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Last-Modified: 2000/07/24

     Q.   Do they continue:  The most badly damaged town, in their
          opinion, is Dresden with an estimated casualty list of
          250,000?  Is that the same figure now?

     A.   That is another exaggeration, as you would expect from
          their previous estimate of 3 to 4 million.

     Q.   But it does not actually say in this report that is an
         exaggeration, does it?

    A.   Well, it does not say that 3 to 4 million is an exaggeration.

    Q.   But it does state it as a fact that the estimated casualty
         list in Dresden was 250,000?

    A.   No, it does not state as a fact.  It says it is in their
         opinion.  So it is a matter of opinion.

    Q.   The opinion is that was the most badly damaged town, that
         was the opinion; not that the opinion was the death roll?

     A.   Yes.  Again that is mere hearsay.  There is no documentary
         evidence they provide there.

    Q.   As a minor matter they also say that the city was filled
         with refugees?

    A.   That is right, yes.

    Q.   So that is two documents that give this upper limit figure?

    A.   No, they are not, well, they are not.  I mean they are not

                                 .          199

          contemporary documents.  Neither of them is a contemporary
          document.  This one is a mere matter of opinion by two
          physicians.  It does not even say where they are from.  It
          does not look to me as if they are actually Dresden
          doctors at all.  There is no evidence here that they were
          even in Dresden.  There is no documentary evidence as to
          the basis of the rather kind of casual footnote in the
          Ardenhau documents.  So neither of these is really worth
          very much at all.

    Q.   While we are still looking at the 250,000 figure, you do
         accept of course that I have never, ever said that it was
         250,000?  I have said this was the upper limit that was
         given, is that correct?

    MR JUSTICE GRAY:  Has anyone got the Corgi edition of
         destruction of Dresden.

    MR RAMPTON:  No.  I think we only have the most modern version
         which is I forget ----

    MR JUSTICE GRAY:  Professor Evans obviously had it at one time.

     MR RAMPTON:  Yes, obviously, and so did his researchers, but
         I cannot say where it is at the moment.

    MR JUSTICE GRAY:  We have probably got the relevant bit.  What
         we want is page 225.

    MR IRVING:  Of the Corgi edition.


    MR RAMPTON:  It is in L1, tab 3.

    MR JUSTICE GRAY:  Plus perhaps the footnote.

                                 .          200

     MR RAMPTON:  Page.

     MR JUSTICE GRAY:  225.

     MR RAMPTON:  That is the 1966 edition.

     MR IRVING:  You agree that all of these figures show I am just
          saying that the upper him limit or the maximum was 250,000?

     MR JUSTICE GRAY:  He is just having a look to remind himself.

     A.   Yes.

     MR JUSTICE GRAY:  Can you read out the bit which refers to the 250,000?

    A.   "Immediately after the war for sound political reasons,
         the Russia occupation authorities broached an announcement
         that the raids on Dresden had cost the lives of only
         35,000 people, and the first postwar Lord Mayor of Dresden
         supported them.  In fact the documentation suggests very
         strongly that the figure was certainly between a minimum
         of 100,000 and a maximum 250,000.  Hans Voight himself
         estimated the final number would have been 135,000, but it
          now appears that there were other officers working
         parallel to his.  On the registration of the victims, for
         example, a police unit with an office just behind ... all
         the evidence is that the figure was actually very much
         higher."  Then there are further estimates of 120, 150,
         180, 220, 140, 202,040 and Goebbels' figure of 250,000.

    MR IRVING:  Do you accept that some of those figures are taken
         dust jacket or blurb material which the author does not

                                 .          201


     MR JUSTICE GRAY:  This is from the text.

     A.   This is in the text.  I have just read the text of this.

     MR IRVING:  I am just looking at the quotations page 510 of the
          expert report.

     MR JUSTICE GRAY:  But we are looking at the Corgi edition.

     A.   Yes.

     MR IRVING:  I have another five or ten more minutes of
          cross-examination, but I want to make sure that Mr Rampton
         has enough time for his re-examination.

    MR RAMPTON:  Yes, I will have plenty of time.

    MR JUSTICE GRAY:  Do not worry about that, because the
         important thing is that you have put everything you want
         to put, Mr Irving. That is the priority.

    MR IRVING:  I do not think I will be able to put everything
         I want to put, but I am keeping it within bounds.  Page
         508, please.  Now you say:  "Irving has intimated", this
         is paragraph 1 halfway down, "that he will contest in
          court that estimates of", well, that I will maintain in
         court that estimates of the casualties vary between 35,000
         and 250,000?

    A.   Yes.

    Q.   Do agree that General Kurt Maynart, the City Commandant of
         Dresden, and that Professor Fetcher, the head of Civil Air
         Defence in Dresden, would have been in a position to
         estimate the final death roll accurately from their

                                 .          202

          positions respectively?

     A.   Not necessarily.  We will have to look at it in a bit more detail.

     Q.   Well, just off the top of your head, if somebody is the
          City Commandant or if somebody is the head of Civil Air
          Defence, do you agree that on the face of it they are
          likely to be in a good position to know what the final
          death figure is likely to be?

     A.   One has to know where they were and what they were doing
         at this time.

    Q.   Where they were, one was City Commandant and one was Head
         of Air Defence, Civil Air Defence?

    A.   Let us accept that for the moment and let you get on to
         the next question.

    Q.   Well, the next question ----

    A.   Accept that they might have been in a good position to know.

    Q.   My Lord, at page 19 of the little bundle I have inserted
          fresh copies of the Funfack letters.  They have not
         changed at all from the translations I provided before,
         but just for the ease of this particular operation.
         Professor Evans, you are familiar with the correspondence
         that I had with a medical officer or a doctor called Max
         Funfack in Dresden?

    A.   Yes.

    Q.   You began quoting one letter he wrote me and then you

                                 .          203

          stopped at a certain point, did you not?

     A.   Where is this?

     Q.   On page 520.

     A.   Yes.

     Q.   You quoted the letter he wrote to me dated January 19th,
          which ends: "Therefore, I can give no firm information
          about the figure of the dead but only repeat what was
          reported to me"?

     A.   Yes.

    Q.   Then rather oddly you tell us what it was?

    A.   That comes several pages later.  One has to ----

    Q.   It is an odd place to break though, was it not?

    A.   It comes on page 533 where I quote that last sentence and
         then go on, because that was necessary.

    Q.   The City Commandant, General Maynart, spoke on about 22nd
         February 1945 of 140,000 dead.

    A.   That is right.

    Q.   That is the City Commandant?

     A.   Yes.

    Q.   How does 140,000 tally with the 135,000 figure that
         I wrote in my book?  Is it more or less or about the same?

    A.   You know that.  You do not have to ask me.

    Q.   You are an expert and I thought I would ask you for an
         expert opinion?

    MR JUSTICE GRAY:  You do not need to be an expert to see
         whether one figure is the same as another.

                                 .          204

     Q.   Professor Fetcher of the Civil Air Defence spoke of 180,000?

     A.   Yes.

     Q.   But of course he then continues to say:  "I have never
          seen written evidence for this"?

     A.   That is right.  He advises you to get in touch with him.
          You could not with Fetcher of course but with Maynart.

     Q.   As you know, of course, I had met a man called Hans Voight
          who had represented to me, and no doubt accurately, that
         he was the head of the missing persons bureau in Dresden,
         and that he had undertaken identification work on the
         bodies for weeks afterwards?

    A.   That is right.

    Q.   And that he thought the good figure, in his estimate,
         would finally reach, the death figure would finally reach 135,000?

    A.   Well, that is somewhat disingenuous, the way you put it.
         He says that he had been able to clear up the identity of
          40,000 of the deed.

    Q.   But did he estimate the final figure what it was likely to be?

    A.   Well, he told you that he estimated it as 135,000, but
         I do not think he is a particularly reliable witness here.

    Q.   But you like Walter Weidauer, do you not, who is the Mayor
         of Dresden, this Communist Mayor who tore the heart out of
         Dresden and tore the palaces down and all the churches

                                 .          205

          and turned it into a socialist jewel?

     A.   I thought it was the British who destroyed the palaces.

     Q.   No.  The main parts were left and the central opera and
          all the rest were there waiting to be rebuilt?

     A.   Which they have been of course, starting with the
          Communists who began rebuilding them.  I do not think the
          fact that someone is a communist totally disqualifies what
          he has to say.

     Q.   Does the fact that Walter Weidauer on page 515 of your
         report described Hans Voight as being a virulent fascist,
         does that qualify what he has to say?

    A.   It does seem that Voight was actually thrown out of the
         GDR as a neo-faschist or a fascist.  I would put more
         credence in Voight's statement that the indices they had
         drawn up of the dead reached the number of 40,000.  That
         seems to me to be more reliable than his then further
         rather wild estimates of 135.  He has no source at all for
         the 135, whereas for his 40,000 he does.  Of course when
          Voight says that the Russians closed down his office and
         struck off the first digit to arrive at their number of
         35, I think that is just expressing Voight's resentment at
         his treatment by the Russians and the East Germans.

    Q.   Have you any evidence at all for this so-called treatment
         and so-called throwing out of East Germany?  Did the East
         Germans normally throw people out of their country or did
         they in fact build a wall and barbed wire minefields to

                                 .          206

          stop people leaving?

     A.   That was in 1961.

     Q.   But you have no evidence at all for this alleged throwing
          out of Voight?

     A.   I am trying to find it.  Well, it is Weidauer's
          description of him.

     Q.   The one who calls him a virulent fascist?

     A.   Yes.

     Q.   Do you call people fascist in your time?

    A.   No actually, not unless I really thought they were.  I do
         not use it as a general term of abuse.

    Q.   At page 518 you use other words like ecstatic and mounting
         excitement and breathlessly to describe the way that
         I went about my research, is that right, frantic marketing?

    A.   It appears to be, yes, particularly to the Provost of
         Coventry Cathedral.

    Q.   On page 520 now, from the first sentence of the letter
          dated January 19th, which you omit, is it not plain that
         I did contact the Funfacks?

    A.   Point me to this, please.

    Q.   You said that I made no attempt to contact the Funfacks.

    A.   Where is this?

    Q.   Page 520.  You have quoted part of that letter, but in
         fact you have missed out the first sentence.

    A.   28th February, let us have a look.

                                 .          207

     Q.   He writes to me and the first sentence is: "You were so
          exceedingly kind as to send my wife a copy of your book
          about the destruction of Dresden. The book has arrived
          safely and we thank you very much."

     A.   Yes, so this is a letter from -- you had sent him the book, yes.

     Q.   Yes.

     A.   But then you had not actually ----

     Q.   Why would I send Funfack a book if not to contact him?

    A.   That is not really what I mean.

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