Archive/File: people/i/irving.david/libel.suit/transcripts/day028.14
Last-Modified: 2000/07/25

   MR IRVING:  If the reference is to Auschwitz, which it probably
        is probably is although we cannot tell from this excerpt,
        then that has been my position all long.  The second
        sentence merely puts icing on the cake, if I can put it
        like that, does not add or subtract anything to it, to the
        sting.  The sting is the death factories did not exist.
        This is a reference to Auschwitz.  We are talking about
        Auschwitz, that is crematorium No. (ii), and I have not
        the slightest doubt that in my summing up, my closing
        speech, I shall establish that case beyond peradventure.
   MR JUSTICE GRAY:  Well, I do not know whether we have the
        transcript of the video?
   A.   Yes, we have parts of the video transcribed.
   MR IRVING:  Let me put this question to the witness; have you
        seen the video, or have you read the transcript?
   A.   I saw parts of the video also, but I am not sure if I saw
        all, and I do not know if I got the whole text.
   MR IRVING:  Am I right in saying that video called "I Shall
        Return", is an overview of the historical revisionist
        challenges?  For example, we have film footage of Dresden

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        in it, do you remember that?  And film footage of
        Dr Goebbels speaking, so it covers more than just the
        Holocaust, does it not?
   A.   Also the coverage of Dresden, I do not know if this is in
        this case, often as Mr Evans puts it, as references to the
        whole procedure of the Second World War and in the top, at
        the top of it to the Holocaust.
   Q.   Let me move to the question from his Lordship when we are
        dealing with Holocaust-related matters, am I only
        referring to Auschwitz or am I referring to other camps,
        like Treblinka, Sobibor, Belzec?
   A.   Of course you are referring to others also, of course.
   Q.   This is your opinion or can you remember clearly or is
        that just ----
   A.   No, no, you referred to others also, of course.
   Q.   I think we will have to ask to see the transcript or have
        the transcript put to me when the time comes.
   MR JUSTICE GRAY:  We have got it.  It is in the German.
   MR RAMPTON:  It is a full transcript.
   MR JUSTICE GRAY:  It is a free-standing sentence referring to
        death camps and death factories generally.  I simply do
        not at the moment understand why you are suggesting it is
        limited to Auschwitz.
   MR IRVING:  Because this video is 90 minutes long, my Lord, and
        not just five lines long.  The part from which this is
        taken (and I know it very clearly) is an exposition of all

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        the arguments on Auschwitz, the decodes, the crematoria,
        coke combustion logistics and all the other matters like
        that.  We are only dealing with that camp, and that is
        quite plain from the context.  That is probably why only
        this part has been quoted.
   A.   So if I have to answer very seriously, then I have to have
        this video or the text.
   MR IRVING:  I think it will be properly put to me in
        cross-examination by Mr Rampton if he is confident in the
        other direction.
   MR RAMPTON:  I am perfectly confident.  It is not the only such
        statement either by any manner of means, but may I tell
        your Lordship that the whole of that video tape, whose
        authorship Mr Irving is in no position to dispute, is
        being translated this afternoon, and that will be ready by
        tomorrow.
   MR JUSTICE GRAY:  Thank you.  Yes, Mr Irving?
   MR IRVING:  So on that video tape, just to ask the question
        again, you cannot be certain one way or the other whether
        I was talking only about Auschwitz or any other camps, you
        cannot remember?
   A.   Again I have to go at least to some ----
   MR JUSTICE GRAY:  Well...
   A.   It does not work.  I mean, I have to see the video in such
        or the text and I will not answer that.
   MR RAMPTON:  My Lord, there is no need for this.  I am going to

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        show some examples in re-examination, so the witness need
        not worry about it at the moment.
   MR IRVING:  That is far more satisfactory.  Page 141, we are
        looking now at Thies Christopherson, just drawing a line
        under him.  You have agreed, have you not, that my
        relationship with Thies Christopherson has been tenuous.
        There have been, I think you said, one or two meetings
        that he organized at which I spoke, Professor Funke?
   A.   Excuse me, I have to... I reorganized the things, so just
        a second.  Yes?
   Q.   Yes, you agree that Professor Christopherson organized one
        or perhaps two meetings at which I spoke, and that there
        is no other real meaningful contact between us?
   A.   I would not say so with respect to these meetings, it is
        the case, but, you know, Christopherson was one of this
        little group of people who are actively enacting this kind
        of, as you call it, revisionist movement.  So he was at a
        given moment of time very important together with Philipp
        and some others.
   Q.   But my specific question was his actual meaningful
        contacts with me have been limited purely to the two
        meetings that he organized at long range, and I turned up
        and spoke and left, is that right?
   A.   There are a lot of references in your diaries and
        interactions that is shown in the bundle.
   Q.   The references are him inviting me to address meetings

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        which I then did not accept?
   A.   Right, this is included, of course.
   Q.   Is there anything else you wish to say about
        Mr Christopherson?
   A.   I have to look at the bundle that was given, just a
        second.  Christopherson, yes, as I said before, more
        Christopherson letters to the Plaintiff than the other way.
   Q.   Yes.  Can I without interrupting you now take you to 143,
        please, Dietler Felderer?  We have not dealt with him.  He
        was the one who Mr Rampton rightly said you could not tell
        whether he was a man or woman.  Am I right in saying there
        has been no contact between Mr Felderer and myself
        whatsoever?
   A.   You were both on this Leuchter Congress and, aside of
        that, I do not know.
   Q.   I shall rephrase it.  Has there been any meaningful
        contact between myself and Mr Felderer whatsoever?
   A.   So far I think not, so far I know, I know the sources.
   Q.   When I asked you yesterday about Mr Gottfried Kussel who
        is on page 144 and next on our list, I asked if you knew
        of any contacts between Mr Gottfried Kussel and your reply
        was, "I do not know"?
   A.   No.
   Q.   There is no mention in the diaries, right?
   A.   Then I have to be more precise.

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   Q.   That is what you said yesterday.
   A.   Say it again?
   Q.   That is what you said yesterday.  Your answer was, "I do
        not know".
   A.   To what question?
   Q.   Had you any information or any evidence that there had
        been any contacts between me whatsoever between myself and
        Mr Gottfried Kussel?
   A.   Then I have to, then I was a bit tired.  To be more
        precise, the kind of context that you have in meetings,
        and I again stated it, I think, today in the morning or
        yesterday that it is of importance that you joined the
        demonstration in Halle, for example, where he was leading
        the demonstration.
   Q.   What you are saying is that because he was in Halle on the
        same day that I was and that he was within one
        geographical mile of where I was, this is a meaningful
        contact between me and this rather unpleasant person?
   A.   No, I have to restate it.
   Q.   You have no evidence for any other kind of contact?
   A.   I have to restate that this whole organization done and
        prepared by Christian Worch was part of the activities of
        the so-called Gesinnungsgemeinschaft that includes at the
        top of this Gesinnungsgemeinschaft of this organization of
        neo-Nazis, Kussel, Worch and one and two or two others.
   Q.   So this is rather like saying that because somebody else

.          P-133



        is member of the AA and you are a member of the AA,
        therefore, you are connected to that man?
   A.   What is AA?
   Q.   Is that what you are saying?
   A.   If you describe your revisionist movement as an automobile
        club, I would say yes.
   Q.   Well, it is the same kind of argument, is it not?
   A.   No, it is not.  You are invited ----
   Q.   Is that good as it gets?
   A.   No, this is not.  It is a total distortion of what all the
        people in the court, of the court, could have seen
        yesterday, and what we described at length.
   Q.   But ----
   A.   That you were invited by one of the leading members of the
        Kuhnen connection, that is by Uschi Worch, to make a
        rabble rousing, as you quote yourself, rabble rousing
        speech to them, in a special moment of reshuffling and
        widening the influence of this very group.
   Q.   That does not answer the question, does it, as to whether
        you have any evidence of contact meaningfully between
        myself and Mr Kussel himself in person which is what this
        is about?
   A.   Again, I cannot say, I cannot answer this in the way you
        question because you cannot separate -- maybe others can,
        I cannot -- you cannot separate a person from a special
        movement and you are referring to another movement with

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        that is very similar.  So a movement is a movement in
        which given persons has a special importance and
        especially in the parallel organization leading persons
        have special importance, and within this parallel
        organization it was Worch and Kussel and one or two
        others, and Worch, both Worchs, organized the meeting
        together with the DNP or NPD leader of this region,
        Dienel, and they asked you to talk at the first, as the
        first and most important of this whole rally.  This is
        something different as compared to whatever, AA.
   Q.   This is getting very tedious.  You say they asked me.
        What evidence do you have for that statement, they asked
        me to speak at this meeting in Halle?
   A.   Again one of the central persons asked you.
   Q.   One of the people?
   A.   Of course, yes.
   Q.   Can I now take you to page 146, please?  This is
        Mr Jurigen Riga -- this is going to be very brief, I hope
         -- you answer in one line, is there any evidence
        whatsoever of the slightest contact between myself and
        Mr Jurigen Riga, meaningful contact?
   A.   I do not know.
   MR JUSTICE GRAY:  It is not on the list actually, so you need
        not really trouble.
   MR IRVING:  I beg your pardon?
   MR JUSTICE GRAY:  He is not on the list, I do not think.

.          P-135



   MR IRVING:  Is he not on our list?
   MR JUSTICE GRAY:  No.
   MR RAMPTON:  No.  Do ask about him, I do not mind.
   MR IRVING:  Mr Rampton did ask about him yesterday.
   MR RAMPTON:  No.  As a matter of fact, I do not think I did. I
        think I was told, without having asked a question, that he
        was the lawyer, he was the wicked neo-Nazi lawyer or
        something, but I am not sure my memory is right.
   A.   He is one of the right-wing extremist lawyers, yes, you
        are right.
   MR JUSTICE GRAY:  Anyway he is not on the list.
   MR IRVING:  Not on the list.  Very well.  Page 147, Wilhelm
        Staglich, but the question I am going to ask is going to
        be for a totally different reason that his Lordship will
        now appreciate.  Your first line says:  "Previous to 1945,
        the end of World War II, Staglich was part of a flak
        battery stationed for several months in Auschwitz".  Will
        you explain what a flak battery is?  Is it an
        anti-aircraft gun battery?  Is it as part of the air
        defence system of a site?
   A.   Yes.
   Q.   Was Auschwitz exposed to air raids?
   A.   Yes.
   Q.   Does this mean to say that at some time previous to 1945
        air defence precautions had been taken at Auschwitz?
   A.   Yes.

.          P-136



   Q.   Are the building of air raid shelters part of air raid
        precautions?
   A.   I do not know but, yes, yes.
   Q.   Thank you very much.  Michael Schwierzak, that is the next
        name on the list on the same page, how would you describe
        my contacts so far as they are known to you apart from
        anti-fascist literature with Mr Michael Schwierzak?
   A.   He, I think, by the intermediation of Mr Worch invited you
        to speak before his little tiny group, National Offensive,
        down in the southern Germany.  This group is part of the
        Kuhnen connection.
   Q.   In other words, the invitation came from Althans and not
        from Schwierzak?  Is that what you are saying by this
        complicated phrase, by the intervention of Mr Althans?
        What did you mean by that?
   A.   I thought it was Worch, but correct me.
   MR JUSTICE GRAY:  Well ----
   MR IRVING:  Well, I do not think it is very important.
   MR JUSTICE GRAY:  --- Mr Irving, I think it would be much more
        helpful if you put what you say were your contacts, if
        any, with Mr Schwierzak.
   MR IRVING:  Well, I thought it would just be helpful if I got a
        straight no from him that this is no evidence of any
        contact between me and Mr Schwierzak.
   MR JUSTICE GRAY:  Well, there is.  There is plenty.  That is
        why I am suggesting that you put your case as to whether

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