Archive/File: imt/tgmwc/tgmwc-01/tgmwc-01-06.04 Last-Modified: 1999/09/04 [Page 181] If the Tribunal please, at this moment I have a new problem about proof which I believe we have not discussed. I have in my hand an English transcription of an interrogation of the defendant Erich Raeder. Of course, he knows he was interrogated; he knows what be said. I do not believe we have furnished copies of this interrogation to defendant's counsel. I don't know whether under the circumstances I am at liberty to read from it or not. If I do read from it I suggest that the defendant's counsel will all get the complete text of it - I mean of what I read in the transcript. THE PRESIDENT: Has the counsel for the defendant Raeder any objection to this interrogation being read? DOCTOR SIEMERS (Counsel for defendant Raeder): As far as I have understood the proceedings to date, I believe that it is a question of procedure in which either proof by way of documents or proof by way of witnesses will be furnished. I am surprised that the prosecution wishes to furnish proof by way of records of interrogations taken at a time when the defence was not present. I should be obliged to the Court if I were told whether, in principle, I, as a defence counsel, may resort to producing evidence in this form, i.e., present documents of the interrogation of witnesses, that is to say, documents in which I myself interrogated witnesses, in the same way as the prosecution has done, without putting witnesses on the stand. THE PRESIDENT: In future the Tribunal thinks that if interrogations of defendants are to be used, copies of such interrogations should be furnished to defendant's counsel beforehand. The question which the Tribunal wished to ask you was whether on this occasion you objected to this interrogation being used without such a copy having been furnished to you. With regard to your observation as to your own rights with reference to interrogating your defendant, the Tribunal considers that you must call them as witnesses upon the witness stand, and cannot interrogate them and put in the interrogations. The question for you now is whether you object to this interrogation being laid before the Tribunal at this stage. DR. SIFMERS: I should like first of all to have an opportunity to see this document. Only then shall I be able to decide whether interrogations can be read, the contents of which I as a defence counsellor am not familiar with. THE PRESIDENT: The Tribunal will adjourn now and it anticipates that the interrogation can be handed to you during the adjournment and then can be used afterwards. (A recess was taken until 1400 hours.) MR. JACKSON: May it please the Tribunal. I should like to ask the Tribunal to note the presence and appearance on behalf of the Union of Soviet Socialist Republics of Mr. A. I. Vijshinsky of the Foreign Office, and Mr. K. P. Gorshenin, Chief Prosecutor of the Soviet Republic, who has been able to join us in the prosecution only now. THE PRESIDENT: The Tribunal notes what Mr. Justice Jackson has said, and observes that Mr. Vijshinsky has taken his seat with the Soviet Delegation of Chief Prosecutors. DR. SIEMERS: In the meanwhile during the lunch hour I have seen the minutes. I should like to observe that I don't think it is very agreeable that the prosecution should stick to their point that the defence should not see the documents until late during the proceedings, or just before the proceedings, or at times even after the proceedings. I should be most grateful to tire prosecution if it should be made possible in the future to let us be informed in good time. Yesterday a list of the documents which were to be presented to-day was put up in room, No. 54. I find that the documents presented to-day are not [Page 195] included in yesterday's list. You will understand that the task of the defence is thereby rendered comparatively difficult. On principle I cannot, in my statement of to-day, give my agreement to the reading of minutes of interrogations. In order to facilitate matters, I should like to follow the Court's suggestion, and declare my agreement that the minutes presented here should be read. I request, however - and I believe I have already been assured by the prosecution, to that effect - that only that part be read which refers to document C-156, as I had no time to discuss the remaining points with the defendant. As to the remaining points, five other documents are cited. Moreover, I request that the part which refers to the book by Kapitan zur See Schuessler, should be read in full, and I believe that the prosecutor agrees with this. THE PRESIDENT: I understood from the counsel for Raeder that you were substantially in agreement as to what parts of this interrogation you should read. Is that right, Mr. Alderman? MR. ALDERMAN: If I understand the counsel correctly, he asked that I read the entire part of the interrogation which applies to the document C-156, but I understood that he did not agree to my reading other parts that referred to other documents. I handed counsel the original of my copy of the interrogation before the lunch hour, and when he returned it after the lunch hour, I handed him the carbon copy. I do not quite understand his statement about a document being introduced which hadn't been furnished to the defendant. We did file the document book. THE PRESIDENT Is this document in the document book? MR. ALDERMAN My understandings that the document book contained all of the document which is stated in this interrogation. It didn't contain the interrogation. THE PRESIDENT Then he is right to say that. MR. ALDERMAN He is right in saying that about this interrogation, yes. THE PRESIDENT You are in agreement with him then. You can read what you want to read now, and it is not necessary for you to read that part to which he objects. MR. ALDERMAN: I think I understand his objection to my reading anything other than the part concerned with C-156, but I anticipate that be may be willing for me to read the other parts tomorrow. This deals with the book which I offered in evidence this morning, document C-156, exhibit USA 41. The defendant Raeder identified that book, and explained that the Navy had to fulfil the letter of the Versailles Treaty, and at the same time make progress in Naval development. I refer to the interrogation of the defendant Raeder at the part we had under discussion:- Q. I have here a document, C-156, which is a photostatic copy of a work prepared by the High Command of the Navy, and covers the struggle of the Navy against the Versailles Treaty from 1919 to 1935-. I ask you initially whether you are familiar with the work? A. I know this book. I read it once when it was published. Q. Was that an official publication of the German Navy? A. This Captain Schuessler (indicating the author) was a Commander in the Admiralty. Published by the O.K.M., this book represented an idea of this officer to co- ordinate all those matters. Q. Do you recall the circumstances under which the authorisation to prepare such a work was given to him? A. I think he told me that he would write such a book as he says here in the foreword. Q. And in the preparation of this work he had access to the official Navy files and based his work on the items contained therein? A. Yes, I think so. He would have spoken with other persons, and he would have had the files which were necessary. [Page 196] Q. Do you know whether before the work was published, a draft of it was circulated among the officers in the Admiralty for comment? A. No, I don't think so. Not before it was published. I saw it only when it was published. Q. Was it circulated freely after its publication? A. It was a secret subject, I think all Higher Commands in the Navy had knowledge of it. Q. It was not circulated outside of Navy circles? A. No. Q. What then is your opinion concerning the comments contained in the work regarding the circumventing of the provisions of Versailles? A. I don't remember very exactly what is in here. I can only remember that the Navy had always the object to fulfil the word of the Versailles Treaty, but, in order to obtain some advantages, the flying men were trained one year before they went into the Navy. Quite young men. So that the word of the Treaty of Versailles was fulfilled. They did not belong to the Navy, as long as they were trained in flying, and the submarines were developed, not in Germany, and not in the Navy, but in Holland. There was a Civil Bureau, and in Spain there was an Industrial Bureau; in Finland, too, and they were built only much later, when we began to act with the English Government about the Treaty of thirty-five to one hundred, because we could see that then the Treaty of Versailles would be destroyed by such a Treaty with England, and so in order to keep the word of Versailles, we tried to fulfil the word of Versailles, but we tried to gain advantages. Q. Would a fair statement be that the Navy High Command was interested in avoiding the limiting provisions of the Treaty of Versailles regarding personnel and the limitation of armaments, but would it attempt to fulfil the letter of the Treaty, although actually avoiding it? A. That was their endeavour. MR. ALDERMAN: Now the rest of this is the portion that the counsel for the defendant asked me to read. Q. Why was such a policy adopted? A. After the first war we were sorely menaced by the danger that the Poles might attack East Prussia, and we therefore tried to strengthen a little our very, very weak combat forces in this way; consequently all our efforts were directed to the aim of having a little more strength against the Poles should they attack us. It is nonsense to think we could have attacked Poland at this stage-and with the Navy. A second aim was to achieve a certain degree of defence against the possible entry of French forces into the Ostsee (East Sea), since we knew that the French intended coming to the aid of the Poles. Their ships entered the Ostsee and the Navy was therefore a defence against a Polish attack and against a French invasion via the Ostsee. Purely defensive aims. Q. When did this fear of an attack by Poland arise in Germany's official circles? A. In the very first years, when Vilna was taken. We felt, at the same time, that they could come to East Prussia. I am not certain about the exact year, since those opinions arose in the German Ministries and were held by the Ministers of the Army and Navy - Groner and Nocke. Q. And this view, in your opinion, was generally held perhaps as far back as 1919/1920, after the end of the first World War? A. The whole situation was most uncertain and confirmed and I cannot give you a very precise picture about the beginning of those years, since I was then working for two years in the Navy Archives, writing a book on the War and on how the Cruisers fought in the First World War. So that for two years I was not occupied with such matters." Likewise the same kind of planning and purposes are reflected in the table of contents of a history of the German Navy, 1919 to 1939, found in captured official files of the German Navy. Although a copy of the book has not been found [Page 197] by us, the project was written by Colonel Scherff, Hitler's special military historian. We have found the table of contents: it refers by numbers to groups of documents and notes on the documents, which evidently were intended as working materials for the basis of chapters to be written in accordance with the table of contents. The titles in this table of contents fairly establish the Navy planning and preparations to get the Versailles Treaty out of the way and to rebuild the Navy strength necessary for aggressive war. We have here the original captured document which is, as I say, the German typewritten table of contents of this projected work, with a German cover, typewritten, entitled "Geschichte der Deutschen Marine, 1919-1939 (History of the German Navy, 1919-1939)" We identify that as our series C-17 and I offer it in evidence as exhibit USA 42. This table of contents includes such general headings - but perhaps I had better read some of the actual headings: Part A (1919 - The Year of Transition). Chapter VII. First efforts to circumvent the Versailles Treaty and to limit its effects. (a) Demilitarisation of the Administration, incorporation of Naval Offices in Civil Ministries, etc. for example: incorporation of greater sections of the German maritime observation station and sea-mark system in Heligoland and Kiel, of the Ems-Jade Canal, etc. into the Reich Transport Ministry up to 1934; (b) The saving from destruction of coastal fortifications and guns. 1. North Sea (strengthening of fortifications with new batteries and modern guns between the signing and the taking effect of the Versailles Treaty); dealings with the Control Commission - information, drawings, visits of inspection, result of efforts." Referring to the group of documents numbered 85: "2. Baltic. Taking over by the Navy of fortresses Pillau and Swinemunde; salvage for the Army of one-hundred and eighty-five movable guns and mortars there. 3. The beginnings of coastal defence. Part B. (1920-1924. - The Organisational New Order) Chapter V. The Navy. Fulfilment and avoidance of the Versailles Treaty. Foreign countries. (a) The inter-allied Control Commissions. (b) Defence measures against the fulfilment of the Versailles Treaty and independent arming behind the back of the Reich Government and the legislative bodies. 1. Dispersal of artillery gear and munitions, of hand and automatic weapons. 2. Limitation of demolition work in Heligoland. 3. Attempt to strengthen personnel of the Navy, from 1923 4. The activities of Captain Lohmann (founding of numerous associations at home and abroad, participations, formation of 'sports' unions and clubs, interesting the film industry in naval recruitment) 5. Reparation for re-establishing the German U-boat arm since 1920. (Projects and deliveries for Japan, Holland, Turkey, Argentine and Finland. Torpedo testing.) 6. Participation in the preparation for building of the Luftwaffe (preservation of aerodromes, aircraft construction, teaching of courses, instruction of midshipmen in anti-air raid defence, training of pilots). 7. Attempts to strengthen the mining branch. Part C- (1925-1932. Replacement of Tonnage). Chapter IV. The Navy, the Versailles Treaty. Foreign countries. (a) The activities of the Inter-allied Control Commission (up to 31.1-27; discontinuance of the activity of the Naval Peace Commission). Independent armament measures behind the back of the Reich Government and legislative bodies up to the Lohmann case. [Page 198] 1. The activities of Captain Lohmann (continuation) their significance as a foundation for the rapid reconstruction work from 1935. 2. Preparation for the re-strengthening of the German U- boat arm from 1925 (continuation), the merit of Lohmann in connection with the preparation for rapid construction in 1925, relationship to Spain, Argentine, Turkey: the first post-war U-boat construction of the German Navy in Spain since 1927; 250 ton specimen in Finland, preparation for rapid assembly; electric torpedo; training of U-boat personnel abroad in Spain and Finland. Formation of U-boat school in 1932 disguised as an anti-U-boat school. 3. Participation in the preparation for the reconstruction of the Luftwaffe (continuation). Preparation for a Naval Air Arm, Finance Aircraft Company Sevra, later Luftdienst CMRH; Naval Flying School Warnemende; Air Station List, training of sea cadet candidates, Military tactical questions 'Air Defence Journeys,' technical development, experimental station planning, trials, flying boat development DOX etc., catapult aircraft, arming, engines, ground organisation, aircraft torpedoes, the Deutschland Flight, 1925 and the Seaplane Race, 1926. 4. Economic re-armament ("The Tebeg' -Technical Advice and Supply Company as a disguised Naval Office abroad for investigating the position of raw materials for industrial capacity and other War economic questions). 5. Various measures. (The NV Aerogeodetic Company - secret investigations.) (c) Planned Armament Work with the tacit approval of the Reich Government, but behind the backs of the legislative bodies (1928 to the taking over of power). 1. The effect of the Lohmann case on the secret preparations ; winding up of works which could not be advocated; resumption and carrying on of other work. 2. Finance question. ('Black Funds' and the Special Budget.) 3. The Labour Committee and its objectives. (d) The question of Marine Attaches. (The continuation under disguise; open reappointment 1932-1933.) (e) The question of Disarmament of the Fleet abroad and in Germany. (The Geneva Disarmament Conference 1927; the London Naval Treaty of 1930; the Anglo-French-Italian Agreement 1931. The League of Nations Disarmament Conference 1932.)
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