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Last-Modified: 2000/07/20

   Q.   Never mind that.  Hitler goes on 11 lines later ----
   A.   And your experts always choose the perverse meaning of the
        word "vernichte".
   Q.   I think the word which Professor Evans has used is the
        literal one, annihilated?
   A.   Yes.  You remember I gave the distinction between
        "annihilated" and "exterminated" once?
   Q.   You can argue with my experts later on down the line,
        Mr Irving.
   A.   I shall try to avoid wasting the court's time.
   Q.   Let us try to deal with matters of substance, shall we?
   A.   Excellent.
   Q.    Ribbentrop expressed a murderous or barbaric choice
        between annihilation and transport to concentration camps?
   A.   That is correct.
   Q.   Eleven lines later in the text Hitler jumps in with an
        analogy which is based on the justification for killing
        wild animals, killing wild animals, in case they should
        cause damage.  Now, that left the matter as plain as a
        pikestaff at the meeting on 17th, whatever might have been
        said on 16th, the Nazis' blunt final point of view was,
         "They have got to be killed", and that came from the
        Fuhrer himself.  You have always known that, have you not,
        because you ----

.          P-46

   A.   I am sorry, you have taken me by surprise.  You said
        Hitler said they have got to be killed?
   Q.   In effect, yes.
   A.   Or are you just trying to slide this in under the door
        while no one is watching?
   Q.   I will read it in English.  This is unvarnished.  "Where
        the Jews were left to themselves", this is Hitler, "as,
        for example, in Poland", nothing about the Warsaw
        uprising, this is general stuff, "gruesome poverty and
        degeneracy had ruled.  They were just pure parasites.  One
        had fundamentally cleared up this state of affairs in
        Poland.  If the Jews did not want to work, they were
        shot.  If they could not work, they had to "verkommen"?
   A.   And you are saying that I concealed all this from my
        book.  I did not mention any of this?  I concealed it?
   Q.   No, Mr Irving, I am not saying that.
   A.   On the contrary, I put it exactly in the third paragraph
        of that page, and yet I am called a Holocaust denier.
   Q.   "They had to be treated like tuberculosis bacilli" --- -
   A.   All that is in there too.
   Q.   --- "from which a healthy body could be infected.  That
        was not cruel if one remembered that even innocent,
        natural creatures like hares and deer had to be killed so
        that no harm was caused.  Why should one spare the beasts
        who wanted to bring us Bolshevism more.  Nations who did
        not rid themselves of Jews perished."  Now, there is

.          P-47

        nothing following that ----
   A.   Can I just read to you the five lines in my book which
        accurately reflect exactly what you read out?
   Q.   Yes, but you have to read the whole of it.  "Poland should
        have been an object lesson to Horthy, Hitler argued.  He
        related how Jews who refused to work there were shot", the
        word you emphasised, "those who could not work just wasted
        away.  Jews must be treated like tuberculosis bacilli, he
        said, using his favourite analogy", Hitler's favourite
        analogy.  "Was that so cruel when one considered that even
        innocent creatures like hares and deer had to be put down
        to prevent their doing damage?"  So what have I left out?
        Tell me what I have left out.
   MR RAMPTON:  Will you please read the rest of the paragraph?
   MR JUSTICE GRAY:  I think, just to put the criticism,
        I personally do not see anything wrong with your
        paraphrase there.
   MR RAMPTON:  Nor do I.
   MR JUSTICE GRAY:  What I think is the criticism (and it is
        important we get the nub of it) is that you have really
        watered down the effect of your accurate paraphrase of
        what Hitler said by adding, as if it were part of the same
        conversation, a reassurance by Hitler, "There is no need
        for eliminating them".  That, I think, is the criticism.
   A.   My Lord, I have said that this is quite accurate, you are
        absolutely right.  We got that quotation wrong by one

.          P-48

        day.  But the fact that a man makes it on one day rather
        than the next does not alter the fact that he said it.  He
        said, "There is no need for that", and I can understand
        Mr Rampton's disquiet about it.  But the fact that it is
        taken down by an accurate recorder like Paul Schmidt,
        Hitler saying, "There is no need for that" cannot be
        ignored, and the fact that I put it down on 16th instead
        of 17th or the 17th instead of the 16th is -- I think it
        is a very shaky position on which to build a $5 million
        trial on.
   MR RAMPTON:  No, Mr Irving.  You see, your problem is this.  You
        were concerned that if left unvarnished, according to
        Schmidt's text, what Hitler said would appear to be fairly
        conclusive evidence that he intended the physical
        annihilation of the Jews?
   A.   So why did I just not leave out the whole thing about the
        hares and the rabbits and the putting down and the
   Q.   Because everybody else can read Schmidt, and what you
        actually did to mislead your English readers was to
        transfer a palliative remark by Hitler from the previous
        day's meeting and stuff into the text for this day?
   A.   You say everybody else can read Schmidt, but, of course,
        at the time I wrote this the Hillgruber was not
        available.  I used the original microfilms.  All this kind
        of stuff became available much later on.  Are you

.          P-49

        imagining that your average reader of Waterstones is going
        to go and get a copy of Hillgruber and find out what is in
        the original text?  No.  I put that in when I could
        perfectly easily have left it out and, of course, I did
        not because I was writing an honest, accurate paraphrase
        of what happened.
   Q.   Yes, Hillgruber was published in 1970 in Frankfurt.
   A.   But I could perfectly easily have left it out, could
        I not?
   Q.   And you did not bother to change it when you wrote your
        1991 edition either, did you?
   A.   Because I certainly attached no importance whatsoever to
   Q.   Well, then, why is Hitler's palliative remark in there at
        all?  It has no business to be there at all.  It is a
        complete rewrite of what actually happened, is it not?
   A.   Hitler's palliative remark, when Hitler says, "There is no
        need for that"?  I should have left that out?  Your
        experts would have left that out; that is quite plain.
   Q.   No, my experts give the correct account.
   A.   Your experts have a record of leaving out documents that
        they cannot explain.
   Q.   Mr Irving, come on.  This is not the playground.  My
        expert has given the correct account chronologically.  He
        describes how on 16th, Horthy said, "But surely I cannot
        murder them?" and Hitler said, "There is no need for

.          P-50

        that.  As with the Slovakians, they can be put in
        concentration camps".
   A.   Yes.
   Q.   On the next day the thing hots up, headed by Ribbentrop
        swiftly followed by Hitler and there is no palliative or
        mitigating element in that, and you knew it so you
        transferred the previous day's remark to this day?
   A.   Deliberately, right?
   Q.   Yes.
   A.   And you have no evidence whatsoever for that adverb, none
        at all.
   Q.   It speaks for itself, perhaps.
   A.   These things happen when you are writing books of 1,000
        pages.  Index cards get mixed up, you get a date wrong by
        one day, sometimes by one month, sometimes even by a year,
        and to say that this is deliberate and perverse, if your
        case depends on that, then I am really sorry for your
   Q.   Well, I am going to press this, Mr Irving, you see,
        because when we get to the 1991 edition ----
   A.   Are we not going to deal with the Hungarian version of the
        same meeting, the Hungarian records?
   Q.   I do not have the Hungarian version.
   A.   Well, of course, I had that and your experts did not.
   Q.   Are you telling me that the Hungarian version has the
        palliative remark of the 16th recorded as having been said

.          P-51

        on 17th?
   A.   No, but we are interested in what it does not have which
        is any German demand for the killing of Jews.
   Q.   Let us, if we may, turn to how you dealt with it in -- --
   A.   You see, this again is something your experts have not
        used.  I have not just used the books on the book shelf.
        Your experts sit in their book lined caves taking down
        their handy reference works.  I do the work in the
   Q.   Can we have, my Lord, it is volume 2, it is D1 (v)?
   MR RAMPTON:  That is right.
   MR JUSTICE GRAY:  It is effectively the same, is it not?
   MR RAMPTON:  No, it is not.  I mean, the substance of what
        I have just put is exactly the same, but there is one
        crucial passage which has been missed out,?
   A.   You appreciate this book is the abridged version?
   Q.   Can I ask you if you are have in court the unabridged
   A.   I am saying the 1991 version is the abridged version of
        the 1977 version.  It was produced originally as a
   Q.   It is interesting, I am going to suggest, Mr Irving, to
        look at what you have left out of the 19 ----
   A.   What has been left out?  Remember, I am not necessarily
        the person who did the editing.

.          P-52

   Q.   This book comes out, this 1991 edition, following your
        conversion to there was no Holocaust, does it not?  What
        we noticed if we look at 542, that is your account of what
        Hitler said, you still fudged together the 17th and 16th,
        but your account of what was said on ----
   A.   Well, it had not been pointed out to me at that time, of course.
   Q.   Your account of what said on 17th stops short at the
        reference to tuberculosis bacilli.  Unlike the 1997
        edition, you have missed out, omitted, the whole of the
        passage relating to the killing of innocent animals to
        prevent them from causing damage, have you not?
   A.   It did not really add very much.  If you are abridging a
        book and you see that you have three sentences which
        repeat the same thing, then you are going to cut out one
        of them.  We had shorten to book by one-third.
   Q.   You missed out the rhetorical question, "Why should one
        spare the beasts who wanted to bring us Bolshevism?"
   A.   Yes, but not for any perverse reason; purely because we
        are shortening the book by one-third and everything gets
   MR JUSTICE GRAY:  But, having said that, would you agree,
        Mr Irving, that it does portray Hitler in a slightly more
        sympathetic light than if one had had the whole of that
        quote set out in the 1991 edition?
   A.   No, my Lord, I would not agree that because the whole

.          P-53

        paragraph has been shortened, and so that actually
        enhances the effect of the ugly sentence that is left in.
        If we leave in ugly sentences and shorten the paragraph as
        a whole without cutting out all the ugly sentences, if we
        were following Mr Rampton's argument, I would have cut out
        all the ugly sentences and not just one in three which is
        what you do when you are shortening a work.
                  It is very easy to do this kind of exercise, go
        through a book that has been abridged and point out that
        sentences have been cut out, but that is the only way to
        shorten it for American -- this was an American edition
        which was produced originally in paperback.
   MR RAMPTON:  I think you were aware of the mix up of dates long
        before the second edition came out because it was pointed
        out to you by Martin Broszat in 1977?
   A.   Possibly, but you have seen how little importance
        I attached to the mix up in dates.
   Q.   Do you not think it appropriate when you are writing a
        history book, if that is what this is, to make it clear
        that, whereas when Horthy referred to his unwillingness to
        kill Jews on 16th, Hitler had said, "There is no need for
        that", by the 17th it is quite apparent from Schmidt's
        notes that the attitude of the Germans, Ribbentrop and
        Hitler, had considerably hardened?
   A.   You say this, but I do not agree.  Remember, I have not
        given dates.  I have not said, "On April 16th Hitler said

.          P-54

        this.  On April 17th Rippentrop said that".  There are not
        dates there.  I summarized both conferences in one

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