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Shofar FTP Archive File: people/i/irving.david/libel.suit//transcripts//day029.16

Archive/File: people/i/irving.david/libel.suit/transcripts/day029.16
Last-Modified: 2000/07/25

   Q.   --- his Lordship asked you and I repeat:  "Is it your case
        that there is not any record, whether tapes, notes or
        anything, of Gita Sereny's interview with Christa
        Schroeder and she is, in fact, making the whole thing up?"
        Answer by Mr Irving:  "Yes".  A false and a knowingly
        false answer, is it not, Mr Irving?
   A.   To this I have to say two things.  The first thing, not in
        any order of priority, is that, as is evident from the
        correspondence which I just read out, there was no

.          P-140

        interview.  She did not get to see Mrs Schroeder.
   Q.   What, you mean you cannot interview somebody by telephone?
   A.   Not in my book.  Secondly, I have to confess that even
        after receiving that letter from the opposing solicitors
        in the other action, I did not look into the
        correspondence and discovery files for reasons which are
        probably evident for you.  To do so would have taken me
        probably 20 or 30 minutes to find the file and look up the
        letter, and at present I am under very great time pressure.
   MR JUSTICE GRAY:  I am sorry, I am not following that at all.
        On 10th February 2000, you were sent a letter which
        specifically directed you to the document.  It would not
        have taken you a second to find it.
   A.   My Lord, my files are not in any very great shape at
        present.  They are in great shape for this action, but
        they are not in great shape for an action which has not
        yet been set down even.  And to have looked and found the
        Sereny discovery and to have found this particular
        document -- all I can say is that I am stating here, I am
        asserting here, that I did not look up this document and,
        even having looked it up, it has not altered my position
        because I knew perfectly well ----
   Q.   But I am sorry, Mr Irving, on 4th January 2000 you
        specifically requested documents relating to what Frau
        Schroeder had said.

.          P-141

   A.   Very well.  In preparation of this case, I have gone
        through our entire discovery for the action against
        Penguin Books which is the current case, which is what
        this number is on the top right-hand corner of the Sunday
        Times letter, 545.  When I took this letter out, my eye
        lit on the fact on paragraph 2 that there were quite
        clearly interesting items that Sereny had not disclosed to
        me, as she should have.  I wrote a routine letter to the
        solicitors for the opponents in that action, saying, "Oh,
        by the way, I note you have not given discovery of those
        documents, please now do so", which is a perfectly
        reasonable act.  They then wrote back that letter.  But
        I already knew from Christa Schroeder that she never
        interviewed Miss Sereny for personal reasons.
   MR RAMPTON:  But she did not make it up, did she, Mr Irving?
   A.   She did not make what up?  The statement?
   Q.   The assertion that Hitler probably knew what was going on
        because he had these four hours, frequently had these four
        hours conversations closeted with his friend, Heinrich Himmler?
   A.   Now, that is not the question you asked me, is it, or the
        question which his Lordship asked me?
   Q.   Yes.
   MR JUSTICE GRAY:  Have a look at it again if you want to.
   MR RAMPTON:  "Did she make it up?"  Answer; "Yes".
   A.   "Is it your case that there is not any record of Gita

.          P-142

        Sereny's interview with Christa Schroder?"  That was the
        first question to which the answer was quite correctly,
         "Yes", "And that she is, in fact, making the whole thing
        up?" in other words, the interview, answer:  "Yes".  And
        I take issue with the way you put her response.  She did
        not say she considered it probable that Hitler knew.  She
        said she considered it improbable that Hitler did not know
        or that he knew nothing, rather, was the exact language.
        That is not quite the same as you have said.  I do not
        want to split hairs, but let us stick to the actual language.
   Q.   Would you like to withdraw the allegation of little
        invention you made against Miss Sereny in this court not
        very long ago?
   A.   No, I would not.  Miss Sereny has stated that she
        conducted interviews with a number of Hitler's staff, who
        disavowed what I had reported of my very lengthy
        interviews with the same people.  It is a matter of
        professional pride that I establish that what I wrote was
        true on the basis of proper interviews, not conducted over
        a snatched telephone conversation.  Proper interviews.
        You have of course seen the very complete and proper
        records I took of those interviews, and I was perfectly
        satisfied from my knowledge of these people and what they
        told me that they had not granted her interview.
        Certainly Krista Schroeder had not and, when it was

.          P-143

        suggested in this court that she had, I knew perfectly
        well that she had not, and it now turns out I was right.
   Q.   The last item on my agenda for today, Mr Irving, is the
        Goebbels diaries, the entry for 13th December 1941, what
        Adolf Hitler said to the Gauleiters and others on 12th
        December 1941.
   A.   And my knowledge of what was in them, presumably.
   Q.   Absolutely.  Precisely that.  My Lord, this is on page 337
        and 338 of Professor Evans' report.  I invite reference to
        that because the English is there.
   MR JUSTICE GRAY:  I am sorry to be tedious about this but where
        should I put the little clip that has just been handed in?
   MS ROGERS:  J2, which is now in an overspill marked J2 to 3.
   MR JUSTICE GRAY:  Rather than being an overspill marked J2 to
        3, it is actually going to be J3.
   MS ROGERS:  I am very happy with that, and I think we are up to
        17 or 18.
   MR JUSTICE GRAY:  I have run out of tabs.
   MR RAMPTON:  May Mr Irving and his Lordship have the Goebbels
        clip and Mr Irving should also have a copy of Professor
        Evans' report.
   A.   In that case I had better clear a large space on my desk.
   MR RAMPTON:  Please turn to page 337.  On page 337 in paragraph
        8 Professor Evans writes this: "On 12th December 1941,
        less than one month after the publication of the article
        in Das Reich, Hitler spoke about the Jews in front of the

.          P-144

        Gauleiters (noted down by Goebbels):  'With reference to
        the Jewish question", Bezuglich der Judenfrage, "the
        Fuhrer is determined to clear the decks".  The actual
        German is reinen Tisch zu machen, which might be better
        translated as make a clean sweep.  "He prophesied to the
        Jews that if they should once more bring about a world
        war, they would experience their own annihilation in doing
        so. That was no mere talk.  The world war is there, the
        annihilation of Jewry must be the necessary consequence.
        The question is to be considered without any
        sentimentality.  We are not there to have sympathy with
        the Jews, only sympathy with our German people".
                  In paragraph 9 on page 338, writes Professor
        Evans:  "Here Hitler mirrored directly Goebbels's
        statements from the article in Das Reich", which I think
        was published in November of that year, 16th I think?
   A.   November 16, yes.
   Q.   "While Irving does cite this speech of 12th December 1941
        by Hitler in Goebbels, he is careful to omit any mention
        at all of this key passage because it shows that Hitler
        was as determined to act brutally against the Jews as
        Goebbels was".
                  Your account of the omission of that may be
        thought crucially important passage from the Goebbels
        diaries from your book on Goebbels, or indeed from
        anything else that you have written so far as I know, is

.          P-145

        I think, if I may summarize this and you will correct me
        if am wrong, that you went to Moscow to look at the
        Goebbels diaries with a specific commission from the
        Sunday Times.
   A.   A shopping list, yes.
   Q.   Which consisted of, or which included, the instruction,
        direction or request to look for material on Pearl
        Harbour?  Is that right?
   A.   Yes.
   Q.   Have I got it right so far?
   A.   Yes.
   Q.   When you got there, you found the glass plates on which
        the diaries were recorded so voluminous or so crowded that
        you stopped four lines into the second of the glass plates
        for this date.  Do you remember that?  Would you like to
        turn to tab 2, which I think are some Irving documents,
        are they not?
   A.   I am sorry?
   Q.   The little clip, the file you have been given.
   A.   Yes, tab 2.  The notes taken by my assistant on our
        progress as we waded through the glass plates.
   Q.   Yes.  The first page in that is headed "box 1", is it not?
   A.   Yes.
   Q.   Whether that means the big filing box or the little box of
        glass plates, I cannot say.
   Q.   I have absolutely no idea.  I am afraid I was not there.

.          P-146

   A.   It is a big filing box.  I can see that because on box two
        she puts in the Russian designation.
   Q.   Could you turn to page 9 please?  It is the original 09 at the bottom.
   A.   Yes.
   Q.   Under No. 38 at the top of the page we see the list of
        plates that you read, or part read, for December 1941, do we not?
   A.   The plates that we found, yes.
   Q.   Whatever.  Lesen is German for read, is it not?
   A.   Read or read, oddly enough.
   Q.   Read.  It must be read.  10th December, read, 11th to 12th
        December, read, Pearl Harbour.
   A.   Read with gelesen.
   Q.   All right.  13th December, lesen, whatever it means.
   A.   Yes.
   Q.   13/14 December, 41, bis vier zeile gelesen?
   A.   Read to the fourth line yes.
   Q.   Yes, to the fourth line.  Now please turn over some
        pages.  There is a lot in here that I do not need.
   A.   I am astonished that she was so meticulous in what she
        wrote down.
   Q.   I am about to suggest to you that she actually might have
        made a significant mistake.
   A.   Ah.
   Q.   At tab 5 of this little file you will see a document in

.          P-147

        Russian dated 23rd February of this year.  If you want to
        turn over, we have attempted the translation.
   A.   I was just about to get my O-level Russian to work.
   Q.   Forget your O-level Russian unless you are going to
        grumble about the translation.  It comes from the Federal
        Archives Services of Russia and Moscow and it is written
        to my solicitors Mishcon de Reya in London.  It says,
        "Dear Sirs, further to your letter we are sending to you
        photocopies Goebbels diary pages for 13th December 1941.
        The photocopies are taken from two separate glass
        plates".  So far you are not falling out with the
        Russians, I think, are you, Mr Irving?
   A.   I am happy to accept this, yes.
   Q.   The second plate starts from page 18.
   A.   I see what they mean.
   Q.   We turn over the page to tab 6 of this little file and we
        find what it is that the Russians have sent us.
   A.   Yes.
   Q.   If you turn through the pages, the numbers are at the
        top.  You find that the first plate ends.  Well, let us
        look at the first page.  The first page has on it 13th
        December 1941.
   A.   Yes.
   Q.   That does not mean that that plate starts on the 13th
        December 1941, does it?
   A.   No, it does not.

.          P-148

   Q.   Right.  So, when the Russians say that plate 1 ends at
        page 17 of this 13th December entry, which you can see,
        they are probably right, are they not?
   A.   Yes.
   Q.   Now I will direct you to where on plate 2, rather far past
        line 4 I fear, your clip that you gave us as representing
        what you transcribed begins.  Page 26, please.  If you
        want to compare it with what you gave us as being your --
        we had better do it in an orderly way.  Your transcription
        is at tab 4, and it begins "Mittags habe ich eine
        Unterredung mit dem Fuhrer".
   A.   Yes.
   Q.   So we can see that that passage starts -- it is the first
        part of your transcription for the 13th and it starts on
        page 26, I think, of plate 2, I ask you to note, of the
        series for this date.  I can tell you, because I have
        marked it all the way through, you run out in the sections
        you say you transcribed on page 38.  Is that right?  Yes,
        it is, I think.  You end with the passage "Das wir im
        Osten nicht weitergekommen sind, als wir jetzt stehen",
        and we find that on page 38 of plate 2, do we not?
   A.   That is when I run out.
   Q.   You end "nach Schutzproblem aber".
   A.   Yes.
   MR JUSTICE GRAY:  Tab 4 is what?  Transcribed microfiche
        material done by Mr Irving in Moscow?

.          P-149

   MR RAMPTON:  Yes.  So point 1, Mr Irving, the story that all
        but four lines of your transcription came from plate 1 is
        just rubbish, is it not?
   A.   I have just done a little bit of a calculation.

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