THE PRESIDENT: Dr. Siemers, this evidence is all a matter of argument. Not only is it a matter of argument, but we have had it over and over again from nearly all the defendants and a good many of their witnesses; and, surely, it is not assisting the Tribunal in the very least to know what this witness said in 1928 or what view he took in 1928.

DR. SIEMERS: May it please the High Tribunal, I believe this will become clear in the following. Minister Severing was a member of the government that held this cabinet meeting of 18 October 1928. I agree with the High Tribunal that the matters have been heard frequently—these things only once, however—but I should like to point out that Sir David even yesterday in cross-examination accused the defendant, despite his testimony, that, against the will of the Reich Government and against the wish of the Parliament, he had violated the Treaty of Versailles. If, therefore, after the testimony of Raeder, the Prosecution persists in their opinion, I have no other possibility to prove the incorrectness of the opinion of the Prosecution than by questioning a witness who...

THE PRESIDENT: The question whether the Treaty of Versailles was violated is a question of fact and, of course, upon that you can give evidence and you did give evidence through the Defendant Raeder; but this witness is not talking about the question of fact. He is arguing that Germany was entitled to defend herself in violation of the Treaty of Versailles. That is what I understood his evidence to be and that is a question of argument, not a question of fact.

DR. SIEMERS: Mr. President, as far as I know juridically...

THE PRESIDENT: Dr. Siemers, the class of evidence which has just been given by this witness will not be listened to by the Tribunal. If you want to prove facts by him, you can prove them, but you cannot prove arguments or his views upon arguments.

DR. SIEMERS: Could Germany with her Wehrmacht protect herself against the incursions in Silesia by Poland?

SEVERING: In the year 1920 the Wehrmacht would not have been able to protect Germany in East Prussia; therefore, it was necessary to protect the population of East Prussia, and this was achieved in that I, personally, agreed that all weapons which were found in East Prussia were to be given to the population. Under conditions which applied at that time, it was, even for purposes of inspection, very hard to pass through the Corridor by rail; so that in 1920, I had to make a tour of inspection by way of water from Stolpmünde to Pillau. I am mentioning this fact to show the difficulties of transportation through the Corridor. In 1920 and ’21, it was not possible for the German Wehrmacht to prevent attacks of Polish insurgents in Upper Silesia and, I am sorry to say, and I emphasize “I am sorry” that a certain self-defense had to be created in order to protect and defend German life and German property.

DR. SIEMERS: Herr Minister, were the measures with regard to rearmament as they were wanted and accounted for since January 1928 by Reichswehrminister Gröner based on defensive or offensive ideas as far as you know Gröner?

SEVERING: As far as I am acquainted with Gröner and his own personal way of carrying on his office, everything that he conceived and carried out was in view of defense.

DR. SIEMERS: Then this should also apply to the armored cruiser A. I should like to know why the Social Democratic Party, which was interested in the idea of defense, was against the building of this armored cruiser.