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The next entry, for 19th March, 1941, which is at Page 54 of
the document book, shows that by March of 1941 Raeder had
begun to consider what prospects of naval action the Russian
aggression had to offer. There is the entry:

  "In case of 'Barbarossa,' Supreme Naval Commander
  describes the occupation of Murmansk as an absolute
  necessity for the Navy, Chief of the Supreme Command
  Armed Forces considers compliance very difficult."

In the meantime, the entries in this document show that
Mussolini, the flunkey of Nazism, was crying out for a more
active Nazi Mediterranean policy. I refer the Court to Page
57 of the document book, the entry for 30th May:

  "Duce demands urgently decisive offensive Egypt-Suez for
  autumn 1941; 12 divisions are needed for that; 'That
  stroke would be more deadly to the British Empire than
  the capture of London'; Chief, Naval Operations agrees

And then, finally, the entry for 6th June, indicating
strategic views of Raeder and the German Navy at this stage,
reads as follows. It is at Page 58 of the document book:

  "Naval Supreme Commander with the Fuehrer: Memorandum of
  the Chief, Naval Operations. Observation on the strategic
  situation in the Eastern Mediterranean after the Balkan
  campaign, and the occupation of Crete, and further
  conduct of the War."

A few sentences below:

  "The memorandum points with impressive clarity to the
  decisive aims of the war in the Near East, which have
  been made tangible by the successes
                                                  [Page 272]
  in the Aegean area. The memorandum emphasises that the
  offensive utilisation of the present favourable situation
  must take place with the greatest acceleration and
  energy, before England has again strengthened her
  position in the Near East with help from the United
  States of America. The memorandum, however, realises the
  unalterable fact that the campaign against Russia would
  be opened very shortly, demands that the undertaking
  'Barbarossa'' which, because of the magnitude of its
  aims, naturally stands in the foreground of the
  operational plans of the Armed Forces leadership, must
  under no circumstances lead to an abandonment,
  diminishing or delay of the conduct of the War in the
  Eastern Mediterranean."

Thus Raeder was, throughout, seeking an active role for his
Navy in the Nazi war plans.

Now, once Hitler had decided to attack Russia, Raeder sought
a role for the Navy in the campaign against Russia, and the
first naval operational plan against Russia was a
particularly perfidious one. I refer the Tribunal to
Document C-170 from which I have just been reading, at Page
59 of the document book. There the Tribunal will see an
entry for 15th June, 1941:

  "On the proposal of Chief Naval Operations, use of arms
  against Russian submarines, South of the Northern
  boundary of the Oland danger zone (declared area) is
  permitted immediately; ruthless destruction is to be
  aimed at."

The defendant Keitel provided a characteristically dishonest
pretext for this action in his letter, Document C-38, which
is at Page 11 of the document book and which will be Exhibit
GB 223. The Tribunal sees that Keitel's letter is dated 15th
June, 1941:

  "Subject: Offensive action against enemy submarines in
  the Baltic Sea.
  High Command of the Navy-O.K.M. (S.K.L.).
  Offensive action against submarines South of the line
  Memel-Southern tip of Oland is authorised if the boats
  cannot be definitely identified as Swedish during the
  approach by German naval forces.
  The reason to be given up to B-day is that our naval
  forces are believed to be dealing with penetrating
  British submarines."

Now, that was on 15th June, 1941, and the Tribunal will
remember that the Nazi attack on Russia did not take place
until the 22nd of June of 1941. In the meantime, Raeder was
urging Hitler, as early as 18th March, 1941, to enlarge the
scope of the world war by inducing Japan to seize Singapore.
The relevant document is C-152, Exhibit GB 122, at Page 23
of the document book. There is just one paragraph which I
would like to be permitted to read. The document describes
the audience of Raeder with Hitler on 18th March and the
entries in it, in fact, represent Raeder's own views:

  "Japan must take steps to seize Singapore as soon as
  possible, since the opportunity will never again be as
  favourable (whole English Fleet contained; unpreparedness
  of U.S.A. for war against Japan; inferiority of U.S.
  Fleet vis-a-vis the Japanese). Japan is indeed making
  preparations for this action, but according to all
  declarations made by Japanese officers she will only
  carry it out if Germany proceeds to land in England.
  Germany must therefore concentrate all her efforts on
  spurring Japan to act immediately. If Japan has
  Singapore, all other East Asiatic questions regarding the
  U.S.A. and England are thereby solved (Guam, Philippines,
  Borneo, Dutch East Indies).
  Japan wishes if possible to avoid war against U.S.A. She
  can do so if she determinedly takes Singapore as soon as

The Japanese, of course, as events proved, had different
ideas from that.

                                                  [Page 273]

By 20th April, 1941, the evidence is that Hitler had agreed
with this proposition of Raeder's of inducing the Japanese
to take offensive action against Singapore. I refer the
Tribunal again to Document C-170 and to an entry at Page 56
of the document book, for 20th April, 1941. A few sentences
from that read:

  "Naval Supreme Commander with the Fuehrer: Naval Supreme
  Commander asks about result of Matsuoka's visit, and
  evaluation of Japanese-Russian pact. Fuehrer has informed
  Matsuoka, 'that Russia will not be touched if she behaves
  in a friendly manner according to the treaty. Otherwise,
  he reserves action for himself.' Japan-Russia pact has
  been concluded in agreement with Germany, and is to
  prevent Japan from advancing against Vladivostok, and to
  cause her to attack Singapore."

Now an interesting commentary upon this document is found in
Document C-66, at Page 13 of the document book. At that time
the Fuehrer was firmly resolved on a surprise attack on
Russia, regardless of what was the Russian attitude to
Germany. This, according to reports coming in, was
frequently changing, and there follows this interesting

  "The communication to Matsuoka was designed entirely as a
  camouflage measure and to ensure surprise."

The Axis partners were not even honest with each other, and
this, I submit, is typical of the kind of jungle diplomacy
with which Raeder associated himself.

I now, with the Tribunal's permission, turn from the field
of diplomacy to the final aspect of the case against Raeder,
namely, to crimes at sea.

The prosecution's summary is that Raeder throughout his
career showed a complete disregard for any international
rule or usage of war which conflicted in the slightest with
his intention of carrying through the Nazi programme of
conquest. I propose to submit to the Tribunal only a few
examples of Raeder's flouting of the laws and customs of
civilised States.

Raeder has himself summarised his attitude in the most
admirable fashion in Document U.K. 65, which the Tribunal
will find at Page 98 of the document book, and which will be
Exhibit GB 224. Now that document, UK 65, is a very long
memorandum compiled by Raeder and the German Naval War Staff
on 15th October, 1939: that is to say, only a few weeks
after the war started. It is a memorandum on the subject of
the intensification of the war at sea, and I desire to draw
the Tribunal's attention to the bottom paragraph at Page 98
of the document book. It is headed: "Possibilities of future
naval warfare."

  "1. Military requirements for the decisive struggle
  against Great Britain.
  Our naval strategy will have to employ all the military
  means at our disposal as expeditiously as possible.
  Military success can be most confidently expected if we
  attack British sea communications wherever they are
  accessible to us with the greatest ruthlessness; the
  final aim of such attacks is to cut off all imports into
  and exports from Britain. We should try to consider the
  interests of neutrals in so far as it is possible without
  detriment to military requirements. It is desirable to
  base all military measures which may be taken on existing
  International Law; however, measures which are considered
  necessary from a military point of view, provided a
  decisive success can be expected from them, will have to
  be carried out, even if they are not covered by existing
  International Law. In principle, therefore, any means of
  warfare which is effective in breaking enemy resistance
  should be used on some legal conception," - the nature of
  which is not specified  - "even if that entails the
  creation of a new code of naval warfare.
  The Supreme War Council will have to decide what measures
  of military and legal nature are to be taken. Once it has
  been decided to conduct economic warfare in its most
  ruthless form, in fulfilment of military
                                                  [Page 274]
  requirements, this decision is to be adhered to under all
  circumstances, and under no circumstances may such a
  decision for the most ruthless form of economic warfare,
  once it has been made, be dropped or released under
  political pressure from neutral powers; that is what
  happened in the World War to our own detriment. Every
  protest by neutral powers must be turned down. Even
  threats of further countries, including the U.S. coming
  into the war, which can be expected with certainty should
  the war last a long time, must not lead to a relaxation
  in the form of economic warfare once embarked upon. The
  more ruthlessly economic warfare is waged, the earlier
  will it show results and the sooner will the war come to
  an end. The economic effect of such military measures on
  our own war economy must be fully recognised and
  compensated through immediate re-orientation of German
  war economy, and the re-drafting of the respective
  agreements with neutral States; for these are the final
  words: for this, strong political and economic pressure
  must be employed if necessary."

I submit that those comments are most revealing, and the
general submission of the prosecution is that, as an active
member of the inner council of the Nazi State up to 1943,
Raeder, promoting such ideas as these, must share
responsibility for the many War Crimes committed by his
confederates and underlings in the course of the war.

But quite apart from this over-all responsibility of Raeder,
there are certain crimes which the prosecution submits were
essentially initiated and passed down the naval chain of
command by Raeder himself.

I refer to Document C-27, at Page 7 of the document book,
which will be Exhibit GB 225. These are minutes of a meeting
between Hitler and Raeder on 30th December, 1939. 1 will
read, with the Court's approval, the second paragraph

  "The Chief of the Naval War Staff requests that full
  power be given to the Naval War Staff in making any
  intensification suited to the situation and to the means
  of war. The Fuehrer fundamentally agrees to the sinking
  without warning of Greek ships in the American prohibited
  area, and of neutral ships in those sections of the
  prohibited American area in which the fiction of mine
  danger can be upheld, e.g., the Bristol Channel."

At this time, of course, as the Tribunal knows, Greek ships
were neutral. I submit that this is yet another
demonstration of the fact that Raeder was a man without

This incitement to crime was, in my submission, a typical
group effort, because in Document C-12, which is at Page 1
of the document book, the Tribunal will see that a directive
to the effect of those naval views was issued on 30th
December, 1939, by the O.K.W., being signed by the defendant
Jodl. And that Document C-12 will be Exhibit GB 226. It is
an interesting document. It is dated 30th December, 1939,
and it reads:

  "On 30th December, 1939, according to a report of the
  Oberbefehlshaberder Marine, the Fuehrer and Supreme
  Commander of the Armed Forces decided that:
  (1) Greek merchant ships in the area around England
  declared by U.S.A. to be a barred zone are to be treated
  as enemy vessels.
  (2) In the Bristol Channel, all shipping may be attacked
  without warning where the impression of a mining incident
  can be created.
  Both measures are authorised to come into effect

Another example of the callous attitude of the German Navy
when it was under Raeder's command, towards neutral
shipping, is found in an entry in Jodl's diary -

THE PRESIDENT: I think perhaps you should read the pencil
note, should you not?

                                                  [Page 275]

MAJOR ELWYN JONES: The pencil note on Document C-12 reads:

  "And to (1) Attack must be carried out without being
  seen. The denial of the sinking of these steamships in
  case the expected protests are made must be possible."

As I was saying, my Lord, another example of the callous
attitude of Raeder's Navy towards neutral shipping is found
in an entry in Jodl's diary for 16th June, 1942, at Page 112
of the document book, which is Document 1807-PS, and will be
Exhibit GB 227. This extract from Jodl's diary is dated 16th
June, 1942, and it reads:

  "The operational staff of the Navy (S.K.L.), applied on
  29th May for permission to attack the Brazilian sea and
  air forces. The S.K.L. considers that a sudden blow
  against the Brazilian warships and merchant ships is
  expedient at this juncture (a) because defence measures
  are still incomplete; (b) because there is the
  possibility of achieving surprise; and (c) because Brazil
  is to all intents and purposes fighting Germany at sea."

This, the Tribunal will see, was a plan for a kind of
Brazilian "Pearl Harbour" because the Tribunal will
recollect that war did not in effect break out between
Germany and Brazil until 22nd August, 1942.

Raeder himself also caused the Navy to participate in War
Crimes ordered by other conspirators, and I shall give one
example only of that. On 28th October, 1942, as Document C-
179, Exhibit USA 543, at Page 63 of the document book shows,
the head of the operations division of the Naval War Staff
promulgated to naval commands Hitler's notorious order of
18th October, 1942, with regard to the shooting of
Commandos, which, in my submission, amounted to denying the
protection of the Geneva Convention to captured Commandos.

The Tribunal will remember the document is dated 28th
October, 1942, and it reads:

  "Enclosed please find a Fuehrer order regarding
  annihilation of terror and sabotage units.
  This order must not be distributed in writing by Flotilla
  leaders, Section Commanders or Officers of this rank.
  After verbal notification to subordinate sections the
  above officers must hand this order over to the next
  higher section which is responsible for its withdrawal
  and destruction."

What clearer indication could there be than the nature of
these instructions as to the naval command's appreciation of
the wrongfulness of the murders Hitler ordered?

THE PRESIDENT: Shall we adjourn now for ten minutes?

(A recess was taken.)

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