[Page 315]

I shall read the German text which, in my opinion, differs from the English translation.

"The Commander-in-Chief of the Navy states: Conquest of Belgian coast provides no advantage for our submarine warfare; points out value of winning Norwegian bases (Trondhjem) with the help of Russian pressure. The Fuehrer will consider the question."

DR. KRANZBUHLER: I beg your pardon, I did not know that it was to be examined again.

THE PRESIDENT: I think we had better have it examined and then the translation certified to.

DR. KRANZBUHLER: I beg your pardon, Mr. President. I, myself, have a question to put to the witness.

[Page 316]

Q. Admiral, Document D-873 has been put to you before. That was a War Diary of U-71, and concerned the supplying of three Norwegians in a lifeboat. The entry was on 21st June. I have already submitted to the Tribunal under Donitz 13, on Page 23 of my Document Book, a statement by the above-mentioned Commanding Officer Flachsenberg. According to that statement, this submarine put to sea on 14th June. It was west of Norway. Can you tell me if that U-boat, therefore, on 21st June, was putting out for operations or returning from operations?

[Vice Admiral Erich Schulte-Monting] A. You mean from memory?

Q. No, you have the dates: put out to sea on 14th June; and the entry was on 21st June.

A. The answer is putting out.

Q. Putting out. As you know, this submarine was a 500-ton vessel. Is a boat of that size in a position to carry out an operation over several weeks with three additional people on board?

A. I believe not. I am not enough of an expert to be able to judge definitely what the extra weight of additional persons on board might mean as far as trimming experiments and such things are concerned; but, apart from that, I do not believe that such a small boat, which is putting out to sea for an operation, can load itself on the way with prisoners. I do not consider that possible.

DR. SIEMERS: Then, with the permission of the Tribunal, the witness may retire.

THE PRESIDENT: The witness can retire.

DR. SIEMERS: Mr. President, in accordance with my intention, as stated at the beginning of this case, I have submitted the majority of my documents during the examination. With the permission of the Tribunal, may I proceed now to submit as quickly as possible the remainder of the documents with a few accompanying statements.

I submit to the Tribunal Exhibit Raeder 18, an excerpt from the Document Book II, Page 105 an excerpt from a book which Churchill wrote in 1935, called Great Contemporaries. I ask the Tribunal to take official notice of the contents. Churchill points out that there are two possibilities; that either Hitler will be the man who will start another world war, or he will be the man who will restore honour and a sense of peace to the great German nation, and bring it back serene, helpful and strong to the forefront of the European family of nations.

As Exhibit Raeder 20, I submit a short excerpt from Adolf Hitler's Mein Kampf, with reference to the fact that the prosecution has said that from that book one could see that Hitler intended to wage aggressive wars. I shall show in my final pleadings how much one can see from that book. I ask that the Tribunal take judicial notice of the short excerpt on Page 154: "For such a policy there was but one ally in Europe, England."

Exhibit Raeder 21, a speech made by Hitler to the German Reichstag on 26th April, 1942, is to show how freedom became even more strictly limited in Germany, and the dictatorship even more powerful.

Document Book IV, Exhibit Raeder 65, intended to facilitate my arguments, is the Hague Agreement about the rights and duties of neutrals in case of naval warfare. I need that for my final pleadings in connection with Exhibit Raeder 66, the statement of opinion by Dr. Mosler in Document Book IV, Page 289, the first document.

THE PRESIDENT: Can you give us the pages?

DR. SIEMERS: Page 289, Mr. President. It is the first page of the Document Book IV.

THE PRESIDENT: Yes.

[Page 317]

I now submit Exhibit Raeder 102, in the same Document Book, Page 449. This is an order of the Second Belgian Infantry Regiment of 13th April, 1940, concerning information about friendly troops and the plan of a fortified position. It can be seen from the document that the friendly troops mentioned are the Allies.

Then I submit Exhibit Raeder 103, Page 452, which is a French document from Headquarters, of 16th April, 1940, concerning measures about the rail transportation of French troops into Belgium.

I ask the Tribunal to take judicial notice of all of these documents, which I shall not read in detail.

The same applies to Exhibit Raeder 104, Document Book V, Page 455, which is the order of the Second British Division concerning security measures in Belgium of 9th April, 1940. There we find a directive similar to one in a document which has been submitted by the prosecution, a directive to establish contact with Belgian civilian authorities.

Exhibit Raeder 105 Document Book V, Page 459, is the statement of a Luxembourg citizen which shows that 200 men, French soldiers in uniform, entered Belgium in armoured cars seven days before the outbreak of the German-Belgian hostilities.

May it please the Tribunal, I originally intended not to submit anything in this trial concerning the character of my client, because I was of the opinion that Grand Admiral Raeder, both at home and abroad, enjoyed sympathy and respect. The first trial brief against Raeder did not affect that intention. Shortly before the presentation of that trial brief, it was changed, becoming considerably more severe and containing moral accusations which seriously inure and impugn Raeder's honour.

I have no doubt that the High Tribunal will understand why under these circumstances, I ask to be permitted to submit some of the documents granted me which concern Raeder's character.

I submit Exhibit Raeder 119 Document Book VI, Page 514. That is a letter from Frau von Poser addressed to me. It is not an affidavit and quite purposely I have submitted the original because, in my opinion, it will make a more immediate and direct impression than an affidavit which I would first have to ask for in my capacity as defendant's counsel.

Similarly, there is a fairly long letter from Professor Dr. Seibt, who also, on his own initiative, approached me. I submit Exhibit Raeder 120 Document Book VI, Page 517. I would be grateful to the Tribunal if it would take judicial notice of that letter. In order to save time, since it is six pages long, I should like to refrain from reading it.

Then I submit Exhibit Raeder 122, Document Book VI, Page 526, a letter from Herr Erich Katz, which I submit with its appendices, and I ask the Tribunal to take judicial notice of it, in order to present one of the cases in which Raeder intervened personally, using his influence and position - he used the official stationery of the Commander-in-Chief of the Navy - in order to intervene on

[Page 318]

As Exhibit Raeder 123, I submit a letter from Gunter Jacobsen that concerns a similar case. Jacobsen, also without my asking it, approached me in order to testify that Raeder rescued his father, who, as a Jew, had been accused of race defilement, from the concentration camp Fuhlsbuttel - I believe it was still a prison at that time - so that Jacobsen could emigrate to England, where he is living now.

I submit as Exhibit Raeder 124, an affidavit -

GENERAL RUDENKO: Mr. President, I must make the following statement. All four exhibits mentioned just now by Dr. Siemers are personal letters from various persons to Dr. Siemers. They are not sworn affidavits. They are not interrogations. Therefore these documents have little probative value, and I wonder whether they ought to be admitted as evidence. Many letters are received, and if they were all to be submitted to the Tribunal, the Tribunal would have great difficulty in establishing the truth, and how far they are of probative value. In that connection, I personally object to the fact that these documents should be accepted as evidence in Raeder's case.

DR. SIEMERS: My Lord, may I -

THE PRESIDENT: The Tribunal does not think that the matter is of sufficient importance to insist upon evidence being upon oath. The documents are admitted.

DR. SIEMERS: Exhibit Raeder 124; I submit an affidavit by Konrad Lotter. The affidavit is very short and with the permission of the Tribunal, I should like to read this one page:

"Grand Admiral Raeder has always appeared to me a man who embodied the finest traditions of the old Imperial Navy. This was true, particularly in regard to his philosophy of life. As a man and as an officer, he was at all times the best model imaginable.

In 1941, when the anti-Christian policy of the Hitler regime began with its full might in Bavaria, when cloisters were closed, and in the education of the youth, intolerance against every creed became crassly manifest, I sent a memorandum of twelve pages to the Grand Admiral, in which I presented to him my objections to this policy. Grand Admiral Raeder intervened at once. Through his mediation, I was called to the Gauleiter, and Minister of the Interior Wagner, in Munich. After a series of discussions between the clerical, governmental and party authorities, an agreement was reached which had the following results: the school prayer was retained, the crucifix was allowed to remain in the schools, etc.; furthermore, fifty-nine clergymen who had been fined 500 marks each were pardoned.

The closing down of cloisters was also stopped at that time. Gauleiter Wagner had to - "

DR. SIEMERS: Very well. Then I just ask the Tribunal to take judicial notice of the remainder.

I submit also the two last documents, Exhibit Raeder 125, and Exhibit Raeder 126.

One hundred and twenty-five is an affidavit by the former Reich Defence Minister Dr. Otto Gessler, and 126 is an affidavit by the Navy Chaplain, Ronneberger. I ask you to take judicial notice of this latter document.

I should like to be permitted to read the short affidavit by Dr. Gessler, since it contains not only something of a purely personal nature, but also remarks concerning accusations against Raeder.

[Page 319]

"I, Gessler, have known the former Grand Admiral Raeder personally since about the middle of the 1920's when I was Reich Minister for Defence. Raeder was then Inspector of the Educational System in the Navy. I always knew Raeder as a man of irreproachable, chivalrous character, as a man conscious of his duty. As to the subject of the indictment, I know very little.

Raeder visited me repeatedly after my release from imprisonment by the Gestapo in March, 1945, when I lay in the Hedwig Hospital in Berlin, and he also made arrangements for me to get home, as I was ill and completely exhausted. I told him then about the ill-treatment which I had suffered, especially the torture. He was obviously surprised and incensed about this. He said he would report it to the Fuehrer I asked him at once to refrain from that, for I had been told officially before that the torture, that all of this was taking place at the explicit order of Hitler. Moreover, I knew definitely that I would immediately be rearrested, since on my release I had signed the well-known declaration, and could not even obtain a confirmation of my detention in order to get a ticket for my trip home.

I heard nothing about secret rearmament in the Navy, neither during my term of office, nor later. During my term of office, until January, 1928, Grand Admiral Raeder could not have been responsible either, for at that time he was not Chief of the Naval Command.

At the time of the National Socialist regime, I was both ignored and snubbed by my former department. One of the few exceptions to this was Admiral Raeder. Before 1939, he invited me a third time to visit the cruiser Nuremberg, although I had refused twice. During the visit in June, 1939, he came to Kiel personally to greet me. At that time we also discussed the political situation. I expressed the apprehension that an attack on Poland would mean a European war. Raeder declared positively that he considered it out of the question that Hitler would attack Poland. When this did happen later, I explained this to myself on the grounds that Hitler liked to place even the highest military leaders face to face with accomplished facts."

As to the last Exhibit Raeder 126, from the Navy Chaplain Ronneberger, I ask the Tribunal to take judicial notice of it since it is too late to read it. It is a factual description and survey of church and religious questions as they affected the Navy.

Mr. President, with that, with the exception of three points, I can conclude my case. Firstly and secondly, there are still two interrogatories missing which have not yet been returned. I ask permission to submit these as soon as they are received.

Then, there is the witness, General Admiral Bohm, who has already been approved, but who, on account of illness, has not yet been able to appear. The British Delegation, through Sir David, has been kind enough to agree that if necessary, this witness can be interrogated at a later date. May I be permitted to ask the Tribunal to keep this open, and, if possible, to allow this to be done. I want to point out now that it will not involve so large a complex of questions as was the case with Admiral Schulte-Monting which the Tribunal knows from the material I have submitted.

This concludes my case Raeder.

THE PRESIDENT: The Tribunal will adjourn.

(The Tribunal adjourned until 23rd May, 1946, at 1000 hours.)

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