Just answer this question with yes or no.
I was convinced that nothing would happen with caladium. That it is impossible to sterilize a human that way and even in small amounts that is, in small experimental series, it is almost impossible to work with caladium.
Q. May it please the Tribunal, before I continue to question the witness I first want to introduce a number of documents from my Document Book II. First Document Pokorny 16.
MR. HARDY: Your Honor, I don't have Document Book No. II. I went through all my document books this morning and I am unable to find Document Book II.
DR. HOFFMANN: I only have it in German.
MR. HARDY: I can't follow in German very well, your Honor.
DR. HOFFMANN: Your Honor, I submitted my Document Books as it should be done and I regret very much that the Prosecution did not got one but I shall be able to change the situation by having an English book fetched.
MR. HARDY: He can proceed with his documents, your Honor and I can render any objections later if I desire to do so. I can follow him.
THE PRESIDENT: Very well, with that understanding counsel may proceed.
DR. HOFFMAN: I now submit document #16, Document Book 2, page 31. There are four photostats of photographs ...
THE PRESIDENT: What is the exhibit number you assigned to this document, counsel?
DR. HOFFMAN: #15, Your Honor.
They are photographs from the Manual of Biological Remedies of the division by Dr. Gerhard Madaus from the year 1938. Photographs have been taken out of the book and have been certified by a notary.
The next document I introduce is Document #17, page 34. This is the monograph by G. Madaus and Fr. E. Koch, "Studies of Animal Experiments Pertaining to Sterilization by Medication." This is the monograph which is the basis of the article in the "Umschau" and which was also inclosed in the letter by Dr. Pokerny.
The next document I would like to submit is Document Pokerny #18, Exhibit 17, page 49. This is a monograph " 'Magic Plants' in the Light of Experimental Research" in "Die Umshhau". This is the document which was also inclosed in Dr. Pokerny's letter.
As Document 21 I submit excerpts from Clinical Endocrinology, a test book for physicians and students, by Arthur Jores, page 58. This will be Exhibit #20.
THE PRESIDENT: Counsel, what has become of exhibits numbers 18 and 19? Are you skipping...
DR. HOFFMAN: 18 and 19? - we have exhibits numbers 17 and 18. No, excuse me, Your Honor, I have not submitted 19 as yet. I submitted Documents 18 and 21.
THE PRESIDENT: And you assigned to Document 21 Exhibit #20, as I understand you. It should be Exhibit #18, should it not?
DR. HOFFMAN: Yes, your Honor.
I then submit Document Pokerny 22, page 59. It is an excerpt from the text book of General Pathology and the Pathological Anatomy of H. Ribbert, and by Dr. Karl Sternberg. This is Exhibit 21.
THE PRESIDENT: That should be Exhibit 19, Counsel.
BY DR. HOFFMAN:
Q: Yes, I beg your pardon.
Then I submit Document 23. This is Exhibit 20, page 60.
Witness, before, you were already speaking about the application of caladium in large and small doses. Would the administration in small doses have anything to do with homeopathic application and what was your attitude toward homeopathic medicine in 1941?
A: After modern medicine had put its knowledge on an absolutely safe basis, on the basis of experimental research, to that modern medicine today can be compared to mathematics. I, therefore, never accepted the theory of the doctrine of homeopathic medicine which does not have an experimental basis. That certain successes were achieved by homeopathic medicine I attribute to the fact that the low concentration of medicine - let us say D-i and D-2 -- are the same as those in medical theory and, in some cases, they are even large. The next concentrations, D-3 and D-4, are in accordance with the smallest amounts used in pharmacology and the rest of the concentrations, up to D-100, are not based on any experimental basis. This is only a broad statement. A great deal could be said about it.
Q: Witness, in 1941, did you know the firm of Madaus and Koch in Dresden-Radebeul? Did you know its name or did you have any relations with this firm?
A: I knew only the name of the firm through the advertisements which were sent to me and because I examined the drugs on the basis of these advertisements and was not satisfied with the results.
Q: Witness, in 1941, when you wrote this letter, did you see from the papers of Madaus and Koch which dealt with caladium - did you see in that an attempt on the part of the firm to open up a new field for homeopathic medicine for themselves?
A: From the report, it is clearly visible that the firm had the intention in regard to inner secretionary diseases to treat them with plant drugs and now wanted to bring out a number of medicines for this field.
Perhaps it would take up too much time if I would quote the appropriate places from the paper, but perhaps, in order to clarify the matter once, I may quote in the paper on experimental medicine, page 83, it says that vegetable materials - hormones .....
Q: (Interrupting) Witness, please state the page where it is written.
A: Page 83.
THE PRESIDENT: Witness, is the quotation which you propose to read very long? If it is, I would suggest that it be prepared and put in as a document.
WITNESS: Mr. President, I wrote down, what I thought at the time thoughts passed very quickly. Of course, this description is somewhat involved. If it is desired, I can submit a scientific document as a sample. However, I would like to ask that I may refer to the main points.
MR. HARDY: Your Honor, this document he is referring to - the translation is in our document books. If we could get the page number we should have the exact translation of what he is reading.
THE PRESIDENT: All, counsel, the Tribunal has had the document books and has examined them and will examine them again. Why is it advisable or helpful for the witness to epeat what is already before the Tribunal and in the document book? He can call attention to certain matters if he considers them important, but I see no object in reading what we already have before us in the case.
DR. HOFFMAN: Mr. President, I agree with you entirely. Only, it seems correct to me that the witness should explain what his thoughts were at the time when he supposed that these drugs would be unsuccessful.
THE PRESIDENT: That is entirely proper, counsel, but I see no object in re-reading That we already have before us. If he will give us the page of the document book where this is found, we can follow his explanations from the document book.
DR. HOFFMAN: Dr. Pokerny, thus, as you have heard, it is not expedient to read that part from the document. Instead I would like to repeat ny question.
THE PRESIDENT: Well, counsel, first give us the page and volume of the document book where we can find this document to which his reference is made.
DR. HOFFMANN: Mr. President, I cannot give you that figure. I would like to have the witness state the page number.
Q From what page did you quote?
A This is somewhat complicated. Of course, I could not refer to the English Document Book, but I referred to the original pages, and since the first paper is the basis of experimental medicine, I regard it as Description I, and the paper in "Unschau" as Edition II. Therefore, I cited the page numbers of these original documents of the quotations I wanted to read, which are included in my German Document Book. The page numbers in the English edition I cannot state.
DR. HOFFMAN: Mr. President, I hear the page numbers in the English Document Book are the same as in the German.
Q Witness, give the number of the pages in the German Document Book, the number of the pages?
A In the paper on experimental medicine it is Document 14 in the Document Book, and that is on page 83.
DR. HARDY: 46-A, your honor's book.
THE PRESIDENT: The Witness may proceed with the explanation.
THE WITNESS: Shall I quote the paragraph?
Q Would you please return to my question? I asked you in the experiments which forms the basis of the papers could you draw any conclusions?
A I could draw the conclusions that the firm prepared drugs from the treatment of inner secretion disorders. Part of these are venereal disease preparations, that is drugs for the sexual sphere. This is also apparent from the paper, that the rirm was inclined to introduce Caladium as a sexual drug. I already stated that in regard to the drug Caladium D-1, which had already been introduced at that time, it was not known to me.
Q Thus from the very beginning for those economic reasons was the scientific value cf the work doubtful for you?
(no response).
A The scientific value or the value of the drug Caladium D-1 I doubted later on altogether, for the simple reason that the authors state that they carry out experiments with mice which brought about sterilization in 10 mice, but those results, however, could not be produced legally. At that tine the experiments with the rats and had not yet been carried out, and it was considered somewhat during that on the basis of this scientific basis to introduce a drug to increase potency under the name of Caladium D-1.
Q Witness, is a homeopathic basic principle applied in these papers and from your point of view of classical medicine what is your attitude?
A Before answering this question I would like to say since I did not know Caladium D-1 I considered the entire paper as an advertisement, so to say, that is a preparation for the introduction of a drug. The homeopathic principle, the reversal, that a drug in enlarged dosages is destructive and in homeopathic dosages is productive, is cited by the authors, and I am under the impression that due to the allegedly destructive effect of Caladium, just because of this homeopathic principle of "the "reversal" effect, the pharmacological effectiveness of Caladium D-1 is supposed to be proven.
Q Witness, what doubts did you have in detail as to the scientific basis of the work?
AAfter the second paper in the "Umschau", that is a semiscientific lay journal, which is based on the same principles as the scientific paper in the journal for experimental medicine, certain contradictions became obvious in both papers. I therefore doubted the value of the work. This assertion I would like to support by two quotations. The question to what extent the male sperm can be damaged by a poison so that the progeny would also be damaged is a concept in medicine which used to be called germ spasmatic damage. This was a question of conflict in hereditary syphillis and T.B. and with opponents of nicotine and alcohol, and for all students of eugenics.
Now, in the experimental medicine this first paper, page 75 of the original, I quote:
"Whether the progeny of a male for only a short time with Caladium animal, which had been treated, will be damaged. Since it is outside of our paper we cannot decide with certainty. We only want to state that one female normal rabbit in spite of good care in the stable and good food produced living animals for one day.
MR. HARDY: He is quoting new from the document book and I haven't been able to catch up with him and find the quotation. I would like to use this in the course of cross-examination and follow this pamphlet, so if you will hesitate while we find this page I will appreciate it.
THE PRESIDENT: Can the witness refer to the number of the page in the German document book?
THE WITNESS: Mr. President, I stated page 75 of the original article.
DR. HOFFMANN: Page 42 of the Document Book II - correction, it is page 41-A,
THE PRESIDENT: You say it is page 41-A?
THE WITNESS: Oh, Yes, Your Honor, it is page 41-A to page 42. Shall I repeat?
Q No, please continue.
A This is on page 42, page 41-A, the second sentence: "It can only be mentioned that a normal female rabbit gave birth to young which lived only one day despite the best of care after having been mated with a male, which had not been treated with Caladium a sufficiently long time."
I would like to add here as an explanation that young animals which live for one day are a daily occurrence with rabbits, and this second version -
Q What page?
A Page 632, at the bottom of the original document.
Q Page 632? That cannot be correct.
A Yes, it is.
Q What page?
A 632.
Q You must be mistaken, witness?
A Oh, excuse me. Page 602.
DR. HOFFMANN: It is page 52 of the document book, Your Honor.
THE PRESIDENT: Proceed, witness.
THE WITNESS: I quote: "It could not be finally determined whether any ill-effect is produced in these young ones, which descend from a male, which has been treated with caladium only for a short period of time, however, it seems probable on the basis of the results obtained to date."
Such an important conclusion, which is treated in such a superficial manner and categorically stated hardly seemed to be correct, to me.
BY DR. HOFFMANN:
Q: Witness, the question of sterility seems to me to be one of the most important factors in these animal experiments. From the treatment of this question by the authors of these papers; did you gather anything from your negative attitude?
A: I do not want to quote the sentences which refer to this in order not to take up too much time here, but I only want to refer to the charts which are on pages 71 and 75, as Chart No. i and Chart No. 4-A of the original, that is on page 75.
MR. HARDY: It might help matters somewhat if the defendant will refer to the document numbers, as he refers to the various pages and charts. He has jumped from one document to the other. That has confused us considerably and the record will not show he is referring to Exhibit 16 as one exhibit is opposed to the other. This refers to Exhibit 17, which is one part of the testimony and refers to Exhibit 16 in the other part. This refers to page 71, which is the pamphlet, which I believe is Exhibit Number ..... I confuse myself. If he will refer to the exhibit numbers, it will help me a bit.
THE PRESIDENT: Counsel, the Tribunal does not want to prejudice the defendant's case, nor interfere with the orderly procedure, but the manner in which you are proceeding is certainly confusing. Would it not be possible for the witness to state his conclusions and later on you can write a schedule as to the page and number on which he bases the conclusion.
I am merely suggesting this, as I do not want to interfere with the presentation of your case, but this method of proceeding is certainly confusing.
BY DR. HOFFMANN:
Q: Witness, you can very well state your final conclusions and don't always refer to the pages, you can refer to them quite generally.
A: Mr. President, that is what I meant before. The paper is Document 14 from Experimental Medicine, the second from "Die Umschau" Document No. 18 is the commentary and I will make the comparison between the two papers in writing if I may be permitted to do so to draw the final conclusions. Then I would, in accordance with your wishes, Your Honor, be able to admit my final conclusions, in writing and state the page numbers.
Q: These scientific references I shall then submit in the form of an affidavit, Your Honor.
THE PRESIDENT: That will be perfectly satisfactory. Proceed, witness.
THE WITNESS: The paper asserts that sterility in human beings may be permanent in the male and in the female it would only bring about a temporary sterilization. If, however, one takes a look at the charts on pages 71 and 75, one sees that of the male animals four remained, two of these die, one is killed. To evaluate the length of sterility only one single animal remains and this animal is observed for 44 days. On the basis of such an experiment one cannot draw any conclusions to the effect that a preparation brings about a permanent sterilization.
With regard to the female animals, of twelve animals, five die of poisoning of the genital, three bring no results and three remain. These three animals are observed for from 40 to 45 days, a span of time which is certainly not sufficient to be able to make any statements about the length of stability, because the vary damaged by the poison needs at least that length of time in order to divert itself of this long term chronic poisoning by the drug or to recover from it.
BY DR. HOFFMANN:
Q: Witness, did you consider the number of the animal series sufficient to clarify such questions, or from the scientific point of view was it necessary to experiment with more animals?
A: The first experiment with male animals was carried out within nine animals, three of whom died and only one remained alive. I already mentioned that. Five were killed.
Of the female animals, a total twelve, there were four failures, five died of chronic poisoning, at least that is how I regard the caladium effect, two were killed and three remained alive, these small numbers thus will in no way prove anything.
I only want to quote the number of animals which are necessary to develop a test. At least 40 animals are necessary really in order to carry out the test.
Q: Witness, Madaus carries out a control experiment with Knollgrass; do you know what that is and do you think such a control group is convincing?
A: After I described the Caladium effect as an unspecific effect of leucocydes, another poisonous plant would have to be used as a control. Knollgrass is not poisonous, therefore the means of comparison is lacking.
Now, the drug was administered by means of injection or orally. By having it administered orally, it is nothing else but feeding and if it is administered as an injection, it is very dangerous because it is not sterilized. Therefore, the control animals who are given Knollgrass die as follows: one male rat gets 50%, if you have two.
Of the female control animals, there was originally three, all of them died, that is 100%. One cannot work with such numbers.
Q: Witness, in the paper you cite the concept of sterilization by medicines; please make some remarks on that subject?
A: The explanation of sterilization by medicines is a concept which was known already before this paper was written. Actually it even originated in 1907 when Hippel and Badenstecher as subsidiary findings put this phenomenon, Madaus and Koch, however, talked as if they had introduced this concept of the medical literature. It is possible that I misunderstood them in this respect, however.
Q. Witness, do you find quotations in the paper which did not sound scientific?
A. In scientific papers sentences like the following sound somewhat peculiar. In both papers, for example, they write the natives administered caladium in large amounts to their enemies in order to extinguish their potency and I cannot imagine how one can administer large amounts of a poisonous plant to any one, especially to an enemy. That is a sentence with a suggestive effect. Furthermore, in the second version on page 600 of the original, the authors speak of the unconscious eating of this plant among the natives and that they regarded the plant as a welcome means of secret elimination of inconvenient enemies. They write also for that purpose they also poison their arrows with the sap of the plant and administer the poison to the natives by the wound made by the arrow. This is a very direct comparison.
THE PRESIDENT: Counsel is it not possible to ask the witness questions concerning his conclusions. The Tribunal is satisfied he has read very extensively on this subject. Can he not give in a more concise form his conclusions on the matter that might be pertinent to the inquiry than by these lengthy references to books of poison arrows and so on? I fail to see any materiality to it, that it has any probative value whatsoever. I don't want to interfere with your case as I said before but cannot the witness begin with his own work and his own conclusions, what he did or did not do?
DR. HOFFMAN: Your Honor, the witness as I have already stated, did two different things, that is, he wrote two letters, that is everything he did, he testified to that effect, and I would like for him to show and to describe why at that time when he studied the papers he was of the opinion that nothing could be achieved with this caladium. That is why I am asking him about it. However, I do not want to go into long scientific discussions. I only thought that these statements representing what he felt at the time when he realized the scientific failure of this work and he told me that, and he also wants to tell that to the Tribunal.
THE PRESIDENT: The witness can very properly state what scientific works he read and give them and put in any reference to the scientific works that you desire and the Tribunal can read them and examine them and it seems that the witness could then state from his studies he made and his examination of these books, and we could then have them in the document books, that he reached certain conclusions.
We will have a recess in a few moments and you can consider the matter further but the witness is not enlightening the Tribunal by the discussions he is giving at this time, as I said by poison arrows and certain causes of this drug, and it seems to me that the matter might be shortened with benefit to all concerned, including the defendant.
BY DR. HOFFMAN:
Q. Witness, I should like to ask you the following question: At the time did you consider how much caladium would be needed in order to sterilize a number of human beings, perhaps even the figure of 3 million which you mentioned in this letter, always with the prerequisite that it would have been possible at all.
A. Dr. Hoffman, there were a large number of reasons which convinced me that the conclusions of the authoris could not be correct. My letter is based on that fact. Now a large number of very important and essential points should be mentioned and I would like to add briefly that after all I have been waiting in order to speak here now at this moment ten months in prison. I sent my letter on the basis of medical consideration. Therefore, the medical defense is my part of the justification. Now in order to answer your question. From the time of the treatment to which the animals were subjected, in one case 40 to 90 days, in another case 77 to 218 days. That corresponds to one-third to one-half of the length of the life of a rat, I only mention this to show how enormously long the times were during which the animals were under treatment and that this cannot be applied to a human being at all because otherwise they would have to be treated twenty to thirty years.
During this time two dosages results. Each animal received a 0.5 cc of fresh sap daily, the rats weigh 150 to 200 grams each, that is they were young, because a grown animal weigh 300 grams, and if one calculates this dosage and applies it to human beings, whose average weight of 70 kilograms, the theoretical sterilization dosage which results for a human being is 13.79 kilograms. In the second dosage under the same conditions a necessary amount of 31 kilograms results. Since fresh sap can neither be injected nor otherwise be used for human beings, it can neither be sterilized nor preserved --- it has to be prepared pharmaceutically because it involves the danger of tentaus. Therefore, the use of raw material would even double the amount, thus according to the dosage one it would be 27.5 kilograms, and according to the second 62 kilograms. Since I wrote in the letter it is very easy to raise them in hot houses, to supplement the calculations I would like to go into that statement, leaving out the consideration of the difficulty of raising tropical plants.
MR. HARDY: May it please Your Honors, I understood the defendant stated he would write a paper in the form of an affidavit and submit it to the Tribunal containing these technical matters. It seems to me that the issue merely is whether or not he has read these particular articles published by Koch and Madaus, whether or not the defendant could determine whether that drug caladium seguinim would in effect sterilize a person if applied to them. It seems to me that his defense is that he realized it would not sterilize a person, hence he recommends it's use in an effort to hoodwink Himmler. It that is it, well it seems there is no necessity to go into technical explanations, As a matter of fact to aid the Tribunal, the Prosecution will undertake to take these these publications and also have an expert write a treatise for the Tribunal in simple layman's language to aid them and the defendant may do likewise and avoid all of this unnecessary testimony in open Court.
THE PRESIDENT: As I have stated several times it appears to the Tribunal that the matter could be more properly presented to the Tribunal in the written form by way of a document and it could be studied at leisure and understood much better than it could be by listening to the witness' scientific dissertation from the witness stand. My suggestions were not intended in any way to injure the defendant's case but I think would help it since listening to the statements from the witness stand is rather confusing.
The Tribunal will take it's recess and counsel may consider this matter and discuss it and see if it cannot be arranged to let the defendant Porkorny dictate his scientific thesis as he pleases rather than, testify here to his conclusions and what he did and why he did it, and then the whole matter will be before the Tribunal exactly as well as indeed in better form than it would be if detailed by him from the witness stand and written into the record in this manner. The Tribunal will now be in recess.
(A short recess was taken)
THE MARSHAL: The Tribunal is again in session.
May it please your Honors, the defendant Mrugowsky is absent this afternoon having been excused by the Tribunal.
THE PRESIDENT: The Secretary will note for the record the absence of the defendant Mrugowsky pursuant to excuse by the Tribunal so that he may consult with his counsel.
Counsel for defense may proceed.
BY DR. HOFFMAN:
Q Witness, please comment briefly on the question what you thought about the number of hot houses which would have been needed to cultivate caladium in Germany.
A Basically I can say that tropical plants grown in hot houses lose their poisonous effect or rather their capacity to produce poison. That is connected with the lack of the natural environment. As for caladium specifically that is a plant of the tropical forest and is subject to very definite conditions of growth which are very difficult. The number of hot houses needed can be seen from the amount of sap which I calculated would be necessary. The plant grows about 1 meter high in a year. Then it needs an area of 1 square meter and weights of about 1½ to 2 kilograms would give 1 kilogram of sap. Therefore, for 10 human beings 273 square meters would have been needed. For 1,000 27,400 square meters. That would be 132 hot houses. Since the letter gives the high figures for 100,000 human beings 13,200 hot houses would have been needed. Since my letter gives the figure of 3 million, a suggestion which could be made only by one insane person to another, I must give the calculations for this figure, too. If it were possible if one wanted to sterilize 3 x 100,000 persons a year, it would have taken 10 years to reach the goal and 6 x 100,000 - it could have been done in 5 years. According to dosage one 79,000 hot houses would have been needed. According to dosage two 151,800 hot houses tropically heated for 5 to ten years. Then comes the path from laboratory and hot house to production which during war time, especially in Germany, would have been very difficult.
Then I knew that I could afford to speak in whatever way was necessary at the time.
DR. HOFFMAN: Mr. President, at the beginning of my examination of the defendant Dr. Pokorny, I had the witness describe under what circumstances he grew up and what the circle of his acquaintances was. I also questioned him about the motive for his letter, and finally, I wanted to bring out the points of view on the basis of which he believed at the time that sterilization with caladium was not possible, working on the paper of Madaus and Company. I am convinced that the presentation of this third part of the examination of Dr. Pokorny can be made expediently in the form of an affidavit and I shall submit this affidavit later and I assume that the prosecution will give their approval.
THE PRESIDENT: Counsel may present any affidavit by the defendant Pokorny, for consideration by the Tribunal and the prosecution, when it is prepared.
BY DR. HOFFMAN:
Q Witness, I have only one more question to put to you. Do you believe, from your point of view, that the attempt to use caladium for sterilization was impossible and that, on the other hand, your motive was successful?
AAccording to the documents which have been submitted so far - for example, the report of Mr. Brack on the 28th of January, 1941, or the testimony of Dr. Romberg that, in Holland, a thousand Jews were castrated and a thousand were given medical certificates about this, the beginning of the Clauberg experiments at about the same time - one can see that, at this time, this problem interested authoritative circles very intensively and that such experiments and castrations were in fact carried out. Now, in October, 1941, my suggestions appear which, as can be seen from casual connections, aroused a certain interest and the authorities concerned took an interest in my plan. The X-ray experiments of January, 1941, were dropped. Now, in October, 1943, the witness Chajin Balitzky stated, from testimony of Dr. levy, that 100 Poles wore subjected to such experiments. In October, 1943, the project was taken up again where it was dropped in the Spring of 1941.