Do you agree with that?

KESSELRING: I cannot completely agree with that concept. As far as Rotterdam is concerned, conditions were exactly the opposite.

SIR DAVID MAXWELL-FYFE: Well, just for the moment we will deal with the Defendant Raeder’s words. Do you agree with them?

KESSELRING: No.

DR. LATERNSER: I have an objection. I object to the earlier and to this present question put to the witness, because they are irrelevant, and secondly because they do not refer to facts but opinions. The witness is here to testify to facts.

SIR DAVID MAXWELL-FYFE: My Lord, the witness is here, as I pointed out carefully, to deal with what is military necessity.

THE PRESIDENT: Sir David, the Tribunal thinks that the question in the form in which you put it may be objectionable, by the introduction of the views of the Defendant Raeder.

SIR DAVID MAXWELL-FYFE: Of course, I bow to the Tribunal, but this witness is called to say that the explanation for this is military necessity. I was asking whether he did not agree with the views of one of his colleagues on this point, what is military necessity. If the Tribunal has any doubt, I would rather pass it. But the question of military necessity is one which the Tribunal will have to consider in a number of fields, and I respectfully do not abandon that point, which will run through the questions I have to ask on other matters.

[Turning to the witness.] Now, I will come to the tactical position at Rotterdam: Will you just tell the Tribunal who were the officers involved? There was a Lieutenant General Schmidt and with him was Major General Student, who were in charge of the troops that were attacking Rotterdam. Do you remember that?

KESSELRING: Only General Student. General Schmidt is unknown to me.