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Archive/File: people/i/irving.david/libel.suit/transcripts/day017.22
Last-Modified: 2000/07/20

   MR IRVING:  My Lord, I fail to see under what wangle Mr Rampton
        is being allowed to produce this document to put it in? It
        has had no relevance at all of the cross-examination that
        I conducted.
   MR JUSTICE GRAY:  We may not have quite got to it yet.  It is
        certainly relevant on the questioning so far on whether
        Schrecken is properly translated as "public rumour", which
        was one of the points we went through this morning.
   MR IRVING:  A very tiny shoe horn for such a long document, my Lord.
   MR JUSTICE GRAY:  I can promise you I am not going to plough
        through it unless I am shown other bits of it that are
        worth ploughing through.
   MR IRVING:  This document was one of the ones that was put
to
        Hitler.
   MR JUSTICE GRAY:  This is, as I understand it, one that is
        suggested was generated by the request.
   MR IRVING:  I think the witness should be asked if there is
any

.          P-196



        evidence that this document was one of the ones that
was
        put to him.
   MR JUSTICE GRAY:  I think that is a fair point.  I think
that
        question should be asked, whether there is any
evidence
        that this particular situation----
   MR RAMPTON:  I am going to come to that.
   MR JUSTICE GRAY:  I think you may have jumped the gun,
        Mr Irving.
   MR RAMPTON:  These documents, taken in conjunction, affect
        three questions, Mr Irving's ----
   MR JUSTICE GRAY:  We have through them.  I remember them.
   MR RAMPTON:  They all arise directly out of cross-
examination.
   MR JUSTICE GRAY:  I think that is right.
   MR RAMPTON:  I mentioned, Professor, that you have also got
        there report number 81 about which Mr Irving
        cross-examined you yesterday without producing the
        document.  He has not got it there, but I can tell
you.
        On page 14 it makes similar remarks about the 72, 90
per
        cent of the people having fled across the Urals?
   A.   This was one that was cited yesterday?
   Q.   It is the day after.  It is 12th September.  We will
hand
        those in later, if we may, my Lord.  Can you turn to
page
        59 of Longerich, part I?
   MR JUSTICE GRAY:  Mr Rampton, before we leave this, I am
taking
        it that the reference to 70 to 90 per cent of the
original
        refugees having fled is a reference supporting one of

.          P-197



        Mr Irving's points, which is that that was what
happened
        to quite a lot of the local Jews, namely they went
into
        Russia.
   MR RAMPTON:  I do not think we dispute that at all.
   MR JUSTICE GRAY:  No.  We are agreed about that.
   MR RAMPTON:  Oh absolutely.  How many Jews do you think
there
        were in the Ukraine before the Germans got there?
   A.   I do not know, but the total Soviet population of Jews
was
        probably around 5 million, and of course only the
question
        of whether one or two million of those were murdered
is
        really where you get the difference between five and
six
        million victims of the Holocaust.
   Q.   In your mind, I know this is probably a matter for his
        Lordship than for me, but maybe I can ask this.  In
your
        mind does it matter whether it is one million or two
        million?
   MR JUSTICE GRAY:  I think that is for me, is it not?
   MR RAMPTON:  Well, except in so far as it may impinge on
the
        question of system, but I think that has been conceded
so
        I need not pursue that.  Page 59 of part I of
        Dr Longerich, do you have that?
   A.   Yes.
   Q.   Paragraph 16.4.
   A.   Yes.
   Q.   He writes this:  "On 25th October, the year is 41,
Hitler
        made the following remark at his table talk after he
had

.          P-198



        once again made mention of his prophecy of 30th
January
        1939.  'This criminal race has the 2 million dead from
the
        world war on its conscience, now hundreds of thousand.
No
        one can say to me we cannot send them into the morass.
        Who then cares about our people?  It is good if the
terror
        we are exterminating Jewry goes before us", and the
word
        for terror is Schrecken in German.
                  You saw in report No. 80 the words the
rumour
        that the Germans shoot to kill all the Jews has
        advantages.  You notice that that comes about a month
and
        a bit before Hitler's table talk on the 25th.  You
have
        seen the Muller order of 1st August 1941.  Is it
        legitimate in your mind as an historian to draw any
        inference about Hitler's reception and knowledge of
these
        reports from that information?
   A.   We could say that there is a certain resonance.  It is
not
        a direct one, but it is an inference that the
materials
        were getting to him and that the Table Talk might be a
        reflection of having read that.
   Q.   If we are good, cautious historians, we do not need
leap
        to giant conclusions from little inferential sketches
like
        that, do we?
   A.   We would say that this a possible inference.
   Q.   Yes.  Thank you.  The Barbarossa guidelines are on --
if
        you have got Dr Longerich's report, can you turn to
the
        second part of it on page 5 where in paragraph 2 he
sets

.          P-199



        out a part of the guidelines for the conduct of the
troops
        in Russia of 19th May.  That is about a month before
        Barbarossa is actually launched, is it not?
   A.   Yes.
   Q.   He translates it as:  "Bolshevism is the mortal enemy
of
        the National Socialist German people ... (reading to
the
        words) ... Germany's struggle.
        2. This struggle demands ruthless, energetic and
drastic
        measures against the Bolshevik agitators, guerillas
        saboteurs and Jews as well as the complete removal of
all
        active and passive resistance".  The German is at
footnote
        10 at the bottom of the page and I have two questions
        about this.  Professor Longerich translates the German
as
         "Those Jews were a separate or disjunctive category
from
        all the rest of them".  Do you understand?
   A.   Yes.
   Q.   Can you look at the German at the bottom of page 10
and
        tell me whether you think he is right write about
that?
   A.   That is the way I would translate it too.
   MR JUSTICE GRAY:  How else could you do it?
   MR RAMPTON:  I do not know.
   MR JUSTICE GRAY:  I am not sure ----
   MR RAMPTON:  I do not know.
   MR JUSTICE GRAY:  --- is this a bit of an Aunt Sally?  I
mean,
        I am not sure what Mr Irving has made of this.
   MR RAMPTON:  I do not know.  I have not heard what he says

.          P-200



        about this.  I know that he does not ----
   MR JUSTICE GRAY:  Well, it is re-examination.
   MR RAMPTON:  No, this arose in the course of cross-
examination,
        this document.
   MR JUSTICE GRAY:  Yes, I know it did, but this point about
        whether Jews are disjunctive as a category.
   MR RAMPTON:  Yes.  Professor Browning said in his
        cross-examination Jews are a separate category.
   MR JUSTICE GRAY:  Yes.
   MR RAMPTON:  So I wanted to check with him against the
German
        whether he thought that Longerich had translated it
        correctly.
   MR JUSTICE GRAY:  Yes, I see.
   MR RAMPTON:  He did not have it in front of him at the time
        when he said it, I think, actually.
   A.   Yes, I was doing that from memory and now I am looking
at
        the document.
   MR RAMPTON:  The second question is this.  Again, this is
said
        to be a document directed at the Vermacht, not at the
SS
        or anybody else like that or the Gestapo.  Who would
have
        written it?
   A.   These would have been prepared in the General Staff,
        I think.
   Q.   Somebody underneath Jodl?
   A.   Yes, or even further down but in the Armed Forces,
yes.
   Q.   Now, the numbers -- page 38 of your report, please,

.          P-201



        Professor, now -- this is the famous 97,000, I should
say
        "notorious".  We do not need the German for this.  I
am
        going to excuse the motor mechanic who is not good at
        German grammar.
                  Page 38:  "Since December 1941, for example,
        97,000 were processed by three trucks in action,
without
        any defects in the vehicles being encountered".
                  How many trucks did they use during this
period,
        December to June 1942?
   A.   They had two trucks that were there constantly.
Another
        truck came and that is the one that had the accident
that
        blew up.  So most of time they had two trucks running,
        part of the time a third truck.
   Q.   I am going to use some arithmetic, then I will ask you
        further questions, if may?  I do not know whether 1941
was
        a leap year or not, but there are from 1st December
'41 to
        1st June 1942, 172 or 173 days.
   A.   Yes.
   Q.   So let us assume it was not a leap year and it is 172.
If
        you divide 97,000 by 172, that means they are
processing
        564 people a day.  If you divide that by three trucks
--
        I know this is rough stuff and maybe the trucks did
not
        have equal capacities -- that means roughly 188 people
per
        truck per day.  If they did, say, four trips a day,
that
        would be 47 people per trip and that would mean --
when
        I say "a day" I mean on a 24-hour basis?

.          P-202



   A.   Yes.
   Q.   That would mean there would be six hours, roughly
        speaking, five and a bit, between each trip.  Does
that
        seem feasible?
   A.   We know the Saurer truck was much bigger than 40.  We
do
        not know the size ----
   Q.   What do you think its capacity was?
   A.   The Saurer truck was, depending on, you know, women
and
        children or adults, would be between 50 and 80.
   Q.   Right.
   A.   But, in general, you know, I mean, I think as they
show
        that the number per day is not beyond the capacity of
the
        two and three trucks.
   Q.   Right.  So four trips a day, that would actually cover
the
        numbers involved, would it not?
   A.   Yes, we know in Semlin when they made -- they could do
two
        trips a day and that would be all the way across
Belgrade
        to a burial site that was much further away than the
        distance between the burial grounds and the Chelmno
camp
        here.
   Q.   I mean, how long does it take to drive 20 kilometres
in
        one of these trucks?
   A.   We are talking about driving about two or three
kilometres
        from the camp.
   Q.   Two or three?  That is a matter of minutes?
   A.   Yes.  The longer period would be the period to gas.
That

.          P-203



        is why the motors had to run inside the camp before
they
        left or the passengers would not be dead when they
        arrived.
   Q.   From start to finish of the operation, what is your
        estimate of how long it would have taken?
   A.   Well, would you have to let the desired number of
people
        into the basement of the main building where they
would be
        undressed, force them up ramp into the truck, close
the
        truck doors, run the motor for probably 20 minutes,
and
        then drive, given the issue of undressing and the
driving,
        on the generous side, we would say an hour, and then
you
        must empty the van and clean it out and drive back.
   MR IRVING:  My Lord, this is purely speculative.  He is not
an
        expert on gassing operating ----
   MR JUSTICE GRAY:  No, Mr irving, you must understand if you
ask
        almost identical questions in cross-examination,
        Mr Rampton must be entitled to ask the same sort of
        questions in re-examination.
   MR IRVING:  Well, I was objecting really to the question
that
        was asked about how long would it take to gas them
and...
   MR JUSTICE GRAY:  But you went into the arithmetic, Mr
Irving.
        That opens the issue for Mr Rampton.  I am afraid you
have
        to take that as being the rule.
   MR IRVING:  Well, I asked a slightly vaguer question.  He
asked
        a specific expert question.
   MR JUSTICE GRAY:  Again that is legitimate, I am afraid.

.          P-204



   A.   I would say this is not speculation in the sense that
        I have read through virtually all the testimony of the
        Chelmno trial and have seen a number of descriptions
of
        the operations, so to call what I have said
speculation
        would be unfair characterization.
   MR JUSTICE GRAY:  Well, it is speculation in the sense it
is
        reconstruction.
   A.   Correct.
   MR RAMPTON:  Yes, reconstruction.  My real question is this.
        Those sorts of rates, whether it is two or three trucks in
        operation at any one time, whether it is 40 or 50 people
        in the truck at a time, whether there are three or four or
        five trips a day for each truck, does the figure of 97,000
        seem to you to be credible?
   A.   It is entirely credible.

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