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Shofar FTP Archive File: people/i/irving.david/libel.suit/transcripts/day019.06

Archive/File: people/i/irving.david/libel.suit/transcripts/day019.06
Last-Modified: 2000/07/24

   Q.   Then you left out the explanatory bit?
   A.   No.  "Even the most erudite and hard working historian", I

.          P-47

        say, "is never going to obtain 100 per cent truth.  He is
        only going to approximate it", and that, I think, gives
        the sense of what you are saying.  I come back to the
        point, I echo the point that you have made about your own
        work, this report is already 740 pages long, and in this
        quotation, I think I give the essence of what you are
        saying there.
                  Moreover, of course, I do put the ellipse in,
        three dots, to tell the reader that I am leaving something
        out there so the reader can do, as you have done, go back
        and cheek the speech and see if I have left anything out
        that I should not have left out.  That is not the case in
        quite a number of the cases in which you abbreviate
        quotations from the original sources, as I have shown in
        my report.
   Q.   Yes, but ----
   MR JUSTICE GRAY:  But it is fair to say Mr Irving does go on
        really to say he is one of those writers who does try to
        get the extra 10 per cent and get 100 per cent accuracy?
        I think that is the burden of the passage as a whole.
   A.   Yes, indeed, yes.
   MR IRVING:  Unfortunately, not everyone has our patience to go
        and look up the original document to see what has been
        replaced by the three dots.  There is another passage,
        while you still have that H1 in front of you, please, can
        I ask you to go to page 106 of H1(i)?  This has a rather

.          P-48

        more important kind of material that has been left out of
        the indented paragraph?
   A.   Yes.
   Q.   In the middle of page 41 of the expert report, my Lord.
   MR JUSTICE GRAY:  Yes, I have it.
   MR IRVING:  Your Lordship will see that the witness has omitted
        all the reference to the organized campaign of window
        smashing and so on that went on around this country to
        persuade Waterstones not to stock my books and other
        booksellers.  He then goes on to mock me for
        that there is a campaign, having cut out the material
        relating to it out of the quotation.
   A.   Sorry, where do I mock you?
   Q.   Page 42 at 254:  "Irving does not appear to believe
        other historians can rise to the challenge; rather he
        believes that there is an international campaign
        by the Jewish community in many countries to stop him
        speaking and selling his books"?
   A.   Well, that is my sense of what you believe.  I do not
        anything mocking in that.  I am trying to convey your
        point of view there.  Once again, of course, in this
        passage that you mention, there are ellipses to denote
        that I have omitted some material, and really what I
        trying to do here is to describe your view of history.
        I am not really concerned with all the details that
        give here about the campaign which you allege is being

.          P-49

        conducted against your work.  That is not what I am
        concerned with.
   Q.   Here you go on about the campaign I allege has been
        conducted against my work, but you have deprived his
        Lordship of knowing details of what that campaign is;
        fact that there was an organized campaign of window
        smashing in the big book stores to persuade them not
        stock my books.
   A.   How is that relevant to my report?  I really do not
   Q.   Because you say (as you have just said) that I allege
        there is a campaign and you say in paragraph 2.5.4
        I seem to believe that there is a campaign to stop me
        selling my books, and yet you have cut out of that
        quotation concrete evidence of the campaign that has
        going on?
   A.   But it is not my concern in this report to deal with
        campaign.  I have given your view here that there is a
        campaign, and I think in the context of a report which
        about your treatment of historical subjects, that that
        enough.  If I went, if I had gone in this report into
        every issue like that, it would have been enormously
        and I really do not think that is relevant to what was
        asked to do.
   MR RAMPTON:  I should intervene.  Mr Irving actually
        the report.  It is only so that it gets on the

.          P-50

        transcript.  The report actually did not say "he seems
   MR JUSTICE GRAY:  "He believes".
   MR RAMPTON:  It says "he believes".
   MR JUSTICE GRAY:  I did notice that.
   MR IRVING:  If had omitted any reference to book burning
from a
        passage about the Nazi activities in 1933, that would
        been duplicitous, would it not?
   A.   It depends what you are trying to write about the Nazi
        activities in 1933.
   Q.   They were suppressing books that they disapproved of.
   A.   If you are writing a dissertation about the Nazi
        towards the Civil Service or the Nazi policy towards
        Bau(?) in 1933, then I do not think book burning would
        necessarily have been a relevant consideration.
   Q.   If I had omitted the book burning in Berlin in March
        from my Goebbels' biography, then this would have been
        duplicitous, would it not, and if I had just said,
        that did not really belong"?
   A.   That is certainly true since Goebbels was centrally
        concerned with it.
   Q.   If I had omitted the window smashing, which is very
        apposite, from the Kristallnacht, that would also have
        been duplicitous, would it not?
   A.   Absolutely, yes.
   Q.   So why is it not duplicitous that you omitted that

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        from that passage you quoted?
   MR JUSTICE GRAY:  I understand your point, but the fact is
        paragraph 254 Professor Evans does refer to your
        that there is an international campaign to prevent you
        from speaking and selling your books.  So he is not
        actually concealing it, is he, in his report?  Anyway,
        I understand the point, but let us go on to the next
   MR IRVING:  Many paranoid people have beliefs which are not
        supported by evidence, my Lord, but if there is a
        of window smashing which is in the discovery, which is
        the documents before the court, the witness should not
        have cut it out of the part that he quotes.
   MR JUSTICE GRAY:  I understand that is the criticism you
        of him, yes.
   MR IRVING:  That is my submission.  That I regard as
        all the adjectives that have been heaped on me by this
                  (To the witness):  In that same paragraph,
        we are back to your report, Professor.  You say:
        does not appear to believe that other historians can
        to this challenge, rather he believes there is an
        international campaign ordered by the 'Jewish
        (our traditional enemies)'"?
   A.   Yes.
   Q.   What entitles you to equate those two as though I had

.          P-52

        that the traditional enemies of the truth or free
        are the Jewish community?
   A.   Well, on your website you list, you have a section
        you list the traditional enemies of free speech.
   Q.   Which includes the Jewish community leaders, yes.
   A.   Nearly all of them.  I think there is only one
        organization there which is not a Jewish organization.
   Q.   But you put the words "Jewish community" in quotation
        marks as though you are taking it out of some document
   A.   I did not want to imply that there was a Jewish
        in that sense.  That is why I put it in inverted
   Q.   You refer quite correctly to my website where I have a
        menu of traditional enemies of free speech, some of
        are specific organizations which are Jewish in
        That is correct?
   A.   Nearly all of whom -- all apart from one.
   MR JUSTICE GRAY:  Have you got the reference for this
either in
        your own report or in the website file because I would
        quite like to see it if the point is being taken.  It
        difficult ----
   MR RAMPTON:  My Lord, I ----
   A.   It is page 168 of my report, my Lord, where I detail a
        number of cases where Mr Irving has equated -- I quote
        here a speech in 1992:  "'Our old traditional enemies
        (are) the great international merchant banks are

.          P-53

        controlled by people who are no friends of yours and
        mine', who were 'annoyed' friend by" ----
   MR IRVING:  What paragraph is that?
   A.   168, paragraph 50.
   Q.   Is there an ellipsis in the middle of that?
   A.   Yes.
   Q.   Will you please look at the document and see the four
        sentences, three fullstops, four semi-colons and 86
        that those three dots represent?
   A.   Could you direct me to ----
   Q.   And see if that is a genuine quote?
   A.   --- the document, please?
   MR JUSTICE GRAY:  Yes.  That is fair.
   MR IRVING:  That is the document, I am very familiar with
   A.   Could you direct me to it, please?
   MR IRVING:  This is highly illuminative and illustrative of
        this witness's methods.
   MR RAMPTON:  I think it is the Clarendon Club.  I think
        Lordship has probably already seen that, in fact.
        Unfortunately, mine is not here.
   MR JUSTICE GRAY:  D2(ii).
   MR RAMPTON:  Yes.  It is K4, tab 5, Clarendon Club.
   MR JUSTICE GRAY:  I am not sure this is actually going to
        the answer to the question, but that may be wrong.
   MR IRVING:  The question is what do those three dots

.          P-54

   A.   K4?
   MR RAMPTON:  K4, tab 5.
   A.   Yes, 5, I have that.
   MR RAMPTON:  This is the Clarendon Club in September 1992
        I think is the reference we have here?
   A.   "Our old traditional enemies".
   MR JUSTICE GRAY:  Bottom of page 3 of 13.
   A.   Yes.  Right, shall I read that out, if you would not
   MR IRVING:  My first question is ----
   A.   May I read that out then?
   MR JUSTICE GRAY:  He is just going to read it first and
        ask the question.
   A.   It is about Andrew Neil, the Editor of the Sunday
        and the Goebbels' diaries which he was publishing in
         -- from you, and that he had come under pressure
        our traditional enemies, pressure not just from the
        advertising industry, pressure not just from the
        self-appointed, ugly, greasy nasty, perverted
        representatives of that community, he came under
        from the international community too because the
        Times, like many other newspapers, needs international
        capital to survive and the international capital is
        provided by the great international merchant banks,
        the great international banks are controlled by people

.          P-55

        are no friends of yours and mine'".
   MR JUSTICE GRAY:  That appears to be Andrew Neil speaking.
   MR IRVING:  What I am looking at is what those three dots
        represent which is not just ----
   MR JUSTICE GRAY:  Pause a moment.  We will get to that in a
   A.   I take that to be Mr Irving's paraphrase and version
        gloss on what Mr Neil was saying.
   MR JUSTICE GRAY:  So the answer is yes, but it is a gloss?
   A.   A very heavy gloss, my Lord, I think, and it goes on
        say, "And Andrew Neil found that these 60 foot long
        posters had annoyed these people, and they put immense
        pressure on him, and we know this because from all
        the world I have been getting press clippings", and so
        and so forth.
   MR IRVING:  Where do the three dots end and the sentence
   A.   "'... are the great international'" -- "our old
        traditional enemies are", it is three lines up from
        bottom of page 3 and the sentence resumes four lines
        from the top of page 4, so that is, five lines are
   Q.   My point is, my Lord, that when you see three dots in
        middle of a sentence like that, you are entitled to
        that a few words have been left out of a sentence, not
        that two words have been taken from one sentence and

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        sentences later they have been glued on to.
   MR JUSTICE GRAY:  Well, I think the point, and bear in mind
        are not really concerned with your criticisms of
        Evans, rather the other way round, but the point is
        whether anything has been left out that materially
        what is quoted.  It seems to me that in this
        instance what has been left out by Professor Evans
        makes no difference.  Indeed, in many ways he might
        made his point more strongly if he had put in what he
        left out, the reference to "the self-appointed, ugly,
        greasy, nasty, perverted representatives of that
   MR IRVING:  I agree, my Lord, but my point is that if I had
        adopted that kind of abbreviation in a paragraph, and
        had cut out three or four sentences, full stops,
        semi-colons and 86 words and replaced them by three
        it would have been completely reprehensible and it
        have been rightly pounced on by all the witnesses in
   MR JUSTICE GRAY:  I would not have thought it was reprehensible
        unless it did some injustice to what remains quoted.
   MR IRVING:  If I can put it another way?  If I were an editor
        in a reputable publishing house and I caught one of my
        authors doing that, then I would sit on him like a tonne
        of bricks and say, "You cannot do this".

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