I should like to refer to Page 29 and quote one sentence:

“The building of battleships will be extended as far as

possible, so as to keep the naval yards at Wilhelmshaven

occupied continuously. The ideal time of construction is about

three years; and it is then explained that, working on the

principle of giving as long employment as possible, the building

time is prolonged as much as possible.”

I believe this shows there was no aggressive intention, since otherwise

the building program would have been speeded up.

Then I ask you to take judicial notice of Page 30, the construction cost

of an armored ship having a tonnage of 10,000 tons, where it mentions

that it was about 75 million marks. This figure is important to me as

evidence in view of the further course of the testimony, where the cost

of the breaches of the Versailles Treaty will be shown.

Finally may I quote from Page 30 a few lines which give the principle

for the employment of the Wehrmacht. I quote:

“Since carrying out the disarmament program, which so far the

German Republic alone among all the Great Powers has effected,

for the Wehrmacht, which serves to protect the borders and

peace, the following eventualities for the taking up of arms

comes into consideration: (a) defense against the stealing of

territories, (b) defense of neutrality in conflicts among third

parties.”

[_Turning to the defendant._] I should like to refer to the individual

breaches of the Treaty of which the Prosecution has accused you. In this

connection, I submit Exhibit Raeder-1, in Document Book 1, Page 1, and I

refer to Page 3, Article 191. It concerns the accusation that Germany,

contrary to the Versailles Treaty, constructed submarines. Article 191

reads, and I quote, “The construction and acquisition of all submersible

craft, even for commercial purposes, is forbidden to Germany.”

I will soon put a question to you in regard to the established fact that

the Navy was interested in a firm which dealt with the designing of

submarines in Holland and in a general construction program for ships

and submarines, which was being carried out in Holland; but in order to

save time, it will be simpler if I read from the Lohmann affidavit which

I submit as Exhibit Raeder-2, in Document Book 1, Page 4. I quote a

short paragraph under 1:

“According to the Treaty of Versailles, the German Reich was

neither to build nor to acquire U-boats. When in July, 1922, the

firm N. V. Ingenieurskantoor Voor Scheepsbouw was established in

the Hague, the Navy acquired an interest in it in order to keep

informed on modern U-boat construction. The intention was to use

the experience gained thereby for the German Navy, when later on

the conditions of the Treaty of Versailles would be annulled by

negotiations and Germany would be again permitted to build

U-boats. Moreover, the Navy wanted, for the same purpose, to

train a small nucleus of skilled personnel. The Dutch firm was

strictly a designing bureau.”

May it please the Tribunal, as a precaution I should like to point out

in this passage that there is a translation mistake in the English copy.

The word “Konstruktion” has been translated “construction,” and

construction means “building” in German. It was not a construction

bureau. As far as I know, “Konstruktion” must be translated “design.”

Since in view of Article 191 this point is important, I want to correct

this.

Trial of the Major War Criminals Before the International Military Tribunal, Nuremburg, 14 November 1945-1 October 1946, Volume 13 · 第 40 / 42 题