THE PRESIDENT: Mr. Denny, the court has also permitted to allow the production of witness Von Neurath.
MR. DENNY: If your Honor Please, we now come to the proof of the defendant's responsibility for the medical experiments performed upon human beings against their will and in disregard of their well-being and their lives. We concern ourselves with high altitude experiments conducted in low pressure chambers and with freezing experiments which were carried out by exposing experimental subjects to cold water and to extreme degrees of dry cold, following which various methods of reviving the victims were tried. The high altitude experiments began about the middle of March and lasted into June in the year 1942. The cold water experiments were initiated about the middle of August 1942 and were completed during October. The dry cold experiments were conducted during, the period from February through April 1943. During this time Milch was Inspector General of the Air Force, State Secretary in the Air Ministry and General Luftzeugmeister. In the former position he was in command of the office which authorized research and medical experiments conducted in behalf of the Air Force. General Hippke who was the physician in change of the Luftwaffe medical Department was directly subordinate to the defendant. As General-luftzeugmeister, head of Air Ordnance, Milch had charge of the development of technical experiments for the Luftwaffe. It may well within the provinces of the defendant in the capacities stated above to encourage scientific experiments conducted for the purpose of developing better equipment for the protection of German fliers against low pressure hazards at high altitude and for the purpose of determining the best method of reviving fliers brought down over cold water. It was a characteristic vice of the Nazi movement that not even scientific projects could be carried out lawfully, so it was with these experiments. The essence of the crime charged in paragraphs 8 and 9 of Count II and paragraph 11 of Count III of the indictment is that human beings, without their consent, were subjected to experiments which put them in danger of injury and death. Positive proof will be offered that many victims were forced to undergo these experiments - for others of whom no detailed information is available - the prosecution will rest on the proposition that the conditions of concentration camp privation and persecution out of which experimental subjects were drawn, precluded the possibility of free consent as it is known to the law.
This defendant was in a position of responsibility. Evidence will be offered to prove that Milch was in control of experimental equipment, that he had, authority over at least one notorious experimenter and that he exercised his jurisdiction over both. We will show that the defendant was put on notice that the experiments were being conducted in a criminal manner, and that this information came to him under conditions which made it absolutely incumbent upon him to fully inform himself concerning the method of conducting the experiments. The Court will see that the defendant was treated by all concerned as a fully informed and officially responsible person. Our evidence will show that this defendant was either an informed criminal or an authorizing principal who closed his ears to unpleasant details and thus he was equally culpable. This then will be the pattern of our proof - that experiments were conducted for the benefit of the Luftwaffe - which were brutal, criminal and fatal - with which the defendant was officially connected - and which received his knowing authorization. At the outset of this part of our case we would ask the Court's attention to two points: first, Milch could have avoided culpability by expedients as simple as refusing to authorize the use of experimental equipment, or by ordering the withdrawal of this equipment - he could have put himself on record as opposing the experiments by refusing to allow Doctor Rascher and others to participate in them. We did none of these single honorable acts. Instead we find him extending the period during which the equipment might be used and we find him expressing an approving interest in the work of the infamous Rascher. Second, we would remind the Court that this is the same man who hardened his heart against the plight of thousands of foreign workers who were oppressed slaves of the Nazi war effort. Nothing could be more in character than that this zealot of total conquest should be callous as well to the right to life of the anonymous hundreds who became victims of Nazi Pseudo-science.
The documents in this case will be presented to your Honors by Mr. McMahon.
MR. McMAHON: May it please this Honorable Court, the first document which the prosecution will introduce is Number 418 which will be Prosecution's Exhibit Number 77. This is a chart showing the organization of the Luftwaffe Medical Corps. It was confirmed and signed by Dr. Oskar Schroeder, representative Chief of Dr. Hippke in the Medical Inspection in 1940. Later in 1944 Dr. Schroeder succeeded Hippke as head of the Medical Inspection. Throughout the chart which represents a portion of the original there has been changed only in a few respects, so that this larger version could be presented for illustrative purposes. We do not contend that it includes every office or person in the Medical Corps, but it does give a general idea of the organizational picture. Defendant Milch appears at the top of the chart. His position as Inspector General of the Luftwaffe is not indicated, yet the fact is that he did occupy this office throughout 1942, as well as being Secretary of State in the Air Ministry, General Field Marshal and General Luftzeugmeister. The later position he was named to in 1941. A chain of command in organization and technical matters runs from Milch to Hippke, Chief of the Medical Inspection, and on the right hand side the line runs through various offices to the DVL, the Berlin Research Institute to which Doctors Ruff and Romberg were attached. All the medical institutes and luftwaffe Medical men were subordinate to the Medical Inspection Chief Dr. Hippke. The black line, representing technical matters only, which runs from Hippke's office to the DVL illustrates this. The DVL was subordinate to Hippke's office in technical matters, at the same time being subject to Milch through the brown line in organizational and technical matters. Dr. Weltz's Institute in Munich is in the lower left-hand corner - the brown line which stops at the edge of the chart continues on, finally running to Hippke, thence to Milch. Dr. Rascher's position is indicated by the brown arrows. Here at Dachau the experiments took place. He was temporarily assigned to work with the SS, but still retained his status as a Luftwaffe physician and rose from Second Lt. to Captain in the Luftwaffe. At all times during the low pressure and the freezing experiments, Dr. Rascher was under the command of the Luftwaffe.
The next document to be introduced in evidence will be 1602-PS and is to be found on page two of the English Document and Page 2 of the German. This will be Prosecution's Exhibit No. 78. This document is a letter from. Dr. Rascher to the Reichsfuehrer Himmler and is his original request for professional criminals and feeble-minded people to be used in high altitude research. It is dated 15 May 1941.
"Dear Reichsfuehrer:
-- Going down to the second paragraph -- for the time being, I have been assigned to the Luftgaukommando VII, Munich, for a medical course. During this course, where researches on high-altitude flights play a prominent part (determined by the somewhat higher ceiling of the English fighter planes), considerable regret was expressed at the fact that no tests with human material had yet been possible for us, as such experiments are very dangerous and nobody volunteers for them. I put, therefore, the serious question: can you make available two or three professional criminals for these experiments? The experiments are made at Permanent Luftwaffe Testing Station for Altitude Research (Bodenstaendige Pruefstelle fuer Hoehenforschung der Luftwaffe) in Munich. The experiments, from which the subjects can, of course, die, would take place with my cooperation. They arc essential for researches on high-altitude flight and cannot be carried out, as has been tried, with monkeys, who offer entirely different testconditions. I have had a very confidential talk with a representative of the air forces Surgeon who makes these experiments. He is also of the opinion that the question could only be solved by experiments on human persons. (Feeble-minded could also be used as test material). I hope sincerely highly esteemed Reichsfuehrer that, in spite of the immense burden of work you carry, you are in the best of health. With my heartiest wishes, I am with Heil Hitler your gratefully devoted. Signed S. Rascher."
The next document the prosecution will offer in evidence will be Prosecution Exhibit No. 79. This is a letter from Rudolf Brandt, Himmler's adjutant, replying to Rascher's letter. It will be found on Page 3 of the English book and 4 of the German book. In this case it is document(Book No. 1) 1582 PS, Document Book 5A is the correct number. In this letter from Brandt, he says that prisoners will be made available for the experiments. The letter reads: "Dear Dr. Rascher: Shortly before flying to Oslo the Reichsfuehrer SS gave me your letter of 15 May 1941, for partial reply. I can inform you that prisoners will of course be gladly made available for the height-flight researches.
I have informed the Chief of the Security Police of this agreement of the Reichsfuehrer SS. and requested that the competent official be instructed to get in touch with you. I want to use the opportunity to extend my cordial wishes to you on the birth of your son. I shall refer as soon as possible to the second part of your letter. Heil Hitler. By order (initials) R. Br.", which is the initials of Rudolf Brandt.
The next document which we will offer in evidence is 400-PS. which will be Prosecution Exhibit No. 80. This will be found on page 4 of the document book 5-A, and 5 of the German copy. This document is the report made by a major -- Major Alexander, U.S. Army Major, who investigated these experiments and drew up a report on them which has been documented. It is entitled, "The Treatment of Shock from Prolonged Exposure to Cold, Especially in Water." Now reading, "It is indeed a curious irony of fate that Himmler, who may have killed his friends the Rascher, for the purpose of keeping secret their experiments, has indeed become -- after his own death -our best source of information concerning every detail and result of these experiments, since, while ordering others to destroy papers and evidence, he, a man of such obviously obsessive qualities found himself unable to dispose of a single scrap of paper.
He preserved all in his special cave hideout, where it was discovered later by American troops. Dr. Rascher obviously was a prodigious letter writer and self-advertiser, which is helpful now, in that it provides information concerning every detail of his work and activities. His interminable preliminary reports, his many letters telling Himmler and his underlings what important work he is doing -- he sometimes sent off more than one letter a day -- have indeed become a most interesting social and historical document, which, however, concerns us only partly for the purpose of this report.
"The idea to start the experiments with human beings in Dachau was obviously Dr. Rascher's. He first proposed it in a letter to Himmler dated 15 May 1941. Dr. Rascher states that while attending a course in aviation medicine at the Luftgaukommando VII in Munich, he began to feel that the problems of human physiology at extreme height should be studied in experiments "in human material". He requested that Himmler place "professional criminals" at his disposal for this purpose, since it was expected that nobody would volunteer for such experiments in which 'the experimental subjects might, die.' He added that the 'Prufostollo for Hobenforschung der Luftwaffe', the organization headed by Dr. Weltz (mentioned above) would be ready to carry out these experiments. On 24 July 1941, Himmler authorized the experiments to be carried out by Dr. Rascher, Dr. Kottenhoff, and Dr. Weltz. A letter from Mrs. Rascher to the Reichfuehrer S.S., dated 24 February 1942, gives further details concerning the progress of the arrangement. This letter was written by Mrs. Rascher 'under my husband's orders' because by that time Dr. Rascher, who was commissioned in the S.S. as well as in the Luftwaffe, had been given to understand that he would have to do all his writing through Luftwaffe channels.
Dr. Kottenhoff had left the team because he was transferred to Roumania. Dr. Weltz was supposed to initiate all technical aspects of the experiments in Dachau, but because he sensed some difficulties in terms of possible objection from higher Luftwaffe authorities, who he heard might consider such experiment's as 'amoral', he delayed the start of the experiments until the Director of the Luftfahrtferschugsansfalt Berlin-Adlershof, Dr. Ruff, and his assistant, Dr. Romberg, joined forces and arrived in Dachau with a low pressure chamber which they supplied. Thereupon a conference was held at Dachau in which Dr. Weltz, Dr. Rascher, Dr. Romberg, and Dr. Ruff took part, and in which technicalities were arranged with Obersturmfuehrer Piorkawski and Obersturmfuehrer Schnitzler of the Dachau Concentration Camp. Dr. Weltz agreed to supply the necessary orders for Dr. Rascher. The actual experiments were begun by Dr. Romberg and Dr. Rascher at the concentration camp in Dachau in March 1942. Dr. Rascher was given an additional stipend from the Research Institute 'Ahnenerbe'. Additional instructions were given by S.S. authorities that Dr. Rascher should personally take an active part in all the experiments on human beings in Dachau, at the request of Mrs.
Rascher, who felt that the other members of the group wanted to have him removed. Mrs Rascher felt that Dr. Weltz particularly wanted to retain ail control of and responsibility for, the experiments and that he wanted to push Dr. Rascher aside; for that reason, in a personal interview with one of Himmler's adjutants, she suggested that Dr. Rascher be attached to the Luftfabrtferschungsansfelt Berlin Adlorhof, in order to make it impossible for Dr. Weltz to transfer him elsewhere. Himmler's office then asked Generaloberstabsarzt Professor Dr. Hippke for the transfer, but Dr, Hippke merely prolonged the orders detailing Rascher to Weltz's organization in Munich. The final report, however, was not published until 28 July 1942. (The full report of these organizations on 'Salvage from highest altitudes', in which the effects of cold were not studied, will be referred to in another report on miscellaneous aviation-medical matters).
"The cold experiments in human beings were authorized on 20 May 1942, in a letter stamped secret and addressed by Generalfelsmarschall Milch to S.S. Obergruppfuehrer Welff in Himmler's office. In this letter, Generalfeldmarschall Milch acknowledges receipt of a telegram of 12 May 1942. He states that the experiments on the effects of great heights have been concluded, but that other important experiments concerning air sea-rescue problems arc regarded as important and desirable. He status that the necessary orders had been given; that Oberstabsarzt Weltz had been ordered to carry them out and that Rascher had been placed at Dr. Weltz's disposal on a part-time basis. He goes on to thank the S.S. for their cooperation with the Supreme Command of the Luftwaffe. Of particular interest is a letter from Rascher to Himmler, dated 15 June 1942. In this report -- in this he reports a conversation with Generaloberstabsarzt Professor Dr. Hippke concerning the cold experiments in human beings. Dr. Hippke is said to have requested these cold-water experiments."
The next document which the Prosecution will offer in evidence is document 1971-PS, which will be Prosecution Exhibit 81. This will be found on page 8 of the English document book and on page 9 and 10 of the German. This is Rascher's first report on the progress of the high-altitude experiments, made to Himmler. This is the first report. Rascher had begun the experiments at about March 15, 1942, the date he arrived at Dachau. This report mentions the fact that deaths had occurred, as is indicated by the autopsy reports on page 3. First reading of the letter which accompanied the report: "Highly esteemed Reichsfuehrer. Enclosed is an interim report on the low pressure experiments so far conducted in the concentration camp of Dachau. May I ask you respectfully to treat the report as secret. A few days ago Reich Physician SS (Reichsarzt-SS) Professor Dr. Grawitz made a brief inspection of the experimentation plant. Since his time was very limited no experiments could be demonstrated to him. SS Obersturmbannfuehrer Sievers took a whole day off to watch some of the interesting standard experiments and may have given you a brief report. I believe, highly esteemed Reichsfuehrer, that you would be extraordinarily interested in those experiments. Is it not possible that on the occasion of a trip to southern Germany you may have some of the experiments demonstrated to you?
If the results so obtained by the experiments are confirmed by further experimentation, entirely new data will be secured for science; simultaneously entirely now aspects will be opened to aviation. I hope that, thanks to the intended efforts of SS Obersturmbannfuehrer Sievers, the Luftwaffe will make no difficulties from now on. I am very much indebted to Obersturmbannfuehrer Sievers as he has **** shown a very active interest in my work in every respect. I thank you respectfully, highly esteemed Reichsfuehrer, for the generous realization of my proposition to conduct such experiments in the concentration camp. With my best wishes for your personal wellbeing, I am, Gratefully yours, signed S. Rascher."
The next document which the prosecution will offer in evidence is NO-318, which will be Prosecution Exhibit No. 82. This will be found on page 9 of the English book and 13 of the German document book. This document is a letter of 16 April 1942 from Obergruppenfuehrer Karl Wolff, of the SS a member of Himmler's personal staff and liaison man between Himmler and the Luftwaffe in this matter of medical experiments. It is addressed to General Professor Dr. Hippke and requests the prolongation of Rascher's assignment in Dachau. This letter demonstrates that the authorization of Rascher was by the Luftwaffe and subject to the decision of the Medical Inspection. The letter reads: "To the Chief of the Medical Service, General Oberstatsarzt, Professor Dr. Hippke. The Stabsarzt Dr. Rascher was commended for special experiments, the execution of which to pother with the experimental establishment for Air Navigation was rendered possible by the Reich Fuehrer SS at Dachau, to the experimental establishment for Aviation, Branch Office Dachau from March 16th until April 16th, 1942. The results obtained until now require a continuation of the experiments, particularly as they cannot bo completely terminated in the time provided as the procuring of a few technical appliances caused difficulties which can only be removed during next week. In the interest of the guarantee of a successful conclusion of the experiments, it is therefore requested to order the continuation of the authorization provisionally for four more 379-a weeks until the termination of the experiments.
Place of command; establishment for experiments for Aviation, Branch Office Dachau. The special research carried out, or actually taking place at Schengau will be individually executed together with the experiments at Dachau by Stabsarzt Dr. Rascher as has been done so far. Signed, SS-Obergruppenfuehrer and Lieutenant General of the Waffen SS."
The prosecution's next exhibit will be No, 83, which is Document No. NO-219. It is to be found on page 10 of the English Book, and on page 16 of the German book. This document is a letter dated 27th of April 1942 to Dr. Rascher, from Rudolph Brandt. Here Brandt asks Rascher to make up an over-all report on the experiments so Himmler can personally present it to Milch. This shows that Himmler intends to acquaint Milch with the progress of the experiment, and indicates that Milch is the Luftwaffe chief in these experiments. The letter reads: "Dear Comrade Dr. Rascher: The Reichsfuehrer has soon your letter of 16.4.42. He has shown the same interest in this report as in the one you sent recently. Ho would like you to make up for him an overall report on the experiments carried out to date, which he would like to present personally to General Fieldmarshal Milch. Kind regards to your wife and yourself. Yours. (initialed) R. Br., (Rudolph Brandt)."
The Prosecution now will introduce Document No. 296, which will be Prosecution's Exhibit No. 84. This is on page 11 of the English book, and page 17 of the German. This document is a letter, dated 29 April 1942. This is a reply by Dr. Hippke to Wolff's letter regarding an extension of Rascher's command. Hippke states that he has forwarded Wolff's letter to the physician of Airgau (VII with the request for extension. The letter reads: "To the Reich Leader SS, Chief of Personal Staff. I have received your recommendation concerning Stabsarzt (Reserve) Dr. Rascher. The recommendation was forwarded by me to the Air Gau Physician VII with the request to extend the Command. Heil Hitler. Signed Hippke."
MR. McMAHON: Prosecution will now offer in evidence Document NO-220, which will be Prosecution Exhibit No. 85. This letter is missing from the English book and the copy you will now receive is a supplemental copy. We will call this page 11a. This is a letter from Sigmund Rascher to the Reichsfuehrer SS Himmler inclosing a shot report. The letter reads:
"Highly esteemed Reichsfuehrer:
Enclosed I am forwarding a short summary on the principal experiments conducted up to date. A detailed report on the practical as well as the theoretical results will take some more time. I shall hurry. Since the material has to be processed the exploitation of the pathological preparations will take about ½ year though the Kaiser Wilhelm Institute for Brain Research will help us, I hope.
"Tonight I succeeded in seeing Dr. Fehrenkamp who has relatively recovered. He appeared to be very interested and I think there will be a fine and fruitful co-operation. Dr. Fehrenkamp who has an enormous knowledge most amiably promised to help me in everything. His opinion on my heart experiments he will give to you himself. From our conversation I have had the impression that a great field of work will open up to me yet. I thank you, highly esteemed Reichsfuehrer, for having opened these opportunities to me to such an extent.
"Unfortunately the extension of my assignment has not been settled yet; in accordance with the present regulations my assignment will be terminated on May 15.
Thanking you again I am with most obedient greetings and Heil Hitler Yours gratefully, signed S. Rascher.
I will now read the report which accompanies this letter, which report is dated 11 Hay 1942 and is on page 12 of the English book and, I believe, page 19 of the German copy.
"Secret Report.
"Based on results of experiments which up to now various scientists had conducted on animals only, the experiments in Dachau were to prove whether these results would maintain their validity on human beings.
"1. The first experiments were to show whether the human being can gradually adapt himself to higher altitudes. Some ten tests showed that a slower ascent without oxygen taking from six to eight hours, kept the functions of the senses of the various VP's, Versuchspersonen, human experimental subjects, fully normal up to a height of 8,000 meters. Within eight hours several VP's had reached a height of 9.5 kilometers without oxygen when bends occurred suddenly.
"2. Normally it is impossible to stay without oxygen at altitudes higher than six kilometers. Experiments showed, however, that after ascent to 8,000 meters without oxygen, bends combined with unconsciousness lasted only about 25 minutes. After this period the VP's had mostly become accustomed to that altitude; consciousness returned, they could make kneebends, showed a normal electrocardiograph and were able to work (60 to 70% of these cases examined).
"3. Descending tests on parachutes, suspended, without oxygen.
"These experiments proved that from 14 kilometers on down severest bends occurred which remained until the ground was reached. The deterimental effects caused by these experiments manifested themselves at the beginning as unconsciousness and subsequently as spastic and limp, paralysis, catotomy, stereotypy, and as retrograde amnesia lasting several hours. About one hour after the end of the experiment the VP's for the most part were still disoriented as to time and locality. The blood picture often showed a shift to the left; albumen and red and white blood corpuscles were regularly found in the urine after the experiment; cylinders were sometimes found. After several hours or days the blood and urine returned to normal. The changes of the electrocardiograph were reversible.
"Contrary to descending tests on parachutes without oxygen, descending tests with oxygen were carried out from heights up to 18 kilometers. It was proven that on the average the VP's regained the normal function of their senses at 12 to 13 kilometers. No disturbances of general conditions occurred during any of these experiments.
Brief unconsciousness at the beginning of the experiment caused no lasting disturbance. Urine and blood showed only a slight change.
"4. As the long time of descent on parachutes under actual conditions would cause severe freezing even if no detrimental effects were caused by lack of oxygen, VP's were brought by sudden decreases in pressure with a cutting torch from 8 to 20 kilometers, simulating the damage to the pressure machine of the high-altitude airplane. After a waiting period of ten seconds, corresponding to stepping out of the machine, the VP's were made to fall from this height with oxygen to a height where breathing is possible. The VP's between 10 and 12 kilometers and at about 8 kilometers pulled the parachute lever.
"5. In experiments of falling from the same height without oxygen the VP's regained normal function of their senses only between two and five kilometers.
"6. Experiments testing the effect of Pervitin on the organism during parachute jumps, proved that the severe after-effects, as mentioned under No. 3, were considerably milder. The Hoehenfestigkeit, ability to withstand the conditions at high altitudes, was only slightly improved, while the bends since they were not noticed occurred suddenly.
"7. Dr. Kliches, Karls-University in Prague, reports in the publication of the Reich Research Council: "By prolonged breathing of oxygen, human beings should theoretically be kept fully fit up to 13 kilometers, practically the limit is around 11 kilometers."
"Experiments which I carried out in this connection proved that with pure oxygen no lowering of the measurable raw energy (ergometer) was noticeable up to 13.3 kilometers. The VP's merely became unwilling since pains of the body cavities grew too severe, dur to the lowering of pressure between body and thin air. when pure oxygen was inhaled bends occurred in all 25 cases only at heights about 14.2 kilometers.
"As practical result of the more than 200 experiments conducted at Dachau the following can be assumed:
"Flying in altitudes higher than 12 kilometers without pressurecabin or pressure-suit is impossible even while breathing pure oxygen. If the airplane pressure machine is damaged at altitudes of 13 kilometers and higher the crew will not be able to bail out of the damaged plane themselves since at that height the bends appear rather suddenly. It must be requested that the crew should be removed automatically from the plane, for instance, by catapulting the seats by means of compressed air. Descending with opened parachute without oxygen would cause severe injuries due to the lack of oxygen besides causing severe freezing; consciousness would not be regained until the ground was reached. Therefore, the following is to be requested. 1. A parachute with barometrically controlled opened. 2. A portable oxygen apparatus for the jump.
"For the following experiments Jewish professional criminals who had committed "Rassenschande" (race pollution) were used; the question of the formation of embolism was investigated in ten cases. Some of the VP's died during a continued high altitude experiment; for instance, after one-half hour at a height of 12 kilometers. After the skull had been opened under water an ample amount of air embolism was found in the brain vessels, and, in part, free air in the brain ventricles.
"To find out whether the severe psychical and physical effects, as mentioned under No. 3, are due to the formation of embolism, the following was done: after relative recuperation from such a parachute descending test had taken place, however, before regaining of consciousness, some VP's were kept under water until they died. When the skull and the cavities of the breast and of the abdomen had been opened under water an enormous amount of air embolism was found in the vessels of the brain, the coronary vessels, and the vessels of the liver and the intestines, etc.
"That proves that air embolism, so far considered as absolutely fatal, is not fatal at all, but that it is reversible as shown by the return to normal conditions of all other VP's.
"It was also proved by experiments that air embolism occurs in practically all vessels even while pure oxygen is being inhaled. One VP was made to breathe pure oxygen for two and one-half hours before the experiment started. After six minutes at a height of 20 kilometers he died and at dissection also showed ample air embolism as was the case in all other experiments.
"At sudden decreases in pressure and subsequent immediate falls to heights where breathing is possible no deep reaching damages due to air embolism could be noted. The formation of air embolism always needs a certain amount of time.
(Signed) Dr. Rascher."
The next document to be presented is NO-476, which will be Exhibit No. 86. The English copy of this is illegible. Consequently, we are distributing another legible copy. I would like to include NO-610 in this Exhibit No. 86. NO-610 is an exhibit containing pictures of high altitude experiments and the results which they had on the experimental subjects.
THE PRESIDENT: We have the copies in the book.
MR. McMAHON: Yes, that was included in the book, Your Honors.
MR. PRESIDENT: What is meant is the document you just offered includes a lot of photographs?
MR. McMAHON: Yes, your Honor, plus the affidavit of Dr. Romberg which is NO-476. The pictures arc NO-610. They are accompanied to this affidavit but they are both to be submitted as Prosecution Exhibit No. 86. This affidavit of Dr. Romberg reads as follows:
"I, Hans Wolfgang Romberg, being duly sworn, depose and state:
