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Last-Modified: 2000/07/20


                                                              [Page 34]


                  I admit too that there are documents contained
        in the expertise of Professor Browning of which I was not
        aware, and which have my own perception of some aspects of
        the Nazi atrocities on the Eastern front.  For example,
        I was not aware that the SS Obergruppenfuhrer Reinhard
        Heydrich had issued instructions to his commanders in the
        Baltic States after Operation Barbarossa began, the
        invasion of Russia, in June 1941, not only to turn a blind
        eye -- this was his instructions -- on the anti-Jewish
        progroms started by the local population in those
        countries, but also actively to initiate them and to
        provide assistance.  That was unknown to me.
                  This document, however, emerged only
recently
        from the Russian archives and there can surely be no
        reproach against me for not having known that when I
wrote
        my biography of Hitler, published in 1977, or in my
later
        works.  That cannot be branded as manipulation or
        distortion, just by way of example.
                  What is manipulation or distortion of
history
        would be this, in my submission:  for example, knowing
of
        the existence of a key document and then ignoring it
or
        suppressing it entirely, without even a mention.
                  If, for example, it should turn out and be
        proven in this very courtroom that in the spring of
1942
        the Nazi leader, Adolf Hitler, was quoted by a senior
        Reich Minister in writing as repeatedly saying that he

.          P-35



         "wanted the final solution of the Jewish problem
        postponed until the war is over"; and if the document
        recording those remarkable words has been found in the
        German archives, it would surely be classifiable as
        manipulation or distortion if an historian were to
attempt
        to write the history of the Holocaust without even
        mentioning the document's existence, would it not, my
        Lord?
                  The Defendants have, as said, arbitrarily
and
        recklessly decided to label me a "Holocaust denier".
        Their motivation for doing so we shall shortly hear
        about.
                  My Lord, before I continue to address the
court
        on this point in my opening statement, may I take this
        opportunity to read to the court, with your Lordship's
        permission, and into the record, a two-page document
which
        I shall refer to over the coming weeks as the Walter
Bruns
        interrogation?
   MR JUSTICE GRAY:  Yes, I do not see why you should not; I
have
        not read it myself.  This is the document you handed
in?
   MR IRVING:  It is the document I gave you, my Lord.  It is
an
        eye witness description.  I do so because perceptions
        matter.  I want at this late hour to leave a firm
        perception in the minds of all those present about
where
        I stand.  It is a document which first came into my
hands
        some time before 1985.

.          P-36



                  I should say, my Lord, by way of
introduction,
        that this document (which is in my discovery) was
        originally a British top Secret document.  Top Secret
is
        only one rung lower than Ultra-secret; some several
steps
        above Secret and Most Secret, in other words.  It is
the
        classification given to the British decoded
intercepts.
        It was top Secret because it is the record of an
        interrogation which was obtained by methods that were
        illegal, I understand, under the Conventions.
                  Enemy prisoners of war (in this case German)
        were brought into British prison camps, treated
lavishly,
        well-fed, reassured by their relaxed surroundings, and
        gradually led into conversation, unaware that in every
        fitting and appliance in the room were hidden
microphones
        capable of picking up everything.  (That was the
        illegality; you are not allowed to do that under the
        Conventions).
                  Released to the British archives only a few
        years ago were all of these reports, but I had already
        obtained several hundred of them 15 or 20 years
earlier.
        I consider these transcripts to be an historical
source
        which, if properly used and if certain criteria are
        applied, can be regarded as part of the bedrock of
Real
        History.
                  I would say further by way of preamble, my
Lord,
        that the speaker whose recorded voice we are about to

.          P-37



        hear, as reproduced in this typescript, was on
November
        30th 1941, the day of the episode he narrates, a
Colonel
        in the German Army Engineers Force (the sappers or
        Pioniere).  He was commanding a unit based at Riga,
the
        capital of Latvia.  He had learned to his vexation
that it
        was intended by the local SS unit to round up all the
        local Jews, including "his Jews" in the next day or
two
        and to liquidate them.
                  I read from this document  before I do so,
my
        Lord, it is of interest to see that, purely by
coincidence
        and chance, Mr Rampton has picked on precisely the
same
        day in the statement which I understand that he is to
make
        following upon mine.
   MR JUSTICE GRAY:  I am not quite following.  Picked on the
same
        day as being what?
   MR IRVING:  The same episode and the same day as an example
of
        my treatment of documents, so it is a very interesting
        case.
                  I read from the document itself.  It is
        headed:  "Top secret.  CSDIC (UK)" which is Combined
        Services Detailed Interrogation Centre UK".  "GG
Report.
        If the information contained in this report is
required
        for distribution, it should be paraphrased so that no
        mention is made of the prisoners' names, nor of the
        methods by which the information has been obtained"
        because, of course, it was illegal.

.          P-38



                   "The following conversation took place
between
        General-Major Bruns", his full name was Walter Bruns.
At
        this time he was at the Heeres-Waffenmeisterschule
which
        was an army school, an armament school, in Berlin,
         "captured at Gottingen on April 8th 1945, and other
        Senior Officer Prisoners of War whose voices could not
be
        identified".  In other words, it is a conversation
between
        this General and various other prisoners overheard by
        hidden microphones on April 25th 1945. "Information
        received: 25 April 1945", in other words, the war is
still
        running.
                   "Translation:  Bruns:  As soon as I heard
those
        Jews were to be shot on Friday, I went to a 21 year
old
        boy and said that they had made themselves very useful
in
        the area under my command, besides which the Army MT
park
        had employed 1500 and the 'Heeresgruppe' 800 women to
make
        underclothes of the stores we captured in Riga;
besides
        which about 1200 women in the neighbourhood of Riga
were
        turning millions of captured sheepskins into articles
we
        urgently required:  ear protectors, fur caps, fur
        waistcoats, etc.  Nothing had been proved, as of
course
        the Russian campaign was known to have come to a
        victorious end in October 1941!"  Sarcasm there.  "In
        short, all those women were employed in a useful
        capacity.  I tried to save them.  I told that fellow
        Altenmeyer(?) whose name I shall always remember and
who

.          P-39



        will be added to the list of war criminals:  'Listen
to
        me, they represent valuable manpower!' 'Do you call
Jews
        valuable human beings, sir?'"  That was the answer.
"I
        said: 'Listen to me properly, I said valuable
manpower. I
        didn't mention their value as human beings'.  He
        said: 'Well, they're to be shot in accordance with the
        Fuhrer's orders!'  I said: 'Fuhrer's orders?' 'Yes',
        whereupon he showed me his orders.  This happened at
        Skiotawa()?) eight kilometres from Riga, between
Siaulai
        and Jelgava, where 5,000 Berlin Jews were suddenly
taken
        off the train and shot.  I didn't see that myself, but
        what happened at Skiotawa(?) - to cut a long story
short,
        I argued with the fellow and telephoned to the General
at
        HQ, to Jakobs and Aberger(?) and to a Dr Schultz who
was
        attached to the Engineer General, on behalf of these
        people".  It is a bit incoherent the way that people
talk
        when they are gossiping with each other. "I told him:
         'Granting that the Jews have committed a crime
against
        the other peoples of the world, at least let them do
the
        drudgery; send them to throw earth on the roads to
prevent
        our heavy lorries skidding'. 'Then I'd have to feed
them!'
          I said:  'The little amount of food they receive,
let's
        assume 2 million Jews - they got 125 grammes of bread
a
        day - we can't even manage that, the sooner we end the
war
        the better'. Then I telephoned, thinking it would take
        some time.  At any rate, on Sunday morning", that is

.          P-40



        November 30th 1941, "I heard that they had already
started
        on it.  The Ghetto was cleared.  They were told:
'You're
        being transferred: take along your essential things.'
        Incidentally, it was a happy release for those people,
as
        their life in the Ghetto was a martyrdom.  I wouldn't
        believe it and drove there to have a look".
                  The person he is talking to says:  "Everyone
        abroad knew about it; only we Germans were kept in
        ignorance".
                  Bruns continues his narrative:  "I'll tell
you
        something:  some of the details may have been correct,
but
        it was remarkable that the firing squad detailed that
        morning - six men with tommy-guns posted at each pit;
the
        pits were 24 meters in length and 3 metres in breadth
-
        they had to lie down like sardines in a tin with their
        heads in the centre'", like that in the pit.
                  "'Above them were six men with tommy-guns
who
        gave them the coup de grace", who shot them. "When I
        arrived those pits were so full that the living had to
lie
        down on top of the dead; then they were shot and, in
order
        to save room, they had to lie down neatly in
        layers. Before this, however, they were stripped of
        everything at one of the stations - here at the edge
of
        the wood were the three pits they used that Sunday and
        here they stood in a queue one and-a-half kilometres
long
        which they approached step by step - a queuing up for

.          P-41



        death.  As they drew nearer they saw what was going
on.
        About here they had to hand over their jewellery and
        suitcases.  All good stuff was put into the suitcases
and
        the remainder was thrown on a heap.  This was to serve
as
        clothing for our suffering population - and then a
little
        further on they had to undress and, 500 metres in
front of
        the wood, strip completely; they were only permitted
to
        keep on a chemise or knickers.  They were all women
and
        small two-year old children.  Then all those cynical
        remarks!  If only I had seen those tommy-gunners, who
were
        relieved every hour because of over-exertion, carry
out
        their task with distaste, but no, nasty remarks like:
         'Here comes a Jewish beauty!'  I can still see it all
in
        my memory: a pretty woman in a flame-coloured chemise.
        Talk about keeping the race pure:  at RIGA they first
        slept with them and then shot them to prevent them
from
        talking.
                   "Then I sent two officers out there, one of
        whom is still alive", in April 1945, "because I wanted
        eye-witnesses.  I didn't tell them what was going on,
but
        said:  'Go out to the forest of Skiotawa(?), see
what's up
        there and send me a report'.  I added a memorandum to
        their report and took it to Jakobs myself.  He said:
'I
        have already two complaints sent me by Engineer
         "Bataillone" from the Ukraine'.  There they shot them
on
        the brink of large crevices and let them fall down
into

.          P-42



        them; they nearly had an epidemic of plague, at any
rate a
        pestilential smell.  They thought they could break off
the
        edges with picks, thus burying them.  That loess
there" --
        that is a kind of ground -- "was so hard that two
Engineer
         'Bataillone' were required to dynamite the edges;
those
         'Bataillone' complained.  Jakobs" -- he was the
engineer
        general in charge of the pioneer corps -- "had
received
        that complaint.  He said:  'We didn't quite know how
to
        tell the Fuhrer'", Adolf Hitler. "'We'd better do it
        through Canaris', the Chief of the German
Intelligence.
                  "So Canaris had the unsavoury task of
waiting
        for the favourable moment to give the Fuhrer certain
        gentle hints.  A fortnight later I visited the
        Oberburgermeister, or whatever he was called then,
        concerning some over business.  Altenmeyer(?)" who was
the
        SS man on the spot "triumphantly showed me:  'Here is
an
        order just issued, prohibiting mass shootings on that
        scale from taking place in future.  They are to be
carried
        out more discreetly'.  From warnings given me
recently,
        I knew that I was receiving still more attentions from
        spies".
                  Then his interlocutor says to him:  "It's a
        wonder you're still alive".  Bruns says:  "At
Gottingen, I
        expected to be arrested every day".


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