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   MR IRVING:  Is there any reason why writing private letters to
        their SS comrades in a letter where they use very robust
        language, does he not -- he says, who cares what happens

.          P-37

        to the Vienna or Pressberg, which I think is now called
        Bratislava, Jews?  It is a robust language, is it not?
   A.   It is the matter of camouflage.  These officers in the
        government of the Generalegouvernement tried of course to
        keep this operation as a secret.  What they would admit is
        they would tell a story about shipping people to the to
        the White Sea and to the marshes, but they would not say
        actually, we are going to transport them to Minsk, I think
        in this case, and they are killed there.  I think the
        interpretation of Aly in this book that it was a
        camouflage letter, I think this is the most likely
        interpretation, but also it is possible that at this
        stage, because he is referring to transports from the
        Reich to Minsk, and the systematic killings of the persons
        transported to Minsk from the Reichs, started in May 1941,
        it is possible, it is not very likely but it is possible,
        that this information had not filtered through to him.  So
        camouflage is one explanation, but also it is possible
        that he did not at this stage know about the systematic
        killings of people transported to Minsk at this stage.  It
        is a letter to SS comrades, not to one.  It is not a
        confidential letter to one of his comrades.  It is to
        comrades, so it was shown to 20 people, 30 people.  There
        were strict rules as far as secrecy was concerned.
   MR JUSTICE GRAY:  Can you explain what significance you attach,
        if any, to Furl having written that the Jews from

.          P-38

        Kurfurstendam and Vienna and Pressberg will not survive?
        What is the implication?
   A.   I think this is the same implication which we heard on
        Thursday when we read through the Wannsee protocol.  This
        is the idea of natural dissemination by hard labour so
        they will not survive.  They will not survive the work
        labour programme they were getting involved to.  If you
        read the last line, "but not without having first built a
        few roads".  So this is, I think, the same idea which is
        expressed clearly by Heydrich in the Wannsee conference minutes.
   MR IRVING:  We have a logical problem here, which is best
        solved by the question do you believe that Furl, who wrote
        the letter, knew the truth, that he knew what was going
        on, he was writing a camouflage letter, or that he did not
        know what was going on?
   A.   No.  I think the camouflage letter, he is referring to the
        official story.  The official story is the Jews are sent
        from Central Europe to the East, and they will be used in
        slave labour programmes, many of them will die, but some
        of them will of course survive.  This is the official line
        and he is using this official version of the story.  But
        at the same time the systematic killing of Jews deported
        from Germany, from central Europe to the East, had already
        started.  So I think the idea Gotz Aly said here that this
        is a camouflage, still camouflage, is, I think, very

.          P-39

   Q.   It is one plausible explanation, is it not?
   A.   I think it is a very good interpretation.
   Q.   It is one possible interpretation, but the other
        interpretation is that Furl is writing to the best of his
        knowledge what happens in a very brutal letter to his SS pals?
   A.   As I said, it is possible that this information that the
        Jews arriving from the Reich in Minsk were systematically
        killed, it is possible at June that this information had
        not filtered through to the office in Krakow.
   Q.   You would have noticed that there are two echoes of
        previous documents here, are there not?  There is the echo
        of having first built a few roads.  Does that remind you
        of the Wannsee conference?
   A.   Yes.
   Q.   Is that the language that was used at the Wannsee
        conference, that they are going to be put to work building roads?
   A.   Yes, that is used there.
   Q.   And this idea of sending into the marsh lands, does that
        remind you of the October 25th 1941 table talk, where
        Hitler says, "who says we cannot send them to the marshes?"
   A.   Yes, of course, but I cannot fully ignore what happened in
        Minsk at the same time in other places.

.          P-40

   Q.   Yes, but we are looking here at chain of command and at
        system and, if you are looking at parallels with the late
        1941 killings, which turn out to have been carried out
        without authority, then this would explain how the people
        who are on the route, shall we say, on the track, the
        train loads heading East, would think that one thing is
        happening, whereas the people at the other end who
        actually receive them with anything but open arms, know
        that something quite ugly has happened to them.
   A.   Yes but this is not an official letter.  This is a private
        letter from Herr Furl to his SS comrades, so it is nothing
        to do with the chain of command.
   MR IRVING:  Does your Lordship have a question on that letter?
   MR JUSTICE GRAY:  No.  Thank you very much.
   MR IRVING:  I am anxious, my Lord, from the timetable point of
        view to leave sufficient time before lunch for
        re-examination, so that the doctor can leave at lunch time.
   MR JUSTICE GRAY:  Do not worry too much about that.
   MR RAMPTON:  I think it unlikely that he will be able to
        anyway, my Lord.
   MR JUSTICE GRAY:  Let us wait and see.  Do not rush it because
        the timetable may have slipped a little.
   MR IRVING:  Dr Longerich, I am now going to go to a memorandum
        written by a man called Horst Arneirt.  Now, when I asked
        you about this on Thursday, it seemed unfamiliar to you.

.          P-41

        Have you had time to review your recollection about it?
   A.   I cannot recall the document you are referring to at the moment.
   Q.   You cannot recall it?
   MR JUSTICE GRAY:  It was not available on Thursday.  That is
        why we passed over it.  Is that not right, Mr Irving?
   MR IRVING:  You did edit a book called (German title)?
   A.   Yes.
   Q.   This document is printed in full at the end of this book,
        pages 240 onwards, and that should be one of the clips
        that I gave to ----
   A.   It has not arrived yet.
   MR JUSTICE GRAY:  I think it was faxed and emailed to the
        Defendants over the weekend.  Is that right?
   MR IRVING:  It was faxed to me from Australia this morning.
   MR JUSTICE GRAY:  So it is not one of the ones that went over
        the weekend?
   MR IRVING:  No.  That was just the Wolff translation.
        Dr Longerich, will you accept that you published the
        memorandum of Arniert as document No. 94 in your book?
   A.   I do not have it in front of me.  Yes, I published the
   Q.   This is a conference relating to the deportation of the
        Jews from France?
   MR RAMPTON:  No, I am sorry, this cannot proceed.  I do not
        want to be horrible, but it cannot proceed without our

.          P-42

        having the document.
   MR JUSTICE GRAY:  Have you not got it?
   MR RAMPTON:  No.  I have a piece of Gotz Aly.  I have something
        from a book by Serge Klasfeld and that is it.
   MR JUSTICE GRAY:  This is headed "Die Endlosung der
        Judenfrager" on the front.
   MR RAMPTON:  I have got it.  Sorry, my fault.
   MR IRVING:  There are two versions of it, my Lord.  One is in a
        book published by Serge Klasfeld, who is a well-known
        French lawyer, but this morning I received a copy of the
        book which is actually published by the witness, edited by
        the witness, in which the same document appears as
        an appendix.  This is a report by a man called Horst
        Arniert dated September 1st, relating to a meeting held on
        28th August, at the SS headquarters, the
        Reichssicherheitshauptamt, with Adolf Eichmann in the
        chair, and he informs the participants that the current
        evacuation programme of the Jews from France is to be
        completed by the end of that quarter.  I am going to look
        just at some of those paragraphs.  You have now a number
        of paragraphs in the document A, B, C, D and E.  A is the
        reinforcement of the deporting transports in October.  B
        is loading difficulties due to the longer hours of
        darkness in October.  C is provision of blankets, shoes
        and eating utensils.  D is the nationality problem.  E is
        the purchase of barracks.  Now I am going to look at C and

.          P-43

        E, in particular, Dr Longerich, and ask you to answer some
        questions on those paragraphs.  First of all, this is a
        genuine document, is it not?
   A.   Yes.
   Q.   Paragraph C, I am going to translate it and you can
        correct me if I am wrong:  "Giving with them blankets,
        shoes and eating utensils for the transport participants.
        The commandant of the internment camp at Auschwitz has
        demanded that the necessary blankets, working shoes and
        eating utensils are without fail to be put into the
        transport, in with the transports.  In so far as this has
        not been done, they are to be sent on to the camp
        afterwards immediately"?
   A.   Yes.
   Q.   Now, if these Jews were being sent to Auschwitz to be
        liquidated, they would not need blankets, shoes and eating
        utensils, would they, and there would be no great urgency
        on the part of the commandant of Auschwitz to have this
        stuff sent on after the train had arrived.
   A.   I think we went through this before.  It is quite obvious
        that not all the Jews in Auschwitz were killed on the
        spot.  From late summer 1942 onwards, the trains stopped
        in a camp called Kausal, it is near Auschwitz, and the
        people fit for work were actually unloaded and spent
        several months in slave labour camps in Silesia.  Some of
        them actually survived.  So I would guess that the

.          P-44

        reference here to shoes and other things refers to the
        people they wanted to keep alive for a couple of months.
   Q.   Paragraph E, the purchase of barracks:  "SS Major Eichmann
        has requested that the purchase of the barracks that have
        been ordered by the commander of the security police in
        the Hague should be immediately put in hand.  The camp is
        going to be erected in Russia.  The departure transport of
        the barracks can be arranged in such a manner that each
        transport train can take three to five barracks with
        them."  What does that tell you about the final
        destination of where these train loads of Jews were going
        to go?
   A.   I have no indication actually that these barrack were
        actually, you know, in the end were loaded on these
        trains.  It is only said that -- Eichmann expresses his
        intention that this should be done.  I have no idea
        whether they did this or not and I have no idea what the
        purpose of this barrack was.  It is referring here to the
        commander of the security police in Den Haag, so this
        relates to the Netherlands, and at the moment I cannot say
        either whether this happened or what the purpose of this
        barracks was.
   MR JUSTICE GRAY:  This is talking about Dutch Jews, not French Jews?
   A.   It refers here under E [German- document not provided].
        So this refers to the Dutch Jews only.  He had no

.          P-45

        responsibility for the Jews in France.  So it is obviously
         -- maybe they had a plan to, I do not know, whether they
        had a plan to build barracks somewhere for Dutch use.  I
        have at the moment no idea.
   MR JUSTICE GRAY:  Like they did for the French Jews?
   A.   Definitely here it is nothing to do with the French Jews.
   MR IRVING:  Dr Longerich, you say you have no idea but in your
        book you reference another document which is in a note by
        a man call Roethke, R-O-E-T-H-K-T, dated August 26th 1942,
        instructing him to raise a list of points at a meeting on
        28th August 1942, which is the one we have been looking
        at.  Here it says, point 8: "When can we count on the
        construction of the barracks of the Dusseldorf camp?  Has
        construction already been commenced?  Where exactly will
        the camp be situated?"  There is a marginal note:
        "Attended to".
   A.   I do not have the document in front of me, I have to say.
   Q.   Yes, but that is a document referenced in the book
        which  ----
   A.   Yes, I should not comment on the document ----
   Q.   Do you remember the Roethkt document?
   A.   Pardon?
   Q.   Do you remember the Roethkt document, the memorandum?
   A.   Well, the book was published in '89, so I cannot recall
        every document in the book, and it should not be a big
        problem to have it in front of me and to read it simply.

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