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Q. That would be certainly two to three weeks before this
letter was written?

A. Yes, certainly.

Q. May I ask you now to tell me one thing more in connection
with the relaxation of the existing restrictions, that is to
say the relaxation of the Versailles Treaty, I presume,
through a disarmament conference. You have mentioned that
four times in this Document, so that I assume that was its
basis.

A. Yes, it was. The whole atmosphere at that time, under
both the governments I mentioned, was such that one could
expect an improvement.

Q. And this was the basis for which, to quote a few names
only, Stresemann, Bruning, fought?

A. Yes.

Q. As they felt it their duty to take certain advance
precautions?

A. Yes.

Q. I think there is no need for me to go into further
details. I have read this document again and again, and have
been unable to find any point on which the prosecution could
base the conclusion that you had National Socialist ideas.

I now come to Document C-140. It is Exhibit USA 51, and is
in the Document Book 10-A at Page 104.

A. May I interrupt you please? Would it not be appropriate
that I should say now what I wanted to say to supplement the
statement in Document C-156, regarding aircraft?

DR. SIEMERS: I beg to apologise. It might be practical to
finish with the infringements of the Versailles Treaty
before going on to another subject. I had forgotten that.

The prosecution has submitted Document C-156. It is Captain
Schnitzler's book from the year 1937 and it contains almost
the same infringements as Document C-32, so that that
Document can be disposed of at the same time.

BY DR. SIEMERS:

Q. In addition, it deals with the case of submarines to be
constructed in Holland, with which we
have already dealt; but there is still one point on which I
should like to have your comments; and
that concerns certain preparations in connection with navy
aircraft which might be permitted later.

                                                            
                                                   [Page 93]
                                                            

A. All sorts of preparations had been made in the field of
aviation long before I came into office. A number of
aircraft had been purchased, as I see from this book. They
were put in the hands of a firm called Severa G.m.b.H., a
limited Company, which was known to the  Minister of
Defence. The Versailles Treaty had permitted anti-aircraft
guns, both on ships and on the coast, as was mentioned
yesterday; and for these anti-aircraft firing practice had
to be arranged. The Control Commission had allowed us a
certain number of aircraft to tow the necessary targets.
These aircraft were flown by ex-naval pilots employed by
this company. The company, in turn, was managed by an ex-
naval pilot.

In addition, as we were not allowed to train naval pilots,
or were not allowed to have any naval air arm, we gave a
year's training in the civil aviation school to certain
prospective naval officers before they joined the Navy, and
through this year's training they developed into very good
pilots. Then they joined the Navy and went through their
ordinary naval training.

The aircraft purchased in this way were temporarily in the
possession of Severa.
G.m.b.H., which also had a good deal to do with the Lohmann
affairs and for that reason was dissolved by Minister of
Defence Groner in the summer of 1928. Groner established a
new company with similar assignments in the autumn of 1928.
But he had signed the agreement himself in order to be able
to ensure that the whole affair was properly conducted.

In this company, in addition to their ordinary work, the
naval pilots carried out experiments in connection with the
development of aircraft for a later naval air arm.

We had the Government's permission to manufacture a model of
every type likely to be of use; but we were not allowed to
accumulate aircraft. The Government had expressly forbidden
that. The result was that in the course of years the company
developed a number of aircraft types which would be useful
at a later date, when we were once more allowed to have
them.

In the early period, exercises in the Navy were carried out
by ex-naval pilots. During these exercises the ships learned
how to behave with regard to aircraft. When these young
naval pilots had to take part in such a course of exercises,
they were discharged from the Navy for that period. It was a
matter involving a good many formalities, but it was always
carried out punctiliously.

Q. I may now turn to Document C-140, which is in Document
Book 10-A, Page 104. It is a letter from Reich Defence
Minister von Blomberg dated 25th October, 1933.

THE PRESIDENT: Did you say 1933?

DR. SIEMERS: Yes, Mr. President, Page 104.

THE PRESIDENT: Well, my Page 104 says 1935

DR. SIEMERS: I beg to apologise, but according to my list,
which I got from the British Delegation, it should be on
Page 104.

THE PRESIDENT How is it headed? Is it "Directives for the
Armed Forces in case of Sanctions"?

DR. SIEMERS: Yes. Sanctions are mentioned under Figure I,
but that is not the heading.

THE PRESIDENT: No, but it is signed "Blomberg." It begins,
"Appendix to the Reich Minister for Defence. 7a IIIa."

SIR DAVID MAXWELL FYFE: My Lord, it must be 1933 from the
subject matter. It must be a misprint. I notice that Dr.
Siemers's copy has got 1933, and from the subject matter
dealt with it must be 1933.

THE PRESIDENT: I see. Very well.


                                                   [Page 94]
                                                            

BY DR. SIEMERS

Q. It is a letter from Reich Minister for Defence Blomberg,
dated 25th October, 1933. It is addressed to the Chief of
the Army, the Chief of the Navy and the Reich Minister for
Aviation.

On this Document the prosecution based its accusations that
you, witness, prepared military plans for an armed
resistance which might become necessary in consequence of
Germany's withdrawal from the Disarmament Conference and the
League of Nations. Perhaps you can briefly state your view.

A. I had no previous knowledge of our imminent withdrawal
from the League of Nations. This directive came out 11 days
after we left the League of Nations; and it deals only with
defensive measures in the event of sanctions being applied
against Germany by other powers in consequence of her
departure from the League of Nations.

It says under 2-C: "I prohibit any practical preparations in
the meantime." So, at first, nothing was done in consequence
of this directive; and the Reich Minister for Defence merely
asked for a report from me as to what should be done.

As far as I remember, no practical preparations of any kind
were carried out by the Navy at the time, because the
situation remained absolutely quiet and there was no reason
to assume that there would be any need for defence.

Q. That is probably indicated by the words under (2)A:
"Preparation for defence against sanctions."

It is well known that we left the League of Nations in
October 1933, 11 days before the document was written; and
this fact has been mentioned by the prosecution on Page 257
of the record.

We now come to Document C-166. This is Exhibit USA 48.

DR. SIEMERS: Mr. President, this is in Document Book 10, on
Page 36. It is a document dated 12th March, 1934. It
emanates from a Naval Command Office and refers to the
preparation of auxiliary cruisers for action. The
prosecution has quoted only the first two paragraphs of this
document; and it has pointed out that it shows that
auxiliary cruisers were to be built and camouflaged as
transport ships "0".

The two paragraphs sound incriminating, but this can very
easily be disproved. May I refer to Lohmann's affidavit,
Document Raeder 2, Volume 1, Page 5 of my document Book. I
refer to paragraph 2. I quote:-

  "Document C-166, submitted to me as a communication from
  the Naval Command Office and dated 12th March, 1934,
  deals with the preparation of auxiliary cruisers for
  action; which, as stated in the document, were to be
  indicated as transport ships '0'. These ships were not to
  be newly constructed but were to be selected from the
  strength of the German merchant navy in accordance with
  the specifications given in the document; and were to be
  examined as to their suitability for the tasks to be
  assigned them. Then plans were made for reconstruction in
  case of necessity, but the ships remained in the merchant
  navy."
  
May I state at this point that in the English translation
the word "Umbau" appears as "reconstruction". I have my
doubts as to whether this is quite correct. I presume that
the interpreter has now translated it in the same way. As
far as I know the German word "Umbau" only means much the
same thing as the English word "changes."

I continue to quote:-

  "The order to select such ships from German shipowners
  was received by various Naval Command Offices, including
  that of Hamburg, where I was serving at the time."
  
Thus far Admiral Lohmann.

BY DR. SIEMERS:

Witness, is Lohmann's statement correct? Have you anything
to add?

                                                   [Page 95]

A. No, I can only emphasize again that there was no question
of immediate construction but only of selecting suitable
ships and examining them with a view to ascertaining the
alterations necessary to enable them to function as
auxiliary cruisers in the case of a general mobilization.
The preparation of the plans and the plans themselves were
to be ready by 1st April, 1935, as laid down in (12). They
were to be submitted to the naval administration, so that in
the case of mobilization, the ship concerned could be taken
off the strength of the merchant navy and converted.

All these proposals for mobilization were, of course, kept
secret.

DR. SIEMERS: I believe, gentlemen of the Tribunal, that the
whole mis-understanding would not have arisen if the
prosecution had translated two further paragraphs. The
English version is very short and (II) is missing. I quote
the text thereof:-

  "It is requested that in co-operation with 'K', first of
  all suitable vessels should be selected and the number of
  15-cm guns which must be mounted to achieve the required
  broadside be determined," and so forth.
  
The word "selected" is used here; so that the intention is
not-as the prosecution asserts-the building of auxiliary
cruisers but the making of a selection from merchant
vessels.

THE WITNESS: Yes; and the ships continued to sail in the
service of the merchant marine.

DR. SIEMERS: The second sentence which I find to have been
unfortunately omitted from the English translation reads as
follows:-

  "As long as only a restricted number of guns" - Page 24 -
  "can be placed at our disposal for this purpose,
  preparations are to be tried out for only four transport
  ships. An increase of this number to six will be
  postponed to a date when more guns are available. By that
  time we shall have some experience in regard to the
  preparation of the first auxiliary cruisers."
  
The fact that only four, or at the most six, merchant navy
vessels were involved shows the insignificance of the whole
matter.

I now come to Document C-189, Exhibit USA 44. It is in
Document Book No. 10 of the British Delegation, Page 66.

I should like your comments. I beg your pardon; I should
remind you that this concerns the conversation between Grand
Admiral Raeder and the Fuehrer aboard the Karlsruhe in June
1934.

Grand Admiral, will you please state your views on the three
points mentioned in this brief document, which you discussed
with Hitler in June 1934.

First: Why was Hitler unwilling to reveal the increase in
displacement of D and E, the Scharnhorst and the Gneisenau,
when, according to this document, these were defensive
weapons and every expert would notice the increased tonnage
of these ships and, as I know, did notice it?

A. At that period we were considering what we could do with
the two armoured ships D and E, after the conclusion of the
impending naval pact with England - i.e., the two ships
which Hitler had granted me for the Navy in the 1934 budget.
We had definitely decided not to continue building these
armoured ships as such as we could make better use of the
material at our disposal.

Q. But surely you realised that every expert in the British
or American or any other Admiralty on a trip would see as
soon as he sighted the ship, that the 10,000 tons had now
become 26,000?

A. Yes, of course.

THE PRESIDENT: Dr. Siemers, when you are examining a witness
directly, you ought not to put leading questions which put
into his mouth the very answer that you desire. You are
stating all sorts of things to this witness and then asking
him, "is not that so?"


                                                   [Page 96]


DR. SIEMERS: I beg your pardon. I shall make every effort to
put my questions differently.

THE WITNESS: My answer is different anyway.

BY DR. SIEMERS:

Q. Yes?

A. We are dealing here in the first place with plans. I
asked permission to revise the plans for these two armoured
ships, first, by strengthening their defensive weapons, that
is the armour plating and underwater compartments, and then
by increasing their offensive armaments, namely, by adding a
third 28-cm. - instead of 26-cm. gun turret. The Fuehrer was
not yet willing to sanction a new 28-cm. gun turret because,
as I said before, he did not in any circumstances want to
prejudice the negotiations going on with Great Britain. To
begin with, therefore, he sanctioned only a medium
displacement of 18,000 to 19,000 tons; and we knew that when
matters reached the stage where a third 28-cm. gun turret
could be mounted, the displacement would be about 25,000 to
26,000 tons.

However, we saw no cause to announce it at this stage,
because it is customary in the Navy that new construction
plans and especially new types of ships should be announced
at the latest possible moment. That was the principal
reason; and apart from that, Hitler did not want to draw the
attention of other countries to these constructions by
giving the figures mentioned or stating the very high speed.
There was no other reason for not announcing these things.

Q. I should like your comments on (2) of the Document. That
has been specially held against you by the prosecution,
because there you state the view that the fleet must be
developed to oppose England later on.

A. At first, as I shall explain later, we had taken the new
French ships as our model. The French Navy was developing
the Dunkerque class with eight 33-cm. guns and a high speed;
and we took that as our model, especially as in Hitler's,
opinion - as you will hear later - there was no question of
arming against England. We intended to reconstruct these two
armoured ships on this pattern as battleships with nine z8-
cm. guns and capable of a high speed. But then we heard that
the King George class was being designed in England with
35.6-cm. guns, and therefore more powerful than the French
type; and so I said, "We shall, in any case, have to depart
from the French type later on and model ourselves on
England, which, is now building ships with 35-cm- guns."

There is an error in the translation, namely: "oppose
England." It says in my text, that developments should
follow the lines of British developments - in other words,
that we should design vessels similar in type to the English
ships. But they were out of date, too, shortly afterwards,
because France was now building ships of the Richelieu class
with 38-cm. guns. Therefore, we decided that we, too, would
build ships with 38-cm. guns. That was how the Bismarck care
to be built; the word "oppose" has no meaning at a time when
we were aiming at an agreement with Britain which would lead
to our being no match for her in any circumstances.

Q. Now we come to point 3 of this Document, which the
prosecution regards as equally important, I quote:
  
  "The Fuehrer demands complete secrecy with regard to the
  construction of U-boats, in consideration, also, of the
  Saar plebiscite."
  
A. I have already referred to the Fuehrer's wish for secrecy
in connection with both the construction of submarines and
the preparations for that construction. This is one of the
points on which he was most sensitive, because in no
circumstances did he wish to prejudice the negotiations. He
himself was extremely cautious generally during this period
and would not in any circumstances do anything which might
sabotage the naval pact which he was so anxious to conclude.


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