My Lord, the state of a man's mind and the expression of his knowledge may be a fact in certain circumstances just as much as it is a fact, as it is stated, as Lord Broyne once put it.
THE PRESIDENT: Yes, if the state of his knowledge is directly relevant to an issue.
SIR DAVID MAXWELL FYFE: Yes, my Lord, that is the point here.
THE PRESIDENT: It is a form of export evidence.
SIR DAVID MAXWELL FYFE: My Lord, in a sense, it is not as your Lordship says in a form, it is not in a usual form, but it is the evidence of somebody who has special knowledge. My Lord, it is a well-known distinction, for example, in the laws of LIBEL between the persons who have expert knowledge and the public at large and, my Lord, the opinion of someone with a special knowledge of the facts must, my Lord, have probative value within Article 19 of the Charter. My Lord, if the provision is that this Tribunal is not bound by the technical rules of evidence as to mean anything at all, I submit it should cover the expression of opinion on a point such as this; that is, the ability to have knowledge, which is given by somebody who is in a special position to state such an opinion.
THE PRESIDENT: It is a very small point, Sir David, and we have to decide the matter and form our own opinion about it, and this man isn't here for the purpose of being cross-examined for anything of that sort.
SIR DAVID MAXWELL FYFE: No, that is so my Lord but, of course that, with respect, cuts both ways. Here he gives an affidavit and part of it as the basis, leads up to that conclusion. I should respectfully submit that that conclusion is a statement of fact --- but, if your Lordship says so, the time will come when we can ask your Lordship to draw that conclusion as a matter of argument ourselves but, my Lord, on the general position, the only reason that I have occupied even this much of the Tribunal's time is that Article 19 is an important matter in view of the prosecution and, therefore, we have to argue against it being whittled down.
It is the only reason that I take up the Tribunal's time.
DR. SIEMERS: Mr. President, may I just draw your attention to one point. Sir David has just been mentioning the well-known legal difference. That is just what I want to make my argument on, the differen ce between fats and opinions. Here opinion is mentioned and please note that the following sentence does even go further there; there, the witness is coming to a legal opinion and he is stating who is responsible; therefore, he is passing some sort of judgment. Furthermore, please, will you consider that this is quite a minor official who, after all, can't possibly make such far-reaching statements, saying that higher formations in Kiel and some other places, quite generally expressed in Germany, had knowledge of something or other.
THE PRESIDENT: The Tribunal will adjourn.
SIR DAVID MAXWELL FYFE: My Lord, before the Tribunal adjourn, might I make a correction and an apology? My Lord, I thought that a copy in German had been put to the witness yesterday, of this affidavit and apparently it was a copy in English. The original affidavit was sent off on the 6th of May; it was verified over the telephone by Colonel Phillimore and it has not yet arrived; an English copy was sent and has been processed and the original will be put in as soon as it arrives. My Lord, I thought we had the original but apparently it has not yet arrived, but it is an English document put to the defendant.
THE PRESIDENT: Will you let Dr. Siemers see the original as soon as it arrives?
SIR DAVID MAXWELL FYFE: Yes.
(A recess was taken.)
THE PRESIDENT: The Tribunal has carefully considered Dr. Siemers' application and it has decided that the passage to which he objects and which he asks the Tribunal to strike out in the affidavit of Walter Kurt Dietmann shell not be struck out, in view of Article 19 of the Charter.
The passage contains an opinion only, and the Tribunal will consider that opinion in relation to the whole of the evidence when it is before the Tribunal, and will decide at that time the probative value of this opinion as well as the probative value of the other evidence.
Dr. Siemers, may I remind you that you told us your re-examination would take, you hoped, about half an hour?
DR. SIEMERS: Yes, Mr. President, I shall conclude very shortly. BY DR. SIEMERS: discussed a good deal, yesterday Sir David put a case to you regarding the attack on the ship Tirpitz. In this connection I should like to ask you: Do you recall that in this particular a point was raised in the testimony of Wagner about the British sailor Evans? number 64, GB-57, Flesch declared: "I do not know that Evans were a uniform"?
Q Then I do not need to submit the document to you?
A No, I don't need it. the same day during Wagner's testimony, he says: "The British sailor Evans was captured wearing civilian clothing"? committed a murder without the knowledge of the Navy?
A Yes. This man had been apprehended by the SD or the Police, not by the Navy. He had been interrogated by the admiralty in the meantime. Bordeaux. I clarified this situation in Wagner's testimony the other day. to escape to Spain.
A Yes, that is true.
discussed yesterday, and when this group was led by Vice Admiral Heye, did our soldiers ever appear in civilian clothing?
Q Always in uniform?
A Yes, always in uniform. They were soldiers and they were used along with submarines and other craft like that.
DR. SIEMERS: As my last point, Mr. President, I should like to point out that yesterday Colonel Pokrovsky submitted a document, USSR 460, which deals with the Moscow declaration.
COLONEL POKROVSKY: My Lord, the point is that yesterday the Tribunal made a decision about submitting to the attorney for the defense extracts from USSR 460. Today the prosecutors have exchanged opinions amongst themselves; and the prosecution of the United States, represented by Mr. Dodd, Sir David Maxwell Fyfe for Great Britain, and myself for Russia, have agreed that it is necessary for us to request you to permit us to read into the record here today, so that it will be included in the record for today, several brief extracts referring to Admiral Doenitz, to Keitel, and to Jodl. These are the excerpts which, yesterday, the Tribunal did not find possible to have read into the record as evidence. We understood the Tribunal in such a manner as to interpret that as being occasioned by lack of time to consider it thoroughly. read into the record today. The excerpts referred to yesterday by the defendant have hot been included in yesterday's minutes. For that reason I am requesting just about five minutes' time to read these excerpts into the record today, on behalf of the prosecution of the three countries.
THE PRESIDENT: What would be the most convenient course, Dr. Siemers? Would you like to have them read now so that you can put any questions upon them?
DR. SIEMERS: Mr. President, may I just make this remark? The Soviet Delegation has been kind enough to put the original at my disposal. I perused the original yesterday, and I looked at the excerpts and extracts. The Soviet delegation has also been kind enough to put a photostatic copy of the extracts involved at the disposal of the High Tribunal. I am completely in agreement with the suggestion, but I personally do not have the intention of putting any questions on this document.
THE PRESIDENT: Very well.
DR. SIEMERS: I would like to ask that the resolution which was put forth by the High Tribunal yesterday be upheld, that this not be read, the same procedure which has been applied to other documents of the same type which were not read either.
THE PRESIDENT: Colonel Pokrovsky, the document was originally in German. Presumably it has been translated into Russian; it has certainly been translated into English.
Unless the members of the French Prosecution want it read, if it hasn't been translated into French there doesn't seem to be any use taking up the time of the Tribunal in reading it into the record, e have got the document in English, and we have all read it.
MR. DODD: Mr. President. I think there is one reason. Even if it read into the record, it will at least be tomorrow before the transcript is available for the defendants who are referred to, and this witness, or this defendant, will be off the stand. If they want to cross-examine about what he has said about them, then we will, I suppose, have to bring this defendant back on the stand. I think we will lose far more time by doing that, rather than now having Colonel Pokrovsky take five minutes to read it. They will all hear it, and then if they want to examine about it, they can do so promptly.
THE PRESIDENT: Very well.
DR. SIEMERS: If you don't wish to ask any questions about it, you can conclude your re-examination, and then Colonel Pokrovsky can read the document, Then any of the other defendants can question the witness upon it if they wish t
DR. SIEMERS: Yes.
THE PRESIDENT: Would that not be the best way, Colonel Pokrovsky?
COLONEL POKROVSKY: Yes.
DR. SIEMERS: I am agreed, Mr. President, but I do believe that this document need not be read, because Mr. Dodd was a little bit incorrect when he said that the defendants are not familiar with this document. They are thoroughly familiar with it. I believe everyone knows it, and I do not think that it needs to be read. However, in the final analysis, it really makes very little difference to me personally.
THE PRESIDENT: If the defendants' counsel do not want i t read then the Tribunal does not want et have it read unless defendants' counsel want to ask questions upon it.
DR. KRANZBUEHLER: Mr. President, I am not interested in having the document read. I know the document.
DR. SIEMERS: I have just been advised that the defense attorneys know the document, do not put any value on having it read and do not wish to put any questions.
THE PRESIDENT: Well then, Mr. Dodd and Colonel Pokrovsky, it does not seem that it serves any useful purpose to have it read.
MR. DODD: No, I am satisfied your Honor. I have not heard from Keitel's attorney; I assume he is satisfied. I am just concerned that at some later date -- a very interesting document to us, of course I am just concerned some question may be raised and I am also sympathetic to the desire of these defendants not to have it read publicly.
The defendant Schacht's counsel has not spoken either. I think it might be well,Mr. President, if we had a careful statement from counsel for each of these men that they do not wish to question on it so that we
THE PRESIDENT: Well, I think the defendants' counsel are all here or all the defendants are represented and they must clearly understand what I am saying and I take it from their silence that they acquiesce in what Dr. Siemer's has said, that they do not wish the document to be read and they do not wish to ask any questions.
COLONEL POKROVSKY: I have not understood your decision, my Lord. Are you permitting me to read these few excerpts or are you not?
THE PRESIDENT: No, Colonel Pokrovsky. I am saying as the defendants' counsel do not wish to document to be read it need not be read.
COLONEL POKROVSKY: We do give a great deal of importance and significance to this document as it involves not only the interests of the defense but also the interests of the Prosecution. reason only a very short part of it was included in the stenographic record for the day and it seems to me that the defense today have reasons not to have it read publicly, especially the defense counsel for Keitel, Jodl and Raeder.
It appears to me that our interests are quite at stake there, I mean that we have it included in the stenographic records.
THE PRESIDENT: Colonel Pokrovsky and Dr. Siemers, the Tribunal has ruled yesterday that it was unnecessary that the document should be read and the Tribunal adheres to that decision in view of the fact that the defendants' counsel do not wish it to be read and have no questions to put upon.
Yes, Dr. Siemers.
DR. SIEMERS: Mr. President, I will now conclude my examination of Grand Admiral Raeder. I do not know whether other questions will be put to Grand Admiral Raeder.
THE PRESIDENT: Is there any question which has arisen out of the cross-examination which the defendants' counsel want to put?
DR. KRANZBUEHLER: I should like to put two questions, Mr. President. BY DR. KRANZBUEHLER: orders and memoranda as to the U-boat warfare. with the U-boat warfare which during your term as commander-in-chief of the navy were issued and which you issued? decrees issued as to the U-boat warfare which took place under my responsibility as well as every naval operation which I ordered.
In the S.K.L. and with the officers of the S.K.L. I worked out these directives, I approved memoranda and in accordance therewith put forth my decrees. The commander-in-chief of the U-boats was solely the tactical commander of the U-boats. He transmitted the orders and he led and carried through the operations. he could not determine who actually gave the orders that the log book of the U-boat that sank the "Athenia" was to be changed.
Admiral Godt testified in answer to my question that he had issued this order at the request of Admiral Doenitz. Do you know of any fact which would show this testimony of Admiral Godt to be incorrect?
A No, I did not concern myself with this case. I only decreed the three points which have been mentioned repeatedly.
Q Therefore, you consider Admiral Godt's testimony as being correct? very reliable.
DR. KRANZBUEHLER: I have no further questions, your Honor.
THE PRESIDENT: The defendant can return to the dock.
DR. SIEMERS: Then, with the permission of the High Tribunal I should like to call my first witness, the former Reich Minister of the Interior, Severing. as follows: BY THE PRESIDENT:
Q Will you state your full name?
A Karl Severing. I am 70 years old and I live in Bielefeld.
Q Wait one minute. Will you repeat this oath after me. pure truth and will withhold and add nothing.
(Witness repeated oath.)
THE PRESIDENT: You may sit down. BY DR. SIEMERS:
Q Mr. Minister, please tell the High Tribunal what role you played up until the year 1933 in the Social Democratic Party and which ministerial posts were yours up until the year 1933. union movement and when I was eighteen years I entered the Social Democratic Party and as a result of that I was active and had honory positions at a relatively early age.
In the year 1905 I was counsellor in the City of Bielefeld. I belonged to the Reichstag from the year 1907 up until the year 1912 and I became a member of the Reichstag once more and a member of the Prussian Diet in the year 1919. I was in the Reichstag and in the Prussian Diet until the year 1933. I was Minister from the year 1920 until 1921, that is Minister of Prussia; then again from 1921 to 1926; from 1930 until 1933. Then in the meantime from the year 1928 until 1930 Minister of the Interior for the Reich.
Q When and why did you leave public life?
A From official public life I took my departure in July of 1932; from political life at the time in Which there was prohibition against the Social Democratic Party. a later date, were you arrested and, if so, at whose order? the Reichstag. This order for my arrest was signed by the then Minister of the Interior, Mr. Goering, who at that time was also president of the Reichstag and, if I may utter an opinion, who would have had the obligation, as president of the Reichstag, to protect the immunity of the members of the Reichstag. Under the breach of this immunity I was arrested at the moment at which I entered the Reichstag building.
Q Mr. Minister, but you participated in the vote on the Enabling Act? against the treatment which was accorded me, had complained to Goering, but this complaint had only the outcome that at the time of the vote I was not permitted to take replies. Then the Reichstag President Goering permitted me to say no as my vote for the Enabling Act?
Q You were arrested but briefly? I was permitted to leave Berlin on the second day and had the instruction to be ready at my home in Bielefeld for further interrogations.
Q Mr. Minister, despite your well-known anti-Nazi position, you were not arrested later and put in a concentration camp -- that is as far as I know' and I say this with all modesty -- of the respect which the old Prussian officials had for me. At the end of October of 1933 I heard from the Police Chief in Bielefeld that something was in the wind against me. The Police Administrator advised me that they would not be in a position to give me any protection and they advised mo, therefore, to leave Bielefeld for several months. I followed this advice that they gave me from October, '33 until the end of March, '34, I lived in Berlin. I used a false name. First of all I stayed with friends; then I was in a small Jewish sanitorium in Wansee.
Then in August of the year 1944 there was a further arrest imminent. The list of those who were to be arrested summarily -- that is the list of those men and women who were suspicioned of having plotted against Hitler in July, 1944, my name was on that list. One of my friends -
THE PRESIDENT: Did you say '44 or '34?
DR. SIEMERS: '44. After the attempted assasination of Hitler of July, 1944.
THE WITNESS: May I continue? BY DR. SIEMERS: given to the police which ordered certain people to be arrested. On this list issued in Bielefeld my name was to be found. Then one of the officials whom I knew from the past pointed out that I was close to my seventieth year of life and had lost my son in the war. By pointing out this fact, that I was almost seventy and that I had lost a son, he succeeded in crossing my name from the list. National Socialists damage you or did you derive any detrimental effect from them? movements. I wasnot especially surprised that the postal service and the telephones were under control. I considered that asa matter of course. But I could not even take a trip without being followed and watched by the police. Mr. Minister, I should like to call your attention to the fact that I had material damage but besides that I had ideal damages, and those I received at the hands of the National Socialist Party after they assumed power I had many disadvantages that way. A political measure, which originated in the year 1932, was used against me, and I might say it was used against me in a criminal way. They talked about me as the "thief of millions", and this epithet was applied to my family and the members of my family.
THE PRESIDENT: Dr. Siemers, is this witness going to rive any evidence which has relevancy to the Defendant's case?
DR. SIEMERS: Yes.
THE PRESIDENT: Well, bring him to it then as soon as possible.
DR. SIEMERS: Very well. BY DR. SIEMERS:
Q Mr. Minister, try to be as brief as possible in this connection. It is of course true that you had ideal damages as well, but as the basis of my examination and your testimony I would like to ascertain whether there were tremendous damages which accrued to you and I would like to have you tell us, but briefly, whether National Socialism -
THE PRESIDENT: Dr. Siemers, what relevancy has that got to Raeder's case?
DR. SIEMERS: Mr. President, I should like to marshal my questions to this point, that through a brief description of the life of the Minister, as shown during National Socialist times, that he can answer the questions which deal with Raeder; that he can give objective answers about Raeder for, first of all, he had no advantages but rather disadvantages from the Nazis.
THE PRESIDENT: You have dealt sufficiently with the disadvantages now. Go to the matters which relate to Raeder. He has given us, from 1933 to 1944, a fairly general account of his life and that ought to be sufficient.
DR. SIEMERS: The prosecution accuses the Defendant Raeder, that in his capacity as Commander in Chief of the Navy he violated the Treaty of Versailles, specifically, with the intention of carrying on aggressive wars, and also, to do with behind the back of the Reich government. In order to shorten the proceedings and the testimony, I would just like to mention that this is a fact; we do not dispute this fact. It is a matter of history that Germany, in the development of her Navy, acted against the stipulations of the Versailles Treaty. These facts are known to the Tribunal. Even before this deadline, the then government decreed that an armored cruiser was to be constructed. About the construction of this cruiser there was a political debate, and in a debate before the Reichstag dealing with this cruiser the witness gave a speech. I have a brief excerpt from this speech which I should like to submit to you and which I should like to read. Mr. President, this is Raeder Exhibit No. 5, to be found in Document Book I, Page 13. This is an extract from a speech by the Reichsminister Karl Severing to the German Reichstag on the 20th of January, 1928.
BY DR. SIEMERS:
Q Mr. Minister, at this period of time you were not a minister. Rather, you gave this speech as a member of the Reichstag?
Q The extract reads: "Now the armored cruiser. The fact that a government, which knows precisely what gigantic sums we must raise during the coming year, should make such demands, is, to say the least, very remarkable. It says, the Peace Treaty permits it -- yes, but the Peace Treaty also decrees the payment of reparations. The 93 million marks demanded for this year will play their decisive part only in their consequences and those consequences require several hundred million marks to raise, which during the next few years seems to me absolutely impossible. Considering the development of weapons for naval warfare, I am unconvinced also of the military value of armored cruisers. It may be that armored cruisers are the backbone of the defense at sea, as the government says. But, to form an active fighting unit, (Gefechtskoerper) a backbone must also be made up of other members, of U-boats and airplanes, and as long as we are not allowed to build these, armored cruisers are of very little value even for defence." Is that extract from the speech correct?
Q Can you gather here that the Social Democrats and you, per-
sonally, at that time were ofthe opinion that the Wehrmacht which was granted Germany according to the Versailles Treaty might not be used for a defensive war because it was not large enough? was not to be used for a defensive war everyone knew and everyone in Germany knows that today who was concerned with political things. It was a very bad situation that obtained for Germany, especially since the establishment of the corridor, and the position which was very bad, in her relation to her eastern neighbor. The insular position of East Prussia even at that time forced Germany to take measures which I saw and carried through with disagreement; but the population of East Prussia had a right to be protected against attacks which were threatening from the east. I'm not speaking about an aggressive war and. I'm not speaking of theplans of the Polish Government, but I would like to refer you to the fact that in the years 1919, 1920 and 1921, there were groups in Poland who wanted to attack. They set foot on the German soil and possibly with the idea of
THE PRESIDENT: This evidence is all a matter of argument. Not only is it a matter of argument, but we have had it over and over again from nearly all the defendants and a good many of their witnesses and, surely, it is not assisting the Tribunal in the very least to know what this witness said in 1928 or what view he took in 1928.
DR. SIEMERS: May it please the High Tribunal, I believe in the course of the testimony it will be shown that Minister Severing is a member of that government, a cabinet member of the 28th, and the government was carried through this cabinet andits meeting. I agree with the opinion of the High Tribunal that thesematters have been heard very frequently, but I should like to point out that Sir David even yesterday in cross-examination accused, the defendant that, against the will of the Reich Government and against the wish of the organizations and despite the testimony of Raeder, he violated the Treaty of Versailles. Then, if after the testimony of Raeder, the Prosecution persists in their opinion, I have no other possibility to correct the inaptitude of the opinion of the Prosecution.
The only way I have to do that is throughthe question ing of the witness.
THE PRESIDENT: The question that the Treaty of Versailles was violated is a question of fact and, of course, upon that you can give evidence and you did give evidence through the defendant Raeder; but this witness is not talking about the question of fact. He is arguing that Germany was entitled to defend herself in violation of the Treaty of Versailles. That is what I understood his evidence to be and that is a question of argument, not a question of fact.
DR. SIEMERS: Mr. President, as far as I know -
THE PRESIDENT: Dr. Siemers, the class of evidence which has just been given by this witness will not be listened to by this Tribunal. If you want to prove facts by him, you can prove them, but you cannot prove arguments or his views upon arguments. BY DR. SIEMERS: attack in Silesia and Poland? East Prussia; therefore, it was necessary to protect the population of East Prussia, and this was brought about in that I, personally, give my voice and agreed that all weapons which were found in East Prussia were to be given to the population. Under conditions with applied at that time, even for purposes of inspection, it was very hard to pass through the corridor even by rail; so that in the year 1920, I had to make a tour of inspection by way of water rather than land. I am mentioning this fact to show the difficulties of transportation through the corridor. I want to show the difficulty. In the years 1920 and '21, it wasnot possible for theGerman Wehrmacht to prevent attacks of Polish insurgents in Upper Silesia and, I am sorry to say, and I emphasize "I am sorry", that a certain self defense had to be created in order to protect and defend German life and German property.
Q Mr. Minister, Reichswehr Minister Groener, beginning with January, 1920, were the peasures which he wanted applying to armament based, as far as you know, on defensive or offensive basis?
everything that he did and carried through was based on the thought of defense.
Q This also applies to the armored cruiser. I should like to know why the Social Democratic Party, who was interested in the idea of defense, was against the building of this armored cruiser.
building of the armored cruiser for the economic situation did not warrant the making of any expenses which were not absolutely necessary. And the Social Democratic Party wanted to prove and to show that they could do everything within their power and they wanted to realize disarmament. They did not believe that the building of an armored cruiser would be a good gesture for the bringing about of negotiations.
Q Mr. Minister, on the 28th of June, 1928, a new Reich Government was formed. Moeller was chancellor; Stresemann was froeign minister, and you were minister of the interior. What position did your government take to the problem about disarmament stipulated in Versailles, disarmament by all countries as vs. the armament of Germany?
A I have already touched and assorted this problem. In the Social Democratic Party and after the entry of Moeller into the government, we were of the opinion that we would have to use all our efforts in order to solve just this problem. In September of 1928 the French Chancellor Moeller, as deputy of the Foreign Minister Stresemann, who was ill, went to Geneva in order to bring this problem before the League of Nations meeting. Moeller gave a very definite and firm speech which, if I remember correctly, was received very cooly by allied statesmen; so that any practical suggestion for the realization of disarmament could not be hoped for.
Q Mr. Minister, in July, 1928, you spoke with Reich Defense Minister Groener about the buget and, specifically, about the fact that there were secret budgets and knowledge which had gone through the Wehrmacht about this dealing with the armored cruiser and so forth. What attitude did you take in this connection and what results came about on the basis of your agreement with Greece? extract from my speech, which you just submitted to the High Tribunal. In the same Reichstag session in which I gave this speech, Groener appeared for the first time as successor of Gossler. I had, as far as Gossler was concerned, given a few farewell words to him. I greeted the now minister with the remark that my political friends would show him respect, but that he would have to deem our confidence first, and on the basis of this remark Groener most likely replied to these remarks. When in the first session of Moeller's Government he approached me and said that he was looking forward to a collaboration with me, on that occasion I quoted a passage from Schiller's works, but between us there was to be truth and only on the basis of this truth and clarity it would be possible to bring about a working together on a collaboration.
THE PRESIDENT: Dr. Siemers, the Tribunal thinks that this is an absolute waste of time and this speech of the witness is entirely irrelevant. Why do you not ask him some questions which have some bearing on the case of Raeder?
DR. SIEMERS: Mr. President, may I remind you that it is an accusation on the part of the Prosecution that the rebuilding took place by using a secret budget and that a rearmament was carried on with the idea of carrying on wars of aggression later on. It is not quite clear to me how I can cross-examine him otherwise than what I am doing to show how in his government these secret budgets, which are practically identical with violations of the Versailles Treaty, how those secret matters were dealt with and that is the point on which I just questioned the witness.
THE PRESIDENT: This speech that you have drawn our attention to is simply a speech in which he said that he did not think that armored cruisers were of any use.
That is the only meaning of the speech, except, insofar as it refers to the fact that reparations had not been paid. For the rest it simply says that armored cruisers, in his opinion, are of no use.
DR. SIEMERS: Mr. President, I do not wish to plead my case. In the speech which I read something else is said. It says there that for economic reasons, the Social Democratic Party was against the building of this armored cruiser, not because of strategic reasons.
THE PRESIDENT: That would have nothing to do with a charge of making an aggressive war in 1939.
DR. SIEMERS: Mr. President, I did not raise the accusation of an aggressive war; the Prosecution did that, but I have to protect my client against the fact that in 1928 he hadintentions of carrying on an aggressive war, and I assert that he had no intention of that sort and that the Reich Government knew about the violations of the Treaty, that the Reich Government took the responsibility for that, and the testimony of the Minister will show that these are actual facts.
THE PRESIDENT: Ask him some direct questions on issues of fact. Then the Tribunal will listen to them if they are relevant, but the Tribunal considers that the evidence of his speech that you have been dealing with is an utter waste of time.
DR. SIEMERS: I shall try to be brief. BY DR. SIEMERS:
Q Mr. Minister, I will put single questions to you. Please answer them.
You said that you demanded of Groener confidence and truthfulness. In this connection, did you ask for a clarification of the secret budget and violations of the Treaty of Versailles which had taken place up to that time? Reichsminister Marx had agreed that under the leadership of Captain Lohmann in the Navy Department there had been a concealment of the budget, and that could not be in accordance with political decency, political sincerity or good bookkeeping.
Q What did Groener reply?