Gotta say that who gave guards 3 dp38 and allowed them to shoot on the move is a very funny guy. VERY funny.
3x DP-28 have pretty much identical DPS to 2x M1919s on Paratroopers, who can also fire theirs on the move. They should have only 0.25 moving accuracy so they're not very good on the move anyway.
One Obersoldaten LMG 34 (0.75 moving accuracy) has way, way more moving DPS than 2x M1919 / 3x DP-28.
(Moving at 35 range gives 9.499 DPS for LMG 34 vs 1.809 per M1919 and worse for DP-28)