Archive/File: people/i/irving.david/libel.suit/transcripts/day010.22
Last-Modified: 2000/07/20

   MR IRVING:  It is a useful exercise.  It is bottleneck in the
        operation which does give us a chance of arriving at some
        kind of concrete results.
   A.   I would of course be quite pleased if somebody who knows,

.          P-188


        if we got some more specific data about, you know, how
        long it would take for this elevator to come up,
because
        obviously if we are 50 per cent wrong, then we
suddenly
        have the bottleneck and there cease to be a bottleneck
or
        not.
   Q.   Just as in the calculation you made earlier on the
Zyklon
        use?
   A.   I took a very generous, very generous I think amounts
for
        delousing.
   Q.   We have those figures and I will supply them to you
within
        the next 24 hours, the actual carrying capacity of the
        lifts, the various models, the size and so on and the
        actual speed in minutes and seconds that it would take
to
        lift that distance.
   MR JUSTICE GRAY:  We are comimg back to that on Friday.  So
let
        us leave that and get on.
   MR IRVING:  My Lord, I just want to conclude by putting a
        number of general questions to the witness, if I may,
        which is, you will be glad to hear, off these very,
very
        minute questions in the broadest possible terms now.
                  You had a colleague working with on your
book,
        did you not, Deborah Dwork?
   A.   Yes.
   Q.   She is now a very famous Professor, is she not, at the
        Clark University?  She has a Chair of Holocaust
studies?
   A.   Holocaust history.

.          P-189



   Q.   Holocaust history.  Without wanting to sound tasteless
        about it, it has become quite an industry, a very well
        funded industry, has it not, this Holocaust education
        business?  She writes in her own papers that she has
        received $5 million a year for funding her Chair and
very
        enterprises?
   A.   She has been able to set up this Institute by this
money
        donated by various donors, yes.
   Q.   I am only asking these questions because you re one of
the
        world's leading Holocaust scholars and you are
probably in
        the best position to educate the court about these
        matters.  It has become big business and it is not
just
        I who say this; a number of other far more learned
people
        than I myself have said this.  The Chief Rabbi of
England
        said it once.
   A.   Mr Irving, I think that I am here as an expert on
        Auschwitz.  If you want to have testimony as a member
of
        the general public, and I am not one of the chief
        Holocaust historians, I am actually a cultural
historian
        who was worked on Auschwitz, as a member of the
general
        public I can answer.  I do not know if the Judge will
be
        very interested in my opinion.
   MR JUSTICE GRAY:  I am interpreting this question as
suggesting
        that your co-author was, effectively, delivering the
goods
        on the Holocaust, that is to say exaggerating it,
because
        she was being paid so well to do so.

.          P-190



   MR IRVING:  This is a very tactful way of putting it, my
Lord.
   MR JUSTICE GRAY:  It was not intended to be particularly
        tactful.
   MR IRVING:  This was the inference I am trying to draw.  I
am
        trying to find the justification for the word that is
        frequently used about my own endeavours as being
        "dangerous".  To what or whom am I being a danger?
The
        only interpretation I can put on it is the fact that I
am
        endangering people like Deborah Dwork who have made it
        quite a lucrative business, if one can regard being in
        education as being a business.  Certainly she makes $5
        million a year for her Holocaust centre out of the
        Holocaust and the history of the Holocaust and
teaching
        the Holocaust.  There are all sorts of profitable side
        lines in publication of books and so on.  This is what
        makes me into a danger, apparently, that if it turns
out
        that this building here has no holes in the roof, then
a
        large number of eyewitnesses have lied, and the whole
mass
        extermination chamber part of the story collapses as
        securely as that roof has done.
   MR JUSTICE GRAY:  Does Professor Dwork manipulate the
evidence
        because she is making so much money out of her Chair?
   A.   I will take your guidance on what I should answer and
what
        not.
   Q.   Answer it shortly.
   A.   May I point out, first of all, that this is money she

.          P-191



        raises for the Institute.
   MR IRVING:  It is not for herself personally of course.  I
made
        that quite plain.
   A.   Yes.  This is money which is raised to create Chairs.
To
        provide students with scholarships, to build up a
        library.  So in that sense I do not think that
Professor
        Dwork at all profits from this.  I also would like to
        point out that when Professor Dwork wrote this book
with
        me, Professor Dwork was not a Professor of Holocaust
        history at Clark University.  That in fact the sum
total
        of support we got for this project to write the book
on
        Auschwitz was 40,000 Canadian dollars which translates
at
        the moment to œ15,000 which I got from the Canadian
        Government, and that is all the support that went into
        writing that book.
   MR IRVING:  The obvious question then is would she have
been
        given a Chair in anything if she had not written the
book,
        let us put it that way round?
   A.   My Lord, I do not see it is relevant.  If you think it
is
        relevant I will answer the question.
   MR JUSTICE GRAY:  It has a sort of a relevance but not in
terms
        of your evidence.
   MR IRVING:  Yes.  I will abandon that line of argument, my
        Lord.  I just wanted to establish the fact somehow
that
        I am considered to be danger to something, and the
word
        danger is what puzzles me.  I am not a member of the
IRA.

.          P-192



        I do not go round blowing up cars.  So what am I
danger
        to?  I tried to put some flesh on to that particular
        matter.
   MR JUSTICE GRAY:  Right.  Next general question.
   MR IRVING:  Next general question, have you had the
opportunity
        to work in the Moscow archives?  I do not know the
answer
        to that.
   A.   I have worked on the basis of the microfilms which
were
        made at the same time that I had to work on this.
   Q.   Yes.  Have you worked in the national archives in
        Washington?
   A.   I have been once there, but not really.  I have not
really
        worked in the national archives.
   Q.   That really surprises me.  You aware, of course, that
the
        national archives in Washington have I suppose the
largest
        collection of captured German records including in
        relation to the SS and Auschwitz?
   A.   Yes, I am aware of that, and also I am aware that many
of
        them have been made available.  I am aware of the fact
        that one uses the archives which are useful for one's
        work.  It happens to be that the archives, you know,
when
        one works as an historian there are various particular
        things one researches for which one needs to go to the
        archives, because the documents are not available and
one
        wants to see those particular archives.  You want to
see
        the documents in situ.  In this case these are the

.          P-193



        Auschwitz construction documents.  Very important in
my
        book, or in our book since the name of Deborah Dwork
has
        been mentioned now, was the archive in Koblenz and to
a
        lesser extent -- this is the German Federal archive in
        Koblenz and to a lesser extent, for example, the
Berlin
        Document Centre and the archives of the court in
Vienna.
        These were the archives where the unpublished
documents
        were all stored.  For other things, more general
        information, I rely sometimes on documents as they are
        produced in facsimile and sometimes even on documents
as
        they are ----
   Q.   Can I halt this avalanche just there?  We are still at
the
        national archives in Washington.  In May 1997 I
believe I
        wrote you quite a lengthy letter?
   A.   You wrote it.  I never received it.  Yes.
   Q.   You never received this letter I wrote to you?
   MR JUSTICE GRAY:  What did it say?
   MR IRVING:  It is a six-page peon of praise of his book, my
        Lord, drawing his attention to certain documents and
        archives and inviting his comment on matters of
history,
        in the way that an historian should.  I wrote to him -
-
        your address is and always has been at all relevant
times
        presumably the Head of the Department of History?
   A.   No, I am not.
   Q.   But you have been at the University Waterloo, have you
        not?

.          P-194



   A.   Yes, but I am in the architectural school.  I am not
in
        the Department of History.
   Q.   If a letter is addressed to you at the University of
        Waterloo and properly stamped and posted, then there
is
        every likelihood that it will reach you, is there not?
   A.   I can only tell, and I am still under oath, that I
never
        received this letter.
   MR JUSTICE GRAY:  This is one question I am not going to
        decide.
   A.   I only learned of it a year ago when people pointed it
out
        to me on the web.
   MR IRVING:  Are you aware that that letter has been posted
on
        my web site for the last two years?
   A.   It happens that I am not very experienced with the
web.
        Only somebody told me last year when I was already
started
        to get involved in this case that it was posted on the
        web, and of course since I was already engaged on
actually
        starting to work on this there was no way I could
respond
        to it.
   Q.   Are you going to make complaints at the University of
        Waterloo that letters properly addressed to you,
properly
        addressed to your department, are not ----
   MR JUSTICE GRAY:  I think we have all got other things to
worry
        about than this wretched letter, if I may say so.
   MR IRVING:  Very well.  Is it not a pity that the letter
did
        not reach you in view of the fact that it contained

.          P-195



        pointers to historical records that would have been of
the
        utmost most information and assistance to you?
   A.   The book was published in 1996.  So your letter is a
year
        late after that.  I do not know which particular
documents
        you point to.  If you want to provide me with a copy
of
        the letter I will comment on these points.
   Q.   There is a copy of the letter in the bundle which I
gave
        his Lordship yesterday.  If I can summarize without
        looking for it, it drew your attention, for example,
to
        the interrogations of Rudolf Hirst which up to that
point
        you had made no attempt to read in the national
archives
        in Washington.  You had written the book about
Auschwitz
        but you made no attempt to read the verbatim
        interrogations of the commandant of Auschwitz?
   A.   May I point to your Lordship that these transcripts of
the
        interrogations Rudolf Hirst were actually published in
        facsimile I think in 1970 and I did read those
facsimile
        reproductions.
   Q.   And yet there is not a trace of them in your published
        volume?
   A.   But it seems to be that as one would want to use
Rudolf
        Hirst as a source, and I did not use every single word
        Rudolf Hirst said.  There are much better sources than
the
        interrogations.  For example, his later memoirs and
his
        essay on the Final Solution which he wrote in Poland
are,
        in fact, places where he himself tries to put he whole

.          P-196



        thing together.  Certainly the Auschwitz book was not
a
        history of what happened to the formation of knowledge
        about Auschwitz after the war.  I do not deal with hat
in
        the book.  I did deal with it in this book, as you
know.
        So I do not think that you can draw any conclusion of
what
        is included in the book of what I consulted or not
        consulted.
   Q.   Well, you gave very detailed footnotes indeed, did you
        not?  You are writing a book about Auschwitz and yet
you
        make no reference at all to having had in front of
you, as
        you say, the entire transcripts of the integration of
the
        Commandant?
   A.   Mr Irving, I just want to ask you, if at a certain
        moment -- I have looked in making this book at 10,000
        documents and ultimately I used 1,000 of them in the
        book.  You are not going to write 9,000 footnotes of
        actually mentioning the documents which you have not
used.
   Q.   I can sympathise with you because I am frequently in
the
        same position, but sometimes there are collections of
        documents that are so important that I have to say you
        ought to have used them?
   A.   Then I am very happy I am not your graduate student.
   MR JUSTICE GRAY:  Let me try to break into this.  My
        recollection is, I am probably wrong about, is that when
        you deal with Rudolf Hirst in your report you deal with
        the interrogations as well as what he says?

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