Archive/File: people/i/irving.david/libel.suit/transcripts/day011.03
Last-Modified: 2000/07/20


   MR JUSTICE GRAY:  It is the undressing room on the right, is it?
   A.   This will be then the undressing room and then the alleged
        gas chambers would be seen here, but you will see in more
        detail.  You already can see here the two chimneys, the
        chimney of the beiluftung and the entluftung, of fresh air
        coming in, foul air coming out.  We see in green where the
        systems are sitting.  This is one of the pipes, that is
        one of the pipes, and this is then a probable
        reconstruction where that hot air would have come in, but
        again we do not have any blueprints for that.
                  Then one would have come into this little
        corridor and then into this large morgue No. 2.  If one
        takes that entry right under the autopsy rooms, this is
        what one would have seen.  But was here at the site, based
        on the drawing of Olaire, we knew there was a ventilation

.          P-19

        system in that thing, but we did not know how it looked
        like because it is not in the blueprints.  It was brought
        in later.  But Olaire depicted to, I have used Olaire as,
        basically, the depiction of the undressing as room as the
        basis for this thing.
                  I am very sorry for the way the lighting has
        been depicted.  This has been, basically, standard 1999
        kind of light fixtures, and this is certainly not how it
        would have looked, the kind of way these light fixtures
        would have looked, but one gets a sense of how much light
        would have been in this room.
                  This is the later staircase.  This is the
        staircase which goes to the outside which was constructed
        in late 1943.
                  What I am going to do now is actually go around
        the undressing room morgue No. 2, and take the second
        entrance which was the entrance which was used in the
        Hungarian action after it was constructed to get a more
        logical flow of people into the underground space.  This
        entrance is also still there.  You can see it.  One would
        go down here and then enter in this underground space and,
        of course, see it then from a different perspective.
                  Now you come into this large underground space
        and now, of course, the ventilation is on the right side
        instead of on the left side.
   MR IRVING:  My Lord, can I ask occasional questions while we

.          P-20

        have him on a particular picture?
   MR JUSTICE GRAY:  Yes.  Try not to interrupt the flow otherwise
        we will get lost, but, yes, I think that is not
        unreasonable.  It is cross-examination.
   MR IRVING:  If we could just go back to the previous picture?
        Can you go back?  What kind of door would have been on
        that entrance?
   A.   We do not know because there is one -- the door is not
        there and the entrance is available in two blueprints
        called "Zeichaufnahme" which means a picture, a
        description, of the actual situation, but these two
        blueprints do not show actually what kind of door.
   Q.   So it could have been an air raid shelter door?
   A.   I do not know.
   Q.   Very well.
   A.   So we are now in this underground space, what became the
        undressing room, as the Defence maintains.  Now we go
        outside -- sorry, I will just go back.  We go -- actually
        behind the columns there is an exit door and comes out in
        the little vestibule, and originally where I stand was the
        original entrance into this vestibule from above.  That is
        the first staircase when we went down, and we see here the
        chimney going up, the entluftung chimney, taking the foul
        air out, and we see here a kind of computer model, this
        computer model, we see here basically the pipe coming off
        the undressing room going into that chimney, and we see

.          P-21

        the second, we see a second pipe -- actually, I do not
        know why it is red right now, but in some way the
        ventilation system of the gas chamber would also have
        connected to this.  We see here an elevator.  Again I have
        to tell you they took kind took 1990's language for it,
        and then here the entrance into the morgue No. 1.
                  Now, at that point again we have something of a
        difficulty, and the difficulty is that you see that there
        is one panel of the door is open, but the second one
        actually is closed.  It is fixed.  The blueprint shows,
        the last blueprint we have shows basically the double
        panelled door opening.  But there is at a certain moment
        an order for this particular door, and from that order it
        is clear that only one of the panels moves and that the
        second thing was actually either closed by masonry or by
        the fixed panel.  We can interpret that later, but in some
        way again I just want to point out at the moment what is
        in the blueprints, what is in inferred out of other
        documents and what, ultimately, is on the basis of
        eyewitness testimony.
                  So this particular reconstruction is made on the
        basis of a combination of the blueprint and a particular
        order for this gastur, as it is called, of one metre by
        100 -- one metre by almost two metres high, 192
        centimetres high.
                  We are now in the gas chamber or in morgue

.          P-22

        No. 1.  We have just walked in and this was the space one
        would have seen.  There are, basically, the entluftung
        system, the foul air is being taken out at the bottom
        connected to that chimney, and we have here the fresh air
        being brought in from the top.
                  Now, I will show you the blueprints in a moment
        because this only is to aid interpreting the blueprints.
        And then added in this particular thing which is not in
        the blueprints are three of the four Zyklon-B insertion columns.
                  Now, so there is none at first column, at third
        column, right there in the fifth column, they are
        alternating on the left and the right side.
                  I just want to go back for a moment.  The
        sub-division of this room in two rooms which happened
        later in 1943 would have occurred on this line here, on
        the fourth column, halfway.  Again, there is no blueprint
        for that.  Then we go back into this elevator space and we
        see here the elevator, there were actually doors brought
        in.  There were no doors and we see here this platform
        going up.
   MR IRVING:  It is a bit like a builder's hoist, is that
        correct?
   A.   Yes.  That is what they actually used because they were
        not able to get the right elevator.  Then this would have
        been the incineration room, of which we actually also have

.          P-23

        photos.  These are the incinerators, these triple muffle
        incinerators.  At the back is the coke supply.  This is
        also the fire grate and this is where the ashes are taken
        out.  So at a certain moment there is a description in
        Tauber.  What happens is that he has put in here, but what
        he says is that actually they start to fire, not that they
        put a fire in the ash muffle.  So he is not actually being
        burned directly, and so, if you read his description, this
        is the ash kind of muffle.
                  One drawing which is important is this.  Could
        you see from the inside of the incineration room, the roof
        of the morgue No. 1?  We have introduced on here, I think
        a little high, I must admit, these alleged insertion
        points, but certainly, because Tauber says that he is
        inside the incineration room, and I asked my student to
        actually step back a few steps from the window, so he does
        not stand right at the window but, if he was standing back
        at say a metre and a half into the space, look through the
        window, would he have been able to see anything?  He
        actually describes the situation and this is what he could
        have seen at those points.
   MR JUSTICE GRAY:  There is another witness who describes
        looking out from the incineration room, is there not?
   A.   I think that only Tauber does that.
   MR JUSTICE GRAY:  I thought there was another one.
   A.   There is another one who sees it from the outside.

.          P-24

   MR JUSTICE GRAY:  Maybe I am confused.
   A.   This is the question.  It is, from the inside of the
        incineration room, what do you see?  We go now back to the
        diagrams and I am going to turn the diagrams around in
        four basic exposures, every 90 degrees we turn around,
        first without the heating duct and then with the heating duct.
                  So again, we have here the incineration room,
        the flues going to the chimney.  We have here the
        entluftung, which is all green, going from the bottom of
        the gas chamber or morgue No. 1, and we have here the one
        system, only one pipe attached to the ceiling of morgue
        No. 2, all connected to this one chimney.  It is clearly
        indicated in the blueprints except this one which was
        constructed later.  We have here the chimney house, so to
        speak.  We have here the Beiluftung going from the second
        little chimney going in.  Then we have here the staircase
        with that slide in between, just indicated again rather
        vaguely.  We tried to create a wall transparent so that
        you can get some sense of what is happening there.
                  Then I am going to show the same thing.  I am
        going slowly to rotate it every ten seconds or so.  One
        can look at from a different perspective.  Now we are
        looking at it from the west almost, and one can see very
        clearly again the size of the undressing room.
                  If I am going too fast, please tell me because

.          P-25

        I will stop.
                  Here we have the staircase going into the
        basement, second staircase added later.  Underground flues
        again.  It is important of course in relationship also to
        crematorium 1 where there was an underground flue
        connecting the building to the chimneys.  The chimney
        seems to be standing separately, does it mean it is not
        connected?
                  OK, so that was the reconstruction.  So, with
        that in mind, I feel that we can go to the actual
        blueprints and so this is a heading of one of the typical
        ones.  Is there anything you would like to see again
        before we go in here?
   MR JUSTICE GRAY:  No but one thing did occur to me as you were
        going through.  Was there any heating in the undressing room?
   A.   There was no heating in the undressing room.
   MR RAMPTON:  Could I ask one question before we leave the
        picture?  It is out of order, I know.
   MR JUSTICE GRAY:  Mr Irving, I think that is sensible, do you not?
   MR IRVING:  Perfectly, my Lord.
   MR JUSTICE GRAY:  We are not exactly playing by the rules at
        the moment.
   MR RAMPTON:  Professor van Pelt, can I do it now before you
        come to the plans and the documents?  You showed us the

.          P-26

        new entrance to the undressing room in 43.
   A.   Yes.
   Q.   Do you know of any document which refers to gas tight
        doors for Leichenkeller 2?
   A.   No, I do not.  The only document which refers to a gas
        door quite literally is in relationship to morgue No.  1,
        not to morgue No. 2.
   MR RAMPTON:  It arose out of what your Lordship asked.
   MR JUSTICE GRAY:  Yes, thank you.
   A.   So this is a typical heading.  This is one of the original
        blueprints in early 1942 because we are dealing here with
        an adaptation.  What is very important -- I am going now
        to introduce, and I am very sorry, I do not think they are
        actually in my expert reports, and I do not really know
        how to do it, but this is the very, very first sketch
        which was ever made.  It was made in October 1941.  It is
        in my book.  It shows basically the same arrangement.  The
        crematorium is slightly different.  They are a number of
        things, but we are here at the ground floor.  You see
        incineration hole.  You see here you the autopsy rooms,
        the elevator more narrow than in the final one but there
        is the elevator.  There is the entrance to the side which
        is the one with the slide and the two stairs, the coke
        storage.  We have the office here, we have some bathrooms
        and so on, and then here we have the sauzuanlage as it
        says, which means the ventilators, not three around the

.          P-27

        chimney but one system preceding the chimney, the chimney
        standing asymmetrically, and here the trash incinerator.
        So this is the very first design.  As you probably realize
        now, the design was changed a little bit.
                  What is quite important in this first design is
        the particular arrangement of the underground space.  The
        only access to the underground space at this moment, and
        we do not know what has happened here or there, but I do
        not think there is any access on that side, but we have
        here the stairs going down with the slide, and then of
        course the elevator coming down right there.

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