Archive/File: imt/tgmwc/tgmwc-14/tgmwc-14-135.04
Last-Modified: 2000/03/17

DIRECT EXAMINATION

BY DR. SIEMERS:

Q. Witness, please tell the High Tribunal what role you
played up until the year 1933 in the Social Democratic Party
and the principal ministerial posts you held up until the
year 1933.

A. At the age of sixteen and a half I entered the labour
union movement and when I was eighteen years old I entered
the Social Democratic Party. As a result I held honorary
positions in the party at a relatively early age.

In the year 1905 I was counsellor in the City of Bielefeld.
I was member of the Reichstag from 1907 until 1912 and I
again became a member of the Reichstag and at the same time
a member of the Prussian Diet in 1919. I was in the
Reichstag and in the Prussian Diet until 1933. I was
Minister in Prussia from 1920 until 1921; then again from
1921 to 1926, and from 1930 until 1933. In the meantime from
1928 until 1930 I was Reich Minister of the Interior.

Q. When and why did you leave public life?

A. I retired from official public life in July 1932, and
from political life when the Social Democratic Party was
prohibited.

Q. Were you arrested because of your leaving public life in
1933, or perhaps at a later date, and, if so, at whose
order?

A. I was arrested on the very same day on which the Enabling
Act was scheduled to be read and passed in the Reichstag.
The order for my arrest was signed by the then Minister of
the Interior, Herr Goering, who at that time was also
President of the Reichstag and who, if I may express an
opinion, should have had the obligation, as President of the
Reichstag, of ensuring the immunity of the members of the
Reichstag. Under a breach of this immunity I was arrested
the moment I entered the Reichstag building.

                                                  [Page 250]

Q. But you participated in the vote on the Enabling Act?

A. The Board of the Social Democratic Reichstag faction had
complained to Goering about the treatment to which I was
subjected, with the result that I was given leave to vote.
But the voting had already come to a close. However,
Reichstag President Goering still permitted me to give my
"no" vote for the Enabling Act.

Q. You were arrested thereafter, but held for only a very
short time?

A. On the next day I had to be present for a further
interrogation. I was permitted to leave Berlin on the second
day and was instructed to be ready at my home in Bielefeld
for further interrogations.

Q. Despite your well-known anti-Nazi position, you were not
arrested later and put in a concentration camp, if I am not
mistaken.

A. I was never in a concentration camp, thanks to the
respect - and I say this with all modesty - which the old
Prussian officials, my previous subordinates, had for me. At
the end of October, 1933, I heard from the Police Chief in
Bielefeld that trouble was brewing. The police notified me
that they would not be able to give me any protection and
advised me, therefore, to leave Bielefeld for several
months. I followed this advice, and from October, 1933 until
the end of March, 1934, I lived in Berlin under a false
name. I first stayed with friends, and then I went to a
small Jewish sanatorium in Wannsee. I had reason to fear
another arrest in August, 1944, as, according to someone
whom I knew in the police, my name was on a list of people
who were to be arrested summarily - men and women who were
suspected of having plotted against Hitler in July, 1944.

THE PRESIDENT: Did you say '44 or '34?

DR. SIEMERS: '44. After the attempted assassination of
Hitler of July, 1944.

THE WITNESS: May I continue?

BY DR. SIEMERS:

Q. Please do.

A. After the attempted assassination of Hitler, orders were
given to the police to arrest certain people. My name was on
the Bielefeld list. Then a police official whom I knew from
the past pointed out that I was close to my seventieth year
and had lost my son in the war. Thus he succeeded in having
my name taken from the list.

Q. Aside from the things you have just pictured to us now,
did you suffer any further at the hands of the National
Socialists?

A. Well, I was considerably hindered in my movements. I was
not especially surprised that my mail was censored and my
telephone tapped. I considered that as a matter of course.
But I could not even take a trip without being followed and
watched by the police.

If you don't mind, I should like to call your attention to
the fact that in addition to material damages there is also
moral damage (ideelle Schadigungen), and in this respect I
suffered a great deal at the hands of the National Socialist
Party after it assumed power. A political measure, taken in
connection with the polls of 1932, was used against me, I
might say, in a criminal way. They talked about me and my
friend Braun as the "Thieves of millions", and this epithet
was also applied to the members of my family.

THE PRESIDENT: Dr. Siemers, is this witness going to give
any evidence which has relevancy to the defendant's case?

DR. SIEMERS: Yes.

THE PRESIDENT: Well, bring him to it then as quickly as
possible.

DR. SIEMERS: Very well.

                                                  [Page 251]

BY DR. SIEMERS:

Q. Herr Severing, try to be as brief as possible in this
connection. It is of course true that you suffered moral
damage as well, but as the basis of my examination and your
testimony, I would like to ascertain whether serious harm
was caused to you and I would like to have you tell us, but
briefly, whether National Socialism -

THE PRESIDENT: Dr. Siemers, what relevancy has this got to
Raeder's case?

DR. SIEMERS: Mr. President, my intention is to show that
Herr Severing, after a brief description of his life during
Nazism, can, without bias, give entirely objective answers
in reference to Raeder. Since he had no advantages but
rather disadvantages at the hands of the Nazis and on the
other side -

THE PRESIDENT: Well, you have dealt sufficiently with the
disadvantages now. Go to the matter which relates to Raeder.
He has given us, from 1933 to 1944, a fairly general account
of his life and that ought to be sufficient.

DR. SIEMERS: The prosecution accuses the defendant Raeder,
that in his capacity as Commander-in-Chief of the Navy he
violated the Treaty of Versailles, with the intention of
carrying on aggressive wars; and that behind the back of the
Reich Government. In order to shorten the testimony, I would
like to mention that it is an undisputed historical fact
that Germany, in developing her Navy, transgressed the
stipulations of the Versailles Treaty. All that is known to
the Tribunal. Even before this time, the government demanded
the construction of armoured cruiser "A" within the compass
of the Versailles Treaty. A great political conflict arose
over the construction of this cruiser and, in connection
with a debate before the Reichstag on the matter, the
witness made a speech. I have a brief excerpt from this
speech which I should like to submit to you. It will be
Exhibit Raeder 5, and is in Document Book I, Page 13. This
is an extract from a speech by the former Reichsminister,
Karl Severing, to the German Reichstag on 20th January,
1928.

BY DR. SIEMERS:

Q. Witness, at this period of time, you were not a minister,
but you made this speech as a member of the Reichstag -
representative of the Social Democratic Party?

A. Yes, that is correct.

Q. The extract reads:

   "Now the armoured cruiser. The fact that a government,
   which knows precisely what gigantic sums we must raise
   during the coming year, should make such demands, is, to
   say the least, quite surprising. It says, the Peace
   Treaty permits it - yes, but the Peace Treaty also
   decrees the payment of reparations. The 93 million marks
   demanded for this year will play their decisive part
   only in the consequences entailed which would require
   the raising of several hundred million marks, which,
   during the next few years, seems to me absolutely
   impossible. Considering the development of weapons for
   naval warfare, I am not convinced of the military value
   of armoured cruisers. It may be that they are the
   backbone of the defence at sea, as the government says.
   But, to form an active fighting unit (Gefechtskorper), a
   backbone must also be made up of other vertebrae, of U-
   boats and airplanes, and as long as we are not allowed
   to build these, armoured cruisers are of very little
   value even for defence."

Is that extract from the speech correct?

A. Yes, that extract is reproduced correctly.

Q. Is it right to conclude here that the Social Democrats
and you, personally, at that time were of the opinion that
the army granted Germany by the Versailles Treaty might not
be sufficient even for a defensive war?

A. That is correct.

                                                  [Page 252]

Q. Will you please comment on that a little more
extensively.

A. That the 100,000 army granted to Germany was not
sufficient even for a defensive war was and is known
possibly to everyone in Germany concerned with political
affairs. Germany had arrived at a very bad situation with
regard to her Eastern neighbours since the establishment of
the Corridor. The insular position of East Prussia forced
Germany even at that time to take measures which I
reluctantly helped carry out; but the population of East
Prussia had a right to be protected against attacks which
were threatening from the East. I am not speaking about an
aggressive war, and I am not speaking of any plans of the
Polish Government, but I would like to refer you to the fact
that in the years 1919, 1920 and 1921, there were aggressive
groups in Poland who set foot on German soil, possibly with
the idea of -

THE PRESIDENT: Dr. Siemers, this evidence is all a matter of
argument. Not only is it a matter of argument, but we have
had it over and over again from nearly all the defendants
and a good many of their witnesses, and, surely, it is not
assisting the Tribunal in the very least to know what this
witness said in 1928, or what view he took in 1928.

DR. SIEMERS: May it please the High Tribunal, I believe that
what follows will, on the contrary, assist the Tribunal.
Herr Severing ' was a member of the government that held
this cabinet meeting of 18th October, 1928. I agree with the
High Tribunal that this matter has been discussed frequently
- but I should like to point out that Sir David, even
yesterday, in cross-examination, accused the defendant that,
against the will of the Reich Government and against the
wish of the organizations and despite the testimony of
Raeder, he had violated the Treaty of Versailles. If,
therefore, despite the testimony of Raeder, the prosecution
persists in its opinion, the only way in which I can prove
the incorrectness of this opinion is by questioning a
witness who -

THE PRESIDENT: The question whether the Treaty of Versailles
was violated is a question of fact and, of course, upon that
you can give evidence and you did give evidence through the
defendant Raeder; but this witness is not talking about the
question of fact. He is arguing that Germany was entitled to
defend herself in violation of the Treaty of Versailles.
That is what I understood his evidence to be and that is a
question of argument, not a question of fact.

DR. SIEMERS: Mr. President, as far as I know juridically -

THE PRESIDENT: Dr. Siemers, the class of evidence which has
just been given by this witness will not be listened to by
the Tribunal. If you want to prove facts by him, you can
prove them, but you cannot prove arguments or his views upon
arguments.

BY DR. SIEMERS:

Q. Could Germany with her army protect herself against
Polish incursions in Silesia?

A. In the year 1920, the army would not have been able to
protect Germany in East Prussia; therefore, it was necessary
to protect the population of East Prussia, and this was
achieved by my personally agreeing that all weapons which
were found in East Prussia were to be given to the
population. Under conditions which applied at that time, it
was, even for purposes of inspection, very hard to pass
through the Corridor by rail; so that in 1920, I had to make
a tour of inspection by way of water from Stolpmuende to
Buelau. I am mentioning this fact to show the difficulties
of transportation through the Corridor. In 1920 and 1921, it
was not possible for the German Army to prevent attacks of
Polish insurgents in Upper Silesia, and, I am sorry to say,
and I emphasize "I am sorry," that certain defence measures
had to be taken in order to protect German life and German
property.

                                                  [Page 253]

Q. Witness, were Reich Minister Groner's rearmament measures
after January, 1928, as far as you know, based on defensive
or offensive ideas.

A. As far as I am acquainted with Groner and his own
personal way of carrying on his office, everything that he
conceived and carried out was in view of defence.

Q. Then this should also apply to the armoured cruiser "A".
I should like to know why the Social Democratic Party, which
was interested in the idea of defence, was against the
building of this cruiser.

A. In 1928 the Social Democratic Party was against the
building of the cruiser, because the economic situation did
not warrant expenses which were not absolutely necessary.
The Social Democratic Party wanted to prove and to show that
they did everything within their power to make the much
discussed disarmament a reality. They did not believe that
the building of an armoured cruiser would be a favourable
gesture for the bringing about of appropriate negotiations.

Q. On 28th June, 1928, a new Reich Government was formed.
Muller was Chancellor; Stresemann was Foreign Minister, and
you were Minister of the Interior. What position did your
government take to the pending problem of disarmament by all
countries as stipulated in Versailles, or to the pending
problem of armament by Germany?

A. I had just made a reference to this problem. We were of
the opinion in the Social Democratic Party even after
entering the Muller government, that we would have to use
all our efforts in order to solve this very problem. In
September, 1928, Chancellor Muller, replacing the Foreign
Minister Stresemann, who was ill, went to Geneva in order to
bring this problem before the League of Nations. Muller made
a very resolute speech which, if I remember correctly, was
received very coolly by Allied statesmen; so that any
practical suggestions for the realization of disarmament
could not be hoped for in the near future.

Q. Witness, in July, 1928, you spoke with Reich Defence
Minister Groner about the budget and, specifically, about
the fact that secret budgets of the Wehrmacht, on the
armoured cruiser and so forth, had become known. What
attitude did you take in this connection and what were the
results following your agreement with Groner?

A. In order to answer this question, I would like to touch
again on the extract from my speech, which you just
submitted to the High Tribunal. In the same Reichstag
session in which I gave this speech, the Reichswehr Minister
Groner appeared for the first time as successor of Gessler.
I had said a few farewell words in honour of Gessler, who
was leaving. I greeted the new minister with the remark that
my political friends would show him respect, but that he
would have to earn our confidence first. It was probably
while thinking of this remark that Groner came up to me in
the first session of the Muller government and said that he
was looking forward to a sincere collaboration with me. I
quoted a passage from "Iphigenie" on that occasion: "May
there be truth between us." Only complete sincerity would
make possible fruitful co-operation, I said.

THE PRESIDENT: Dr. Siemers, the Tribunal thinks that this is
an absolute waste of time, and this speech of the witness is
entirely irrelevant. Why do you not ask him some questions
which have some bearings on the case of Raeder?

DR. SIEMERS: Mr. President, may I remind you that the
prosecution has made the accusation that the rebuilding
followed by means of a secret budget, and that a secret
rearmament was carried on with the idea of starting wars of
aggression later on. It is not quite clear to me how I can
cross-examine him in any other way than by asking him how in
his government these secret budgets, which to an extent are
practically identical with violations of the Versailles
Treaty, were dealt with. That is exactly what I have just
questioned the witness on.

THE PRESIDENT: This speech that you have drawn our attention
to is simply a speech in which he said that he did not think
that armoured cruisers were of any use. That is the only
meaning of the speech, except in so far as it refers to the
fact that reparations had not been paid. For the rest, it
simply says that armoured cruisers, in his opinion, are of
no use.

                                                  [Page 254]

DR. SIEMERS: Mr. President, I may not and do not wish to
make a plea here. In the speech which I read, something else
is said. It says there that the Social Democratic Party was
against the building of this armoured cruiser, because of
economic reasons, and not because of strategic reasons, and
that if an armoured -

THE PRESIDENT: What has that got to do with a charge of
making an aggressive war in 1939?

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