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                                                   [Page 88]

HUNDRED AND THIRTY-FIRST DAY

THURSDAY, 16th MAY, 1946

THE MARSHAL OF THE COURT: If it please the Tribunal, the
defendants Sauckel and von Papen are absent.

The defendant Raeder resumed the witness-stand and testified
further as follows:-

DIRECT EXAMINATION-Continued

BY DR. SIEMERS:

Q. Grand Admiral, yesterday we finished with the somewhat
involved Document 32, and we had got as far as (11). We now
come to (12), "Ammunition Stocks in Excess of the Armament
Permissible." May I remind the Tribunal that this is
Document C-32, Exhibit USA 50, Document Book 10-A, on Page
8.

Witness, may I ask what you have to say to the accusation
that you exceeded the permissible amount of ammunition?

A. Some ammunition stocks were in excess of the permissible
amount and some were below it. I cannot tell you at this
date what the reason was in each particular case. I assume
that this depended to a very considerable extent on the
amounts left over from the last World War.

In the case of the first two items, the 17 and 15-cm.
shells, the actual stocks rather exceeded the quantity
permitted; whereas the third item, 10-5 cm. shells, fell
very far short of it; instead of 134,000 there were 87,000.
In the case of the 8.8 cm. shells there was an excess. Then
comes a deficit again, and so on. But they are all very
insignificant amounts.

Q. In the copy before the Tribunal there appears to be a
note in the third column-on the next page in yours, witness-
saying that quantities of ammunition were being
manufactured, or in course of delivery, and that the total
amount permissible would soon be exceeded.

I only wanted to ask you this: the list was made out in
September 1933; are the figures stated correct for September
1933, or autumn 1933?

A. I did not quite understand you, I am afraid.

Q. If it says in this Document that measures to be taken
later would bring the totals above the quantities
permissible, which - according to this statement - they had
not yet reached, then is that correct for autumn 1933?

A. That may be assumed - yes - because new gulls and new
ammunition were being manufactured; old ammunition then 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
permissible amount. A comparatively large amount of heavy
artillery ammunition had been granted us for heavy coastal
guns; and we had by no means as much as we were allowed to
have.

DR. SIEMERS: For the assistance of the Tribunal, I may point
out that this last point is proved by the actual documents
in the hands of the Tribunal. In the Tribunal's copy (12),
column 2, just beside the separate figures, there is a
sentence which says: "that the whole quantity permitted for
heavy artillery has not been reached."

Q. We now come to (13), "Exceeding the permissible stocks of
machine guns, etc., rifles, pistols and respirators."

                                                            
                                                   [Page 89]


A. Here, too, it must be admitted that in isolated cases
stocks were a little higher than permitted. There were, for
instance, 43,000 gas-masks, instead of the 22,500 permitted.
Large numbers of rifles and machine-guns were taken away
even by individuals after the World War to farms, etc. They
were later called in and for that reason there was a
comparatively large accumulation of them. But we are not
dealing here with any very considerable quantities.
Similarly, ammunition, bayonets, hand-grenades,
searchlights, sundry equipment, etc., also exceed the
prescribed limits, but not to any great extent.

Q. Now (14), "Obtaining 337 m/gC/30 without scrapping
equally serviceable weapons." As I did not -

THE PRESIDENT: Surely, Dr. Siemers, it would he 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 got as far as 13 - and you are dealing with
each one.

DR. SIEMERS: Mr. President, personally I am entirely
agreeable. I am sorry that I caused the Tribunal so much
trouble in connection with this Document. As I am not a
naval expert, I had a great deal of trouble finding my way
through it, but I do not think that I was the cause of the
trouble. The prosecution, you see, has made use of the
single points in evidence.

THE PRESIDENT: Dr. Siemers, the question is - I am not
blaming you, but we want to get on. We are not blaming you.
Cannot it be done in one explanatory statement, one short
statement?

DR. SIEMERS: I will try, Mr. President, and I will shorten
it.

BY DR. SIEMERS:

There is no need to say anything about (15) to (17). I think
we have dealt with the most important points. Those
connected with plans for a later date were not to be
effective until the years 1933 and 1934. I may perhaps just
point out to the Tribunal that (17) refers to the intended
construction of reserve destroyers. The Versailles Treaty
permitted the construction of these.

I pass over (18) because we have already dealt with that.
(19) - again - only refers to intended construction. (20) I
may consider irrelevant; it only concerns the arming of
fishery cruisers. (21) to (29) -

THE PRESIDENT: I think, perhaps, you should ask the
defendant to explain some of these observations in the third
column. I mean in (18) for instance, "Difficult to detect.
If necessary can be denied."

A. These were explanations given to our League of Nations'
representative at the disarmament conference by the
competent expert. It does not refer to local conditions.
Construction of submarine parts, for instance, took place
abroad or was to be prepared. It was actually carried out in
1934 and 1935, and the first submarine was launched at the
end of June 1935.

Q. I may take it, witness, that only the construction and
purchase of submarines was prohibited?

A. Yes, the construction in-Germany.

Q. I cannot prove until a later stage that no violation of
the treaty was involved by the construction of spare parts;
but I think you will have to give some indication of your
reason for wishing to conceal it, in view of the fact that
spare parts were not forbidden. I may remind you that this
took place in September 1933, at a time when negotiations
had already been planned.

A. At that period, before the English naval agreement was
concluded on the basis of 35 to 100, Hitler was particularly
anxious to avoid everything which might embarrass the
negotiations in any way. The construction and preparation of
submarine parts came under this head as being a subject on
which England was peculiarly sensitive.

                                                            
                                                   [Page 90]

Q. Was there not an additional reason for this appendix and
other remarks in this second column, namely, the unfortunate
experiences which the Navy had had in home politics; the
fact that whenever the slightest action was taken, a quarrel
immediately ensued on the political home front?

A. Yes; and that went so far that the Defence Minister was
attacked on occasion by Prussian Ministers who disagreed
with the ministers of the Reich - e.g., Muller, Severing,
Stresemann and, later, Bruning - who alleged to the Reich
Chancellor that he took steps which he was not authorized to
take. In reality, however, the Reich Government itself had
sanctioned these things already and had put its signature to
them.

Q. So these things were kept secret for reasons of home
policy, so that they should not be apparent -

A. Yes.

Q. With the approval of the Reich Government?

A. With the approval of the Reich Government. As regards the
firms, a number of firms -

Q. I am now anxious to refer back to (20) column 2, as I see
from the record that the prosecution also expressly in the
circumstances raised this point in connection with the
arming of fishing vessels, emphasized it and made it the
basis of a charge: "Representing warning shots as a
bagatelle."

A. These fishing vessels were quite small vessels and were
normally unarmed. They served to supervise the fishing boats
in the North Sea right up to Iceland, to help them in case
of emergency, to take sick men aboard and to afford them
protection against fishermen of other nations. We thought it
advisable to mount at least a 5-cm. gun on these ships as
they were actually warships. "Warning shots" means that they
fired a salute when they wanted to draw the fishermen's
attention to something, so it was quite an insignificant
affair; and had no need to be camouflaged as a mere
bagatelle but was one in fact.

Q. We now come to (21) to (28), which are lists of various
firms, including industrial firms, working on armament
contracts. The Versailles Treaty admitted certain firms for
this type of work, while it excluded others. In actual fact,
other firms had received contracts. Perhaps you can make a
general statement on this point.

A. This was at a time when we had strong hopes that progress
would be made at the disarmament conference. The Macdonald
Plan, which brought about a certain improvement, had already
been accepted; and we might expect, in consequence, that the
few factories still left to us would have to increase their
output during the next few years. I may refer you to the
shipping replacement scheme. Consequently, factories
producing specialized articles were better equipped and
supplied. There was, however, never any question of heavy
guns or anything of that kind, but of automatic fuse-
igniters, explosives - for instance, mine containers, etc.,
small items, but specialist items which could only be made
by certain firms. But, apart from the firms admitted, other
firms which had been excluded were also employed. Thus, for
instance, the Fried. Krupp Grusenwerk A.G. at Magdeburg -
(25) - was equipped to manufacture anti-aircraft guns and
anti-aircraft barrels from 2 cm. to 10.5 cm-; similarly
(26), a firm manufacturing anti-aircraft ammunition,
explosives, etc., (27) -

Q. I do not think we need the details.

A. No. And then engines for which there was also a great
demand.

Q. I have one question which applies to all these figures.
Is there not a certain excuse in view of the fact that some
of the firms admitted had already dropped out for economic
reasons?

A. Yes, you can certainly say that. These firms had
comparatively few deliveries which were not sufficient to
keep them going.

Q. Witness, I think one not only can - I think one must -
say so. May I draw your attention to point 22, column 3,
which reads: "The list in any case is out of date as some
firms have dropped out."

                                                            
                                                   [Page 91]
                                                            

A. Yes.

Q. That leaves us with (29) and (30). (29): "Preparations in
the field of experiments with motor-boats." I think that
these were preparations on a very small field.

A. At the moment I cannot tell you exactly what this means.

Q. I do not believe in any case that the Tribunal will
attach any importance to it.

Then I only want you to make a final statement on (30),
which reads: "Probably in the near future further
considerable breaches will be unavoidable up to 1934." To
all intents and purposes you have already made a statement
on that point by your reference to the negotiations planned
with the British Government, some of which were already in
progress.

A. Yes, that was the point.

Q. These are matters, therefore, which were in any case due
to be discussed in the course of the negotiations with the
British Government and for the Admiralty.

A. You cannot say that of them all. For instance, points (1)
to (3) deal with mines. The number of mines was to be
increased and modern material was to replace the old. It
goes on in the same way with the transfer of guns from the
North Sea to the Baltic, not with the scrapping of guns.

Q. To conclude the whole matter, may I ask you to say what
impression the whole thing made on a naval expert like
yourself; all things considered, would you say that these
were minor violations? How far would you say that their
character is aggressive?

A. As I said yesterday, most of them were very inadequate
defence improvements applied to an almost entirely
defenceless position. The individual items, as I explained
yesterday, are so insignificant that it is really impossible
to spend very much time on them. I believe that the Control
Commission also had the impression that very little weight
need be attached to all these matters, for in 1925, when
that Commission left its station at Kiel, where it had
worked with the organizations of the naval command,
Commander Fenshow, Admiral Charlton's chief of staff and
head of the Commission, whose main interest was guns, and
who had worked with a Captain Renken, a specialist in these
matters, said:

  
  "We must leave now; and you are glad that we are going.
  You did not have a pleasant task; and neither did we. I
  must tell you one thing. You need not think that we
  believe what you have been saying. You did not say a
  single word of truth; but you have given your information
  so skilfully that we might have been convinced, and for
  that I am grateful to you."
  

Q. I now come to Document C-29, which is Exhibit USA 46.

Mr. President, it is in Raeder's Document Book 10, Page 8 of
the prosecution's Document Book.

THE PRESIDENT: You mean 10-A?

DR. SIEMERS: No. 10, Page 8. This Document, too, was
submitted during the general indictment made by the
prosecution at the beginning of the trial on 27th November.
It is a letter - a document signed by Raeder, dated 31st
January, 1933; General Directives for the support of the
German armaments industry by the navy.

BY DR. SIEMERS

Q. The prosecution pointed out this letter, and has thought
fit to conclude from it that on the very day after Hitler's
nomination as Chancellor of the Reich, you were definitely
supporting him. Will you define your attitude, please?

A. There is no connection at all between this letter and
Hitler's accession to power. You must admit that it would be
impossible to compile so long and complicated a document,
which was, after all, carefully prepared, between the
evening of 30th and the morning of 31st January. This
document expresses the hope which I mentioned before, that
even under Papen and Schleicher the

                                                            
                                                   [Page 92]
                                                            

stipulations of the Versailles Treaty and the Disarmament
Conference might be somewhat relaxed. The British Delegation
bad repeatedly said that they favoured the gradual
restoration of equal rights. We had, therefore, to get our
industry into the best possible condition as far as the
manufacture of armaments was concerned, by increasing its
output by enabling it to meet competition.

As I say in paragraph (c) of this letter, almost every
country was, at that time, making efforts in the same
direction, even those which, unlike Germany, had had no
restrictions imposed on them. Great Britain, France, North
America, Japan, and - especially - Italy were making the
most determined efforts to make sure of a market for their
armaments industry; and I wanted to follow their example in
this particular sphere. In order to do this, there had to be
an understanding between the various departments of Naval
Command Staff to the effect that support must be given to
this industry; and this support took the form of a
considerable degree of secrecy on technical matters and
developments. That is why I explain in paragraph (c) that
secrecy in small matters is less important than maintaining
a high standard and keeping the lead.

I stated in the final sentence that, to sum up, I attached
particular importance to the continued support of the
industry in question by the navy, even after the expected
relaxation of the present restrictions, so that the industry
would command confidence abroad and would find a market.

This had nothing at all to do with Hitler nor with any
independent rearmament on my own behalf.

Q. Can you tell us when, approximately, you drafted these
directives?

A. During the month of January - perhaps at the beginning of
January - we had a conference on the matter, and after that
I had them put in writing.


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