that Defense Counsel will fill this record full of such matters as that, and the Prosecution either can take the position of ignoring them or trying to find out exactly what went on in each experiment.
For my own part I can not see their materiality, and certainly I can not see their probitive value; unless they are willing to assume the burden that experiments are systematically carried out in other parts of the world in the manner here alleged by the Prosecution, then I can not see that they have any materiality. If they can prove that and if that is the purpose for which they are offered, and they can show that everybody all over the world was doing what we charge these people with doing, why, then, it certainly would have some materiality and probitive value. Otherwise, I for one object to the offer of this document for any purpose other than eliciting an opinion from the witness who was on the stand, and I don't think it need be admitted for that purpose since he has already been shown the document and has given his opinion.
DR. SERVATIUS: Mr. President, may I state my point of view with regard to the speech by the Prosecutor?
The probitive value of this document, in my opinion, is very apparent. Just what the defendant is being charged with here is shown by the document with the case it sets forth. It shows that, by order of the government, experiments are being carried out on persons of whom the expert of the Prosecution himself says that they could not be considered as voluntary.
In addition to this, the general importance of this document is apparent. One speaks about crimes which the defendants are alleged to have committed, but we wan to determine if they are crimes. Precisely the ethical and legal bases are very doubtful in this case. The Prosecution refers to the criminal law code of all countries, which is to be basis in judging these defendants, and the Prosecution has placed an expert on the stand here who has voiced an opinion in the ethical sense. The purpose was to establish a basis for the accusation. I now must be given the possibility present the material that counters these motives. I do not need to go into the facts if all the experiments are described in articles and books in accordance with the truth.
For me it is an important point of view that these things are being accepted by the public all over the world without any objection. For example, here in Document 1, no voice was raised in America to object to this. This is not a single case. The same thing is happening in all countries for many years. In Document Book 3 I have composed a number of articles from literature which would astonish everybody, but it is still more astonishing that nobody in the world has been excited about it.
Now we have an accusation made in the same sense, and the law of humanity is referred to--that it must be of importance to be able to prove that humanity and humaneness have not been considered to that extent up to now.
It is correct that the document has been presented only for identification thus far, but I now request that it be admitted in evidence.
DR. SEIDL (Defense Counsel for defendants Gebhardt, Oberhouser and Fischer): May it please the Tribunal, in consideration of the fact that this is a basic question, I request permission to express myself briefly in connection with this question.
May it please the Tribunal, a number of defendants, and particularly the defendants whom I represent, are being accused of having carried out medical experiments, and that these acts represent crimes. In order to support these claims, the Prosecution has referred to the general regulations of the criminal code, as set forth in Control Council Law Number 10. This law does not set forth that an experiment under certain conditions is a crime, but this law contains every other law and deeds like murder, injury, and so on.
The law is not something that is hovering in the air, but, in order to reach a just verdict, it is necessary to show actual conditions in the field in question and to examine them. Therefore, if the defense presents evidence of this kind, it is not in order to claim that in other countries -- in the United States and in France -crimes of this kind are also being committed, but the one to fulfill the abstract contents of the criminal code. It is a fact that many laws do contain these characteristics of the actual deeds. -Indications which have a certain evaluation as a prerequisite. In order to judge the question, if a medical experiment, it's a crime. The question has to be examined if this experiment violates a law. Furthermore, the question has to be examined if such experiment is a deed with which a person can be charged. Examining those questions, it cannot be indifferent if physicians in other countries act in such a given situation. For the defense, therefore, it is decisive, if also in other countries and under application of the generally valid, ethical and medical professional standards, physicians, in the interests of a higher goal, of a view to a special necessity, can carry out such experiments. Insofar as evidence so far presented by the defense is important because it places the Tribunal in a position to examine, to obstract the laws in their application and reality and to properly evaluate the presentation, just like international law, can these things be equally represented, just as little as possible in judging the question, if a certain medical experiment represents a crime, without considering the practice of physicians in other countries. That is all I have to say.
PROFESSOR SAUTER: (Counsel for the defendant Blome): May it please the Tribunal, first of all I would request you to tell me if a very principal question is not involved here. In my opinion, we have reached a decisive phase in the trial. For us defense counsels it is not a case of raising a lot of smoke, as the representative of the prosecution has stated.
A defense which realizes its responsibility and fulfills this duty properly rejects that. For us, we on our part want to contribute to the glorification of the legal situation, and so, to give the necessary basis to the Tribunal in order to reach a verdict which will actually, from all sides, be considered as fair, correct and wise. The defendants have been accused of inflicting injuries, physical injuries and murder. As the law is written, in your law code as well as ours, "Thou shalt not kill. Thou shalt not inflict physical damage. Thou shalt not injure anybody." But what the human being has to do individually in order to fulfill this law, and in what cases he can diverge from this law, we are not directly told by the law. In a case, like the case on hand, the medical professional ethics will have a decisive weight. A professional concept of the physician who properly fulfills his duty, will show to the Judge, in order to enable him to judge what is necessary for medical science, and what is superfluous; what can be considered as legal, and what is without any doubt illegal. The professional concept of the medical profession gives this information on the subject. That is the professional concept not only of the German physicians, but also of the foreign medical profession, just like certain basic principles exist which always return in the same way in all criminal codes, so for the medical profession, in all civilized states there are certain procedures and directives which are being followed by all countries and which must be considered correct. If now the defense is able, by means of a large number of literary evidence from the press and also from special medical journals-if the defense is able to give a basis for the Tribunal in order to clarify this difficult question, under what conditions and with what precautionary measures such experiments are permissible, then the Tribunal will certainly welcome, if it can also consider this material in reaching a verdict. The defense cannot be satisfied that any individual export, for example like Professor Leibbrand, is a certain way is the only assistant of the Tribunal in deciding these difficult questions. Your Honors, already the fact that Professor Leibbrand maintains the point of view that a prisoner was not at all able to give his consent to an experiment requires a certain amount of coercion towards accepting this opinion.
Furthermore, we have heard that a large number and series of experiments was mentioned by this export which the medical literature deals with. For the most part, he did not know it at all. And the, he only stated: "Yes, I know them", but he did not with a single word state his opinion to them, and he did not mention any word, if he likewise considers the experiments carried out in foreign countries as criminal, or if he considers those experiments abroad justified and legal.
Your Honors, if it has been stated, crimes are being committed everywhere, not only in Germany, but also in foreign countries. Then this prase does not serve the decision of our case at all. If serious scientists report in medical journals about experiments which they have carried out and if, furthermore, no public prosecutor and no court in the world objects to those experiments, or has taken these scientists to give an account of themselves, then this expresses the fact that, in the case of the research concerned, no crimes were committed, but that there were serious scientific attempts. And, when I read through these document books, when amongst the scientists from whom the reports originate I see directors of international repute, directors who have received the highest distinctions for their work, for these experiments, then this may lead to a certain caution with regard to the question that it is stated then, these people who are living abroad, also are just simply criminals, and their research must be considered as criminal.
But the prosecution does not bear this consequence into account. And, in the interests of justice, in ay opinion, it must be examined if, and to what extent, and in what connections one or the other experiment, which one or the other of the defendants may have carried out must be placed on the same level with experiments which have been not described as crimes by the international press, but as medical achievements, which in many cases received the highest recognition. As a result of this, Your Honors, I am of the opinion that it is not only in the interests of the verdict in this trial, but also in the interests of medical science itself, that those trials should contribute to tell the medical scientists in Germany and all over the world, when they can carry out experiments, and under what prerequisites they have to start, and hat precautionary measures they have to follow, and things of that kind.
Your Honors, if this question is clarified as a result of your verdict, then this will contribute just as much to the needs of the medical profession as the first Nuremberg trial contributed to the further development of international law. I therefore request that it is necessary that you should obtain knowledge of this literature, and that perhaps you shall occupy yourself with it in your verdict. That is all I have to say, Mr. President.
MR. McHANEY: I have listened with great interest to the impassioned pleas of Dr. Sauter and other defense counsel, but I have not yet heard a clear delineation of the purpose for which this proof is offered, and the materiality to this case. I would suggest that the Court reserve its ruling, that the defense get together and make up their collective minds as to precisely what they expect to prove with this, and just exactly how it relates itself to the matter at issue in this case; that, on the basis of such a statement, the prosecution will submit a brief to the Tribunal. The prosecution has always assumed, the burden, and has added in the indictment, that these experiments or these murders and tortures and other inhumane treatments resulted from medical experiments carried out on involuntary human subjects.
I do not think they can find one word or one statement, anywhere the world over, that says such medical experiments are lawful anywhere. The thing at issue in this case is the voluntary character of the experiments here carried out, and it behooves this Court nothing, adds nothing to the proof, to have them load down this record with hundreds of examples of human experimentation. This trial is not condemning human experimentation generally at all, and not one word has been uttered by the prosecution to indicate such a thing. The ordinary law of assault and battery and manslaughter certainly gives to the United States, and I take it they exist in Germany, and if these defendants committed experiments upon persons who didn't cosent to undertaking those experiments, then I see no difficult legal question presented at all. And now we can talk in very impassioned terms about the necessity of this Tribunal orienting itself upon the precise conditions under which every human experiment has ever been carried out. I submit that it is both unnecessary, immaterial and constitutes and intolerable burden, and will prolong this trial beyond any measure of reason. The very experiment they're talking about in Life Magazine, reads on its face that it is voluntary; then how can it be material to justify the experiments carried out by Schilling in Dachau, when the prosecution has undertaken the burden of proving those experiments were carried out on non-volunteers, persons who were forced to undergo the experiment. Then whence comes the materiality of an experiment carried out in a prison in the State of Illinois, with malaria. Now, it so happens that we know a little bit about that experiment. We have the forms which were submitted to the prisoners, which advised them what would be done to them, and which required that they sign their name to it on the bottom if they wished to undergo it. We have a radio speech made by one of the persons who did undergo it; we have quite a mass of facts concerning this particular experiment, and the same thing will be true of other experiments, to which they will make some sort of an allusion during the course of this case. But I submit they prove nothing they don't clarify anything at issue in this trial, and would put, in fact, the burden on the prosecution of clarifying the little scrap of evidence - if you call it evidence - which they will try to throw into the record of this case.
Then we will have to come forward and really tell the Tribunal what it's all about, or the Tribunal will have the uneasy feeling that maybe there was something going on here, something like something that has been charged here. I think it's a rather important issue, and one which bears very materially on the length of this trial, and I think it would clarify the situation if defense counsel would clearly and concisely state what they expect to prove by this type of evidence and how it bears on any issue which we have in this case, and then we will undertake to answer it.
THE PRESIDENT: The Tribunal will be in recess now.
(A recess was taken).
THE MARSHAL: The Tribunal is again in session. May it please your Honor the defendant Oberhauser is absent in accordance with the approval of the Court.
THE PRESIDENT: The Secretary General will note for the record that the defendant, Herta Oberhauser, is absent with the consent of the Court.
The question of admitting an exhibit was being considered by the Court before the recess.
DR. FLEMMING: Yes.
THE PRESIDENT: The Tribunal is ready to rule on that question. The Court has considered the document of the defendant Brandt as Exhibit No. 1, and without establishing any rule which ill be a precedent in any future case, each case as it arises will be individually considered by the Tribunal. The Tribunal admits in evidence the defendant's Karl Brandt, Exhibit No. i.
DR. SERVATIUS (Attorney for defendant Karl Brandt):
Document No. 2, Exhibit No. 2, I submit the periodic list of experiments; it hasn't been made ready in the English yet, and it will be submitted to the Tribunal in the English translation at a later date.
As Exhibit No. 3, I am submitting the chart, which can be seen on the wall, together with an affidavit of the co-defendant Brack, which was already read into the record. This will become Exhibit No. 3 A; it is Document KB 15, Exhibit No. 3; KB 8, Exhibit 3 A.
THE PRESIDENT: The Court will require that copies be furnished to each member of the Tribunal.
DR. SERVATIUS: They haven't been made available as yet since the mimeographing department is overburdened, but they will be submitted to the Tribunal at a later date. Mr. President, I submit the originals and I shall see to it that the Tribunal will receive their copies.
THE PRESIDENT: That will be sufficient; you may submit the copies.
JUDGE SEBRING: Is it the chart, Doctor, or Brandt's affidavit that you are asking to be submitted as Exhibit 3?
DR. SERVATIUS: The chart as 3, and the attached affidavit as 3-A. I further submit as Exhibit 4-A the Document KB-29, which was the document of the prosecution, NO-150. That will become Exhibit 4-A and 4-B. It was already submitted during the course of the examination.
MR. HARDY: What does that document refer to that you just mentioned, Doctor?
DR. SERVATIUS: The contents of the document constitute a letter by Bouhler according to which he has to give directives with reference to the execution of euthanasia.
THE PRESIDENT: Well, where is that document to be found? Is that contained in Brandt's document book?
DR. SERVATIUS: No, it is not contained in the document book. It was submitted during the examination. It was submitted by the prosecution and you will receive copies later, and I have already submitted the photostat.
MR. HARDY: Your Honor, I do not recall that Document NO-150 was submitted by the prosecution. I believe it was submitted by defense counsel in examination of Brandt, and I imagine English copies are available and I will try to assist Dr. Servatius in getting them for you.
DR. SERVATIUS: It has been submitted to the Language Division but was not yet returned. I shall submit it as soon as I have it.
I am now offering an affidavit of Miss Alike Krohne. She is an employee who worked in the office of Brandt. It can be found in the document book, page number 7 under KB-4. I have a technical question in that connection. There are two document books. This is contained in document book number 1, page 7.
THE PRESIDENT: Copies of this document book furnished to the Tribunal do not have the pages numbered. Where do we find this document?
DR. SERVATIUS: There is an index at the beginning of the document book, and the document books are numbered according to their figures so that you can easily find document KB-4.
THE PRESIDENT: Unfortunately, the index page of the Brandt document book 1 is illegible.
DR. SERVATIUS: Your Honor, it is page number 8. Your Honor, the English text isn't quite legible.
THE PRESIDENT: we have found the document, Karl Brandt Exhibit 4.
DR. SERVATIUS: Mr. President, I would be grateful if you would tell me how you want me to read the documents. Will it be sufficient if I just roughly tell you the content and then cite certain passages, or is it necessary to read the document in its entirety? I may point out that during the trial before the IMT it was considered sufficient if merely the essential points were referred to in order to shorten the proceedings.
THE PRESIDENT: The Tribunal is of the opinion that that will be sufficient, to call attention to essential portions of the document.
MR. HARDY: May it please the Tribunal, I have two questions to ask Dr. Servatius in connection with this affidavit.
JUDGE SEBRING: May I ask first, that is coming in as what exhibit number?
D3. SERVATIUS: It will be Exhibit Number 5.
MR. HARDY: In connection with Exhibit Number 5, as I see it from my copy, I believe this document was not signed in the presence of Dr. Servatius, and not having the rules of the Tribunal before me now in connection with the procedure necessary to receive a document here in evidence in good form, I question the right to admit this into evidence due to the fact that such certificate that it is a correct signature was not obtained by Dr. Servatius or in his presence. It shows on the face of the document that the affiant is from Bremen. I reserve the right now to object to this document later after I have had time to peruse the rule of the Tribunal in connection with the admissibility of affidavits.
THE PRESIDENT: The prosecution may reserve the right to object to the document.
DR. SERVATIUS: Mr. President, I signed this document and thereby certified that it was signed in my presence.
I believe it is an error on the part of the prosecution to say that just because the woman was in Bremen it wasn't signed in my presence; it actually was. If this explanation doesn't suffice I would have to bring a new certification of the witness saying that she signed this in my presence.
HR. HARDY: The prosecution accepts the word of counsel that it was signed in his presence and refrains from objection.
THE PRESIDENT: To save future trouble a corrected certificate should be found showing that the witness signed the document in presence of counsel.
DR. SERVATIUS: The witness Krohne was employed as a secretary with the defendant Brandt from the beginning of the war until January 1944, and she says that the agency was normally in the Reich Chancellery but to that in reality Brandt worked in the surgical university clinic. She knows about the order of March 1944 which referred to the anti-chemical warfare counts and she says that that decree was very brief. I quote: "I definitely know that it did not contain directives on experiments with poison gas nor did I see later on in the correspondence or elsewhere anything that would have intimated that Professor Brandt had anything to do with such." End quote.
Then the witness refers to a radio interview regarding the office of Professor Brandt and she says the following, and I quotes:
"In January 1945 Professor Brandt participated in a radio interview by Dr. Ott in the Berlin Broadcasting Station and made the following declaration as to the functions of his new agency. I remember that upon the question as to the character of his position towards the other agencies of the Reich he replied that one had to consider his position as that of a sort of 'differentiate'.
The witness continues and I quote: "I wrote that interview together with the secretary Hanke at the time and was also present when it was being recorded and was comparing the transmission with my manuscript."
Finally the witness states that the professor Brandt was active as an Oberarzt in addition to his other duties, in addition to his other organizational duties.
This brings me to my next document which can be found in the document book under KB-5. It is an affidavit made by a certain Dr. Richard Reinhardt who was commissioned to institute the treasury and who received all the material connected with that agency. The witness, as a member of the Wehrmacht was commissioned and assigned to Agency Brandt in 1945. My text by error has 1943; that is, he was only assigned to this agency near the end of the war out on the basis of his special tasks received insight into the entire files. He settles in detail the structure of the office; he pictures the legal foundation; and he confirms what we already know from the testimony of witness Dr. Lammers, namely, the size of the office, the scarcity of funds, and then comes to the question of euthanasia, and in that connection he says, and I quotes:
"I can give the assurance that among the controlled cash receipts no items pertained to or were in connection with the euthanasia program."
The witness knows something about the gas defense decree of the 1st of March 1944 which was recorded under the designation, Noli, and in that connection he ..../..... says the following and I quote:
"The decree which was filed among tie usual secret records of the agency had been handed over to me by the secretary for a quick study. I do not recollect its wording exactly but it reads about as follows: 'charge my General Commissioner Professor Dr. Karl Brandt to intervene authoritatively in questions of gas defense. The Reich Minister for Armament and War Production is instructed to give Professor Brandt admittance to tie assembly shops at any time and to offer him all necessary assistance and information he might require.'" I now come to the following document which id Document KB-6 which I offer as Exhibit Number 7. It is the affidavit of another employee, a certain Frau Jutta Rach.
From the 1st of April 1943 until April 1945 she was active in Karl Brandt's office. She was in chau cf keeping the registry and she became famili .r wit! tie contents of the records kept there, amongst them Hitler's initial euthanasia decree to Brandt and Bouhler, and in that connection she says the following and I quote:
"With reference to this euthanasia decree there was no special correspondence and what there was only in the form of reports from doctors or parents on births of physically or mentally handicapped children for whom euthanasia was requests. They were dealt with only insofar as it was advised to consult recommended medical authorities for study of the case or to get financial assistance. Approvals for the requested euthanasia were never given."
The witness further makes statements about the persons that had access to the office and says the following, and I quote:
"Reichsleiter Bouhler and the agency chief Brack I am acquainted with as members of the Fuehrer's Chancellery. There was no official correspondence with them in any way connected with euthanasia or Reich committee. The names of Professor Dr. Hayde, Professor Dr. Nietsche are unknown to me. If they had anything to do with an agency in my time I would necessarily have known them.
The names of Dr. Pfannmueller, Schumann and Falken hauser were not know to me in the agency either. Correspondence with Dr. Linden's office, so far as I know, was limited to bombed out hospitals and their transfer. There was no correspondence either with Dr. Conti in connection with euthanasia and Reich Committee matters. So far as I knew there was also no written correspondence with Blankenburg, Hegener and Haefner. Blankenburg and Haefner are indeed known to me but only for the reason that they worked in the same office building."
I do not know of any discussion on Euthanasia with Bouhler's office. I would have necessity known of this.
I now skip a paragraph and I come to the part where the witness speaks about Bodelschwing, and I quote:
"I further testify that at that time professor Brandt enjoyed thoroughly friendly relations with Pastor von Bodelschwing. In the Summer of 1943 I was present when Pastor von Bodelschwing once.spent a whole afternoon as a guest in Professor Brandt's residence, and both of them conversed very unreservedly. I can further recall that Pastor von Bodelschwing once spoke publicity of the fact that his institutions had been spared such encroachments."
I now come to Document KB 7, which I am offering as Exhibit No. 8.
THE PRESIDENT: Just a moment. What document did you offer a.s Brandt's Exhibit 6.
DR. SERVATIUS: Exhibit 6 is Document Karl Brandt, KB 5, and the document which was just road, KB 6, will become Exhibit No. 7. That is the document of Jutta Rach.
I now come to Document KB 7, which will become Exhibit No. 8. It is n affidavit of the nurse Netty Germann. It only has a general content and shows that the defendant Karl Brandt was active a s physician in the clinic and that he carefully cared for his patients. This is being submitted in order to show in what manner the activity of Karl Brandt was exercised and how he was engaged in his various tasks.
And, the Document KB 8 has already been submitted, and that brings me down to Document KB 9, which will become Exhibit No. 9. This is an affidavit of Professor Werner Schulemann. Doctor Schulemann is a specialist in Malaria research, and I quote:
"During the war I was a full professor of pharmacology at the University of Bonn and was a consultant at the Special-Malaria Hospitals Godeshohe and Rheinblick in Bad Godesberg, in the Army Command District VI. In these hospitals in connection with my institute Malaria research was carried on, and carried on in accordance with the methods recognized and customary with specialists at home and abroad.
"I came in contact with Professor Karl Brandt in the Summer of 1943 when I approached him in order to make the Malaria hospitals secure from other claims and was successful in winning his help. In the scientific discussions on Malaria research which took place then Professor Karl Brandt never made any suggestions or gave any directions to me, or even made any allusion to the effect that experiments should be performed on human beings in an unlawful manner. In particular, he did not speak of Malaria experiments which had been carried cut in Dachau.
"If Professor Karl Brandt had been active in this type of research he would have had to discuss the questions involved with me especially as I am known as a specialist in this field. I received very high scientific distinctions for my achievements in the production of synthetic malaria medicines, among others the Mary-Kingsley medal of the Liverpool School of Tropical Medicine in 1938; and after the occupation by the allied troops I immediately got permission to continue the work in my institute. On the basis of all that I know about Professor Brandt. I consider it highly improbable that he had anything to do with criminal experiments, or that ho approved of them, asked for them or suggested them.
"I met Professor Brandt twice during the war and each time I was pleased at his clear, clean and frankly critical attitude towards the entire development. I emphasize especially his frankness and his understanding for academic-scientific problems."
I drop out Document KB 10, which is the witness Gutzeit, and I submit now Document KB 11, Exhibit No. 10. This is an affidavit of Doctor Schieber. It is designated as Affidavit II, since, more than one was given by him. The witness Schieber speaks about the "Action Brandt". This work was Already mentioned during the course of the proceedings and. he explains the "Action Brandt" as the execution of a medical program. He goes on to speak about these special orders which Brandt received and I quote: This order was issued at the beginning of March 1944 as a parallel to the medical program, "Action Brandt". This decree in its **, contents, is addressed to the Speer Ministry and was, according to its purpose, immediate production order by which Professor Doctor Karl Brandt was opposed to the manufacture, as a buyer, and conceding the production had full powers of control at the same time.
As far as I remember there was no scientific medical research order for professor Karl Brandt attached to it. We are here concerned with the anti-chemical warfare decree.
And, I now come to the next document which was also made by the witness Schieber. It is KB 12, which I am submitting as Exhibit No. 11. It deals with the fact that Defendant Karl Brandt managed to get animals at great expense in the Summer of 1944, and that he transferred them from Spain to Germany. It says here in order to carry out the task, and we are concerned with biological research parallel to human beings, as certain animal action was started by me and Professor Karl Brandt for the Armament office, of approximately 200,000 Swiss Franks, and after my recognition as Chief of Army Supply Office in October 1944, from the Speer Ministry, I made strenuous efforts together with Professor Karl Brandt to have a large number of animals brought by extremely difficult air transportation from Spain to Germany. These were put at Professor Karl Brandt's disposal for experimental purposes.
I then submit Document KB 13, as Exhibit No. 12. This is an affidavit by the co-defendant Rudolf Brandt, which I am going to read, and I quote:
"I, Rudolf Brandt, defendant in Case I before the Military Tribunal at Nuremberg, Germany, have given a series of affidavits which were produced in evidence by the Prosecution during this case. I affirm, under oath, that after having been duly warned that I am liable to punishment if I make a false statement. My statement corresponds to the truth and was made to be offered in evidence at the Military Tribunal I at Nuremberg, Germany.
"In this affidavit I have given the the Prosecution, and which were produced as evidence, I declared that toe co-defendant Professor Karl Brandt, surely has had knowledge of the Sterilization and that, of course, he had known of the Euthanasia experiments, and that he surely had known of the Typhus experiments.