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Shofar FTP Archive File: people/i/irving.david/libel.suit//transcripts/day018.17


Archive/File: people/i/irving.david/libel.suit/transcripts/day018.17
Last-Modified: 2000/07/24

   MR IRVING:  It begins, does it not, "I have spent 30 years now
        working in the archives in London, in Washington and
        Moscow, in short around the world.  If I express an
        opinion, it is properly a reasonably accurate opinion
        which I have arrived at over a period of years", and
then
        you have left something out.  Can you tell us what has
        been left out?
   A.   Yes. Without fear or favour to either side and
certainly
        not as a result of being bribed or corrupted or
        intimidated.
   Q.   "In researching Hitler" does it then continue?
   A.   No.
   MR JUSTICE GRAY:  No.
   MR RAMPTON:  That is a confusion.  The "researching Hitler"
bit
        is a different footnote.  It is footnote 6.
   MR JUSTICE GRAY:  I realise that, because it comes after
the
        little (v).  That is obviously right, Mr Irving.

.          P-146



   MR IRVING:  Now we are back to Hitler's War again.
   A.   I omitted that because I do not think you have been
bribed
        or corrupted or intimidated.
   MR RAMPTON:  I am waiting for my bag of pure gold.  I do
not
        understand.
   MR IRVING:  Gold with a capital G I think is going to come
now
        beyond (ii) of the 1977 Hitler's war.  In fact, you
are
        going to dislike me over this because, although the
        footnote says it is the 1977 edition, my Lord ----
   A.   It might be 1991.
   Q.   It is the 1991 edition and it is pages 6 to 7.
   A.   It is in fact I think 7 to 8, not 6 to 7, so you are
wrong
        there too.
   MR JUSTICE GRAY:  Come on.
   MR IRVING:  Can we begin with the middle?  "For the few
        autobiographical works I have used, I prefer to rely
on
        the original manuscripts rather than the printed texts
as
        in the early postwar years apprehensive publishers,
        especially the licensed ones in Germany, made drastic
        changes in them", and then you have left out a bit?
   A.   Yes.  For example, there is a lot of detail there
which is
        not really of any concern to me.
   Q.   Then you continue "But historians".
   A.   Yes.
   Q.   What you are saying is that everything you left out is
a
        lot of detail which is not of concern to you?

.          P-147



   A.   Mr Irving, to borrow your own phrase, I did not want
to
        fill my report with acres of sludge.
   Q.   Although it provides verisimilitude to the allegation?
   A.   I am not disputing it here.  I am trying to present
your
        own point of view here as succinctly as I can.
   Q.   Did your Lordship identify the passage left out?
   MR JUSTICE GRAY:  Yes I did.  It is the sort of point you
need
        not labour.  I understand what the point is.
   A.   If it helps, I quite accept that you have identified
the
        forgeries and falsifications.  I am not disputing that
at
        all.
   Q.   Is it not so that on these two pages, pages 30 to 31
of
        your expert report, you rather pour cold water, cold
        douche, on the idea that I have succeeded in spotting
        source document after source document, particularly in
the
        form of diaries or alleged diaries which turn out to
have
        been phoney or prettified up?
   A.   Where do I do that?
   Q.   In paragraph 233, and I will read it out while you are
        going back to it.  "(Irving) listed a whole variety of
        diaries and other sources on which he claimed --
without
        any references to back his assertion up, however --
        previous historians had relied ...."  Now of course
you
        see the point why I am irritated that you left out the
        detail I had put in which you chopped out, because you
        said it did not concern you.

.          P-148



   A.   I am not disputing this at all.  What I am really
writing
        about here is your claim that other historians,
reading on
        in the paragraph, your "idle predecessors" had failed
to
        detect them each successive biographer has repeated or
        engrossed the legends, historians have never troubled
to
        consult basic documentation, and so on. That is what
the
        issue is here.  I am not disputing at all that you
have
        identified ----
   Q.   There are numbers of diaries floating around which are
        still broadly quoted by the great historians, even
        somebody as reputable as Andreas Hilgruber has relied
on
        the Engel diary for example?
   A.   I thought you did not read the work of other
historians,
        Mr Irving.
   Q.   I am very familiar with what Andreas Hilgruber has
written
        in the criticisms of his work in this respect.
   A.   So you do read other historians.
   MR JUSTICE GRAY:  Professor Evans, may I make a suggestion
        because we are going to be here a very, very long
time.
        It is really is best not to argue, as it were.  It is
        tempting, I know.
   A.   My Lord, the point I am trying to make in this passage
is
        not that Mr Irving has not discovered falsifications
and
        forgeries.  I accept that absolutely.  The point I am
        trying to make here is that, without any references or
        support, in any references to documents or other

.          P-149



        historians' work, he is levelling unjust accusations
at
        other historians.  That is the nub of this paragraph.
   Q.   You go on to then criticise him for not bothering to
visit
        so and so.
   A.   I am sorry, my Lord, no, I do not.  I am saying that
he
        has accused other historians of not bothering to
visit.
   MR JUSTICE GRAY:  You are right to correct me.
   MR IRVING:  Was that criticism by me justified that other
        historians failed to visit these people?
   A.   You have not provided any documentation of this
        allegation.
   Q.   Well, do I not in the introduction to my book Hitler's
War
        draw specific reference to the widow of Walter Havel,
the
        widow of Anst von Bisecker, who was the mother of the
        later president of Germany, who all provided their
private
        papers and diaries to me of their late husbands?
   A.   I do not dispute that they have provided you with
        material, Mr Irving.  I am not disputing that at all.
   Q.   These are specific examples of widows who had not been
        visited by these lazy German historians.  I am not
        inventing this, am I?
   A.   But you have not provided any support of the
accusation
        that later historians have repeated or engrossed the
        legends created by their predecessors and so on and so
        forth.
   Q.   Let me put it in question form. If German historians
have

.          P-150



        existed from 1945 to approximately 1970, 25 years
without
        visiting the widows of these well-known Germans, who
might
        very well have the private diaries of their late
departed
        husbands, is this not laziness on the part of the
entire
        body of German historians, academics or otherwise, not
to
        have made such visits to these people?
   A.   No, I do not accept that.  Historians are constantly
        discovering new sources.  There are many historians
who
        have discovered sources that you have not discovered,
but
        I would never accuse you of being lazy.
   Q.   Is it not remarkable that not one single German
historian
        had visited the widow of Ribbentrop's state secretary
to
        ask, do you have your husband's diaries in 25 years?
   A.   The normal procedure with papers and files is that
        archivists approach people whom they think might have
them
        and that is what is normally done.  That has of course
        taken place.
   Q.   In this case clearly they had not.  The Institut fur
        Zeitgeschichte had not bothered to visit them.  The
        Bundesarchives had not bothered to visit them?
   A.   However the Institut fur Zeitgeschichte had a great
number
        of former leading Nazis in to give interviews,
collected a
        great deal of material, so it is very difficult to
        criticise them, particularly since you have described
them
        in your own work as being an admirable institution.
   Q.   Commendable, yes.  Would you go to the next paragraph,

.          P-151



        please, which is paragraph 2.3.4?  I am trying to make
        forward progress.  On line 3 you criticise the fact
that
        I constantly say the German historians have just
quoted
        each other and it is the biggest active incest since
1945,
        I have occasionally said, they just run around quoting
        each other.
   A.   Yes.
   Q.   Each one assuming that the other one had the source.
   A.   Yes.
   Q.   You have said, give me one example or justify this
have
        you not, in that paragraph?
   A.   Yes.
   Q.   You were not here two or three days ago when we read
one
        page from the history published by Michael Berenbaum.
Do
        you know who Michael Berenbaum is?
   A.   Yes, I do.
   Q.   The ex director of the US Holocaust memorial museum.
Do
        you know who Professor Aberhard Jackeln is?
   A.   Yes, indeed I do.
   Q.   Are you aware that Aberhard Jackeln wrote a paper in a
        book recently published by Berenbaum in which he looks
at
        the historiography of the Holocaust?
   A.   I am not familiar with that one, no.
   Q.   If I tell you that that paper contains -- I know what
        your answer is going to be -- a statement by Aberhard
        Jackeln that, until my book Hitler's War was
published,

.          P-152



        historians had just quoted each other, or they had not
        bothered to do the research, they had only started
        researching once my book was published with my
outrageous
        opinions, as he calls them, does that not justify my
        statement that until that time, 1977, there had been
no
        independent research?
   A.   Well, first of all, I would have to see that statement
by
        Jackeln to make sure that it says what you say it says
        and, secondly, then I would have to check it to see if
he
        justifies it by reference to the work of other
historians.
   Q.   If, since 1955, approximately, the American National
        Archives in Washington had on microfilm available
freely
        in the public domain microfilm copies of all Heinrich
        Himmler's papers, and all his handwritten telephone
notes
        and all his handwritten diaries so far as they were in
        United States hands, is it not to be criticised that
not
        one single German historian or scholar or any other
        historian or scholar had made any use of them until I
came
        along and used them?
   A.   There are two points there.  First of all, it depends
on
        what historians actually are researching as to what
        sources they consult.  Secondly, of course, it depends
on
        the use they make of them.  Trying to cut this
discussion
        short, I do not dispute that you have been the first
        person to read and discover many documents.  I am not
        disputing that at all.  What I am disputing is the
fact

.          P-153



        that you criticise other historians for relying on
weak
        and unprofessional evidence, and quoting each other
for
        the last 45 years, without providing any
substantiation of
        those statements whatsoever.
   Q.   Professor, I agree with you, but is it not true that
at
        the time I wrote Hitler's War in 1977, this was a
        perfectly justified criticism to make, and that nobody
had
        done the research until I came along?
   A.   Research on what, Mr Irving?
   Q.   Heinrich Himmler's handwritten telephone notes, for
        example.  We have 300 pages of Heinrich Himmler's
        handwritten telephone notes; you would imagine that
one
        historian would have bothered to transcribe them.
   A.   Yes, but you state in 1991 that conventional
historians of
        the Jewish Holocaust have not consulted the Himmler
        telephone notes and pocket diaries, and historians
have
        certainly used them between 1977 and 1991.
   Q.   By that time they had come along and started using
them,
        that is correct, but I published the original
introduction
        with an addendum.  But, in the light of what we have
been
        saying in the last 20 minutes, is not your judgment
that
        I do not deserve the title of historian and do not
deserve
        the title of scholar rather harsh and unjustified?
Would
        you be prepared to reconsider that opinion now?
   A.   I think it is harsh, but I do not think it is
        unjustified.  It is not a question of what you
discover or

.          P-154



        what you bring to light, it is a question of what you
do
        with the material that you have got.
   Q.   If what I did with it was make available my
transcripts of
        the Himmler telephone notes immediately to all other
        historians by placing them in the archives in Munich,
is
        that reprehensible?
   A.   No, it is thoroughly commendable but that is not what
I
        mean.  What I mean is what you do with it in the way
that
        you interpret it, which we still have not got on to.

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