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Shofar FTP Archive File: people/i/irving.david/libel.suit//transcripts/day022.08


Archive/File: people/i/irving.david/libel.suit/transcripts/day022.08
Last-Modified: 2000/07/24

Q.And you are going to say that it is totally impossible for
any reader reading that line for the first time without
the benefit of what I would call cheats, in other words
printed versions of the document, to mistake in that
ancient German handwriting "H A B E N" for "J U D E N"?
Is that going to be your answer?
A.Yes.  I think you have to read this carefully.  You thread
your way through it.  When you are reading handwriting, if
you find something difficult to read or ambiguous, you
then search for other similar letters, the same letter in
other words in the same hand to try and figure out what
that particular hand's version of a B or a D or an E or a
U actually looks like.  What we are dealing with here is
your claim that that says, "Juden zu bleiben" or, as you
say in Hitler's War in 1977, Himmler telephoned Paul with
the order that Jews are to stay where they are.  Whereas
in fact it is "Verwaltungsfuhrer der SS haben zu bleiben",
it is the administrative offices of the SS have to stay.
  From this text there are a number of indications
which somebody who was not biased and looking for some
evidence to the contrary, that is say an objective
historian, that this is "haben zu bleiben".  First of
all,
the fact that it is indented, the second line "haben

.  P-66



zu bleiben" does suggest that it runs on from the
first
line.  The new entries here begin right next to the
middle
of the page.  They are not indented.  Secondly, this
writer, as is common in this handwriting, generally
puts a
kind of what you might call a little inverted
circumflex
over a U.
Q.Invariably or generally?
A.Generally.  Obviously, this is written in some haste.
Q.So that is not the clue then?
A.That is a general tendency and you can see that above
"Besuch" with a little thing over the U.
"Fliegermeldungen" is another one there at the top.
There is another one over the U.  So that is the
general
habit of this writer.
Q.But not invariable?
A.Well, you take that from -- that is one of a number of
indications.  That is the second one.  Then you
compare Bs
and Ds.  You can see, when you compare the B of
"bleiben"
with a B, or if that B in "haben" is a D, making it
"Juden", then you look for another D to see whether
that
is the way the writer writes, and so on and so forth.
I
think we have been through this at some length in
cross-examination.
Q.You are going through it at some length, but can I now
ask
you a simple question?  You have gone through this at
some
length.  Does that indicate it is quite difficult to
read

.  P-67



words like this?
A.It was a conditional.  I said, if you are having
difficulty, if you are finding it a problem, then that
is
what you do as an objective historian.  Myself, I
think it
is very clear from this.
Q.Of course, if you came to the conclusion that it was
reasonable, if you privately came to the conclusion it
was
a reasonable kind of mistake to make when one is
reading
that document for the first time, you would
immediately
tell the court, would you not?
A.Yes I would.
Q.You would have no hesitation in saying to the court
that,
yes, this is a reasonable mistake for David Irving to
make.  Although I do not like him, on this occasion I
will
say this is quite right.  You would do that, would you
not?
A.I do not dislike you, Mr Irving.  I have no personal
feelings at all.  But I do not think this is a
reasonable
mistake to make.
Q.Yes.
MR JUSTICE GRAY:  Can I ask you two questions actually, one
is
I cannot remember what "Verwaltungsfuhrer" is.
A.Administrative officers or leaders -- Administrative
leaders.
Q.And the other is the extent of the textual analysis of
the
kind you have just described that you undertake
depends in

.  P-68



a way on the significance of the document.  I mean,
some
documents you really are not going to spend ages
trying to
work out.  Is this a sufficiently significant document
for
it to be reasonable to expect an objective historian
to
undertake the sort of exercise that you just been
describing?
MR IRVING:  My Lord, that is precisely question I was going
to
ask.
MR JUSTICE GRAY:  I have asked it for you.
A.The significance that Mr Irving places upon it does
require that, that is to say, when it says in Hitler's
War
that Himmler telephoned SS General Oswald Pohl with
the
order that Jews are to stay where they are.  That is
quite
a significant statement and it, therefore, does
require
that kind of textual analysis.  Normally, when you are
--
it is kind of the lowest form of historical
imagination,
as it were, when you find handwriting difficult and
you do
this.  You can do it fairly quickly, in my view, with
this
particular...
MR IRVING:  Have you done this kind of textual analysis
with
every single document you looked at, Professor?  Does
it
take you very long to write your books?
A.Yes, I mean, of course I do this with documents, yes,
when
I am reading through them.
Q.You look at a letters, you look at little caps over
the
Us, you look to see if it is a B or a D?  You do this
with

.  P-69



every word you read, do you?
A.Yes.  You get used to a certain hand and if it is --
if
you find difficulty in reading a word, as one
frequently
does, then that is exactly what you do.  I published
an
edition of 350 handwritten police reports, as you
know,
and they were quite difficult to read.  I frequently
had
to engage in this kind of exercise if they are written
in
different hands by policemen who only had a very
elementary education.
Q.But it would be normal if somebody came to you and
pointed
out and said, "Oh, I don't think this word is this,
that
word is probably that", then you would do that kind of
textual analysis, but you would not necessarily do it
with
every word before you came up against that particular
----
A.Well, you would do it with words that were significant
or
difficult to read.  I mean, normally, as I say, you
get
used to a hand and if you are reading through this,
this
is not a particularly difficult example of this
particular
script, in fact.
Q.There are two obvious corollaries to the questions
which I
have to ask.  The first question is, in your opinion,
did
I deliberately make this reading in order to serve my
political bias?  Was it deliberately perverse reading
or
was it an inadvertent misreading?
A.I think it is a deliberately perverse misreading.
Q.In other words, I knew the correct meaning and

.  P-70



I deliberately chose the other one?  That is what the
word
"deliberate" means.
A.Yes.
Q.In other words, I knew it was "haben" but I
deliberately
wrote it as "Juden" and I hoped nobody would look at
the
original document, is that right
A.Well, it is quite clear from this that it is "haben".
I
find it very difficult to think ----
Q.Not, that is not what I am asking.  You are saying,
 "I knew that it was wrong and I deliberately wrote
the
wrong word"?
A.Well, we are getting a bit into psychology here.  I
mean,
as it, I am trying to second guess your thought
processes
here, but I think you wanted to find a statement like
this, and when you found what you thought was a
statement
like that, you just said, "Hooray" and you did not
care to
look at it any closer.  You misread this.  You were
mislead by your overwhelming desire to exculpate the
Nazi
leadership into misreading this as "Juden" instead of
"haben"; whereas to any objective historian, taking
even
a minimal amount of care about reading this, it was
very
easy to establish that this meant "Verwaltungsfuhrer
der
SS haben zu bleiben".  To that extent, therefore, I
think
you deliberately misused and abused this text.
Q.Can I just explain to you the meaning of the word
 "deliberate"?  "Deliberate" means, and I am sure my
Lord

.  P-71



will correct me if I am wrong, I knew that the word
was
"haben" and I deliberately wrote "Juden" in order to
serve a political end, is that what you are saying?
A.I am saying that it is very obviously that this word
is  ----
Q.That is not the answer.
A.--- "haben"; that any objective historian reading this
would have very little difficulty in establishing this
as
"haben", and you put it as "Juden zu bleiben" which
itself is grammatically an extremely peculiar phrase
which
should alert anybody to the fact that it is not likely
to
be what you say it is.  You wanted it to read "Juden
zu bleiben" and you made it read "Juden zu bleiben".
That
is what I am saying.
Q.So your submission to the court is that I knew it read
 "haben" and I deliberately wrote "Juden"?  I have to
keep
asking this.  Will you give a simple yes or no to that
question?
MR JUSTICE GRAY:  I think you got an answer "yes".
MR IRVING:  The answer is yes?
A.Yes.
MR IRVING:  Thank you very much, my Lord.  Now, the obvious
corollary to that is, if that sentence is taken out of
the
book, does that in the slightest change the thrust of
that
paragraph?  In other words, was there any reason why
the
sentence should have been put in?

.  P-72



A.Let me have a look at the paragraph, please.  This is
Hitler's war, 1977 edition.
Q.Yes.  My Lord, this goes to the importance of the
whole
matter really.  If the answer is that it can be taken
out
without changing the meaning, then the last 10 minutes
have been largely wasted.
MR JUSTICE GRAY:  No, I do not think that is right at all.
So
that you know why I do not think that is right, I will
tell you reason and it is simply this, Mr Irving, that
you
might be able to say in relation perhaps even to every
one
of the passages that are criticised, "Well, by itself,
that does not amount to much", but I think the
Defendants'
case, just so that you know what I am understanding it
to
be, is that if you put them all together, then they
are of
significance.  I think that is the way it is put.  I
am
not saying for a moment I accept it but ----
MR IRVING:  Then we would have to look at the word "all"
and
see what "all" is.
MR JUSTICE GRAY:  Yes, of course.
MR IRVING:  Are we just going to look at three sentences
and
pick two that are adjacent where two flaws have been
made
or are we going to look at the whole book?
A.Right, yes.  Well, the paragraph ----
MR JUSTICE GRAY:  Page?
A.Page 332 in the edition that I have, my Lord, Hitler's
War
1977, and it consists of an accumulation of
falsifications

.  P-73



of documentary evidence of which this is one.
MR IRVING:  Do you agree that the sentence complained of
was
cut out of the following edition?
A.Could I have a look at the following edition, please?
Q.Or was it cut out of the Goebbels biography?
A.Which do you want me to look at, Mr Irving?
Q.Let us look at the Goebbels biography.
MR RAMPTON:  It is at page 427 of the 1991 edition of
Hitler's
War, I think.
A.Right.  Let us have a look at that first.  Page 427?
MR RAMPTON:  Yes, 427 at the bottom.  I think it is there
actually.  I do not think it is cut out at all.
MR IRVING:  Well, that is why I suggested the Goebbels book
instead because the ----
MR RAMPTON:  Yes, I have no doubt that is why.
MR IRVING:  Well, obviously, the error was pointed out to
me
relatively later on.
MR JUSTICE GRAY:  Well, it is exactly the same, I think.
A.Exactly the same -- I will take your word for it, my
Lord.
MR IRVING:  Professor Evans, do you agree that the error
was
rectified in the Goebbels biography in the
corresponding
passage?
A.Where is this?  Page, please?
Q.377 approximately, is it not.
A.Page.
MR JUSTICE GRAY:  377?

.  P-74



A.377 again.
MR JUSTICE GRAY:  I am not sure about that.
MR RAMPTON:  I think it is 379 actually, I think it is.
MR JUSTICE GRAY:  That is right.
THE WITNESS:  That is rather difficult but, presumably, we
are
looking for a lack of any mention.
MR IRVING:  That is right but, in other words ----
MR JUSTICE GRAY:  It has gone altogether, has it?  Yes.
MR IRVING:  --- it has gone altogether?
A.But, see, you are essentially lifting paragraphs from
Hitler's War and putting them into Goebbels, but
changing
them slightly.
Q.I am relying on a reliable source, namely Hitler's War,
when I write the Goebbels biography.  Do you agree, to
answer my question, that I took the appropriate action
when the error was pointed out to me and that I excised it
from all future editions of the work?
A.Can you give me some evidence to show when the error was
pointed out to you?  I think it was pointed out -- was
this one of the ones pointed out by Professor Bruchsal or
not?  That is not really the issue, is it, though?

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