The Nizkor Project: Remembering the Holocaust (Shoah)

Shofar FTP Archive File: people/i/irving.david/libel.suit//transcripts/day010.21


Archive/File: people/i/irving.david/libel.suit/transcripts/day010.21
Last-Modified: 2000/07/20

   Q.   --- was originally designed for the purpose of acting as a
        joint mortuary crematorium?
   A.   But this crematorium was of a size and a capacity which
        has absolutely no precedent at all, or for that matter has
        never been followed by a crematorium of this size ever.
        There is no civilian crematorium at all of this size.  The
        largest civilian crematorium so far as I know had three
        single muffle ovens and never had something like 15 muffle ovens.
   Q.   Was that in wartime or in peacetime?
   A.   In Germany people built in peacetime and destroy in
        wartime.  It is very unusual to build these kind of
        buildings in wartime.
   Q.   Yes.  You appreciate, do you not, that that lift shaft was
        the bottleneck through which all the victims of the
        Holocaust had to go, if we follow the standard version?
   A.   I think most of the victims in the Holocaust died outside
        Auschwitz.  So at least ----
   Q.   These 500,000 you talk about?
   A.   --- these people who went through that lift, that would
        have been a bottleneck between gassing and
incineration.
   Q.   I appreciate your earlier point.  Of course far more
        people died than those 500,000 and I have never
challenged

.          P-180



        that point, let there be no doubt about that.  We are
        looking at this building where, as you yourself said,
more
        people died in this gas chamber than in any in other
place
        on earth?
   A.   But bottleneck, of course, the bottleneck of course --
if
        there is going to be a bottleneck, let us say this
door is
        going to be a bottleneck, a real serious bottleneck,
if
        somebody screams "fire" in this room and we all try to
get
        out as quickly as possible and some do not notice
there is
        another room, another exit which says "fire exit"
there,
        but if people file out, as they do at the end of these
        sessions, in a relatively orderly fashion, this is not
a
        bottleneck.
   Q.   If everyone here is dead, then they have a problem,
then
        things slow down?
   A.   But the question is, the issue is, is it a bottleneck,
        also has to be considered in relationship to how long
it
        will take to incinerate those bodies.  So if at a
certain
        moment it would take, let us say, 20 hours to
incinerate
        the bodies of the people who have been gassed in the
        morgue, you have 20 hours to move the bodies upstairs.
So
        then question is over that time would there be a
        bottleneck, yes or no, because the incineration room
        upstairs cannot also take all the 1500 bodies,
whatever
        number of people were gassed downstairs.  So only if
you
        want to get all the bodies up simultaneously is this
going

.          P-181



        to be a serious bottleneck.
   Q.   So they used the mortuary, however the people died,
for
        the time being as a mortuary then?
   A.   I mean corpses were removed in small batches from the
        mortuary to the incineration room to feed the
        incinerators.
   Q.   Yes.  Can we get some idea of the speed of the
operation,
        because your eyewitnesses differ, do they not, as to
how
        frequently this procedure was repeated?
   A.   Which procedure?
   Q.   The liquidation procedure, people being rammed into
the
        gas chamber 2,000 at a time.  We are looking at
figures
        basically here.  We not concerned with the "if".  We
are
        looking at how many.
   A.   Again I am happy to discuss these testimonies when I
have
        them in front of me.  I thought we were talking about
the
        elevator right now.
   Q.   We are talking about the elevator.  If the people are
        being rammed in at one time into the gas chamber and
they
        are being liquidated and then they are being taken out
        through that one exit, up that relatively small lift
        shaft, this is the bottleneck which is going to be
like
        the bottleneck in an hour glass.  You cannot speed up
the
        process?
   A.   But the bottleneck in an hour glass is only a
bottleneck
        if you want all the sand to go down simultaneously.
If

.          P-182



        you want the sand to go down in an hour it is not a
        bottleneck.
   Q.   But it is a controlling factor on the speed of the
whole
        liquidation programme, is it not?
   A.   But there are much more important factors like the
speed
        of incineration in the ovens.
   Q.   You say it is more important, but let us look at the
        elevator.  To make it absolutely plain, there was no
other
        way of bringing the bodies from downstairs up to the
        furnace stage level?
   A.   There is another way.  You could take the stairs, but
that
        would have been very, very ----
   Q.   But that was not used?
   A.   --- it would be very inefficient and awkward.
   Q.   Yes.
   A.   My Lord, I presume that a question is coming.
   MR JUSTICE GRAY:  I am presuming.  I am waiting for it.
   MR IRVING:  Yes.  What do we know about the carrying
capacity
        of that elevator?
   A.   There is a document for that.  The elevator, this
document
        in March for that, I think it is March 1943, they
carried
        the original one which was installed for 750 kilos.
   Q.   750 kilos.
   A.   They immediately asked to increase the carrying
capacity
        of that elevator by providing extra cables to 1500
kilos.
   Q.   What do we know about the provision of the motors for

.          P-183



        those elevators?
   A.   Again I do not want to talk about that right now.  I
do
        not have the document.  But I do know, because I
actually
        looked it up this morning, that they were adapting
that
        particular -- it was a temporary elevator -- to a
weight,
        to a carrying load of 1500 kilos.  So I presume if
they do
        that, that indeed there is a motor which will be able
to
        hoist 1500 kilos.
   Q.   This was made by Daemarg, I believe, the company?
   A.   Yes.
   Q.   The provisional one.  Why was there a provisional one
        installed, because the final ones were not ready?
   A.   Because the SS, despite whatever they were doing in
        Auschwitz, were unable to get an elevator in early
1943.
   Q.   They could not get the priority.
   MR JUSTICE GRAY:  Anyway, carrying a load of 1500 kilos,
that
        would be how many corpses?
   A.   An average one 60 kilos.  It seems a little high, by
that
        would be -- the theoretical carrying capacity would
be,
        let us say, 20 corpses, so that would be 20, 25
corpses.
   MR IRVING:  The same question of course is how many people
you
        can pack into a telephone box, but packing them in
takes
        time.  It would be difficult to envisage having a
working
        lift system with people piled four or five or six or
seven
        high, because quite simply the doors would not close?
   A.   There were no doors.

.          P-184



   Q.   There were no doors?
   A.   No.  It was simply a platform which went up and down.
   Q.   That would be even worse then.  The bodies would
        presumably get jammed against the side of the lift
shaft
        if they piled them too high.  I am just looking at
        practicalities here, that although technically the
final
        version of the lift, and I emphasise that, was going
to
        have the 1500 kilogram capacity, in theory, when was
that
        lift actually installed?
   A.   The 750 kilograms was installed by the time the
building
        was finished and immediately they asked to double the
        capacity the oven.
   Q.   And the 1500 one was not of course installed at this
        time?
   A.   It was not immediately, but they asked immediately for
the
        increase in the carrying capacity.  So obviously they
        wanted, whatever they were bringing up from the
morgue,
        they probably wanted, they felt they needed more
capacity
        for this lift.
   Q.   Yes.  It was not in fact installed until the end of
1943,
        the bigger the one?
   A.   The final one, no.  This is only a modification to add
        extra cables.  This is not the final elevator which is
put
        in when finally the factory gets around to deliver
them.
   Q.   Is it not odd that once again the question arises
here,
        that here is one of the most important killing centres
in

.          P-185



        the Third Reich and they just cannot get the stuff,
they
        are not getting the priorities?
   MR JUSTICE GRAY:  Shall we stick to one point at a time?
You
        are on whether this was a bottleneck.
   MR IRVING:  Can we now look at how long it took to make one
        round trip and load up?  Have you any estimate of how
many
        minutes or seconds it would take?
   A.   To load up how many corpses?
   Q.   Well, this is the question.  You have told us that it
        would take a large number of corpses, but I find this
hard
        to believe if they had no doors and walls on this
lift; it
        was just a platform going up and down?
   A.   I think there are too many variables right now to
stand
        here in court.  I am happy to sit down and, like the
        Zyklon-B, spend a couple of days considering this
        question.
   Q.   I am not asking you to do that.  I am just asking you
to
        do a back-of-an-envelope calculation which will help
us to
        form some idea of how long it would take to raise
2,000
        bodies from this underground morgue to the furnace
level,
        bring them in, stack them on, raise them up, unload
them
        at the top level, bring the thing down empty again and
        repeat the cycle?
   A.   I do not do a back-of-the-envelope and I would just
want
        to do it as I am thinking out loud and nothing more.
Let
        us say that it would take three to four minutes to
load

.          P-186



        this platform, that it takes another minute ----
   Q.   With how many?  With how many bodies?
   A.   Let us 10 bodies, 15 bodies, three to four minutes.
Let
        me just make a note of it as I am going on.  Then let
us
        say it takes one minute and that is a long time for
this
        platform to go up one storey.
   Q.   No, because if it is a freight elevator in fact it
takes
        twice as long.  We know that from Neufert, do we not?
   A.   But we are talking one storey and we talk about a
minute
        and a minute is a very long time.
   Q.   A freight elevator does go slower than a passenger
        elevator?
   A.   Yes, but we still talk about ----
   MR JUSTICE GRAY:  Come on much, not much turns on that,
does
        it? We must keep an eye on realities.
   A.   We talk about 2 metres 50.  We talk about 8 feet going
        up.  Let us say it is another three, and I am very,
very
        generous, you know, three, whatever, two, I mean less,
one
        minute to unload the thing.
   MR IRVING:  One minute to unload ten bodies?
   A.   Yes.  A minute is a long time.
   Q.   That is being very generous.  I would suggest that the
        round trip, loading and unloading, would take about
ten
        minutes each time?
   A.   Ten minutes.  So?
   Q.   Then we have 2,000 bodies to process in this manner.

.          P-187



   A.   So in your calculation we have, and I am slightly
        disgusted right now by the thing I have to do, but ---
-
   Q.   These are very rough calculations, but I am suggesting
        that we have a serious bottleneck which indicates that
the
        figures that talk about have been inflated.  I am only
        looking here at the figures.  I am not looking at
whether
        this happened or not.
   A.   It is going a little fast for me, my Lord, right now.
        I am happy to come back to this on Friday.
   MR JUSTICE GRAY:  If you prefer to, as it is a new point to
        you.
   A.   I am just trying to calculate in my head on the 10-
minute
        basis, and, let us say we, what did we say, 10, 15
corpses
        on the thing, it would mean that in 10 minutes you
        get ----
   Q.   10 to 15.
   A.   It is one ----
   MR IRVING:  My Lord, I think it would be useful if he was to
        return to this after he has had time to do a calculation.
   MR JUSTICE GRAY:  If you prefer.
   A.   Yes, I would prefer to do that, because I think it seems
        to be a very important point.

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