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globally and less grandly, saying there were none, which implies that nowhere in my entire writings have I have used historical documents properly?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 Q. Never once I did use a historical document correctly?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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