“Q. Would a fair statement be that the Navy High Command was interested in avoiding the limiting provisions of the Treaty of Versailles regarding personnel and the limits of armaments, but would attempt to fulfill the letter of the Treaty, although actually avoiding it?

“A. That was our endeavor.”

MR. ALDERMAN: Now the rest of this is the portion that counsel for the defendant asked me to read:

“Q. Why was such a policy adopted?

“A. We were much menaced in the first years after the first war by the danger that the Poles would attack East Prussia, and so we tried to strengthen a little our very, very weak forces in this way; and so all our efforts were directed to the aim of having a little more strength against the Poles should they attack us. It was nonsense to think of attacking Poland in this stage by the Navy. A second aim was to have some defense against the entering of French forces into the Ostsee (East Sea), because we knew that the French had the intention to sustain the Poles. Their ships came into the Ostsee, Gdynia, and so the Navy was a defense against an attack of Poland and against the entrance of French ships into the East Sea; quite defensive aims.

“Q. When did this fear of an attack from Poland first show itself in official circles in Germany, would you say?

“A. In all the first years. They took Vilna; in the same minute we thought they would come to East Prussia. I don’t know exactly the year, because those judgments were the judgments of the German Government Ministers, the Army and Navy Ministers—Gröner and Noske.

“Q. Then those views, in your opinion, were generally held and existed perhaps as early as 1919-1920, after the end of the first World War?

“A. Oh, but the whole situation was very, very uncertain, and about those years in the beginning I cannot give you a very exact picture, because I was then 2 years in the Navy Archives to write a book about the War and the fighting capacity of cruisers. For 2 years I was not with those things.”

MR. ALDERMAN: Likewise the same kind of planning and purposes are reflected in the table of contents of a history of the German Navy, 1919 to 1939, found in captured official files of the German Navy. Although a copy of the book has not been found by us, the project was to have been written by Oberst Scherff, Hitler’s personal military historian. We have found the table of contents; it refers by numbers to groups of documents and notes of documents, which evidently were intended as the working materials for the basis of chapters, to be written in accordance with the table of contents. The titles in this table of contents clearly establish the Navy planning and preparation to get the Versailles Treaty out of the way and to rebuild the naval strength necessary for aggressive war.