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   Q.   What is that?
   A.   The fact that he never records in any of his diaries that
        he did and whenever he put suggestions to Hitler, then he
        records it in his diary.  This is the subtle distinction.
        If you read all the diaries and not just one glowing ember
        which is thrust into your hands by one of your experts,
        when you are familiar with the entire diaries, then you
        know how to use them.
   Q.   Which is how, Mr Irving?
   A.   The way I just described to you.  I would have been
        looking here for a passage where Goebbels then says,
         "I then put to the Fuhrer the proposal that we do,
this,
        that and the other and Hitler agreed", but there is
        nothing of that.  This is just Goebbels ranting on,
        happily coming back in the after glow of having sat
with
        the Fuhrer, and once more the Fuhrer has put the
        gramaphone record on about the prophecy.

.          P-142



                  I mean, if I am an author of a book which
has
        not got to be a two volume book, writing a book that
is
        going to come down to a reasonable economic length,
you
        have to make judgment calls on what you put in and
what
        you take out.  If something you are going to leave out
        does not really advance the argument one way or the
other,
        then you leave it out.
   Q.   But, you see, your omissions of the Goebbels'
references
        to Hitler are the omissions of all those references
which
        put Hitler in a bad light?
   A.   Let me also put something in a legal sense.  This
entry
        can be held against Goebbels' evidence but not against
        Hitler, of course.
   Q.   We are not conducting a legal enquiry when we are
writing
        a history book, Mr Irving, are we?
   A.   We are to a certain extent.  The man, the people we
are
        writing about are dead.  They are entitled that we
should
        marshal the same kind of criteria that we would in a
court
        of law.  We are looking at serious crimes that have
been
        committed, indeed, the worst atrocities this last
century.
   MR JUSTICE GRAY:  Well, I am about a quarter of the way
with
        you.  I think the fact it does not come from the
horse's
        mouth reduces its weight, but it has weight
nonetheless?
   A.   Unquestionably it has weight, my Lord, but then you
come
        up against the problems of the other weight, the
weight of
        the tome you are writing; you are already facing a

.          P-143



        problem.  I have had to shorten the book already down
from
        the 1977 edition by approximately one-third in order
to
        put the first volume in as well, and you have those
weight
        problems you have also have tempo problems.  You do
not
        want to bog the whole text down by repeating yet again
        with has been said elsewhere.  The fact that Adolf
Hitler
        had planned a radical solution for the Jewish problem,
        whatever he meant by that, has been spelt out
innumerable
        times elsewhere in the book.
                  What is far more interesting in this
particular
        quotation, the real meat of this quotation is Dr
Goebbels
        having learned somehow, presumably from an SS report,
that
        what happened to the Jews in Lublin when they arrived,
as
        I said, beggars all description, as a caption I have
used,
        I believe, in the Goebbels' biography, where I quoted
it
        at far greater length, my Lord.  You will find I
quoted it
        at far greater length in the Goebbels' biography
because
        in the Goebbels' biography it is important.  The
material
        goes to what Goebbels' own knowledge was.
   Q.   Will you forgive me, Mr Rampton, just to ask a couple
of
        questions.  If you look at that paragraph at the top
of
        page 465, tell me if I am wrong, but it appears to me
the
        point you are really conveying to readers there is
that
        Goebbels did not discuss the disposal of the Jews or
the
        realities of the disposal of the Jews ----
   A.   With Hitler?

.          P-144



   Q.   --- with Hitler and, secondly, that Hitler was still
        talking about getting the Jews right out of Europe.
   A.   This is a very important point that I make, and he
        continues to say this ----
   Q.   But if you look -- just let me complete the point,
then
        add whatever you like -- at what Goebbels' diary
actually
        records, it includes the phrase "The Fuhrer is the
        persistent pioneer and spokesman of a radical solution
        which is demanded by the way things are and thus
appears
        to be unavoidable"?
   A.   Yes, but what is ----
   Q.   And Goebbels has referred earlier to only 40 per cent
of
        the Jews being available for work, the rest being
        liquidated?
   A.   In my submission, my Lord, the way I used this
material
        was absolutely correct.  I quoted the meat of the
        quotation from the diary, I quoted what we know from
the
        diary about how far his conversation went with Hitler,
but
        I certainly did not try to get cleaver in reading
between
        the lines and suggesting that either he got this
        information from Hitler, which is most likely, he got
it
        almost certainly in the form of a report, a so called
        esdebricht, the same as you have got the report from
the
        Bunzig conference and so on; and that he then went to
see
        Hitler and he sat basking in Hitler's glow for a
while.
        They exchanged anti-Semitic remarks, but Goebbels did
not

.          P-145



        venture to put this material to him, and he came back
to
        Berlin, dictated his diary reflecting, "Well, Hitler
is
        after all the champion and protagonist of radical
        solutions, he is the one".  But at the same time
Hitler
        is, apparently, talking about pushing them out and the
        Madagascar solution, about pushing them out to Russia
and
        that kind of thing.
                  This is the discrepancy in the records that
you
        are confronted with, as I say in the table talk
passage
        that I insisted should be read out.  This is a first
        person record taken by a qualified stenographer,
Heinrich
        Heime, and the people who are present are the people
who
        are actually conducting the massacre, Heinrich
Himmler,
        and yet here is Hitler apparently saying something
which
        is totally at variance with what is at that very
moment
        happening.  This is why it is so significant, my Lord,
        that how could, unless there is a lot of hypocrisy
        going on here, but for what purpose?  These were Top
        Secret memoranda, taken down by Heinrich Heim, signed
by
        Martin Bormann and then put in the files, the so-
called
        table talk.
   MR JUSTICE GRAY:  Thank you.
   A.   You see, it is very easy to look at just one diary
entry
        like the Goebbels' diary and mull backwards and
forwards
        across that without realising that there is a lot of
        collateral evidence that reinforces the position one
takes

.          P-146



        and how one edits it, which is not necessarily
perverse
        and certainly is not manipulation.
   MR RAMPTON:  Mr Irving, it is difficult for me, without
having
        had a response from you to our various reports -- it
is
        not a criticism -- to know when I am looking at a
        particular Goebbels' diary entry whether you have read
        them or not as your reading seems per force to have
been
        somewhat selective.  That is not a criticism either.
   A.   Mr Rampton, I have read the entire Goebbels' diaries
as
        they were available on microfilm from left to right
twice.
   Q.   When?
   A.   Once when they arrived in 1970, in other words, when
        I obtained them from the American archives, and once
again
        when I wrote the Goebbels' biography in the late 1980s
or
        early 1990s.
   Q.   Sorry, I am not understanding, but I thought we had,
        unless I have gone completely mad, a discussion this
        morning about the entry for 13th December 1941?
   A.   That was not available.  I am talking about the
Goebbels'
        diaries when they were available.  The Goebbels'
diaries
        only became available, well, they became available in
        several chunks over the last 50 years.
   Q.   So this is one you had read?
   A.   March 27th 1942?
   Q.   Yes.
   A.   Yes.

.          P-147



   Q.   I am going to have to ask you that question every
time,
        you see, when we look at these entries.   It is one
you
        have read and you chose not to include the reference
to
        Hitler being the leader and spokesman of the radical
        solution; instead, you included, if it was a question
of
        space, the last sentence, in your words, "The Jews
have
        nothing to laugh about now", did you not?  You skipped
        right down ----
   A.   "The Jewry had nothing to laugh about" in Evans'
words,
        yes.  Very similar.
   Q.   Yes.  His translation is slightly better than yours --
--
   A.   Except it is less literate, less literary.
Occasionally,
        when you make a translation for a book that will be
        published, you have to go for the literary rather than
the
        wooden.  This is a slightly more wooden translation.
   Q.   This is not an important point, but it is dangerous,
is it
        not?
   A.   I try to avoid wooden translations for documents if I
am
        writing a book for publication.  I try to put a
literal
        translation.  With Goebbels, it becomes very difficult
        because his diaries are written in a vernacular -- a
lot
        of slang put in them.
   Q.   You do record fairly enough the diary entry of 20th
March
        and the remark on 19th by Hitler -- I have it in here,
it
        is at the bottom of page 464 -- "The  Jews must get
out of
        Europe.  If need be, we must resort to the most brutal

.          P-148



        methods", do you not?
   A.   I cannot find it in the book.
   Q.   I am so sorry.  It is in the last paragraph on page
464.
   A.   On March 19th he quoted in his diary, yes, that is
right.
        OK.
   Q.   Yes, only this remark.
   A.   Yes. "We must resort to the most brutal methods".
   Q.   In your first edition, you got the chronology wrong,
did
        you not?
   A.   It is possible, yes.
   Q.   Yes, you did.  You said that Dr Goebbels' meeting with
        Hitler on 20th came after that entry of the 27th which
we
        have been looking at.
   A.   It is possible.
   Q.   That is not a criticism, it is a fact, so nobody
should
        confuse themselves by looking at the 1977 edition.
Then
        you go on:  "That Goebbels privately knew more is
plain"
         ----
   A.   Yes.
   Q.   --- etc.  What was the evidentiary foundation for the
        assertion that Goebbels plainly knew more?
   A.   Privately knew more.
   Q.   What?
   A.   That he privately knew more.
   Q.   Yes, than Hitler did.
   A.   He quoted a remark by Hitler that the Jews must get
out.

.          P-149



        He privately knew more because the SD had sent to him,
        Goebbels, the report on whatever is going on that
beggars
        all description, the killings at 40 per cent, 60 per
cent.
   Q.   Mr Irving, I am sorry about this.  I am not trying to
        rewrite history; I do not have to.  I am trying to put
        myself in the position of an historian who is writing
an
        account of these dark days, and sees that Hitler on
19th
        when evidently he and Goebbels had had a meeting
saying
        that the Jews must get out of -- I will get it right -
-
        Europe.  "If need be, we", that is the German
government,
         "must resort to the most brutal methods ----
   A.   To get them out.
   Q.   What is the most brutal way of getting somebody out,
        oustvotting somebody?
   A.   No, it is not.  It is being knocked up at 2.00 or 3.00
in
        the morning by Gestapo hammering on your door and
saying,
         "You have got 15 minutes to pack and come down to a
        central collecting point and then you are going to be
put
        on a train with the aforementioned three tonnes of
bread".
        That is a brutal means of getting people out in any
        language.
   Q.   It is a brutal means, but if we are going to be
literal
        minded and go into the school room, we know that
"most" is
        a superlative, do we not?
   A.   Yes.
   Q.   What is the most brutal means of removing people?

.          P-150



   A.   Most brutal means of getting people out?  Using brute
        force, getting the Gestapo, dogs.
   Q.   I am going to see if I can find what word is
attributed to
        Hitler.
   MR JUSTICE GRAY:  I do not know where that diary entry is.
   MR RAMPTON:  I do not either; that is the trouble.
   MR JUSTICE GRAY:  I am not sure it is going to matter very much
        because Mr Irving is making the point that in the end we
        are talking of getting them out of Europe and not anything
        else, so it does not really matter what word is used.
        That is what you are saying, Mr Irving, is it not?

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