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Shofar FTP Archive File: people/i/irving.david/libel.suit/transcripts/day004.04


Archive/File: people/i/irving.david/libel.suit/transcripts/day004.04
Last-Modified: 2000/08/01

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   Q.   And does each plate represent one day?
   A.   No.
   Q.   No?
   A.   They just filmed continuously and when one plate ran out,
        they would then put another glass plate in and film the
        next one.  That is why one plate, if you will note on that
        list, is called December 13th and the next plate is called
        December 13th to 14th.
   Q.   Can I ask you -- I will ask you one more question and then
        I will ask you to look at something -- do you know from
        memory -- you do not seem to have a record of it -- how
        many pages the entry for 13th December 1941 was?
   A.   No.
   Q.   All right.  Well, perhaps I can help you.  I do not know.
        It is a possibility.  Could Mr Irving please be given
        bundle H4(ii)?
   MR JUSTICE GRAY:  I am afraid I have not got this, Mr Rampton
        I am sorry.  Thank you.
   MR RAMPTON:  Could you turn to a handwritten FN 156?
   A.   156?
   Q.   It is about two-thirds of the way through the file.  It is
        what I call a sideways document.  You have to turn the
        file around in order to read it.
   A.   I have it, yes.
   Q.   It is a German document.  It is headed on the right-hand 
    column on page 487, internal page 487, 13th December in

.          P-28



        German 1941, yes?
   A.   Yes.
   Q.   Just glance at this.  It runs through -- I think it is the
        whole entry -- to page 501.  These are double pages.  So
        it does not involve turning over a lot of pages.  501 is
        where 14th December starts.  Now, do you recognize this
        printed version?
   A.   I do.  If you look on page FN 156, you find the passage
        that is on my transcript.
   Q.   Sorry?  They are all 156.
   A.   I am sorry.  It is on printed page, on book page 494.  At
        line 283, 282, you see the sentence beginning
         "Nachmittags", "In the afternoon the Fuhrer speaks to the
        Gauleiters".
   Q.   I see that.
   A.   That is the passage which I got.
   Q.   You have got that passage.  But you also got more than
        that, did you not?  Where is your U boat war, your boat
        war?
   A.   In that same paragraph.  It continues in that same
        paragraph on printed page 494, book page 494.  It
        continues about the U boat.
   MR JUSTICE GRAY:  And on the opposite page?
   A.   And on the opposite page.
   MR RAMPTON:  Yes, I see that, what is puzzling me about this,
        Mr Irving, is this.  I think you translated some of this

.          P-29



        or all of it for the Sunday Times, did you not?
   A.   Yes.
   Q.   Can you turn to page 496?
   A.   Yes.
   Q.  "Dab wir im Osten", that is the last of your typewritten
        German passages, is it not?
   A.   If you say so, yes.
   Q.   Well, it looks the same, does it not?
   A.   Page handwritten 21 of my note?
   Q.   Yes.
   A.   That is correct.
   Q.   That is the same one.  I think that was the last of the
        passages on this day that you translated for the Sunday
        Times, was it not?
   A.   It was all that I had at the time.
   Q.   Yes.  It is all that you brought back with you?
   A.   That is correct, yes.
   Q.   I understood your evidence about that.  Can you turn over?
   A.   498 you probably want, 498.
   Q.   498 has disappeared.
   MR JUSTICE GRAY:  So it was not 30 or 40 pages further on, it
        was two pages further on.
   MR RAMPTON:  No, well, that is----
   A.   My Lord, when you see these pages, it is printed in the
        large, I forget the actual technical name for it, but we
        call it the Fuhrer typewriter, and it is printed with four

.          P-30

        spaces between each line.  He has about 100 words on each
        page, my Lord, so it is very many further pages further
        on.
   Q.   Sorry, that is what I was trying to find out.  In my
        version it is very few pages further on.
   A.   In your photocopy of the original facsimile?
   Q.   No, in this printed version it is only ----
   A.   It is only a few pages further on, yes.
   Q.   Three?
   MR JUSTICE GRAY:  But the point is that, apparently, in the
        original diaries it is all very much spread out?
   A.   For your Lordship's amusement, I will bring one page
of it
        to you tomorrow and you can see what it looks like.
   Q.   If anything turns on it, I do not know.
   A.   I think Mr Rampton apprehends that this is a major
point;
        it has been flashed around the world that I was wrong
        again.
   Q.   Well, I think you have made the point on Thursday that
you
        did not actually know it was 30 or 40 pages further on
        because you did not ever read it so you could not
tell?
   A.   Now we know, my Lord.
   MR RAMPTON:  This is one thing I am concerned about,
        Mr Irving.  You said, and I will read you your words -
-
        have you had your transcript ----
   A.   Yes, I have.
   Q.   --- for Thursday?  His Lordship is right.  It was

.          P-31



        something along the lines of 30 or 40 pages further on
        which is just not right, is it?
   A.   What is not right, the exact phrase?
   Q.   I will find the exact words.
   MR JUSTICE GRAY:  It is page 153.
   MR RAMPTON:  That is right.  You said:  "Had I read on
another
        30 or 40 pages in the diary for that day, I would
probably
        have come across the full length description of the
report
        Gauleiters' speech on which Longerich is relying?
   A.   Absolutely right.  This is probably 30 pages further
on,
        but it shows my guess was absolutely right ----
   Q.   30?
   A.   --- without even having seen it.
   Q.   Tell me, if you will, if you look at -- this is edited
by
        Elke Frohlich, is it not?
   A.   Yes.
   Q.   But it is not any sense edited by having things
omitted?
   A.   I do not believe so, no.
   Q.   It is a continuous text?
   MR JUSTICE GRAY:  Mr Rampton, is there much mileage in this
        because I think the next day, I mean the next page,
        I asked, "How do you know it is 30 or 40 pages further
        on?" and he makes clear that he did not know it was,
but
        he had a glass plate with 45 pages on it and it was on
        that, so it must have been on the next one?
   A.   It would have been 25 pages on that one, my Lord --
no, 48

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        single pages.
   MR RAMPTON:  Is this glass plate that you transcribed, or
some
        of it, the only one for that date that you looked at?
   A.   Well, this is the reason why I provided you over the
        weekend with a list of the actual pages that we looked
at,
        the actual glass plates.
   Q.   Yes, but do you understand there is a difference -- I
know
        you do -- between what you transcribed and what you
looked
        at?
   A.   We looked at all the glass plates.
   Q.   You did?
   A.   Quite simply to establish an inventory.  I looked
through
        every single glass plate in the 1500 glass plates with
        this magnifier, established from the title line across
the
        top what period was covered, put a yellow post-it on
the
        glass side, not the emulsion side, of each plate
        indicating what date it was.
   Q.   So you will have read the passage that Longerich
relied
        on?
   A.   You did not hear what I said.  On the top of every
page,
        on the top of every plate there was a title line
written
        in handwriting saying the dates, the actual dates
covered
        by that plate, like 13th to 14th December 1941.  You
did
        not have to look actually at the individual pages.
        I could see straightaway and say this is 13th to 14th
        December 1941, it is already out of our period of
interest

.          P-33



        because we were looking at Pearl Harbour.
   Q.   How did you make your selection if you did not read
the
        whole thing?
   A.   Time made the selection for us.  We knew we were only
        there for a limited length of days.  We had a flight
to
        come back to England.  You had to make judgment
decisions
        and say, well, Pearl Harbour was December 7th 1941, we
are
        already on December 13th, my commission from the
Sunday
        Times was to get material relating to Pearl Harbour.
I
        had already read as much as I considered was
necessary.
        Had I known that later on in the same entry he would
have
        gone on about the Fuhrer talking to the Gauleiters at
        greater length, I might have gone on, but you cannot
        tell...
   Q.   You have answered my question, I think, which is that
you
        did not read it at the time?
   A.   That is correct, and it was not before me at the time.
        Even now, to buy these diaries, you have to lay out
more
        than 1,000.  So it is quite an expensive task.  I
have
        now purchased them, but they have only just been
        published.
   Q.   While you have that out, can I ask you a little word
about
        something you said on Thursday?  I think you told us,
if
        you look at the passage quoted in Longerich, yes?
   A.   The passage quoted in?
   Q.   Well, the passage quoted by Longerich is at the bottom
of

.          P-34



        page 498 of the Frohlich edition?
   A.   Yes, "In connection with the Jewish question, the
Fuhrer
        has decided to make tabula rasa".
   Q.   Yes, and then it goes on, "He prophesized to the Jews
that
        if they began yet another World War, they would
thereby
        bring about their own destruction", roughly speaking?
   A.   It is a crude translation, yes.
   Q.   He is reporting there, is he not, either something
Hitler
        said to the Gauleiters on 12th December, or he is
        reminding himself of what Hitler said on 30th January?
   A.   January.
   Q.   1939 in the ----
   A.   You cannot tell from this particular quotation.
   Q.   You cannot, can you?
   A.   It is the old gramaphone record that Hitler played
again
        and again.
   Q.   Yes, indeed.  Then you say, well, you know from that
point
        on, I think, "Das ist keine Phrase gewesen", that
these
        are no longer Hitler's words because it is in direct
        speech?
   A.   It is in direct speech, yes.
   Q.   So is the first sentence, is it not?  "Bezuglich der
        Judenfrage ist der Fuhrer entschlossen"?
   A.   Yes, that is correct.
   Q.   That is also in direct speech?
   A.   He uses direct speech.

.          P-35



   Q.   He is reporting that, so far as the Jewish question is
        concerned, the Fuhrer is determined to make a clean
sweep?
   A.   Yes.
   Q.   Yes.  That is direct speech, is it not?
   A.   Yes.
   Q.   If you look over to the other side of the page, the
first
        complete paragraph, the first sentence of the first
        complete paragraph, "Im Osten sieht der Fuhrer
uberhaupt
        unser kommendes Indien" is in reported speech, is it
not?
   A.   No.
   Q.   No?
   A.   It would be in "osten siehe der Fuhrer", S-I-E-H-E,
would
        be reported speech, that would be the subjunctive.
   Q.   That is fine.  The next sentence is also in direct
speech,
        is it not?
   A.   That is direct speech.
   Q.   And so is the next sentence, is it not?
   A.   That is correct, yes.
   Q.   And the next one, well, this is in the past in the
sense
        that he is reporting that the Germans have overrun and
        settled in the past?
   A.   The whole paragraph is in direct speech.
   Q.   It is, is it not?
   A.   Yes.
   Q.   And do you say that those are Goebbels' private
thoughts
        and not a report of what Hitler said?

.          P-36



   A.   He is reporting in his own words what Hitler's
opinions
        and intentions are.
   Q.   Precisely.  So would you care to withdraw your
criticism
        of Dr Longerich for putting what is in direct speech
into
        Hitler's mouth?
   A.   Are you not referring to the same passage, Mr Rampton?
   Q.   No, but it is all part of the same two paragraphs.
   A.   No, the specific allegation that you made was that
        Longerich was quoting Hitler when, in fact, he was
quoting
        Goebbels which is my comment.
   Q.   How can you tell that the first paragraph on the
        right-hand side is not also just Goebbels quoting
        Goebbels?
   A.   We can refer back to the specific sentence that was the
        subject of your complaint, because we have now moved on to
        a different paragraph and you are trying to ----

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