Archive/File: people/i/irving.david/libel.suit/transcripts/day005.11
Last-Modified: 2000/08/01

   Q.   Then if you go to Lublin and you go east/south/east
        towards the Russian border you come to a place Kelm or
        Khelm.
   A.   First of all Treblinka and then Kelm, yes.

.          P-92



   Q.   And you go sharp left northwards to Sobibor?
   A.   Yes.
   Q.   Which is just again next to the border.  If on the
other
        hand you turn right before you get to Kelm or Khelm
and go
        to Savadar, again, travelling right down to the border
on
        a single line you get to Belsec?
   A.   Yes.
   Q.   Those, Mr Irving, were little villages in the middle
of
        nowhere, and from the 22nd July 1942, if these figures
you
        have given in your book are right, which they are not
        quite, but the volume, if you multiply, must be
hundreds
        of thousands of Jews transported from Lublin and
Warsaw
        and as I shall show you after the adjournment also
from
        the East; what were those Jews going to do in these
three
        villages on the Russian border?
   A.   The documents before me did not tell me.
   Q.   No, but try and construct in your own mind, as an
        historian, a convincing explanation.
   A.   There would be any number of convincing explanations,
from
        the most sinister to the most innocent.    What is the
        object of that exercise?  It is irrelevant to the
issues
        pleaded here, I shall strongly argue that, it would
have
        been --
   MR JUSTICE GRAY:  If you want to take that point, can you -
-
   A.   -- it would have been irresponsible of me to have
        speculated in this book, which is already overweight,
and

.          P-93



        start adding in my own totally amateurish speculation.
   MR RAMPTON:  No, you mistake me, Mr Irving, it is probably
not
        your fault I, as his Lordship spotted what I have
done,
        I have taken what you have wrote in the book as a
stepping
        stone to my next exercise, which is to show the scale
of
        the operation, and in due course, and I give you fair
        warning, to demonstrate that anybody who supposes that
        those hundreds of thousands of Jews were sent to these
        tiny little villages, what shall we say, in order to
        restore their health, is either mad or a liar.
   A.   -- Mr Rampton, can I just draw one parallel and say
during
        World War II large numbers of people were sent to
        Aldershot, which is also a tiny village, but I do not
        think anybody is alleging there were gas chambers at
        Aldershot.
   MR JUSTICE GRAY:  I think actually the problem Mr Irving
has is
        we moved on a different phase of the case. We are no
        longer dealing with allegations of manipulating the
        historical records which we were when we were going
        through "Hitler's War" and so on. I think really Mr
        Rampton is now on the issue of Holocaust denial, where
the
        defence case is that what you have said flies in the
face
        of evidence, but it is not an allegation of
manipulating
        the record.  Do you follow what we are on now?
   A.   The evidence he has adduced so far apart from that is
from
        my own books.

.          P-94



   MR JUSTICE GRAY:  You objected to the question, I am trying
to
        explain what I perceive at the moment to be its
relevance.
   MR RAMPTON:  Your Lordship is absolutely right.
   A.   Mr Rampton knows which way he is going, but of course
        I have to prepare little minefields all the way round
just
        in case.
   MR JUSTICE GRAY:  It is important you know where he is
going
        and that is why I was trying to help you.  Anyway I
think
        the question perhaps needs to be put again, does it,
        because I am not sure there has been an answer yet.
   MR RAMPTON:  No.  I suggest, Mr Irving, that anybody -- any
        sane, sensible person would deduce from all the
evidence,
        all the available evidence, including, if you like,
the
        shootings in the East which you have accepted, would
        conclude that these hundreds of thousands of Jews were
not
        being shipped to these tiny little places on the
Russian
        border in Eastern Poland for a benign purpose?
   A.   Mr Rampton, what possible other conclusion could
somebody
        have drawn from reading that page in my book?  You are
        implying that the reader is being invited to draw a
        different conclusion.
   Q.   No, I am wondering what your position is, you see,
        Mr Irving, because if it is simply this; I accept that
the
        Germans systematically murdered Jews in vast numbers
        throughout 1941, accelerating through 1942 1943 and
        reaching a crescendo in 1944, but I simply do not
accept

.          P-95



        there were any gas chambers, then I am not bothered
        because it does not matter how it is done, the fact is
it
        is a systematic genocide.  I want to know whether you
        accept that; if you do accept it, then we can forget
the
        Professor van Pelt and all his works and everything
else
        beside in relation to Holocaust denial.
   A.   It is my belief that Professor van Pelt's purpose in
        coming here is prove to us that the gas chambers at
        Auschwitz existed.
   Q.   He is not.  He is coming here to demolish the basis of
        your Holocaust denial, which is the Leuchter Report,
        amongst other things?
   A.   But the Leuchter Report relies solely on the gas
chambers
        in Auschwitz.  So there seems to be a contradiction in
        what you said.
   Q.   So if, for example, Franjiseck Piper, the custodian of
the
        museum as he was, at Auschwitz, now proposes a figure
of
        1.whatever it is, 2 million Jews murdered, I do not
mean
        worked to death or killed by types, murdered in
Auschwitz,
        you are going to accept that, are you?
   A.   No.  I have a good reason not to and --
   Q.   I think in that case we are back to where we are,
alas.
        I thought I saw a chink of daylight, but it is not
there.
   MR JUSTICE GRAY:  Right, well, I am not clear in my mind
what
        it is that it is suggested Mr Irving may need to look
at
        over the luncheon adjournment.  I have no idea whether
it

.          P-96



        is practical to ask him to do that or whether it is
not.
   MR RAMPTON:  It is probably not, because they are spread
all
        over the bundles and that would be quite unreasonable
        because he would have to stay here and I would have
spend
        at any rate 40 minutes giving him a list of documents
and
        that would not be sensible either.  I will go as
        cautiously as I can in the afternoon and I will try
and
        make sure if I do not remember, perhaps your Lordship
        will, to find out as I ask the questions whether the
        documents in question is one that he has seen before
or
        not.
   MR JUSTICE GRAY:  Yes.  Mr Irving, do you have any problems
        with that?  You are going to be asked about documents
        which I suspect you know about now, but you may well
say
        in relation to it some of them, well, I see that now
and
        I saw that last summer, but I did not know about it
when
        I was writing "Hitler's War"?
   A.   I am in your Lordship's hand on that matter but where
        possible I shall state which ones I have seen for the
        first time.
   Q.   That will not cause you a problem, will it?
   A.   No.  Your Lordship will decide later on whether it is
        relevant or not.
   MR RAMPTON:  I will give your Lordship a copy too.  I am
not
        saying it is exhaustive, complete, or comprehensive --
        what Miss Rogers and I have done is to produce a

.          P-97



        chronological list of the relevant events.  I am not
going
        to start at the beginning of this in my cross-
examination,
        but it does give Mr Irving an idea of what I will be
        asking about this afternoon.
   MR JUSTICE GRAY:  The topic is what?
   MR RAMPTON:  The topic is the scale of what happened during
the
        summer and early autumn of 1942, from which one can
make
        quite obvious deductions, both about system and
knowledge,
        and also about the intent.
   MR JUSTICE GRAY:  Your case is these are deaths in the gas
        chambers?
   MR RAMPTON:  Oh, there is no question.
   MR JUSTICE GRAY:  They started operating in November 1941.
   MR RAMPTON:  The first gassings start systematically in
        December 1941 at Chelmo, I am not going to deal with
        Chelmo this afternoon, except at the tail end if I get
        there.  There is the three Reinhardt camps; Belsec,
        Sobibor and Treblinka.  They used a different system
of
        gassing.  They used a vehicle exhaust --
   A.   Carbon?
   Q.   -- carbon monoxide.  You can also suffocate someone
with
        carbon dioxide, can you not?
   A.   You can suffocate someone by locking them into a
closed
        room.
   Q.   And by hydrogen cyanide at Auschwitz.  I do not say
there
        were not some random murders as well by kicking,
shooting,

.          P-98



        but the system was gas?
   MR JUSTICE GRAY:  Yes, so Mr Irving is going to get a copy
of
        this, so at any rate he will have some; is that right?
   MR RAMPTON:  Yes.
   MR JUSTICE GRAY:  Mr Irving, that will at any rate give you
        some foretaste of what is to come this afternoon.
   MR RAMPTON:  I am not saying he must read it.  But it might
be
        helpful if he did.
   MR JUSTICE GRAY:   We will adjourn now and resume at 2.00
pm.
                       (Luncheon Adjournment)
                     MR DAVID IRVING, continued.
                  Cross-Examined by MR RAMPTON QC, continued.
   THE WITNESS:  My Lord, before he begins his cross-
examination
        on this, can I make a few general observations on
these
        documents?
   MR JUSTICE GRAY:  What difficulties you are going to have
        dealing with them, or what?
   A.   I would draw attention to three general observations
which
        I may not have a chance to make when we go through
them
        document by document.
   MR JUSTICE GRAY:  I think that is fair, Mr Rampton.
   MR RAMPTON:  It is what?
   MR JUSTICE GRAY:  Fair that he should do so now before
going
        through these various documents.
   MR RAMPTON:  I did not hear, I was looking for documents.
   MR JUSTICE GRAY:  He going to make three points and I am
going

.          P-99



        to allow that to happen?
   A.   General observations, and please interrupt me if you
think
        they are wrong.  Obviously, some of them I am familiar
        with because they come from my own records, some of
them
        I am not.  I am unhappy about the elipses, the
passages
        that have been left out. I do hope we will have a
chance
        to see the whole document rather than just these
        abbreviated versions.
   MR RAMPTON:  Oh, yes, carry on.
   A.   In general, of course, there are much larger elipses
which
        are the material surrounding the documents, if I could
put
        it like that, which are not represented here.
   MR JUSTICE GRAY:  Yes.
   A.   The second observation I would make, my Lord, is this.
        Bear in mind all along that we are now 55 years down
the
        road since the end of World War Two and we are
entitled to
        expect a better quality of evidence and documentation
from
        the archives than would have been accepted, say, in
1945
        or 1946.  This is the standard I have always held in
front
        of myself.  I say to myself if, even now, there are no
        better documents than this, therefore we have to be
much
        more careful about how we assess these documents that
are
        put to us.  We are no longer entitled to jump across
from
        mountain peak to mountain peak.  We have to say that,
if
        there are no other documents, then there is probably a
        reason why there are no other documents.  That is the
sum

.          P-100



        total of the observation I wish to make.
   MR JUSTICE GRAY:  Thank you very much.
   MR RAMPTON:  As to that last point, Mr Irving, jumping from
        mountain peak to mountain peak may sometimes be
        necessary.  Sometimes one can do it because one knows
what
        is lying on the ground in between, and there is
nothing
        the matter with that, is there?
   A.   Yes, from one's general expertise.
   Q.   No, no, the general array of evidence.  Mr Irving,
never
        mind that for the moment.  It is the fact, is it not,
        perhaps I am wrong but I do not think so, I think you
said
        it several times in this court, what I might call the
        residue of German wartime documents that we have got,
        whether from the bottom fighting units, police units
or
        whatever, right up to the top, is fragmentary?
   A.   I would say on the contrary, it is there in
embarrassing
        superabundance.
   Q.   We have everything, have we?
   A.   There is such a volume of documentation that in the
United
        States they still have not finished cataloguing it.
They
        are still working on it and usually the Germans create
        multiple copies of the documents that they are dealing
        with.  So, if they had destroyed in one place, they
would
        exist in another.
   Q.   So, unless a document has been deliberately destroyed,
        which it might well have been, one could expect to find it

.          P-101


        somewhere at some stage in the future near or far?  Is
        that right?
   A.   I would have expected to have found it in the past,
        frankly, at least one copy of it.

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