COL. PHILLIMORE: Briefs and document books have been handed in. The documents are in the document book in the order in which I shall refer to them, and the references in the brief to the documents are in that same order. On the first page of the brief is set out the extract from the Indictment as Appendix A, which deals with the allegations against this defendant. It sets out the positions he held and charges him, first, with promoting the preparations for war, set forth in Count One; second, with participating in the military planning and preparation for wars of aggression and wars in violation of international treaties, agreements, and assurances, set forth in Count One and Two of the Indictment; and thirdly, with authorizing, directing, and participating in the War Crimes set forth in Count Three of the Indictment, including particularly the crimes against persons and property on the High Seas.
Now, if at any place I appear to trespass on Count Three, it is with the consent and courtesy of the Chief Prosecutor for the French Republic.
My Lord, on the second page of the brief are set out first the positions held by the Defendant Dönitz; and the document in question is the first document in the document book, 2887-PS, which has already been put in as Exhibit Number USA-12. The Tribunal will see that after his appointment in 1935 as Commander of the Weddigen U-boat Flotilla—that was, in fact, the first flotilla to be formed after the end of the World War in 1918—the defendant, who was in effect then Commander of U-boats, rose steadily in rank as the U-boat arm expanded, until he became an admiral. And then on the 30th of January 1943, he was appointed Grossadmiral and succeeded the Defendant Raeder as Commander-in-Chief of the German Navy, retaining his command of the U-boat arm. Then on the 1st of May 1945, he succeeded Hitler as head of Germany.
My Lord, as appears from a number of documents which I shall put in evidence, the defendant was awarded the following decorations: On the 18th of September 1939 the Cluster of the Iron Cross, first class, for the U-boat successes in the Baltic during the Polish campaign. This award was followed on the 21st of April 1940 by the high award of the Knight’s Cross to the Iron Cross, while on the 7th of April 1943 he received personally from Hitler the Oak Leaf to the Knight’s Cross of the Iron Cross, as the 223rd recipient, for his services in building up the German Navy and, in particular, his services for the offensive U-boat arm for the coming war, which were outstanding. And now I put in the next document in the document book, D-436, which becomes Exhibit GB-183. That is an extract from the official publication Das Archiv on the defendant’s promotion to vice admiral. It is dated the 27th of September 1940, and I read the last two sentences:
“In 4 years of untiring and, in the fullest sense of the word, uninterrupted work of training, he succeeds in developing the young U-boat armed personnel and material till it is a weapon of a striking power unexpected even by the experts. More than 3 million gross tons of enemy shipping sunk in only 1 year, achieved with only a few boats, speak better than words of the merits of this man.”
The next document in the document book, 1463-PS, which I put in as Exhibit GB-184, is an extract from the diary for the German Navy, 1944 edition, and it serves to emphasize the contents of that last document. My Lord, I won’t read from it. The relevant passage is on Page 2, and if I might summarize that, it describes in detail the defendant’s work in building up the U-boat arm, his ceaseless work in training night and day to close the gap of 17 years during which no training had taken place, his responsibility for new improvements, and for devising the “pack” tactics which were later to become so famous. And then his position is summarized further at the top of Page 3. If I might read the last two sentences of the first paragraph on that page:
“In spite of the fact that his duties took on immeasurable proportions since the beginning of the huge U-boat construction program, the chief was what he always was and always will be: leader and inspiration to all the forces under him.”
And then the last sentence of that paragraph:
“In spite of all his duties, he never lost touch with his men; and he showed a masterly understanding in adjusting himself to the changing fortunes of war.”
It was not, however, only his ability as a naval officer which won the defendant these high honors: his promotion to succeed the Defendant Raeder as Commander-in-Chief of the Navy, the personal position he acquired as one of Hitler’s principal advisers, and finally, earlier candidates, such as Göring, having betrayed Hitler’s trust or finding the position less attractive than they had anticipated, the doubtful honor of becoming Hitler’s successor. These he owed to his fanatical adherence to Hitler and to the Party, to his belief in the Nazi ideology with which he sought to indoctrinate the Navy and the German people, and to his masterly understanding in adjusting himself to the changing fortunes of war, referred to in the diary and which the Tribunal may think, when I have referred them to the document, may be regarded as synonymous with the capacity for utter ruthlessness. His attitude to the Nazi Party and its creed is shown by his public utterances.