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Last-Modified: 2000/08/01

   Q.   Even for an idiot like me it is an easy word, it means
        "placed before"?
   A.   No, "lagen" is to lay --
   Q.   Laid before, more gently than placed before.
   A.   -- something which should be more impressive for me would
        have been the phrase (German spoken) "the Fuhrer has taken
        cognisance of"; you will always find that on the
        documents.
   Q.   At all events, I am right it does not have any
        consequences for the murderers of these 363,000 Jews?
   A.   Mr Rampton, this is not a hanging document; I think if
        this document were to be shown to an English jury in a
        murder case they would say, well, it is interesting and
        probably the guy did it, but I will not send him to the
        gallows just on the basis of this one document.
   Q.   Probably, that is right.
   A.   Yes, well, I have allowed that word.

.          P-160



   Q.   Thank you very much, probably, that is all I need,
thank
        you, Mr Irving, Hitler, as we observed before is not
on
        trial here.
                  Will you have a look with me, please, at an
        earlier event, which is a table talk of Hitler's on
the
        25th, it was your remark --
   A.   25th October 1941?
   Q.   -- that put me in mind.  Here I am afraid we are going
to
        get involved in an argument about German grammar, but
        never mind, I think I can cope.  On page 323 of
Professor
        Evans' report, this comes from page 377 of Goebbels,
under
        letter A.  I will read what Professor Evans says:
                   "In his book "Goebbels" Irving comments on
the
        deportation of Jews from Berlin, starting in October
        1941:  'Hitler was neither consulted nor informed'.
                  As a matter of fact you know that to be
untrue,
        do you not, Hitler was --
   A.   I was reading Hitler --
   Q.   -- I am so sorry, I quoted from the book.  "Hitler was
        neither consulted nor informed".
   A.   -- deported the Jews from Berlin -- I would need to
read
        the whole paragraph I am afraid in my book before I
allow
        a judgment on that one sentence.
   Q.   OK.  I will come back to that.  That is a minor point.
        But if you like to we my be just to deal with this
        quickly.  Perhaps we better have the Goebbels book to
look

.          P-161



        at.  It is page 377.  Have you got your own copy
there?
   A.   300 and?
   Q.   377, chapter 43 entitled "Exodus".  I will put it in
        context by reading the top of the first complete
        paragraph.
   A.   By Holocaust denier, David Irving, right?
   Q.   Yes, Mr Irving.  "His mass expulsion of the Jews from
        Berlin was beginning.  On October 14th 1941 SS
General...
        signed the formal order as National Chief of Police
and
        the deportations began the next day.  500 or 1,000 at
a
        time, family by family, the Berlin Jews were
rounded... in
        synagogue in ... loaded aboard passenger trains...
        freighting to the East."
                  Then you list some of the trains.  "All four
        were bound for the ghetto at Lodz between October 18th
and
        November 2nd confirmed Speyer's diaries, some 400,500
        Jews were'evacuated'" releasing to him... Gauleiter
        Goebbels one thousand ... (reading to the words) ...
        supposedly for bombed out Berliners ... went to their
        closest... Hitler was neither consulted nor informed";
        about what, Mr Irving?
   A.   About --
   Q.   Was he neither consulted nor informed?
   A.   About this particular deportation phase, this wave of
        deportations from Berlin.
   Q.   -- can you turn on to page 330 of Professor Evans'

.          P-162



        report.
   A.   330?
   Q.   329.  It is a few pages on from where we were, but
keep
        your finger where I was, paragraph 2:
                  "As far as the expulsions are concerned,
        Goebbels noted in his diary on 19th August 1941 that
        Hitler had approved them in principle:  'Apart from...
        Fuhrer gave me approval to ... (reading to the words)
...
        as soon as first possibility of transport offered
        itself'."  Is that a correct translation of what is in
it
        Goebbels' diary?
   A.   Yes, it is, it is also in my Goebbels biography.
   Q.   I did not ask you that, is it a correct translation?
   A.   Yes.
   Q.   You have answered my second question, and it is an
entry
        of which you were aware?
   A.   Yes.
   Q.   Then says Professor Evans this: "On 18th September
1941
        Himmler in fact had told his subordinate in the
        Warthegau"; that would be Griser (?) I suppose, would
it?
   A.   The --
   Q.   What?
   A.   -- well, no, Griser was not Himmler's subordinate.
Griser
        (?) would have come directly under Hitler.
   Q.   It does not matter.  "Himmler in fact had told his
        subordinate... Fuhrer wishes the old Reich and the

.          P-163



        Protectorate to be ... (reading to the words) ... as
        quickly as possible.  I am thus aiming to transport
the
        Jews of the Old Reich and Protectorate if possible
before
        the end of this year into the eastern
        territories ... (reading to the words) ... two years
        ago... as a first step, in order to move them further
        still to the east next spring." This is September
1941?
   A.   Yes.
   Q.   "One month later" says Professor Evans "on September
24th
        1941 Goebbels noted in his diary that Hitler had made
a
        final decision on the matter.
                  I can bring the Fuhrer... of internal
political
        problems to decide upon:  the Fuhrer is of the opinion
        that the Jews must be taken out of the whole of
Germany
        bit by bit.  The first... free of Jews are Berlin,
Vienna
        and Prague... I have the hope that we shall succeed
even
        in the course of this year in transporting a
significant
        portion of Berlin's Jews off to the East."
                  Now I suppose you were aware of that entry
too,
        were you not, Mr Irving?
   A.   You suppose wrongly, that was a diary entry which I
have
        not got.
   Q.   It is a diary entry you never had?
   A.   I have not got it, no, I have never seen it.
   Q.   Then I think one has to look at page 374 of Goebbels.
It
        may not be right.

.          P-164



   A.   I thought my memory was correct, September 23rd I
have,
        but not the 24th.
   Q.   Yes, I think that is right.
   A.   It is difficult for me to remember over the last ten
years
        to remember which entries I have seen and which I have
        not.
   Q.   I would accept it in general that is probably right,
you
        have not seen this entry? Had you seen the Himmler
note or
        whatever it is?
   A.   No.
   Q.   Have you seen the Himmler document?
   A.   The Griser, yes, of course.
   Q.   Yes, right.  It is very unlikely, is it not, that in
the
        light of these two entries of 19th August by Goebbels
and
        18th September by Himmler that Hitler did not know
about
        the deportation?
   A.   Yes, you are right, I should have phrased it
differently,
        I should have said there is no evidence that Hitler
was
        consulted or informed.
   Q.   Little point in a way, Mr Irving, but again you see
these
        points are cumulative.  Perhaps significant, because
once
        again you are giving Hitler a clear acquittal when the
        evidence is suggestive that he probably did know about
it?
   A.   On the contrary, an acquittal of what?  I have made it
        perfectly plain beyond peradventure that Hitler gave
the
        orders for the expulsion of the Jews. And the fact he
was

.          P-165



        not informed on a particular phase of it is not
        exoneration.
   Q.   So, it is only four trains or whatever it is you are
        talking about?
   A.   The fact it is now beginning in Berlin, and that it is
        happening at this moment.
   Q.   It is not a big point in your narrative?
   A.   The fact that I decided to write in the short form
rather
        than the long form part is part of the general
tendency to
        books as short as possible.
   MR JUSTICE GRAY:  It is a complete non-point, is it not?
Why on
        earth should it matter whether Hitler was informed
about
        these four particular trains?
   A.   It is really a non-point.
   MR RAMPTON:  Yes.  Thank you very much.  No, I am sorry,
        Mr Irving, unusually I have made a concession that
        I should not have done.  You take your Goebbels book
        again.
   A.   Yes.
   Q.   This is why I need a team of 40 people, because I do
not
        have your memory.
   A.   Be glad you do not have my memory.
   Q.   I have not done years of research on this subject,
only a
        few months.  274 of Goebbels.
   A.   274?
   Q.   374, I beg your pardon.  After the bit you notice

.          P-166



        September 23rd?
   A.   Yes.
   Q.   There is an asterisk, then there comes this: "Hitler
had
        confirmed to him that little by little all Jews were
to be
        expelled from Berlin Vienna and Prague, note 91"?
   A.   Yes.
   Q.   Please turn to page 642, note 91, diary September
24th,
        1941?
   A.   Very good.  Yes.
   Q.   Once your memory failed you did it not, Mr Irving?
   A.   Yes.
   Q.   So you had seen this entry?
   A.   Shot out of water on that one, I am afraid.
   Q.   Yes.  Why if it is not in historical terms a
significant
        event, because you concede that Hitler had ordered the
        deportations generally from the Outreich and the
        Protectorate, and indeed from Berlin?
   A.   Yes.
   Q.   Why bother to mention whether or not Hitler was
consulted
        or informed?
   A.   When you write paragraphs you should have a topic
        paragraph, a topic sentence beginning -- it is a
        literary -- not a ploy, a device, a literary device,
at
        the beginning of a chapter you should have a topic
        paragraph at the beginning of a chapter and a topic
        sentence at the beginning of a paragraph.  It is a way
of

.          P-167



        helping the reader, a little clue to reader what is
        following.  So what matters in this paragraph is not
that
        opening floscal (?) as the Germans would say, not that
        little opening throw away line, but what then follows,
        which is the quotation from the table talk.  I do not
        blame you for concentrating on a throw away line, but
I am
        going to concentrate on the table talk which now
follows.
   Q.   This was by way of introduction to the table talk,
        Mr Irving.  It is a little point, but I am going to
        suggest at the end of this case that every time Hitler
        floats into the picture in your books, it is in order
for
        him to be, as it were, conferred innocence.
   A.   Every time?  Every time?
   Q.   More or less.
   A.   Ah.
   Q.   There is no point in putting in that sentence except
to
        say "poor old Adolf did not know about this beastly
        business", yet again.
   A.   Mr Rampton, have you ever written books that have to
        sell?
   Q.   Yes, as a matter of fact, I have.
   MR JUSTICE GRAY:  Not sure how well they sell.
   MR RAMPTON:  Well, they are meant to be sold.
   A.   I had an exceedingly good American editor who taught
me
        will over again how to write books, that is one of the
        things he taught me, always have a topic sentence at
the

.          P-168



        beginning of a paragraph, that is what I would call a
        topic sentence.
   MR JUSTICE GRAY:  But where does the reader of "Goebbels"
learn
        this was all Hitler policy anyway to transport the
Jews
        out of the Reich?
   A.   I beg your pardon?
   Q.   That is a question to you; where does the reader of
        "Goebbels" learn that this was all Hitler policy
anyway
        to transport the Jews out of the German Reich?
   A.   Probably where I quote the Griser telegram --
   Q.   I am sure, but where do you --
   A.   -- I would have to look in the index.
   Q.   -- do not take time, you do somewhere refer to that
        document?
   A.   Yes.  I repeatedly say that on Hitler rests the
initiative
        for ordering the expulsion, but what happens when they
        arrive there is the moot point.
   MR JUSTICE GRAY:  I just does not have the reference in
mind.
   A.   I will find it.
   MR RAMPTON:  It is not an important point, and I apologise
if
        I spent a bit too long on it, but there it is.  It is
the
        next part I am truly interested in.  "Ten days after
the
        forced exodus began [he, that is Hitler]
        referred ... (reading to the words) ... to the way the
        Jews had started this war.  'Let nobody tell me Hitler
        added that despite that we cannot park them in the

.          P-169

        marshier parts of Russia" By the way he added it is not a
        bad thing that public rumour attributes to us a plan to
        exterminate the Jews.  He pointed out however that he had
        no intention of starting anything at present.  'There is
        no point in adding to one's difficulties at a time like
        this."
   A.   I am ready for you.

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