Archive/File: people/i/irving.david/libel.suit/transcripts/day023.19
Last-Modified: 2000/07/24

     Q.   Page 484, you write two-thirds of the way down: "Irving
         is, of course, aware of this exchange which suppresses it
         altogether".  What proof do you have in writing that I am
         aware of this exchange?

    A.   Because you used the Goebbels Nuremberg diary as a source.

    Q.   No, I did not.

    A.   Right, then "Nuremberg, the last battle" ----

    Q.   I have used one extract from the Gilbert book.


                                 .          180


     A.   Yes.  That is note 27 on page 143 of "Nuremberg, the last
          battle".

     Q.   Which is one extract from the Gilbert book which is the
          Julius Schreiber papers.  Does that mean to say that
          I have read the entire book?

     A.   One would presume so, yes.

     Q.   Are you aware that I had in fact Gilbert's original papers
          when I wrote the Nuremberg book?

     A.   Yes.

    Q.   Yes.  So, in other words, you assume something there which
         turns out not necessarily to be true?

    A.   Well, since you cite the book in your work, I assume you
         have read it.

    Q.   Yes, two lines from the bottom of that page you say,
          "Ribbentrop writing under duress in allied captivity"  ----

    A.   No, you say that.

    Q.   --- do you accept that he was writing under duress?

     A.   Sorry, you say that.  You say: "Special
         circumstances ... (reading to the words) ...  Ribbentrop
         writing under duress in allied captivity" ----

    Q.   But if you turn the page ----

    A.   --- "and facing an inevitable death sentence has to be
         borne in mind".  Well, he was in captivity, of course, and
         he was facing a death sentence.

    Q.   Are you familiar with the physical conditions that the


                                 .          181


          prisoners lived in at Nuremberg?

     A.   Yes.

     Q.   No table, no medication, no hygiene, no light, no
          spectacles and all the rest of it?

     A.   Well, I am not sure I accept all of that.

     Q.   Page 486:  Hitler's last will and testament, or his
          political testament.  This is the one he dictated on the
          last day of his life, is that right?

     A.   486 -- 5 to 6.

    Q.   5 to 6?

    A.   We may have slightly different pagination here.

    Q.   I am looking just at the first two lines.  My Lord, do you
         have that?

    A.   The last five lines of page 485 and first two of ---
-

    MR JUSTICE GRAY:  Last five lines on page 485?

    A.   Yes, the indented quotation, my Lord.

    MR IRVING:  I said page 486, the last...

    A.   Well, the first two of page 486.

     Q.   What do you think Hitler meant by the Jews "having to
         atone for his guilt", "the Jew having to atone for his
         guilt even if by more humane means than being burned alive
         in air raids", and so on.  What do you think he meant by  ----

    A.   Well, let us read the quotation.  "I also made it quite
         plain that if the nations of Europe are going to be
         regarded as mere shares to be bought and sold by those


                                 .          182


          international conspirators in money and finance, then
          Jewry, the race which is" -- sorry, "then, Jewry, the race
          which is the real criminal in this murderous struggle will
          be saddled with the responsibility.  I further", says
          Hitler, "left no one in doubt that this time millions of
          Europe's Aryan peoples would not die of hunger, millions
          of grown men would not suffer death, nor would hundreds
          and thousands of women and children be allowed to be
          burned and bombed to death in the towns without the real
         criminal having to atone for his guilt", that is the Jew,
         of course, "even if by more humane means".  I assume there
         he is saying it is not, I mean, it is not bombing and
         burning to death in the towns or dying of hunger.  It is
         shooting and gassing.

    Q.   So you think that he is referring there to the Holocaust,
         the Auschwitz, the gas chambers, the cyanide, the choking
         to death, all the horrible things that have been described?

     A.   Now, I am not saying I agree that it was humane; I am just
         saying he thought it was humane, or appears to say so here.

    Q.   Could it not equally ----

    A.   He was always, after all, and we have had several
         quotations today, congratulating himself on how humane he
         was towards the Jews.

    Q.   Does it not make for greater sense than this rather


                                 .          183


          plausible suggestion that the Holocaust was humane which
          is what you are proposing?

     A.   I am not proposing it.  It is Hitler who is proposing it.

     Q.   Which is what you are proposing is the meaning on this
          word, to be assigned to this word, that what Hitler is
          saying that, "We have had hundreds thousands, if not
          millions, of people burned alive, women and children, in
          our cities and we have just deported the Jews, booted them
          out to Siberia", or wherever he thought they had gone, and
         that is what he is referring to when he talks about them
         having had to atone for their guilt by more humane means,
         because the only other alternative is that you are
         accepting that the Holocaust was more humane?

    A.   No, that is not at all.  That is another classic example
         of the way you twist everything to your own polemical
         purposes.  I am not saying the Holocaust was more humane.
         I am not making a judgment at all.

    Q.   Or being machine gunned into pits?

     A.   I am simply quoting Hitler, and Hitler is saying that the
         Jews will have to atone for what he regards as their crime
         of having killed millions of Aryans through hunger,
         burning alive and so on, they will have to atone for it by
         more humane means which, I assume, he means, not explicit
         about it at all, he means gassing, possibly shooting.

    Q.   Well, the reason for that is, of course, you say there is
         a connection between that and the memorandum submitted in


                                 .          184


          July 1941 by Ralf Heinz Hupner who says, "Would it not be
          more humane to find some rapidly working means of
          disposing of the Jews rather than have them exposed to the
          privations of the winter?"

     A.   Where do I say that?

     Q.   This is on page 486 -- I am sorry, 489.

     A.   9?

     Q.   Yes.

     A.   Yes.

    Q.   Are you suggesting that the Hupner message was ever shown
         to or read by Hitler?  Was it not addressed to Adolf
         Eichmann?  Are you suggesting there is a direct causal
         link between the Hupner message and the Hitler ----

    A.   No, I am not.

    Q.   So just a bit of a smoke screen by you then?

    A.   No, it is not a smoke screen.  I am drawing attention to
         the parallel there as ----

    Q.   Or do you think ----

     A.   --- as evidence of a wider mind set.

    Q.   Or do you think that the reference to humanity or humane
         is, in fact, an allusion to the blockade that we, Allies,
         imposed on Germany in World War I and after World War I
         which resulted in the deaths of large numbers of Germans?

    A.   I see no evidence of that in this statement by Hitler.

    Q.   490, in paragraph 11, you cast doubt on the secretly
         recorded conversation between Ribbentrop and a British


                                 .          185


          officer?

     A.   No.

     Q.   Paragraph 11 on page 490?

     A.   No.  Where do I cast doubt on that?

     Q.   490?

     A.   Right, I have it, paragraph 11.

     Q.  "Irving claims he had a fund of collateral documentary
          evidence"?

     A.   Yes.

    Q.   And you then lament the fact that there is this secretly
         recorded transcript which does not seem to have been
         included in my list of documents, and so on?

    A.   Yes.  I am very cautious there -- conscious I might have
         overlooked it, but it does not seem to be there.

    Q.   You are not familiar with the XP series of transcripts
         which are in my files -- you accept that it is possible it
         was in the documents?

    A.   Well, that is why I have phrased it cautiously there.

     Q.   Page 491, paragraph 14, does that paragraph, far from
         being contradictory, not actually confirm that Ribbentrop
         asked Hitler and Hitler denied all knowledge and that was
         the end of it?  This is the Maidonek episode.

    A.   Well, no, he is just saying he did not know anything about
         it until the Maidonek affair.  That is all it says.

    Q.   493, paragraph 5.1.1.  I just draw his Lordship's
         attention to the fact the witness appears to be pleading

                                 .          186


          innuendos of words there which is not part of his remit.

     MR JUSTICE GRAY:  No, I will not pay any attention to that.

     MR IRVING:  Page 495, paragraph 5.1.5, if I can find it?

     MR JUSTICE GRAY:  Well, that simply says that he is going to
          deal with the statistics and the numbers killed in the
          raids on Dresden.

     MR IRVING:  Yes.  You say that my number of deaths in Hamburg
          of what I put at 48 -- did I say 48,000, 50,000?

     A.   48, 50,000, yes.

    Q.   And you consider this number to be totally exaggerated and
         perverse and another example of my manipulation and distortion?

    A.   It is not a very strong argument, but you do go for the
         highest number available.

    Q.   Is the reason ----

    A.   Which does not seem to have any basis and certainly is not ----

    Q.   Have you not ----

     A.   It certainly is not borne out by the local investigations.

    Q.   Have you not repeatedly referred to the fact that I have
         gone for these 50,000 figure in Hamburg and the high
         figure in Dresden and Fortzheime and elsewhere as an
         example of the distortions and false statistics that
         I introduced?

    A.   I think this is the only other mention of Hamburg, apart
         from the brief discussion of your use of the exaggerated

                                 .          187


          figure in the caption to an illustration in one of your books.

     Q.   Are you now back peddling on that because ----

     A.   It is not repeated.

     Q.   Are you now back peddling on that because you have seen
          the page from the strategic air offensive against Germany,
          the official history which I have introduced in that
          little bundle?  My Lord, it is page 9 of the little
          bundle, pages 8 and 9.  Does footnote 1 say in regard to
         the Hamburg air raid:  "In addition, there were 2,000
         missing.  The total number of deaths was probably nearer
         50,000 than 40,000"?

    A.   Sorry.

    MR JUSTICE GRAY:  Sorry, page?

    MR IRVING:  It is page 9 of the little bundle this morning, my Lord.

    A.   It does not say which raid this was.

    Q.   That is going to be your answer, is it?

     A.   No, I mean, I take it that is 43, yes.  Well, what I
         would say is that a responsible historian should in
         reaching an estimation of the number of people killed in
         bombing raid should look at all the available
         investigations there have been.

    Q.   Would you consider ----

    A.   And this is from 1961 which is relatively early after the
         event and does not actually give any source, any German

                                 .          188


          source, at all.

     Q.   Would you consider ----

     A.   The German investigations in Hamburg of the bombing deaths
          came to a much lower figure.

     Q.   Would you consider that Sir Charles Webster and Nobel
          Franklin, the official historians who had the complete
          captured German and British records at their disposal in
          writing this multi-volume work, are reasonable historians
          for another historian to use as a source?

    A.   Well, let me -- two points -- yes, but this is 1961.  I
         mean, there have been plenty of German investigations of
         the Hamburg bombing raids since then which a responsible
         historian would use.  This is relatively early after the
         event and it does not cite any German material here at all.

    MR JUSTICE GRAY:  We are talking about Hamburg here, are we?

    MR IRVING:  Yes, we are talking about the 1943 raid on hamburg.

         Are you aware that volume 4 of this work contains the
          entire police president's report on the Hamburg air raid
         as an appendix?

    A.   It is not cited here in arriving at the numbers killed.

    Q.   Can you answer my question?

    A.   Yes.

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