DR. LATERNSER: Yes, sir. Thank you.
DR. MENZEL: for defendant General Kuntze.
MR. FULKERSON: I just wanted to ask the Court if the Court has the document books which are now going to be presented. I don't have them.
THE PRESIDENT: I am advised by messenger that they are in the back room and will be presented here shortly.
(Document books produced.)
THE PRESIDENT: You may proceed.
DR. MENZEL: Menzel, on behalf of the defendant Kuntze. Before beginning with the presentation of documents on behalf of Kuntze, I should like to point out the following i.e. to the submission of further defense document books, referred to previously. From the compilation read by the Court before, the impression might be gained that the defense at the very last moment wished to produce a number of document books of the usual type, and that a delay was caused by this tactic. This is not the case. In my case, for instance, in the case of Document Book 4, it is by no means an ordinary document book of 50 or 60 pages. There are merely two documents which arrived rather late; one of them hears the date 30th of December, and which jointly only amount to 1-1/2 pages. Only because the other document book, No. 3, had been concluded, a new document book was to be presented. It is - as I have said before, only a very short text and it will only mean very little in the way of translation. May I now proceed with the reading of documents from Kuntze Document Books 1 to 3? I shall probably need one day for this. First, I wish to read the documents showing the necessity of the purges in Serbia. They were actions - operations in order to dispel and dissipate the bands; to prevent formation of new bands; to get hold of weapons; and to protect the population.
I shall begin with Document #34 in Document Book #2 on pages 5 to 7. The English pagination corresponds to the German. This document will be Exhibit #1. This document and subsequent documents are documents which have already been submitted by the prosecution and which, therefore, already have been assigned exhibit numbers. These documents, however, were not completely submitted by the prosecution. Only excerpts were read into the record. The prosecution naturally submitted those parts which appeared to support their thesis and their view. The points which I now wish to submit have neither been read nor have they been included in their document books.
I shall begin therefore with Document #34, Kuntze Book 2, Exhibit #1. It's a report of the Plenipotentiary Commanding General in Serbia to the Armed Forces Commander Southeast, dated 28 October 1941. The excerpts made by the prosecution bore Exhibit #124. They were in Book 4 on page 80 in the German text and page 132 of the English text. The newly submitted excerpt concerns only #2 A:
"Passenger train Doboj-Tuzla looted by Communists. 6 civilians killed. 6 wounded."
The document shows the necessity of purging operations.
The same is true of the continuation of this document on page 6. It's a report of the Plenipotentiary Commanding General in Serbia to the Armed Forces Commander Southeast, dated 31 October 1941, same exhibit number of the prosecution, excerpt 2b:
"Near Vrba 2 read bridges again destroyed. Guards and workers near Palilula kidnapped by bandits. 8 Serbian communities raided, looting in several communities in Croatia."
The thrid page of the same document is a report also made by the Plenipotentiary Commanding General in Serbia to the Armed Forces Commander Southeast dated 30 November 1941. The only relevant excerpt from this 10-day report is section 1:
"Political Situation.
"Serbian administrative organs have been further paralyzed by bandit raids on community offices, which extend to a great part of the Nisch surroundings."
This finishes this document.
I shall now proceed with the next document. Document #35 in the same Document Book #2 on pages 8 to 9, to be Exhibit 2, Kuntze. The prosecution exhibit number was 126. The first page contains a report by the Plenipotentiary Commanding General in Serbia to the Armed Forces Commander Southeast. I shall merely read from this report dated 9 November 1941, 2b:
"Blowing up of tracks near Dolac, Nisch-Skeplje line blocked for 47 hours, connection by changing trains.
"Air reconnaissance established the existence of many road blocks on Kraljeve-Raska road.
"Besna road bridge near Ilijas destroyed.
"Telephone line Sabac - Lesnica cut."
I shall then read point 3a:
"342nd Infantry Division: Operation southeast of Sabac and west of Kozeljeva completed. Bandit forces, who have now lost connection with one another, dispersed. Enemy losses are high, at least 100 were killed in combat.
"Rural population, who had been suppressed up till now, welcome German troops. Request their continued protection."
This shows the necessity for mopping up operations and also the fact that the occupation power had to repel the band attacks. It also shows the attitude of the population regarding this mopping up operation.
I shall now refer to the next document in Document Book 2. Correction, I have still to read from the next page of the same document, page 9, a report by the Plenipotentiary Commanding General in Serbia to the Armed Forces Commander Southeast dated 22 November, 1941. I shall read from section 2b:
"In Belgrade another 11 communists have been arrested. Unoccupied communities followed by a number of names, raided."
This also shows the necessity for mopping up operations.
I now wish to turn to Document #36, Document Book 3, pages 10 to 12 to be Exhibit #3 and it is connected up with the previous documents. Page 10 is a daily report which has already been submitted by the Prosecution in excerpts as Exhibit 128, in Volume 5, page 102 of the English and page 70 of the German. I shall now read those excerpts not presented by the Prosecution which also show the necessity for mopping up operations.
"Serbia: 1.) In the area south of Krupanj again strong bandit forces. Northeast of Bola Palanka, and southwest of Krusevac 2 communities raided, 2 concrete bridges north of Vlasetince (east of Loskov) destroyed. In Belgrade depot with 500 kilograms of ecrasite discovered in the vicinity of the Danube railroad station, 29 arrests.
"Croatia: Continued numerous raids in the area of Sarajevo-TuzlaDoboj.
"On Bos. Novi-Bos. Krupa line, attack on Croat armored train. Raids by insurgents and damage to a concrete bridge near Poljana. A time-bomb exploded on the Belgrade-Agram main line west of Brod. Little damage, traffic not disrupted."
I shall now proceed with the next page of the same document, a daily report dated 18 December 1941. I merely wish to read the excerpt:
"Serbia: 1. Strong bandit forces southwest of Valjevo. Bandit force west of Kosnjerici effects evasive action towards Croat border. An unoccupied community raided east of Pozarevac.
"2. 342nd Infantry Division: During operation in former Mihailovic territory 1 trench mortar, 16 heavy aerial bombs, and much equipment captured.
"717th Infantry Division: Operation near Lebane completed. Enemy dispersed, 10 killed, 4 machine guns captured. No casualties of own forces."
"4- Blowing up of tracks near Vranje (Bulgarian territory) on Nisch-Skoplje main line; line was blocked for several hours."
This not only shoves the necessity for another mopping up operation, but also the fact that the bandits escaped and that events in neighboring territories also took place.
I shall now refer to the next page. That's page 12. It's an excerpt from a daily report dated 30 December 1941:
"Servia: 20th till 24th December. 5 unoccupied communities near Nisch raided."
This finishes Document 36.
The next document, Document 37 in Document Book 2 will be Exhibit 4. Prosecution Exhibit 176. The first page, 13, contains an excerpt from a daily report of the Commander in Serbia dated the 14th of February 1942. I shall read from 2b:
"Increased enemy activity in the Derventa area. Begov Han railroad station and saw-mill (in Bosna Valley) attacked and burned down by insurgents. Rail connection cut on 13th until 2000.
"Rogatica encircled by insurgents."
The next page of the document, that's page 14, excerpt from a daily report of 15 January 1942, the Commanding General in Serbia to the Armed Forces Commander South East:
"12 February. 11 telegraph poles sawed down on Nisch-Knjazevac road. Power and water supply in Rogatica cut off by insurgents.
"Poison gas shells found in Zenica railroad repair shop."
This also shows the oppression endured by the civilian population at the hands of the insurgents and it's significant that poison gas shells were found.
So much for Document 37.
I shall now start with another topic: Documents designed to prove that the occupation by the German occupation power was effective at that time. It's a series of documents and I thought that presentation of these documents was superfluous because it could not possibly be doubted that at the time an adequate occupation of the country was in force. As the prosecution, however, contests that an effective occupation existed at all, I am unfortunately compelled to submit these documents. They show, as we shall see later in some detail, that in Serbia, except for sabotage and single attacks, there was law and order.
That, in Croatia however, several interventions were necessary. These documents further show that the German occupation power was strong enough to fulfill its occupation tasks because the insurgents took evasive action. Further measures taken by the German occupation powers against Ustasha are described in these documents and also excesses perpetrated by Ustasha. The documents also show that the occupation authorities did not incite any ethnic fightings but tried to restrict them. Also, as regards the treatment of prisoners, these documents are rather informative.
I shall now begin with Document No. 65 in Document Book III, pages 1 to 3. It will be Exhibit No. 5. It is on page 1.
THE PRESIDENT: Pardon me; we do not have Document Book III as yet.
DR. MENZEL: Well, it is not my fault because the document book was filed already a long time ago.
THE PRESIDENT: I am advise that it left the defense center on December 21st and the message center seemingly had a lost weekend. At least, the document is lost.
DR. MENZEL: I understand the book was translated towards the end of December and the English translation was available to us by the beginning of January. Therefore, it must be misplaced and I don't know how.
MR. FULKERSON: Your Honor, perhaps he can sort of skip over what he was going to introduce in Book III and just go on in Books 1 and II which we have here and thus prevent a break in the proceedings. Is that possible.
DR. MENZEL: I have just heard that the English translation will be available by tomorrow. I shall, therefore, omit the topic regarding an effective German occupation. I don't wish to impair it by dealing with other topics now because it mainly consists of Document Book III. I shall then deal with this point at the very end of my presentation. Now I shall deal with another topic. I shall, therefore, submit the documents showing that at that time in the Southeast there were summary courts martial. Of course, this was not mentioned in all the documents because it was a matter of course, but I should like at least presents few documents.
I shall begin with Document Book II. Document 48 on pages 33 to 35......
If it please the Tribunal, I understand that the documents books have just arrived.
May I then revert to my previous topic?
THE PRESIDENT: If that is your wish then it is agreeable with the Tribunal. You present the case as you see fit under the circumstances now.
DR. MENZEL: Then I should prefer to stick to my original plan. The Tribunal will recall that I was dealing with the question of how far the occupation was effective. It was a question of Document 63 in Book III, Exhibit No. 5. It was a report to the Military Commander Southeast.
THE PRESIDENT: Which page, please?
DR. MENZEL: Pages 1 to 3. It is a report to the Wehrmacht Commander Southeast, the Commanding General, dated 10 January 1942. I shall read Section 1.
"General and Enemy Situation.
"As a result of the arrival of Bulgarian troops? the authority of the Nedic Government has been undermined. So far, however, there are no signs for its resignation. There is a considerable despendency among the population. Up till now no open outbreaks of hostilities against the occupation power have occurred.
"For the rest, the enemy situation as a whole in Serbia, as well as in the adjoining Croatian territory, is unchanged. Apparently larger enemy movements are prevented owing to the season.
"The number of acts of sabotage, consisting of 57, is somewhat high as during the last period of report. The focal point of the sabotage activities is, as before, in the area east of Nish. Raids against the main rail lines in Croatia are increasing."
This shows that the occupation was effective because there was quiet and law and order in Serbia and in Eastern Croatia;
even in a complete and effective occupation some sabotage cannot be entirely avoided. The document also shows that there were no reprisals taken for those acts of sabotage.
I shall now refer to the next page. It is a report dated the 20th of January 1942, same agencies:
"General&enemy Situation-Overall situation unchanged. Arrival of the Bulgarians continued to take place without friction. Conduct of the Serbian auxiliary police units and the Chetniks of Kosta Pecanac towards the Bulgarians has so far been loyal.
"The only stronger bands which are still present are in the Serbian Montenegrin border area south of Uzice, in the area southwest of Valjevo, in the area southwest of Nish. "The first of the above mentioned bands is being checked by a relatively strong Serbian Volunteer Unit, against the other two bands operations by the Serbian auxiliary police are being prepared."
That is page 2, to be followed by page 3, report of the 30 January 1942, same agencies. That is from the Commanding General Serbia to the Military Commander Southeast, Section 1:
"I. General Situation and Enemy Situation "1.) Over all situation in general unchanged.
"Eastern Croatian Area: The general picture about the conduct and intentions of the Dangic-people is not completely clear as yet. The Dangic units, have evaded combat with German troops.
"The experiences gained during the operation of the 342nd and 718th Infantry Divisions corroborate the enemy picture which was expected in the combat area. The enemy accepted the fight at scattered places only; owing to the weather situation and the terrain which is difficult for the attacker the enemy also succeeded in withdrawing large units into the mountains and roadless forests. It is to be assumed that, following withdrawal of the German troops, these groups will attempt to resume their activities.
Presumably the area of assembly for the dispersed bands is at the moment in the area north and northeast of Sarajevo.
"Communist terror acts are increasing in the area directly east and southeast of Zanica (surprise attacks, lootings, recruiting measures) "It has been ascertained that the area of "Ozren-Planina" was the springboard for the partisan activities in the area west and southwest of Doboj up to Toslic."
This also shows there was law and order in the Serbian area and that in Eastern Croatia the enemy took evasive action. For the rest it can be shown again that the terms "Communist" and "partisans" were used indiscriminately in these reports.
I now wish to turn to Document Book II. That is Document No. 40, pages 19 to 20. The English pages are 19 to 20a. This document will be Exhibit 6.
(Menzel) It is a report to the OKW, from Wehrmacht Commander Southeast, dated 29 January 1942. I read from Figure 3:
"3) Cooperation with Croatian troops satisfactory. Croatian liaison officers well trained and energetic, Croatian troops cannot be used independently because of lack of training and equipment, as well as lack of officers and serviceable non-commissioned officers. Cooperation with Croatian air force satisfactory.
Cooperation on Italian side so long as fighting is not involved. Use of Italian airmen led to our own losses as reported, further use of them was accordingly dispensed with. Promised Italian operation on the south wing did not come off because of non-arrival of the Italian division."
I shall omit the next sentence and shall proceed with Section 4:
"The insurgents again retreated cleverly into their locations in the distant areas of the difficult territory before the advancing German troops. This cannot be prevented by the Croatian troops remaining in the area which has been mopped up, as they are inferior in combat."
I shall then omit a few sentences, and at the end:
"The overwhelming majority of the Serbian people behave in a friendly way to the German troops and are anxious when they march away, since they fear the continuation of excesses by Ustasha. Thousands of Serbian refugees have arrived near Kos. Mitrovies and south of Zvornik without food or lodging; danger of disease and danger of new unrest in Serbia."
"5) Lasting pacification cannot be brought about without intensive occupation at the same time, since the insurgents, who are firmly rooted in the population, retreat skillfully and vanish into their houses as the situation may be.
Effective operations only possible in favorable weather waste of troops now committed is too great in comparison with results obtained.
Following agreement with Croatian government an attempt is being made to bring about tranquility in Eastern Bosnia. For this purpose the entire area remains a zone of operations. Commander of 718th Div., who is in command of all Croatian and German troop units, is exercising executive power upon order of the Plenipotentiary Commanding General in Serbia. An attempt is being made in close connection with the Croatian government to build up a new administration in the country.
At present an operation is proceeding against Ozren Mountains, from which about the same result may be expected.
The following would be necessary for effective pacification measures:
1) Unified supreme command of all German, Italian and Croatian troops.
2) More or less simultaneous operations in the entire Croatian area in order to prevent the insurgents from disappearing into unoccupied or only slightly occupied areas, as has been repeatedly established up to now.
3) Fundamental change in the Italian attitude, who up to now have avoided any conflict with insurgents.
Active fighting is necessary.
4) Substantial reinforcement of the German troops for the German occupation army area, since 1 div. or 2 regiments are not enough.
5) No toleration whatsoever of the Ustasha in territory inhabited by Serbs.
Only under these conditions can a final pacification be brought about of the areas and transport roads so important to the German war economy. Otherwise with present forces only local mopping up in very narrow districts is possible without safe supply routes to and from."
This document shows that the enemy did not feel strong enough to oppose the occupation power, but that they always took evasive action; that the Serbian population was not hostile towards the Germans, but was rather afraid of the Ustasha.
The difficulties in enforcing the occupation consisted, as this document shows, in the failure of the Italians and the Croatians in mopping up their areas. It is apparent from the document how strong the position of the Germans was as compared with the Ustasha.
So much for this document.
I now have to revert to Document Book 3, Document 64, pages 4 to 6 in German and English, to be Exhibit 7. It is an excerpt from the War Diary, Marcy 1942. I shall read from page 5:
First, report of the 1 March 1942.
"Section 3: Acts of sabotage and surprise attacks have decreased in numbers as compared to the previous period of report, however, they extended over the entire eastern area of Croatia and Serbia. The total number of the reported incidents amounts to 45."
Then, Section 4, the second sentence:
"The formation of new bands and increased activities by those which already have been reported, as well as increased Communist propaganda, make a new revolt early in the year increasingly likely."
This report is particularly important regarding the revolt which was to be expected in the spring, and to which the order of the 19 March is to be attributed. This order threatens the necessary stringent measures which later were not enforced, as will have to be established by the plea.
Now reading from the same page, under Section II:
"An Insurgent Infantry Division inflicted heavy casualties upon the enemy in numerous skirmishes and, during a search, arrested a number of suspected persons who were detained for court martial investigation."
The next excerpt, IV:
"594 seriously injured and sick Serbian prisoners of war arrived in Belgrade from Germany. They were distributed to the Military Hospitals in Belgrade and Kragujevac for further medical care by Serbian medical personnel."
It is evident from this page that suspects were dealt with by court martial; that there were no reprisals ordered for acts of sabotage, and that medical care was accorded to Serbian prisoners.
The next page, that is page 6 -
MR. FULKERSON: I do not want to be discourteous, but I would like to ask for more matter and less argument. We have a time allotted for us to make our argument in which we draw our conclusions from this testimony; as I understand it, we are now simply supposed to be presenting it.
DR. MENZEL: I am endeavoring, if the Tribunal please, to be as succinct as possible, and to make such statements as are absolutely necessary to make it intelligible while this very document is being presented. All other matters will, of course, be dealth with in my plea.
THE PRESIDENT: If you will kindly make your explanatory remarks just as brief as possible, it will be helpful to the Tribunal.
DR. MENZEL: I will now road from the next page, that is page 6.
The German losses were:
"Germans: 25 killed, 61 wounded, 13 missing Croatians:
42 killed, 92 wounded, 15 missing Bulgarians:
17 killed, 24 wounded Total:
84 killed, 177 wounded, 28 missing."
These figures are necessary in order to determine at a later stage the ratio of the reprisals to the losses.
I shall then read from Section 6, merely a breif excerpt:
"The Serbian Government, with the approval of the administrative staff, arranges for meetings in which the population is informed about the situation by prominent persons, is warned not to commit any rash acts and in which an attempt is made to win their loyal cooperation."
That is, a warning not to commit sabotage acts.
DR. LATERNSER: If the Tribunal please, I beg your pardon, but with the agreement of my colleague, I wish to offer one more document which I omitted previously. I regret the inconvenience caused but I would like to do it now.
It is document List, 157, which is to be Exhibit 139. It is in Document Book 3, page 41. I merely wish to read one paragraph, the 4th paragraph, It is an affidavit of the Judge Advocate Gruen.
The passage reads:
"While I served with the Staff of the Military District South East it did not come to my attention that partisans, who had been captured in combat or in between operations, were executed without judgment from either courts-martial or a military court.
I informed the army judges under my command to the effect that the provisions of International Law were to be observed also in the fight against partisans and that all captured partisans would have to be brought before the courts. This point was also discussed in talks held by the judges. The judges were advised to inform their convening authorities accordingly. During my repeated official trips when, I checked the activities of the military courts and the courtsmartial I did not notice in Serbia any infringements in this direction."
I thank the Court for its indulgence.
DR. MENZEL: May I now proceed with document No. 38, Kunze, in Document Book 2, pages 15 and 16, in the German text, and 15 and 16A in the English text. If these document books are constantly changing, then it is due to the fact that I wish to present these reports in their proper chronological sequense in order to cover the whole period of time.
THE PRESIDENT: This is Exhibit 8 is it not?
DR. MENZEL: Exhibit 8.
THE PRESIDENT: We will not be able to complete the reading of this during this afternoon's session, and with the identification of the document we will adjourn at this time until 9:30 tomorrow morning.
(Tribunal in recess until 0930 hours January 3, 1948)
Official transcript of Military Tribunal V, Case VII, in the matter of the United States of America against Wilhelm List, et al, defendants, sitting at Nurnberg, Germany on 8 January 1948 , 0930, hours, Justice Carter presiding.
THE MARSHAL: Persons in the Courtroom will please find their seats.
The Honorable, the Judges of Military Tribunal V.
Military Tribunal V is now in session. God save the United States of America and this Honorable Tribunal.
There will be order in the Court.
THE PRESIDENT: Mr. Marshal, will you ascertain if all of the defendants are present in the Courtroom?
THE MARSHAL: May it please Your Honor, all of the defendants are present in the Courtroom.
THE PRESIDENT: Judge Carter will preside at this day's session.
PRESIDING JUDGE CARTER: You may proceed.
DR. MENZEL: May it please the Tribunal, I wish to proceed with the presentation of documents. The Court will recall that we stopped yesterday with Exhibit No. 8 that was Document 38, in Document Book 2 Kunze, Pages 15 and 16 in the German, and Pages 15 to 16a in the English.
These documents, generally, are documents designed to prove that contrary to the assertions made in the trial brief of the Prosecution, the occupation was effective. This document in particular from page 15 will be submitted as proving that in Serbia there were only small bands, and that the insurgents in Eastern Croatia did not stand up and fight, but took evasive action.
It is a report by the Commanding General in Serbia, addressed to Military Commander Southeast, dated the 10th of February, '42. May I now read from Section 1:
I. Enemy Situation
1.) Serbian area: It was now possible to get a fairly clear picture concerning the bands appearing around Nish and Kursumlja.
There are 3 groups in the region between the Suvaplanina and Babikagora, as well as south and north of the Toplica.
I shall omit the next sentence and proceed with the first sentence of Section 2:
2.) Croatian area: Operation Ozren Area also confirmed the enemy picture expected there. The enemy never took up a position for a decisive battle, but after slight local resistance withdrew into impassable terrain so as to assemble again afterwards.
I shall omit the next sentence and proceed with the next paragraph:
Insurgents mobilized northeast and northwest of Doboj. At present their strength can be assumed to be more than 2500 men. They are threatening the Doboj-Bosnia Brod railroad.
The southern part of the Croatian east area is being disturbed by bands which are appearing again after the conclusion of the operation of the 342nd Inf. Div.
I shall omit the remainder of Section 2.
Under Section 3:
3.) Acts of sabotage and attacks have increased considerably during the period of the report in Serbia, especially in the area east of Nish, in contrast to which they remained on about the same level in the Croatian east area as in the period of the previous report. The number of cases reported amounts to a total of 63.
That finishes page 15 and 15a. I shall now proceed with page 16. This document is designed to prove that in general law and order prevailed in Serbia but that a new insurrection was possible, and that attacks were carried out everywhere where bands were reported.
The document will also be submitted as proving that suspects were subjected to summary courts martial. Again it is a report by the Commanding General in Serbia, to the Armed Forces Commander Southeast in the proper chronological sequence, dated 20 February '42.
I shall read from 3:
3. Acts of sabotage and attacks.
The number of acts of sabotage and attacks comprised in Serbia and in the Croatian east area has again increased in comparison with the period of the last report, especially in east Serbia where some serious acts of sabotage on transport cars and telephone lines between Nish-Loskovac and Nish-Kursumlija are to be noted.
The total number of cages reported amounts to 73.
I shall omit one sentence and proceed with Section 4:
If in general it was comparatively quiet in the Serbian area during the period of the report, nevertheless it should not be overlooked that this circumstance is mostly to be attributed to unfavorable weather. The appearance of smaller or larger bands is reported by almost all subordinate units. The possibility continues to exist that the insurgents are secretly making preparations on a larger scale for a new rising.
I shall omit the first part of the next paragraph II regarding the 714th Infantry Division, and shall proceed in the middle of the paragraph:
Besides this, the Division successfully carried out several moppingup operations against a number of villages, during which a number of suspects were arrested who are being brought before a court-martial investigation.
So much for Document 38.
May I now turn to the adjoining document, that is Document 39 in Document Book II on pages 17 and 18 of the German text, and 17 and 18 in the English, to be Exhibit No. 9. It is in Document Book 2. This document is submitted as establishing attacks on unoccupied communities, and setting forth that a mopping-up operation was necessary to protect the civilian population. It is a report by the Armed Forces Commander in Serbia to the Armed Forces Commander Southeast, dated the 21 of February, 1942. I shall read from 2 (b):
"Apparently a larger number of insurgents in the Vlasotinca area, 13-17 February, attacks on Rutevca and Vrelo near Aloksinac, Luzeno, etc."
That is the report dated the 21st of February.
The next page, page 18 of the same document, contains a similar report dated the 23rd of February, 1942, submitted as establishing that Jewish partisans were also participating in the insurrection. I read figure 2a:
"Communist Jewish special messenger with Serbian, Italian and Albanian identification papers arrested in Podujevo. Interrogation in progress."
That finishes Exhibit No. 9.