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 CONTENTS

Title Page

1. Blair
2. Nick
3. Blair
4. Blair
5. Blair
6. Nick
7. Blair
8. Nick
9. Blair
10. Blair
11. Blair
12. Nick
13. Blair
14. Blair
15. Blair
16. Nick
17. Blair
18. Blair
19. Nick
20. Blair
21. Blair
22. Blair
23. Nick
24. Blair
25. Nick
Epilogue
Author’s note
About Olivia
 C opyright © 2020 O livia H ayle
All rights reserved. No part of this publication may be distributed or transmitted without the prior consent of
the publisher, except in case of brief quotations embodied in articles or reviews.

All characters and events depicted in this book are entirely fictitious. Any similarity to actual events or
persons, living or dead, is purely coincidental.

The following story contains mature themes, strong language and explicit scenes, and is intended for mature

readers.

Cover by by Sarah Armitage Design

Edited by Stephanie Parent

www.oliviahayle.com
 When you are afraid, all love disappears.
When you love a person, all fears disappear.

- Osho
 1

BLAIR

I’m at a wedding out of state when I’m confronted with my worst

enemy. I spot him before he spots me: across the crowded reception
hall, wearing a suit disdainfully, like he wants to shrug it off and
transform into the brute he is inside.
Enemy might be too tame a word. Nightmare is a much better
description. For a people-pleaser like me, he’s a personal affront.
I’ve tried to make him my friend for near on a decade and I’ve failed
for just as long.
He takes a sip of his brandy and sweeps a dark gaze over the
guests. I’ll be noticed any second now. How had I not known he’d
been invited to this wedding?
“Is that Nicholas Park?” Maddie asks at my side, speaking his
name with obvious relish. I wish I could say no. I want to tell her
that his reputation isn’t deserved, that he’s not that special when
you’ve seen him drunk and disheveled.
But that would be lying.
“Yes,” I say, feeling like I’m confirming something far more than
just his name. Because even drunk and disheveled, he’s absolutely
magnificent.
“Aren’t you two friends?”
“He’s my brother’s friend.”
 Maddie’s laughter is a bit too high-pitched. “Well, that’s even
better! You have to introduce me, Blair.”
“I don’t think so.”
“Why not?” Her voice drops. “Is what they say of him true, then?
Is it better to stay away?”
“I wouldn’t know,” I say, though I do. It’s definitely better to stay
away. I’ve been trying to for the better part of a decade, but like a
bad rash, he keeps returning, and there are no over-the-counter
remedies in sight.
“I’ve heard that he once burned down a club he owned, just to
get the insurance money.” Maddie’s voice is vibrating with delight at
the idea of Nick committing fraud. “I had no idea he’d be here today.
Did you know he was invited?”
“No,” I say honestly. “I had absolutely no idea. I can’t imagine he
knows either the bride or the groom.”
I reach up to run a hand through my hair and glance casually
around the room. Nick is leisurely strolling through the throng of
people with his glass in hand. Despite his suit, he looks out of place
amongst the mingling guests in brightly colored dresses and dark
tuxes—like a fox in a hen house. Who’d left the gate unlocked?
“Introduce me, Blair,” Maddie urges again. “Come on.”
And before I can protest, her hand is on my arm and I’m pulled
forward on my heels. They dip into the grass with every step I take.
Nick sees us approach, his eyes flitting past Maddie to bore into
mine.
Dark, so dark, and not a hint of amusement in them. His lips
grow thinner, the rough cut of his jawline working once. So he
hadn’t expected to see me here, either.
“Blair,” he says. The gravel in his voice is no surprise to me, but it
still makes my stomach tight with nerves.
“Nick.”
Beside me, Maddie preens. I clear my throat. “This is Madeleine
Bishop. She’s a friend from college. We both know the bride.”
She extends her hand and Nick gives it a brief shake, face
impassive.
 “A pleasure,” she says smoothly. It’s her flirting voice—I
recognize it from our partying days.
Nick doesn’t acknowledge it. He nods to the bar behind us
instead. “The groom was on the thirty under thirty list in Forbes, but
can’t shell for an open bar?”
Maddie laughs, like he’s being unbelievably clever. I cross my
arms over my chest. “So you know the groom?”
“That’s not what I said.”
“So you’re here on the bride’s invitation?”
His eyes flit back to mine. “Wouldn’t you like to know?” he asks.
“But I think I’ll keep you guessing. Ladies, it’s been a pleasure.”
And then he strides off toward the bar without a second glance.
Beside me, Maddie turns to me with incredulous eyes. “Wow,” she
breathes. “You weren’t kidding. You two really aren’t friends.”
“That’s what I said,” I say tersely, running a hand over my hair
again. It shouldn’t be a sore subject. It’s been years, after all, since
my big brother befriended Nicholas Park. And still, his dislike of me
stings like salt in a never-closing wound.
Maddie takes the hint. “Let’s ignore him altogether,” she says.
“They’re dividing guests into teams. Come on, let’s join.”
I take another sip of my champagne and give her a bright smile.
We’re at a wedding. We’re here to celebrate love and life and
happiness. The sun is shining. It shouldn’t be difficult to put Nicholas
Park out of my mind.
“Let’s,” I say.
But as it turns out, that’s absolutely impossible to do when he
refuses to stay out of sight. I’m standing in line for the cornhole toss
when a shadow stalks in beside me. Like an electric current sliding
over my skin, I know who it is before he speaks.
“Blair Porter, Seattle’s top socialite, playing outdoor games.”
I roll my neck and pretend to ignore the jab. I fail. “It’s a time-
honored sport. Besides, as a guest of the wedding party, you’re
supposed to attend all the wedding festivities.”
“And I suppose you think I haven’t?”
I squeeze my lips tight to prevent my words from spilling out. I
manage restraint for a proud five seconds. “I hadn’t seen you at any
of the pre-ceremony events.”
“Well, I’ve never been good at following rules.”
“Why were you invited, anyway? Who do you really know here?”
He raises a dark eyebrow. “Such skepticism, Blair. Don’t you think
I have friends?” The mocking tone in his voice makes it clear that
the question is rhetorical. I answer it regardless.
“Other than my brother? No.”
He steps up beside me. Somewhere from the corner of my eye, I
see Maddie slink back in line, abandoning me to my new partner.
Damn.
Nick doesn’t answer my question. “This is a wedding to be seen
at,” he says smoothly. “Have you seen how many photographers
they’ve hired? Why do you think you were invited?”
My stomach churns at the question. Becca and I had been
friends in college… Sure, we hadn’t spoken much since, but I hadn’t
thought twice about accepting the invitation to her wedding.
“You’re saying I’m a trophy guest.” I speak the words harshly, like
they don’t offend me.
Nick raises an eyebrow. The sharp sunlight throws his rough
features into relief. “Tell me Cole wasn’t invited as well.”
Bending down to pick up a corn-bag, I weigh it in my hand,
refusing to answer his taunt.
Nick’s voice is satisfied. “He was, then. But he didn’t come.”
“He couldn’t,” I say, hating how defensive the words sound. At
the time, it didn’t seem odd that Becca had invited my billionaire big
brother. I’d thought it a kindness. How had I been so stupid?
If Nick sees my realization, he doesn’t acknowledge it. He
unbuttons the clasp of his gray suit jacket instead, a smirk on his
lips. He must be aware of the way the other guests are watching
him. Watching us.
“Is that why you were invited too? For the press and prestige?”
Nick’s chuckle isn’t amused. He understands the words as I’d
meant them—having him attend an event made it noteworthy, but
not always in a particularly good way. If my brother is seen as a
powerful businessman, Nick is the unscrupulous one.
 “We’re up,” he says instead, voice like crushed glass. “Don’t
miss.”
And of course I do. Despite my aim, there’s no scoring after his
words. The opposing teams cheers, high-fiving each other.
When I turn to Nick, his lip is curled. “I told you not to.”
“I didn’t know I needed advice.”
“It couldn’t hurt.”
I grit my teeth against the annoyance that rises up inside me. I’m
a happy person. I like to smile and converse and make people
happy. It’s what I’m good at, damn it. And somehow Nicholas Park
always makes me forget that.
No longer. I give him a blinding smile. Judging by the faint
widening of his eyes, it wasn’t what he’d been expecting.
“Here, why don’t you throw the next one.”
He accepts the corn-bag I hand him with suspicious eyes. “I see,”
he says. And that’s all he says, even as he lines himself up, focusing
on the cornhole. Tall and muscular, with wide shoulders, he’s an
imposing figure. Always has been.
He throws. It flies in an arc through the air and lands solidly in
the hole. I don’t look him in the eyes—I turn away instead, but I
don’t head to the back of the line.
Nick follows me towards the bar.
“What are you doing?”
“I’m participating in the wedding activities. I was recently told
that I wasn’t being a good guest.”
“Why are you really here?”
His gaze fastens on something in the distance. I’m left staring up
at the column of his throat, the rough-hewn features that have held
me captive for ages.
“Nick, I—”
“Shh.”
“Did you just shush me?”
He looks down at me, speculation in his gaze. His words come
quickly. “Pretend you like me for fifteen minutes.”
I blink at him. “Fifteen minutes?”
 “I know it’s a rather long time frame,” he grinds out, “but yes,
fifteen minutes.”
“No one’s that good an actress,” I mutter. He rolls his eyes at my
words.
And then Nick does the most amazing thing. He puts a hand on
my low back, like it belongs there, as if he touches me all the time—
as if this isn’t the first time we’ve touched since we shook hands
eight years ago.
He bends down. “Look up at me,” he instructs. “Laugh as if you
enjoy talking to me.”
“Why?” I hiss back.
Brief hesitation. “I’ll owe you one.”
“Whatever I want?”
Longer hesitation this time. “Within reason, yes.”
I turn on my biggest smile, then. The one that stretches wide
and reaches my eyes. It’s my killer mingling smile, the one I only
pull out when I really need to pack a punch. “Fifteen minutes,” I say,
batting my eyelashes. “Start the timer.”
Nick blinks once. Twice. Then he gives a subtle nod to a few men
standing not too far from us, drinks in hand.
“See the one with glasses?”
“Yes.”
His hand drifts higher, flattening against my back. The touch is
warm even through the fabric of my dress. “I’m going to talk to him,
and I want you by my side as I do.”
“Pretending to like you.”
“Yes.”
“Why?”
“Need to know basis, honey,” he says sweetly. The endearment
sounds mocking from him.
“All right, sugar muffin,” I respond just as tartly. “Fourteen
minutes left.”
He grits his teeth audibly at that.
The men look up as we approach, their conversation abruptly
dying.
 “Mr. Park,” the man in glasses says. His tone is cold. “I didn’t
know you’d be here.”
“Last-minute invite,” Nick says, an odd tone in his voice. Is that…
gentleness? He must be trying to win points here somehow. “This is
Blair Porter.”
I extend a hand, still smiling widely. “A pleasure to meet you all.”
They introduce themselves. “I’ve met your brother a few times,”
the man in glasses—Mr. Adams—says. “Lovely guy.”
I resist the urge to glance at Nick. So that’s why I’m here, smiling
at him. He’s using me in all of my trophy invitedness. “Yes, he is,” I
say, leaning into Nick’s side. “Despite being friends with this one.”
They laugh at my joke and Nick is forced to join in. The pressure
of his hand on my back increases in a not so subtle warning to
behave. Idiot, I think. I just made you look more likeable.
“That’s right,” Nick says. “We’ve known each other for what,
eight years now, Blair?”
“Something like that,” I say.
The shorter of the three men smiles at me. “I hope you’ll stay
long enough to meet my wife. She’s around here somewhere, and
she reads every style interview you give.”
“That’s lovely,” I say warmly. “I’d love to meet her.”
Nick clears his throat and I tear my gaze away to look up at him
expectantly, forcing friendliness into my gaze.
“Enjoying the time away from Seattle?” Nick’s question is open-
ended, but his entire body language is focused on Mr. Adams.
Subtle, I think, wondering how Nick would react to my hand on his
back in warning.
“I am, yes,” Mr. Adams says. “Some time away can be good.
Clears the head.”
Nick nods gravely. “Lends itself to making excellent decisions.”
“This is not the place to discuss business,” Mr. Adams retorts. The
two men at his side both look away, clearly uncomfortable with the
turn of conversation. Nick is tense beside me.
This won’t do.
I put a hand on his arm affectionately, looking over at Mr. Adams
with a smile. “Even at a wedding,” I say, making my voice light. “Can
you believe it? It’s impossible to get this guy to relax!”
Nick sighs. “About as impossible as you walking past a store
without purchasing anything.”
“Well, we all have our vices,” I tease, my wide smile still in place.
“I’m sorry we bothered you.”
“Not at all,” Mr. Adams says. “It was a pleasure to meet you, Miss
Porter.”
“Likewise.”
The three men stroll on, leaving Nick and I to revel in our
peaceful, friendly bliss. I hit his arm.
“What the hell was that for?”
“You call me a trophy guest, someone invited here for
appearance’s sake, and then you use me in just the same way?”
There’s no remorse or denial in Nick’s eyes. Just sly calculation.
“You did well.”
“I was coerced.”
“No, you weren’t. Now I owe you one.” He speaks the words with
obvious distaste.
I put my hands on my hips. “So you’re what? Trying to take over
his company? Buy out his board? Tank his stocks?”
Nick narrows his eyes at me. “You don’t need to know,” he says,
articulating every word.
I flick my hair over my shoulder and feel a faint sense of triumph
as his eyes track the movement. “Well, that was the first and last
time you use my name to boost your reputation.”
“Trust me, it’s definitely the last time.” He takes a sip of his drink
and mutters something that sounds an awful lot like not worth it.
I shake my head at him and start to head back to the festivities,
to people who actually enjoy having me around.
“Running back to your sycophant friends?” he throws after me.
“Don’t you have a hostile takeover to plan?”
His crooked grin is wolfish. “Good idea,” he says. “I heard a few
of the bridesmaids are single…”
“Oh, screw you.”
“Are you offering? I don’t think your fifteen minutes are entirely
up yet.”
 “You wish,” I hiss, retreating across the lawn before he has a
chance to answer. How much easier my life would be if my brother
hadn’t decided to become best friends with the least friendly man on
the planet. Infuriating, maddening, and absolutely impossible to
ignore.

I remember the first time I’d seen him. It had been nearly a decade
ago, when he’d stalked into the restaurant together with my brother
for dinner. I’d had no advance warning that my brother’s friend
would be joining us. That was Cole’s way, sometimes, especially in
those days—he did what pleased him, like a bulldozer or a rocket.
You could either stand in his way and get crushed, or adapt to his
speed. Over the years, I’ve gotten very good at adapting.
Nick had worn their college jersey, ironically, like it was beneath
him. I’d never seen a man who moved like he did—he walked like a
street fighter.
He’d joined our table with a perfunctory nod to me.
“This is Nicholas Park,” my brother had said, flipping open the
menu. “We’re seniors together.”
“A pleasure to meet you,” I said, extending a hand. He’d looked
at it once before he shook it. I remember that clearly—his brief
hesitation.
That’s when I’d felt the scars on the inside of his palm. Faint, but
raised, and unmistakable. The surprise in my gaze must have been
easy for him to read. He’d withdrawn his hand and opened his
menu.
And that had been that. I’d been too intimidated—too impressed,
to be honest—to speak much during that dinner. The next time Cole
and I were alone, I’d peppered him with questions about Nick. I’d
done it with an air of impetuousness, and he’d rolled his eyes at his
annoying little sister and all her questions. He’d never realized that
my inquiries came from a place of burning curiosity and genuine
interest.
 Because handsome was far too tame a word for Nicholas Park.
There was a slight crook to his nose that gave his face character; his
black hair was cut too short to be fashionable. And yet, the olive
tone to his skin, the dark of his eyes, the wildness in his jaw…
I’d been struck.
And then he’d struck me.
Oh, not like that, of course. But his verbal spear had found its
mark just the same. That damn party and that damn poker game.
Even recalling it eight years later, it makes my cheeks burn with
indignity. Anger. The way he’d turned me down with a tone of voice
that was so cold it burned.
He’d been playing poker. The room was smoke-filled, the air
heady, the tension around the table high. I’d walked straight in. It
had been foolish—I can admit that much in retrospect. I barely knew
anyone at the table; Walker was the older brother of one of my
childhood friends, and our fathers worked together. But the rest
were strangers.
Apart from Nick.
He’d seen me when I’d walked in. His eyes had met mine for a
few seconds and then he’d refocused on his cards like I was nothing
at all. There hadn’t even been a hint of recognition in his eyes.
That should have been a sign, really. But I’d had two and a half
glasses of wine and I was heady with nerves and excitement. Nick
was here at this party, without my brother in tow. We’d already been
introduced. I was his best friend’s little sister.
It was time he saw me as something other than that.
So I planned on joining the game with a couple of hundred bucks
to my name. It was a lot, and I was reluctant to risk it, but my
reluctance was worn thin by the memory of Nick’s sharp-edged jaw.
I was brave-verging-on-stupid.
I stopped next to Nick, almost leaning on his chair. He didn’t
acknowledge me.
“Good game?” I asked.
“Can’t tell until it’s over,” he’d responded. A few of the guys
around the table had smiled at that, like the answer was obvious,
like I’d been a fool for asking.
 That didn’t dissuade twenty-one-year-old me. “Deal me in? I
have the cash.”
At that, Nick had actually put down his cards. The other guys
were looking at me then. Some with interest in their eyes—one of
them ran his gaze up my form in a way that was nothing short of
lewd.
Nick met my gaze. The eyes gave me no quarter, offered no
mercy. They were dark like coal and just as fiery.
“This isn’t a game for little girls,” he said. “Run back to your
friends now.”
Maybe it would have been okay if he’d said it as a joke. If there
had been a teasing note to his voice, a bit of irony. Perhaps even
anger—I’d know what to do with that. But the cold civility in his tone
shocked me to my core. It was a dismissal. I wasn’t used to being
dismissed.
That was the first time I’d reached out to Nick in the hopes of
being friends, and it was the first time he rejected me out of hand.
But it wouldn’t be the last.
 2

NICK

“Thank you, gentlemen,” I say, shaking their hands in turn, my grip

firm. Three generations of Adams’s look back at me with varying
levels of hostility. I don’t add any more words. I don’t tell them that
this was an affair well-done or that they’ll be pleased. I’m fairly
certain they won’t be by the time my ownership of the company is
finished.
Old Mr. Adams gives me a nod. “You take care of our business
now, young man.”
I want to grit my teeth at the epitaph, but nod. If by taking care
you mean tearing it apart and selling the pieces to the highest
bidder, then yes. Sure.
They filter out of my office, having just agreed to sell their family
business and life’s work. Gina is waiting by the door with a practiced
smile. She’ll escort them out and go over the final paperwork, far
away from the man who essentially gave them no choice in the
matter.
Me.
Leaning back in the chair, I put my hands at my temples. Victory.
This is victory, and it still doesn’t taste sweet enough.
It had become a drug, this. Playing the long game. Taking over
companies. Buying them for a pittance.
Selling them for parts.
 I flip my pen over in my grip and pull up the company’s website
again. B.C. Adams. An old, respectable clothing chain, as all-
American as apple pie and stuffed turkey and checkered picnic
tablecloths. Just sold to me by one Pierce Adams, Pierce Adams Jr.,
and Bryce Adams.
This deal had been months in the making. My company had
circled them since last year’s quarter reports left investors reeling.
The company was floundering. At its current state, it’s only a matter
of months before bankruptcy is a given.
One after one, other potential buyers were scared off by the
abysmal financial results. One I had taken care of myself by
spreading a false rumor about an upcoming merger and acquisition.
They’d dropped out of the race right before I’d swooped in with my
final offer.
The board had been all for accepting. Like rats deserting a
sinking ship, they saw me for the piece of flotsam I was.
The three Adams’s? Not so much.
That’s why I’d gone to that godforsaken wedding in Oregon in
the first place. Pierce Adams Jr. would be there, attending as a friend
of the groom, so I needed to be there too. Show that I was a man
to be trusted. That I could kiss babies and hug women. Could you
grab a beer with him?
I wasn’t running for president, but it felt damn near close when I
needed to have all three of the Adams’s votes. Using Blair Porter’s
heavenly smile to help with that had been a stroke of brilliance.
Just the memory of her conjures up familiar feelings of
frustration and anger. Blonde hair the color of wheat, curling around
a heart-shaped face. Honey-brown eyes that I most often saw
narrowed in annoyance.
She’d been angry to see me, a spitting kitten with her hackles
raised. That was true to form. For as long as I’d known her, she’d
been angry with me for one reason or another. Good.
Anger I could handle—anger I liked.
And the scolding she’d given me at the end… I can’t believe you
used me for your business deal!
 It almost brought a smile to my face, just remembering it.
Basking in her anger felt a bit like basking in the sunlight. Both
equally fiery and all-consuming.
And then she’d been gone in a flurry of silky fabric and flowing
hair, back to her harem of low-tier socialites and fans.
I shake my head at my own thoughts. Blair Porter has already
occupied too much of my time today. It’s time to focus on the far
easier task at hand—and that’s turning a failing clothing giant
around enough so that I can butcher it profitably.

When I arrive at one of Cole’s properties in the evening, he’s already

waiting for me by the tennis courts. In his white shorts and T-shirt,
he looks pristine, every inch the golden-boy billionaire he is. He
hates it when I call him a blue blood, but that’s exactly what he
looks like. The Porters were rich long before he began building his
empire.
“Hey,” he says, lobbying a tennis ball hard at my chest. I catch it
before it makes contact. “I heard you ran into Blair at the wedding
last weekend.”
Had she tattled to her brother? A pang of disappointment hits
me. She usually kept our banter private.
“I did.”
I take my place at the baseline and Cole is forced to raise his
voice. “And you both made it out alive?”
“Evidently.” I call back, tossing the ball high and serving, ignoring
the fact that he’s not in the right spot. He handles it deftly and for
the coming minutes there’s nothing but the sound of tennis balls
against racquets and the thrill of the game. I lose myself in the fight,
as I so often did when I was young, surrendering to the pumping of
blood and adrenaline.
Cole might come from different stock—he has a background of
athletic competitions and trophies—but the thrill of the hunt is the
same.
 We’re well-matched, have been after playing so many times
together over the years. By the time we’re done, we’re panting,
chugging from our water bottles.
“Damn,” he says finally. “Have you been practicing with an
Olympian while I was away? Your slices are deadly.”
I grin at him. “I had a good morning.”
He braces himself against the edge of the net. Sweat glistens on
his skin; I’m sure I look much the same. “Did you close the deal,
then?”
“I just did, yeah.”
His face lights up into a smile, and for a moment it’s
uncomfortably similar to Blair’s—not that she’s ever smiled at me like
that. “Hell yes. Well done, man!”
“Took me long enough.”
“Can you finally tell me which company it is? I need to know
where to shop one last time.”
“B.C. Adams.”
His smile fades. “Shit. Really?”
“Yeah.”
“That chain is massive. And failing. People have been placing
bets on how long it’ll stay afloat.”
“Well, a little bit longer at least. I need to squeeze out a profit
from it first.”
Cole runs a hand through his hair. “Fuck,” he says again. “A
clothing chain. They must have massive stores of inventory.”
“I’m betting on that, yeah.”
“And you need to flip it fast to pay the overhead. Do you know
anything about retail?”
Uncomfortable though it is to admit, I answer him truthfully. “No.
But I’ll hire people who do.”
He bends down to tie his shoelaces. The wedding band on his
left hand shines golden in the sunlight. The man had become near
insufferable with happiness after his wedding to Skye. “Hire Blair,” he
suggests. “She knows fashion.”
I stare down at him. “What?”
 “She studied business and fashion. She had that fashion brand a
few years back, remember?”
Yes, I do, and the memory isn’t a good one. She’d launched a
collection at twenty-three that had crashed and burned not two
years later. Not exactly a ringing endorsement.
But even if that wasn’t the case—even if she was the most
qualified person on the planet—there’s no way she’d work with me.
“I remember,” I say. “But…”
“But what?” Cole meets my gaze baldly. I know he won’t accept a
bad word about Blair. I’m on thin ice, and for the first time in a long
while, I can feel the danger. Cole gives me a lot of leeway, sure, but
absolutely none when it comes to his family.
But then it hits me.
There’s no way she’d agree.
“It’s a good idea,” I say. “You’re right, she knows the industry. I
could hire her as a consultant.”
Cole’s shoulders relax. “It would be good for her. For you both,
I’m sure. Who knows, maybe you can both finally learn how to get
along?”
I nod, though my agreement is an absolute lie.
It sounds like a nightmare.
“I’ll ask her,” Cole continues. “I’m seeing her later.”
“Good.” I swing my bag up on my shoulder and make my face
impassive. She’s going to say no—what excuse she’ll use to Cole, I
don’t know. But if there’s one thing I’m sure of, it’s that Blair Porter
has never hated anyone more than she hates me.
 3

BLAIR

“Do you never lock the front door?”

“Not when you have a front gate.” My brother leans against the
kitchen island, still in his dirty gym clothes, a protein shake in hand.
“Have you abandoned showering?”
He shoots me a don’t-start look. “I just got back from playing
with Nick.”
I ignore that. “Is Skye around?”
“No, she’s out with Timmy and her sister tonight.”
“Oh.”
“Try not to look so unhappy about that, will you?” Cole rolls his
eyes. “I’m the one who’s technically flesh and blood.”
I aim a kick at his shins as I walk past. We might be older now,
but he’ll always have it coming. “I’m unfortunately aware of that,
yes.”
I hop up on one of the barstools and reach for a muffin from the
center basket. Ever since Cole married Skye, there’s always good
food in the house. It’s one of the many, many positive changes she’s
wrought on my brother.
“Skye texted me about the skiing weekend,” I say, “three weeks
from now. I’m guessing you closed on the place in Whistler?”
Cole reaches for a muffin of his own. “Yes. It was the third link I
sent you.”
 “You know,” I say good-naturedly, “a lot of billionaires will buy
their own islands in the Caribbean. You couldn’t be that kind of
billionaire, could you?”
My brother gives me an amused glare. “No. That’s for
egomaniacs and James Bond villains.”
“But an eight-room chalet nestled deep in the snowy mountains
isn’t?”
He flicks his muffin liner over to my side. “One more word and
you’re uninvited.”
“You wouldn’t dare. Skye would have your head.”
“Unfortunately very true.” He reaches for yet another muffin.
“How’s work going?”
“Good,” I say. “I’m cautiously optimistic.”
The glare he shoots me this time is tired. “You have to stop being
cautious at some point, Blair. You’re never cautious in any other area
of your life.”
There’s truth to his words but I ignore them, spinning around on
the barstool instead. Ever since my fashion brand spectacularly
crashed and burned—so spectacularly that it was still used as an
example in the media of what not to do—talking about my career
dreams hurt. Better to work in silence than let people see me fail a
second time.
“You’re probably right,” I admit.
“Probably?”
“It’s the best I can give you,” I tell him. “Remember, I’m
programmed to oppose you at every turn. That’s what a little sister
does.”
“Yes, and don’t I know it,” Cole says. “But put that on hold for
just five minutes, okay? I’ve had an idea.” There’s a warning in his
voice. “And before you bite my head off, let me just say that I
genuinely think this might be good.”
“What did you do now?”
“I didn’t do anything, but I… well, I suggested something to Nick
and he agreed.”
I look up at him. “To Nick?”
 “Yes. He’s just bought a clothing giant. It’s a pretty massive deal,
actually. He needs to hire a consultant to advise with the retail and
fashion side. You could be that consultant. You know the industry.”
I put my purse down on the kitchen island with a bang. “Work for
Nick?”
“For Nick’s company, yes.” Cole glances over at me. “Unless you
find it too distasteful. He’s probably slashing jobs right this moment
to ensure they’re profitable enough for as long as he needs them to
be.”
My fingers dance over the hem of my skirt. “You said Nick
agreed?”
“Yes, he did. It was practically his idea.”
My raised eyebrow must have been question enough, because
my big brother rolls his eyes. “All right, so it wasn’t. But I know
you’d be great at this, Blair. What do you have to lose?”
Ah.
What he really means is what do I have left to lose. After my
failed attempt at a fashion line, of course I’d jump at this chance.
“And you’re certain Nick agreed,” I say slowly. It makes no sense
to me. Why would he entertain the idea for more than a second?
The man has zero belief in my abilities.
“Yes, he did.”
That’s when it dawns on me—Nick doesn’t think I can do it. He
agreed because he bet on me being the one to turn it down.
I put on the brightest smile possible. If nothing else, accepting
will annoy the hell out of him. “Of course I’ll do it. I’ll give him a call
right away.”
Cole’s smile is wide. “Perfect. And who knows, perhaps the two
of you will finally get to know one another better?”
My smile doesn’t even falter. “Yes, who knows?”

Nick doesn’t pick up the phone himself. I speak to his assistant

instead, a no-nonsense man with an equally no-nonsense tone of
voice. He pauses briefly when I introduce myself.
“Porter?” he says in clarification. “Blair Porter?”
“Yes.”
“All right. I’ll run it by Mr. Park immediately and get back to you
within the hour.”
He calls me back within ten minutes, and this time, his voice is
nothing short of glacial. Whatever Nick’s reaction was, it certainly
hasn’t warmed his assistant toward me.
I wish I could have seen it. Did he dramatically sweep all his
things off his desk in a fit of anger? Or perhaps brood coldly, his
hands white-knuckled around the edge of his desk?
“Mr. Park is glad you accepted,” his assistant lies coolly. “You’re
welcome to come into the office tomorrow morning. We’ll send you
more detailed instructions by email within the hour.”
My head spins as I hang up the phone. The decision to agree
had been impulsive—driven by the desire to tell Nick off, to show
him up. To beat back against his belief that I’m nothing but a
socialite and a failed fashion designer.
I push back from the desk in my home office and look around at
my mood boards, at the rack of samples in the corner. Above my
desk is a framed quote. Work in silence, let success be your noise.
The next time I launch a brand, it will be quietly. It won’t have my
name on it. And it will be a success.
I run a hand over the smooth silk of a slip skirt. Solutions for
everyday women, that’s my concept. Making the clothes you already
own look good—no need to buy more. Extensions for bra straps. No-
line panties. Beautiful T-shirt bras and shapewear and sneaker socks.
Everything for the modern woman’s closet, available to order online,
in beautiful packaging. Well, it will be available, once it’s launched.
But it’ll have to wait a little while longer—long enough that I can
show both my brother and Nick that I’ve still got it.
There’s something about confronting a man you know dislikes you.
It’s reckless power and churning nerves and fire in my stomach. It’s
made worse still, somehow, when it’s a man you once harbored a
stupid crush on. That crush is long gone by now—driven away by his
consistent harshness and dismissal. Whittled away by comments
about my status as a trophy invite and inveterate shopaholic.
But I’ve never been one to back down, and when it comes to
Nicholas Park, it’s not even an option. That would mean surrender,
and surrender means defeat, because that’s the only language a
man like him understands.
So I show up bright and early the next day at his office. Located
in a mid-rise in downtown Seattle, it’s nothing like the shiny
skyscrapers my brother prefers.
A simple sign by the front door, so small you’d miss it if you
didn’t know you were looking for it.
Park Incorporated.
I’ve dressed for the part, my clothing my armor. My hair is glossy
and blonde down my back and the belt of my trench coat is double-
knotted around my waist. One fashion consultant at your service,
Nick.
I’m greeted instead by a no-bullshit woman in her mid-forties. A
faint frown mars her features.
“You’re Blair Porter,” she points out.
It’s not a question, but I nod regardless. “Yes, that’s me.”
“I’m Gina Davies, hello. Mr. Park told me to expect you. Let’s get
you set up and briefed. I’m told you have a background in fashion
and business?”
“I do, yes. A bachelor on the subject and two internships, not to
mention personal business experience.” I meet her unflinching gaze.
If she’s aware of the fiasco of my former fashion brand, I can’t tell.
“Excellent. Here’s your desk. I expect you’ll be visiting different
stores or working while traveling, but while you’re here, this is
yours.” She pushes a thick file over to me and a laptop bag. “Here is
all the information you’ll need on B.C. Adams. Mr. Park will brief you
himself this afternoon, but for now, get acquainted with the firm.”
 “I’m already fairly well acquainted,” I say, sinking down in the
seat. “I used to be a regular customer.”
It’s meant as a lighthearted comment, but Gina seems to take it
seriously. “Then maybe you can see why they’ve been failing to
attract customers for the last decade. We need to turn that around if
we’re to get rid of the inventory and assess their production value.”
I give a nod and open the binder carefully. “And Nick will see me
this afternoon?”
“Mr. Park will, yes.” She pushes away from the desk. “I’ll let you
get settled in. Tomorrow we visit the closest store.”
And that’s all the introduction I get.
But as I dive deeper into the documents I’ve been given, it’s not
hard to see the structural flaws of the business. Their retail model is
dated; no online store, no shipping. The clothes they’re selling are of
good quality, and they’re preppy, but they’re plain. There’s no clear
branding. There’s no logo.
No wonder they’re struggling.
I’m so deep into research that I barely hear the knock on the
door. It’s Miles, Nick’s assistant—I recognize the glacial voice
immediately.
“Mr. Park will see you now.”
I push away from the desk and deliberate for a moment over
whether to bring the binder. Miles sees me considering and gives a
faint sigh.
“Bring it,” he says, turning on his heel and striding down the
corridor without checking if I’m following.
Okay then. Nick’s company probably doesn’t score highly on the
“employee satisfaction” index, but then again, I hadn’t expected it to
with him as the founder.
His office is on the other side of the complex. For a moment, I
amuse myself by imagining him instructing Gina in the placement of
my desk. I don’t care where she is, but make sure she is as many
feet away from me as possible. Yes, I want you to measure it.
Miles stops outside a closed door and presses down on the
button of an intercom. “Miss Porter is here for you.”
“Send her in.”
 I grin at Miles, hoping to draw out some form of response from
him. All the employees here can’t be ice-men. “Thanks for escorting
me here,” I say brightly.
He gives me a narrowed glance, as if he can’t quite figure out my
game, and pushes the door open. Oh well. I’m sure I’ll wear him
down eventually.
Nick is standing by a window, his back to me. The only one I’ve
never managed to wear down with my charm. The door closes
behind me. Locked in with the beast.
“Lovely office you have here,” I say. “The mood seems to be
somewhere between a slaughterhouse and a prison. I can’t decide
which I’m leaning toward more.”
Nick doesn’t turn. Dressed in black suit pants and a dark shirt,
sans jacket, he looks… impressive. I know he’s trying to rattle me by
not speaking—by not looking at me.
I hate that it’s working.
“Cole told me it was your idea to hire me. I’m guessing that was
somewhat of a white lie, but I’ll go along with it if it’ll make your life
easier.”
Nick shrugs, his wide shoulders rising and falling once. “Believe
what you like,” he says, “as long as you’ll do the job I’ve hired you
for.”
At that, my hackles rise. Have I ever suggested otherwise?
“So far, all I know is that it involves evaluating B.C. Adams as a
business.” I take a seat opposite his desk, ignoring the fact that he’s
also ignoring me. “I’ve been given a file about their financial
information. That’s all I know. Care to fill me in?”
Nick turns to look at me. There’s still nothing in those dark eyes
of his—he’s capable of looking so cold, so still, like someone carved
him from marble with too rough a hand. I sit still under the hawk-
like gaze.
“And?” he says. “Do you think you can do it?”
“Yes.” I pour more confidence into the word than I feel. “But I
want you to tell me the truth about last weekend.”
Impossibly, he grows even more still. “Last weekend?”
Exploring the Variety of Random
Documents with Different Content
 The sweep of the law of conspiracy is an important consideration
in determining the criteria of guilt for organizations. Certainly the
vicarious liability imposed in consequence of voluntary membership,
formalized by oath, dedicated to a common organizational purpose
and submission to a discipline and chain of command, can not be
less than that which follows from informal cooperation with a
nebulous group to a common end as is sufficient in conspiracy. This
meets the suggestion that the prosecution is required to prove every
member, or every part, fraction, or division of the membership to be
guilty of criminal acts. The suggestion ignores the conspiratorial
nature of the charge. Such an interpretation also would reduce the
Charter to an unworkable absurdity. To concentrate in one
International Tribunal inquiries requiring such detailed evidence as to
each member would set a task not possible of completion within the
lives of living men.
It is easy to toss about such a plausible but superficial cliché as,
“One should be convicted for his activities, not for his membership.”
But this ignores the fact that membership in Nazi bodies was itself
an activity. It was not something passed out to a passive citizen like
a handbill. Even a nominal membership may aid and abet a
movement greatly. Does anyone believe that Hjalmar Schacht sitting
in the front row of the Nazi Party Congress of 1935, wearing the
insignia of the Party, was included in the Nazi propaganda films
merely for artistic effect? This great banker’s mere loan of his name
to this shady enterprise gave it a lift and a respectability in the eyes
of every hesitating German. There may be instances in which
membership did not aid and abet the organizational ends and
means, but individual situations of that kind are for appraisal in the
later hearings and not by this Tribunal. By and large, the use of
organization affiliation is a quick and simple, but at the same time
fairly accurate outline of the contours of a conspiracy to do what the
organization actually did. It is the only one workable at this stage of
the trial. It can work no injustice because before any individual can
be punished, he can submit the facts of his own case to further and
more detailed judicial scrutiny.
 While the Charter does not so provide, we think that on ordinary
legal principles the burden of proof to justify a declaration of
criminality is upon the prosecution. It is discharged, we think, when
we establish the following:
1. The organization or group in question must be some
aggregation of persons associated in some identifiable relationship
with a collective general purpose.
2. While the Charter does not so declare, we think it implied that
membership in such an organization must be generally voluntary.
That does not require proof that every member was a volunteer. Nor
does it mean that an organization is not to be considered voluntary if
the defense proves that some minor fraction or small percentage of
its membership was compelled to join. The test is a common-sense
one: Was the organization on the whole one which persons were
free to join or to stay out of? Membership is not made involuntary by
the fact that it was good business or good politics to identify one’s
self with the movement. Any compulsion must be of the kind which
the law normally recognizes, and threats of political or economic
retaliation would be of no consequence.
3. The aims of the organization must be criminal in that it was
designing to perform acts denounced as crimes in Article 6 of the
Charter. No other act would authorize conviction of an individual and
therefore no other act would authorize conviction of an organization
in connection with the conviction of the individual.
4. The criminal aims or methods of the organization must have
been of such character that its membership in general may properly
be charged with knowledge of them. This again is not specifically
required by the Charter. Of course, it is not incumbent on the
prosecution to establish the individual knowledge of every member
of the organization or to rebut the possibility that some may have
joined in ignorance of its true character.
5. Some individual defendant must have been a member of the
organization and must be convicted of some act on the basis of
which the organization is declared to be criminal.
D. Definition of Issues for Trial.
The progress of this trial will be expedited by clear definition of
the issues to be tried. I have indicated what we consider to be the
proper criteria of guilt. There are also subjects which we think are
not relevant before this Tribunal, some of which are mentioned in
the specific questions asked by the Tribunal.
Only a single ultimate issue is before this Tribunal for decision.
That is whether accused organizations properly may be
characterized as criminal ones or as innocent ones. Nothing is
relevant here that does not bear on a question that would be
common to the case of every member. Any matter which would be
exculpating for some members but not for all is irrelevant here.
We think it is not relevant to this proceeding at this stage that
one or many members were conscripted if in general the
membership was voluntary. It may be conceded that conscription is
a good defense for an individual charged with membership in a
criminal organization, but an organization can have criminal
purposes and commit criminal acts even if a portion of its
membership consists of persons who were compelled to join it. The
issue of conscription is not pertinent to this proceeding but it is
pertinent to the trials of individuals for membership in organizations
declared criminal by this Tribunal.
We also think it is not relevant to this proceeding that one or
more members of the named organizations were ignorant of its
criminal purposes or methods if its purposes or methods were open
and notorious. An organization may have criminal purposes and
commit criminal acts although one or many of its members were
without personal knowledge thereof. If a person joined what he
thought was a social club but what in fact was a gang of cutthroats
and murderers, his lack of knowledge would not exonerate the gang
considered as a group, although it might possibly be a factor in
extenuation of a charge of criminality brought against him for mere
membership in the organization. Even then the test would be not
what the man knew, but what, as a person of common
understanding, he should have known.
 It is not relevant to this proceeding that one or more members of
the named organizations were themselves innocent of unlawful acts.
This proposition is basic to the entire theory of the declaration of
organizational criminality. The purpose of declaring criminality of
organizations, as in every conspiracy charge, is punishment for
aiding crimes, although the precise perpetrators may never be found
or identified. We know that the Gestapo and SS, as organizations,
were given principal responsibility for the extermination of the
Jewish people in Europe—but beyond a few isolated instances, we
can never establish which members of the Gestapo or SS actually
carried out the murders. Any member guilty of direct participation in
such crimes can be tried on the charge of having committed specific
crimes in addition to the general charge of membership in a criminal
organization. Therefore, it is wholly immaterial that one or more
members of the organizations were themselves allegedly innocent of
specific wrongdoing. The purpose of this proceeding is not to reach
instances of individual criminal conduct, even in subsequent trials
and, therefore, such considerations are irrelevant here.
Another question raised by the Tribunal is the period of time
during which the groups or organizations named in the Indictment
are claimed by the Prosecution to have been criminal. The
Prosecution believes that each organization should be declared
criminal during the period referred to in the Indictment. We do not
contend that the Tribunal is without power to condition its
declaration so as to cover a lesser period of time than that set forth
in the Indictment. The Prosecution feels, however, that there is in
the record at this time adequate evidence to support the charge of
criminality with respect to each of the named organizations during
the full period of time set forth in the Indictment.
Another question raised by the Tribunal is whether any classes of
persons included within the accused groups or organizations should
be excluded from the declaration of criminality. It is, of course,
necessary that the Tribunal relate its declaration to some identifiable
group or organization. The Tribunal, however, is not expected or
required to be bound by formalities of organization. In framing the
Charter, the use was deliberately avoided of terms or concepts which
would involve this trial in legal technicalities about “juristic persons”
or “entities.” Systems of jurisprudence are not uniform in the
refinements of these fictions. The concept of the Charter, therefore,
is a nontechnical one. “Group” or “organization” should be given no
artificial or sophistical meaning. The word “group” was used in the
Charter as a broader term, implying a looser and less formal
structure or relationship than is implied in the “organization.” The
terms mean in the context of the Charter what they mean in the
ordinary speech of people. The test to identify a group or
organization is, we submit, a natural and common-sense one.
It is important to bear in mind that while the Tribunal no doubt
has power to make its own definition of the groups it will declare
criminal, the precise composition and membership of groups and
organizations is not an issue for trial here. There is no Charter
requirement and no practical need for the Tribunal to define a group
or organization with such particularity that its precise composition or
membership is thereby determined. The creation of a mechanism for
later trial of such issues was a recognition that the declaration of this
Tribunal is not decisive of such questions and is likely to be so
general as to comprehend persons who on more detailed inquiry will
prove to be outside of it. An effort by this Tribunal to try questions of
exculpation of individuals, few or many, would unduly protract the
trial, transgress the limitation of the Charter, and quite likely do
some mischief by attempting to adjudicate precise boundaries on
evidence which is not directed to that purpose.
The prosecution stands upon the language of the Indictment and
contends that each group or organization should be declared
criminal as an entity and that no inquiry should be entered upon and
no evidence entertained as to the exculpation of any class or classes
of persons within such descriptions. Practical reasons of conserving
the Tribunal’s time combine with practical considerations for the
defendants. A single trial held in one city to deal with questions of
excluding thousands of defendants living all over Germany could not
be expected to do justice to each member unless it was expected to
endure indefinitely. Provision for later, local trial of individual
relationships protects the rights of members better than can possibly
be done in proceedings before this Tribunal.
With respect to the Gestapo, the United States consents to
exclude persons employed in purely clerical, stenographic, janitorial
or similar unofficial routine tasks. As to the Nazi Leadership Corps
we abide by the position taken at the time of submission of the
evidence, that the following should be included: the Fuehrer, the
Reichsleitung (i.e., the Reichsleiters, main departments and
officeholders), the Gauleiters and their staff officers, the Kreisleiters
and their staff officers, the Ortsgruppenleiters, the Zellenleiters, and
the Blockleiters, but not members of the staff of the last three
officials. As regards the SA, it is considered advisable that the
Declaration expressly exclude (1) wearers of the SA Sports Badge;
(2) SA controlled Home Guard Units (SA Wehrmannschaften) which
were not strictly part of the SA; (3) The Marchabteilungen of the
N.S.K.O.V. (National Socialist League for Disabled Veterans); and (4)
the SA Reserve, so as to include only the active part of the
organization, and that members who were never in any part of that
organization other than the Reserve should be excluded.
The Prosecution does not feel that there is evidence of the
severability of any class or classes of persons within the
organizations accused which would justify any further concessions
and feels that no other part of the named groups should be
excluded. In this connection, we would again stress the principles of
conspiracy. The fact that a section of an organization itself
committed no criminal act, or may have been occupied in technical
or administrative functions, does not relieve that section of criminal
responsibility if its activities contributed to the accomplishment of
the criminal enterprise.

E. Further Steps Before This Tribunal.

Over 45,000 persons have joined in communications to this
Tribunal asking to be heard in connection with the accusations
against organizations. The volume of these applications has caused
apprehension as to further proceedings. No doubt there are
difficulties yet to be overcome, but my study indicates that the
difficulties are greatly exaggerated.
The Tribunal is vested with wide discretion as to whether it will
entertain an application to be heard. The Prosecution would be
anxious, of course, to have every application granted that is
necessary, not only to do justice but to avoid the appearance of
doing anything less than justice. And we do not consider that
expediting this trial is so important as affording a fair opportunity to
present all really pertinent facts.
Analysis of the conditions which have brought about this flood of
applications indicates that their significance is not proportionate to
their numbers. The Tribunal sent out 200,000 printed notices of the
right to appear before it and defend. They were sent to Allied
prisoner of war and internment camps. The notice was published in
all German language papers and was repeatedly broadcast over the
radio. The 45,000 persons who responded with applications to be
heard came principally from about 15 prisoner of war and
internment camps in British or United States control. Those received
included an approximate 12,000 from Dachau, 10,000 from
Langwasser, 7,500 from Auerbach, 4,000 from Staumuehle, 2,500
from Garmisch, and several hundred from each of the others.
We undertook investigation of these applications from Auerbach
camp as probably typical of all. The camp is for prisoners of war,
predominantly SS members, and its prisoners number 16,964
enlisted men and 923 officers. The notice of the International
Tribunal was posted in each barracks and was read to all inmates.
The applications to the Tribunal were forwarded without censorship.
Applications to defend were made by 7,509 SS members.
Investigation indicates that these were filed in direct response to
the notice and that no action was directed or inspired from any other
source within the camp. All who were interrogated professed no
knowledge of any SS crimes or of SS criminal purpose, but
expressed interest only in their individual fate. Our investigators
report no indication that the SS members had additional evidence or
information to submit on the general question of the criminality of
the SS as an organization. They seemed to think it necessary to
make the application to this Tribunal in order to protect themselves.
Examination of the applications made to the Tribunal indicates
that most members do not profess to have evidence on the general
issue triable here. They assert that the writer has neither committed,
witnessed, nor known of the crimes charged against the
organization. On a proper definition of the issues such an application
is insufficient on its face.
A careful examination of the Tribunal’s notice to which these
applications respond will indicate that the notice contains no word
which would inform a member, particularly if a layman, of the
narrowness of the issues here, or of the later opportunity of each
member, if and when prosecuted, to present personal defenses. On
the other hand, I think the notice creates the impression that every
member may be convicted and punished by this Tribunal and that his
only chance to be heard is here.
In view of these facts we suggest consideration of the following
program for completion of this trial as to organizations.
1. That the Tribunal formulate and express in an order the scope
of the issues and the limitations on the issues to be heard by it.
2. That a notice adequately informing members as to the
limitation on issues and the opportunity for later, individual trial, be
sent to all applicants and published as was the original notice.
3. That a panel of masters be appointed as authorized in Article
17(e) of the Charter to examine applications and report those
insufficient on their own statements, and to go to the camps and
supervise the taking of any relevant evidence. Defense counsel and
prosecution representatives should of course attend and be heard
before the masters. The masters should reduce any evidence to
deposition form and report the whole to the Tribunal to be
introduced as a part of its record.
4. The representative principle may also be employed to simplify
this task. Members of particular organizations in particular camps
might well be invited to choose one or more to represent them in
presenting evidence.
 It may not be untimely to remind the Tribunal and defense
counsel that the prosecution has omitted from evidence many
relevant documents which show repetition of crimes by these
organizations in order to save time by avoiding cumulative evidence.
It is not too much to expect that cumulative evidence of a negative
character will likewise be limited.
Some concern has been expressed as to the number of persons
who might be affected by the declarations of criminality we have
asked. Some people seem more susceptible to the shock of a million
punishments than to the shock of 5 million murders. At most the
number of punishments will never catch up with the number of
crimes. However, it is impossible to state even with approximate
accuracy the number of persons who might be affected. Figures
from German sources seriously exaggerate the number, because
they do not take account of heavy casualties in the latter part of the
war, and make no allowances for duplication of membership, which
was large. For example, the evidence is to the effect that 75 percent
of the Gestapo men also were members of the SS. We know that the
United States forces have in detention a roughly estimated 130,000
persons who appear to be members of accused organizations. I have
no figures from other Allied forces. But how many of these actually
would be prosecuted, instead of being dealt with under the
denazification program, no one can foretell. Whatever the number,
of one thing we may be sure: it is so large that a thorough inquiry
by this Tribunal, into each case, would prolong its session beyond
endurance. All questions as to whether individuals or sub-groups of
accused organizations should be excepted from the Declaration of
Criminality, should be left for local courts, located near the home of
the accused and near sources of evidence. These courts can work in
one or at most in two languages, instead of four, and can hear
evidence which both parties direct to the specific issues.

F. Conclusion.
This is not the time to review the evidence against particular
organizations which, we take it, should be reserved for summation
after all the evidence is presented. But it is timely to say that the
selection of the six organizations named in the Indictment was not a
matter of chance. The chief reasons they were chosen are these:
collectively they were the ultimate repositories of all power in the
Nazi regime; they were not only the most powerful, but the most
vicious organizations in the regime; and they were organizations in
which membership was generally voluntary.
The Nazi Leadership Corps consisted of the directors and
principal executors of the Nazi Party, which was the force lying
behind and dominating the whole German state. The Reichs Cabinet
was the facade through which the Nazi Party translated its will into
legislative, administrative, and executive acts. The two pillars on
which the security of the regime rested were the armed forces,
directed and controlled by the General Staff and High Command,
and the police forces—the Gestapo, the SA, the SD, and the SS.
These organizations exemplify all the evil forces of the Nazi regime.
These organizations were also selected because, while
representative, they were not so large or extensive as to make it
probable that innocent, passive, or indifferent Germans might be
caught up in the same net with the guilty. State officialdom is
represented, but not all administrative officials or department heads
or civil servants; only the Reichsregierung, the very heart of
Nazidom within the Government, is named. The armed forces are
accused, but not the average soldier or officer, no matter how high
ranking. Only the top policy-makers—the General Staff and High
Command—are named. The police forces are accused, but not every
policeman: not the ordinary police, which performed only normal
police functions. Only the most terroristic and repressive police
elements—the Gestapo and SD—are named. The Nazi Party is
accused, but not every Nazi voter, not even every member; only the
leaders, the Politische Leiter. (See Chart No. 14.) And not even every
Party official or worker is included; only “the bearers of sovereignty,”
in the metaphysical jargon of the Party, who were the actual
commanding officers and their staff officers on the highest levels,
are accused. The “formations” or strong arms of the Party are
accused, but not every one of the seven formations, nor any of the
twenty or more supervised or affiliated party groups. Nazi
organizations in which membership was compulsory, either legally or
in practice (like the Hitler Youth and the Deutsche Studentschaft);
Nazi professional organizations (like the Civil Servants Organization,
the National Socialist Teachers Organization, and the National
Socialist Lawyers Organization); Nazi organizations having some
legitimate purpose (like the welfare organizations), have not been
indicted. Only two formations are named, the SA and the SS, the
oldest of the Nazi organizations, groups which had no purpose other
than carrying out the Nazi schemes and which actively participated
in every crime denounced in the Charter.
In administering preventive justice with a view to forestalling
repetition of these crimes against peace, crimes against humanity,
and war crimes, it would be a greater catastrophe to acquit these
organizations than it would be to acquit the entire 22 individual
defendants in the box. These defendants’ power for harm is spent.
That of these organizations goes on. If they are exonerated here,
the German people will infer that they did no wrong and will easily
be regimented in reconstituted organizations under new names
behind the same program.
In administering retributive justice it would be possible to
exonerate these organizations only by concluding that no crimes
have been committed by the Nazi regime. Their sponsorship of every
Nazi purpose and their confederation to execute every measure to
attain those ends is beyond denial. A failure to condemn these
organizations under the terms of the Charter can only mean that
such Nazi ends and means cannot be considered criminal, and that
the Charter of the Tribunal is considered a nullity.

2. THE NAZI PARTY LEADERSHIP CORPS

The Nazi Party Leadership Corps—it is proposed to demonstrate
—was responsible for planning, directing, and supervising the
criminal measures carried into execution by the Nazi Party, which
was the central core of the common plan or conspiracy charged in
Count I of the Indictment. Moreover, it will be shown, the members
of the Leadership Corps themselves actively participated in the
commission of illegal measures in aid of the conspiracy. In the light
of the evidence to be discussed, the Leadership Corps may be fairly
described as the brain, the backbone, and the directing arms of the
Nazi Party. Its responsibilities are more massive and comprehensive
than those of the army of followers who blindly and faithfully did its
bidding.

A. Composition, Functions, Responsibilities, and Powers of the

Leadership Corps.
In considering the composition and organizational structure of
the Leadership Corps, preliminary reference is made to the
organization chart of the Nazi Party (Chart Number 1) as well as a
chart of the Leadership Corps of the Nazi Party appearing at page 9
of a magazine published by the Chief Education Office of the Nazi
Party entitled “Das Gesicht der Partei” (The Face of the Party). These
charts and the evidence to follow show that the Leadership Corps
constituted the sum of the officials of the Nazi Party: it included the
Fuehrer; the Reichsleiter and Reich office holders; the five categories
of leaders who were area commanders (called Hoheitstraeger, or
“bearers of sovereignty”) ranging all the way from the 40-odd
Gauleiter in charge of large districts down through the intermediate
political leaders to the Blockleiter, charged with looking after 40 to
60 households; and what may best be described as the Staff Officers
attached to each of the 5 levels of Hoheitstraeger.
Organized upon a hierarchical basis, forming a pyramidal
structure, the principal Political Leaders on a scale of descending
authority were:

Fuehrer
Reichsleiter (Reich Leaders) and Main Office and Office
Holders
Gauleiter (District Leaders) and Staff Officers
Kreisleiter (County Leaders) and Staff Officers
Ortsgruppenleiter (Local Chapter Leaders) and Staff Officers
Zellenleiter (Cell Leaders) and Staff Officers
Blockleiter (Block Leaders) and Staff Officers

A large part of this and other evidence relating to the composition of

the Leadership Corps of the Nazi Party is to be found in the 1943
edition of the Organization Book of the NSDAP, an authoritative
primer on Nazi organizations which was edited by the defendant,
Reich Organization Leader of the NSDAP, Dr. Robert Ley.
The Reichsleitung of the Leadership Corps consisted of the
Reichsleiter or Reich Leaders of the Party, the Hauptaemter (Main
Offices) and the Aemter (or Offices). The Reichsleiter of the Party
were, next to Hitler, the highest officeholders in the Party hierarchy.
All the Reichsleiter and Main Office and officeholders within the
Reichsleitung were appointed by Hitler and were directly responsible
to him. The Organization Book of the NSDAP puts it as follows:

“The Fuehrer appoints the following Political Directors:

“Reichsleiter and all Political Directors, to include the Directors
of the Womens Leagues within the Reich Directorate or
Reichsleitung.” (1893-PS)

The significant fact is that through the Reichsleitung perfect

coordination of Party and State machinery was guaranteed. The
Party Manual describes it this way:

“In the Reichsleitung the arteries of the organization of the

German people and of the German State merge.” (1893-PS)

To demonstrate that the Reichsleiter of the Leadership Corps

included the most powerful coalition of political overlords in Nazi
Germany, it is necessary only to mention their names. The list of
Reichsleiter includes the following defendants on trial: Rosenberg,
Von Schirach, Frick, Bormann, and Ley.
The evidence to be presented will show that Rosenberg was the
leader of an organization named for him, the Einsatzstab Rosenberg,
which carried out a vast program of looting and plunder of art
treasures throughout occupied Europe. The evidence will further
show that, as Representative of the Fuehrer for the Supervision of
Nazi Ideology and Schooling, Rosenberg participated in an
aggressive campaign to undermine the Christian churches and to
supersede Christianity by a German National Church founded upon a
combination of irrationality, pseudo-scientific theories, mysticism,
and the cult of the racial state.
It will be shown that the late Defendant Ley, acting as the agent
of Hitler and the Leadership Corps, directed the Nazi assault upon
the independent labor unions of Germany and before destroying
himself first destroyed the free and independent labor movement;
and that he replaced it by a Nazi organization, the German Labor
front or DAF, which he employed as a means of exploiting the
German labor force in the interests of the conspiracy and to instill
Nazi ideology among the ranks of the German workers.
It will be shown that Frick participated in the enactment of many
laws which were designed to promote the conspiracy in its several
phases. Frick shares responsibility for the grave injury done by the
officials of the Leadership Corps to the concept of the rule of law by
virtue of his efforts to give the color of law and formal legality to a
large volume of Nazi legislation violative of the rights of humanity,
such as the legislation designed to stigmatize and eliminate the
Jewish people of Germany and German-occupied Europe. As chief of
the Party Chancellery, immediately under Hitler, Bormann was an
extremely important force in directing the activities of the Leadership
Corps. As will be shown, a decree of 16 January 1942 provided that
the participation of the Party in all important legislation,
governmental appointments, and promotions had to be undertaken
exclusively by Bormann. He took part in the preparation of all laws
and decrees issued by the Reich authorities and gave his assent to
those of the subordinate governments.
The list of Reichsleiter of the NSDAP set forth in the National
Socialist Yearbook (1943 Edition) shows that the following 15
Reichsleiter were in office in 1943 (2473-PS):
 “THE REICHSLEITERS OF THE NSDAP
“Max Amann Reichsleiter for the Press.
“Martin Bormann Chief of the Party Chancery.
“Phillipp Bouhler Chief of the Chancery of the Fuehrer of
the NSDAP. Chairman of the official Party
Investigation Commission for the
Protection of National Socialist Writings.
“Walter Darré On leave.
“Otto Dietrich Reich Press Chief of the NSDAP.
“Franz von Epp Chief of the Kolonialpolitischen Amtes.
“Karl Fiehler Chief of the main office for Municipal
Politics.
“Wilhelm Frick Leader of the National Socialist “faction”
in the Reichstag.
“Joseph Goebbels Reich Propaganda Leader of the NSDAP.
“Konstantin Hierl Leader of the Reich Labor.
“Heinrich Himmler Reich Leader of the SS. The Deputy of
the NSDAP, for all questions of
Germandom.
“Robert Ley Reich Organization Leader of the NSDAP.
Leader of the German Labor Front.
“Victor Lutze Chief of Staff of the SA.
“Alfred Rosenberg Representative of the Fuehrer for the
supervision of all mental and ideological
training and education of the NSDAP.
“Baldur von Schirach Reich Leader for the Education of Youth
of the NSDAP.
“Franz Xaver Schwarz Reich Treasurer of the NSDAP.”
(2473-PS)
The principal functions of the Reichsleiter included carrying out
the tasks and missions assigned to them by the Fuehrer or by the
Chief of the Party Chancellery, Martin Bormann. The Reichsleiter
were further charged with insuring that Party policies were being
executed in all the subordinate areas of the Reich. The Reichsleiter
were also responsible for insuring a continual flow of new leadership
into the Party. With respect to the function and responsibilities of the
Reichsleiter, the Organization Book of the NSDAP states as follows:

“The NSDAP represents the political conception, the political

conscience, and the political will of the German nation.
Political conception, political conscience, and political will are
embodied in the person of the Fuehrer. Based on his
directives and in accordance with the program of the NSDAP
the organs of the Reich Directorate directionally determine
the political aims of the German people. It is in the Reich
Directorate that the arteries of the organization of the
German people and the State merge. It is the task of the
separate organs of the Reich Directorate to maintain as close
a contact as possible with the life of the nation through their
sub-offices in the Gau * * *
“The structure of the Reich Directorate is thus that the
channel from the lowest Party office upwards shows the most
minute weaknesses and changes in the mood of the people *
**
“Another essential task of the Reich Directorate is to assure a
good selection of leaders. It is the duty of the Reich
Directorate to see that there is leadership in all phases of life,
a leadership which is firmly tied to National Socialist ideology
and which promotes its dissemination with all its energy * * *
“* * * It is the supreme task of the Reich Organization Leader
to preserve the Party as a well-sharpened sword for the
Fuehrer.” (1893-PS)

The domination of the German Government by the top members

of the Leadership Corps was facilitated by a circular decree of the
Reich Minister of Justice, dated 17 February 1934, which established
equal rank for the offices within the Reichsleitung of the Leadership
Corps and the Reich offices of the government. In this decree it was
expressly provided that
“the supreme offices of the Reichsleitung are equal in rank to
the supreme Reich Government authorities.”

The Party Manual termed the control exercised over the machinery
of government by the Leadership Corps “the permeation of the State
apparatus with the political will of the Party.”
Domination by the Leadership Corps over the German State and
Government was facilitated by uniting in the same Nazi chieftains
both high office within the Reichsleitung and corresponding offices
within the apparatus of government. For example, Goebbels was a
Reichsleiter in charge of Party propaganda, but he was also a
cabinet minister in charge of Propaganda and Public Enlightenment.
Himmler held office within the Reichsleitung as head of the Main
Office for “Volkdom” and as Reichsfuehrer of the SS. At the same
time, Himmler held the governmental position of Reich Commission
for the Consolidation of Germandom and was the governmental
head of the German police system (Chart Number 1). This personal
union of high office in the Leadership Corps and high governmental
position in the same Nazi Leaders greatly assisted the plan of the
Leadership Corps to dominate and control the German State and
Government.
In addition to the Reichsleiter, the Reichsleitung (Reich Party
Directorate) included about eleven Hauptamter, or Main Offices, and
about four Amter, or Offices. The Hauptamter of the Party included
such main organizations as those for personnel, training, technology
(headed by Speer), “Volkdom,” (headed by Himmler), civil servants,
communal policy, and the like. The Amter, or offices, of the Party
within the Reichsleitung included the Office for Foreign Policy under
Rosenberg which actively participated in plans for aggression against
Norway, the Office for Colonial Policy, the Office for Geneology, and
the Office for Racial Policy.
Certain of the main offices and offices within the Reichsleitung
appeared again within the Gauleitung, or Gau Party Directorate, and
Kreisleitung, or County Party Directorate. Thus, the Reichsleiter and
main office and office holders within the Reichsleitung exercised,
through functional channels running through subordinate offices on
lower regional levels, total control over the various sectors of the
national life of Germany.
(1) Gauleiter. For Party purposes Germany was divided into major
administrative regions, Gaue, which, in turn, were subdivided into
Kreise (counties), Ortsgruppen (local chapters), Zellen (cells), and
Blocke (blocks). Each Gau was in charge of a Gauleiter who was the
political leader of the Gau or district. Each Gauleiter was appointed
by and was responsible to Hitler himself. The Organization Book of
the NSDAP states:

“The Gau represents the concentration of a number of Party

counties, or Kreise. The Gauleiter is directly subordinate to
the Fuehrer. He is appointed by the Fuehrer. The Gauleiter
bears overall responsibility to the Fuehrer for the sector of
sovereignty entrusted to him. The rights, duties, and
jurisdiction of the Gauleiter result primarily from the mission
assigned by the Fuehrer and, apart from that, from detailed
directives.” (1893-PS)

The responsibility and function of the Gauleiter and his staff

officers or office holders were essentially political, namely, to insure
the authority of the Nazi Party within his area, to coordinate the
activities of the Party and all its affiliated and supervised
organizations, and to enlarge the influence of the Party over people
and life in his Gau generally. Following the outbreak of the war,
when it became imperative to coordinate the various phases of the
German war effort, the Gauleiter were given additional important
responsibilities. The Ministerial Council for the Defense of the Reich,
which was a sort of general staff for civil defense and the
mobilization of the German war economy, by a decree of 1
September 1939 (1939, Reichsgesetzblatt, Part I, page 1565),
appointed about sixteen Gauleiter as Reich Defense Commissars.
Later, under the impact of mounting military reverses and an
increasingly strained war economy, more and more important
administrative functions were put on a Gau basis; the Party Gaue
became the basic defense areas of the Reich and each Gauleiter
became a Reich Defense Commissar (Decree of the Ministerial
Council for the Defense of the Reich of 16 November 1942, 1942
Reichsgesetzblatt, Part I, page 649). In the course of the war,
additional functions were entrusted to the Gauleiter so that at the
end, with the exception of certain special matters, such as police
affairs, almost all phases of the German war economy were
coordinated and supervised by them. For instance, regional authority
over price control was put under the Gauleiter as Reich Defense
Commissars, and housing administration was placed under the
Gauleiter as Gau Housing Commissar. Toward the end of the war, the
Gauleiter were charged even with military and quasi military tasks.
They were made commanders of the Volkssturm in their areas and
were entrusted with such important functions as the evacuation of
civilian population in the path of the advancing Allied armies, as well
as measures for the destruction of vital installations.
The structure and organization of the Party Gau were
substantially repeated in the lower levels of the Party organization
such as the Kreise, Ortsgruppen, Cells, and Blocks. Each of these
was headed by a political leader who, subject to the Fuehrer
principle and the orders of superior political leaders, was sovereign
within his sphere. The Leadership Corps of the Nazi Party was in
effect a “hierarchy of descending caesars.” Each of the subordinate
Party levels, such as Kreise, Ortsgruppen, and so on, was organized
into offices or Amter dealing with the various specialized functions of
the Party. But the number of such departments and offices
diminished as the Party unit dropped in the hierarchy, so that, while
the Kreise office contained all, or most of the offices in the Gau
(such as the deputy, the staff office leader, an organization leader,
school leader, propaganda leader, press office leader, treasurer, judge
of the Party Court, inspector, and the like), the Ortsgruppe had less
and the Zellen and Blocke fewer still.
(2) Kreisleiter (County Leaders). The Kreisleiter was appointed
and dismissed by Hitler upon the nomination of the Gauleiter and
directly subordinate to the Gauleiter in the Party hierarchy. The Kreis
usually comprised a single county. The Kreisleiter, within the Kreis,
had in general the same position, powers, and prerogatives granted
the Gauleiter in the Gau. In cities they constituted the very core of
Party power and organization. According to the Organization Book of
the NSDAP:

“The Kreisleiter carries over-all responsibility towards the

Gauleiter within his zone of sovereignty for the political and
ideological training and organization of the Political Leaders,
the Party members, as well as the population.” (1893-PS)

(3) Ortsgruppenleiter (Local Chapter Leaders). The area of the

Ortsgruppenleiter comprised one or more communes or, in a town, a
certain district. The Ortsgruppe was composed of a combination of
blocks and cells and, according to local circumstances, contained up
to 1500 households. The Ortsgruppenleiter also had a staff of office
leaders to assist him in the various functional activities of the Party.
All other political leaders in his area of responsibility were
subordinate to and under the direction of the Ortsgruppenleiter. For
example, the leaders of the various affiliated organizations of the
Party, within his area, such as the German Labor Front, and the Nazi
organizations for lawyers, students, and civil servants, were all
subordinate to the Ortsgruppenleiter. In accordance with the
Fuehrer principle, the Ortsgruppenleiter or Local Chapter Leaders
were appointed by the Gauleiter and were directly under and
subordinate to the Kreisleiter.
The party Manual provides as follows with respect to the
Ortsgruppenleiter:

“As Hoheitstraeger [Bearer of Sovereignty] all expressions of

the Party will emanate from the Ortsgruppenleiter; he is
responsible for the political and ideological leadership and
organization within his zone of sovereignty.
“The Ortsgruppenleiter carries the over-all responsibility for
the political results of all measures initiated by the offices,
organizations, and affiliated associations of the Party. * * *
The Ortsgruppenleiter has the right to protest to the
Kreisleiter against any measures contrary to the interests of
the Party with regard to an outside political appearance in
public.” (1893-PS)

(4) Zellenleiter (Cell Leaders). The Zellenleiter was responsible

for four to eight blocks. He was the immediate superior of and had
control and supervision over the Blockleiter (Block Leader). His
mission and duties, according to the Party Manual, corresponded to
the missions of the Blockleiter. (1893-PS)
(5) Blockleiter (Block Leaders). The Blockleiter was the one Party
official who was peculiarly in a position to have continuous contact
with the German people. The block was the lowest unit in the Party
pyramidal organization. The block of the Party comprised 40 to 60
households and was regarded by the Party as the focal point upon
which to press the weight of its propaganda. The Organization Book
of the NSDAP states:

“The household is the basic community upon which the block

and cell system is built. The household is the organizational
focal point of all Germans united in an apartment and
includes roomers, domestic help, etc. * * * The Blockleiter
has jurisdiction over all matters within his zone relating to the
Movement and is fully responsible to the Zellenleiter. * * *”
(1893-PS)

The Blockleiter, as in the case of other political leaders, was

charged with planning, disseminating, and developing a receptivity
to the policies of the Nazi Party among the population in his area of
responsibility. It was also the expressed duty of the Blockleiter to spy
on the population. According to the Party Manual:

“It is the duty of the Blockleiter to find people disseminating

damaging rumors and to report them to the Ortsgruppe so
that they may be reported to the respective State authorities.
“The Blockleiter must not only be preacher and defender of
the National Socialist ideology towards the members of nation
and Party entrusted to his political care, but he must also
strive to achieve practical collaboration of the Party members
within his block zone * * *.”
“The Blockleiter shall continuously remind the Party members
of their particular duties towards the people and the State * *
* The Blockleiter keeps a list (card file) about the households
* * * In principle, the Blockleiter will settle his official
business verbally and he will receive messages verbally and
pass them on in the same way. Correspondence will only be
used in cases of absolute necessity * * * The Blockleiter
conducts National Socialist propaganda from mouth to mouth.
He will eventually awaken the understanding of the eternally
dissatisfied as regards the frequently misunderstood or
wrongly interpreted measures and laws of the National
Socialist Government * * * It is not necessary to him to fall in
with complaints and gripes about possibly obvious
shortcomings of any kind in order to demonstrate * * *
solidarity * * * A condition to gain the confidence of all
people is to maintain absolute secrecy in all matters.” (1893-
PS)

There were in Germany around a half million of these Blockleiter.

Large though this figure may appear, there can be no doubt that
these officials were in and of the Leadership Corps of the Nazi Party.
Though they stood at the broad base of the Party pyramid rather
than at its summit, where rested the Reichsleiter, by virtue of this
fact they were stationed at close intervals throughout the German
civil population. It may be doubted that the average German ever
looked upon the face of Heinrich Himmler. But the man in the street
in Nazi Germany could not have avoided an uneasy acquaintance
with the Blockleiter in his neighbourhood. It was the block leaders
who represented to the people of Germany the police-state of
Hitler’s Germany. In fact, the Blockleiter were little fuehrers with real
power over the civilians in their domains. The authority of the
Blockleiter to exercise coercion and the threat of force upon the civil
population is shown in an excerpt from page 7 of the magazine
published by the Chief Education Office of the Party, entitled “The
Face of the Party”:

“Advice and sometimes also the harsher form of education is

employed if the faulty conduct of an individual harms this
individual himself and thus also the community.”

(6) Hoheitstraeger. Within the Leadership Corps of the Nazi Party

certain of the Political Leaders possessed a higher degree of
responsibility than others, were vested with special prerogatives, and
constituted a distinctive and elite group. These were the so-called
“Hoheitstraeger” (Bearers of Sovereignty) who represented the Party
within their area of jurisdiction, the so-called Hoheitsgebiet. The
Party Manual (1893-PS) states as follows:

“Among the Political Leaders, the Hoheitstraeger assumed a

special position. Contrary to the other Political Leaders who
have departmental missions, the Hoheitstraeger themselves
are in charge of a geographical sector known as the
Hoheitsgebiet [Sectors of Sovereignty].
“Hoheitstraeger are:
“The Fuehrer
The Gauleiter
The Kreisleiter
The Ortsgruppenleiter
The Zellenleiter
The Blockleiter.
“Hoheitsgebiet are:
“The Reich
The Gau
The Kreis
The Ortsgruppe
The Zelle
The Block.
“Within their sector of sovereignty the Hoheitstraeger have
sovereign political rights. They represent the Party within
their sector. The Hoheitstraeger supervise all Party Officers
within their jurisdiction and * * * are responsible for the
maintenance of discipline. * * * The directors of offices, etc.,
and of the affiliated organizations are responsible to their
respective Hoheitstraeger as regards their special missions. *
* * The Hoheitstraeger are superior to all Political Leaders,
managers, etc., within their sector. As regards personal
considerations, Hoheitstraeger * * * are endowed with special
rights.
“The Hoheitstraeger of the Party are not to be administrative
officials * * * but are to move in a continuous vital contact
with the Political Leaders of the population within their sector.
The Hoheitstraeger are responsible for the proper and good
supervision of all members of the nation within their sectors *
* *.
“The Party intends to achieve a state of affairs in which the
individual German will find his way to the Party * * *.” (1893-
PS)

The distinctive character of the Politischer Leiter (Political

Leaders) constituting the Hoheitstraeger, and their existence and
operation as an identifiable group, are indicated by the publication of
a magazine, entitled Der Hoheitstraeger, whose distribution was
limited by regulation of the Reich Organization Leader to the
Hoheitstraeger and certain other designated Politischer Leiter. The
inside cover of this exclusive Party magazine reads as follows:

“DER HOHEITSTRAEGER, the contents of which is to be

handled confidentially, serves only for the orientation of the
competent leaders. It may not be loaned out to other persons
* * *” [then follows a list of the Hoheitstraeger and other
Political Leaders authorized to receive the magazine.] (2660-
PS)

The magazine states that, in addition, the following were entitled

to receive it:
“Commandants, Unit Commanders and Candidates of Order
Castles; the Reich, Shock Troop and Gaue Speakers of the
NSDAP; the Lieutenant Generals and Major Generals of SA,
SS, NSFK, and NSKK; Lieutenant Generals and Major Generals
of the HJ.” (2660-PS)

The fact that this magazine existed, that it derived its name from
the Commanding Officers of the Leadership Corps, that it was
distributed to the elite of the Leadership Corps—that a House
Bulletin was circulated down the command channels of the
Leadership Corps—demonstrates that the Leadership Corps of the
Nazi Party was an identifiable group or organization within the
meaning of Article 9 of the Charter.
An examination of the contents of the magazine Der
Hoheitstrager reveals a continuing concern by the Leadership Corps
of the Nazi Party in measures and doctrines which were employed
throughout the course of the conspiracy. The plans and policies of
the inner elite of the Leadership Corps gain clarity through a random
sampling of articles published and policies advocated in various
issues of the magazine Der Hoheitstrager. From February 1937 to
October 1938 these included the following: anti-Semitic articles,
attacks on Catholicism and the Christian religion and clergy; the
need for motorized armament; the urgent need for expanded
Lebensraum and colonies; persistent attacks on the League of
Nations; the use of the Block and Cell in achieving favorable votes in
Party plebiscites; the intimate association between the Wehrmacht
and the Political Leadership; the racial doctrines of Fascism; the cult
of “leadership”; the role of the Gaue, Ortsgruppen, and Zellen in the
expansion of Germany; and related matters.
(a) Organization of Political Leaders. The Political Leaders were
organized according to the leadership principle (1893-PS):

“The basis of the Party organization is the Fuehrer thought.

The public is unable to rule itself either directly or indirectly *
* * All Political Leaders stand as appointed by the Fuehrer
and are responsible to him. They possess full authority
toward the lower echelons * * * Only a man who has
absorbed the school of subordinate functions within the Party
has a claim to the higher Fuehrer offices. We can only use
Fuehrers who have served from the ground up. Any Political
Leader who does not conform to these principles is to be
dismissed or to be sent back to the lower offices, as
Blockleiter, Zellenleiter for further training * * *
“The Political Leader is not an office worker but the Political
Deputy of the Fuehrer * * * Within the Political Leadership,
we are building the Political Leadership of the state * * * The
type of the Political Leader is not characterized by the office
which he represents. There is no such thing as a Political
Leader of the NSBO, etc., but there is only the Political Leader
of the NSDAP.” (1893-PS)

Each Political Leader was sworn in yearly. According to the Party

Manual (1893-PS), the wording of the oath was as follows:

“I pledge eternal allegiance to Adolf Hitler. I pledge

unconditional obedience to him and the Fuehrers appointed
by him.” (1893-PS)

The Organization Book of the NSDAP also provides:

“The Political Leader is inseparably tied to the ideology and

the organization of the NSDAP. His oath only ends with his
death or with his expulsion from the National Socialist
community.” (1893-PS)

(b) Appointment of Political Leaders. The appointment of the

political leaders constituting the Leadership Corps of the Nazi Party
proceeded as follows, according to the Party Manual:

“The Fuehrer appointed the following Political Leaders:

“a. All Reichsleiter and all Political Leaders within the
Reichsleitung [Reich Party Directorate], including women’s
leaders.
“b. All Gauleiter, including the Political Leaders holding offices
in the Gauleitung [Gau Party Directorate], including Gau
women leaders.
“c. All Kreisleiter.
“The Gauleiter appointed:
“a. The Political Leaders and women’s leaders within the Gau
Party Directorate.
“b. The Political Leaders and directors of women’s leagues in
the Kreis Party Directorate.
“c. All Ortsgruppenleiter.
“The Kreisleiter appoints the Political Leaders and the
Directors of the Women’s Leagues of the Ortsgruppen
including the Block and Cell Leaders.” (1893-PS)

c. Power of Hoheitstraeger to Call Upon Party Formations. The

Hoheitstraeger among the Leadership Corps were entitled to call
upon and utilize the various Party Formations as necessary for the
execution of Nazi Party policies.
The Party Manual makes it clear that the Hoheitstrager has
power and authority to requisition the services of the SA:

“The Hoheitstrager is responsible for the entire political

appearance of the Movement within his zone. The SA leader
of that zone is tied to the directives of the Hoheitstrager in
that respect.
“The Hoheitstrager is the ranking representative of the Party
to include all organizations within his zone. He may
requisition the SA located within his zone from the respective
SA leader if they are needed for the execution of a political
mission. The Hoheitstrager will then assign the mission to the
SA * * *
“Should the Hoheitstrager need more SA for the execution of
political mission than is locally available, he then applies to
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