.." So far, that speech.
THE PRESIDENT: Since you are passing from that now, we might perhaps adjourn.
(A recess was taken.)
BY DR. SIEMERS: you used the sentence before the Kellogg Pact. In conclusion, I should like to ask you, did this principle of January, 1928 remain your principle during the whole time of your command of the Navy?
DR. SIEMERS: In connection with the Versailles Treaty, I should now like to submit an affidavit, because some figures are necessary here, which it is easier to submit in writing than by interrogation. I shall turn to Affidavit II, Raeder No. 8, document book 1, Page 39. misunderstanding, I should like to point out that Vice admiral Lohmann has nothing to do with the captain Lochmann, who was well known, almost famous, in the 20's. The tribunal may remember that the Lohmann affair was mentioned in connection with the broaches of the Versailles Treaty. Captain Lohmann at that time died in 1930, and has nothing to do with the author of this affidavit, Vice Admiral Lohmann. Admiral Raeder was in charge of the Navy. It was already concluded in 1928.
THE PRESIDENT: Are you wanting to callthis Admiral Lohmann as a witness?
DR. SIEMERS: No, I did not name him as a witness, as he was satisfied with the affidavit. Because of the many numbers, the British prosecution delegation agreed to turning in the affidavit, but asked that Admiral Lohmann might be cross-examined. And that was arranged with me.
THE PRESIDENT: I see, yes. You do not need to go into all those figures of tons, do you? You do not need to read all these, do you?
DR. SIEMERS: I do not want to read the individual figures. I would like to point out that this is not the affidavit about Doenitz; this is Raeder No. 8, Page 39.
THE PRESIDENT: Yes,; I have the one. There are a good many tons in it, though.
DR. SIEMERS: I should like to read under Roman numeral "I":
"Under the Versailles Treaty, Germany was permitted to build 8 armoured ships."
"Germany, however, built only three armoured ships, the 'Deutschland', the 'Admiral Scheer', and the 'Graf Spec'.
"2. Under the Versailles Treaty, Germany was permitted to build 8 cruisers. Germany, however, built only 6 cruisers." I shall omit the details.
"3. Under the Versailles Treaty, Germany was permitted to build 52 destroyers or torpedo boats. Germany, however, built only 12 destroyers and no torpodo boats." BY DR. SIEMERS: exhausted the possibilities of the VersaillesTreaty. It specifically omitted the construction of the larger ships. So I ask for your opinion.
A. That is correct. It is astonishing that the Versailles Treaty in this period of time was used so little. I was reproached for this when the National Socialist Government took power. It was not considered, however, that the government at that time, and the Reichstag, were not of a mind to improve those ships. We had to fight for this permission to build up the Navy. which we were permitted primarily in order to make a pitiable defense of the coast in extreme emergency.
Q I shall come back to Document 332. It is established that during the time of the Versailles Treaty, Germany did not take advent ago of the provisions of the Treaty. On the other hand, on the basis of the documents submitted by the prosecution, it has been shown that the Navy committed broaches of the Versailles Treaty in other connections. The individual breaches were given with great precision by the prosecution. breaches were committed behind the back of the Reichstag and the government. Is this accusation justified?
A. Not at all. I must repeat that I was not connected with those breaches. First, on the first of October, 1938, I became chief of the Navy Command in Berlin. But since it was done previously, I had nothing to do with it. Then I came to Berlin, The Lohmann case which you mentioned previously had already been concluded. It was in the process of being liquidated. And the Reich defense minister Groener, when the affair was first discovered, ordered the army as well as the navy to report to him all breaches which were in process, and from then on he would discuss these things with Colonel von Schleicher. He liquidated the Lohmann affair, and this liquidation was still in progress when I came there. assign the responsibility for all these broaches of the Versailles Treaty to the Reich government as a whole, then the Hueller-Severing-Stresemann Government, since he believed that he could no longer boar this responsibility. these matters, the chief of the army command, General Heil, and I, as well as some office chiefs in the administration, were called to a meeting, and at that cabinet session all the ministers were present. General Heil and I had to report openly and completely as to what broaches were undertaken by the army and the navy. and removed the responsibility from the Reich defense minister, who, however, continued to be responsible for the execution of things. Everything which happened in the future we had to report to the Reich defense minister, and were not allowed to undertake any stops alone. Reichsminisminister of the Interior, Severing, who showed great understanding for the various necessities. command, gave a list of the individual breaches?
Q And thereupon the government told you, "We will take the responsibility" agreement with the Reich government?
A Yes; the Reich defense minister Greener was extremely sensitive on this point. He insisted that he shall learn everything and should approve everything. He thought that only in this way could he take the responsibility. I had nothing whatever to do with the Reichstag. The military chiefs were not allowed to have any contact with the Reichstag or its members. Any contact with the Reichstag was through the Reich defense minister or by Colonel von Schleicher on his behalf. I could talk about the fact with the Reichstag members only in the so-called budget committee, where, aside from the Reich defense minister, I was sitting and had to comment on his statements. secret departments within the construction program of the navy without the approval of the Reich government?
A. Without the approval of the Reich government, and, above all, of the Reich defense minister.
DR. SIEMERS: May I ask the Tribunal in this connection, from Raeder Exhibit No. 3, document Book I, cage 10, please look at Article 50, It reads:
"In order to be valid, all decrees and orders issued by the Reich President, including those pertaining to the Armed Forces, must be countersigned by the Reich Chancellor or the competent Reich-Minister. By the act of countersigning, responsibility is accepted." existed in October 1928. An important part of the construction of the Navy was that the old line ships from the former war were to be renewed.
In this connection, I submit to the Tribunal Raeder Exhibit No. 7, document Book Roman Numeral I, page 23. Book shows, under paragraph No. 2. It at first was submitted at the suggestion of the Reichstag, and then I might point out on page 24, #3, it shows that this hip construction replacement plan refers to three armored ships, and it is added that the construction could last until 1938. This figure is important, as the Prosecution will note, that in 1933 the Construction Plan was set up until 1938, in order to deduce a plan for attack. period, 1938, which, as the prosecution will admit, can have nothing to do with a war of aggression.
Q. The submission of the plan was through the Reich Government and you did the work, the preparatory work?
A. Yes.
Q. Is this only true of the ship replacement plan for 1938, or was it always handled in the some way in subsequent years?
A. The plan as submitted was true basically of the Reichstag. Each individual ship, however, had to be included in the budget plan of the year in which the construction was to begin and had to be separately approved. The whole construction program was thus in close agreement with the Reich Government and the Reichstag.
DR. SIEMERS: From this ship replacement program in connection with the Document I should like to point out two points which will greatly shorten the questioning of the witness. out that the great age of all the ships and all the liners referred to, which necessitated replacements, necessitated a ship replacement program. in it's 89th session of 18th June, 1929, asks the Reich Government for an extension of the construction program. The general opinion at that time is that, as the ship replacement program shows, set down in the Frankfurter Zeitung Title of 15 August 1928, and the Frankfurter Zeitung points out that an armored cruiser gains its full value only as a member of a squadron. The Frankfurter Zeitung was the best German newspaper and only in 1945 during the war it was forbidden, when the National Socialist Dictatorship became worse and worse.
I should like to point out on page 29 and quote one sentence:
"The building of the battleships will be stretched out over a long period of time, so as to hove the Navy where Wilhelmshaven occupied continuously. The ideal time of construction is about three years." occupation as long as possible. building program would have been hastened. having a tonnage of ten thousand tons, was about 75 million marks. testimony, where the value of the breaches of the Versailles Treaty wall be shown, and finally on page 30 may quote a few lines from the plan of the militarization of the Wehrmacht. I quote:
"For the Wehrmacht and the German Reich to defend its borders and protect it's peace, and since the German Republic as the only one of the great powers carrying out it's armament, the following possibility had to be taken into consideration: The employment of the armed forces as a defense against armed territories, and as a defense agains neutrality."
which the Prosecution brought up.
I, page 1, and refer to page 3, Article 191. It is a question of the acquisition by Germany contrary to the Versailles Treaty and of the constructof submarines. Article 191 reads and I quote:
"The construction and acquisition of all submersibles, even for commercial purposes, is forbidden to Germany." ship construction of submarines in Holland, and was interested in a general ship construction program and of submarines which were being constructed in Holland, in order to save time again it will be simpler if I refer to the affidavit of Vice Admiral Lohman, Roman NumeralI in Document Book I, page 4, Raeder Exhibit No. 2.
I shall read the short paragraph under Roman Numeral I:
"According to the Treaty of Versailles, the German Reich was neither to build nor to acquire U-boats. When in July, 1922, the firm N. V. Ingenieurs Kantoor Voor Scheepsbouw was established in the Hague, the Navy acquired an interest in it in order to keep informed on U-boat construction. The intention was to make use of the experience gained thereby in the German Navy, when later on conditions of the Treaty of Versailles would be annuled by negotiation, and Germany would be again permitted to build U-boats. Moreover, the navy wanted, for the same purpose, to train a small nucleus of skilled personnel."
Mr. Tribunal, I should like to point out at this point there is a translation mistake in the English copy. The word "Konstruktion" has been translated "construction", and construction means "Schiffsbau" in German. It was not a construction bureau. As far as I know "Konstruktion" must be translated "design". to set it right.
I quote:
"The first German U-boat was commissioned 29 June 1935. The program of parts to build U-boats had started correspondingly earlier." German-English fleet agreement was already in existence at that time. I will as. if this statement of Admiral Lohmann is correct.
A Yes. It corresponds with the facts.
Q Then I come to Prosecution document 441, U.S. 47. This is in document Book Raeder, document Book 10, on page 22 in the numbers of the British Delegati This is your letter of the 10th of February 1932 in regard to torpedo armament of the S-boats, the speed boats.
THE PRESIDENT: Is this in Document Book 10-A or 10?
DR. SIEMERS: Document Book 10. The old document bock.
THE PRESIDENT: My pages are wrongly marked somehow. It is all right.
DR. SIEMERS: Please excuse me. That is how the figures were given to me.
THE PRESIDENT: It is correct in the other members' books. BY DR. SIEMERS: Versailles treaty. For that reason, you are accused in this connection. Did this involve only the 5 speed boats mentioned in this document?
A Yes. There were 5 boats which we used as patrol boats in the ship replacement program which we had demanded in the program, which in themselves had no armament.
A. Not bigger than 40 tons, perhaps smaller.
Q Were more boats of this type built during the Versailles Treaty?
A I cannot say with Certainty. In any case, we had no armed boats in addition. Of course, what is what I mean. It was so that we had 12 plus 4, or 16. We Were allowed to build 16 torpedo boats. A torpedo boat of 200 tons could not be produced at that time because of the question of the motors and the question of navigability. For that reason, we did not build these torpedo boats. We kept a number of quite old torpedo beats from the beginning of the century. We kept them in the Service in order to be able to train crews with them. We could not fight with these boats any more. But during this time we could not replace these boats We wanted to have some small boats capable of action even if small, which if the Baltic was blocked off could be of use.
I ordered that these torpedo boats should be arranged for that purpose, should have torpedo tubes on board. In 32 when we hoped that at the disarmament Conference we might make some progress, in order not to have breaches of the Treaty to make our situation worse, I had one boat armed at a time in order to test out the armament, and then I had the armament dismounted again so that there was only one boat available with armament at any one time. control and political sistuation after the disamament conference would permit. were allowed to construct?
Q And instead, you built only 5 torpedo boats with 200 tons. In the last analysis then, if the accusation accused that you were not including these 5 torpedo boats, you Were not doing anything secret but you wanted to discuss it with the control commission at the proper time. Prosecution submitted, Document C. 32, U.S. 50. The document is in Document Book 10-A, Page XX 8; in the new document book of the British Delegation. This list includes all breaches dated 9 September 1933. The Prosecution justly points cut that this, confirmation is Very thorough. The Prosecution presented it just as thoroughly, although I believe I can prove that they are in the last analsis small matters; but I am forced to answer these accusations which were brought up in detail.
Branch Number 1: Exceeding the permitted number of mines, in Column 2 in the Versailles Treaty; and by the commission 1,565 mines were permitted, but we owned 3,675 mines. That is 2,000 mines too many. Please tell the Court what the significance of this is -- which is doubtless true. representative at the Disarmament Conference, so that if this thing should be mentioned he could give them an explanation. That is why it was so explicit, ever though most of the things it contains are of minor importance.
I should like to add to what I said previously as regards Poland. In view of the political situation at that time we had to fear that the Poles, if they should under take an invasion of cur country, would have certain support from the sea -- or could have Certain support from the sea, by France. Since ships at that time often visited the Polish port of Gdynia through the Baltic entrance, Baltic front, they could proceed against our ports. For this reason the defense of the Baltic entrances by mines played an important role. For this reason, we undertook this breach of the Treaty in order to be able at least to protect the Baltic -- blow the Baltic entrance at the narrow points; which was of course possible only for a Certain time. With these mines only a stretch of 27 sea miles could have been blocked. A part of Danzig or a part of the bolt could have been blocked. affective for any length of time. This only was a security defense, but still they exceeded the number of Mines permitted from the war supplies still available total amount which Germany had at that time, not just the amount which was exceeded that which was permitted?
Q And then I should like to have an approximate comparison. It was said, for comparison, that the British in the First World Tar in the North Sea laid about 450,000 to 500,000 mines. Do you recall if this number is approximately right?
AApproximately it may be right. I cannot say exactly from memory.
A second small question now. Is it true that the Luftwaffe Reichsmarsha Goering in mining English harbors in one action alone used thirty to fifty thousand mines? "Continuous storing of guns from the North Sea area for Baltic artillery batteries." smaller caliber.
What can you say about this breach of the treaty?
A This is quite a small breach. There were a comparatively large number of guns on the North Sea coast. On the other hand, the Baltic coast was comparatively bare of guns since we wanted to retain free entry to the Baltic for we had great interest in blocking off the Baltic. For this reason we laid gun barrels which belonged in the North Sea but which had been brought to the Baltic for repairs. We stored them in the Baltic area for a long time in order to be able to set up these guns on the Baltic coast in case of attack. The North Sea had many guns and it was much easier to defend than the Baltic coast. Baltic coast. guns are mentioned, the ten largest being 28 centimeters were actually destroyed.
Please comment on this. "Deutschland", six 20 dentimeter guns were constructed or for the "Deutschland" and the cruisers forty-eight 15 centimeter guns were constructed, and so forth. We then had to scrap a corresponding number of old guns. Ten of this number were actually scrapped. All the guns were turned ever to the army for scrapping and we received a receipt for them, saying that the guns had been scrapped. We learned, however, that the army had not in fact scrapped the guns. But aside from the ten 28 centimeter guns it used them for the army for fortifications to be built in case of attack since the army had no such guns at all.
Q I should like to make the time clear. This must have been a breach of the treaty which occurred long before the time you took office as chief of the navy command.
A This happened between 1919 and '25 for the most part. In any case I had nothing to do with those matters.
"Deviation from the places settled by the Entente for the disposition of coastal batteries." the middle sized batteries were placed very close to each other. In the batteries the guns were placed very close to each other. According to our experience from the World bar the heavy and medium sized guns Within the batteries were placed further apart so that a single hit would not destroy several guns at once. For this reason we loosened up these heavy and middle batteries and moved the guns a little further apart. For that reason they were no longer in the places they had been at the time of the treaty. Otherwise nothing was changed. because they were purely technical? artillery batteries and the storing of flak ammunition.
place then allowed by the Entente. Is the same thing true as to this as you said about number 4?
A No, not completely. We were glad to put the flak batteries, we wanted to put them where they were particularly useful and could be used, while the Commission did not want to have them at these places. As a result we left the flak batteries where they were but at other points we prepared socalled gun-platforms or provisional platforms so that in case of attack from any enemy we could set up the flak guns in order to use then most effectively. the foundations for a defense?
Q Then comes number six:
"Laying gun-platforms in the Kiel area." through to Kiel was to be as unarmed and unhampered as possible. For this reason the setting up of guns in the Kiel area was especially forbidden and in order to be able to set up some guns in a hurry in case of necessity gun platforms were prepared there also.
"Exceeding the calibre permitted for coastal batteries." accusation. of six 15 centimeter, three 17 centimeter guns were built. Of course, It is deviation insofar as the guns were to stay there but there can be some doubt raised whether these six 15 centimeter guns might not have been better along the coast than the three 17 centimeter guns; that they are numerically less than permitted. two centimeters.
Baltic and for the purpose of finding mines and as mine-blowing aids, which we wanted to lay at the entrance of the Baltic and which were to be controlled by them and defended against light enemy forces. For this reason we gave then each one 10.5 centimeter gun and one machine gun C-30.
Q The minimum armament in practice?
"Arming of six E-beats and eight motor mine-sweepers."
Number ten:
"Setting up practice flak batteries."
Is that a breach of the treaty?
A Yes, it was a flak battery. It was only because near the garrisons where there were barracks we wanted an opportunity for practice exercises. That is why we set up these batteries near barracks. There was no intention of using them in this place for defense. It was only a matter of expediency for training. Take 23. because I believe it is necessary, since the prosecution read almost all these items.
A Friedrichsort is the entrance to Kiel. If enemy ships enter they salute there; the salute must be answered. Two 7.7 centimeter field cans had been approved, which had been rendered unserviceable; one could shoot only with absolute cartridges. We considered it expedient, since there was a battery foundation available there, that instead of those 7.7 centimeter guns we set up four 8.8 centimeter flak guns.
THE PRESIDENT: The Tribunal will adjourn.
(The Tribunal adjourned until 16 May1946, at 1000 hours.)
THE MARSHAL OF THE COURT: If it please the Tribunal, the report is made that the Defendants Sauckel and von Papen are absent. follows: BY DR. SIEMERS: 32, and we had got as far as Point 11, We now come to 12, "Transgression or Infringements of the Permitted Amount of Ammunition," May I remind the Tribunal that this is the document, C-32, or US-50, which is in the document book 10-A, on page 8. We come to point 12, which contains three columns. exceeded the permissible amount of ammunition? mitted amount. I cannot now, today, tell you what the reasons were in any case, by I assume that to a very considerable extent this was due to the fact that there were excess amounts from the last World War. were excess amounts; whereas the third amount, 10.5 centimeter, appears to be short instead of 134,000 permitted there were 87 thousand. In the case of the 8.8 centimeter shells there were excess numbers. Then there were 8,600 allowed of the 6 centimeter, but instead only an actual number of 3,600, and the same situation applying to the last item.
In the third column there appears to be some explanation regarding this. On the following page it says that amounts of ammunition were partly being manufactured and partly under delivery and that the total amount permissible will soon be exceeded.
stated September 1933. According to these figures, it would have been compiled according to the situation in the autumn of 1933, wouldn't it?
A I didn't quite understand you, I am afraid. figures which were permissible had been exceeded, then whereas in accordance wit this statement they were short, then this must apply to the situation in autumn 1933. ammunition had to be scrapped. It also must be noted that ammunition for heavy artillery which is not listed here was in every case short of the standards. We had a comparatively large amount of heavy artillery and ammunition for heavy coastal guns which had been granted us.
We hadn't as much as we could have had.
DR. SIEMERS: For the assistance of the Tribunal I want to point out that to this last point is proved by the actual documents in the hands of the Tribunal. I am referring to figure 12 on page 2 and the paragraph immediately after the figures. It says that the ammunition for heavy artillery has not been included.
Q We now come to figure 13, "Exceeding the number of machine guns, etc., rifles, pistols and respirators." just slightly higher than permitted. This was greatest, for instance, in gasmasks, showing 43,000 actual instead of 22,500 permitted. There were large quantities of machine-guns after the World War which had been put away by individual persons. They had been hidden in farms and so forth. Later on, they were once more collected and by reason of that there was a comparatively large accumulation of them. But nowhere here are we concerned with any considerable figures. And the same applies to ammunition, bayonets, hand-grenades, search-lights and such like. Anyway they are not considerable amounts.
Q Now, figure 14, "Obtaining 337 m/g C/30 without scrapping equally serviceable weapons" -
THE PRESIDENT: Surely, Dr. Siemers, it would be possible to deal with all these various points in the documents in one statement, as to why there were these excesses. We have a statement here which contains thirty different items, and you have only gotten as far as 13 -- and you are dealing with each one.
DR. SIEMERS: Mr. President, personally I am most agreeable to stopping talking about the document. As I am not a naval expert, I had a great deal of trouble finding my way through it, but I don't think that I was the cause of this. The Prosecution, you see, have submitted every individual point -
THE PRESIDENT: Dr. Siemers, the question is, I am not blaming you, but we want to get on. We are not blaming you. Can't it be done in one explanatory ststement. one short statement?
DR. SIEMERS: I shall try, Mr. President, and I shall abbreviate it.
BY DR. SIEMERS:
Well, they are the most important points. They were points which were planned for the most important years; they applied to the years '33 to '34. intended construction of reserve destroyers and that construction was permitted through the Versailles Treaty.
I'll skip 18 because we've dealt with that. Nineteen, once more, only intended construction. Figure 20, I may consider it irrelevant. It's the arming of fishing vessels. Figure 21 to 29 -
THE PRESIDENT: I think, perhaps, you should ask the defendant to explain some of these remarks in the third column. I mean in 18, for instance, "Difficult to detect. If necessary can be denied." at the disarmament conference on his way by the expert in question. It doesn't refer to the local conditions. Construction of U-boat parts, for instance, took place abroad or was to be prepared, and in 1934 and '35 it took place. The first submarine was launched at the end of June of 1935.
Q May I ascertain, Mr. Witness, that only the construction and purchase of submarines was prohibited? agreements in the case of the spare part or parts, but I think that you ought to point out just why at that time, and in spite of the fact that spare parts were permissible, one intended to conceal this. May I remind you that this is September, '33, at a time when negotiations were planned. regarding the negotiations 35 to 100, Himmler was particularly anxious to avoid everything which might in any way interfere with the negotiations. Since the subject of submarines was a particularly delicate one in England, it was part of this plan to treat the construction of U-boat parts in that manner.
Q Wasn't this appendix and several other remarks in this column due to the unfortunate experience which the navy had made politically in the country; namely, that every time when the smallest action was taken there was an immediate inner political row about it?