From the files of Justice Robert H Jackson, US chief prosecutor at Nuremberg.

MEMORANDUM TO: Mr. Justice Jackson,

Major General Donovan
Colonel John H. Amen
Colonel Telford Taylor
Sidney S. Alderman
Robert G. Storey
Thomas J. Dodd

SUBJECT: Photographic Evidence

After viewing the film which was shown last night which traces the rise the Nazi power, and internal domination of Germany and the Nazi plans for aggressive war, I have the strong conviction that the film should not be used as evidence during the course of the prosecution's presentation but rather as a photographic summation which would be shown at the very end of the prosecution's case in chief or immediately preceding the concluding argument of the prosecution counsel at the end of the entire case.

Allowing for the improvements in the film which will result from cutting portions of the footage and joining the segments which are now separated, the film would still be "illustrative" rather than "evidentiary". It contains some good admissions but they are not sufficiently striking to warrant their use during the presentation of evidence and I doubt seriously if there is anything in the film which the defendants themselves would deny if they had knowledge.

In addition, I would, in the cutting process, eliminate the scenes which follow the movement across the border in Austria, Sudetenland and the Rhine, in all of which flag waving, smiling faces and the presentation of flowers help to nullify our notion that by these acts the people were planning or waging a war against their

neighbors. I would also cut considerably the actual war shots at Rotterdam and Norway leaving only a suggestion that this was the beginning of war. If we are going to go into war shots showing the destructiveness of war, then we had better do it wholesale and include Stalingrad, Coventry, et cetra, but I don't think these should be used.

[Gordon Dean]

Gordon Dean