Archive/File: people/i/irving.david/libel.suit/transcripts/day021.02
Last-Modified: 2000/07/24

   Q.   Did you look in the equivalent collections which are in
        the Federal archives in Koblenz?
   A.   I believe we did, yes.
   Q.   Did you also look not just at the collections of documents
        which were in Munich but also at the collections of
        correspondence that I had donated to the Institute of
        History in Munich between myself and, for example, Adolf
        Hitler's private staff?
   A.   I think we did, yes.  We looked at as much as we could
        find in the time available.
   Q.   The time available was 18 months, is that right?
   A.   To write the whole report, yes, of which this is only one chapter.
   Q.   You had a large number of people, or relatively large
        number of people, working on your staff?
   A.   Two.
   Q.   It was probably several man years.
   A.   Two.  I had two people, Mr Irving.
   Q.   Again, it was several man years in the compilation of
        these particular aspects?
   A.   Well, not really, no, because everybody of course had
        other things to do at the same time.  None of us was
        working full time on this.
   Q.   Yes.  Do you think that any documents in my collection
        would have eluded your attention, or your researchers'

.          P-10

        attention?
   A.   I hope not, but it is always possible.
   Q.   It is always possible.  So, although it is possible that
        some of my documents on which I base my book may have
        eluded your attention, you quite boldly used these very
        repugnant words about my writing, about having distorted,
        manipulated and had no possible evidence, and this kind of thing?
   A.   If you can show me that there are important documents in
        your collections which run against what I have said, then
        obviously I will accept it.  I said I hoped that important
        documents did not elude our attention, and I have based
        what I say here and what I write here on the most thorough
        possible research in the time available.
   Q.   On balance, you disapprove of my method of relying to any
        great degree on the statements made either to me or to
        postwar investigators and historians and interrogators by
        the members of Adolf Hitler's private staff, is that
        correct?
   A.   We have been over this ground, Mr Irving.
   Q.   Well, let us go through it again.
   A.   This is later testimony, sometimes given many years after
        the event, and therefore has to be treated with caution on
        those grounds alone.  Other things being equal, as it
        were, one gives somewhat greater weight to contemporary
        evidence such as the Goebbels diaries.  And, in addition

.          P-11

        of course, we have already discussed this, members of
        Hitler's entourage had good reason not to tell the whole truth.
   Q.   You say that you attach great importance to Goebbels'
        diaries.  Would you look at footnote 2 on page 233 of your
        report, please?  You list there a number of these books
        that are on your shelves in your book lined cave where you
        do your writing, if I can put like that.  Do any those
        books show any sign of having used the Goebbels diaries?
   A.   I do not think that is a very fair question, Mr Irving.
        The point here is simply that I am introducing the section
        on the Reichskristallnacht.  I say in sentence to which
        that is a footnote:  "The episode is well-known to
        historians.  There have been many important and scholarly
        studies based on a painstaking examination of the original
        archival documentation.  These include two accounts by
        staff members of the Institut fur Zeitgeschichte in Munich
        and other detailed studies", and so on.  This is simply an
        indication to the court of the fact that this is a
        well-known episode about which historians are writing.
   Q.   Do you accept that every single item you refer to on that
        page, including all the books and all the well-known
        studies, and the work of historians at the institute, all
        emerged before I brought back the Goebbels diaries from
        Moscow relating to precisely this episode?  Therefore they
        are, to that degree, superseded, they are old hat?

.          P-12

   A.   I would not describe them as old hat, Mr Irving, and in
        any case the point I am making there is that this has been
        the subject of many studies over many years.  This is not
        something that has suddenly emerged into our knowledge
        with the Goebbels diaries.
   Q.   Now, you have relied in your footnote 1 on Hermann Graml
        (who I know personally).  He wrote that book in 1956, did
        he not?
   A.   Indeed, yes, that is right.
   Q.   Are you aware of the fact that I submitted my entire
        chapter on this Reichskristallnacht to Hermann Graml for
        his, not clearance, but for his edification and for him to
        comment on at the time I wrote the book?
   A.   No, I am not, no.
   Q.   But would you have expected to find that in the
        correspondence put before you in the discovery process?
   A.   I did not, no.  If it is there, it is there.  You can show
        it to me.
   Q.   Again the second source in footnote 1 is 1957 which is,
        what, 33 years old?
   A.   Indeed.  I am trying to establish here, Mr Irving, the
        fact that this is a well-known episode in history which
        has been studied over many years by many historians.  I am
        not saying that all these books are absolutely right or
        that they are the last word or that they are up-to-date.
        I am saying they are works by scholars which in their day,

.          P-13

        if you like, were advances of knowledge.
   Q.   And these scholars have nothing to learn from us
        revisionists then?
   A.   It depends what you mean by "revisionists".
   Q.   If somebody brought back from Moscow the Goebbels'
        diaries, would that not be a contribution to the
        historical debate?
   A.   That is something different.  You do not have to be a
        revisionist to bring back the Goebbels diaries from
        Moscow.
   MR JUSTICE GRAY:  Mr Irving, I expect you will come shortly,
        will you not, to what it is in Goebbels diaries that you
        say casts important light on the events of
        Reichskristallnacht?
   MR IRVING:  I am laying the groundwork for the
        cross-examination, my Lord.  I am establishing what this
        expert's credentials are for this particular matter.
        Professor Evans, you have worked for five years in Germany?
   A.   On and off over a period of about 30 years, yes, if you
        totted up all the times I had been there, I have not done
        it, but it would come to, I do not know, five, six years.
        It is difficult to say.
   Q.   But do you think that your knowledge of German is
        sufficient to understand all the vernacular and all the
        slang phrases and all the nuances?

.          P-14

   A.   Mostly, yes.  I would not say it was absolutely perfect.
        It is impossible for any foreigner to enter totally 100
        per cent into the inside of a language.
   Q.   Would you say that I having worked in Germany for 39 years
        on and off would have possibly a better knowledge of
        German than yourself?
   A.   It is possible and I do not dispute the fact you have a
        very good knowledge indeed of German, Mr Irving.
   Q.   Is it right that the sources that you have relied upon by
        way of preference are largely war criminals who were
        properly convicted at Nuremberg and elsewhere for their
        activities, whereas not one of Adolf Hitler's personal
        private staff was ever convicted as a war criminal?
   A.   No, I do not think that is true.
   Q.   Which part is not true, that not one of Adolf Hitler's staff ----
   A.   No, no.  The fact that I have relied on these sources and
        in any case that -- I mean, relied, for example, on the
        Goebbels' diaries.
   Q.   Was Karl Wolff a war criminal?
   A.   He was sentenced in 1964.
   Q.   Was Max Jutner a war criminal?
   A.   Now, I am not sure, but in any case the point here --- -
   Q.   I am just commenting on the odd feature that you rely on
        Nazi war criminals and ----
   A.   You will have to point out to me, Mr Irving, where I rely

.          P-15

        on the testimony of Max Jutner, and so on.
   MR JUSTICE GRAY:  I think, if I may say so, that is an entirely
        fair observation.  I quite understand the criticism.  You
        are saying he has relied on convicted criminals for -- --
   MR IRVING:  In preference to people who have not got a criminal
        record.
   MR JUSTICE GRAY:  --- his contentions.  But let us get to the
        nitty-gritty of it.  I think that is what the witness is
        saying and I think it is a fair point, if I may say so,
        Mr Irving.  Where does he rely on Wolff?
   MR IRVING:  It is a comment on the quality of sources, my Lord,
        and the quality of sources is very important, particularly
        in a matter like this.
   MR JUSTICE GRAY:  I quite agree, but this point only has any
        impact if you show me where he relies on Wolff or
        whoever  ----
   MR IRVING:  It is where I rely on rather than where he relies
        on, my Lord, which we are now going to come to.  Would you
        look at the little bundle of documents which was handed to
        you this morning which begins with the word "Deckblatt",
        "Sammlung Irving Deckblatt", do you find that?
   A.   Yes.
   Q.   If you would just briefly scan it you, would you agree
        that this appears to be the covering sheet of a file of
        documents relating to one Wilhelm Bruckner?
   A.   That is right.

.          P-16

   Q.   Do you know who Wilhelm Bruckner was?
   A.   He was the head of Hitler's, a sort of personal or
        adjutantur in the 1930s.
   Q.   He was dismissed in ----
   A.   '40.
   Q.   --- humiliating circumstances in December 1940, is that
        correct?
   A.   Yes.  He was also a senior officer of the SA, the brown
        shirts, and he was an old Nazi -- he seems to have been
        already active before 1923.
   Q.   Yes.  So that he was Hitler's chief person adjutant at the
        material time, namely the Reichskristallnacht?
   A.   That is right.
   Q.   In November 1938?
   A.   Yes.
   Q.   From this covering sheet, it is evidence that I collected
        a number of papers and manuscripts and affidavits and
        letters from him?
   A.   That is right.
   Q.   In fact, this collection was obtained by me from his son,
        Manfred, in March 1971 and, as was my way, I denoted all
        these documents to the Institute of History in Munich?
   A.   Yes.
   Q.   Did you find this file of documents?
   A.   Now, what we found was a summary of a statement by,
        I mean, you are referring here to page 252 of my report,

.          P-17

        is that correct?
   Q.   I am asking you just about this one document in front of
        you at present about the Irving collection?
   A.   Well, yes, but Bruckner is dealt with on page 252 of my
        report, and I think we should really look at that to get
        the context.
   Q.   No, I am asking you to answer my questions first please
        which is ----
   A.   I am trying to point out the context here.
   Q.   --- have you bothered to find the Bruckner papers on which
        I relied in writing this passage?
   A.   Well, now, we tried to chase up a reference of yours which
        was very difficult to find in the Institute for
        Contemporary History, and the only thing that we could
        find, because you did not point very carefully to it, was
        a summary statement of what Bruckner said.
   Q.   So the answer to my question is, no, you did not find the
        file of Wilhelm Bruchner papers of which this was the
        covering sheet?
   A.   This "Deckblatt" here.
   Q.   Yes, but this covering sheet was actually brought to your
        attention, was it not?  It was part of my discovery along
        with 500 other such covering sheets?
   A.   It is just a covering sheet, Mr Irving.
   Q.   Yes, but in the discovery there were 500 such covering
        sheets, there were 500 collections of documents that

.          P-18

        I gave to the Institute of History, and this was one of
        them, and it was copied by the instructing solicitors so
        you were aware that this file on Wilhelm Bruckner existed
        in the Institute and yet you did not find it or use it?
   A.   Well, what does it say?  Let us have a look at the
        description under No. 1:  "Brief description" -- I am
        translating here [German- documents not provided].
         "Documents from the"...
   Q.   "Wilhelm Bruchner papers"?
   A.   "Papers of Wilhelm Bruchner, herein [German] ----
   Q.   In other words ----
   A.   "Declaration on oath 3749 on [German] SA on Adolf Hitler.
        Notice notes on the [German] Putsch 1934.  General
        religious considerations and" ----
   Q.   "Clemency" ----
   A.   --- "clemency" ----

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