1. Between September 1939 and April 1945 all of the defendants herein,
acting pursuant to a common design, unlawfully, willfully, and knowingly
did conspire and agree together and with each other and with divers
other persons, to commit war crimes and crimes against humanity, as
defined in Control Council Law No. 10, Article II.
2. Throughout the period covered by this indictment all of the
defendants herein, acting in concert with each other and with others,
unlawfully, willfully, and knowingly were principals in, accessories to,
ordered, abetted, took a consenting part in, and were connected with
plans and enterprises involving the commission of war crimes and crimes
against humanity.
3. All of the defendants herein, acting in concert with others for whose
acts the defendants are responsible, unlawfully, willfully, and
knowingly participated as leaders, organizers, investigators, and
accomplices in the formulation and execution of the said common design,
conspiracy, plans, and enterprises to commit, and which involved the
commission of, war crimes and crimes against humanity.
4. It was a part of the said common design, conspiracy, plans, and
enterprises to perform medical experiments upon concentration camp
inmates and other living human subjects, without their consent, in the
course of which experiments the defendants committed the murders,
brutalities, cruelties, tortures, atrocities, and other inhuman acts,
more fully described in counts two and three of this indictment.
5. The said common design, conspiracy, plans, and enterprises embraced
the commission of war crimes and crimes against humanity, as set forth
in counts two and three of this indictment, in that the defendants
unlawfully, willfully, and knowingly encouraged, aided, abetted, and
participated in the subjection of thousands of persons, including
civilians, and members of the armed forces of nations then at war with
the German Reich, to murders, brutalities, cruelties, tortures,
atrocities, and other inhuman acts.