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"In your statement of September 5 you said in connection with the Pacific fleet maneuvers, "Let us see what actually would have happened to this fleet of circus vessels. Instantly on leaving San Francisco, Pacific submarines would have planted mines at all entrances.' What Pacific power do you refer to?"
"Japan."
"Has Japan the greatest number of submarines?"
"I don't know."
"Are there any other submarines in the Pacific besides ours?"
"Yes, Japan, Holland and Great Britain has them."
"Has Japan more submarines than Holland?"
"I don't know."
Here it became evident both from the nature of the witnesses' replies and the expression on his face that he was in a "fighting mood."
"Has Japan any mine-laying submarines?"
"I don't know."
Holds Quiz Irrelevant.
"Do you know how many mines a mine-laying submarine can carry?"
"No."
"Referring to this fleet of circus vessels, do you know how many submarines were with it?"
"I don't know, and it makes no difference."
"There were 90," said Maj. Gullion.
"Well, give them 150."
"Do you know how many submarines are with the fleet?"
"I don't carry those figures in my head."
"How many mine sweepers are with the fleet?"
"I don't know. It's all a matter of record and I can find it."
"Did you know the fleet had an adequate number of mine sweepers?"
"No."
"Do you know how the fleet is protected against mines?"
"No."
"Do you know what a paravane is?"
"No."
"Do you know that when the sortie operations began provision was made for guarding against mines and simulating attacks on submarines?"
"No."
Denies Allegation.
"In your view the Pacific has no mine-laying submarines?"
"Who said that?" replied the witness.
"You said that."
"No I didn't."
"Do you know if any battleships were sunk by mines laid by submarines?"
"Yes, the Audacious."
"Are you familiar with Corbett?"
"Jim Corbett," asked the witness and the courtroom roared.
"No, the naval authority. In his book he says the Audacious was not sunk by mines."
"I've heard people say it was."
"Do you take what they say over an eminent authority?"
"Sometimes."
"Are you aware that Germany and Great Britain had mine-laying submarines in the war, and that the British fleet left its harbors at will? Do you believe that mines at San-Francisco Harbor would damage the sortie?"
"It would under certain conditions."
Denies False Impression.
"Don't you think your statement that submaries with mines could have damaged the fleet on leaving San Francisco created a false impression in the minds of the people?"
"What statement."
"I'll read it again," said Maj. Gullion, and when he had finished, Col. Mitchell said he did not believe it created a false impression.
"It wouldn't create half as much impression in case we had war."
"Don't you think wour statement was slightly exaggerated?"
"I do not."
"You still have that number in mind I read to you," and here Mr. Reid objected and Maj. Gullion withdrew the question.
"In your statement of September 5 you said the whole Pacific Ocean could be distributed off into squares where submarines would operate, one submarine to 900 square miles."
Calls Question Foolish.
"Are you aware that that area of the Pacific known as the fleet route to the Far East covers 10,000,000 square miles?" asked Maj. Gullion.
"No."
"Assuming each district covers 900 square miles, your plan would require 12,500 submarines?"
"That's a foolish question as far as I am concerned."
"Do you know the cost of the modern submarine is about $5,000,000?"
"It might cost more than that."
"Granting that Japan's submarine force is equal in efficiency to Germany's during the war, would it not require 125,000 submarines to be effective in the Pacific?"
"No."
"Are you aware that the submarines would cost about $624,000,000,000?"
"No."

TESTIFIES IN HIS OWN BEHALF
[[Image]]
NATIONALS PHOTO
COL. WILLIAM MITCHELL
As he appeared when quizzed today at the court-martial trying him for criticizing the Air Service.

"We stated the wealth of the United States was about $302,000,000,000, and it would cost over twice the wealth of the country to carry out your plans."
"I would like you to furnish my plans."
Maj. Gullion, for the third time, read Col. Mitchell's statement as to what submarines could have done to the Pacific fleet when it left for the maneuvers, and then Col. Mitchell said: "I would like to have that in the record, as that would be what would happened."
Mr. Reid objected to the question of cost to carry out the plan, but it was overruled. However, no direct answer was given and Maj. Gullion asked, "Have you any idea as to whether the wealth of the United States is greater than Japan's?
"Probably greater."
"Then to carry out your plan, which was heralded to the world, it would cost twice as much as the total wealth of the United States." Mr. Reid objected to the words "which was heralded to the world," which were used by Maj. Gullion, and the latter withdrew them.
"You further stated that submarines can attack battleships. Is that so?"
"It depends."
"If it attacked on the surface, what would prevent it from being sunk by destroyers?"
"It might or might not be sunk."
"What is the speed of submarines?"
"I don't know."
"How long must a submarine run at high speed?"
"What is it?" asked the witness.
"Eight to ten knots," replied Maj. Gullion.
"How long could a submarine travel at these speeds?"
"I don't know."
"What is the speed of the fleet?"
"The commander-in-chief reports it is 7 1/2 knots."
Admits Charge "Opinion."
Maj. Gullion began questioning Col. Mitchell regarding charges he had made about the Pacific maneuvers of the fleet. He was asked where he got the information on which he based his charges that this was a "big parade," presumably of no military value.
"That was my opinion," answered the witness.
"Do you mean that all of your San Antonio statement was merely your opinion?" inquired Maj. Gullion.
"I started it all out by saying it was my opinion," said Col. Mitchell.
"Then there is no statement of fact anywhere in it?"
"No, it was all my opinion."
Maj. Gullion then questioned the witness about the use of torpedoes in warfare and asked him if he had ever seen a torpedo which could hit the bottom of a ship and produce gas clouds, as Mitchell's statement had implied. The witness admitted he had not.
"Since all your statements were not facts and were only based on your opinion," asked the prosecution, "will you please state the source of your information so that we can differentiate between your opinions and your imagination."
"My source of information was studies I had made in the Northern Hemisphere and what I have seen, looking into the future to see what our national defense should be," Mitchell explained.
The witness admitted his inability to cite any instance of a fleet being attacked by gunfire from a submarine, but added that past history would not prove anything about the future.
Reading from Mitchell's charges that the Australian cruise was a parade of the fleet that cost the Navy from $40,000,000 to $80,000,000, Maj. Gullion asked Col. Mitchell if he had read the plans for these maneuvers before issuing his statement. The witness said he had not.
"Then how did you get your information?" demanded the prosecution.
"From the newspapers," replied Col. Mitchell.
"Do you always get your information from the newspapers? persisted Maj. Gullion.
"Yes, whenever the Navy is concerned—you can't get any information in any other way about the Navy," Mitchell declared.
Maj. Gullion then sought the source of Mitchell's information that the Australian cruise cost from $40,000,000 to $80,000,00. The defendant said he got the figures from conversations with several officers. Asked if he thought that was the best source of such data, Mitchel replied that it often was.
Asked to Explain.
"Did you mean to infer that the Australian cruise cost from $40,000,000 to $80,000,000 in excess of regular operations of the fleet?" asked the prosecution.
"Yes, in my opinion, that's what I meant to infer," replied the witness.
Maj. Gullion then stated that the officer in command of the cruise had reported that the cost of the maneuvers was $550,000 over usual expenditures for operations and maintenance.
"Compare this figure with your estimate and tell me if you don't think your statement was misleading," Maj. Gullion state.
"No; it was not misleading. I underestimated it," Mitchell relied.
The witness started to explain his answer, but the court interrupted to call a recess for luncheon.

MITCHELL ENDURES BITTER CROSS-FIRE
War Department Examination Precipitates Charges and Counter-Charges.
Nash. Star - 11/24/25
A general melee of fast-flying accusations and recriminations, charges and counter-charges furnished an afternoon of unprecedented activity for the spectators in the courtroom of the Mitchell trial yesterday, when Col. Mitchell was subjected to bitter cross-examination by the War Department.
The excitement was enhanced by the occasional mixing in of Representative Frank R. Reid, chief counsel for the accused, and Col. Winship, law member of the court. The latter made valiant efforts to serve in the role of arbiter, and by sheer force of legal opinion managed to break up threatening verbal encounters between counsel.
The court itself developed a case of nerves and Brig. Gen. Edward L. King, the most nervous member of the court, displayed his frayed condition on two occasions during the day, when he ordered news photographers ejected from the room. It was the third time since the trial started that Gen. King had manifested his strong dislike for photographers, and he made known his animosity in no uncertain tones.
Effort to Discredit Witness.
A major part of the cross-examination of Col. Mitchell yesterday afternoon was devoted to an attempt to discredit the credibility of the witness before the court. Maj. Allen Gullion and Maj. Francis B. Wilby, the two "big guns" rushed to the front of the prosecution by the general staff when it appeared Col. Sherman Moreland, the trial judge advocate, was in need of immediate assistance. They conferred time and time again before the assaults on the good faith of the accused were launched. Maj. Gullion came out openly and announced to the court that it was his intention to show that Col. Mitchell, who has charged that high ranking officers of the Army and Navy have given false and misleading information to committees of Congress, himself has committed the same offense.
Maj. Gullion declared the accused had made charges against honorable officers, had maligned their motives and attributed to them unworthy ends. "We intend to prove," he explained, "that he has made inaccurate statements to committees of Congress, but we are not going to attack his veracity at this time—only his credibility."
Statement Is Disclaimed.
An effort was made to draw from the witness the admission that, after viewing an exhibition flight at Bolling Field of the Loening amphibian plane of the type taken to the Arctic by the Navy, he had complimented Grover Loening, the designer and builder, and had declared it would be excellent for exploration work. Col. Mitchell disclaimed any knowledge of such a conversation and added: "I didn't consider the ship adequate for any service duty, as it had not been thoroughly service tested. I don't see how it could have been possible for me to have told Loening it was a good plane for the Arctic."
"Now, colonel," continued Maj. Gullion, "there are a great many officers in other arms of the service for whose judgement you have a great deal of respect. Suppose all had ideals on the improvement of their services, do you realize how much it would cost to carry them out?"
"That has nothing to do with air power. I can't answer a question of that kind," he replied.
Line of Questioning Shifted.
The questioning shifted to the phrases "criminal negligence" and "almost treasonable administration" of the War and Navy Departuents, which were employed in the September 5 statements. "What is treason?" asked Maj. Gullion.
"There are two definitions," responded the witness. "One is the Constitution definition about giving aid and comfort to the enemy during war, and the other is to give up or betray the Nation. I believe the department's system is almost treasonable in that they don't give the proper place to air power in the development of the national defense."
"You've used the words 'almost treasonable administration.' Do you think a fair interpretation would be that you meant the criminal offense of treason?"
"Yes."
The witness then was called upon to explain the phrase "ashamed of the cloth he wears," which appeared in the San Antonio statement. Col. Mitchell declared it referred to officers of the Air Service "and not of the Army." They are "subjected to the worst example of command ever known to any nation," he declared, adding, "High ranking officers make inspections, ask foolish questions and show they know nothing about the subject."