Archive/File: people/i/irving.david/libel.suit/transcripts/day027.11
Last-Modified: 2000/07/25

   Q.   It is not impossible, of course, that these skinheads have
        been bribed to come along and shout those slogans for the
        benefit of the newsreel cameras?
   A.   No way, because I looked very exactly to the surrounding
        conditions and I laid this out before the break, and
        I could extend it to hours, what this special meeting in

.          P-94



        early November '91 meant, especially for the two levels of
        the three I mentioned, that is the neo-Nazi reorganizing
        attempts and the reference and the organizational capacity
        they want to extend to the violent skinheads scenery in
        East Germany.
   Q.   Of course, you agree that, if I had no connection with
        anybody at that Halle function, apart from the invitation
        from Mrs Worch to come and deliver a five-minute talk,
        then what the infrastructure may have been is not
        necessarily something that I will have heard about?
   A.   It is a kind of denying, if I may say so.  This whole
        circumstance, this political revisionist, the like,
        circumstances, you took side, you cooperated for a period
        of time with 26, you know, mentioning of the interaction
        between the Worches and so forth, the Ewald Althans
        interaction was even more intense, the Karl Philipp
        interaction.  So, if I may draw the attention to the whole
        picture you will get if you see Mr Irving throughout these
        years interacting with these groups, and he again and
        again had to face this, and all the way long he reiterated
        his quest to speak before these audiences, and was there.
        So in that sense, I will draw a different picture than
        this is alluded in the question of Mr Irving.
   Q.   You talk about getting the global picture.  Well, today
        and I suppose now tomorrow as well, we will be getting the
        global picture, which is everything I was doing at that

.          P-95



        time and not just these one or two episodes that have been
        selected.  Do you agree with that?
   A.   Not everything, oh no.
   Q.   There is a much wider picture.
   A.   I just pinpoint these things that are of importance for
        the libel act, having extremist views, are you a dangerous
        Holocaust denier.  You know, the Holocaust denier thing is
        somehow embedded in these political years, and that may
        cause a judgment to be dangerous, and this is up to of
        course the court and not to me.  But there is something
        that conflates the two levels of activities -- conflate,
        coming together.
   MR JUSTICE GRAY:  Converge?
   A.   Converge, excuse me.
   MR IRVING:  Yes.  You have picked altogether on, I think we
        will find we end up with about half a dozen names that
        mean anything, because most of these people, you will
        probably agree, I have never met or heard of before.  So,
        if we end up with half a dozen or a dozen names.
   MR JUSTICE GRAY:  That is too broad to be answerable.
   MR IRVING:  There is a question that actual follows.  That was
        a comma there.  The question now follows.  Professor
        Funke, will you now please have a look at the little
        bundle of documents I gave you, so we can give it a kind
        of scale of proportion.
   A.   Is this the bundle J?

.          P-96



   MR JUSTICE GRAY:  Yes.
   MR IRVING:  Yes, it is.  Professor Funke, if you just look at
        pages 4, 5, 6 and 7, I do not want you to read them, just
        look at the numbers at the top of each of those pages.
        Will you agree with me that those are the title pages of
        five of my address lists on my computer, and that they
        show respectively totals of addresses of 571, 1169, 966,
        2000, 158, 1662 records?  All told about 6,500
        acquaintances that I have, just from these five address
        lists.  You have picked on six or 12 or of that order of
        magnitude.  I have contacts with all of these 6,500
        people.  That is the global picture.  You have picked on
        just these few.  Would you agree that therefore possibly
        the poisonous extremism which you think you have found in
        David Irving is possibly diluted when it is dropped into
        the larger ocean of all these worldwide contacts, many of
        whom are left wing liberals, for example?
   A.   It is not my duty to judge the 6,000 plus addresses and to
        look after them.
   Q.   Yes.
   A.   It was my duty to refer to the cause of the libel act, and
        so far I have to reiterate that the bunch of people we
        discussed before the break are so decisive in making up a
        very violent movement, that of course there is a question
        how far, Mr Irving, if I may say so, you are interacted
        with them, or not.  My judgment is that you were in the

.          P-97



        course of these years.
   Q.   In your opinion, yes.  I will be looking at a lot of these
        names in detail as we go through your report but I am
        going to ask general questions now.  You had complete
        access to all my private diaries, although I noticed in
        your report there is a reservation about whether it was
        complete access or not.  You had complete access to all my
        telephone logs.  Did you notice that in my private diaries
        at the beginning of every year there were pasted lists of
        people who received Christmas cards from me, or from whom
        I received Christmas cards, just as one thermometer, so to
        speak, of personal friendships?  Did you notice these lists?
   A.   I saw some of them and, of course, I did not address it
        because it is not to the interests of the public court
        I let of course out all the very private things, and this
        is due to my personal understanding, and I think also to
        the rules of the court.
   Q.   But, Professor Funke, you would certainly have mentioned
        in your report if you had noticed that I had received
        regularly Christmas cards from the Worch family or from
        your Thomas Dienel, or any one of these other people, you
        would have mentioned it, would you not, or if I had sent
        them?  It would have indicated a closer degree of intimacy
        than just being telephoned by these people?
   A.   This question presses me to go in further detail to what

.          P-98



        I realized with respect to both Worch, and again I have to
        restrict myself, but what I can say definitely and we can
        have further detailing of that, that there was a very,
        very intense relationship, cooperation, and what-have- you,
        between David Irving and Christian and Ursula Worch.  This
        is for sure.
   MR JUSTICE GRAY:  Yes, but we were on Christmas cards.  You do
        not need to repeat what you have said already, if I may
        say so, Professor.
   MR IRVING:  The answer is no, I think, is it not?
   MR JUSTICE GRAY:  I think the answer is that if you had
        discovered there were Christmas cards being exchanged with
        the Worchs regularly, you probably would have said so?
   A.   I do not know.
   MR IRVING:  Another general question:  in the exchanges that
        passed between myself and the Worchs, is there any element
        of Holocaust denial or anti-Semitism to your memory?
   A.   Say it again?
   Q.   In the exchanges, the contacts, between myself and Worch,
        Mrs or Mr Worch, was there any element of Holocaust denial
        or any element of anti-Semitism?
   A.   I mean, the very fact that Mr & Mr Worch was a key
        organizer of this very Holocaust denier Congress in Munich
        is an indication that, yes.
   Q.   Mr Worch was an organizer of the Leuchter Congress, in
        your opinion?

.          P-99



   A.   No, of the first Congress in 21st April '90.
   Q.   On what?
   A.   He was there and he was there again.
   Q.   On what evidence do you base that statement?
   A.   If I may add, he was there again in late March, as you
        could see just a minute ago.
   Q.   You say he was there, but how many people do you estimate
        were there Lowenbraukeller in Munich on 21st April 1990,
        2,000 people?
   A.   I do not know.  It was said that there were 800 or so.
   Q.   So being there is not enough.  What evidence do you base
        your statement that Worch was an organizer of that Congress?
   A.   Because he prepared it together with others.  He was - ---
   Q.   What evidence?
   A.   He was responsible for the so-called security thing.
        I said deliberately that this picture, we are both of
        these various persons stood together, that is Althans, on
        the one hand -- he was, of course, the more important --
        and Christian Worch, on the other hand, showed something
        about the degree in which they were interacting by
        preparation and enacting the Congress.
   Q.   So your statement is based purely on that visual image we
        have of Althans standing next to ----
   A.   No, also the references in what you got, I think, of the
        whole, of the whole letters from you to them and back and

.          P-100



        so forth.
   Q.   I do not want to hold you up, but if you can find evidence
        that Worch was involved in the organization of the
        Lowenbraukeller meeting, then perhaps you can present it
        morning?
   MR JUSTICE GRAY:  Sorry, is the Lowenbraukeller meeting --- -
   MR IRVING:  April 21 1990, my Lord.  That was the second video
        that was shown to us today.  (To the witness):  You
        estimate there were 800 people in the audience?
   A.   I cannot say.  I was not there.
   Q.   And all people that were drawn to our attention, the
        person you identified as Michael Kuhnen craning his neck,
        the one without glasses, and Otto Ernst Remer and Manfried
        Reuder, these are the names of people you picked out, they
        were all sitting halfway down the audience, were they, or
        in the middle of the audience?
   A.   I do not know.
   Q.   They were not wearing nameplates or anything?  They had no
        name tags on, did they?
   A.   So far as I saw, no.
   Q.   These may seem silly questions to you, but I have to ask
        them for obvious reasons.  It was the same on the first
        video that was shown at Hagenau.  You identified there
        Mr Faurisson, Mr Zundel and Mr Worch and somebody you said
        seemed to be Staglich?
   A.   Yes.

.          P-101



   Q.   And do you agree that I was not visible on any of those
        shots in which those people were visible.  Therefore,
        there is no indication that I was in the room at the time
        that they were there or when mr Zundel was making his speech?
   A.   Not by this video.
   Q.   Not on this video?
   A.   No, I cannot see because you spoke at the given time and
        the video is not the last proof if you are at this given
        moment you were in the room, and there is no way to
        identify it 100 per cent.
   MR JUSTICE GRAY:  I beg your pardon for interrupting.  Are we
        on the April 1990?
   A.   No, he went back to Hagenau.
   MR IRVING:  This is Hagenau, the first video, my Lord, Hagenau.
   A.   Yes.
   Q.   The people pointed out to us were Mr Faurisson, Mr Zundel,
        Mr Worch and somebody who "seems to be Staglich".  Those
        are the only comments I have to make on the videos which
        were, as I understand it, only introduced or accepted for
        identification, rogues gallery purposes, on this
        occasion.  Unless your Lordship has any questions to ask?
   MR JUSTICE GRAY:  I do one, yes, is Worch's first name is Uschi?
   MR IRVING:  "Christian".

.          P-102



   A.   There are two Worchs.
   MR IRVING:  And his wife is Ursula.
   MR JUSTICE GRAY:  Who is Uschi?
   MR IRVING:  His wife, Ursula.
   A.   It is a shortening or a kind of nickname of Ursula.
   MR JUSTICE GRAY:  Mr Irving, I am not sure whether you are
        putting this, are you suggesting you were not there for
        the whole of the Halle meeting?
   MR IRVING:  Yes, my Lord.  I am suggesting that I arrived two
        or three minutes before it all began.  I got on the back
        of truck, made my 10 minute brief statement to the young
        Germans, got back in my car and got out of it as fast as I
        could being thoroughly aggravated by the whole episode.
   A.   Can I say something to that?
   MR JUSTICE GRAY:  Yes, please.
   A.   You said two or three minutes before you staged your speech?

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