Archive/File: people/i/irving.david/libel.suit/transcripts/day020.13
Last-Modified: 2000/07/24

   Q.   For example -- I do not want to go over old ground --
        the Baltic States and so on?
   A.   Let us leave the Baltic States out of it.  What you say is
        that "maybe the chairman of St Martin's Press was right
        when he said this book suggests they (the Jews) had it
        coming to them, maybe I did not make it plain enough and
        maybe I did not put enough distance between myself and Dr
        Goebbels, or maybe I did not put in all the
        arguments, counter arguments, I should have done to be
        politically correct".  One notes that sneering phrase at
        the end there.
                  Then you go on in paragraph 55 to recount what
        you said in a meeting.  "I said", quoting you, "to a
        leader of the Jewish community in Freeport Louisiana, you
        are disliked, you people. You have been disliked for three
        thousand years.  You have been disliked so much that you
        have been hounded from country to country, from pogrom to
        purge, from purge back to pogrom, and yet you never asked

.          P-112


        yourselves what is it that the rest of humanity does
not
        like about the Jewish people, to such an extent" ----
   MR IRVING:  Witness, we have had all this so many times My
        Lord, if he is going to read these parts, he must read
the
        other parts as well.
   A.  "that they repeatedly put us through the grinder?" --
        I know you do not want this read out, Mr Irving, but I
am
        going to read it out.
   MR IRVING: I want all of it read out and not just your
        selection.
   MR JUSTICE GRAY:  Mr Irving, will you be quiet.  The
witness is
        trying to answer your question.
   MR IRVING:  He is not.  He is just wasting time.
   A.   "And he went berserk", you go on, this Jewish man.
"He
        said:  'Are you trying to say that we are responsible
for
        Auschwitz?  Ourselves?' And I said, 'Well, the short
        answer is yes'".
   MR IRVING:  "The short answer is yes".  And?
   A.   "The short answer I have to say is yes.  If you had
        behaved differently over the intervening 3,000 years"
----
   Q.   But you have left out bits, have you not, the whole
way
        through that?  You left out four passages from that?
   MR JUSTICE GRAY:  Mr Irving, we have been through all this
        before.  We are going to resume at five past two and
        I hope you will move on.
   MR IRVING:  With respect, my Lord, he should not have been

.          P-113



        allowed to read out the truncated version again.
   MR JUSTICE GRAY:  Five past two.
                       (The Luncheon Adjournment)
   (2.05 p.m.)
                      Professor Evans, recalled.
                  Cross-Examined by Mr Irving, continued.
   MR JUSTICE GRAY:  Yes, Mr Irving?
   MR IRVING:  My Lord, I anticipate that in the rest of this
        afternoon we will get through as far as the
        Reichskristallnacht and well into it, in fact.
   MR JUSTICE GRAY:  Good.
   MR IRVING:  That is certainly my aim.  In other words, we
will
        definitely manage that.
   MR JUSTICE GRAY:  Good.
   MR IRVING (To the witness):  Professor Evans, on page 171
you
        quoted this passage.  I am not going back to that
        passage.  I have one problem with that quotation you
gave
        us in paragraph 56 -- you provided no source for it?
   A.   Yes, that is oversight on my part.  The source is
given on
        page 7 of my answers to your written questions, your
        questions of 2nd January.  That is video tape 225,
        interview in Key West, Florida, 1996, just 33 minutes
into
        the interview.
   Q.   Tape 225?
   MR JUSTICE GRAY:  Have we got that?
   MR RAMPTON:  I am sorry, which one is it?  I am lost.

.          P-114



   MR JUSTICE GRAY:  Tape 225, Key West 1996.  Do you want us
to
        look at it, Mr Irving, for context or not?
   MR IRVING:  I will not delay the court.  Obviously, I
wanted to
        see what the context was of that and see if there had
been
        any omissions.  Professor, when you make omissions
from a
        document, do you always indicate it by ellipses?
   A.   Yes, of course.  You will find one there, in fact.
   Q.   Yes, it would be very sloppy not to indicate the
omission,
        would it not?
   A.   It would be a mistake, yes.
   Q.   And if I were to do that, of course, you would rightly
        criticise me?
   A.   That would depend on the circumstances.  It could
either
        be just an oversight, a misprint, or it could be
        deliberate falsification, depending on the
circumstances.
   Q.   I am anxious to try to shorten your answers.  I know
that
        the Welsh are famous for their loquacity, and I hope
that
        this will not be taken by Mr Rampton as yet another
        example of my racist predilections when I say that,
but
        your answers sometimes do tend to run overboard and
his
        Lordship has given me little assistance in this
matter.
   MR JUSTICE GRAY:  No, well, I think that is the sort of
thing
        you have to leave to me, Mr Irving.
   MR IRVING:  I am an unskilled cross-examiner, as your
Lordship
        is aware, and if you feel that the witness is
overrunning
        his time, I would be grateful if your Lordship would
be

.          P-115



        bring it to the witness's attention.
   MR JUSTICE GRAY:  Of course I will.  That is one of my jobs
and
        it has not happened yet though.
   MR IRVING:  I say that because we are now going to come to
        Madagascar briefly at paragraph 57 on page 172.  Can
        briefly say, in your view, whether the Madagascar plan
was
        not a feasible option when the Nazis talked of the
        Madagascar plan, whether it was a pipe dream or it was
a
        realistic project.
   MR RAMPTON:  Sorry, can I just interrupt?  Before we move
to
        Madagascar, my Lord, the reference is, in fact, in K4,
tab
        8.  It is an interview called Cover Story on 4th March
        1997, in fact -- that is the date of the programme.
It is
        an Australian television company, and the relevant
passage
        is at page 7 of that transcript.
   MR JUSTICE GRAY:  Thank you very much.
   MR IRVING:  Was Madagascar  ----
   MR JUSTICE GRAY:  I am sorry, can you pause again?  I have
a
        slight problem with my screen.
   MR RAMPTON:  K4, tab 8, page 7.
   MR IRVING:  In that case, before we come to Madagascar, in
view
        of the fact it was an Australian company I was talking
to,
        can I ask you one question?  Witness, what is the time
        difference between Florida and Australia,
approximately?
        Is it about 12 hours?
   A.   I have no idea actually.  I imagine, probably, yes.

.          P-116



   Q.   So if an Australian radio station is conducting a live
        interview in the day time, in fact, you are being
        telephoned in the middle of the night?
   A.   If it is a live interview.
   MR RAMPTON:  No, I am afraid again we have gone way off
course
        somewhere around the end of the world.  This is an
        Australian film crew travelling with Mr Irving in
America
        and doing the interview when they are there.
   MR IRVING:  Right.  In other words, this is another of the
        edited broadcasts which I shall have to pay attention
to.
   MR JUSTICE GRAY:  Mr Irving, if you want to make a point
that
        the context affects what you said about the Jews
bringing
        it on themselves, then, by all means, go to the full
        transcript.  You have been told where it is.  But if
you
        do not make that kind of point, then I think we really
        ought to get on to Madagascar.
   MR IRVING:  There would be a better time to do it, my Lord,
in
        view of the fact that your Lordship is anxious to make
        progress.  If I were to look at that transcript now, I
        would have to be provided with a bundle, look it up,
sit
        down and read it and we would lose at least 10
minutes.
   MR JUSTICE GRAY:  So Madagascar?
   MR IRVING:  Madagascar.  (To the witness):  Was Madagascar
a
        feasible operation, in your view?
   A.   On the basis of the continued British effective
command
        over the seas, it became clear well into the war that
it

.          P-117



        was not.  I mean, obviously, it requires the ability
to
        travel across -- this is the plan, the solution, the
plan
        to deport the Jews to Madagascar clearly requires
command
        over the seas.
   Q.   But if the war had come to an end and an agreement had
        been reached with Vichy France or whichever French
        government was in power?
   A.   This is getting into extremely hypothetical realms
because
        that makes assumptions about how the war might have
come
        to an end and then about international agreements, and
so
        on.
   Q.   I think the question I am really asking is did the
Germans
        regard it as a feasible operation or was it just
baloney?
   MR JUSTICE GRAY:  At what date?  I think that is the
relevant
        part of the question.
   MR IRVING:  At all relevant dates when Madagascar was
        discussed, in other words, from 1938 in, I think, June
        when it was first mentioned by Adolf Hitler to
Goebbels
        right the way through to July 24, 1942 when it
vanishes
        from the map of history?
   A.   I think they certainly took it seriously.  There is
quite
        a large amount of discussion about it in 1940 through
        1941.  I think it became increasingly clear in the
course
        of 1941 that the conditions were not right.  Of
course,
        the invasion of the Soviet Union changed the picture
        somewhat and I think by the middle of 1942 it
certainly

.          P-118



        was not taken seriously and references to it, I think,
can
        be regarded as camouflage.
   Q.   Were these discussions that you are talking about at
        Hitler's level as well?
   A.   Including at Hitler's level, yes.
   Q.   Including at Hitler's level.  At least for sometime,
in
        your view, the discussions were not baloney, they were
        meant seriously?
   A.   It certainly looks like that from the documents, so
        whether it was realistic is another matter, but they
        certainly took it seriously.
   Q.   Is it not difficult to reconcile that notion with a
Nazi
        ideological desire to exterminate all the Jews they
could
        get their hands on?
   A.   Well, as we know, the Nazi desire to exterminate all
the
        Jews they could get their hands on only became, at
least
        it grew in the course of war.  I think while -- there
are
        really two answers to that.  One is that the
systematic
        extermination of the Jews did not begin until well on
into
        the autumn of 1941, and about the time in which the
        Madagascar plan began to, as it were, take second rank
and
        then began to fade away.
                  Secondly, of course, I do think that one has
to
        remember that the Madagascar plan, such as it was, I
do
        not think it was ever seriously worked out in detail,
was
        one which deported the Jews across the seas in, one

.          P-119



        presumes, extremely poor conditions, and just dumped
them
        on a large, somewhat inhospitable tropical island in
        conditions that were entirely unsuited to sustaining a
        large society of millions of Europeans.
   Q.   Would those conditions have been worse than in a slave
        labour camp like Auschwitz or better?
   A.   I do not accept that the conditions in the slave --
sorry,
        I do not accept that Auschwitz was simply a slave
labour
        camp.  That is the first thing I would say.  The
second is
        that it is very conjectural, but they may well have
been
        comparable certainly in terms of disease,
malnourishment.
        It is sort of a parallel in a way to the
ghettoization,
        I think.
   Q.   Do you accept that the population of Madagascar has
grown
        from around 2 million in 1938 to 13 million now?
   A.   I do not see what the relevance that is to -- of that
is
        to Nazi plans in 1940 and '41.
   Q.   The final question on this field.  What you are
saying, in
        other words, is that Nazi ideology towards
exterminating
        the Jews changed sometime in 1941 from getting them
out of
        sight, effectively, to exterminating them?  Is that
what
        you are saying, there was a change in their ideology?
   A.   There is a sort of continuum.  I think that Nazi
        anti-Semitism always had its murderous elements, as
became
        clear immediately on the invasion of Poland or,
indeed, in
        the Reichskristallnacht and so on.  But the systematic

.          P-120



        extermination of European Jews was a policy that only
        gradually became formulated in the course of 1941 and
the
        early months of 1942.
   Q.   Would you turn now to page 173?  We will just look
very
        briefly at your four central tenets of Holocaust
denial.
        You think that to be Holocaust denier, you have got to
be
        somebody who says that the number of Jews killed by
the
        Nazis was far less than 6 million?  Is that one
criterion?
   A.   That is, yes.
   Q.   I am not quite clear about the criteria.  Does one
have to
        be a member of each of these four groups or any one of
        them?
   MR JUSTICE GRAY:  I think we have had this before and the
        answer is, no, you do not have to be a subscriber to
all
        four views.  You can, as it were, adopt one or two of
them
        and you can hold them in a full-blooded way or less
so.
   MR IRVING:  So any one would qualify you to be the title.
   MR JUSTICE GRAY:  Professor Evans, you have dealt with this
        before in your evidence?
   A.   I have dealt with this before -- it is on the transcript,
        my Lord.
   MR JUSTICE GRAY:  It is on the transcript.
   MR IRVING:  Yes, but if his Lordship is right, then his
        Lordship is, effectively, saying that anybody who says the
        figure is not 6 million but 5 million or 4 million is a
        Holocaust denier.

.          P-121

   MR JUSTICE GRAY:  I am not saying anything.  I am saying what
        Professor Evans said yesterday.
   A.   If I may say, sir, what I argued was that you really need
        all four.

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