Archive/File: people/i/irving.david/libel.suit/transcripts/day004.11
Last-Modified: 2000/08/01

   Q.   Then, low and behold, almost a year later, or just over a
        year later, comes along a report from the East saying that
        just that has happened?
   A.   Yes.
   Q.   A report to Hitler?
   A.   December 29th 1942, yes.
   Q.   So, as a matter of historical fact, Mr Irving, you have
        always known about report No. 51 on 29th December 1942,
        have you not?
   A.   Yes.

.          P-94



   Q.   The probability that Hitler saw that report and was,
        therefore, what shall we say, implicated in the murder of
        all those 363,000 Eastern Jews is confirmed, is it not, by
        our subsequent knowledge of this document?
   A.   Yes.  There is no contention between us on that point.
   Q.   So, historically speaking, the fact is that the systematic
        killing of the eastern Jews, whether in Minsk or Kovno
or
        Kiev or anywhere else, was part of a Fuhrer plan?
   A.   As a part of the partisan combating.  I am trying to
        specify exactly what interpretation one can safely put
on
        two rather skimpy documents with 12 months between
them.
                  It has to be said that this telephone
notice,
        this agenda, is about as skimpy as one can imagine.
One
        would only wish that Himmler had been more literary in
his
        endeavours and told us precisely what was going on.
   MR JUSTICE GRAY:  Would it be wrong to read it that they
were
        to be treated in the same way as partisans were being
        treated, namely they were going to be shot just as
        partisans ----
   A.   Precisely, my Lord.
   Q.   --- because they were supporting the ----
   A.   And I know that some people would say, well, the Jews
        provided the partisan reservoir, but, of course, the
        obvious argument against that is "and the women and
        children too" and the answer to that is, of course,
they
        were not.  So this was, undoubtedly, part of the
majority

.          P-95



        atrocity on the Eastern Front which I have never
denied.
   MR RAMPTON:  Well, then please will you look at report No.
51
        itself?  I know we have looked at it before, but these
        documents are, in our submission, so intimately
connected
        that it is necessary to look at it again.  You will
find
        that in (which I hope you have) H3(i) which is the
first
        tranche of Professor Browning's documents at footnote
        28(ii).  H3(i), do you have?
   A.   Yes.
   Q.   Then if you turn to FN 28(ii) at the bottom right-hand
        corner of the page, you should have it?
   A.   I have it.
   Q.   This is a report -- I will not go through it all again
--
        only for a part of the East.  It does not say
anything,
        for example, about Ostland.  It talks about South
Russia,
        Ukraine and the Bialystok area which is to the west of
        White Russia, is it not?
   A.   Yes.
   Q.   As we noticed before, under paragraph 2, listed as
gang
        helpers, and what was the other word?
   A.   "Partisan accomplices" is the way I would translate
that.
   Q.   Sorry, what?
   A.   "Accused of being partisan accomplices or fellow
        travellers".
   Q.   Yes, fellow travellers?
   A.   And suspects.

.          P-96



   Q.   Or whatever.  Some were arrested, some were executed,
        which is perhaps not very surprising, not in huge
numbers,
        a total under B of 14,000 -- well, comparatively not
in
        huge numbers, I should have said.  Under C, as a
separate
        entry for heaven knows why, a separate entry, 363,211
        Jews?
   A.   Yes.
   Q.   So, is it your thesis that Hitler would have been
likely
        to think, "Oh, well, I am sure all those Jews were
getting
        up to no good in the underground or the Resistance or
        whatever, the subversives, and there were all that
many of
        them so the poor old SS had to shoot them", is that a
        realistic scenario, Mr Irving?
   A.   That being sarcastic, presumably?
   Q.   I am being entirely sarcastic.
   A.   Yes, of course not.
   Q.   Not to you, but I mean that is not a credible
suggestion,
        is it?
   A.   Of course it is not, no, and this document I have
printed
        in several of my books.  I think I was probably the
very
        first person to have drawn attention to it.  I may be
        wrong on that.
   Q.   This is important, Mr Irving.  So you agree with me
that
        this is just some kind of fiction, really, to put them
        under band helpers and band whatever the other things,
        accomplices.  This is put, coldly and bluntly, a
record of

.          P-97



        the number of Jews deliberately executed for the
reason
        that they are Jews and for another, is it not?
   A.   I have no evidence of that, but that is a reasonable
        supposition.  But I would also continue from that
point
        and say what worries me about this document is that we
        have no evidence that Hitler took it on board, as we
would
        now say.  He never referred in later conferences
saying,
         "I remember back in December we got that document
saying
        we had killed 3,000 Jews, jolly good show!"
   Q.   But you have had this document for a long time?
   A.   Oh, yes.
   MR JUSTICE GRAY:  But the evidence suggests that it was
laid
        before Hitler, does it not?
   A.   I agree, my Lord, but there is a difference between
        documents being laid before a Prime Minister or a Head
of
        State at a time when disaster, the world is crashing
        around his ears, it is the height of the Stalingrad
        Crisis, and the fact that he actually imbibed the
facts
        and figures contained in it, this may be precisely why
        Himmler put it to him at that time.  This has been
known
        to happen, that people -- documents are shovelled in
front
        of them.
   Q.   We now know that he did ask to be kept informed about
the
        shootings on the Eastern front.
   A.   18 months earlier, my Lord, yes -- that is not
strictly
        accurate, my Lord.  He asked to be kept informed of
the

.          P-98



        activities of the Einsatzgruppen.  Broadly speaking,
their
        major activity was policing the rear areas and to them
        fell the task of killing the Jews.
   MR RAMPTON:  Have you any idea of the cost of ammunition at
        that time in the history of the Reich?
   A.   Cost of ammunition?
   Q.   Yes.
   A.   I would imagine the price per round was relatively
low.
   Q.   So it would not be a huge economic expenditure to
kill,
        let us say, 700,000 Jews by shooting?
   A.   It is much cheaper to kill them with bullets than with
        cyanide gas.
   Q.   Much noisier too?
   A.   I take your word for it.
   Q.   Well, bullets, they were not using silencers, were
they?
   A.   I am afraid you have lost me there.
   Q.   It is more likely to come to public attention, is it
not,
        and it is also, I mean, I do not know how many
soldiers
        they used by per shooting?
   A.   I think there were six machine gunners, according to
        Bruns, was it not?
   Q.   I do not know.
   A.   Who took it in turns.  They were relieved.
   Q.   Evidently, at some stage it became too much for many
of
        the people that had to do it?
   A.   Yes, I am sure.

.          P-99



   Q.   Whereas -- we will come to the other matters later on.
        Now, I would like Mr Irving -- my Lord, this is the
last
        thing, if I may, that I will do before the
        adjournment  ----
   MR JUSTICE GRAY:  Yes.
   MR RAMPTON:  --- to have a copy of Professor Evans' report.
   A.   While it is being fetched, my Lord, can I ask you, do
you
        read the newspaper accounts that are published at all
of
        this action?
   Q.   Not much, no.
   A.   Not much?
   Q.   Well, if you have been there, there is not much point
in
        reading about it.
   A.   I agree, but the newspapers sometimes report things
that
        have not been dealt with in the courtroom.
   Q.   Yes, I know.  Why do you mention that at this stage?
   A.   Well, over the weekend I have been studying some of
the
        accounts, and it would disturb me if I thought you
were
        accepting what the press reported about things.
   MR JUSTICE GRAY:  No, I rely on what I hear here.
   A.   This is the Evans report.
   MR RAMPTON:  Yes.
   A.   Page?
   Q.   That will probably take us up to, at any rate, 5 to 1.
        Page 134.  There may be more to come of this after the
        adjournment when I have done a bit more research, but

.          P-100



        these two little snippets will do for the moment.  For
the
        moment, I have not fished out original transcripts,
        Mr Irving, so I hope you will forgive me.  If
Professor
        Evans has mistranscribed what you are alleged to have
        said, then no doubt, you will tell us.  Page 134(c)
        "Systematic nature of the extermination".  This is
        Professor Evans:  "A refusal to accept that the
        extermination of the Jews was systematically organised
or
        centrally directed is a major element in the
phenomenon of
        Holocaust denial"?
   A.   As defined by him.
   Q.   I am reading his words.  You can cross-examine him
about
        his words, not me.  "Where does Irving stand on this
        issue?  Even before he changed his mind on the numbers
        killed and the use of gassing as a murder technique,
        Irving was denying that the Nazi extermination of the
Jews
        had been carried out in a systematic manner.  Thus,
for
        example, in 1986, two years before his change of mind
on
        these issues, Irving told reporters in Brisbane,
        Australia:  'I am not attacking the figure of 6
million.
        I am not attacking the fact that the Jews were killed,
but
        I am attacking or questioning whether, in fact, it was
a
        tragedy ordered and organized on the very highest
German
        state level, namely by Hitler himself, and I think
this is
        what they find very repugnant'."  Who was "they" in
that
        sentence?

.          P-101



   A.   I do not know.
   Q.   "'because if my hypothesis is correct, then it means
that
        all these Jews, and it maybe any figure, I don't look
at
        the figure concerned, if my hypothesis is'" -- sorry,
it
        is difficult to read, "'if my hypothesis is correct,
it
        indicates that the Jews were the victims of a large
number
        of rather run-of-the-mill criminal elements which
exist in
        central Europe, not just Germans, but Austrians,
Latvians,
        Lithuanians, Estonians, feeding on the endemic
        anti-Semitism of the era and encouraged by the
        brutalization which war brought about anyway'."
                  Then if we go over the page, please, and
then
        there is the bit about these chaps who did it being
        motivated by revenge for bombing.  135, Professor
Evans
        makes the comments:  "Irving did not explain how
allied
        bombing raids on Germany could have turned Latvians,
        Lithuanians and Estonians against the Jews".  Maybe
you
        just made a slip, did you, Mr Irving?
   A.   It is quite clearly being misread by whoever --
Professor
        Evans has misread that.  He is reading into the words
        I used a much tighter link there.  Quite clearly, the
        people living in the Baltic provinces had their own
        reasons for hating the Jews.  I do not propose to go
into
        them here.
   Q.   I do not know whether it is a speech; it is a press
        conference.

.          P-102



   A.   It is a verbatim press conference probably.
   Q.   Yes.  Paragraph 3?
   A.   But, as far as the German killers and the Austrian killers
        went, certainly there are very clearly links between some
        of the killers concerned and what they experienced in the
        air raids.

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