"Jan Cloete [mixed race] of Omaruru, states under oath: 'I was in Omaruru in 1904. I was commandeered by the Germans to act as a guide for them to the Waterberg district, as I knew the country well. I was with the 4th Field Company under Hauptmann Richardt. The commander of the troops was General von Trotha.
"I was present at Hamakari, near Waterberg when the Hereros were defeated in a battle. After the battle, all men, women and children, wounded or unwounded, who fell into the hands of the Germans were killed without mercy.
"The Germans then pursued the others, and all stragglers on the roadside and in the veld were shot down and bayoneted. The great majority of the Hereto men were unarmed and could make no fight. They were merely trying to get away with their cattle.
"Some distance beyond Hamakari, we camped at a waterhole. While there, a German soldier found a little boy, about nine months old, lying in the bush. The child was crying. He brought it into the camp where I was.
"The soldiers formed a ring and started throwing the child to one another and catching it as if it were a ball. The child was terrified and hurt and was crying very much. After a time, they got tired of this and one of the soldiers fixed his bayonet on his rifle and said he would catch the baby.
"The child was tossed into the air towards him, and as it fell, he caught it and transfixed the body with the bayonet. The child died in a few minutes and the incident was greeted with roars of laughter by the Germans, who seemed to think it was a great joke.
"I felt quite ill and turned away in disgust because, although I knew they had orders to kill all, I thought they would have pity on the child. I decided to go no further as the horrible things I saw upset me, so I pretended that I was ill, and as the captain got ill too and had to return, I was ordered to go back with him as [a] guide. After I got home, I flatly refused to go out with the soldiers again."
This excerpt, from the "Blue Book", published by the British government in August 1918 and presented to both houses of parliament in London, forms part of a landmark lawsuit filed in Washington DC in late June by Namibia's Hereto tribe in which they are seeking $2 billion in reparations from three German companies.
The companies are accused, in the suit, of forming a "brutal alliance" with imperial Germany to exterminate over 65,000 Hereros between 1904 and 1915.
The three companies, which include the Deutsche Bank, (the other two defendants are yet to be made public), are said, by the court documents, of having formed part of the German colonial enterprise that "employed explicitly sanctioned extermination, the destruction of tribal social organisation, concentration camps, forced labour and medical experimentation, etc", to advance their common financial and political interests.
Spurred by the discovery of diamonds and other minerals in Namibia, and after observing the extraction of enormous wealth from Africa by other colonial powers, the Germans embarked on their own conquest. In the process, says the lawsuit, they killed more than 65,000 Hereros, about 80% of the Hereto population at the time.
Some historians have called it "the first genocide of the 20th century" but Germany has repeatedly resisted calls for compensation. Although it has described the near extermination of the Hereros as a "dark chapter" in its history, Germany has stopped short of an outright apology.
The court documents filed in New York by the Hereros' American lawyers claim that the "Deutsche Bank was the principle financial and banking entity in [Namibia] from 1890 to 1915. Disconto-Gessellschaft, acquired by Deutsche Bank in 1929, combined with Deutsche Bank to control virtually all financial and banking operations in [Namibia] from 1890 to 1915. …