Archive/File: people/i/irving.david/libel.suit/transcripts/day004.13
Last-Modified: 2000/08/01

   MR RAMPTON:  You go on.  I think we have to accept there were
        Mi Li type massacres, where SS officers, the
        Einsatzgruppen commanders, did machine gun hundreds, if
        not thousands of Jews -- oh hundreds if not thousands,
        sorry, I must get it right, did machine gun hundreds if
        not thousands of Jews into pits on the Eastern Front at
        Riga at Minsk and at other locations, this kind of thing
        did happen?
   A.   -- I think quite clearly this is not hundreds of
        thousands, I mean this is...
   Q.   It is not hundreds of thousands?

.          P-113



   A.   I mean the evidence I have given is quite clearly we are
        talking about hundreds of thousands, not just hundreds or
        thousands in cases ----
   Q.   We do not need the hundreds, do we?
   A.   Hundreds of thousands.
   MR JUSTICE GRAY:  I think Mr Irving is saying it is a misprint
        or whatever the word is he said and what he meant was
        hundreds of thousands not if not thousands?
   A.   Because if at this meeting I have read out the Bruns'
        report where alone several thousand people were machine
        gunned into one pit one could not talk about hundreds.
   MR RAMPTON:  This is one of these speeches, presentations
        lectures, I do not know, that you will have approved
        before it went into print in this whatever it is?
   A.   This is correct, yes.
   Q.   Yes.  Never mind, it is a small point.
   A.   Yes.
   Q.   The main point is this, Mr Irving, this is another
        statement in exactly the same vein as the statements you
        made at Brisbane in 1986, is it not, Mi Li type massacres?
   A.   Yes, I am being accused of being consistent, am I?
   Q.   Yes, you are, you are accused of consistently and
        knowingly reducing the extent of the responsibility for
        these massacres?
   A.   Very well.
   Q.   Do you accept that charge, or not?

.          P-114



   A.   Trying to identify the responsibility, yes.  On the basis
        of very meagre evidence.
   Q.   The words "Mi Li type massacres" mean this, do they not,
        to any educated or half educated audience, these massacres
        were done by criminal gangers unauthorized in the East
        without the approval, consent or knowledge of the people
        in Berlin?
   A.   That is correct.
   Q.   That is correct, and it was wrong, was it not?
   A.   That was wrong, yes.
   Q.   And you knew that it was wrong?
   A.   No, I did not, not at this time.
   Q.   Not in 1992?
   A.   No.
   Q.   When did you learn that it was wrong, Mr Irving?
   A.   I suppose once I began studying the documents for this
        case in detail, and we started looking at the individual
        documents of the kind we have been looking at in court
        today that becomes quite plain.
   Q.   Sorry.  Yes, I did not mean to interrupt.
   A.   It becomes quite plain that there was a co-ordination,
        there was a degree of direction.  For example, the
        killings in the Eastern territory - in the Baltic
        provinces which carried out admittedly by the local
        populations, the SS were told to join in and help and it
        turned a blind eye.  So there was a lot of nodding and

.          P-115



        winking going on in a degree that quite clearly indicates
        a systematic direction going on between Berlin and the
        Eastern Front where the killings were taking place.
   Q.   I missed the last part of that answer, it ended systematic
        direction, you are saying --
   A.   Systematic direction going on between the Eastern front
        and Berlin in connection with these killings.
   Q.   -- I am grateful to you. It is in this same speech is one
        of places where you refer to the Bruns evidence, is it
        not?
   A.   I believe so, yes.
   Q.   I am sorry, I am being harassed from all sides.  I will
        try to make both points at once if I possibly can but I do
        not think I can.  Can you turn back, please, to, where is
        it?
   MR JUSTICE GRAY:  Page 24.  Are you on Bruns?
   MR RAMPTON:  Sorry.
   MR RAMPTON:  You were asked a question on page 23, you will
        find right hand column under "Questions":  "What do we
        know about the people who are responsible for the
        massacres of Jews by firing squad in Minsk and other
        areas?  How high did the responsibility go?"  Were you
        not?
   A.   Yes.
   Q.   And it was at that point we come to Bruns, is it not?
   A.   Yes.

.          P-116



   Q.   And as I think we have been through already so I am
not
        going to go through it again, you do not when
reporting
        Bruns' evidence make any reference to the order which
        Altemeyer said he had, which were Fuhrer orders, that
it
        should happen, nor to the qualifications and the
second
        conversation that must happen more discreetly?
   A.   If I read it here says, one particular Bruns described
to
        his pals in appalling detail the massacre he himself
saw
        near Riga on November 30th 1941, I am not going to
read
        that out one here, so I did not read out any of it
        apparently.
   Q.   But the direct answer to the question, would it not,
        difficult for you when you said these were "Mi Li type
        massacres".  This chap Bruns actually said he had been
        told it was a Fuhrer order?  "But I do not think it is
        probably right" you could have added, of course?
   A.   I think we have gone over this point in some detail on
a
        previous occasion.
   MR JUSTICE GRAY:  Yes, we have.
   MR RAMPTON:  I rather agree.  I had not spotted the
question
        before, that was all.
   A.   My Lord, might I just read out ten lines of
continuation
        of that particular speech, because it goes to
        how unreliable a lot of this evidence is?
   MR RAMPTON:  Where are you, Mr Irving?
   A.   At the top left of page 24.  It is just a typical --

.          P-117



        problem we have with eyewitness evidence where
apparently
        equally credible document gives a version of a story
which
        is on the face of it highly unlikely.
   MR JUSTICE GRAY:  Well, yes, if you want to read it out.
   A.   If it would be a useful exercise, or if your Lordship
so
        directed I would not, of course.
   MR RAMPTON:  I do not object.
   MR JUSTICE GRAY:  There is no objection taken, if you want
to,
        then do.
   A.   Purely as an exercise in how unreliable evidence can
be
        from prisoners of war.  Here is a prisoner of war in a
        conversation on December 20th. A man called
Obergaufreiter
        Till, who was captured in August 1944.  He claimed to
have
        been guarding the railway at Auschwitz in July 1943
when a
        train load of Greek Jews arrived.  This again is an
        intercepted and overheard conversation.  Till said:
"The
        SS man kicked a Jewish woman who was highly pregnant.
He
        kicked her right in the stomach and knocked her down
and
        the unborn baby came almost out.  He took hold of it
        pulled it out, threw it on the ground and told the
woman
        to get up.  He put that child on the truck that was
        standing there to take away the dead people to be
        burned."  The British officer is then heard asking:
"The
        child was dead, of course?" Till then said:  "Yes, and
the
        woman could not get up she was hardly dressed and he
        grabbed her by the breast.  He wanted to pull her up.
He

.          P-118



        just ripped her skin and everything out of her
breasts.
        There was a captain there from the army.  I think his
name
        was Captain Klug.  He went after that SS guy, he took
him
        by the shoulder, turned him round and said:  "Are you
        crazy to do something like that, are you not ashamed
of
        yourself?" And so on.
                  As I comment this is the kind of rubbish
that
        gets into these interrogation reports and part of the
job
        of being a responsible writer or researcher is to sift
the
        wheat from the chaff and try evaluate which ones are
        credible.  It may be that this is an entirely true
story,
        but on the face of it I considered it was not. That is
the
        kind of problem we have, it is all very well in court
look
        at documents which have been singled out by the
        Defendants, and say, look at this one, look at that
one,
        why have you ignored this?  As an historian working in
the
        archives you are confronted with tens of thousands of
        documents and you have to make your own choice.
   MR RAMPTON:  Yes, Mr Irving.  You made a statement to --
why
        did you want to read that out, as opposed to just
drawing
        attention to it, saying this is something you could
not
        believe?
   A.   Why did I wish to read it out?
   Q.   Why did you want it read it out?
   A.   It is self- evident.  It is material of precisely the
same
        quality as General Brun's eyewitness account; it comes

.          P-119



        from precisely the same provenance, from the Combined
        Services Detailed Interrogations Centre transcripts
and
        yet we have to make a value judgment and say this
document
        I believe, that document I do not believe or this
document
        I believe this much, that portion I am less inclined
to
        believe.  And on balance, as I think I explained to
the
        court earlier, when it came to Bruns' recollection of
what
        Altemeyer said about, "we have got the Fuhrer's order
but
        we are going to disregard it", I am afraid I attach
the
        value to it which I consider to be proper.
   Q.   Mr Irving, if I put General Bruns' Report of
Lieutenant
        Altemeyer's words in those terms you would have given
me
        the most terrible rocket, would you not?  "We are
going to
        disregard it"; he did not say that at all, did he?
   A.   I beg your pardon?  Disregard --
   Q.   He did not say "we are going to disregard it"?
   A.   -- no, discount certain elements of it.
   Q.   Yes, I see.
   A.   Which on -- prima facie less likely than others.  We
can
        believe the part where he says he can see the girl in
the
        flame red dress in his mind's eye because all
experience
        tells us that is the kind of detail people do report.
   Q.   We have done it before --
   A.   We have also dealt with SS braggarts who shoot their
        mouths off --
   Q.   -- we have done that one, Mr Irving, I will not pick
up

.          P-120



        the conflict again.  I would not be allowed it anyway.
                  I want to ask you this about your Mi Li
remark,
        which I have now lost, of course.  We have to accept
that
        there were Mi Li types massacres.  You have accepted
it
        was wrong.  You could have found out that it was wrong
        before you made it, could you not?
   A.   -- find out what was wrong?
   Q.   The characterization of these organized, systematic
        shootings known to Berlin in the East of the eastern
Jews;
        the characterization of those Mi Li type massacres was
        wrong, you have accepted it was wrong, and you could
have
        known it was wrong before you made that --
   A.   I think to be more specific, there were Mi Li type
        massacres.
   Q.   -- I am sure there were?
   A.   But there were also others that were clearly on orders
        from above.
   Q.   I do not want to go back over old ground again.
   A.   Yes.
   Q.   But my question was not that to which you gave an
answer;
        my question was, you had the means of knowing it was
wrong
        before you said it, did you not?
   A.   What would those means have been?
   Q.   You could have done the same research in the EMs going
        back to Berlin as everybody else has done?
   A.   I do not think everybody else does done it for a
start;

.          P-121



        secondly, I am not a Holocaust historian, as I keep
        reminding the court.
   Q.   Then why are you discussing it here and why are you
making
        a categorical assertion that they were simply
unauthorized
        gangster killings?
   A.   I am being asked by a member of the audience my
opinion on
        this and I am giving the opinion based on my knowledge
at
        that time.
   Q.   Now I want to come to something different that arises
from
        some things you were saying on Thursday.  I promised
you
        that I would come back to it and I will.  It is
Hitler's
        log note, telephone log note, of the 30th --
   A.   November 1941.
   Q.   -- yes.  It has to do with the manuscript, not the
sense,
        the manuscript, and your transcription of the
        word "haben -- "
   A.   This is December 1st?
   Q.   November 30th 1941.
   A.   December 1st 1941?
   Q.   There was a copy of it -- December 1st, you are quite
        right, I got the wrong date.  There was a copy of it in
        your little bundle, my Lord, at the back of J3.
   MR JUSTICE GRAY:  Yes?
   A.   December 1st.
   Q.   Have you got it, Mr Irving?
   A.   No.

.          P-122



   MR JUSTICE GRAY:  We all know it by heart by now?
   A.   I know it by heart.
   MR RAMPTON:  No, for this purpose the witness will need the
        actual copy.
   MR JUSTICE GRAY:  Have you got that little clip?
   A.   No my Lord I no longer have it.
   MR JUSTICE GRAY:  Is there a spare copy?  Bundle C.

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