Archive/File: people/i/irving.david/libel.suit/transcripts/day023.19 Last-Modified: 2000/07/24 Q. Page 484, you write two-thirds of the way down: "Irving is, of course, aware of this exchange which suppresses it altogether". What proof do you have in writing that I am aware of this exchange? A. Because you used the Goebbels Nuremberg diary as a source. Q. No, I did not. A. Right, then "Nuremberg, the last battle" ---- Q. I have used one extract from the Gilbert book. . 180 A. Yes. That is note 27 on page 143 of "Nuremberg, the last battle". Q. Which is one extract from the Gilbert book which is the Julius Schreiber papers. Does that mean to say that I have read the entire book? A. One would presume so, yes. Q. Are you aware that I had in fact Gilbert's original papers when I wrote the Nuremberg book? A. Yes. Q. Yes. So, in other words, you assume something there which turns out not necessarily to be true? A. Well, since you cite the book in your work, I assume you have read it. Q. Yes, two lines from the bottom of that page you say, "Ribbentrop writing under duress in allied captivity" ---- A. No, you say that. Q. --- do you accept that he was writing under duress? A. Sorry, you say that. You say: "Special circumstances ... (reading to the words) ... Ribbentrop writing under duress in allied captivity" ---- Q. But if you turn the page ---- A. --- "and facing an inevitable death sentence has to be borne in mind". Well, he was in captivity, of course, and he was facing a death sentence. Q. Are you familiar with the physical conditions that the . 181 prisoners lived in at Nuremberg? A. Yes. Q. No table, no medication, no hygiene, no light, no spectacles and all the rest of it? A. Well, I am not sure I accept all of that. Q. Page 486: Hitler's last will and testament, or his political testament. This is the one he dictated on the last day of his life, is that right? A. 486 -- 5 to 6. Q. 5 to 6? A. We may have slightly different pagination here. Q. I am looking just at the first two lines. My Lord, do you have that? A. The last five lines of page 485 and first two of --- - MR JUSTICE GRAY: Last five lines on page 485? A. Yes, the indented quotation, my Lord. MR IRVING: I said page 486, the last... A. Well, the first two of page 486. Q. What do you think Hitler meant by the Jews "having to atone for his guilt", "the Jew having to atone for his guilt even if by more humane means than being burned alive in air raids", and so on. What do you think he meant by ---- A. Well, let us read the quotation. "I also made it quite plain that if the nations of Europe are going to be regarded as mere shares to be bought and sold by those . 182 international conspirators in money and finance, then Jewry, the race which is" -- sorry, "then, Jewry, the race which is the real criminal in this murderous struggle will be saddled with the responsibility. I further", says Hitler, "left no one in doubt that this time millions of Europe's Aryan peoples would not die of hunger, millions of grown men would not suffer death, nor would hundreds and thousands of women and children be allowed to be burned and bombed to death in the towns without the real criminal having to atone for his guilt", that is the Jew, of course, "even if by more humane means". I assume there he is saying it is not, I mean, it is not bombing and burning to death in the towns or dying of hunger. It is shooting and gassing. Q. So you think that he is referring there to the Holocaust, the Auschwitz, the gas chambers, the cyanide, the choking to death, all the horrible things that have been described? A. Now, I am not saying I agree that it was humane; I am just saying he thought it was humane, or appears to say so here. Q. Could it not equally ---- A. He was always, after all, and we have had several quotations today, congratulating himself on how humane he was towards the Jews. Q. Does it not make for greater sense than this rather . 183 plausible suggestion that the Holocaust was humane which is what you are proposing? A. I am not proposing it. It is Hitler who is proposing it. Q. Which is what you are proposing is the meaning on this word, to be assigned to this word, that what Hitler is saying that, "We have had hundreds thousands, if not millions, of people burned alive, women and children, in our cities and we have just deported the Jews, booted them out to Siberia", or wherever he thought they had gone, and that is what he is referring to when he talks about them having had to atone for their guilt by more humane means, because the only other alternative is that you are accepting that the Holocaust was more humane? A. No, that is not at all. That is another classic example of the way you twist everything to your own polemical purposes. I am not saying the Holocaust was more humane. I am not making a judgment at all. Q. Or being machine gunned into pits? A. I am simply quoting Hitler, and Hitler is saying that the Jews will have to atone for what he regards as their crime of having killed millions of Aryans through hunger, burning alive and so on, they will have to atone for it by more humane means which, I assume, he means, not explicit about it at all, he means gassing, possibly shooting. Q. Well, the reason for that is, of course, you say there is a connection between that and the memorandum submitted in . 184 July 1941 by Ralf Heinz Hupner who says, "Would it not be more humane to find some rapidly working means of disposing of the Jews rather than have them exposed to the privations of the winter?" A. Where do I say that? Q. This is on page 486 -- I am sorry, 489. A. 9? Q. Yes. A. Yes. Q. Are you suggesting that the Hupner message was ever shown to or read by Hitler? Was it not addressed to Adolf Eichmann? Are you suggesting there is a direct causal link between the Hupner message and the Hitler ---- A. No, I am not. Q. So just a bit of a smoke screen by you then? A. No, it is not a smoke screen. I am drawing attention to the parallel there as ---- Q. Or do you think ---- A. --- as evidence of a wider mind set. Q. Or do you think that the reference to humanity or humane is, in fact, an allusion to the blockade that we, Allies, imposed on Germany in World War I and after World War I which resulted in the deaths of large numbers of Germans? A. I see no evidence of that in this statement by Hitler. Q. 490, in paragraph 11, you cast doubt on the secretly recorded conversation between Ribbentrop and a British . 185 officer? A. No. Q. Paragraph 11 on page 490? A. No. Where do I cast doubt on that? Q. 490? A. Right, I have it, paragraph 11. Q. "Irving claims he had a fund of collateral documentary evidence"? A. Yes. Q. And you then lament the fact that there is this secretly recorded transcript which does not seem to have been included in my list of documents, and so on? A. Yes. I am very cautious there -- conscious I might have overlooked it, but it does not seem to be there. Q. You are not familiar with the XP series of transcripts which are in my files -- you accept that it is possible it was in the documents? A. Well, that is why I have phrased it cautiously there. Q. Page 491, paragraph 14, does that paragraph, far from being contradictory, not actually confirm that Ribbentrop asked Hitler and Hitler denied all knowledge and that was the end of it? This is the Maidonek episode. A. Well, no, he is just saying he did not know anything about it until the Maidonek affair. That is all it says. Q. 493, paragraph 5.1.1. I just draw his Lordship's attention to the fact the witness appears to be pleading . 186 innuendos of words there which is not part of his remit. MR JUSTICE GRAY: No, I will not pay any attention to that. MR IRVING: Page 495, paragraph 5.1.5, if I can find it? MR JUSTICE GRAY: Well, that simply says that he is going to deal with the statistics and the numbers killed in the raids on Dresden. MR IRVING: Yes. You say that my number of deaths in Hamburg of what I put at 48 -- did I say 48,000, 50,000? A. 48, 50,000, yes. Q. And you consider this number to be totally exaggerated and perverse and another example of my manipulation and distortion? A. It is not a very strong argument, but you do go for the highest number available. Q. Is the reason ---- A. Which does not seem to have any basis and certainly is not ---- Q. Have you not ---- A. It certainly is not borne out by the local investigations. Q. Have you not repeatedly referred to the fact that I have gone for these 50,000 figure in Hamburg and the high figure in Dresden and Fortzheime and elsewhere as an example of the distortions and false statistics that I introduced? A. I think this is the only other mention of Hamburg, apart from the brief discussion of your use of the exaggerated . 187 figure in the caption to an illustration in one of your books. Q. Are you now back peddling on that because ---- A. It is not repeated. Q. Are you now back peddling on that because you have seen the page from the strategic air offensive against Germany, the official history which I have introduced in that little bundle? My Lord, it is page 9 of the little bundle, pages 8 and 9. Does footnote 1 say in regard to the Hamburg air raid: "In addition, there were 2,000 missing. The total number of deaths was probably nearer 50,000 than 40,000"? A. Sorry. MR JUSTICE GRAY: Sorry, page? MR IRVING: It is page 9 of the little bundle this morning, my Lord. A. It does not say which raid this was. Q. That is going to be your answer, is it? A. No, I mean, I take it that is 43, yes. Well, what I would say is that a responsible historian should in reaching an estimation of the number of people killed in bombing raid should look at all the available investigations there have been. Q. Would you consider ---- A. And this is from 1961 which is relatively early after the event and does not actually give any source, any German . 188 source, at all. Q. Would you consider ---- A. The German investigations in Hamburg of the bombing deaths came to a much lower figure. Q. Would you consider that Sir Charles Webster and Nobel Franklin, the official historians who had the complete captured German and British records at their disposal in writing this multi-volume work, are reasonable historians for another historian to use as a source? A. Well, let me -- two points -- yes, but this is 1961. I mean, there have been plenty of German investigations of the Hamburg bombing raids since then which a responsible historian would use. This is relatively early after the event and it does not cite any German material here at all. MR JUSTICE GRAY: We are talking about Hamburg here, are we? MR IRVING: Yes, we are talking about the 1943 raid on hamburg. Are you aware that volume 4 of this work contains the entire police president's report on the Hamburg air raid as an appendix? A. It is not cited here in arriving at the numbers killed. Q. Can you answer my question? A. Yes.
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