I am referring to Document Number Raeder-2, which has been submitted to the Tribunal already. This is the affidavit by Lohmann, on Page 5. I quote from Document Book 1, Page 8:

“Within the limits defined by the German-English Naval Agreement, the German Navy commissioned four battleships. I append the dates of laying down the keel, launching, and commissioning, as far as I can still determine them. Scharnhorst: laid down keel, exact date cannot be determined; launched, 3 October 1936; commissioned, 7 January 1939. Gneisenau: laid down keel, date cannot be determined; launched, 8 December 1936; commissioned, 31 May 1938. Bismarck: laid down keel, 1936; launched, 14 February 1939; commissioned, 2 August 1940. Tirpitz: laid down keel, 1936; launched, 1 April 1939; commissioned, 1941.”

Admiral Lohmann was unable to ascertain the exact date. The “H”—I may add that the other ships mentioned under Document C-23 were planned but were broken up later. They had already been broken up in the summer of 1939, and this applies only to the first “H.” So far there is no question of final preparation or construction. Since an obvious violation of the treaty exists, we now have to consider in what light this violation should be regarded. The Prosecution have said that this violation of the treaty is criminal since it implies intended aggression. In order to save time, especially since technical problems are involved, I should like, before questioning the defendant further, to submit Document Number Raeder-15, within the scope of the documentary evidence which I have submitted with the Tribunal’s permission. In my opinion, this document proves that there was no intention of aggression.

Document Number Raeder-15 is an affidavit—I beg your pardon—it is in Document Book 1, Page 94. This document deals with an affidavit deposed before a notary at Hamburg by Dr. Ing. h.c. Wilhelm Süchting and is important for the refutation of Document C-23, and for that purpose I should like to quote:

“I am the former Director of the shipbuilding yard of Blohm & Voss in Hamburg. I was with this firm from 1937 to 1945”—pardon me—“from 1907 to 1945 and I am conversant with all questions concerning the construction of warships and merchant ships. In particular, as an engineer I had detailed information about the building of battleships for the German Navy. Dr. Walter Siemers, attorney at law of Hamburg, presented to me the Document C-23, dated 18 February 1938, and asked me to comment on it. This document shows that the Navy, contrary to the previous agreement, informed the British that the battleships Scharnhorst and Gneisenau—as well as other intended constructions—had a displacement and draught of about 20 percent less than was actually the case.

“I can give some details to explain why this information was given. I assume that the information given to the British—information which according to naval agreement 4 had to be supplied 4 months before the keel was laid down—was based on the fact that the battleships Scharnhorst and Gneisenau were originally intended to have a displacement of 26,000 tons and a draught of 7.50 meters and the battleship “F” (Bismarck) a displacement of 35,000 tons and a draught of 7.90 meters, as stated.

“If these battleships were afterwards built with a greater displacement and a greater draught, the changes were the result of orders given or requests made by the Navy while the plans were being drafted and which the construction office had to carry out. The changes were based upon the viewpoint repeatedly expressed by the Navy—namely, to build the battleships in such a way that they would be as nearly unsinkable as possible. The increase of the tonnage was not meant to increase the offensive power of the ship”—I beg your pardon, Mr. President. I shall be finished in a moment—“The increase of the tonnage was not meant to increase the offensive power of the ship but was done for defensive and protective purposes.”

I may perhaps point out that in the English text there is a mistake in translation. In this text the word “not” is missing. It should read, “was not meant,” and not “meant.”

“As time went on, the Navy attached more and more importance to dividing the hull of the battleship into a greater number of compartments in order to make the ship as unsinkable as possible and to afford the maximum protection in case of leakage. The new battleships were therefore built broad in the beam with many bulkheads, only about ten meters apart, and many longitudinal and latitudinal bulkheads outside the torpedo bulkhead. At the same time, both the vertical and the horizontal armor-plating were, as far as my information goes, heavier and composed of larger plates than those used by other navies. In order...”

THE PRESIDENT: In other words, his explanation is that they were altered in the course of construction for technical reasons. It does not matter what the technical reasons are.