Archive/File: people/i/irving.david/libel.suit/transcripts/day013.20
Last-Modified: 2000/07/20

   A.   When was Reichart's book published?
   Q.   1994.
   A.   Was that available to me at the time?
   Q.   I have no idea.
   A.   When you see yourself that it was supplied to me in 1997
        with the covering letter.
   Q.   Look at Bergander's book.  Have you not read that?
   A.   No.
   Q.   35,000.
   A.   I know Bergander very well as a human being and I respect
        him as a friend and he is a jolly decent chap, but I do
        not put his book in the same category as I put Reichart's
        book having read Reichart's book.
   Q.   Mr Irving, a final question about Dresden.  Then, my Lord,
        I shall run out topics for today.  I explain what benefit
        we might gain from that when I finish.  One final question
        on Dresden.
                  Is it right that when your German publishers put
        a out version of Dresden in 1985 they described it as a novel?
   A.   I believe I am right in saying that Schindler's List when
        it is published has always had the title "a novel" written
        on the front the jacket.
   Q.   Is the answer to my question yes or no?
   A.   Yes, indeed, and they apologised to me for their mistake.
        I consider that to be a repugnant kind of suggestion on

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        your part.
   Q.   It is entirely consistent with every question I have been
        asking you on this topic since we started on it this
        morning.  Pie in the sky, Mr Irving, your figures.  May I
        suggest that the reason why you have done it is because
        you want to make false equivalence between the numbers of
        people killed at Dresden and the numbers of people killed
        at Auschwitz?
   A.   If I am permitted to re-examine myself in-chief then
        I would say the following, and it may be you would wish to
        interrupt me.
   MR JUSTICE GRAY:  No.  That is a question and so answer it in
        whatever way you think fit.
   MR RAMPTON:  Is that right?
   A.   Do I consider my figures to be pie in the sky?  No.
   MR JUSTICE GRAY:  Well, it is a bit more than that.
   MR RAMPTON:  A little bit more than that.
   A.   Would you repeat it?
   Q.   I suggested that your figures are fantastic, that they
        have no sound basis in real evidence, and I suggested the
        reason why, to which you say no, and I suggested that the
        reason why you have done it is that you want to make a
        false equivalent between the numbers of people who died in
        Dresden and the numbers of people who were killed by the
        SS in Auschwitz?
   A.   I repudiate that suggestion.  I can only state in general

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        that I did not just write a book about the air raid on
        Dresden; I also spent three years of my life researching
        all the major air raid attacks, not only on German cities
        but on other cities, that I was able to compare the air
        raids on German cities like Hamburg, Castle, Fausheuim and
        Damschadt, if you look at the death rolls -- am I going
        too fast?
   Q.   No.  I was distracted.  I do not mean to be discourteous.
   A.   I had the impression you were not listen.  I was able to
        compare the death rolls in those cities with the death
        roll in Dresden and come to an independent conclusion,
        independent of what people might write to me in private
        letters, that on the balance of probabilities, given the
        scale of catastrophe that was inflicted on Dresden, the
        number of homes destroyed, the numbers of people rendered
        homeless, the numbers of people in the city, the fact that
        the city had no air raid precautions whatsoever, that it
        had no air raid sirens, it had no defences, it had no
        guns, it had no shelters, on the balance of probability
        more people probably died in Dresden than are known to
        have died in Hamburg in a much smaller air raid when far
        fewer bombs are dropped, far fewer homes are destroyed and
        far fewer people rendered homeless.  That, therefore,
        although I respect Reichter's work on the basis of the
        documentation of the numbers of bodies dragged up to the
        cemeteries, I concluded that probably more people died in

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        Dresden because there were not enough bodies to find.
   MR RAMPTON:  My Lord, that concludes my cross-examination on
        Dresden.
   MR JUSTICE GRAY:  Yes.
   A.   I have still repeated the figures of 60,000 to 100,000 in
        my latest edition of the Dresden book.  On my web site
        edition I have drawn attention to the fact that the
        figures are probably controversial which I think is the
        correct way to go about it.
   MR RAMPTON:  My Lord, that being so ----
   MR JUSTICE GRAY:  Mr Irving, do sit down.
   MR RAMPTON:  I have no further questions to ask Mr Irving this
        afternoon.  The remaining topics are, there is a gentleman
        called Almeyer who was for a short time an officer at
        Auschwitz.  I am not interested in, shall I say, the
        substance of Herr Almeyer's evidence, but I shall want to
        ask Mr Irving some questions about that.  It is only about
        two questions.  Then there is Moscow.
   MR JUSTICE GRAY:  Then there is who?
   MR RAMPTON:  Moscow.  My proposal for that, actually it is not
        mine again, it is Miss Rogers' clever plan and it is not a
        trick, she has produced a sort of schedule of events which
        I can spend a day wading through in court by reference to
        documents, but which does seem to us to be really rather a
        waste of time, since, as I think your Lordship has already
        observed, much of this may turn out to be common ground.

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        What we propose to do, particularly since it is only 20 to
        4, is to give your Lordship and Mr Irving a copy of this,
        it is a similar sort of document to the one we have been
        using this afternoon in relation to Dresden, and ask
        Mr Irving to read it overnight and to mark on it those
        areas which are in dispute.  Then I can ----
   MR JUSTICE GRAY:  Yes.  Mr Irving, are you happy about that?
   MR IRVING:  My Lord, I am not entirely happy about it.  I was
        not happy about this tabulation that was put in because of
        its tendentious nature in parts.  They put in quotations
        extracts from quotations.
   MR JUSTICE GRAY:  That the sort of thing that is slightly
        concerning me.  That is not a criticism of Miss Rogers.
   MR IRVING:  Some of them are deeply prejudicial they are before
        your Lordship.  Your Lordship is a human being.  If one
        reads the entire letter you can see what the entire letter
        was about in connection ----
   MR JUSTICE GRAY:  I think what I will say, and I understand
        your concern, is read whatever it is that is being
        produced.
   MR RAMPTON:  I will not give it your Lordship.
   MR JUSTICE GRAY:  I do not suppose you mind me seeing it, do you?
   MR RAMPTON:  He did say he was a bit worried it might colour
        your Lordship's mind or something to that effect.
   MR IRVING:  It is already a selection of documents made from

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        their own bundles which are not agreed bundles.
   MR RAMPTON:  Mr Irving, it will not do you any harm to read it,
        if I may suggest.
   MR IRVING:  I am not easily harmed, Mr Rampton.
   MR RAMPTON:  No, that is perfectly plain.
   MR JUSTICE GRAY:  Read it and then we will see in the light of
        your reading of it what we are going to do with it, if anything.
   MR RAMPTON:  I am quite happy for your Lordship to have one,
        but if Mr Irving is worried about it ----
   MR IRVING:  I prefer if your Lordship waits until I have read
        the first ----
   MR JUSTICE GRAY:  You say that and I think that is not unreasonable.
   MR RAMPTON:  Then beyond that which I am going to do in the
        form of broad questions to which I expect to get negative
        answers, if necessary, I will put the questions, Mr
        Irving's political associations, and I will leave the
        detail to be dealt with by my experts so far as they are
        going to be witnesses.
                  Only perhaps at the end, or perhaps not, some of
        Mr Irving's utterances about, put bluntly, anti-Semitism
        and racism, for which there would be marked up files, by
        tomorrow morning, but I do not have them yet.
   MR JUSTICE GRAY:  I have not, sort of, gone through to think of
        any other topics that may need to be covered, but I am

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        sure you have.
   MR RAMPTON:  I am going to have a trawl through the undergrowth
        with Miss Rogers tonight to see if there is anything that
        we have missed, but we do not think there is. Else.  We
        think that is all that is left.
   MR JUSTICE GRAY:  Adjutants occurs to me.
   MR RAMPTON:  I keep forgetting them because I do not like them,
        I find them muddly, but the fact is there may be something
        in them that I do need to do.  I am hopeful that I will
        finish cross-examining Mr Irving by the end of tomorrow,
        if not sometime early on Thursday, but certainly this week.
   MR JUSTICE GRAY:  That is very helpful.
   MR RAMPTON:  Then, my Lord, I tell your Lordship this, next
        week on Monday, Professor Browning will be here, and this
        is always subject to evidence that Mr Irving wants to
        call, because we are, in effect, unless he has finished
        his case at the end of this week, interposing.  Then
        sometime when Professor Browning is finished, Professor
        Evans and following him, Dr Longerich.
   MR JUSTICE GRAY:  Right.
   MR RAMPTON:  So that should cover the next couple of weeks, the
        beginning of next week, which means we have done actually
        pretty well on the time schedule.
   MR JUSTICE GRAY:  Good.  I have said this before, Mr Irving,
        but if you want a pause between the experts, I would be

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        more than happy to agree to that.
   MR IRVING:  I may well ask for one day before we take on Evans.
   MR JUSTICE GRAY:  I think that is entirely reasonable.
   MR IRVING:  Yes.  Between the experts, I think we are ready for
        Browning.
   MR RAMPTON:  I do not know, but my suspicion is that Professor
        Browning will not in the witness box very long.
   MR JUSTICE GRAY:  As we have a few minutes, I have a bit of a
        mound of documents.
   MR IRVING:  My Lord, the cream sheet of paper just confirms
        what I said to you yesterday morning, just those points
        that I made, and I thought you might like to have that in writing.
   MR JUSTICE GRAY:  Thank you very much.
   MR IRVING:  The other items belong in the Dresden clip of
        Dresden documents they gave you.
   MR JUSTICE GRAY:  Right.  I think what I will do with these is
        put them, whatever it was, L1.
   MR IRVING:  Yes.  I was going to give your Lordship a bundle of
        photographs, but I find these repulsive photographs
        probably sit better in the Dresden file where they belong.
   MR RAMPTON:  Yes, I put that glossy brochure in the waste basket.
   MR IRVING:  I will retrieve it, if I may.  I know you do not
        think very much of what we did to Dresden, but I do.
   MR RAMPTON:  What do you mean?

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   MR IRVING:  You said, "So what?"
   MR JUSTICE GRAY:  No.  We have disposed of "so what",
        Mr Irving, once and for all.
   MR RAMPTON:  Enough "so whats", Mr Irving.
   MR JUSTICE GRAY:  I am putting it in tab 4 of L1 which I know
        is your bundle.
   MR JUSTICE GRAY:  10.30 tomorrow.
                  
(The witness stood down)

            (The court adjourned until the following day)


















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