THE PRESIDENT: Dr. Siemers, that was fully gone into in cross-examination, and the defendant stated his explanation of the words used.
DR. SIEMERS: From Document C-190, which is the conversation on 2 November 1934 aboard the Emden between you and Hitler, Sir David has held up to you that Hitler, in a discussion with you and Göring, said that he considered the expansion of the Navy in the planned manner an absolutely vital necessity, since war could not be conducted unless the Navy safeguarded the ore imports from Scandinavia. It was said that this would have to be understood to mean that the Navy was planned in view of a war and in view of safeguarding the ore imports, which really meant aggressive intentions. Are you of the opinion that the British Navy was not planned to safeguard imports to England or for the event of war and was not equipped accordingly?
RAEDER: No, there is not the slightest doubt about that.
DR. SIEMERS: Six submarines are mentioned in this document. Considering that figure, may I ask you to tell me the number of submarines that Germany would have needed in order to conduct an aggressive war?
RAEDER: Well, at any rate, many more than we had in October 1939, a multiple of that.
DR. SIEMERS: From a document, Mr. President, which was submitted yesterday, D-806, I want to quote, in addition to the second paragraph which has been quoted, the first paragraph and put it to the witness. It is D-806, GB-462, submitted yesterday at noon.
[Turning to the defendant.] There it says:
“1.) Reference: Submarine Construction Program. On 27 October 1936 I made decision regarding the full utilization of the still available U-boat tonnage according to the Naval Agreement of 1935 and regarding the immediate ordering of the construction of U-41 to U-51.”
Were these the rest of the submarines within the 45 percent limit to which we were entitled according to the Naval Agreement of 1935?
RAEDER: Yes, that is right, judging from the figures.