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Shofar FTP Archive File: people/i/irving.david/libel.suit//transcripts//day029.11

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Last-Modified: 2000/07/25

   Q.   That fine.
   A.   Everything after footnote 28, if you see what I mean?  Not
        just the last statement.
   Q.   I follow that, but it includes the figures given in the
        last sentence, does it not?
   A.   Yes.
   Q.   "Interpole figures, in Deutsche Nachrichten-Buro
        (hereafter DNB) July 20th 1935; and see Kurt Daluege,
         'Judenfrage als Grundsatz' in Angriff, August 3rd 1935",
        and then there are some general references about the
        general demimonde.  Tell me first, Mr Irving, who is, who
        was, I should say, Kurt Daluege?
   A.   He was the head of the Ordungspolizei which is the order
        police in Germany.
   Q.   Yes, Mr Irving.  Tell us a wee bit more about him, would you?
   A.   Oh, he was a mass murderer later on.  He was in charge of
        all the killing on the Eastern Front.
   Q.   He was, what shall I say, an enthusiastic member of the
        Nazi Party?
   A.   Yes.  And he met his just desserts on the Czech gallows.
   Q.   So one should be rather cautious, perhaps, about what one

.          P-94

        is told by Mr Daluege, do you not think?
   A.   Yes, properly cautious.
   Q.   Properly cautious.  You will see that I have used his
        files which are in the German Federal archives.  That is
        what the reference is that you left out.
   Q.   I am going to show you what are the references on which
        you have relied.
   A.   No?  Yes, this one.
   Q.   Yes.  Now, the first of these documents, Mr Irving, is a
        written version, probably a draft, in the sense that he is
        going to speak as they say nowadays to it, I rather say
        from it, he is going to speak from, this is Daluege, on
        20th July 1935 at a press conference, is it not?
   A.   Yes.  I have not seen this typed document.  I relied on
        the Gothic typed face one.
   Q.   Look at the Gothic one if you prefer because it is
        identical.  The sixth paragraph of the Gothic is identical
        to the sixth paragraph ----
   A.   Yes.
   Q.   --- on our pages 16 to 17 of the typescript.  Since the
        typescript is easier to read, can we look at the bottom of
        page 16 of this little clip?  You will have to forgive me
        if my translation is a wee bit rocky.  We will get it
        proper translated, my Lord, in due course.  Does it say
        this, roughly speaking:  "Even though we have succeeded in
        decreasing the number of cases of fraud in the Reichs

.          P-95

        capital to 18,000 in 1934 compared with 31,000 in 1933,
        the damage caused still amounts to over 112.5 million
        Reichsmarks", am I doing all right so far?
   A.   Yes.
   Q.   And here we come to the conclusion after further
        investigation that "a considerable or significant part, if
        not the largest, of these fraudulent manipulations are
        still committed by Jews."
   A.   Yes.
   Q.   Right, where did you get your figure of no fewer than
        31,000 cases of fraud committed by Jews?
   A.   I am just now looking for the original quotation.  What
        page was the original quotation?  43?
   Q.   It is 47.  You have the year wrong, but I am not going to
        criticise you for that.  You put 1932 instead of 1933, but
        leave that on one side.
   A.   Have you checked the two books that I give as sources there?
   Q.   No.  I have not checked the two books, Mr Irving.  This is
        your primary source.  The books have been checked, yes,
        and so I am not on false ground.
   A.   Yes -- well, I will give you a conditional response which
        probably will not satisfy you, and say that if the books
        which are also given in the footnote, there are four
        sources given in the footnote, do not support the year
        which is different from the year contained in the document

.          P-96

        you gave me, or do not support the figure of 31,000, then,
        clearly, the same kind of error has occurred here as
        happened with the 1.20 a.m. telegram that in the course of
        writing six separate drafts one after the other this kind
        of error goes ----
   Q.   You have ----
   A.   --- but it is a conditional response.
   Q.   You have effectively doubled, or more than doubled, the
        number of fraud cases attributed by this rabid Nazi
        Daluege to the Jews in Berlin in that year, have you not?
        At the very most, even if the Jews are 50 per cent, it is
        only 15,500 cases attributable, according to Daluege, to
        Jewish perpetrators?
   A.   Yes.  If you are right, then that is correct, but, I
        mean, I have to say that is a conditional answer not
        seeing all the sources.
   Q.   Right.
   A.   And I would not be able to reconstruct that now because
        I no longer have access to the sources that I had at the
        time for the reasons you know.
   Q.   Why do you say that these are Interpol statistics in your
   A.   Presumably from one of the sources.
   Q.   No.  Interpol was not actually established as Interpol
        until after the war.
   A.   I am very sorry, but, of course, the Haus an Wannsee, the

.          P-97

        famous Wannsee House, where the Wannsee conference took
        place, was the headquarters of Interpol.  Interpol was
        actually founded by Reinhardt Heydrich.
   Q.   Yes, but, no, it was not called Interpol, was it?
   A.   It was presumably written out in full.
   Q.   Even assuming (which I do not) that this was an innocent
        mistake on your part to double the number of offences
        attributable to Jews, do you think it right when your
        source is this man Daluege uncritically simply to take his
        figure as being right?  You state it as a fact, you see.
        In probability, he had already doubled the figures at
        least, do you not think?
   A.   You are faced with a problem, of course, when you are
        writing a history of the 1930s, you look at as
        many sources as you can of what sources are available.
        These are the sources from the German Federal archives
        which contain all Daluege's papers.  It is very easy to
        say, "Well, why do you take those figures because I do not
        like those figures, why do you not take these figures?"
        You have to take some kind of figures from somewhere, and
        if you are writing the Battle of Britain and you are going
        for a long time to believe Winston Churchill's figures of
        how many Nazi bombers were shot down, and we no know that
        those are wrong.  But there we have the benefit of
        complete access to records and you can correct the

.          P-98

   Q.   May I suggest, Mr Irving, that if a reputable historian
        were writing about this, he would say, "According to the
        Nazi propagandist, Kurt Daluege, whose figures are very
        probably not reliable" ----
   A.   Yes.
   Q.   --- perhaps as many as 15,500 frauds were attributable to
        Jews", but to assert that that is what Goebbels would find
        in 1932 is just the most appalling distortion of the
        truth, is it not?
   A.   I do not agree.  I have made it quite plain what the
        source of this evidence is.  You found it, your
        researchers found it.  Everybody knows who Kurt Daluege
        was.  He was not a Nazi propagandist.  He was the head of
        the German police system.  He was in a position to know.
        He is giving facts to a learned audience.  They would be,
        no doubt, in a position to check and expose these facts if
        they were wrong.  I certainly would not have said it was
        an Interpol function if I did not have the evidence for
        it, and I am not going to waste the court's time looking
        in these pages of Gothic script for the actual evidence
        for it, why would I have invented that?  And, of course,
        if you look at the rest of the page ----
   Q.   I can think of a simple answer, Mr Irving ----
   A.   If you had looked at the rest of the page that you did not
        read out, I have relied on the figures from the German
        Federal Statistical Office on the percentages and so on.

.          P-99

        I built up a very careful picture from all the regular
        sources and, admittedly, we are -- I beg your pardon.
   Q.   We are going to look at some of those in a moment, Mr Irving?
   A.   And, admittedly, in this particular matter we have to rely
        on a dodgy source which is what you are trying to suggest.
   Q.   We do not have to, Mr Irving.
   A.   But then, of course, the Goebbels diaries are dodgy
        sources too.  They are diaries written about the arch Nazi
        liar, and you have to pick and choose and that is the
        problem you have when you are writing history about the
        Nazis and it is a problem when you write about history
        about anything.
   Q.   Oh, Mr Irving.  Where in that Daluege, which is your
        primary source, that Daluege document, do you have find
        any reference to insurance swindles?
   A.   What basis do you have for saying it is the primary source
        when it is a source of four.
   Q.   It is the first source you cite?
   A.   The reason for lumping several sources under one number is
        because otherwise the book is going to look like a rash of
        measles, every single word is going to have a note number
        attached to it.  So it is the standard practice that you
        will lump three or four sources relating to the previous
        two or three statements, even if they are gathered up in
        one sentence, into one note number.  This does not mean to

.          P-100

        say that is the primary source for that statement.
   Q.   Can we agree this far ----
   A.   Have you ever written book?  Oh, we had this out before,
        did we not?
   Q.   Yes, we have had this before and, yes, I have.  It is not
        a very good book, but I have written a book, yes.
   A.   It is quite a difficult task to satisfy all the parties,
        the publishers, the readers and everybody else.
   Q.   I do not agree with you, Mr Irving.  I do not accept that
        for one moment.  This is a case of deliberate distortion
        by you so as to inflate the number of wicked, dishonest
        Jews in Berlin in 1932.  That is my case and you may as
        well know it, because what we have got is you double
        Daluege's numbers, at least, you have relied on an
        unreliable source, you have attributed his figures to
        Interpol and you have spoken about insurance swindles
        which are not mentioned in Daluege's document.
   A.   But I am sorry to sound incorrigible.  There are four
        sources listed under that footnote, and you have waved one
        source at the court and said, "It is not in this source of
        the four".  If you were to do your job properly, you would
        produce the other three sources and say, "It is not in
        these three either".
   Q.   All the figures, I am told, come from Daluege.  How about
   A.   Who is that or what is that?

.          P-101

   Q.   That is a note passed to me by people who know better than
        I and , apparently, better than you, Mr Irving?
   A.   I mean, with the utmost respect for your researchers, if
        they had done their job properly, they would have had
        those books that I cited in court as well, and they would
        possibly even have given me fair warning and said,
         "Mr Irving, we are going to challenge you on these
        figures; do you want to spend the lunch hour or this
        evening just providing the evidence for them?"
   MR JUSTICE GRAY:  Well, it was in Professor Evans' report.
   MR RAMPTON:  It is all in Professor Evans' report, Mr Irving.
        This document which you now have at the back of that
        little clip is one of Professor Evans' documents.
   A.   I have only got the Daluege report here.
   Q.   What?
   A.   I have only got the Daluege report.
   Q.   No, it is folded at the back, I hope.  It is an A3 size
   A.   Oh, this one?
   Q.   Yes.
   A.   Right.
   Q.   Now look at the front of it, will you, please, Mr Irving?
        This is what you might call a slightly more reliable
        source, you may think, because it is the official Berlin,
        it is the official German statistics?
   A.   Is this from my discovery or from elsewhere?

.          P-102

   Q.   What?
   A.   Is this from my discovery or from ----
   Q.   No, this is Professor Evans'.
   A.   I mean, it is important to know whether this is from my
        discovery or from your own research.
   Q.   Why?  It is a public document, Mr Irving.
   A.   All right, yes.
   Q.   You are the great archive fiend.
   A.   There is no need for that tone of indignation.  I am just
        asking a simple question.
   Q.   Well, Mr Irving, really.  Is this a forgery then by
        Professor Irving (sic) and his cronies?
   A.   No, I am sure you are familiar with the point I am trying
        to establish.

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