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Last-Modified: 2000/07/24

     MR IRVING:  You are not claiming to be an expert on Goebbels
     and his relationship with Hitler, are you?

     A.   We have been through the nature of my expertise right at
     the very beginning, Mr Irving.

     Q.   You are not claiming to be an expert on Goebbels and his
     relationship with Hitler, are you?

     MR JUSTICE GRAY:  I think in these pages he necessarily is
     claiming that.

     MR IRVING:  Very well.  Are you aware of how often Dr Goebbels
     was with Hitler each year around this time?  Would it be
     five or ten or 20 times a year?

    A.   I have not counted, Mr Irving.  You tell me.

    Q.   The answer is you have not any idea, have you?

    MR JUSTICE GRAY:  That is gratuitous.  Put the number of times.

    A.   It seems from the diary entries that I have read to have
    been fairly frequent over the years.

    MR IRVING:  Fairly frequent.  What do you mean by fairly

    A.   Would you like to put to me a number?  I have not counted,
     Mr Irving.  What I am doing here is writing not so much
     about Goebbels and Hitler but about your account of
     Goebbels and Hitler.  That is the purpose of my report.

    MR JUSTICE GRAY:  Mr Irving, if it is your case that Goebbels
    was hardly ever seeing Hitler at this time, then I think

                                 .          30

     you ought to say so and, if necessary, give the number of
     times they would have net, or presumably spoken on the
     telephone, I do not know.

     MR IRVING:  Can you accept that Dr Goebbels, in the year 1942,
     saw Adolf Hitler about ten times all told?  I mean in

     A.   Ah, that is a different matter.

     Q.   As opposed to at mass meetings or something like that?

     A.   I do find it difficult to accept anything you say,
     Mr Irving, without looking at the documentary basis for it.

     Q.   That makes life easier for you, does it not, but can you
     just answer the question?

     A.   It does not.  It makes life a lot more difficult, actually.

     Q.   You do accept that I worked for 35 years on the Adolf
     Hitler book and I worked for nine years on the Goebbels
     biography, so that I am something of an expert on both

     A.   The question is how you worked, Mr Irving.

     Q.   Well, I am asking you a simple question.  How many times
     do you think Goebbels actually visited Hitler in 1941 and in 42?

     A.   I have and I am giving the answer.  I have not counted.
     My purpose here is to look at your account and your
     manipulation of this entry of 27th March to support your

                                 .          31

     argument that Goebbels was concealing information about
     the extermination of the Jews from Hitler.  That is my
     purpose here.

     Q.   Is it not the fact that, from 1939 onwards until 1944,
     after the bomb attempt on Hitler's life,
     their relationship can at best be described as distant?

     A.   No.  I do not really think that is true.

     Q.   In view of the fact that Dr Goebbels as the Minister of
     Propaganda visited Hitler only about ten times per year
     during those years, is not that a distant relationship?

     A.   We do not know how many times they spoke on the phone.

     Q.   Have you seen any references in the Goebbels diaries to
     telephone calls from Adolf?

     A.   Or to Adolf, no.  I think Goebbels had a good knowledge of
     what Hitler knew and talked about.  It occurs frequently
     in his diaries.

     Q.   If you express that opinion, you must have a pretty
     profound knowledge of Dr Goebbels, is that right?

     A.   Not necessarily, no.  I have read plenty of diary entries
     in which account -- these are the diaries entries I read
     in order to check up on the use you make of them.  That is
     what I have done here.

    Q.   Have you and your researchers read the entire entries of
    Dr Goebbels' diaries?

    A.   Of course not.  That would have been absolutely
    impossible.  It is an enormously long collection of stuff

                                 .          32

     and that is not what we had to do.  Our task was to look
     at the use you make of certain specific diary entries.

     Q.   Are you familiar from the correspondence that has been
     shown you in discovery that I invited various Goebbels
     experts, including Dr Frohlich and Dr Friedrich Karbermann
     and others who have worked on the Goebbels diaries like
     myself, whether they have come across one single entry
     which explicitly shows that Adolf Hitler was aware of the
     homicidal killings of the Jews in the Goebbels diaries?

    A.   Yes.

    Q.   The answer is no, there is no such entry?

    A.   I do not accept that.

    Q.   Have you not seen this correspondence?

    A.   No, sorry.  The correspondence yes, but I do not accept
    the conclusion that you make of it.

    Q.   You accept that they have read the diaries, unlike you, in
    their totality, but you do not accept what they say?

    A.   Ah, sorry.  I thought you were saying that is what you
    said.  Then in that case you have to show me a letter in
    Dr. Frohlich says that he has never seen such a----

    MR JUSTICE GRAY:  Let us short circuit this.  Are you aware of
    any explicit acceptance, or document which shows explicit
    knowledge on Hitler's part of the extermination programme?

    A.   Well, I think there is evidence in the diaries that he did
     know.  In this particular entry, when Goebbels says, "The
     Fuhrer is the persistent pioneer and spokesman of a

                                 .          33

     radical solution", what else can he mean, except some
     degree of extermination, 60 per cent extermination, or
     more?  He cannot mean at this stage, March 1942, that a
     radical solution is simply deporting them to the East.

     Q.   You read that entry, just to summarize it, as Goebbels
     saying that what Globocnik is up to is in accordance with
     what the Fuhrer wants done?

     A.   Hitler indeed has been a pioneer, persistent pioneer, of
     this radical solution.

    MR IRVING:  Do you agree ----

    A.   One can also look at the entry of 30th May 1942, which
     I cite at length in the letter of revision to my report
     that I sent on 10th January this year.  Here again,
     I think there is a clear indication that this is recording
     a meeting of Hitler with Goebbels, a meeting between
     Hitler and Goebbels, where at the first paragraph Goebbels
     says that he presents the Fuhrer with his plan to evacuate
     the Jews out of Berlin with none remaining, Hitler is
     completely of his view, says Goebbels, and goes on to give
     orders and so on.  "I plead once again for a more radical
     Jewish policy", this is on 30th May 1942, "whereby I am
     just pushing at an open door with the Fuhrer".

    Q.   You have left out quite bit, have you not?

    A.   Well, I will read the whole passage if you really want me
     to.  I am trying to short things a bit. He goes on in the
     next paragraph to then say, "An extermination of criminals

                                 .          34

     is also a necessity of state policy", thus implying quite
     clearly in the previous paragraph that he has been talking
     about the extermination of Jews.  So that is another
     indication to my mind.

     Q.   As you have raised this particular entry, will you go to
     the bundle I gave you this morning and turn to page 2?

     A.   Yes.

     Q.   It is sometimes quite helpful that you go off on these
     excursions.  Is that pages of the Goebbels diary?

    A.   Yes.

    Q.   My Lord, do you have this particular document?

    MR JUSTICE GRAY:  I do, yes.  Thank you very much.

    MR IRVING:  Is this diary a typescript diary on the large Adolf
     Hitler typewriter, or the large face typewriter?

    A.   It is certainly large, unless it has been enlarged.

    Q.   So this time Dr Goebbels was dictating the diary to his
     private secretary, Richard Otty, is that right, the

    A.   Yes, I think so.

    Q.   He did so since July 1941, did he not?

    A.   That is right, yes.

    Q.   So this is not in any sense a private diary any more full
         of top secrets.  It is an official diary he is keeping?

    A.   No, I do not think it is an official diary.  I think it is
         a private diary.  There are certain things that he might
         feel he cannot say in it, which he could say when he was

                                 .          35

     writing it down in his own hand, but it is still a private

     Q.   Was the Final Solution in its homicidal sense something
     that was top state secret, and not to be written down in
     private diaries or official diaries?

     A.   Which do you mean?  Official diaries or private diaries?

     Q.   Look at the first page, page 2 in my little bundle.  You
     will see that it starts off with, "Yesterday the military

     A.   Yes, he always start off like that.

     Q.   It does not look like a private diary, does it?

     A.   He always starts off with the military situation.  It is a
     private diary.  He keeps tabs on the military situation.

     Q.   On page 3, the last three lines, "The Fuhrer has returned
     from his headquarters to Berlin to speak to an officers'
     course in the Sports Palace".  So Hitler has come to
     Berlin and Goebbels grabs the opportunity to have one of
     his rare meetings with him?

     A.   Yes, that is right.

     Q.   The next page is the part you then began reading?

     A.   Yes.

     Q.   Page 4, line 3?

     A.   Yes.

     Q.   "I briefed the Fuhrer once more on my plan, to evacuate
     the Jews completely from Berlin"?

     A.   Yes.

                                 .          36

     Q.   Why does he have to do it "once more"?  Why did not Hitler
     leap at it and say, "Yes, sure, why are we waiting, what
     are we waiting for?"  Why does Goebbels have to keep on
     putting this to Hitler if there was any eagerness on
     Hitler's part to deal with the Jews?

     A.   Because some were remaining, and it is a new situation
     which seems to have emerged which has alarmed Goebbels,
     and which he goes on at some length about later in the

     Q.   Then he continues.  "It is entirely my opinion", gives
     Speers the job, "to take care as quickly as possible that
     the Jews who are working in the German arms factories,
     arms economy, are replaced by foreign workers"?

     A.   Yes.

     Q.   Then he continues with a piece you left out, "I see a
     major danger in the fact that there are still 40,000 Jews
     in the capital of the Reichs who would have nothing more
     to lose, who are running around free".

     A.   Yes.

     Q.   Is there not a provocation, and is it not just asking for
     assassination attempts, if that kind of thing happens,
     then you cannot sleep safely in your own bed?  That is
     roughly what it says, is it not?

     A.   That is right, yes.

     Q.   If I turn the page, we have now leapt forward.

     A.   Yes.

                                 .          37

     Q.   I think this is probably the part that you then begin
     quoting again.  Halfway down, "The Germans take part in
     subversive movements only when the Jews lead them astray
     to it.  That is why we have to liquidate the Jewish
     danger, cost what it may.  How little the Jews in reality
     can fit in or assimilate to the Western European life you
     can see from the fact that, when they are sent back into
     the Ghetto, they very rapidly become ghettoised again".
     So he is talking about a geographical movement, is he not,
     they are in Western Europe and we are going to have to
     kick them out?

    A.   Yes, but this appears to be taken from Table Talk.  The
     point about this entry is that it really subsumes two
     different conversations.  The first of these appears to be
     a private conversation between Goebbels and Hitler, where
     he says, "I once more present the Fuhrer with my plan to
     evacuate the Jews out of Berlin".

     Q.   What makes you think that this is ----

     A.   Sorry, this is quite explicit.  The bit you left out
     I will go on:  "Once these outrages or assassination
     attempts break out, then one's life is no longer safe".
     I will carry on reading.  "The fact that even 22 year old
     Eastern Jews took part in the latest fire bomb attack
     speaks volumes.  Thus I plead once again for a more
     radical Jewish policy whereby I am just pushing at an open
     door with the Fuhrer.  The Fuhrer has the opinion that the

                                 .          38

     danger will become greater for us personally the more
     critical the war situation becomes.  We find ourselves in
     a similar situation to that of the second half of 1932
     where bashing and stabbing were the order of the day, and
     one had to take all possible security measures to escape
     from such a development in one piece".

     Then he goes on in a new paragraph, still this
     conversation with Hitler: "The extermination of criminals
     is also a necessity of state policy".

    Q.   Yes, we have had that already.

    A.   Let me give the German.  The German gives actually a very
     strong feeling.  Auch die Ausmerzung der Verbrechers:
     Literally also the extermination of criminals.

    Q.   What does "ausmerzung" mean.

    A.   Here it means the extermination -- he goes on to say
     exactly what he means.

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