Archive/File: people/i/irving.david/libel.suit/transcripts/day018.16
Last-Modified: 2000/07/24

   Q.   --- I do not deserve to be called an historian?
   A.   --- reinforced by what I have read in the transcripts over
        the last weeks.  I thought it would be helpful to the
        court to outline my conclusions in advance, as it were,
        instead of keeping the court guessing and waiting as
it
        ploughed through my report.  But, of course, it is
        somewhat kind of upside-down, if you see what I mean?
I
        mean, this is, in a sense taking the conclusion in
        advance.
   Q.   Let us go now to page 26 where you talk about my
        publishing career, you say most of my books about the
Nazi
        leaders and Nazi Germany.  Are you familiar with the
book
        I wrote on the German atomic bomb project, which was
the
        first book ever written on that subject and which was
very
        highly praised by Nobel prize winner like Otto Haan,
Verna
        Eisenberg?
   A.   No, I am not.  I have not read that one.
   Q.   This book was not provided to you by the Defence
        instructing solicitors to form your judgment on?
   A.   Let me come back to the point, Mr Irving, that you
have
        written about 30 books, some of which are more
relevant to
        the issues which are at the centre of this case, and
        others and in the time available I am sure you would
agree

.          P-137



        I could not possibly read through them all, even with
a
        team with two research assistants working for me.
        Therefore, I selected the ones which I thought were
most
        relevant to the issues which are at the centre of this
        case.
   Q.   But you have allowed yourself, notwithstanding that,
some
        pretty sweeping judgments on my credentials, have you
not?
   A.   On the basis of what I read which I think is a fair
        selection.
   Q.   But at the end of that paragraph ----
   A.   Let me remind you, this a 740-page report.  There is
an
        enormous amount of detail in it, and it simply was not
        possible to go any further in the time available.
   Q.   But if you make seeping judgments about author's
entire
        corpus as a historian over a 39-year writing career,
and
        you say that he has not deserved the title of
historian or
        he is not a scholarship and all the rest of it, one
        assumes that you are familiar with all his works,
        including these ones which have not been the least bit
        controversial and attracted the highest praise from
people
        in positions to know?
   A.   No.  I make it quite clear in the report that I am not
        familiar with all of your works, that I have done a
        selection for the reasons that I have said, but ----
   Q.   You are familiar with my book on the Hungarian
uprising?
   A.   No.  That seemed so far away from the issues at the
centre

.          P-138



        of this case that it really was not one that I should
have
        read.
   Q.   But you do pass comment on it on page 27?
   A.   Yes, in this section, Mr Irving, I am simply trying to
        give a brief run down of what you have written.  That
is
        all I am trying to do.
   Q.   But in the process of running me down you might also
have
        paid attention to the book I wrote on the German
        Intelligence Service, the Forschungsamt, and on the
German
        Eastern Frontiers, the history of the German Eastern
        Frontiers, but they appear to have escaped your
attention
        also?
   A.   For the reasons I have said, I did not have time to
read
        all of your books.  However, as I say in the report, I
am
        quite satisfied on the basis of what I have read that
        reading more would only lead to the same kind of
        conclusions that I have drawn from what I have read.
   Q.   You comment on page 28 at the end of the first
paragraph
        on my website?
   A.   Yes.
   Q.   You say that it contains materials by myself or by
people
        who are congenial to me and views that are congenial
to
        me.  Is that a fair description?
   A.   Where do I say this?
   Q.   At the end of the first paragraph on page 28: "This is
        constantly changing", you say, "but it includes
lengthy

.          P-139



        documents and analyses produced or reproduced by
Irving
        himself as well as by others whose views are
congenial."
        In other words, what are you implying is I just have a
        gallery of claqueur?
   A.   No, not at all, Mr Irving.  This is a section in which
        I am trying to outline the availability of
documentation
        on which it is possible to base an assessment of your
        work.
   Q.   Are you not familiar with ----
   A.   I am saying that simply because, therefore, it is
possible
        to take this into account.  That is all I am saying
there.
   Q.   Are you not familiar with the fact that if you go to
my
        website you will find not only documents to support my
        cases, such as they are, but also opposing documents
        fairly and prominently displayed, and that I have
included
        links to all the hostile websites in the manner which
is
        now part of the courtesy and etiquette of the
internet?
   A.   Yes, and you include daily transcripts of this entire
        proceedings and indeed a copy of my own report.
   Q.   I have made it available.
   A.   But that is not the point I am trying to make here.  I
am
        simply trying to outline the fact that there is an
        enormous amount of material which was available to me
in
        writing this report.
   Q.   But you are not trying to make the point ----
   A.   It is not intended as criticism.  I am not night
trying to

.          P-140



        make the point that you do not produce any others.
That
        is not what I am arguing about.
   Q.   But the way you have written it implies that I only
print
        or reproduce or publish materials that are congenial
to
        me?
   A.   No, it does not.  I am sorry.  Let me read the
sentence:
        "The is", it is the website I am referring to, "This
is
        constantly changing, but it includes lengthy documents
and
        analyses produced or reproduced by Irving himself, as
well
        as by others whose views are congenial to him."  That
        follows a sentence saying he has also made his views
in a
        variety of, and so on, a frequent writer of letters to
        newspapers, all these books, that is all I am trying
to
        say.
   Q.   Where do you say in that paragraph that I also include
the
        views of those which are diametrically opposed to me?
   A.   It is not relevant to what I am saying there.  What I
am
        saying there is that there is a lot of material on
which
        to base an assessment of your work.  All I am saying
there
        is that your website is part of the basis on which it
is
        possible to assess your work.
   Q.   You appreciate that running a website costs a lot of
        money.  Is there any reason why I should put material
        which is opposed to my viewpoint unless I was
scrupulously
        fair in everything I do in public life?  In other
words,
        the exact opposite of what you described earlier in
your

.          P-141



        report as being unscrupulous and manipulative and
        deceptive?
   MR JUSTICE GRAY:  Can I put it this way, so we can perhaps
move
        on.  Would you agree that it is credible that Mr
Irving
        puts on his Internet website material which is opposed
to
        him, such as your report?
   A.   Yes, of course.  Obviously it is in the interests of
        getting more users for the website to give to do that
kind
        of thing.  I do not dispute that at all.  I am not
        criticising you at all.
   MR IRVING:  Moving on now to qualifications which is 2.2.1.
        You quite rightly say that in all the examinations I
took
        at school history was the only subject I flunked?
   A.   I do say that.
   Q.   Is that one of your lighter remarks rather in the vein
of
        the thing in the pornographic section?
   A.   Yes.  I just thought it was a nice quote.
   Q.   In fact you have four 'A' levels and I have nine. So
how
        does this shape itself?
   A.   I do not know how many years.  Did you do them all at
        once?
   Q.   I kept on plugging away.  If we now continue to where,
        looking at whether you have to be an historian to be
an
        historian, so to speak?
   A.   Yes.
   Q.   In your view, do you have to be an academic historian?
Do

.          P-142



        you have to have degrees to be able to write history?
   A.   No.  I say so here that this is not, I think, a
        particularly strong powerful criticism.  The work has
to
        be assessed on its merits.  There are, as I say, any
        number of ----
   Q.   Very reputable historians?
   A.   -- Reputable historians who do not have formal
academic
        qualifications.
   Q.   People like Walter Laqueur?
   A.   Or Tony Fraser, many people.  We are all agreed on
that.
   MR JUSTICE GRAY:  We are all agreed about this, so we can
pass
        on.
   MR IRVING:  My Lord, the point I am making is that
paragraph
        2.2.2 in the second line, having made that point and
very
        generously saying there is a good deal to say for this
        argument, he then goes on to say: "As he suggests in
the
        above passage, he has no academic as an historian".
   A.   Then I go on to say in the next sentence:  "Although
these
        are serious initial disadvantages for becoming a
        professional historian, there are plenty of examples
of
        reputable and successful historians whose lack of
formal
        academic qualifications is as striking as Irving's."
So I
        am agreeing with you.
   Q.   Sometimes your bias does come through, does it not?
If
        you go to the first line of the next paragraph, 2.3.2:
        "Irving tells anyone willing to listen that he is an

.          P-143



        expert historian".  That is a bit of a sneer there, is
it
        not?
   A.   I would be happy to withdraw that if you think it is a
        sneer.  It is nothing to do with your academic
        qualifications.
   Q.   When we are talking of withdrawing things, later on,
on
        line 4 of that paragraph, you have withdrawn quite a
lot,
        have not, where you put the three dots?
   A.   Let me have a look.
   Q.   Can you have a look, please, at the 1977 edition of my
        book Hitler's War?  Do you have it, my Lord?
   MR JUSTICE GRAY:  Yes, I have it.
   MR IRVING:  Line 4.  We will see exactly what you have left
        out.
   A.   I do not think I have it here.
   MR JUSTICE GRAY:  It can be provided.  It is the
introduction.
   MR IRVING:  Page xii.
   A.   I do not have xii here.
   MR JUSTICE GRAY:  There is a bundle which does not have the
        introduction.  Can you find one which does.
   A.   It has the introduction.
   Q.   That is where it is, xii.
   A.   Yes.  There are different editions of this book, my
Lord.
        I think that is the problem.
   MR JUSTICE GRAY:  Yes, but you have the 1977 edition?
   A.   Yes, I have it.

.          P-144



   MR IRVING:  I am terribly sorry, we are looking at the
wrong
        thing.  It is footnote five we should be looking at
and it
        is the speech in Victoria.
   A.   Yes.
   Q.   I am terribly sorry.
   MR JUSTICE GRAY:  Start again.
   MR IRVING:  I have written in the margin "Pure Gold" so I
think
        it is going to be worth looking at.  I have said:
"What
        is omitted?  Pure gold, read it out".  This is a
speech,
        is it not, that I made in Victoria on October 28th
1992 on
        the subject of freedom of speech, having been just
awarded
        the George Orwell Freedom of Speech prize and shortly
        before I was taken off by eight Mounted Policemen in
        handcuffs.
   MR JUSTICE GRAY:  Can the Defendants side produce a
reference
        for this?
   MR RAMPTON:  I am just trying.
   MR JUSTICE GRAY:  That is very kind.
   MR RAMPTON:  H1 (i), tab blank, page 29.
   MR IRVING:  You have made two omissions, have you not?
   A.   Can you point me to the page?
   MR JUSTICE GRAY:  Page 29, yellow tab.
   A.   Which is the page on which this statement occurs? .
   MR IRVING:  I am sorry, my Lord.  I should have come better
        prepared with the actual missing passages available.
   MR JUSTICE GRAY:  It is unusual that you are not.

.          P-145



   MR IRVING:  Would it be helpful if I passed on to the next
        one?
   MR JUSTICE GRAY:  I was going to suggest that.  They have
found
        it.
   MR RAMPTON:  Page 31, my Lord, third paragraph at the
bottom of
        the page.
   MR JUSTICE GRAY:  Thank you very much.  Page 31 in the
stamp at
        the bottom of the page.
   A.   Yes.

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