The next document, C-5, has already been put in as Exhibit GB-83. This is from the defendant, as Flag Officer U-boats, addressed to the Supreme Command of the Navy, the naval war staff. It is dated the 9th of October 1939, and it sets out the defendant’s view on the advantages of Trondheim and Narvik as bases. The document proposes the establishment of a base at Trondheim with Narvik as an alternative.
Now the next document, C-151, has already been put in as Exhibit GB-91. It is the defendant’s operation order to his U-boats for the occupation of Denmark and Norway, and the operation order, which is top secret, dated the 30th of March 1940, is termed “Hartmut.” The members of the Tribunal will remember that the document, in the last paragraph, said:
“The naval force will, as they enter the harbor, fly the British flag until the troops have landed, except presumably at Narvik.”
The preparations for war against England are perhaps best shown by the disposition of the U-boats under his command on the 3rd of September 1939, when war broke out between Germany and the Western Allies. The locations of the sinkings in the following week, including that of the Athenia which will be dealt with by my learned friend, Major Elwyn Jones, provide corroboration. On that, I would put in two charts; I put them in as Document D-652, and they become Exhibit GB-190.
My Lord, I have copies here for the members of the Tribunal. They have been prepared by the Admiralty. There are two charts. The first sets out the disposition of the submarines on the 3rd of September 1939. There is a certification attached to the chart, in the top left-hand corner, which I should read:
“This chart has been constructed from a study of the orders issued by Dönitz between 21 August 1939 and 3 September 1939 and subsequently captured. The chart shows the approximate disposition of submarines ordered for the 3rd of September 1939 but it cannot be guaranteed accurate in every detail as the files of captured orders are clearly not complete and also some of the submarines shown apparently had received orders at sea on or about 3 September to move to new operational areas. The documents from which this chart was constructed are held by the British Admiralty in London.”
My Lord, there are two points I would make on that first chart. First, it will be apparent to members of the Tribunal that U-boats which were in those positions on the 3rd of September 1939 had left Kiel some considerable time before. The other point which I would make is important in connection with my learned friend Major Elwyn Jones’ case against the Defendant Raeder, and that is the location of the U-boat U-30. The members of the Tribunal may care to bear it in mind while looking at the charts now.
The second chart sets out the sinkings during the first week of the war, and the location of the sinking of the Athenia will be noted. There is a short certification in the left-hand corner of the Tribunal’s copies:
“This chart has been constructed from the official records of the British Admiralty in London. It shows the positions of the sinkings of the British merchant vessels lost by enemy action in the 7 days commencing the 3rd of September 1939.”
My Lord, I turn to the defendant’s participation in War Crimes and Crimes against Humanity.