Archive/File: people/i/irving.david/libel.suit/transcripts/day007.18
Last-Modified: 2000/07/20

   Q.   Yes, Mr Irving.  We will continue, shall we?  I think
        I was at the words: "But Mr Zundel has used the scientific
        methods and, taking this as a starting point, I have now
        begun over the last few months going round the archives,
        with a completely open mind, looking for the evidence
        myself because, if Auschwitz, just to take that
        one cardinal tent pole of the case, itself was not an
        extermination factory, then what is the evidence that it
        was?"  I do not understand that sentence but I understand
        the sense of it.  "This is one thing I have to look at.
        How did all the evidence come into existence?  It is an
        interesting case because we all now accept that the media
.          P-153



        knows, everybody knows, it has become a matter of
common
        experience, judicial notice has been taken of the fact
        that Auschwitz was an  extermination camp.  So what is
the
        evidence that it was? If you then start going all your
way
        back down the pipeline to find out where this evidence
        comes from, you come up with one or two or three
documents
        and eyewitness accounts and that is all."
                  Now, that was your account of the state of
the
        evidence regarding the proposition that Auschwitz was
a
        totas fabrik in August 1988, some five months after
the
        end of the Zundel trial.
   A.   Yes.
   Q.   You had not even bothered going to look at the archive
in
        Auschwitz, had you?
   A.   I think I did not say here that I went to the
Auschwitz
        archives.
   Q.   You said you had been round the archives with a
completely
        open mind looking for the evidence.
   A.   Yes.
   Q.   You tell your audience that all you come up with is
one or
        two or three documents and eyewitnesses accounts and
that
        is all.
   A.   Let me explain to you the situation at the time as
        I understand it, archively speaking.  The Soviet
archives
        were not opened until 1990, I believe I am correct in
        saying.

.          P-154



   Q.   I am listening.  Please continue.
   A.   I do not like talking to the back of counsel.
   MR JUSTICE GRAY:  It happens all time in court.  It has to.
It
        is not rudeness or anything else.  It is just the way
of
        the world.
   A.   I promise I will not turn my back on people when they
are
        speaking to me.
   Q.   Just carry on with your answer, please.
   A.   Soviet archives had not been opened at that time.
Poland
        was still behind the iron curtain.  The wall had not
come
        done.  Am I making my point?
   MR RAMPTON:  No, not in the least bit.
   A.   Which of those sentences did you not understand?
   Q.   I understood the first sentence, which was completely
        irrelevant because we are in 1988. I am not interested
in
        Moscow. I asked you about the archive at Auschwitz so
        leave Moscow out of it.
   A.   Our present state of information about Auschwitz, the
        superior information we now have about Auschwitz,
comes
        primarily from the fact that the Russians, when they
        arrived in Auschwitz, captured the records of the camp
        intact, particularly the construction records of the
camp,
        which therefore went to the Moscow archives.  Poland,
        where Auschwitz is situated, was behind the iron
curtain.
   Q.   I am getting some information.  Continue.  Yes?
   A.   Principal archives which were being used by historians
at

.          P-155



        this time were in the national archives in Washington,
and
        the German Federal archives, to which I at that time
still
        had access, not having been banned from them by the
German
        government in the interests of German people.
   Q.   Are you familiar with the work which you disparagingly
        call the French country chemist, Jon-Claude Presac?
   A.   I am not familiar with his work, no.
   Q.   You know who he is, do you not?
   A.   Yes.  He wrote this being volume on the desk.
   Q.   He did indeed.  Do you know that he went to the
archive in
        Auschwitz in 1982 and 1983?
   A.   Maybe they found favour in him which they did not find
in
        me.
   Q.   You never asked?
   A.   I am not a Holocaust historian, Mr Rampton.  At this
time
        in 1988 I was writing, if I remember correctly, the
latest
        edition of the Hermann Goring biography or I was
working
        on the second volume of my Winston Churchill
biography,
        neither of which would have required me to go to
        Auschwitz.
   Q.   You cannot have it both ways.  You cannot have it that
        Auschwitz did not exist and you cannot have it that
there
        is no evidence in the archive if you have never
looked.
   A.   If I say I have been round the archives, I am not
saying
        I have been round all available archives, including
those
        had Poland and elsewhere.  I am saying I have been
round

.          P-156



        the archives, which at that time is perfectly true.  I
        might even have gone to the Public Records Office to
see
        what they had.
   Q.   You might have been round the archives of the Royal
        Botanical Gardens in Kew, for all I know.
   A.   I find that a cheap remark.
   Q.   Of course it is cheap, but this is a very cheap----
   A.   Which you say is a matter of great sensitivity to the
        Jewish people.
   Q.   This is a very cheap fraud that you have perpetrated
on
        the 50 or so people in this room because what you are
        telling me is that you have looked everywhere and all
        anybody can come up with is two or three documents.
   A.   I have not said I have looked everywhere.  This is
again
        your manipulation of the sentence, your rather
superfluous
        gloss. To look everywhere you need to spend the kind
of
        money that your team has spent.
   MR JUSTICE GRAY:  Can I put it a different way round? Which
        were the archives that you had spent a few months
going
        round?
   A.   I do not want to be ambushed by references from my own
        diary, but I would suspect, from the way I put that
        sentence, that I went to the German Federal Archives
and I
        went to the national archives in Washington, and
possibly
        to the Hoover library in California where they also
have a
        certain amount of material relating to this.

.          P-157



   Q.   So you have done a fair amount of research into the
        Holocaust, or into Auschwitz?
   A.   Yes, but not specifically for that.  I would have gone
        there for other purposes and I would then have called
up
        roles of microfilm of Heinreich Himmler's papers which
are
        in great abundance in the national archives and I
would
        have looked at some of the Nuremberg documents.  But I
had
        not travelled there specifically to research the
        Holocaust.  At this time I was researching probably
        Winston Churchill Volume 2.
   MR RAMPTON:  So, when you said on page 6 that in relation
to
        Hitler you had been round the archives of the entire
        world, we have to exclude Auschwitz from that, do we
not?
   A.   Can I see the exact reference?
   Q.   Yes, of course you can.  You are talking about Hitler
and
        his knowledge of whatever, I do not know, Auschwitz
        I suppose, five lines up from the bottom?
   A.   Because I worked in the archives of the entire world,
        including the public archives here in Wellington
Street.
        That shows as Ottawa, by the way.
   Q.   Please do not give us a list.  The entire world is the
        entire world, but apparently does not have Auschwitz
in
        it.
   A.   It did not have anything behind the iron curtain and
the
        people who were in the audience at that time would
have
        realized that.

.          P-158



   Q.   Oh, I see.  So they would not have been in the least
bit
        deceived?
   A.   Mr Rampton, you have to put yourself back to 1988
before
        the wall came down.
   Q.   I do not think so, because I am told that the archive
at
        Auschwitz was readily accessible to anybody with the
        proper credentials, that is to say I am an historian,
        please may I have a look because I intend to write a
        serious piece of research about this, before I go
public
        on what it was or was not.
   A.   So we are coming back on to the negligence argument
        again?
   MR RAMPTON:  No.
   MR JUSTICE GRAY:  The picture I have, and I think we
probably
        need to press on a little bit, is that Auschwitz may
or
        may not have been accessible to somebody like
yourself,
        but you never in fact enquired about getting access to
the
        Auschwitz archive?
   A.   I ought to have but did not.  If I was going to write
        about Auschwitz and the Holocaust then I ought to have
but
        did not.
   Q.   That is a fair summary of factual position?
   A.   Yes, with the rider that I added, my Lord, that if I
        intended to write about the Holocaust, then I would
have
        done that and ought to have done it.
   MR RAMPTON:  I add to this, and you not only deliberately

.          P-159



        decided not to go to Auschwitz because you were not
        interested in finding the truth before making these
        statements ----
   A.   Deliberately decided not to?
   Q.   Yes, deliberately decided not to. You made a
deliberate
        decision. If you were the slightest bit interested in
the
        truth about Auschwitz, you would have gone there.
   A.   If I was writing a book about Auschwitz and the
Holocaust,
        then I would have gone there.  When I became deeply
        involved in it, thanks to this litigation, and I tried
to
        go to Auschwitz, then I was banned from entry, the
only
        person in the world who has so far been banned,
        apparently.
   Q.   That was recently, Mr Irving.
   MR JUSTICE GRAY:  There we are.
   MR RAMPTON:  What is more, Mr Irving, what is important
about
        this very early speech in your Holocaust denial
career, is
        that you actually deliberately misled your audience in
        Toronto or Ottawa or wherever it is into believing
that
        you had done the research and had found that there was
no
        evidence.
   A.   I can only repeat what I previously said, Mr Rampton,
that
        my audience were not stupid and they knew that the
iron
        curtain was still standing at that time, even if you
have
        forgotten it.
   MR JUSTICE GRAY:  Is that the lot from that speech?

.          P-160



   MR RAMPTON:  That is all I want from Toronto/Ottawa,
whichever
        it be.
   A.   There is, of course, a great deal more in that speech,
my
        Lord, which your Lordship may well read later on.  The
        reasons why one is sceptical about the report by the
two
        Slovac Jews, for example, and so on. I am not just
        speaking off the top of my head.  It is quite clear, I
        think, by that time that I went to the Reisaltz
Library
        and had a look at the origins of the war refugee board
and
        its entire file on that report and so on.  It is a bit
        deceptive really just to take these single paragraphs
out
        and hold them up.
   MR JUSTICE GRAY:  We may have to have more discussion about
the
        mechanics of dealing with the contextual points that
you
        want to take.
   MR RAMPTON:  I quite agree about that and, as I think I
have
        already said at some time in this case if not just
now,
        one of the problems with this sort of an exercise is
that
        there is a danger that the most innocent selectivity
can
        lead to distortion.  I do not want that to happen.  I
do
        not want to skin this cat by a false case, if you see
what
        I mean.
   MR JUSTICE GRAY:  I follow that.  This is not a criticism
and
        please do not think it is, but we have taken, I do not
        know, three quarters of an hour on one relatively
        unimportant speech, and I do not think we can do that
with

.          P-161



        all of them, can we?  It really is not a criticism.
This
        is very difficult.
   MR RAMPTON:  I realize that.  I would make the complaint,
if
        I had to, that I never get an answer to my question.
   MR JUSTICE GRAY:  I am not being critical either way.
   MR RAMPTON:  I get a speech, and that is one of the reasons
why
        it takes such a long time.
   MR JUSTICE GRAY:  I did suggest prime examples.
   MR RAMPTON:   That is quite a prime example, in our
submission.
   MR JUSTICE GRAY:  I think the answer is a selection of
prime
        examples, followed by a marked up list of those that
are
        relied on, and then and then we will work out how best
to
        allow Mr Irving to take the context.
   MR RAMPTON:  My Lord, I think I already read some of the
most
        important parts of the press conference announcing the
        publication of the Leuchter report.
   MR JUSTICE GRAY:  Can you give me the reference?
   MR RAMPTON:  That is tab 5 of same file.
   A.   If you had listened, with respect, to what I said about
        weighting the verbal utterances less heavily in the
        written books and so on, perhaps we would have avoided
        part of this misery.

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