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Last-Modified: 2000/07/20

   Q.   Do you sometimes in your books make comparisons between
        the number of deaths caused by Allied bombing raids with
        the number of deaths caused by Nazi bombing raids?
   A.   I think the word "comparison" would be wrong, my Lord, but
        I have done it in a way that possibly a journalist would,
        I have mentioned the facts in successive sentences.
                  In my very first book "The Destruction of
        Dresden", if your Lordship were to turn to the very last
        page of that book, which I have with me, and it is in the
        bundles I distributed this morning, of "The Destruction of
        Dresden", the very last page says:  "That this was
        undoubtedly a terrible crime.  It was a crime committed
        against a city in Germany, a country which had carried out
        the most appalling massacres against helpless citizens."
        I forget the actual wording I used, but it is in that
        book.  There was that kind of comparison.  I do not
        consider it to be offensive to say too colloquially
"you
        did it too" and when airmen say, as I asked them at
the
        time, I would ask the Bomber Command airmen who
pressed
        the button and dropped the bombs, I would say to them
what
        were your feelings?  They said they had no feeling
because
        they could not see their victims.  I consider this is
not

.                                      P-183



        an adequate justification but I do not think this goes
to
        the issues in this case.
   Q.   Yes.  The next section is the allegation that is made
by
        the Defendants that you consort and associate with
some
        pretty unsavoury characters in North America and
        elsewhere; that is to say very right-wing extremists?
   A.   My Lord, can I deal with this in summary in general
        terms?
   Q.   Yes.
   A.   At this stage, undoubtedly if they want to go through
it
        piece by piece and name by name and phrase by phrase.
   MR RAMPTON:  My Lord, I am sorry to intervene, particularly
to
        correct a judge, but your Lordship might have missed a
        couple of sections, I think.
   MR JUSTICE GRAY:  Have I?
   MR RAMPTON:  After Dresden comes -- it may be because the
way
        the file is arranged.
   MR JUSTICE GRAY:  There is Hitler's Adjutants.
   MR RAMPTON:  Yes, Hitler's Adjutants.
   MR JUSTICE GRAY:   That does not belong in Dresden.
   MR RAMPTON:   No.
   MR JUSTICE GRAY:   That is rather why I skipped it.
   MR RAMPTON:  Another route to the exoneration.  But your
        Lordship went straight from Dresden to right wing
        extremism.
   MR JUSTICE GRAY:  Yes.

.                                      P-184



   MR RAMPTON:   Along the way jumping over Hitler's
Adjutants.
   MR JUSTICE GRAY:   And Nazi anti-Semitism.
   MR RAMPTON:   Yes.
   MR JUSTICE GRAY:   You are quite right.
   MR RAMPTON:  Hitler Adjutants is quite an important
section,
        certainly.
   MR JUSTICE GRAY:  Thank you for that, Mr Rampton.  Can
        I therefore invite you to comment on the -- you will
find
        this as page 7.
   A.   Page 7.
   Q.   The allegation that you really ignored the evidence
when
        you claim --
   A.   Shall we go through 1 to 6 in detail, my Lord, now?
   Q.   -- yes, if you would like to because Mr Rampton is
quite
        right --
   A.   The allegation is that I ignored the most basic
cautions
        in interviewing members of Hitler's staff.  Well,
jealousy
        place a part in this.  Adolf Hitler's personal staff
at
        the end of World War II, so far as they survived, were
        very bruised people.  He had four female secretaries,
they
        were all locked up for periods of several years by the
        Allies. I remember my friend, Ralph Hoffmann, who
        I invited to lunch just to see what it would be like
to
        having a liberal playwright lunching with Hitler's
        secretary.  When he heard that the Americans had
locked
        her up for two years he said but why did they put you
in

.                                      P-185



        prison?  She said I typed for the Fuhrer.  I typed for
the
        Fuhrer.  He said, but millions carried guns for the
        Fuhrer.  They were very bruised people.  They did not
want
        to speak to their own historians and they certainly
did
        not want to speak to the former enemy.  It took me
many
        years to win their confidence by methods that might be
        found odious.  I would become very friendly.  In the
case
        Christa Schroeder particularly, I would just invite
her
        out to lunch and say Frau Schroeder we will not talk
about
        the War, knowing very well that she would want
eventually
        to mention something that happened.  But at the moment
        I took out a pen she would clam up.  She would not say
        anything, so I had to write a note afterwards. It was
this
        kind of situation.  Very delicate, drawing them out
and
        then eventually after five or ten years Christa
Schroeder
        revealed that she had written private letters to a
woman
        friend throughout her time with Hitler and she got all
        those letters back. She produced the letters and gave
them
        to me.
                  The allegation is -- I think allegation No.
2
        that I would use documents like that in injudiciously.
   Q.   -- just one more question on the first criticism; you
say
        that you accept that you did not approach the matter
in
        what you regard as the ideal way, but you say there
was no
        all alternative because that was the only way of
getting
        these people to talk?

.                                      P-186



   A.   A historian is accustomed to going to archives or my
        reproof to the historians, particularly of the
Defendants'
        historians, is that they sit if their book lined caves
        taking books out of shelves, taking a sentence and
working
        it into their own fabric and at the end of the day not
        cricking anything to the sum total of human knowledge.
        I did the exact opposite.  I ignored the book lined
        caves.  I did not reads their books, which they
regarded
        as a personal slight.  I went to the very fountainhead
of
        the information, the people who had worked at Hitler's
        side for twelve years. By then I aver and I submit and
        I strongly resent in this court on oath at no time was
        I not aware of the fact that I had to treat what they
said
        to me with the utmost caution, and it was only when I
was
        satisfied they were being completely frank with me,
that
        I added weight to the evidence they gave me and I will
        give two examples of that, my Lord.  One of them was
        Walter Frentz.  He was the personal film camera man
        attached to Hitler's staff and he took the colour
        photographs of Hitler's staff which figure in a lot of
my
        books.  One day Heinrich Himmler said to Walter Frentz
in
        August 1941, which he told me and this is the reason I
am
        saying this, because I persuaded him to tell me
something
        against himself.  He said that Heinrich Himmler had
said
        to him in August 1941, Herr Frentz it gets very boring
        here at the wolf's lair, doesn't it?  We are going out
to

.                                      P-187



        the Eastern Front for a few days, do you want do come
with
        us?  Two or three days later Himmler said to Walter
Frentz
        and Frentz related to me this one evening over a body
of
        wine (he is still alive) at Lake Constance.  Himmler
said
        to Frentz, tomorrow we are going to be doing a mass
        shooting, do you want to come along and have a look?
The
        next morning in the misty hours of dawn Frentz and
Himmler
        and Carl Wolf, and a number of other SS gentlemen,
Frentz
        himself is in the airforce, found themselves standing
at
        one end of a field outside Minsk, at the other end of
        which, as Frentz described it to me, large pits had
been
        dug out by "backhose" or bulldozers and truck loads of
        civilians who were being driven up and stood of this
pit
        and being machine gunned in the pit.  He described
this to
        me in great deal.  I do not have to go into all the
detail
        he gave here, my Lord.  His wife was very astonished
to
        hear this.  Halfway through this description his wife,
        Mrs Frentz, said, Walter, I have never heard this
before.
        And Walter went slightly pink because I suppose he was
in
        his cups and he had not realized he had told me so
much.
        Mrs Frentz niggled slightly in the way that wives do
and
        said, Walter, you say these were civilians being shot,
        were there women and children being shot too?  Walter
        Frentz said, "I cannot remember", but you could tell
from
        the way he said "I cannot remember" that he could.
                  My Lord, I aver that if I get that kind of

.                                      P-188



        information out for the first time from a man who has
not
        even told it to his own wife, then I have succeeded in
        extracting information, even from Hitler's Adjutants.
                  There is another episode of exactly the same
        character.  I persuaded a man to talk to me who had
been
        the Adjutant, not of Hitler, but the Adjutant of
Hitler's
        Adjutant, his SS Adjutant.  Hitler's SS Adjutant was
an SS
        general named Hermann Fegolein.  He subsequently
married
        the sister of Eva Braun.  Hermann Fegolein's Adjutant
was
        Johannes Gohler, who lived in Stuttgart.
   Q.   May I interrupt you, it is going to be helpful to the
        transcriber, who is having a fairly massive task with
all
        these names if you when you mention a fresh name just
        spell it out.
   A.   I have given her a list of 5,000 names. His Adjutant
was a
        man I am going to speak of SS Colonel Gohler.  I will
not
        bother with the accents.  Johannes Gohler told me that
in
        the last days of the War, in April 1945, he was
present
        when Heinrich Himmler, the chief of the SS came to see
        Hitler and reported that there was a concentration
camp in
        Turinier (?), probably the Buchenwald Concentration
Camp,
        about to be captured by the American forces, and what
they
        should they do with the inmates, because they could
not
        evacuate them all in time, Gohler said to me, Mr
Irving,
        Hitler said, Herr Heiss Fuhrer, stay over until the
end of
        the conference. After the conference Gohler said,
after

.                                      P-189



        the conference Hitler sat on the edge of the
conference
        table with his legs dangling and said, "Herr Himmler,
        those convicts are to be liquidated if they cannot be
        evacuated in time".  I asked Mr Gohler about that
episode
        on three separate occasions, spread over several years
        just to see if there were discrepancies in the
different
        versions, rather like a stereoscopic picture of the
        episode.  The narrative remained the same.  You will
find
        that particular episode in my books on Adolf Hitler.
That
        is an episode recounted to me by an SS officer against
the
        reputation and honour of the SS and against the honour
and
        reputation of Adolf Hitler, yet I extracted it from
        Hitler's Adjutants, or the person who I would
certainly
        put in this category. This is what entitles me to aver
        once again that I have not failed in my duty as an
        historian in so far as the Adjutants are concerned.
   Q.   That conversation, which I am bound to say I do not
        remember, is in "Hitler's War"?
   A.   Certainly in "Hitler's War".
   Q.   Cited in a way that accepts it did happen?
   A.   Unquestionably, my Lord, yes.
   Q.   I am afraid I have not got that in my mind.  Yes.  I
think
        you were on the...
   A.   That was number 2.
   Q.   Yes.  That is illustrative, is it really, about what
you
        are saying about that criticism?

.                                      P-190



   A.   Well, the plaintiff, that is myself, is tendentious in
his
        choice and interpretation of documents, rejecting out
of
        hand the greater wealth of statements.  My Lord, you
will
        have noticed the subtle difference between statements
and
        documents, I am sure.  Directly implicating Hitler in
the
        Final Solution and adopting as persuasive the few
        statements exculpating Hitler without any proper
        explanation for so doing.
                  My Lord, in your former incarnation as a
        barrister I am sure you have also had to weigh
statements
        and documents and decide which you attach more
importance
        to.  Documents in this connection are anything from a
        wartime document, a microfilm, a tape recording, an
aerial
        photograph, a deciphered intercept, or even a building
as
        document in this connection; where a statement made by
        somebody for whatever purpose, usually to exculpate
        himself and pass the blame on to somebody else, as
        frequently happened in the war crimes trials, is to be
        viewed with the utmost suspicion.
                  Statements in my submission are usually
relied
        upon by people who have not got enough documents, they
        have not got enough documents because they have not
gone
        out and done the fieldwork.  They like using the
        statements because they fit in with their preconceived
        notions, whereas the documents like the ones I have
        I mentioned, the Schlegelberger document and the
Himmler

.                                      P-191



        telephone notes are inconvenient.  They find no
        explanation for them.  So they prefer their statements
to
        my documents, my Lord.  This may seem a trite answer,
but
        it is the answer which I shall give until they come at
me
        with chapter and verse in cross-examination.
   Q.   Yes, I think this is another example of an allegation
that
        is really only capable of being dealt with by looking
at
        the individual cases relied on.

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