DR. SIEMERS: May I perhaps make one remark about what Sir David said regarding group “D”? They were not objected to because they have already been mentioned in Ribbentrop’s case; but only because they deal with the same subject matter, that is true. The same subject matter, namely, Greece, is dealt with; and I can only reply that the Prosecution have charged the Defendant Raeder in Document C-152 with having aimed at, and brought about, the occupation of the whole of Greece. The facts concerning this statement of three lines I can present only if I am allowed some documents referring to Greece and only if these are not refused on the grounds that the documents concerning Greece were turned down quite generally in Ribbentrop’s case.
Now, I come to group “E” which begins with Document 26. The same statements apply which I have already set forth in regard to Documents Numbers 101 to 107. The attacks planned by the Allies on the oil regions in neutral Romania and in the neutral Caucasus—as I should like to remark in parenthesis—have already been dealt with in these proceedings. The Tribunal will remember that I asked Göring during his examination about entries in Jodl’s diary pertaining to this question and he has given information about the reports received by Germany, on Pages 6031 and 6033 of the transcript of 18 March (Volume IX, Pages 402-404). This testimony too concerns only the subjective side, that is, what was known by Germany. I must prove that the objective side, the fact that this had actually been planned, agrees exactly with the subjective side, that is, with these reports. These documents, Numbers 26, 30 to 32, 36, 37, 39, 40 to 44, are to prove that. Then comes Number 99 which has already been dealt with, which seems to be here in duplicate; Number 101, and Number 110 which also seem to be duplicates.
I turn now to Group 6, which is supposed to be irrelevant, dealing with the attack on Norway. I have already, on principle, set forth my reasons and I beg the Tribunal not to deny me these documents under any circumstances. If I am not granted these documents, I shall simply not be in a position to present evidence in a reasonable manner without telling everything myself. I can present proof in regard to a question of such importance only if documents are granted me just as they are granted the Prosecution. But if all the documents, practically all the documents concerning this question are refused, then I do not know how I am to treat such a question. And I believe that the Tribunal will wish to assist me in this matter.
I am requesting this especially for the following reasons: When I gave my reasons for wanting to present this particular evidence, I asked that those files of the British Admiralty be brought in, which dealt with the preparations and planning regarding Scandinavia, that is, Norway. Sir David did not object at that time but said he would have to consult the British Admiralty. The Tribunal decided accordingly and granted my application. In the meantime the British Admiralty has answered, and I assume that Sir David will agree to my reading the answer which has been put at my disposal. This answer is as follows—it concerns, if I may say that in advance...
THE PRESIDENT: We have had the answer, I think, have we not? We have had the answer and transmitted it to you.
DR. SIEMERS: Thank you very much. From this reply it can be seen that the files will not be submitted, that I cannot get the necessary approval. It can also be seen that certain facts which will be important for my presentation of evidence will be admitted by the British Admiralty; but in reality I am not in a position to prove anything by means of documents. Since I am unable to make use of this evidence, I ask at least to be allowed the other means of presenting evidence, that is, the documents contained in the German White Books. These are documents recognized as being correct. In all cases they are facsimiles. They can be carefully examined and I believe...
THE PRESIDENT: Dr. Siemers, we are dealing with your application for particular documents. We are not dealing with any general argument or general criticism that you have to make. We are only hearing you in answer to certain objections on behalf of the British Prosecution.
DR: SIEMERS: Your Honor, unless I am very much mistaken—in which case you will pleas correct me—Sir David, with a few exceptions, defined his position regarding these documents under “F”—this is a large number, from 59 to 91 with some omissions—as a whole and not his position regarding each individual document. But I have to say the same thing to practically each document and asked only that I be granted those documents as a whole, for I cannot make headway without these documents...
THE PRESIDENT: You were not referring to these documents. You were referring to the fact that the British Admiralty was not prepared to disclose its files to you. It has nothing to do with these documents at all.
DR. SIEMERS: I believe I have been misunderstood, Your Honors. I have already stated very clearly why I need these documents for my presentation of evidence regarding the Norway action. Beyond that I said merely that if these documents are not granted me, then I cannot present any evidence. I am deprived of it. I asked the Tribunal merely to take into consideration the fact that the documents from London, which I had originally counted on, are not at my disposal. And I do not know why this request, which I am submitting to the Tribunal and which is only in explanation of my previous statements, is being taken amiss by the Tribunal.