Archive/File: people/i/irving.david/libel.suit/transcripts/day010.18
Last-Modified: 2000/07/20

   MR JUSTICE GRAY:  Well, I mean, that is the point that I
        have just put to you, Mr Irving.  Can you tell us what the
        answer is?
   MR IRVING:  I appreciate that Mr Rampton would prefer to
        conduct my cross-examination for me.
   MR JUSTICE GRAY:  Just answer my question.
   MR IRVING:  I will come clean and say precisely what points
        I am going for.  Professor van Pelt has suggested that,
        because in one of the drawings there is a requirement for
        the vorwarmung or prewarming of the mortuary.  This has a
        sinister connotation.  Am I right, Professor?
   A.   This is not there was drawing.  This is there was letter,
        so I did not in any of my discussion, when you asked me
        about drawings right now, include that particular
        document.  I said I was specifically talking about
        drawings.
   Q.   While we are on that document, can you tell me how
        important is that letter and how much reliance would you
        place on that as being halfway to the smoking gun?
   A.   I do not know if I should answer this right now since
        another question was posed.
   MR JUSTICE GRAY:  Is your answer because I am going to go back,
        that it is part of the convergent evidence? Is that how
        you put it?

.          P-153



   A.   It is an important part of convergent evidence, yes.
   MR JUSTICE GRAY:  Let's go back, Mr Irving.  I am going to
        insist that we get this clear and then we know where we
        are going.
   MR IRVING:  May I return to the prewarming later on, my Lord?
   MR JUSTICE GRAY:  Of course you can return to it later on.
        What is your position going to be?  Supposing that the
        evidence satisfies me that there is reason to believe that
        this was intended to be there was gas chamber and not an
        air raid shelter, is that something you accept or dispute?
   MR IRVING:  It should be, with respect, my Lord, relatively
        easy for the witness to say there are two or three
items,
        as he in fact said, which were to him, taken in
        conjunction with each other, adequate evidence that
there
        was a sinister purpose.
   MR JUSTICE GRAY:  That is as may be, but I would like an
answer
        to my question because I think you must come clean as
to
        your position.
   MR IRVING:  I do not think I am equivocating.  My position
on
        this particular room is that it was never used in
there
        was gas chamber sense, in the sense described by the
        eyewitnesses because of course the lack of holes
proves
        that the eyewitnesses have lied.
   MR JUSTICE GRAY:  That is getting close to an answer but it
is
        not quite an answer.  Are you accepting it was a gas

.          P-154



        chamber in the sense that it had the facility for gas
to
        be inserted by whatever means, but contending that
humans
        were never killed by gas in that chamber?
   MR IRVING:  Certainly on one occasion it was referred to as
a
        Vergasungskeller and also referred to as a
sonderkeller, a
        special cellar or special basement.  That I also
accept.
        What I do not accept is that it was going to be used
for
        the mass killing of human beings by gas.  This is a
very
        clear statement.  What I do postulate is that it was
also
        simultaneously being held in prospect and even
converted
        for use as an underground air raid shelter, being one
of
        the very few subterranean buildings on the site in the
        event that mass attacks in this part of Poland also
began,
        given the proximity of the IG Farben works.
   MR JUSTICE GRAY:  I am sure I missed it, but was part of
that
        answer that yes, you do accept that it was there was
gas
        chamber and that you accept that it was on occasion
used
        for killing human beings?
   MR IRVING:  I accepted it was referred to as there was gas
        chamber, my Lord, which is not quite the same thing
and
        there are documents ----
   MR JUSTICE GRAY:  Are you accepting it was in fact there
was
        gas chamber?
   MR IRVING:  That I have not seen evidence for.
   MR JUSTICE GRAY:  So you are not accepting that?
   MR IRVING:  I am not accepting that part of the statement

.          P-155



        because I have not seen any evidence that bears that
part
        of the statement out.  I have seen evidence that it
was
        referred to by the German authorities as there was
        Vergasungskeller, there was room for gassing in.
   MR JUSTICE GRAY:  But you still do not accept that it was
in
        fact there was gas chamber?  Is that the position?
   MR IRVING:  That is precisely my position, my Lord.
   MR JUSTICE GRAY:  Then we go through the drawings.
   MR IRVING:  The drawings, but only in respect to
elucidating
        this point.  You said that you had two or three
matters in
        the drawings which you thought would bear out this
        contention?
   A.   I am just trying to make up my mind how to do this.
We
        are going to go through there was complex exercise in
        which I have now to make up my mind how to work most
        effectively through this.
   MR JUSTICE GRAY:  Just think. Do you want to adjourn for
five
        minutes?
   MR IRVING:  Alternatively, we could come back to this
question
        on Friday, my Lord, which would give one whole day to
look
        at the drawings and I could move on to the prewarming
        question, which is the next one logically.  I would
prefer
        to do that, frankly.
   MR JUSTICE GRAY:  I think, since we have reached the point
of
        the drawings and we have just had that exchange, I
would
        slightly prefer to do it now.

.          P-156



   A.   May I ask something? There are some ways this could be
        helpful because I am not completely unprepared for
this
        thing.  I have two ex students of mine make on the
basis
        of all the blueprints there was computer model of
        crematorium No. (ii).  This is only on the basis of
the
        blueprints and whatever is added is very clear.  For
        example, the only thing which is added are the Zyklon-
B
        introduction columns which are clearly not in the
        blueprints, and there was speculative depiction in one
of
        them of how the hot air system would have worked.
This is
        all prepared.  I have slides of this whole
reconstruction
        by which we can actually translate the blueprints into
        something which laymen in architecture can read.  I
have
        them also as pictures that were printed out.
                  On Friday, with always the blueprint right
next
        to it, I could give there was complete presentation of
        this building to show the important things which would
        maybe help your Lordship to get quicker into the gist
of
        things.  It is something I am prepared to do.  I can
do it
        without it, but it will be more of there was struggle
to
        do without it.
   MR JUSTICE GRAY:  Mr Irving, do you have any objection to
that
        being done as an exercise?
   MR RAMPTON:  That is what I would have proposed, my Lord.
        Given what I would submit is the relative collapse of
the
        eyewitness evidence in relation to this building ----

.          P-157



   MR JUSTICE GRAY:  Just answer the question.  Do not worry
about
        the eyewitness evidence.
   MR IRVING:  Then the answer is yes I think it would be very
        fair to Professor van Pelt.
   MR JUSTICE GRAY:  We will do that on Friday.
   A.   In forms of slides or with the pictures?
   MR JUSTICE GRAY:  Whichever is easier.  Mr Irving is happy
you
        should do it, so you do it in whichever way is the
more
        informative for the court.
   A.   I would like to do it then in slide form since it is a
        more public thing and I can point at things on the
screen
        and it is always clear to what I am pointing.
   MR JUSTICE GRAY:  If you are happy with that, Mr Irving?
   MR IRVING:  Provided it goes strictly to the issues that we
        have delineated.  The Professor said that there were
there
        was number of points which, taken in conjunction,
        substantiate his beliefs and we do not just have a
general
        cook's tour of the building.
   MR JUSTICE GRAY:  No.  This is designed to show that the
        blueprints have pointers within them which suggest the
use
        of that chamber was as there was gas chamber.
   A.   Yes.
   MR IRVING:  That can only be there was useful exercise.  So
we
        will leave the drawings for the moment, Professor, and
we
        will continue just briefly with the documentary
evidence.
   MR RAMPTON:  My Lord, again, I am puzzled.  Mr Irving seems
to

.          P-158



        be under the impression that there were only two
relevant
        eyewitness accounts so far as this witness is
concerned.
        I am there was bit bothered by that.  I could come
back to
        it in re-examination but I think there may be a
        misunderstanding -- Mr Irving said it several times --
        between Mr Professor van Pelt and Mr Irving.
   MR JUSTICE GRAY:  I think Professor van Pelt has identified
        five camp officials.  I think we all know that there
are
        others.
   MR RAMPTON:  Yes.
   MR IRVING:  These are the five principal ones on which he
rests
        his case as far as the eyewitness are concerned and I
do
        apologise if I gave the impression that I had only
        demolished two of them.
   MR JUSTICE GRAY:  Let us leave the debating points on one
side
        and press on with the cross-examination croaks.
   MR IRVING:  Professor van Pelt, prewarming of the mortuary.
        You have rightly raised your eyebrows on that and said
        this surely has there was sinister purpose.  Have
        I summarized your position correctly?
   A.   Shall we get the document maybe?  It is in the bundle.
   Q.   Yes.
   MR JUSTICE GRAY:  K 2.
   MR RAMPTON:  Yes, tab 4 of K 2.
   MR RAMPTON:  It is page 39, my Lord, in the handwriting.
   MR JUSTICE GRAY:  Thank you.

.          P-159



   MR IRVING:  This is there was letter from Auschwitz to the
Topf
        company, is it not?
   A.   Yes.  It is there was letter sent on 6th March 1943,
which
        is a little over there was week before the building is
        really taken into use.
   Q.   Would you like to translate the first paragraph, or
shall
        I?  On the basis of your proposal this agency or this
        office is in agreement that the basement No. 1, this
is
        the mortuary No. 1 with the collapsed roof, is that
        correct?
   A.   Yes.
   Q.   Should be prewarmed with the exhaust air from the
spaces
        of the three extractor fans.  Would that be correct?
   A.   Yes.  Probably it is there was forced draft, yes.
   Q.   They are going to have some kind of heat exchanger so
that
        they can take heat from the furnaces in some way?
   A.   Yes.  I can explain very simply what happens is that
the
        ovens are connected to the chimney -- this was Topf's
        idea -- in order to get there was better draft from
the
        ovens to the chimney, they thought to actually --
there
        are five ovens and then there is the waste
incineration
        oven which was never built, to have one ventilator at
        every two ovens which was going to basically suck the
        smoke out of the oven into the chimney to put there
was
        ventilator there.  These ventilators were placed in
small
        rooms.  The idea is that of course there is going to
be an

.          P-160



        incredible heat built up in these ventilators because
the
        smoke is very hot, that you could regenerate, and
there
        were other plans also, that heat.  This particular
        proposal is to use the heat built up in these little
rooms
        in which the ventilators are, to bring that back into
        morgue number 1.
   Q.   There was lot of the documents in fact do indicate
there
        was desire to conserve energy, do they not?  To
extract
        the energy from the incineration plant and this kind
of
        thing, use it for boiling water for the showers and so
        on?  Am I right?
   A.   Yes.  There are there some proposals.
   Q.   What concerns you about the prewarming?  Why should
this
        room not be prewarmed, the mortuary?
   A.   What concerns me of course is that one would want to
keep
        the morgue cool, and that to actually blow hot air
into
        there was morgue does not make much sense if the space
is
        going to be used as a morgue.
   Q.   Is this your considered opinion as an architect, or as
an
        historian, or as an archeologist?
   A.   As there was person who has common sense.

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