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Last-Modified: 2000/07/24

    Q.   Is not it true that with 20-20 hindsight that we all now
         have, thank God, although in some of us our eyesight is
         failing, we can perceive where figures are accurate and
         figures are not accurate?

    A.   Let me just deal with the previous point.  You sent him a
         book which is fine, but the point is that you do not, you
         describe him in the book and he is replying to you here
         really in relation to the book which you sent to him, you
          are describing him as Dresden's Chief Medical Officer or
         Deputy Chief Medical Officer, whereas he says he was not;
         he was just a specialist in neurology.  He says:  "I have
         only ever heard the numbers third hand", and you describe
         him as being a kind of first-hand source.  So he has a
         number of objections in the letter to what you say in the book.

    Q.   That is not the point.

                                 .          208

     A.   What I say here is on your rely to Funfack you had not in
          fact tried to contact Funfack to establish whether these
          things were true or not before you wrote the book.

     Q.   That is not what you write though, is it?  In paragraph 5,
          page 520, you say:  "From his reply on 28th February to
          Funfack's letter, it is clear that Irving had in fact made
          no effort whatsoever to contact Funfack"?

     A.   Yes, it is quite clear what that means from the context of
          the previous quotation and description.

    MR JUSTICE GRAY:  It depends what you mean by "had".

    MR IRVING:  Yes.  Do you agree that Dr Funfack living, as he
         did, behind Iron Curtain in one of the most Stalinist of
         the Eastern European states, Eastern Germany, had every
         good reason to be apprehensive when he was contacted by
         somebody living in the West and sending him presents and
         gifts and visiting him, and this is very evident indeed
         from the reference he makes in the letters to me about how
         he is doing everything now through the authorities, and
          that he had exceedingly unpleasant visits from members of
         the Ideological Committee of the City Commission and
         things like that?  Is it not quite plain that the
         situation of terror they were living in?

    A.   He is actually suggesting that you contact the
         authorities; not that you contact him through the
         authorities but that you contact the authorities with
         reference to getting further work.  I do believe you

                                 .          209

          yourself visited East Germany and visited Dresden under
          the Communist regime.

     Q.   Did you, Professor, every have any contact yourself with
          Soviet citizens or citizens living in the Soviet zone of
          Germany at that time or thereabouts?

     A.   Not in 1965 when I was schoolboy, but certainly under the
          GDR, yes, I was visitor on a number of occasions.

     Q.   It was a police state, was it not?

     A.   You may describe it as such, yes, it is true.

    Q.   Well, did they have an organization known as the Stazi?

    A.   Indeed, yes.

    Q.   Did they have large numbers of political prisoners in their jails?

    A.   Substantial numbers, yes, that is true.

    Q.   So that somebody receiving letters from Western Germany or
         from England was, in fact he mentions in one of his
         letters that it had a stamp on the outside and this kind
         of thing; in other words, he is living in a state of ----

     A.   May I just ---

    Q.   --- genteel terror, if I can put it like that?

    A.   There is no doubt that correspondence was monitored by the Stazi.

    Q.   So this is one very good reason that he would have for
         denying that he had been anything at all in the Third
         Reich, is it not?

    A.   Not really, no.  I do not think there is any shame in

                                 .          210

          being a medical officer in Dresden in the Third Reich.  It
          is not as if he was us a Obersturmbannfuhrer in the SS or
          the concentration camp.

     Q.   Did you not read that inference into his second letter
          where he explains the reason why he is wearing his uniform
          in the photograph?  You remember the famous photographs of
          the mass relations and there he is in his uniform and he
          takes great pains in his letter to me to explain that that
          is the one occasion he wore the uniform because otherwise
         he could not have got through the police cordons?  Does
         not that kind of thing in a letter written from East
         Germany tell you anything?

    A.   It does not cast doubt on what he says, that he was never
         the chief medical officer and that his knowledge was only third hand.

    Q.   His knowledge is direct from Klaus Maynart, is it not, the
         City Commandant, and from the Chief of the Civil Air
         Defence who stated their estimates to him and repeatedly
          said afterwards: "We cannot believe these low figures we
         are hearing about now."  They expressed their astonishment
         to him, did they not?

    A.   Yes, many people did, but there is no documentary evidence
         there.  The document we are dealing with is a forgery
         which you knew to be a forgery and yet you present it to
         the Provost of Coventry as genuine.

    Q.   When a writer is carrying out research on a subject like

                                 .          211

          this and he establishes contact under difficult conditions
          with sources as close to the facts as these sources
          purport it or appear to be, is not perfectly proper and
          the opposite of perverse for that writer to use the facts
          and figures that he gives to them?

     A.   I am sorry, I did not quite follow that question.  It was
          a bit convoluted.

     Q.   It is getting a bit late.  We will move on.

     MR JUSTICE GRAY:  Are you talking about Funfack's own figures
         or the figures he gives from ----

    MR IRVING:  Yes, precisely, the statements, the figure given to
         him, the quality of the source.

    MR JUSTICE GRAY:  Given to him by Maynart?

    MR IRVING:  Yes.  It tallies closely with the figures given by
         Voight at that time?

    A.   It is just gossip and rumour.

    Q.   Page 544, paragraph 2 line 2, you refer to a letter to me
         from a man called Sperling.  Was Sperling an official of
          the Federal German Statistical office?

    A.   Yes.

    Q.   Is that the German Government Ministry which is
         responsible for keeping all census and statistical figures
         relating to Germany?

    A.   That is the West German office, yes, at that time.  Indeed.

    Q.   Did he write a letter in which he stated that immediately

                                 .          212

          after the attack on Dresden the number of dead was
          estimated by local authorities at 180,000 to 200,000?
          Never mind about whether the figure is right or not, but
          did he write that to me?

     A.   Is this in discovery?

     Q.   It is on page -- you quote it on paragraph 544, your
          paragraph 2.

     A.   Yes.  I am not sure I have seen this letter.

     Q.   Well, where else did you get it from?

    A.   This is quoting your version of it.

    Q.   On microfilm which was in the discovery.  It is over the
         page, the footnote 151.

    A.   Yes.

    Q.   He wrote that letter to me before the book was published,
         April 25th 1962?

    A.   Yes.

    Q.   Information of that quality from that German Government
         source, would you describe it as perverse for a historian
          a writer to use that figure?

    A.   Let us have a look at exactly what this says.

    MR JUSTICE GRAY:  Who was Sperling?

    A.   He is an official of the Federal Ministry of Statistics.

    MR IRVING:  Statistics in Germany which keeps figures like this.

    A.   In West Germany in the mid-1960s.  The figures that
         Mr Irving quotes in his very various works as having been

                                 .          213

          given by Sperling seem to vary from one edition of the
          book to another one:  180 to 20,000 in one, 120 to 150 in
          another and then 120 to 150 again and then up to half a million.

     Q.   He quotes both those sets of figures, does he not, in his
          letter, is that right?

     A.   Can we have a look at the letter?

     MR JUSTICE GRAY:  Where is the letter?  Can we dig it out?

     MR IRVING:  He quotes the letter actually in the book, in his report.

    MR JUSTICE GRAY:  147, note 147.

    A.   No, my Lord, I do not think it is.

    MR JUSTICE GRAY:  Is that wrong?

    A.   544.

    MR IRVING:  Page 544, paragraph 2.  Unless they misquoted the
         passage from the letter, that is the actual quotation in
         quotation marks which gives both sets of figures.

    A.   Yes, to the microfilm.

     MR IRVING:  My Lord, I only have two more questions now and
         then I am through.

    MR JUSTICE GRAY:  I would quite like to find Dr Sperling's letter.

    MR RAMPTON:  If your Lordship would like to see the document.

    MR JUSTICE GRAY:  If you have it available.

    MR RAMPTON:  It is page 15 of whatever this thing is that

         I have here, tab 3 of L1.  It is first of all in German.

                                 .          214

          It is on pages 15 and 16 it is in German, and on pages 17
          and 18 it is in English.  I am afraid I cannot read either of them.

     MR JUSTICE GRAY:  L1 tab 1?

     MR RAMPTON:  Tab 3 of page 15.  The Professor has not got it.

     MR JUSTICE GRAY:  Is this from Goring?

     MR RAMPTON:  No.

     MR JUSTICE GRAY:  L1 tab 3.

     MR RAMPTON:  Yes.

    MR JUSTICE GRAY:  Pages 17 and 18.

    A.   It is the blue numbers.

    MR RAMPTON:  The blue numbers on the bottom right-hand corner.

    MR JUSTICE GRAY:  Goring at the top of the page.

    A.   I still do not have this.

    MR RAMPTON:  It is tab 2.

    MR IRVING:  My Lord, the translation appears to be on the
         second and fourth pages.

    MR JUSTICE GRAY:  Yes, page 18.  It almost completely is illegible.

    MR IRVING:  I have put a bracket in the margin next to the
         paragraph I quoted and relied upon.

    MR JUSTICE GRAY:  It is more literal in the German.

    MR IRVING:  It is exactly the same as is quoted in the expert report.

    MR JUSTICE GRAY:  Mr Irving, what does the last sentence in
         that paragraph say?

                                 .          215

     MR IRVING:  On the expert report?

     MR RAMPTON:  No, in the letter.

     MR JUSTICE GRAY:  Dr Sperling's letter.

     MR IRVING:  My Lord, as a result of the shock, the offices ----

     MR JUSTICE GRAY:  I think Dr Sperling comes up with a figure of 60,000.

     MR IRVING:  Yes.

     A.   Yes, but you say that it is 120 to 150, Mr Irving.

     MR IRVING:  "After weighing all democratic factors and
         technical numeral inferences, most probability is attached
         to a figure of 60,000 losses", yes.  In West Germany at
         that time the tendency was throughout to quote low figures
         for air raids by the Allies, by the British on German
         cities.  This was a very, very clear tendency which
         existed from the end of the war onwards.  If I can draw
         one very simple parallel here.  When I visited Dresden in
         1990 on February 13th to my astonishment the whole of the
         city centre was turned into a huge funeral procession with
          millions of candles descending on the city centre in
         commemoration of the air raid.  Something like that never,
         ever happened in Western German.  In Western German the
         effect of Allied air raids on the cities was played down
         for reasons of greater politics.

    MR JUSTICE GRAY:  So the government statistician is giving a
         politically correct figure?

    MR IRVING:  My impression on the reason why he said, "We are

                                 .          216

          inclined to play it down to 60,000", I weighted that in a
          manner which arose from the fact that I was familiar with
          the West German tendency to minimalize air raid casualties?

     A.   I am sorry, he did not say "we are inclined to play it
          down" or weighting it.  He said:  "After weighing up all
          demographic factors and technical numeral inferences most
          probability is attached to a figure of 60,000 losses",
          which we know to be a very considerable exaggeration,
         since the generally accepted agreed documented figure is
         around 25,000 to 35,000.

    Q.   Is 60,000 still within my bracket, if I can put it like
         that, of 35,000 to 250,000?

    A.   That bracket, but of course in many places you say it is
         between 100,000 and 250,000, in many editions of the book.

    Q.   The final matter I want to deal with before turning you
         over to Mr Rampton again with many thanks, is the
         allegation that I sat on the information of the real
          figures for six or seven weeks before turning them over in
         the famous letter to The Times?

    A.   Where is this?

    Q.   This is page 546 or thereabouts.

    MR JUSTICE GRAY:  I am not sure that is the right reference.

    MR IRVING:  Unless your Lordship has a better one?

    MR JUSTICE GRAY:  I think there must be a better one.

    A.   This is Schlussmeldung.

                                 .          217

     MR IRVING:  I if I can summarize in two lines again what
          happened.  Simultaneously the West German authorities and
          the East German authorities provided me with high quality
          documents, giving very specific figures, and the question
          is:  When did I receive these documents and when did
          I make use of them?

     MR JUSTICE GRAY:  Yes, I remember the point, but I do not think
          that is where it is dealt with in Professor Evans' report.

    A.   547.

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