The Nizkor Project: Remembering the Holocaust (Shoah)

Shofar FTP Archive File: people/i/irving.david/libel.suit/transcripts/day011.08

Archive/File: people/i/irving.david/libel.suit/transcripts/day011.08
Last-Modified: 2000/07/20

   MR JUSTICE GRAY:  Is this 4 or 5 or were they indentical?
   A.   This is No. 4.  Left equals right.
   MR JUSTICE GRAY:  Otherwise the same?
   A.   We are going to turn to the model now.  What is the
        important thing is that these are stoves indicated in
        these rooms.  The plan only shows basically a block with a
        cross through connected to a chimney.  I was not present

.          P-65

        when this final thing was drawn, and my ex students have
        drawn in what are Canadian stoves basically, big iron
        ones.  It would be more likely, given what the design
        culture was and the means of production in Poland that it
        would have been a so-called cuttle hole in the design at
        least.  But what we also know is that this cuttle oven
        that were installed, but at a certain moment also are
        stories about portable stoves.  I do not know really know
        what to make of that, but they were heated with portable
        stoves, these spaces, which means the cuttle oven broke
        down, yes or no.
   Q.   What were these spaces again?
   A.   These are the alleged gas chambers right here, and then we
        have here the entrance vestibule, undressing room, in the
        winter used as undressing room, but also a morgue
        installation room.  In the summer there are accounts that
        people undress outside of the building.
   MR IRVING:  The average gas chambers, how were they designated
        on the blue prints?
   A.   They are not designated at all.  There is no designation
        at all.  Actually, this room is also not designated.  So
        now we actually are looking at the side we are going to
        enter very soon.  Again, I do not think we need to explain
        too much, except these chimneys, which are sitting right
        there, to which these stoves are connected, and also again
        the small little windows, 30 by 40 centimetres, as the

.          P-66

        plan says, which give access to these throw light or not
        into those lower spaces.
   Q.   Can I ask you what was the building made of?  Just bricks
        was it?
   A.   Bricks, yes.
   Q.   Quite a flimsy construction, in other words?
   A.   Yes.  I mean flimsy.  If you throw a bomb on it, yes.
        Certainly these spaces would not have been very useful as
        an air raid shelter.  Now our eye level has gone down and
        we are now going towards this entrance right here, this
        vestibule.  We have now come into the vestibule.  We turn
        left first inside this very big room which gives access to
        the schloit and then the incineration room.  This is that
        very large hole in the middle, which eyewitnesses say were
        used especially in the winter as an undressing room but
        also was used as a morgue.
                  Now we turn around 180 degrees.  I want to show
        you.  It is an open roof truss situation there, the
        vollmar as it is called, V O L L M A R, that is, it is the
        most economical way to construct a roof in a wartime
        situation.  Now we turn around.
   Q.   What are those roof trusses made of?  Steel or wood?
   A.   Wood.  This was really as cheap as possible and as light
        as possible.
   Q.   So it would have been totally unsuitable as an air raid
        shelter then, this building?

.          P-67

   A.   Yes.  So we now go back towards the incineration, towards
        the vestibule.  I just want to say that this actually is a
        detail which is in the photos of the building and not in
        blue prints, but at a certain moment in the construction
        they decided to put windows in that room, which are not in
        the blue print, but they are in the photos.
   Q.   About how high up are those windows off the ground?  Could
        you see in them?
   A.   No.  They were quite high.  You would not see in them.
   Q.   Which is what you would expect in a mortuary then?
   A.   Yes, possibly, or another use.  So now we have turned
        around 180 degrees and we are looking back at that door,
        just before, and I am going back into that space to the
        right.  What I am going to do is take you through these
        spaces.  It is a kind of surreal experience, I must say,
        but I do not have a picture right now of this space, but
        immediately go into this space.  So I have a view going in
        here.  Then first we have two views inside this space,
        which is one from the door looking in, and then from that
        point looking back.  Let us call this for a moment No.  1,
        and this No. 2.  Then we look inside this space and from
        the door looking back.  That is room No. 2, so at any
        given moment we know where we are.
                  We are now in that second vestibule, and we look
        here in that space No. 1 to the side, and we have here
        actually at the end of it an opening which actually gives

.          P-68

        access to the ovens.  These ovens were always fired from
        the back, these cuttle ovens, or they could be.  Two or
        three rooms shared them.  So this was to the point where
        they could be heated and the same is actually right here.
        That is what the blueprints indicate but it is not in the picture.
                  I just want to point out this porthole sitting
        right there, 30 by 40 centimetres, in the plan.  I do not
        know exactly which blue print we are talking about in the
        court bundle, but now we are looking in room No. 1.
        Again, two of those openings right there, plus an outside
        door, which by the way opens to the outside.
   Q.   Before you move on from that picture, Professor can I ask
        you, is there any provision in this room that the
        blueprints or drawings inform us for drainage?
   A.   There is drainage, yes.
   Q.   Where are the drains in this room?
   A.   They are not depicted, but the blueprints show them.
   Q.   You appreciate that, if this is a gas chamber, it would
        need drainage?
   A.   Yes, but the blueprint, I did not oversee the final making
        of these models.  They are in some way crude but in the
        blueprints I am happy to point out the drainage to you.
   Q.   I would be happy, when you return to the witness box, that
        you do so because, when people die en mass, it produces
        unpleasant after effects which need to be cleaned up.  If

.          P-69

        there is no provision for drainage, it is a problem we
        have of course with Leichenkeller No. 1, with the draining
        provisions there too, which are of course far worse, being
   A.   We can just look at the blueprints in both cases to look
        at the drainage, I think.
                  Now I just walk outside of that door.  I just
        want to show you that we were in this room right there.  I
        just popped outside.  We will go back in that room right
        now.  Now we look back to the door we came in and there
        one sees the stove in the corner, and this port hole right
        there, 30 by 40 centimetres connecting to the next room.
        There we have little detail.
   Q.   Would you like to tell the court what inference you are
        inclined to draw from the porthole's presence?
   A.   The portholes together are obviously the kind of gas tight
        shutters which I mentioned in one the bills, 30 by 40
        centimetres.  They are they are being ordered, 12 of them,
        six for this building, six for the other one, and they are
        ordered at the size of 30 by 40 centimetres.  The plan
        shows quite literally they are 30 by 40 centimetres.  It
        is in the bundle in detail.  We have enlarged it a few
        times.  Then of course a number of these portholes have
        survived and are installed in crematorium 1 right now in
        the back, and can be inspected, and again are 30 by 40
        centimetres and obviously they are very thick and they

.          P-70

        have a kind of gas tight design that there is a number of
        different, I do not want really know, my English starts to
        reach its limit.
   Q.   Fasteners?
   A.   Jambs have a kind of seal in it in the way it is designed
        so it is very difficult.  They are very thick.  They are
        like 20 centimetres thick.
   MR JUSTICE GRAY:  Have they been tested for cyanide?
   A.   They have not been tested for cyanide.
   MR IRVING:  Would you agree that those shutters that have been
        found in the Auschwitz camp are in fact standard German
        air raid shutters supplied by manufacturers to a standard design?
   A.   First of all, I do not know but it was very clear.  What
        we do know is that these are 30 by 40 centimetres and that
        the things ordered were gas tight things of 30 by 40
        centimetres.  The only plan I have where they have twelve
        of these holes of 30 by 40 centimetres is actually the
        plans for these rooms at the end of crematoria (iv) and 5,
        which obviously were not air raid shelters because the
        roof construction is too flimsy.
   Q.   Am I right in suggesting that the inference you are
        drawing is that through these apertures the top six
        substances were thrown?
   A.   Yes.  We go back in the vestibule.  We are now moving to
        room No. 2.  The door is open and we see now the stove,

.          P-71

        and again in the room one of these little openings.  Now
        we are in the room, just entered.  Here is the stove.  We
        look now to the outside door, two other 30 by 40
        centimetres little windows, and we turn around now.  We
        look back at the stove and the door towards the second
        vestibule, so to speak.
   Q.   Professor, why would they not have adopted the method they
        allegedly adopted here and just drilled holes in the roof
        to drop the substances through?
   A.   The problem, first of all, is you would have to go on the
        roof and this building was all above ground.
   Q.   Yes.
   A.   This method was used already in bunker No. 2 and bunker
        No. 1, where they used basically holes or little windows
        in the side of the building to introduce the Zyklon-B.  So
        it was a proven method.
   MR JUSTICE GRAY:  What is the evidence for that?
   A.   For what?
   Q.   That they injected Zyklon-B through the windows of bunker
        No. 2 and No. 1?
   A.   Eyewitness testimony.

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