Archive/File: people/i/irving.david/libel.suit/transcripts/day016.09
Last-Modified: 2000/07/20

   Q.   Yes.  But in each one were they all the same size?
   A.   No, this is all four together.  Einsatzgruppen A was
        I think the largest at 900, Einsatzgruppen B was probably
        the smallest at 600.
   Q.   Their tasks were not just killing people, were they? They

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        had tasks?
   A.   Yes.
   Q.   Can you specify to the court what the other tasks of the
        Einsatzgruppen were, apart from killing people?
   A.   They were to, well, kill others than Jews.  They were to
        capture Soviet function areas, communist party members and
        they were to be killed, they were to secure left behind
        documentation, particularly trying to get NKPD documents
        or communist government documents, so they were to take
        likewise what was called all preventative measures against
        potential enemies.
   Q.   Rather like CIC after the Second World War?
   A.   Well to uncover if agents had been left behind the
        retreating armies.
   Q.   Rather like the CIC, the Counter Intelligence Corps of the
        American Army after the Second World War, except for the
        killing operations, of course?
   A.   I do not know what the CIC was exactly.
   Q.   Are you familiar with the Sonderkommando Kunsberg, for
        example, the operations they carried out raiding Foreign
        Ministry buildings after the fall of Prague and Belgrade
        and so on, capturing documents?
   A.   Securing documents was one function.
   Q.   Quite an important function, was it not, of the
        Einsatzgruppen?  They had an intelligence gathering function?

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   A.   They do not refer too often in the documentation.  This
        does not seem to have been a priority, but it was
        something, when they did it, they boasted about it.
   Q.   Professor, I disagree with you on that.  If you were to
        read the event reports of the Einsatzgruppen, you will
        surely find that their killing operations are only one
        paragraph, and that they have other paragraphs detailing
        in some detail, describing in some detail, the
        intelligence gathering operations in which they were
        involved and other routine police rear area operations?
   A.   The reports are very long and the killing of Jews is
        usually one section within that much longer report.
   Q.   Dealt with in a very callous manner, just 20,000 Jews were shot.
   A.   It is usually done fairly briefly.
   Q.   Have you ever tried to do a back of the envelope
        calculation on the feasibility of these killing
        operations, given the limited number of personnel who
        would have been available and the limited number of trucks
        that they had and the primitive nature of their trucks?
        Do you remember reading in any of these reports about how
        their horse drawn carts had broken an axle and that kind
        of thing?
   A.   I do not remember a report on a broken axle, but I do
        remember reports where they deal with manpower problems,
        so that by late July they have gotten permission to raise

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        auxiliary units in the area, that they often refer to the
        co-operation of the Army in providing people for cordons,
        that according to the preinvasion agreement between the
        Army and the SS, the Army was to provide logistical
        support so, when they needed extra trucks and this kind of
        thing, the Army was expected to provide them.  So that
        when we say that an Einsatzgruppen operation involved a
        kommando, that is not the only manpower that is involved.
        What we have found from the newer documentation from the
        Soviet Union is the degree to which the Einsatzkommando
        has since wanted to hog all the credit.  Now that we see
        more documents, we can see that others were involved too.
   Q.   The Soviet archives have been very important, have they
        not, the former Soviet archives?
   A.   They have been important in fleshing out what happened in
        the Soviet Union.  I do not think they have transformed
        our understanding of what happened elsewhere in Europe a
        great deal.
   Q.   I have read your report with enormous interest, because of
        course I am not a Holocaust expert, but I have shown
        particular attention to the sources that have been used,
        the archives in Minsk you refer to?
   A.   Minsk, Riga, Moscow.
   Q.   How long have these archives been available to the average
        run of the mill incorrigible revisionist historian who
        wants to go and do research in them, do you think?  Ten

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        twenty, thirty years or quite recently?
   A.   I have not worked in them.  Gerald Fleming, I believe, got
        into the Riga archives very early on, and he has kindly
        provided me with my first documents out of these areas.
        So that it was possible to get into some of them.  It was
        also possible in the Zentralstellar in Germany to look at
        copies of documents that they had gotten from the Soviet
        Union much earlier.
   Q.   In Potzdam?
   A.   No Ludwigsberg outside Stuttgart.
   Q.   West Germany?
   A.   Yes.  They had gotten what we now see, in a sense the
        cream of the crop.  They had in fact seen many of these
        documents and brought photocopies back to Ludwigsberg.  We
        had seen a number of the documents that then we found out
        were either in the secret archives or somewhere else.
        Historians could now see the whole pack.  What you had was
        the selection in Ludwigsberg of selected documents.
   Q.   Let me try to zero in what you just said.
   MR JUSTICE GRAY:  Before you do that, Mr Irving, I am so sorry
        to interrupt because I am trying not to.  It is difficult
        being interrupted, but I just want to see where we are
        getting with this.  We know that you accept that the
        Einsatzgruppen killed probably hundreds of thousands.
   MR IRVING:  We are looking at numbers, now, my Lord.
   MR JUSTICE GRAY:  Let me make sure I am understanding where we

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        are going -- killed hundreds of thousands of Jews.  It may
        well be that what you are suggesting at the moment is that
        those reports were exaggerated.  But surely, for the
        purposes of this case, what really matters is that going
        back to Berlin were reports giving the numbers that they
        gave, because at this stage in the case we are really on
        how high the knowledge went, and was there a systematic
        programme in place.
   MR IRVING:  I am very familiar with what Mr Rampton is trying
        to get out of this case, my Lord.
   MR JUSTICE GRAY:  Do not worry about what he is trying to get
        out of the case.  I want to make sure that I know where we
        going with the cross-examination.
   MR IRVING:  I will put my cards face up on the table then,
        which I was hoping not to have to do as early as this in
        the cross-examination.
   MR JUSTICE GRAY:  You must in order to answer my question and I
        am sorry to interrupt.
   MR IRVING:  We are looking at the August 1 1941 document.  That
        is at the bottom of this particular alley, the document
        with which your Lordship is familiar.
   MR JUSTICE GRAY:  That is rather my point.  I am sorry to
        interrupt you.  All right, maybe a lot of the Jews were
        fleeing over the Urals and they were being shot by the Soviets.
   MR IRVING:  That is not that document. The fleeing Jews and the

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        question of the killing capacities, the manpower, the
        personnel, the trucks base and so on, goes purely to the
        matter that Richard Evans has raised.  Your Lordship will
        be familiar with the fact that Richard Evans has suggested
        four criteria for what a Holocaust denier is.  A Holocaust
        denier is somebody who says Hitler did not know; a
        Holocaust denier is somebody who says the figures were
        less, and that is what this is about, that particular
        matter.  I am entitled to suggest that the figures have
        been exaggerated and now unfortunately the Professor knows
        precisely what I am after.
   MR JUSTICE GRAY:  All right.  If you concede as much as you do
        concede, I wonder whether there is a great deal of scope
        for debate on this particular topic.
   MR IRVING:  The figures are important, my Lord, I do suggest,
        because there was undoubtedly an appalling massacre on the
        Eastern Front.  I do not deny it.  No sensible historian
        does deny it, rather.  I am not going to be shot down by
        Mr Rampton for suggesting the figures are not as large as
        they have been made out to be and there is room to suggest
        that, whatever one has conceded, I rather dispute the word
        conceded, it is a position I have always adopted, the
        figures are smaller than have been commonly suggested.  I
        will not pursue this much further.
   MR JUSTICE GRAY:  No.  It is really just to clarify my thinking
        but thank you for that answer.  I appreciate that

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        dimension.
   MR IRVING:  Interesting though all this is, and nothing would
        please me more than to have a long conversation with
        Professor Browning, this is the court's time and I am
        acutely aware of that.
   MR JUSTICE GRAY:  That is what I am conscious of, too.
   MR IRVING:  Where was I?
   MR JUSTICE GRAY:  I am sorry, I interrupted your flow.
   A.   I believe we were talking about documents that an
        historian would have had access to in the 1980s as opposed
        to after 1989.
   MR IRVING:  Yes.  In other words, it should not really be held
        against a historian if he has not gone and worked in Minsk
        and Riga and these other places in your view?
   A.   A number of those key documents in fact were by the 1970s,
        and in the Zentralsteller some copies were in the
        Institute in Munich.  They are cited in books and at
        various conferences, and then we find that they were part
        of a larger file.  But many of the key documents were
        available before 1989.
   Q.   I understood you to say that the German official or
        semi-official historical institutes had privileged
        access to Russian collections which are not immediately
        made available to other historians?
   A.   No, not the historical institutes, the German judiciary in
        the process of trying Germans, most of which took place in

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        the 60s and 70s, did have access, and that they in turn at
        Ludwigsberg allowed historians to come and see their documents.

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