Archive/File: people/i/irving.david/libel.suit/transcripts/day012.02 Last-Modified: 2000/07/20 . P-9 MR IRVING: In that case I would draw you attention then when the time comes to a third document here, my Lord, which is the Washington Post on the morning before St Martin's Press took its decision and they quoted the Second Defendant as an authority for their decision. Your Lordship may consider it to be tenuous or you may consider it to be relevant. MR JUSTICE GRAY: No, I do not consider it to be tenuous. I just wonder how this witness can help on this. MR IRVING: Well, setting it in its broader context, as saying this is not just a misfortune that has befallen me, but is part of a group strategy, my Lord, and difficult though it is to establish, I will do what I can for the next five or 10 minutes and then turn him to whatever cross-examination Mr Rampton desires to make. MR JUSTICE GRAY: But I understand the way you put it. Thank you. MR IRVING: So you perceived the Jewish community as working in a certain way in order to suppress a certain book? A. Yes. Q. Yes. A. Well, there were several tactics the Jewish organizations have used. That was another one. Q. Yes. You have had a chance to read most of this bundle, which is identified by me as bundle E ---- A. Yes, I have. . P-10 Q. --- over the weekend, is that correct? A. Yes, I have. Q. Could you, again in just a very few lines, describe how the documents you have read in that bundle support or refute your own -- I have to ask what these papers are that you are looking at. A. This is simply a statement that I wrote out. Q. I think we will have to ask you to testify really from within yourself rather than from the written paper. A. Yes. I was not aware of that. Q. Yes. Having read the bundle of documents, would you describe roughly what the bundle of documents comprises? A. Well, the bundle of documents comprises a record of suppression of David Irving, cancelling of speeches, avoiding of contracts, as a result of pressure of various Jewish organizations in different countries. Q. Just from one country or from several countries? A. From several countries -- Canada, South Africa, Australia, I believe. Q. You would put the suppression of that book within that framework? A. Yes. If I had known about that actually, I would have explained in that section, including more examples of that, showing some examples of that. Q. Have you seen items in this bundle which lead you to believe that the Second Defendant has made herself a part . P-11 of that endeavour? A. Yes, I have. There was an article in the Washington Post quoting her -- I do not have the exact quote here. I can read it. MR JUSTICE GRAY: If you are going to rely on it in some way, perhaps you could tell me what it says? A. Yes. MR IRVING: It is ---- A. OK. In the Washington Post of April 3, 1996, she is quoted as saying: "In the past ... it says that in every generation there shall be those who rise up to destroy us. David Irving is not physically destroying us, but is trying to destroy the memory of those who have already perished at the hands of tyrants. They say that they do not publish reputations, they publish books, but would they publish a book by Jeffery Damer on man, boy relationships? Of course, the reputation of the author counts and no legitimate historian takes David Irving's work seriously". It is that last part that certainly drew my attention because I have seen historians praise his work, but also just the fact that she was literally part of the pressure on St Martin's Press. Q. Can I ask you to go to page 250 of the bundle? A. I do not have a copy here. Q. I will give you a copy. This is bundle E, if you go to page 250 of bundle E? . P-12 A. Yes. Q. Is that a letter from the Simon Wiesenthal Centre to the Second Defendant, Mrs Deborah Lipstadt? A. Yes, it is on the head of Simon Wiesenthal, signed by Saul Litman. Q. Does it make reference to a student paper I sent to you? A. Yes. Q. Does Mr Litman who wrote the letter conclude the letter saying, "Please recognize that it is not for publication or direct quotation. It is, after all, an unedited student's work and contains many phrases and comments that neither you or I would use in a situation which clearly involves considerable delicacy"? A. Yes, that is a direct quote. Q. Would you now turn to page 251? A. Yes. Q. Is this, apparently, an anonymous report of approximately ---- A. 25 pages. Q. --- 12 pages or thereabouts called, "History Rewritten, the World of David Irving"? A. Yes. Q. Have you seen anything in that report which indicates that there has been a deliberate attempt made by an organization to destroy my legitimacy as an historian? A. Well, yes, on page 253 ---- . P-13 MR JUSTICE GRAY: What do you say this document is that you are looking at, Professor McDonald? MR IRVING: It was a document that was provided to the Second Defendant by the Simon Wiesenthal Centre, my Lord. MR JUSTICE GRAY: That is the one referred to in the letter you have just taken us to? MR IRVING: We have to presume so, my Lord. It took a certain amount of fight to obtain a copy of this for the solicitors. I had to obtain court order finally to obtain a copy of it. MR JUSTICE GRAY: I see. MR IRVING: They provides what looks like the covering letter in a separate episode and gave it the same discovery number, No. 500. But all I propose to do is to rely on the content of this document which went to the Second Defendant, and you have drawn our attention to page 253, and which paragraph do you consider is suggestive of an attempt to destroy my legitimacy as an historian? A. In the first full paragraph, is still in the introduction, it refers to quotes later on from you, but then it says in the middle of that paragraph: "These quotes serve as a clear example of why he should not be allowed to disseminate his message of hate as freely in other public forums". Q. Which paragraph is that again? A. The first full paragraph on page 253. . P-14 Q. Beginning with the words "The focus of"? A. Yes. Q. "These quotes serve as a clear example of why he should not be allowed to disseminate his message of hate as freely in other public forums"? A. That is quite correct, and further ---- Q. At the bottom of that page, can I draw your attention to the sentence beginning, "The importance of" ---- A. Yes. Q. --- "such work is to deny Irving the legitimacy he so desires in his attempts to spread his anti-Semitic and racist messages", and are there any other passages in that which indicate an organized attempt to destroy my legitimacy? A. Yes, just a minute here. It probably bears mentioning on page 256 that, although the author of this report does view David Irving as a flawed historian, it is acknowledged that his revisionist themes are interspersed with genuine historical insight. Again, that is, sort of, what exercises me, but at the bottom of page 258, the last paragraph on page 258. Q. Would you read it out, please? A. The entire paragraph? Q. Yes. A. "David Irving's techniques challenge the most educated minds to adopt his version of reality. By revealing . P-15 Irving's methods, the illusion is portrayed as facts and his writings have been unveiled. Hence, while claiming to be a legitimate historian, Irving can now be identified with his underlying purpose, to morally rehabilitate Adolf Hitler and the Third Reich. Given this accurate version of reality, it is all the more clear why his activities must be curtailed and why his alleged legitimacy must be eradicated". Q. There is one particular passage, is there not, that you have read where they actually talk about the need to destroy my legitimacy as an historian? A. Well, I believe that was the main one. The final -- no, OK, yes, on page 273. Q. Yes. A. The author goes into various possibilities of how to deal with David Irving, one of which was just to go for free speech, but the other suggests, it says, "In the case of" -- this is on page 253 ---- Q. "In the case of David Irving", right? A. It is after the indent quote -- what? Q. The third paragraph, right? A. OK, yes. "In the case of David Irving, in his brand of Holocaust denial, the ultimate response is to cease providing him with a forum to convey his skewed version of history and to negate his attempts to obliterate the memory of millions of victims." . P-16 And I might point out also the last paragraph on page 276, where he quotes John Keegan: "No historian of the Second World War can afford to ignore David Irving". So, again, despite the fact that he is regarded among historians as important, some one must read, there are attempts to make, to curtail his freedom of speech, and so on. MR JUSTICE GRAY: Professor McDonald, how does that establish that Professor Lipstadt is part of this conspiracy to discredit Mr Irving? A. To my knowledge and my only, the only linkage between Professor Lipstadt and this is the Washington Post interview. Q. What has this to do with the Washington Post? MR IRVING: My Lord, this document was from Professor Lipstadt's own discovery. MR JUSTICE GRAY: I follow that. It is a document that she was sent, apparently unsolicited, by the Simon Wiesenthal organization. What does that prove against her? A. Well, OK, this document -- there is not, but my impression was that David Irving has a general complaint about persecution by Jewish organizations and that is what I thought we were addressing here. MR JUSTICE GRAY: I see. Thank you. MR IRVING: My Lord, your Lordship said "unsolicited". In fact, there are other documents in this bundle where we . P-17 see the second Defendant specifically writing to all these bodies asking, effectively, what dirt they have on me, both in Canada and in the United States and in London. There is a whole list of them whom she thanks in her introduction, whereupon your Lordship will see from this bundle on a later date -- I shall draw your Lordship's attention to it -- that I made an application for specific discovery of these items. Unfortunately, we are not going to have a chance to cross-examine the Second Defendant on the completeness of her discovery, and I have done what best I can to establish what information she had. May I proceed? MR JUSTICE GRAY: Yes, please. MR IRVING: Professor McDonald, have you seen correspondence in this bundle between the Second Defendant and the Yad Vashem and, in particular, with Professor Yehuda Bauer, B-A-U-E-R? A. Yes, I have. Q. What was the content of that correspondence in brief? We can look at the correspondence ---- A. Do you have the page number for it? In brief, the content was to remind Professor Lipstadt of the importance of including David Irving in the book. Q. Had she not then included me in the original draft of her book from the correspondence that you have seen? A. I believe it was that you were mentioned in that, but the . P-18 clear intent was to emphasise you to a greater extent than it was before.
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