11. Between September 1939 and April 1945 all of the defendants herein
unlawfully, willfully, and knowingly committed crimes against humanity,
as defined by Article II of Control Council Law No. 10, in that they
were principals in, accessories to, ordered, abetted, took a consenting
part in, and were connected with plans and enterprises involving medical
experiments, without the subjects’ consent, upon German civilians and
nationals of other countries, in the course of which experiments the
defendants committed murders, brutalities, cruelties, tortures,
atrocities, and other inhuman acts. The particulars concerning such
experiments are set forth in paragraph 6 of count two of this indictment
and are incorporated herein by reference.
12. Between June 1943 and September 1944 the defendants Rudolf Brandt
and Sievers unlawfully, willfully, and knowingly committed crimes
against humanity, as defined by Article II of Control Council Law No.
10, in that they were principals in, accessories to, ordered, abetted,
took a consenting part in, and were connected with plans and enterprises
involving the murder of German civilians and nationals of other
countries. The particulars concerning such murders are set forth in
paragraph 7 of count two of this indictment and are incorporated herein
by reference.
13. Between May 1942 and January 1944[5] the defendants Blome and Rudolf
Brandt unlawfully, willfully, and knowingly committed crimes against
humanity, as defined by Article II of Control Council Law No. 10, in
that they were principals in, accessories to, ordered, abetted, took a
consenting part in, and were connected with plans and enterprises
involving the murder and mistreatment of tens of thousands of Polish
nationals. The particulars concerning such murder and inhuman treatment
are set forth in paragraph 8 of count two of this indictment and are
incorporated herein by reference.
14. Between September 1939 and April 1945 the defendants Karl Brandt,
Blome, Brack, and Hoven unlawfully, willfully, and knowingly committed
crimes against humanity, as defined by Article II of Control Council Law
No. 10, in that they were principals in, accessories to, ordered,
abetted, took a consenting part in, and were connected with plans and
enterprises involving the execution of the so-called “euthanasia”
program of the German Reich, in the course of which the defendants
herein murdered hundreds of thousands of human beings, including German
civilians, as well as civilians of other nations. The particulars
concerning such murders are set forth in paragraph 9 of count two of
this indictment and are incorporated herein by reference.
15. The said crimes against humanity constitute violations of
international conventions, including Article 46 of the Hague
Regulations, 1907, the laws and customs of war, the general principles
of criminal law as derived from the criminal laws of all civilized
nations, the internal penal laws of the countries in which such crimes
were committed, and of Article II of Control Council Law No. 10.