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

   Q.   No.  This is not a trap.  We are trying to educate the
        court.  I have to admit that I have learned a lot out of

.          P-169

        Neufert as I went along as well.  But I think I have made
        the point that the provision of heating in a mortuary is a
        requirement, at least by the guidelines which were
        standard in all German architects' offices at that time,
        and no special significance can be read into the fact that
        they were trying to it in a cost effective way by using
        heat from the incinerators.
   A.   If that were to be the case, the heating installation
        would have been included in the original design of the
        crematorium.  It is not.  What actually it says here is
        why, why do you want to be able to keep the temperature of
        the morgue in that range of 2 to 12 degrees?  It is
        because the corpses still have to be viewed by the people
        who are basically the family members.  If we look at the
        diagram, I am very sorry, my Lord.  I have a diagram and
        you do not, but there is actually a diagram which shows
        that there is a Leichenshauraum, which means a room to
        show or to look at the corpse.  So this is a very usual
        thing in a crematorium.  The body is stored.  It happened
        to us very recently in my family.  You go and before the
        final cremation you still have an opportunity to look at
        the corpse.  You do not want to look at the corpse where
        ultimately frost has destroyed the corpse.  This is the
        purpose for that particular thing.  It has nothing to do
        with the mechanics or the physics of incineration.  It has
        to do with a certain sense of decorum.

.          P-170



   Q.   The fact remains, does it not, that the guidelines say
        mortuaries have to be warmed and they are going to
have
        the local building inspector from Kattowitz or Cracow
        coming round and he is going to say, ' Oy, you have
not
        got heating in here, cannot switch on until you have
the
        heating fixed"?
   A.   The fact of the matter, my Lord, is that these are
merely
        guidelines.  If the guidelines in Neufert had been
        followed by the Auschwitz central building office,
they
        would have included the heating for the heating system
and
        also probably the cooling system for the morgue from
the
        beginning in the design.  This has not been done.  For
a
        year and a half this design has been developed without
any
        ability whatsoever to bring any heat in that morgue so
it
        is absolutely, I think, nonsense to suggest that, with
        this Neufert in mind, the Auschwitz architects were
        designing their morgues.
   MR JUSTICE GRAY:  By March 1943 how far advanced was the
        construction of crematoria (ii) and (iii)?
   A.   The building was finished and the design started in
        October 1941.
   MR IRVING:  They could not switch it on because they had
not
        made provision for the heating at this point.
   A.   They had forgotten it, but the inspector in Kattowitz
        obviously had also overlooked this one issue.
   Q.   But the burden of the letter of course says this is a
very

.          P-171



        cost effective way of doing the heating.  It is not
saying
        you have forgotten the heating, it is saying let's do
it
        by this way because that is going to save the Reich
money
        or fuel or whatever.
   A.   Please, Mr Irving, show me any other letter.  I have
never
        seen one.  I am under oath, I understand, here.  I
have
        never seen any other letter talking about bringing any
        heating, any hot air, or any other means of heating
into
        the morgue.
   Q.   But fact remains that mortuaries have to be warmed, so
our
        common sense for once is wrong.  The audience is wrong
in
        this particular question.  The book gets it right.
The
        book says it has to be kept in a range of temperatures
        between 2 degrees and 12 degrees, either by heating or
by
        cooling.
   MR JUSTICE GRAY:  What about crematoria 4 and 5?  Was there
any
        heating provided for that?
   A.   There were stoves in crematoria 4 and 5.
   Q.   That was how they heated them?
   A.   Yes, no cooling installation.
   MR IRVING:  Would you now turn to page 255, please?  We
have
        now left the heating element.
   A.   Sorry, my Lord, I would like to come back to this
answer
        because I have made a mistake.  The "them" you refer
to
        were probably morgues.  I refer to the gas chambers of
        crematoria 4 and 5.

.          P-172



   MR JUSTICE GRAY:  I was referring to the morgues or the
        mortuaries, yes. Did they have any heating?
   A.   There was a mortuary in crematoria 4 and 5 and they
did
        not have any heating.
   MR IRVING:  Will you now turn to page 255 of the architects
        guidelines?
   A.   Yes.
   Q.   This shows halfway down on the right things that are
        needed for air raid shelters.  Does this show a door
        opening outwards?  Can you see the metal gas tight
door
        with the typical heavy handles?
   A.   Can you refer me to the particular passage?
   Q.   Page 255, on the page called Luftshutz air raid
protection
        ARP, and it has various sketched layouts of air raid
        shelters and various air raid protection
installations.
        I am sorry, my Lord, I should have provided you with a
        copy.
   MR JUSTICE GRAY:  I am following.
   MR IRVING:  Do you agree that that shows a steel door or a
door
        of some heavy substance designed to open outwards with
        handles on the outside?
   A.   I do not see any steel door.  That is the problem.  Oh
        there is a door.
   Q.   Yes.  Two of them?
   A.   Yes.  That is one.
   Q.   (German spoken - document not provided) 4104.  They

.          P-173



        actually had a German standard, the equivalent of
British
        standard, what a standard gas tight door looked like.
I
        will make an enlargement of this and provide it to
your
        Lordship because it is exactly like the doors that
        I believe the other side will produce pictures of.
   A.   OK.  It is unclear to see what is in and out in this
        drawing.  To be very honest, if this door is hung on
the
        inside -- again it is a very technical matter and I am
        uncomfortable discussing this without you actually
seeing
        the picture.
   MR RAMPTON:  I am also a bit uncomfortable trying to follow
a
        cross-examination when I do not have the document.
   MR JUSTICE GRAY:  I know, but let us try and do the best we
        can?
   A.   Shall I draw what actually the picture shows and then
I
        think we have a very quick answer.
   MR JUSTICE GRAY:  You are saying that the drawing is
equivocal
        about whether it opens inwards or outwards?
   A.   No.  It shows that this door actually turns towards
the
        inside and there is a very easy way to substantiate
that.
   MR IRVING:  Do you wish to explain why.
   MR JUSTICE GRAY:  Yes.  If you want to, yes, do.
   A.   The door is on the inside of the wall, so there is a
wall
        and the question is where would the door be hung.  I
am
        trying to think this through.
   MR JUSTICE GRAY:  I cannot see that that would affect which
way

.          P-174



        it opened, but maybe I am missing something.
   A.   May I draw it?
   MR JUSTICE GRAY:  Yes, of course.
   A.   I have in my bag a lot of air raid shelter designs in
        Auschwitz.  So there is a wall right here.  There is a
        wall right there, and then the door is hung sitting
right
        here, and the door is like that.  The implication of
        course is that the door opens like that.
   MR IRVING:  It is not going to open any other way.
   A.   No.
   Q.   It is going to come up against----
   A.   I just want to say that I am talking here, just trying
to
        think out loud.  I do not have anything more right now
        about it.
   MR JUSTICE GRAY:  I think I know what you are going to say
        next.
   A.   I have not seen this door and I have not inspected
this
        particular shelter, but if indeed the door is fastened
        right here and right there, it would make sense to me
to
        think that, if the hinges are right there, the hinges
        would be on the inside, not on the outside because, if
        they are on the outside, it would be easy to blast
them
        off.  That is all I can say right now if you want to
        determine what is inside and outside.  I do not want
to
        make any more specific statements on this.  But we can
        look at documentation on doors and air raid shelter
design

.          P-175



        in Auschwitz and I am happy to do that to the court.
   MR IRVING:  That is the actual copy.  I have marked it with
an
        arrow, my Lord.  You will see the door rests on rims
on
        the outside of the wall.
   MR JUSTICE GRAY:  Yes, I see.
   MR IRVING:  I did alert the defence to the fact that I was
        going to take an interest in Neufert and I enquired
        whether Professor van Pelt had a copy of Neufert.  I
am
        sorry, I did not alert them to the specific matters
that
        I was going to raise.  Finally, is there anything
further
        you wish to say on the subject?
   A.   No.  I think it is very difficult to come to any
        conclusion right now on the basis of that drawing.
   Q.   But common sense suggests that, if you have 4,000
pound
        bombs blasting outside a building, you do not want a
door
        that is going to come flying open into your face?
   A.   I do not know.  It is common sense that you do not
want,
        if a building collapses and collapses over the air
raid
        shelter, you do not want all the brick and rubble to
be
        right in front of the door so you can never open the
        door.  So you are inside there without able to leave.
   Q.   Can I now in general ask you by what means the corpses
        were taken out of the gas chamber upstairs to the
level
        where the furnaces were?
   A.   In crematorium (ii)?
   Q.   In crematorium (ii) I am only interested in
crematorium

.          P-176



        (ii).
   A.   I just have to redirect my mind.
   Q.   I am only interested in crematorium (ii) because that
is
        where you said this was where the 500,000 people were
        killed.  You called this the centre of the atrocity.
   A.   They were brought up by elevator.
   Q.   They were carried up by elevator.  It is difficult to
say
        where it was, I suppose, is it not?
   A.   No it is actually quite easy.  The elevator is right
        here.  Actually the pit is still there.
   Q.   The pit is still there?  Do you know anything about
the
        dimensions of the elevator shaft?
   A.   It would be a little over, I would say, 2 metres 30,
one
        side, maybe 1 metre 40, 50 in the other.
   Q.   In our language how many feet is that?  Six or seven
feet?
   A.   Yes, eight feet by five feet, something like that.
   Q.   Yes.  Well 2 metres 30 is six feet, about seven feet.
   A.   We can check it on the blueprints, so why do we not do
        that?
   Q.   This is quite an important point, my Lord.  This is
the
        bottleneck.  We are looking at the bottleneck now.
   A.   We have actually the dimensions 2 metres 70 by 1 metre
43,
        so 2 metres 70.  In the blueprints this is document
3B,
        tab 1, of the documents, it says in the enlargement to
the
        right.  So 143 would be 4 feet, 4 feet 10 inches and 2
        metres 70 would be ----

.          P-177



   Q.   Eight feet?
   A.   No, it would be 9 feet, 30 centimetres per foot.
   Q.   So, what, it is about as big as one of these table
tops,
        is it, the shaft?
   A.   No, 9 feet is longer than this table, and certainly it
is
        much wider.  This is less than a metre.
   Q.   I am just trying to get an idea.  Of course, that is
not
        the area of the floor space in elevator itself, is it?
   A.   The elevator, we can go back to the blueprint.
   Q.   Yes.
   A.   It says -- the dimension is taken, the width is taken
on
        the basis of the actual width of the platform.  In the
        length I have to admit, at least in the design, the
actual
        platform would have been slightly less than 2 metres
70.
   Q.   Because of course you have got to have room for the
        counter weight to go up and down?
   A.   No, the counter weight, there is a space for the
counter
        weight right -- it is spared out to the side towards
        morgue No. 1.
   Q.   Although it is not in any of these designs, in the
Neufert
        designs the counter weight comes down inside the
shaft?
   A.   Are we referring to the plans of the crematorium or to
        Neufert?
   Q.   You are saying there was an extra shaft to the counter
        weight?
   A.   There is quite a substantial space, I would say
probably

.          P-178



        one foot and a half, at the side of the platforms
through
        which the counter weight could go.
   Q.   Very well.  So what was put into this?  It was like a
        hospital lift, was it, in which bodies put or how
would it
        normally be designed if this operating as a mortuary,
what
        kind of insulation?  Would a gurney or stretcher be
        wheeled in there carrying the bodies if it was a
normal
        mortuary?
   A.   I have no idea how lifts in normal mortuaries are.
The
        information says "auf Zug", I presume that in this
case
        this was designed for this building.  This building
        obviously deals with mass mortality one way or
another.
        So I think it is very unlikely that a gurney would
have
        been wheeled into this thing, because I would not know
why
        you would bring out a gurney into this morgue, and
then
        load it on a gurney, put the gurney in the elevator
and
        then immediately burn the body upstairs in a mass
        incineration facility.
   Q.   First of all, we will start with the normal mortuary
        design because this was presumably a standard mortuary
        design which has been adapted for special conditions?
   A.   No, Mr Irving, this is standard mortuary design.  This
is
        a rather unique mortuary design, probably unique in
the
        world, in the history, no, it is not a standard.
   Q.   But it was designed as a mortuary?
   A.   Sorry, I stated it wrongly.  You said "mortuary"

.          P-179



        I meant ----
   Q.   The entire building was ----
   A.   --- crematorium.

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