Archive/File: people/i/irving.david/libel.suit/transcripts/day018.14
Last-Modified: 2000/07/24

   Q.   I see, topics as broad as that?
   A.   -- accuse Mr Irving of Holocaust denial.  Then I decided
        to look at what he himself describes as the chain of
        documents which show that, in his view, Hitler was, as he
        says somewhere, the best friend the Jews ever had in the
        Third Reich.  So we looked at as many of those as we
        could, all of the ones we could find, and in all of those

.          P-118

        we found the same thing, that is to say, where there were
        distortions, suppressions and manipulations.  That is what
        I am saying there.
   MR IRVING:  We are going to come to the next paragraph, but
in
        retrospect would you wish that you had phrased that
final
        sentence less globally and less grandly, saying there
were
        none, which implies that nowhere in my entire writings
        have I have used historical documents properly?
   A.   Well, I did not find that in what I looked at.
   Q.   Never once I did use a historical document correctly?
        Never once did I use material that had been before me?
In
        all the records and books that you examined and we are
        going to see in a few pages time which books you did
        examine.
   A.   Yes.  By occasion, I mean of course the topics that we
        examined.  No doubt, if you say that Hitler was born
on
        such and such a date in such and such a year, that is
a
        correct statement.
   Q.   That is not what you are saying.  I will repeat it
again,
        "We have not suppressed any occasion on which Irving
has
        used accepted and legitimate methods of historical
        research, exposition, interpretation.  There were
none."
        You are referring to my entire corpus of writing.
   A.   Indeed, yes, and I am following on the statements in
the
        previous paragraphs and pages where I describe the
methods
        used to draw up the report, and the word "occasion"
there

.          P-119



        refers to the various topics that we looked at, which
are
        outlined in the previous paragraphs.
   Q.   I would not want to rewrite your report.   What you
should
        therefore written surely was----
   A.   I am sure you would.
   Q.   -- not "there were none" but "there were none in the
few
        instances that we examined".  Is that you are trying
to
        say?
   A.   I do not accept that there were few instances.
   Q.   Three instances, Reichskristallnacht, Dresden and the
        Adjutants.  Is that correct?
   A.   That is not correct at all, Mr Irving.  We examined a
        great many other instances.
   Q.   But then you continue in the next paragraph of course,
        then comes the purple prose as to what you alleged to
have
        found swimming around in this cesspit of David
Irving's
        writings.  "I was not prepared", you write, "for the
sheer
        depth of duplicity, his numerous mistakes, that is the
        bottom line but one, and the egregrious errors".  On
the
        contrary, "they were not accidental", you say, on the
        contrary, it is obvious that they were calculated and
        deliberate.  Now, do you still stand by this
assessment?
   A.   Most certainly, yes.
   Q.   In all my writings?  Or are you just referring to
these
        few passages that you are being specific about?
   A.   I am referring to the passages, the instances which we

.          P-120



        examined.
   Q.   I think it would probably be helpful to his Lordship
if
        you just listed on the fingers and thumbs of one or
two
        hands which specific instances this sweeping and
rather
        brutal judgment applies to?
   A.   They are listed on the contents page of my report, my
        Lord.
   MR JUSTICE GRAY:  Yes.
   Q.   These are the only instances you are referring to with
the
        sweeping judgment, in other words you are not going to
        pass judgment on the rest of my writings?
   A.   Well, I am satisfied, as I say in the report, that we
        examined a sufficient number of instances to assure
        ourselves that they were representative of your
writings.
   Q.   All the rest.  I am afraid I was not properly
listening to
        your answer in response to his Lordship's question.
Who
        picked these instances?  Was it picked in committee
with
        the Defendants?  Did they say, why not go for
        Reichskristallnacht, pick on Dresden too, he is weak
on
        that?  Did you have a free hand?
   A.   I had a free hand and I picked them myself.
   Q.   No suggestions were made from the Defence upon
instructing
        solicitors?
   A.   Not to my recollection, no.
   Q.   Happened to pick on Reichskristallnacht and happened
to go
        to Dresden, although not very familiar with my work

.          P-121



        previously?
   MR RAMPTON:  My Lord, in fairness to the witness, Mr Irving
        probably was not listening, often one does not listen
very
        carefully when cross-examining, there was an earlier
        answer to the effect that what started the topics
listed
        at paragraph 4 of the contents page on the second page
was
        the very first item in that entry, "Irving's chain of
        documents" and thing leads to another, therefore.
   MR IRVING:  Well, the chain of documents, of course, refers
        specifically to Hitler's responsibility for the Final
        Solution.
   MR RAMPTON:  Yes, but it includes, for example, eight or
nine
        examples, just as an example, Reichskristallnacht,
which
        in itself is an enormous subject.
   MR IRVING:  It does not include Dresden and it does not
        include  ----
   THE WITNESS:  No.  As I explained in the report, I thought
that
        it was not really sufficient just to look at the chain
of
        documents.  The reason for that was that it might be
        arguable, as a number of your reviewers have indeed
        argued, that you were, as it were, unsound on that one
        issue, but sound on everything else.  So I decided to
look
        at Dresden because that is the book which established
your
        reputation and has probably sold more than -- correct
me
        if I am wrong -- any other of your books.
                  So that seemed to be one of your strongest

.          P-122



        books, if not your strongest book, so I decided to
look at
        that as well.  I did not want to confine myself, in
other
        words, simply to the chain of documents relating to
        Hitler's responsibility or, you would argue,
        non-responsibility for the Final Solution.
   Q.   Could it be that you set out with the belief that I
had
        used these methods that you describe as sheer depth of
        duplicity and of distortion and the rest, and that you
had
        preconceived that notion, then you picked on three or
four
        roads by which to arrive at that particular Rome, so
to
        speak?
   A.   No, that is not the case at all; as I describe in the
        report, I had very little knowledge of your work and I
was
        aware of your reputation as having been somebody who
was
        in many cases, in many areas, a sound historian, and I
was
        rather surprised at the results that I found.  I
described
        that all in my report and that was an honest
description
        of my reaction.
   Q.   Are you going to be prepared to eat your words if we
take
        each one piece by piece and find out that you were
        misjudging me?
   A.   Let us see.
   Q.   Then we shall come to that ----
   MR JUSTICE GRAY:  Can I ask you this, Professor Evans?  Did
you
        consider Mr Irving the military historian, if you
follow
        what I mean by that?  It is not really your subject,
as

.          P-123



        I understand your evidence this morning?
   A.   Yes, it seems to me that he is a military and
political
        historian.
   Q.   I do not doubt that, but I just wondered whether you
have
        considered as a separate aspect of his historical
writings
        his writings on military as opposed to political
history?
   A.   No, because they do not really relate to this case.
   Q.   Well, I thought that might be your answer, yes.
   A.   Obviously, though, it is enormously -- as you can see,
        this is a 740 page report.
   Q.   I am well aware of that.
   A.   It took an enormous amount of time and effort to do
and
        there is simply a limited amount of time available.
   MR JUSTICE GRAY:  Yes.  No, it is not a criticism at all.
        I just wanted for myself to know.  Thank you.
   MR IRVING:  So if somebody had mentioned the name "David
        Irving", would you have said to yourself, "Oh, yes,
that
        is the Holocaust historian"?
   A.   No.
   Q.   You would have said, "That is the specialist in Third
        Reich personalities" or "The specialist in Naval war"
or
        what?  Would anything have occurred to you?
   A.   Well, you have written on a variety of subjects, of
        course, but they have mostly been, with the exception,
        I think, of the book on Hungary in 1956, books about
        Germany and the Second World War and aspects of German

.          P-124



        politics, German personalities, biographies of leading
        German figures and aspects of the war.
   Q.   You say on page 20 -- my Lord, now at the top of page
20
        of his report -- "That is precisely why they are so
        shocking.  Irving has relied in the past, and
continues to
        rely in the present, on the fact that his readers and
        listeners, reviewers and interviewers lack", well,
        "expertise" you say there.  You are saying that
everyone
        who reads my books, effectively, are ignorant and so
they
        cannot spot how duplicitous I am.  Is that what you
are
        saying?
   A.   Let me read the sentence:  "Irving has relied in the
past,
        and continues to rely in the present, on the fact that
his
        readers and listeners, reviewers and interviewers lack
        either the time, or the expertise, to probe deeply
enough
        into the sources he uses for his work to uncover the
        distortions, suppressions and manipulations to which
he
        has subjected them".
                  Let me carry on just in the next sentence,
if
        I may:  "The late Martin Broszat and the American
        historian Charles W Sydnor, Jr., whose work is
referred to
        below, are virtually the only previous historians to
have
        gone some way down this road".
   Q.   I said in about six lines what you have said in 12,
that
        roughly what I said was right, that they were so
        ignorant  ----

.          P-125



   A.   No, that is not true at all.  That is why I read the
        sentence out.  I said "either the time or the
expertise".
   Q.   To see through me, is that what ----
   A.   To uncover -- I do not want to read it all over again,
        Mr Irving.
   Q.   This list of ignorant reviewers and listeners and
readers
        of my books, does it include people Captain Stephen
        Roskill, the official Naval historian?
   A.   I did not describe him as ignorant, Mr Irving.
   Q.   Well, you said they did not have the time or the
        expertise.
   A.   I said they lacked either the time or the expertise.
And
        anyone who has been involved in reviewing books knows
        that, particularly if you are reviewing for a daily or
        Sunday newspaper, you have a very tight deadline to
meet
        and you do not have the time to go back to the
archives
        and check everything out.
   Q.   You have reviewed books for the Jewish Chronicle, have
you
        not?
   A.   I have reviewed books for the Sunday Telegraph, I have
        reviewed books ----
   Q.   Answer my question.  You have reviewed books for the
        Jewish Chronicle?
   A.   I have indeed reviewed books for the Jewish Chronicle.
   Q.   So you are familiar with the fact that they do not
have
        enough time, when you are reviewing books, this is
where

.          P-126



        your expertise there comes from?
   A.   I said you do not have enough time to go back to the
        archives and the original sources to check the
statements,
        and also, as I go on in the report to say, that,
normally
        speaking, reviewers of academic, scholarly and non-
fiction
        works generally, unless they have reasons to suppose
        otherwise, make the basic assumption that the author
is
        honest and reporting honestly what he or she finds.
   Q.   Knows what he is talking about.  Well, that is the
        assumption that we are making in this court about you
too,
        is it not, really, that you are not prejudiced or
biased
        or that you have no private animosities towards
anyone?
   A.   I am glad you think so.
   Q.   Yes, it is an assumption we all make.  But now can I
come
        back to my question, which is that these ignorant
        reviewers and listeners, for whatever reason, do they
        include people like Captain Stephen Roskill, the
official
        Naval historian?
   A.   I do not describe them as "ignorant", Mr Irving.  I
say
        they lack either the time or the expertise -- one or
the
        other.
   Q.   Professor AJP Taylor, would that include him?
   A.   He was not a Professor, but, aside from that, I think
he
        is one of the historians who ----
   Q.   Professor Hugh Trevor Roper, would you include him in
that
        kind of wayward, negligent category, a reviewer?

.          P-127



   A.   As I go on to say, the ----
   Q.   But we are going to go on to the next two names you
have
        mention in a minute, but let us deal with ---
   A.   You have mentioned.

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