Archive/File: imt/tgmwc/tgmwc-14/tgmwc-14-134.02
Last-Modified: 2000/03/16

Q. You say that does not offend you as a description. That
is all I wanted to get clear. I do not want to spend a great
deal of time.

A. But the headings mean nothing.

For instance, it might say in the actual text that the Navy
did not fit into the National Socialist State properly. I do
not know. The same holds good of the fleet. Of course -

Q. I am not going to waste time on it. There were three
matters which you dealt with in your examination-in-chief,
and I am not going to deal with them in detail; but I just
want to remind you of them and put one general question. You
can put that document away; I am not going to pursue it
further. (A short pause). Would you mind putting that
document away and giving me your attention for the next
question?

You were asked about the E-boats, your survey list, that
long document, in September 1933, and the question of
disguised auxiliary cruisers as transport ships O. Is this a
fair summary of your answer: that you admitted that these
breaches of the Treaty took place, but said in each case
that the breach was only a little one. Is that a fair
summary of your answer? Is it?

A. No.

Q. Now, let us take it in bits, then. Are you disputing that
any of these matters with regard to the E-boats, the matters
on the survey lists or the transport ships O-are you
disputing that any of these matters took place? I understood
you admitted they all did take place -

A. No, but they took place in the way I described. For
instance, these auxiliary cruisers were not built. We were
not allowed to do that. We were allowed to make plans and we
were allowed to select those ships which, in the event of
war - if a war had broken out in which Germany was attacked
by another State - could have been used as auxiliary
cruisers. That was not a violation. If it were I would admit
it. The U-boat design office in Holland was not a violation
of the Versailles Treaty. The wording was quite different; I
do not remember the third case which you mentioned.

Q. Now, you remember there was a long list in your document.

A. Yes, of course.

Q. And I understood, maybe wrongly, that you admitted these
things took place, but you said, "the breach is only a
little one."

A. Yes, of course. Those were small things, but they were
urgently necessary in Germany's defence interests.

Q. Now, I want to ask you about an officer of yours, Vice-
Admiral Assmann. Was he an officer in whom you had
confidence?

A. He was a very able historian.

Q. Will you answer my question? Was he an officer in whom
you had confidence?

A. I had confidence that he would write history correctly.

Q. That is all I wanted. Now, would you have a look at a new
document, D-854, which, my Lord, will be Exhibit GB 460.
Now, that is an extract from one of a series of essays on
the operational and tactical considerations of the

                                                  [Page 187]

German Navy and consequent measures taken for its expansion
between 1919 and 1939, contained among the files of Vice-
Admirals Assmann and Gladish, who were in the historical
section of the German Admiralty.

Now, would you mind not looking at it for a moment,
defendant? I want to ask you some questions and then you can
look at it with pleasure afterwards. Do you agree that in
nearly all spheres of armament where the Navy was concerned,
the Treaty of Versailles was violated in the letter and all
the more in the spirit? Do you agree with that?

A. No, by no means in every sphere. In the most important
sphere we were far behind the Versailles Treaty, as I
explained to you very clearly. Possibly we infringed it in
the other direction by not doing as much as we could have
done.

Q. Will you just look at this document. At the beginning,
the first quotation, your officers say:-

  "That - as was stated - in nearly all spheres of armament
  where the Navy was concerned, the Treaty of Versailles
  was violated in the letter and all the more in the spirit
  - or at least its violation was prepared - a long time
  before the 16th of March, 1935 ... "

Are your admirals wrong in stating that? Is that what you
are telling the Tribunal?

A. May I please see which page this is on? I have not seen
it yet. Yes, he says:-

  "in nearly all spheres of naval armament ... "

That is not the case, for in the sphere of -

Q. That is what I put to you; is that right?

A. No, it is not eight. We had not even built as many ships
as we could have built, but - as I have explained
repeatedly, the violations were concerned with -

Q. You have explained that.

A.  - violations were -

Q. Really, we do know the position of your shipbuilding
yards. You have given that explanation and it is a matter of
discussion whether it is of any value. I am not going to
argue with you. I am asking you this question: Are you
saying that the admirals of your historical section are
wrong in that sentence that I read out to you?

A. Yes, I am stating that. It is wrong as it stands.

Q. I see. Well, now let us pass on - the Tribunal will judge
that - to the statement of Admiral Assmann. It goes on:-

  "This probably took place in no other sphere, either so
  early, or under such difficult circumstances, as in the
  construction of a new submarine arm. The Treaty of
  Versailles had only been in force a few months (since
  10th January, 1920), when it was violated in this point."

Do you agree with Admiral Assmann on that?

A. No, he is wrong. It was not violated at all in this
point, and the reason it started so early was because all
the ex-U-boat commanders and U-boat officers and technicians
were out of a job and offered their services to maintain
technical developments in U-boats abroad; that is why it was
so early. But that has nothing to do with me because I had
no say in these matters then. At that time I was working on
the Navy archives.

Q. Well, how are you able to be so confident today that
Admiral Assmann is wrong? I thought you said that he was a
good historian. He had not to go back very far. He only goes
back twenty years.

A. A good historian can make mistakes, too, if his
information is wrong. I merely said I had confidence in him
-

Q. Well, let us just see how far he was wrong. We need not
go into the first paragraph, which deals with shipbuilding
for Japan, but take the second one. Do you see the paragraph
which begins,

  "As early as 1922, three German shipbuilding yards
  established a German U-boat design office in Holland
  under a Dutch cover name, with about thirty

                                                  [Page 188]

  engineers and builders. In 1925 a Dutch shipbuilding yard
  built two 500-ton U-boats for Turkey according to the
  plans of that office, which enjoyed the financial and
  personal support of the Naval Command. In this matter,
  too, Captain Lohmann was responsible for final
  decisions."

Is that right?

A. We have admitted that. That was in no way a violation of
the Versailles Treaty.

Q. We will not argue that, but it is right anyway. Admiral
Assmann is right about that. There he deals with Finland and
with Spain. And, if you look at the end of the paragraph,
after dealing with Spain, he says:-

  "In the autumn of 1927 the Naval Construction Department
  was commissioned to carry out construction in Spain by
  the Chief of the Naval Command, Admiral Zenker, who
  accepted the responsibility despite all the difficulties
  in the field of home politics. The working out of the
  project and the drawing up of the construction plans took
  place in the Dutch Bureau. After completion in 1931, the
  ship carried out trial runs and diving exercises from
  Cadiz to Cartagena, under German direction - "

A. Yes-

Q. "and with German personnel, consisting of officers,
engineers, naval construction students and foremen."

That is all. That is quite right, is it not?

A. Yes, but the shipbuilding designer from our Designing
Office, in particular, as well as the above-named other
persons employed on U-boat construction, were discharged
from the Navy.

Q. And just look at the last sentence

  "This boat which is now the Turkish submarine Guer became
  the prototype for the U-25 and U-26."

A. Yes.

Q. Now, the 250-ton submarines which were made in Finland.
And, if you look at the last sentence of the next paragraph:-

  "The Finnish U-boat was the first U-boat plan to be
  worked out in Germany and successfully carried out; the
  Dutch office was called upon only to work out the
  details. The Finnish 250-ton vessel became the prototype
  for U-1 to U-24 - "

A. Yes.

Q. And now the next paragraph:-

  "The building and the thorough trial of the prototype
  vessel made it possible to obtain the parts for U-1 to U-
  24 in 1933 to '35, long before the order for the assembly
  of the vessels; and the latter was prepared beforehand as
  far as was possible without endangering secrecy."

A. Yes.

Q. Now, would you turn to Page 156. You see where the next
quotation is from.

  "At the beginning of 1935" - that is six months before
  the Anglo-German Treaty - "there were probably Six 250-
  ton boats ready for assembly, six 275-ton and two 750-ton
  boats on which preparatory work was being done. About
  four months were needed for assembling the small ships
  and about ten for the big ones, dating from 1st February,
  1935, but everything else was still quite uncertain."

Now, look at the next words

  "It is probably in this very sphere of submarine
  construction that Germany adhered least to the
  restrictions of the German-British Treaty.
  
  Considering the number of U-boats which had already been
  ordered, about fifty-five U-boats could have been
  provided for up to 1938. In reality one hundred and
  eighteen were ready or ordered.
  
  The preparations for the new U-boat arm were made so
  early, so thoroughly and so secretly, that as early as
  eleven days after the conclusion
  
                                                  [Page 189]
  
  of the German-British Naval Treaty, which permitted the
  construction of U-boats, the first German V-boat could be
  put into commission on 29th June, 1935."

Now, take that sentence, which is written by Admiral
Assmann, and we have seen what your connections with Assmann
were through about one hundred documents. He said:-

  " It is probably in this very sphere of submarine
  construction that Germany least adhered to the
  restrictions of the German-British Treaty."

Now, you have told this Tribunal, during several hours of
your evidence, that that was a freely negotiated treaty, of
which you were very proud, and which you were ready to
support. Are you telling the Tribunal that your admirals are
wrong in saying that in submarine construction Germany least
adhered to the restrictions of that freely negotiated
treaty?

A. That is a completely erroneous conclusion. I have stated
here that, as long as no negotiations with Great Britain had
taken place with regard to the pending treaty, all the
preparations which we did make were exclusively attended to
abroad - that in the proportion which probably -

Q. Defendant, you can make your explanation -

A. Will you please stop interrupting me.

Q. We will take it in this order, and do not get cross about
it. You answer my question, and then you make your
explanation. Now answer my question first. Are you saying
that Admiral Assmann is wrong in saying in that first
sentence: "That it was just in the sphere of submarine
construction that Germany least adhered to the restrictions
of the German-British Treaty"? Is Admiral Assmann wrong when
he says that, is that what you are telling the Tribunal?
Well, that is my question.

A. He is wrong. I said so; I have already said so.

DR. SIEMERS (Counsel for defendant Raeder): Mr. President, I
believe these are not questions relating to facts. They are
questions for legal decisions. It is a legal argument as to
just how Article 191 of the Versailles Treaty is to be
interpreted.

THE PRESIDENT: The Tribunal thinks that the question is
quite proper. In his explanation, of course, he can explain
that in his view it was not a breach of the treaty and he
has already explained that. He can give us his opinion about
it. He was the head of the German Navy.

BY SIR DAVID MAXWELL FYFE:
Q. Well, now, will you take the second sentence -

A. But I should like to finish, if I may. I wish to explain.

All these things were preparations made outside Germany. The
point under discussion is whether the Finnish U-boats were
constructed with the help of German designers. That is true.
German designers were not forbidden to help Finnish
designers to draft designs for U-boats. It is also true that
this U-boat later -

Q. I am awfully sorry to interrupt you, but you know this is
not dealing - this sentence is not dealing with this early
period. This is dealing with the period after the Anglo-
German Treaty in 1935 and that is what I want you to answer
me about. This Finnish matter was long before that.

A. I am still speaking of the period preceding the
agreement, for I was accused of manufacturing U-boat parts
abroad. And the fact is that -

Q. Yes, I know, but do you not see that -

A. I have not given my answer yet. No -

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