Archive/File: people/i/irving.david/libel.suit/transcripts/day019.03
Last-Modified: 2000/07/24

   MR IRVING:  Oh, very definitely, my Lord, I submit.  I have
        already suggested it in connection with the Hamas and
        Hisbollah allegation; I have been exposed to very severe
        risks.  In connection with being accused of being a
        Holocaust denier, I have been exposed to the risk of what

.          P-19

        happened to Professor Faurisson.  His jaw was smashed so
        badly, it was wired together for six weeks and he had acid
        poured in his eyes, and he was a man slightly older than myself.
   MR JUSTICE GRAY:  I think I have tried to explain to you
        earlier that all this sort of thing can be relevant to
        damage, but it has to be linked to the Defendants.
   MR IRVING:  I shall be making a submission on damages later on.
   MR JUSTICE GRAY:  Just bear in mind that that is the way I am
        seeing it.
   MR IRVING:  As this witness did refer to Professor Faurisson in
        terms of rebuke, I thought it appropriate to show him
        photographs of what happened to people who stick to
their
        principle at the other end of the scale.
   A.   I do not think you can make me responsible for what
        happened to Professor Faurisson.
   Q.   No.  Witness, you have read or your researchers have
read
        very large parts of my diaries and private papers and
        lectures and speeches?
   A.   Yes.
   Q.   Have you at any time in any of those readings come
across
        any evidence whatsoever that I was associated with the
        Hamas or the Hisbollah terrorist leaders or with Lewis
        Farakan, the notorious black American anti-semite?
   A.   Well, that was not what I was asked to do, so we did
not
        read them for that purpose.

.          P-20



   MR JUSTICE GRAY:  Even so, can you answer?
   A.   We read the material in order to, well, I am trying to
        explain that my expertise may be not very good at that
        particular level, there were other expert witnesses
who
        were asked to do that.  I did collect information
which is
        on page 174 and afterwards of my report, which is
about
        your connections with Holocaust deniers, and I did
find --
        I am trying to find it in my report -- connections
with
        Ahmed Rami, page 198.
   Q.   Can you tell the court what these alleged connections
        were?
   A.   Yes.  You appeared on the same platform as him in the
        so-called Leuchter Congress, 23rd March 1991.
   Q.   Is there any reason why I should have recognized Mr
Rami,
        in your opinion?
   A.   I think if one appears on a platform with other
speakers,
        one knows who they are.
   Q.   Is there any connection at all between this Mr Rami
and
        the gentleman, Mr Farakan that I mentioned, or the
        Hisbollah and the Hamas?
   A.   I have to claim that I do not have any direct
expertise on
        that.  I cannot say.
   Q.   Have you found any kind of correspondence between
myself
        and Mr Rami?  Has any been shown to you?
   A.   Not to my recollection.
   Q.   So apart from this ----

.          P-21



   A.   But, as I say, that is not what I was really looking
for.
        I am really concerned with looking at connections
between
        you and people whose main business is Holocaust
deniers.
   MR JUSTICE GRAY:  So the answer to the original question,
        whether you have discovered any links, as it were, is
no?
   A.   Is no, that is right.  That is not to say that there
is
        not any but...
   Q.   No, but you have not come across it?
   A.   I have not come across it, no.  I mean, he, Rami,
occupies
        about four lines of my report.
   MR IRVING:  Yes.  Is there any particular reason why you
        mentioned Rami in this connection?  Is he a terrorist
or
        an extremist?  I mean, to me, he unknown.  I know
nothing
        at all about him.
   A.   Well, I find that difficult to believe since you
appeared
        on the same platform as him in a meeting, a public
        meeting.  He is an extremist who runs an extreme
        anti-semitic website which I have looked at.
   Q.   When you say that he appeared on the same platform, do
you
        have photographs of him standing shoulder to shoulder
with
        me or are you just saying that he was there one day
and I
        was there the next day?
   MR JUSTICE GRAY:  Do you challenge having been on the same
        platform as him?
   MR IRVING:  I want to know what he means by this, my Lord.
   MR JUSTICE GRAY:  No, I am asking am asking you because you

.          P-22



        have to put your case, Mr Irving.  I mentioned that on
        Thursday.  Is it your case that you have never
appeared on
        a platform with Mr Rami?
   MR IRVING:  Never knowingly appeared.
   MR JUSTICE GRAY:  Never?
   MR IRVING:  If I can put it like that, my Lord.
   A.   I footnote video tape 201.
   MR JUSTICE GRAY:  Never knowingly appeared?  I see.
   MR IRVING:  Well, quite simply, because when is this video
        taped alleged to have been?
   A.   23rd March 1991.
   MR IRVING:  1991.  So it is nine years ago and this is
somebody
        who has, apparently, stood near me on a platform and
this
        is good as the connection gets?
   A.   Well, you were both speakers.  As I say, this is not a
        very important part of my report; it only occupies a
few
        lines.
   Q.   Will you turn to page 37 of your report, please?  We
are
        now moving on, my Lord.  Paragraph 244.  You talk
about
        the unreliability of Hitler's former aids as a source?
   A.   Yes.
   Q.   And, effectively, my gullibility in falling for
everything
        they said?
   A.   No.  I would not accuse you of being gullible, Mr
Irving.
   Q.   My lack of critical nous, shall we say, in accepting
what
        Hitler's Adjutants and secretaries and people have
told me

.          P-23



        -- is that the burden of that paragraph 244?
   A.   Critical intention, I think.
   Q.   Do you accept, however, that on numerous occasions I
have
        persuaded Hitler's private staff and the Adjutants and
        their juniors to reveal to me matters which were
against
        their interest, or against the interest of Adolf
Hitler
        which is probably more significant?  Do you accept
this is
        true?  Do you remember from The War Path where
Hitler's
        private secretary, Krista Schroeder, describes to me
on
        the night of the long knives, June 30th 1934, when
they
        returned to the Chancellery afterwards Hitler vanished
and
        had a shower?
   A.   Yes, I remember that.
   Q.   Do you remember what Hitler said to her when he
        reappeared, roughly?
   A.   Very vaguely.  You would have to remind me of the
exact
        words.
   Q.   "So Fraulein Schroeder, now I have had a shower and I
feel
        as clean as a new born babe"?
   A.   That is right.
   Q.   Do you feel that speaks highly for Adolf Hitler, that
he
        murders his closest compatriots and has a shower and
        washes himself clean?
   A.   No, I do not.  But you do say in a document which I
quote
        on page 604 that, once the former members of Hitler's
        staff, once you had won their confidence I think you
mean,

.          P-24



        they thought well now at last they were doing their
chief
        a service.  So it seem to be your view that you
persuade
        them that they were doing Hitler a service by talking
to
        you.
   Q.   I think the sense is that they were doing history a
        service.
   A.   That is not what you said.
   Q.   They were telling the story -- what are the exact
words
        that I used?
   A.   The exact words were, and I think you have reversed
the
        sense here a bit, once they had won your confidence --
        I think you mean once you had won their confidence --
and
        they knew you were not going to go and report them to
the
        State Prosecutor, they trusted you and they thought
well,
        now at last they were doing their chief a service.
   Q.   Yes.  How would they be doing their chief a service if
        they told me details of how Hitler had ordered the
        liquidation of the inmates of a concentration camp?
   A.   That is not what Krista Schroeder said, was it, to
you?
   Q.   I am giving specific examples now.  You said that
        I persuaded these people to talk, but that I then fell
for
        them, so to speak, and that I did not manage to use my
        methods, my oily greasy methods, shall I put it like,
in
        fact to get from them information against their self-
        interest which is what I contend I did.
   A.   Oily and greasy are not my words.

.          P-25



   Q.   They are words I put in -- I oiled these remarks out
of
        them, shall I put it like that?  If I put this one
example
        to you, that I persuaded an SS officer who was on
Hitler's
        staff to describe to me the meeting between Hitler and
        Himmler in April 1945, where Hitler gave the order to
        liquidate all the inmates of Buchenwald if they could
not
        be evacuated in time, do you remember that episode?
   A.   Yes, I do.
   Q.   Was that in any way -- did it reflect well on Adolf
        Hitler, do you think?
   A.   No, it certainly did not, but obviously there are some
        places in which they do reveal things, at which some
of
        them reveal things, which are not ----
   Q.   I will give you only one further example because I do
not
        wish to test his Lordship's patience but it is
important
        here because I am accused of having exonerated Hitler
and
        fallen for the Adjutants' wiles.  You are familiar
with
        the colour photographs that are in some of my books of
        Adolf Hitler's staff, are you?
   A.   Yes.
   Q.   Will you accept that these photographs were taken by
        Hitler's film cameraman whose name was Walter Frentz?
   A.   Yes.
   Q.   He described to me, did he not, a visit to the Eastern
        Front with Heinrich Himmler in August 1941 where they
        witnessed a mass shooting outside Minsk, to which
shooting

.          P-26



        you also refer of course, do you not?
   A.   Yes.
   Q.   This man Walter Frentz was present.  Are you aware
that he
        described to me in great deal at 2 o'clock one morning
the
        whole episode, including how Himmler told him to take
        photographs of the shootings, and other very vivid
        details?
   A.   Yes.
   Q.   Was that in any way in his own interest to tell me
that
        story?
   A.   We are moving slightly away here.  What we are talking
        about, of course, is their attitudes to, or what they
        report of, Hitler and Hitler's views, and in that case
it
        really does not apply to that.
   Q.   We will move on to Hitler's views in this connection
in a
        minute, but will you just answer my question?  If
Walter
        Frentz told me this story, how he was with Himmler and
        witnessed a mass shooting, and took photographs of it,
did
        that in any way reflect well on either himself, the
        witness, or on Adolf Hitler, for that matter?
   A.   I would think no, but then he might have thought
something
        different.
   Q.   If I now tell you that Frentz took photographs back to
        Hitler's headquarters and showed them to Hitler's
Chief
        Adjutant, and the Chief Adjutant said, "If you know
what
        is good for you, you will destroy these photographs,

.          P-27



        Mr Frentz", is this a significant contribution to a
        historical debate which I, with my methods, obtained,
do
        you think?
   A.   The answer is, if that is the case, then yes.  I am
not
        denying, Mr Irving, that your interviews with Hitler's
        former staff have contributed in some ways to
historical
        knowledge, not at all.
   Q.   So your judgment against me in that paragraph is
        overhasty, would you agree?
   A.   No, I do not agree.  I think, taken as a whole, your
        interviews with Hitler's staff, as I show in a chapter
of
        the report, are uncritical, and in some cases also
involve
        elements of falsification of what they actually said,
or
        of the nature of their sources that you used.
   Q.   I will come to those particular episodes later on, but
in
        general?
   A.   This is a general statement which is a conclusion
drawn
        from the detailed cases that I look at later on in the
        report.
   Q.   You have said that I used these statements only in the
        service of their chief, so to speak, and I did not put
in
        material from the Adjutants or the secretaries which
was
        unfavourable, and that I was uncritical in my
assessment
        of these sources, and I have given you three episodes
        where quite clearly I persuaded members of Hitler's
staff
        to reveal from their innermost memory things that they

.          P-28



        probably told nobody else.
   A.   Where do I say the things that you say I say?
   MR JUSTICE GRAY:  I do not think the word "always" is to be
        found, Mr Irving.  I think that is the difference between you.
   MR IRVING:  That is why I suggested that the phrase overhasty
        was probably justified, and overhastily rushed a judgment
        on me, which is not borne out by all the evidence my Lord.
   MR JUSTICE GRAY:  The evidence I think I am hearing from
        Professor Evans is that usually -- that may be an under
        statement -- you are portraying these Adjutants as having
        told you things which are in Hitler's favour, but
        sometimes not.  Is that a broad summary?

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