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Q. Defendant, I want you to understand what my next series
of questions is directed to. I do not want there to be any
misapprehension. I am now going to suggest to you that these
breaches of treaty and your naval plans were directed
towards the possibility, and then the probability of war. I
would just like you to take the same document that I have
been dealing with, C-23. We will use that to pass from one
to the other.

                                                  [Page 194]

Would you turn to Page 5 of Document Book 10, and there you
will see that there is a memorandum, I think of the Planning
Committee to the Commander-in-Chief of the Fleet, Admiral
Karls. We have heard your view of Admiral Karls, that you
thought he was a very good officer, and in fact he was your
first choice as your successor.

Now, that is in September 1938, and it is a top secret
opinion on the strategic study of naval warfare against
England, and you see "a" says:-

  "There is full agreement with the main theme of the

Now, look at paragraph 1:-

  "If, according to the Fuehrer's decision, Germany is to
  acquire a position as a world power, she needs not only
  sufficient colonial possessions, but also secure naval
  communications and secure access to the oceans."

Do you agree with that, defendant?

A. Yes, that is correct. I know the whole document.

Q. Now, look at "2":-

  "Both these requirements can only be fulfilled in
  opposition to Anglo-French interests, and would limit
  their position as world powers. It is unlikely that this
  can be achieved by peaceful means. The decision to make
  Germany a world power, therefore, forces upon us the
  necessity of making corresponding preparations for war."

Do you agree with that?

A. Yes, that is all quite correct.

Q. Now, let us take "3":-

  "War against England means at the same time war against
  the Empire, against France, probably against Russia as
  well, and a large number of countries overseas - in fact,
  against half to two-thirds of the whole world."

I need not ask you about that, because the facts have shown

Now, look at the next:-

  "It can only be justified - "

A. (Interposing.) Yes, but I must be allowed to comment on
that document.

Q. Oh certainly, I am sorry. We got on so quickly I thought
we were not going to have any explanation.

A. In 1938, as has been stated here quite often, the
Fuehrer's attitude towards Great Britain became more
difficult in spite of all the efforts of Blomberg and myself
to tell him that it was possible to live in peace with
England. In spite of that the Fuehrer ordered us to prepare
for possible opposition by England to his plans. He, for his
part, never contemplated a war of aggression against her;
and we in the Navy less; in fact, I have proved that I did
nothing but try to dissuade him from that. In 1938 he
ordered us to make a study similar to those we had already
made in the case of other possibilities of war - which it
was the duty of the Wehrmacht Command to do - but dealing
with the course which a war against England might take and
what we would require for it. This study was prepared, and I
reported to the Fuehrer that we could never increase our
fighting forces to such an extent that we could undertake a
war against England with any prospect of success. It would
have been madness for me to say that we could. I told him
repeatedly that by 1944 or 1945 we might build up a small
naval force with which we could start an economic war
against England or seize her commercial shipping routes, but
that we would never really be in a position to conquer
England with that force. I sent this study, which was
compiled under my guidance in the Naval War Staff, to
Admiral Karls who was very clear-sighted in all such
questions. He thought it his duty to explain in this
introduction, which agreed with our opinion, the
consequences which such a war against Great Britain would
have for ourselves, namely, that it would bring about a new
world war, which neither he nor we in the Navy nor anyone in
the Armed Forces wanted - not even Hitler himself, as I
proved the other day - hence this statement. He said that if
we must have war with England, it was essential that we
should first of all have access to the ocean, and, secondly,
that we should attack English trade

                                                  [Page 195]

on the sea routes of the Atlantic. Not that he planned such
a venture. He was only thinking of the case of such a war
breaking out very much against our will. It was our duty to
follow this train of thought to its logical conclusion.

Q. You say that, "The war against it" - that is the war
against England - "can only be justified and have a chance
of success if it is prepared economically as well as
politically and militarily."

Then you go on to say, "waged with the aim of conquering for
Germany an outlet to the ocean."

Now, I just want to see how you prepared.

A. Yes, that is quite clear and quite correct.

Q. Let us just look how you had begun to prepare
economically. Let us take that first, as you put it first.

Would you look at Document C-29, which is Page 8.

THE PRESIDENT: Sir David, had we not better break off now
before going into this?

(A recess was taken.)


Q. I told you, defendant, that I was next going to ask you a
question about Document C-29, which is on Page 8 of the
English Document Book 10, and on Pages 13 and 14 of the
German Document Book. You will remember, this document gives
general directions for export given by the German Navy to
the German armament industry -

A. Yes.

Q. ... and you told us when you were dealing with the
document, that you wanted your service not to be small-
minded about matters of a not very high secrecy but in
addition to that, your general policy was that the German
armament firms should develop a foreign trade so that they
would have the capacity to deal with the increased demands
of the German Navy as soon as possible. Is that right, is
that a fair summary, or shall I repeat it?

A. Yes, but it must be added that I said that we hoped at
that time that the Treaty of Versailles would be relaxed,
because it was a comparatively favourable period for
negotiations about disarmament, and we already had
government departments, headed by Papen and Schleicher, both
of whom showed great understanding for the needs of the
Armed Forces and therefore fought hard for that at the
disarmament conference. So a definitely legal development
might be hoped for in this direction; and on the other hand,
our entire industry was unable to cope with armaments
production except on an insignificant scale and had
therefore to be increased. I again stress the fact that it
had nothing to do with the Hitler regime. That decree just
happened to come out on 31st January.

Q. I do not think you are really disagreeing with me that
your policy, your broad economic policy for the German
armament industry, was to develop its export trade so as to
be able to deal with increased home requirements in future
years; that is what you advocated, is it not, that the
German armament industry should at once increase its export
trade so as to be able to deal with increased home
requirements when these requirements arose? Is not that

A. Yes, that is correct, but I do not quite understand that
expression. Did you say "Eigenhandel" or "Eisenhandel" -
internal trade or iron trade? I did not quite hear the
expression - "Eigenhandel" or "Eisenhandel".

Q. "Aussenhandel" (Foreign trade).

A. "Aussenhandel" - yes, we wanted to be able to compete
industrially with other nations, so that our industry would
be in a favourable position and would gain strength.

                                                  [Page 196]

Q. Now, I will ask you to turn to Document C-135, which is
Page 20 of the English Document Book and Page 73 of the
German Document Book.


SIR DAVID MAXWELL FYFE: Book 10, my Lord, yes.


Q. Now, you remember that document, you dealt with it. You
said -

A. Yes, it was dealt with in the Lohmann affidavit.

Q. Yes, it is a document of, I think, April, 1933, judging
by the dates which I put to you a moment ago, and you said
to the Tribunal, in giving your evidence, that it was mere
chance that the year 1938 was mentioned; that that was the
same period as has been dealt with.

A. It has already been stated several times that the year
1938 was mentioned.

Q. Has it been mentioned in some Weimar Republic document?
Will you just look at the second last paragraph; that will
be on your Page 74, Page 21 of the English document. It is
in the middle paragraph of Paragraph 3:-

  "Reichskanzler Adolf Hitler had made a clear political
  request to build up for him in five years, that is, by
  the first of April, 1938, armed forces which he could
  place in the balance as an instrument of political

Is that sure, that Hitler had made a clear political

A. Yes, as far as I remember, he demanded a sort of Five-
Year Plan in 1933, the last year of which -  1938 - happened
to coincide with the 1938 start of our substitute plan for
subsurface construction, and that directive had obviously
been given for the whole of the armed forces; since the
Naval Agreement, which gave us the right to arm only in the
proportion of 1:3, and not in accordance with any special
plans of our own, had become the basis for the Navy as early
as 1935.

Q. The point that I want to deal with is this: Did Hitler
tell you that be wanted these forces to place in the balance
as an instrument of political power, did he tell you that?

A. I can no longer tell you that; but I believe that it is a
perfectly ordinary expression to say that one uses one's
armed forces as a political instrument which could be thrown
into the scales, so that we need no longer be kicked around
by the different nations, as had so far been the case. In my
opinion, no suspicion attached to the expression.

Q. To put it bluntly, Hitler was telling you, "by 1938 I
want armed forces that I can use in war, if war should
become necessary." That is what it means, is it not? That is
what you understood it to mean, is not that right?

A. No. There was no word about a war, only about the fact
that we had to keep our position among the other nations so
that we could no longer be tossed about, as had hitherto
been the case.

Q. If anyone tried to push you over, you could fight; that
is it, was it not?

A. That is obvious. That would be the case, of course, if we
were attacked. We wanted to be in a position to defend
ourselves if we were attacked. Up till that point we were
unable to do this.

Q. Now, just let us take the first example, when you
contemplated fighting. If you look at Document Book 10 A, C-
140, Page 104 of the English translation and Page 157 of the
German version, you remember that is the directive of Field-
Marshal von Blomberg on Germany leaving the disarmament
conference and League of Nations. Here there is a pretty
full general directive as to what military measures you
would take if the members of the League of Nations applied
sanctions against you; in other words you were quite
prepared -

A. Yes -

Q.  - for a war in that eventuality; that is so, is it not,
and that is what it says, it shows all preparations for a

                                                  [Page 197]

A. These preparations were made, if I remember correctly,
eleven days after we had left the League of Nations, and it
was quite natural that, if the Fuehrer believed that, in
consequence of our leaving the League of Nations, which was
quite a peaceful action in itself, warlike measures or
sanctions would be applied against us, we should have to
defend ourselves; and if such an attack was probable we had
to take these preparatory steps.

Q. So you realised, defendant, that as early as October,
1933 the course of Hitler's foreign policy might have
brought about an immediate war, did you not?

A. No, I did not consider that such a measure as the
secession from the League of Nations, where we had always
been treated unjustly because we had no power behind us,
would result in war with any, other power. Nevertheless, it
was right to take such eventualities into consideration.

Q. I see. That is good enough for me.

Now, just let us look at the same Document Book, C-153, on
Page 107 of the English version and Pages 164 to 167 of the
German version. That is, you will remember, your armament
plan for the third armament phase, and I would just like you
first of all to look at paragraph 3.

In (a) and (b) of paragraph 3 you give the general basis for
your arrangements:

  (a) For the military leaders a sound basis for their
  operations and considerations, and
  (b) for the political leaders a clear picture of what may
  be achieved with the military means available at a given

A. Yes, it is obvious that such a plan would have this

Q. And that your political leaders were to make their plans
on what armed forces you had available for war, if
necessary. That was what you were contemplating then, was it

A. Yes, that is a matter of course; I reported to the
Fuehrer that I could put a certain military strength at his
disposal during that year. The Chief of State had to know
that, in order to know what he could count on. But that has
nothing to do with plans for war. That is the case in every
nation. On the other hand, I cannot influence the political
leader as to what forces we should have. I can only tell him
what I can muster for him. Therefore I had nothing to do
with political matters. I only do what is necessary and what
is done in every State.

Q. Now just look at paragraph 7.

I am not going to argue with you as to whether States base
their foreign politics on things other than war as a matter
of argument, but look at paragraph 7.

  "All theoretical and practical B-preparations are to be
  drawn up with a primary view to readiness for a war
  without setting a starting time."

That means that you had to put the Navy on a war footing
without delay. Is not that right?

A. No, no. This concerns the sequence of the measures to be
taken. The armament plan listed the most important immediate
requirements of the Navy, and at that point I said that this
applied to forces to be used in a sudden war - in plain
language, the mobile fleet, which must be in a state of
constant readiness. It had to be kept ready for action at a
moment's notice and this had to have priority. All other
matters, such as quarters, and things that had nothing to do
with direct combat, were attended to afterwards.

Q. I thought that is what I put to you, that the fleet had
to be ready and ready for war. However, you have given your
account of it.

Just turn over, if you will be so good, to Page 66 of
Document Book 10, Page 285 of the German Document Book, C-
189, my Lord.

Q. Now, I want to raise just this. one matter on which you
made a point in your examination and which I must challenge.
You say in paragraph 2:-

  "The C.-in-C. Navy expresses the opinion that later on" -
  and I ask you to note the words 'later on' - "the fleet
  must, in any case, be strengthened against England, and
  that therefore, from 1936 onwards, the large ships must
  be armed with a 35-cm- gun."

                                                  [Page 198]

Now, are you telling the Tribunal that "gegen England " does
not mean "against" in the sense of in antagonism to,
directed against, in opposition to - that it merely means in
comparison to? Are you seriously saying that, are you?

A. I explained the other day that we are dealing here with
the question of keeping pace with other navies. Up to that
time we had kept pace with the French Navy, which had 33-cm.
guns. Then England went beyond that in mounting 35.6-cm.
guns on her ships and then, as I said before, France went
beyond England in using 38-cm. guns. Therefore I told the
Fuehrer that our 28-cm. guns, which we believed we could use
against the French Dunkerque class, would not be heavy
enough, and that we would have to take the next bigger
calibre, that is 35.6, like those of the English ships. That
was never done, because the French began to use 38-cm. guns
and our Bismarck class followed the French lines.

That comparison of calibres and classes of vessels was at
that time quite customary and was also -

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