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Shofar FTP Archive File: people/i/irving.david/libel.suit/transcripts/day002.09

Archive/File: people/i/irving.david/libel.suit/transcripts/day002.09
Last-Modified: 2000/07/20

   A.   I will say generally, of course, and it is important for
        the case to know, and I am saying this on oath, I have
        never knowingly or wilfully misrepresented a document or

.                                      P-174

        misquoted it, or suppressed parts of the document
        would run counter to my case, I think it is important
        state that.  Any of the other allegations in that
        misquoting, misconstruing, mistranslating, distorting
        manipulating a document I have not done.  I shall be
        surprised indeed if the defence manage to make out a
        watertight case on even one document in that line.
        I think I would hang up my hat if that could be
        established against me.  It would be a despicable
        for a historian to do, but it would be also very
        difficult, because in my case I have always
        instantaneously made my documents available to my
        opponents.  Sometimes in advance of publication of my
        book I would turn over documents like the Bruns Report
        Professor Fleming.  When I found the article Aumeier
        Report in the British archives I actually contacted
        Professor Richard van Pelt, whose book on Auschwitz
        I greatly admired and I said you will certainly find
        document of great interest and I told him exactly
        the file was to be found. I have always been like
        It would be very difficult simultaneously do that, my
        Lord, and at the same time distort the document
        you are going to get found out and shot.  So I did not
        it.  But that is the only general remark I would make
        possibly of importance because it is a statement on
   Q.   I think that is right.  The next topic that is

.                                      P-175

        by the Defendants is the bombing of Dresden in 1945?
   A.   Again, I will make a general statement on it, my Lord.
        This was the -- it was not actually the first book
        I wrote. The first book I wrote was a history of the
        bombing war, but it was only published in German -- in
        Switzerland.  It was written at the same time as I
        the book "The Destruction of Dresden", which was a
        year task, between 1961 and 1963.
                  I emphasise the years, because in 1961 and
        of course, we were not in the happy position that we
        in now where we can go to the public archives and see
        documents.  I understand that I can go down the road
        the public archives and actually see correspondence
        I had with Harold Wilson, this kind of thing.
        I personally frown on it.  I liked the old 50 year
        because there were ways round it. But in those years
        was a 50 year rule in operation.  In you wanted to
write a
        history of something that happened in World War II you
        could not get the original documents if you were not
        official historian.
   Q.   That is from the British --
   A.   From the British point of view.
   Q.   -- what about the German records, were they available?
   A.   The German records were in a more difficult position
        because Dresden lay in the Soviet zone of Germany, the
        German Democratic Republic as it had by that time

.                                      P-176

        and although I had established cordial relations with
        Archives Director in Dresden, Dr Walter Lange, they
        under no kind of obligation or compulsion to make
        records available to me and they did so on a very
        piecemeal basis, what the Germans would call in salami
        slices, piece by piece they would give me a document,
        according to how they thought they could fit it into
        Cold War propaganda.  I had to weigh it from that
point of
                  I emphasise this because three years later
        the book was published those same officials in East
        Germany decided they had now just found a report on
        statistics on the air raid on Dresden which produced
        figures which were different from mine.
   Q.   You are making this point really to explain why your
        estimate of the number of deaths, which is really what
        Dresden issue is about?
   A.   Yes.
   Q.   Has fallen fairly dramatically from a quarter of a
        million --
   A.   I would not say "fallen", that implies only way, I
        say "fluctuate".
   Q.   -- in a downwards direction, would you accept that?
   A.   If you were a scientist you would not say "the figure
        this", you would say it is probably that, with a upper
        margin of this and a lower margin of that.  You would

.                                      P-177

        a range of probabilities, and the range of
        I have given has remained roughly the same, but I have
        brought down the target figure.  The original figure
        I gave, I hasten to add, was not my figure, it was the
        figure given to me by a man who met the Trevor Roper
        criteria.  If you remember, my Lord, somebody who is
in a
        position to know.
                  This was a man who was school teacher in
        who had nothing to gain from it, who had asked no
        for it, but after the air raid on Dresden, which took
        place on February 13th 1945, this school teacher had
        unfortunate task of running the missing persons bureau
        Dresden, the Dead Person Section, he had been given
        job of setting a card index in this appalling task of
        trying to identify the dead.  They did it, for
        they collected buckets of wedding rings from the
        I am sure the defence will appreciate when I talk
        buckets of wedding rings, gold wedding rings, were
        collected from the corpses of the air raid victims
        inside a German wedding ring there is the initials and
        date of the wedding, so they could identify the corpse
        from that. Or they could have an index card just
        "KD" and a date on the inside of wedding ring. They
        up this card index.
                  Of course, this was incomplete because they
        not got all the corpses and not all the corpses were

.                                      P-178

        adults, not all the adults were married.  But he was
        to extrapolate and he kept a diary, which he also made
        available to me.  When I asked him the 60,000 dollar
        question, I said, Dr Voigt or Mr Voigt, how many
people in
        your estimate died in that air raid on Dresden?  He
        me an upper estimate and a lower estimate, and he then
        said that in his own belief the figure was probably
        135,000.  Which was the figure I then used, and I
        the source as being this man.  In other words it was
not a
        figure on my authority, it was a figure on the
        of the source.  I see no reason really to depart from
        figure because, it may sound self-defeating, I say
        there is not much difference between 135,000 dead and
        35,000 dead.  Both of them are a monstrous tragedy or
        crime, depending on which end of scale you are viewing
        from.  If you are one of those dead it hurts just as
        if you are one of the 35,000 or one of 135,000.  So
        I confess that I did not dedicate as much work to try
        pin down the actual death roll as no doubt the defence
        would have liked me to have done, the Defendants in
        case, my Lord.
                  But I would also submit this cannot be
        categorized as being wilful misrepresentation, or
        distortion.  My Lord, you will remember that I said
        the German police chief's document giving a different
        death figure had been found three years after I wrote

.                                      P-179

        book.  It was supplied to me by the East German
        authorities, very kindly, voluntarily, and by an
        extraordinary coincidence in exactly the same post
        I received from the West German Government a summary
        the German Finance Ministry files for that week which
        contained precisely the same figures that that East
        document contained, because otherwise one which might
        suspected this was an East German cold war propaganda
        trick.  So it was a very authentic kind of document.
        even then you had to say the document was dated,
        I believe, March 10th 1945, less than four weeks after
        air raid on Dresden.
                  My Lord, I do not know if you have seen the
        photographs of Dresden after the air raid.  There was
        very much left standing.  The building -- the city was
        pancaked.  Nobody had excavated the city centre. The
        people who were living in the old town were still
        in the basements where they had been suffocated or
        alive.  So the figure that the Police Chief gave in
        report of March 4th 1945 could still only be regarded
   Q.   What is the figure in the current edition of
        of Dresden"?
   A.   Can I just complete what I was about to say, I was
        pausing for dramatic effect.  The step which I then
        having received this document, was as follows:

.                                      P-180

        I discussed it with my publisher, and I said that it
        an important enough document that I had to draw it to
        attention of the reading public immediately, and he --
        Mr Kimber -- and Mr Kimber, God rest his soul, he
        David do not do that.  If you do, it will come down on
        your head. It will reflect on you in a bad way, and I
        this is an important document, and I have a duty to
        it to the attention of reading public, and I sent it
as a
        letter to The Times, which is in the discovery, and
        Times newspaper published it, I believe, on July 6th
        within a very true days of my actually receiving the
        document from the East Germans, the new figures, the
        that there was a considerably lower death roll
        by the local Police Chief. I added my reservations,
        fact that the city was still largely unexcavated, even
        then, in 1966 and the fact that local Police Chief was
        charge of air raid civil defence measures.  So he had
        reason to give a bigger figure.  He would prefer to
give a
        lower figure.
   Q.   This is Mr Grosse?
   A.   I cannot remember exactly which name it was, the man
        wrote the final report.  Grosse wrote the incorrect
        report, the propaganda report, my Lord.  I emphasise
        fact that I made this immediately known to the reading
        public and not only that but at my own expense I had a
        reprint made of that letter by The Times newspaper.  I

.                                      P-181

        500 copies printed and for the next few years I
        that letter with all my correspondence to other
                  Now I do not know any other historian who
        have taken action like that, my Lord.  He would hoped
        nobody found out, possibly.  He certainly would not
        gone out of the way to draw the attention of other
        to an error or possible error that he had made in one
        his own books. To find myself now, 30 years later,
        defending myself against the allegation of
        and distortion beggers description, it is repugnant,
   Q.   What is the figure in the current edition of
        of Dresden" for the number of deaths?
   A.   I have reduced my best estimate to the region of
        This is the edition which is called "Apocalypse 1945"
        destruction of Dresden because it was not until three
        years ago that I sat down and analysed that Police
        report and compared it with the Grosse Report and saw
        obvious similarities and the obvious discrepancies and
        decided that the Grosse Report had been deliberately
        issued by the Propaganda Ministry for propaganda
        purposes.  But 60,000, my Lord, 35,000, 135,000, you
        disagree with me, but I see no difference between
        figures, any more than somebody whose says it was not
        million who died in the Holocaust, it was only one

.                                      P-182

        which is the kind of sentence I would never utter because
        each one of those people being killed is a crime and
        I consider people being killed in saturation bombing air
        raids, although I am British, I think it is wrong.

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