Archive/File: people/i/irving.david/libel.suit/transcripts/day029.16 Last-Modified: 2000/07/25 Q. --- his Lordship asked you and I repeat: "Is it your case that there is not any record, whether tapes, notes or anything, of Gita Sereny's interview with Christa Schroeder and she is, in fact, making the whole thing up?" Answer by Mr Irving: "Yes". A false and a knowingly false answer, is it not, Mr Irving? A. To this I have to say two things. The first thing, not in any order of priority, is that, as is evident from the correspondence which I just read out, there was no . P-140 interview. She did not get to see Mrs Schroeder. Q. What, you mean you cannot interview somebody by telephone? A. Not in my book. Secondly, I have to confess that even after receiving that letter from the opposing solicitors in the other action, I did not look into the correspondence and discovery files for reasons which are probably evident for you. To do so would have taken me probably 20 or 30 minutes to find the file and look up the letter, and at present I am under very great time pressure. MR JUSTICE GRAY: I am sorry, I am not following that at all. On 10th February 2000, you were sent a letter which specifically directed you to the document. It would not have taken you a second to find it. A. My Lord, my files are not in any very great shape at present. They are in great shape for this action, but they are not in great shape for an action which has not yet been set down even. And to have looked and found the Sereny discovery and to have found this particular document -- all I can say is that I am stating here, I am asserting here, that I did not look up this document and, even having looked it up, it has not altered my position because I knew perfectly well ---- Q. But I am sorry, Mr Irving, on 4th January 2000 you specifically requested documents relating to what Frau Schroeder had said. . P-141 A. Very well. In preparation of this case, I have gone through our entire discovery for the action against Penguin Books which is the current case, which is what this number is on the top right-hand corner of the Sunday Times letter, 545. When I took this letter out, my eye lit on the fact on paragraph 2 that there were quite clearly interesting items that Sereny had not disclosed to me, as she should have. I wrote a routine letter to the solicitors for the opponents in that action, saying, "Oh, by the way, I note you have not given discovery of those documents, please now do so", which is a perfectly reasonable act. They then wrote back that letter. But I already knew from Christa Schroeder that she never interviewed Miss Sereny for personal reasons. MR RAMPTON: But she did not make it up, did she, Mr Irving? A. She did not make what up? The statement? Q. The assertion that Hitler probably knew what was going on because he had these four hours, frequently had these four hours conversations closeted with his friend, Heinrich Himmler? A. Now, that is not the question you asked me, is it, or the question which his Lordship asked me? Q. Yes. MR JUSTICE GRAY: Have a look at it again if you want to. MR RAMPTON: "Did she make it up?" Answer; "Yes". A. "Is it your case that there is not any record of Gita . P-142 Sereny's interview with Christa Schroder?" That was the first question to which the answer was quite correctly, "Yes", "And that she is, in fact, making the whole thing up?" in other words, the interview, answer: "Yes". And I take issue with the way you put her response. She did not say she considered it probable that Hitler knew. She said she considered it improbable that Hitler did not know or that he knew nothing, rather, was the exact language. That is not quite the same as you have said. I do not want to split hairs, but let us stick to the actual language. Q. Would you like to withdraw the allegation of little invention you made against Miss Sereny in this court not very long ago? A. No, I would not. Miss Sereny has stated that she conducted interviews with a number of Hitler's staff, who disavowed what I had reported of my very lengthy interviews with the same people. It is a matter of professional pride that I establish that what I wrote was true on the basis of proper interviews, not conducted over a snatched telephone conversation. Proper interviews. You have of course seen the very complete and proper records I took of those interviews, and I was perfectly satisfied from my knowledge of these people and what they told me that they had not granted her interview. Certainly Krista Schroeder had not and, when it was . P-143 suggested in this court that she had, I knew perfectly well that she had not, and it now turns out I was right. Q. The last item on my agenda for today, Mr Irving, is the Goebbels diaries, the entry for 13th December 1941, what Adolf Hitler said to the Gauleiters and others on 12th December 1941. A. And my knowledge of what was in them, presumably. Q. Absolutely. Precisely that. My Lord, this is on page 337 and 338 of Professor Evans' report. I invite reference to that because the English is there. MR JUSTICE GRAY: I am sorry to be tedious about this but where should I put the little clip that has just been handed in? MS ROGERS: J2, which is now in an overspill marked J2 to 3. MR JUSTICE GRAY: Rather than being an overspill marked J2 to 3, it is actually going to be J3. MS ROGERS: I am very happy with that, and I think we are up to 17 or 18. MR JUSTICE GRAY: I have run out of tabs. MR RAMPTON: May Mr Irving and his Lordship have the Goebbels clip and Mr Irving should also have a copy of Professor Evans' report. A. In that case I had better clear a large space on my desk. MR RAMPTON: Please turn to page 337. On page 337 in paragraph 8 Professor Evans writes this: "On 12th December 1941, less than one month after the publication of the article in Das Reich, Hitler spoke about the Jews in front of the . P-144 Gauleiters (noted down by Goebbels): 'With reference to the Jewish question", Bezuglich der Judenfrage, "the Fuhrer is determined to clear the decks". The actual German is reinen Tisch zu machen, which might be better translated as make a clean sweep. "He prophesied to the Jews that if they should once more bring about a world war, they would experience their own annihilation in doing so. That was no mere talk. The world war is there, the annihilation of Jewry must be the necessary consequence. The question is to be considered without any sentimentality. We are not there to have sympathy with the Jews, only sympathy with our German people". In paragraph 9 on page 338, writes Professor Evans: "Here Hitler mirrored directly Goebbels's statements from the article in Das Reich", which I think was published in November of that year, 16th I think? A. November 16, yes. Q. "While Irving does cite this speech of 12th December 1941 by Hitler in Goebbels, he is careful to omit any mention at all of this key passage because it shows that Hitler was as determined to act brutally against the Jews as Goebbels was". Your account of the omission of that may be thought crucially important passage from the Goebbels diaries from your book on Goebbels, or indeed from anything else that you have written so far as I know, is . P-145 I think, if I may summarize this and you will correct me if am wrong, that you went to Moscow to look at the Goebbels diaries with a specific commission from the Sunday Times. A. A shopping list, yes. Q. Which consisted of, or which included, the instruction, direction or request to look for material on Pearl Harbour? Is that right? A. Yes. Q. Have I got it right so far? A. Yes. Q. When you got there, you found the glass plates on which the diaries were recorded so voluminous or so crowded that you stopped four lines into the second of the glass plates for this date. Do you remember that? Would you like to turn to tab 2, which I think are some Irving documents, are they not? A. I am sorry? Q. The little clip, the file you have been given. A. Yes, tab 2. The notes taken by my assistant on our progress as we waded through the glass plates. Q. Yes. The first page in that is headed "box 1", is it not? A. Yes. Q. Whether that means the big filing box or the little box of glass plates, I cannot say. Q. I have absolutely no idea. I am afraid I was not there. . P-146 A. It is a big filing box. I can see that because on box two she puts in the Russian designation. Q. Could you turn to page 9 please? It is the original 09 at the bottom. A. Yes. Q. Under No. 38 at the top of the page we see the list of plates that you read, or part read, for December 1941, do we not? A. The plates that we found, yes. Q. Whatever. Lesen is German for read, is it not? A. Read or read, oddly enough. Q. Read. It must be read. 10th December, read, 11th to 12th December, read, Pearl Harbour. A. Read with gelesen. Q. All right. 13th December, lesen, whatever it means. A. Yes. Q. 13/14 December, 41, bis vier zeile gelesen? A. Read to the fourth line yes. Q. Yes, to the fourth line. Now please turn over some pages. There is a lot in here that I do not need. A. I am astonished that she was so meticulous in what she wrote down. Q. I am about to suggest to you that she actually might have made a significant mistake. A. Ah. Q. At tab 5 of this little file you will see a document in . P-147 Russian dated 23rd February of this year. If you want to turn over, we have attempted the translation. A. I was just about to get my O-level Russian to work. Q. Forget your O-level Russian unless you are going to grumble about the translation. It comes from the Federal Archives Services of Russia and Moscow and it is written to my solicitors Mishcon de Reya in London. It says, "Dear Sirs, further to your letter we are sending to you photocopies Goebbels diary pages for 13th December 1941. The photocopies are taken from two separate glass plates". So far you are not falling out with the Russians, I think, are you, Mr Irving? A. I am happy to accept this, yes. Q. The second plate starts from page 18. A. I see what they mean. Q. We turn over the page to tab 6 of this little file and we find what it is that the Russians have sent us. A. Yes. Q. If you turn through the pages, the numbers are at the top. You find that the first plate ends. Well, let us look at the first page. The first page has on it 13th December 1941. A. Yes. Q. That does not mean that that plate starts on the 13th December 1941, does it? A. No, it does not. . P-148 Q. Right. So, when the Russians say that plate 1 ends at page 17 of this 13th December entry, which you can see, they are probably right, are they not? A. Yes. Q. Now I will direct you to where on plate 2, rather far past line 4 I fear, your clip that you gave us as representing what you transcribed begins. Page 26, please. If you want to compare it with what you gave us as being your -- we had better do it in an orderly way. Your transcription is at tab 4, and it begins "Mittags habe ich eine Unterredung mit dem Fuhrer". A. Yes. Q. So we can see that that passage starts -- it is the first part of your transcription for the 13th and it starts on page 26, I think, of plate 2, I ask you to note, of the series for this date. I can tell you, because I have marked it all the way through, you run out in the sections you say you transcribed on page 38. Is that right? Yes, it is, I think. You end with the passage "Das wir im Osten nicht weitergekommen sind, als wir jetzt stehen", and we find that on page 38 of plate 2, do we not? A. That is when I run out. Q. You end "nach Schutzproblem aber". A. Yes. MR JUSTICE GRAY: Tab 4 is what? Transcribed microfiche material done by Mr Irving in Moscow? . P-149 MR RAMPTON: Yes. So point 1, Mr Irving, the story that all but four lines of your transcription came from plate 1 is just rubbish, is it not? A. I have just done a little bit of a calculation.
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