Archive/File: people/i/irving.david/libel.suit/transcripts/day029.05
Last-Modified: 2000/07/25

   MR RAMPTON:  And your audience absolutely love it, do they not,
        Mr Irving?  It is music to their ears, is it not?
   A.   They travel 200 miles sometimes to come and hear me speak, yes.
   Q.   Good.  Now I want to ask you about the National Alliance,
        if I may.  For this purpose you will need Bundle A.  It is

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        the request for information and the answers that the
        witness will need.  Page 79 of the request first of all,
        question 23, in the middle of the page under the main
        heading, the National Alliance.  We asked you the
        questions, Mr Irving.  I hope you have got it: "Do you
        agree that the National Alliance is responsible for the
        material contained in the appendix to Rebecca Goodman's
        witness statement?  Do you agree that it is the largest
        and one of the most influential neo-Nazi organizations in
        the United States of America, being extremely right-wing,
        racist and anti-Semitic?  Do you agree that it publishes
        and/or advertises through National Vanguard publications
        which are extremely right-wing, racist and anti-Semitic"?
        Then we asked you:  "Do you agree that you spoke at
        various National Alliance events"?
                  You will find your answers to questions 23 and
        25 in a document in tab 9, I think I am told, page 7.  Can
        I ask you this?  When you receive a document like this in
        the course of legal proceedings, and I know this is not
        the first time you have litigated, do you take the
        questions which are asked seriously?  Do you take this to
        be a serious event in the course of the proceedings?
   A.   Well, in view of what happened to Mr Aitken, I take it
        very seriously indeed, yes.
   Q.   So your response to the first question about your
        knowledge of the National Alliance is this: "I have no

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        association of the body known to the Defendants as the
        National Alliance as such or whatsoever.  I cannot rule
        out that members of that organization, which I take to be
        a legal organization in the United States, have attended
        functions at which I spoke.  Accordingly I have no
        knowledge of, and I take no interest in, what materials it
        publishes or distributes.  I have no knowledge whatsoever
        of the character of the National Alliance, other than what
        is now claimed by the witnesses for the Defendants, nor
        the publications which it is alleged to publish or advertised".
                  In relation to the next question, in answer to
        the next question, you gave this answer: "I do not agree
        that I have spoken at any National Alliance meetings.  It
        might be that on occasions a gentleman who was a member of
        the National Alliance offered to organize a lecture for
        me.  In other words, he undertook to find a suitable
        room.  But I then circulated 'my' entire local mailing
        list to provide an audience.  No doubt he brought his
        friends as well.  It will be seen that in all these
        photographs of these events which are produced at trial,
        there is no kind of National Alliance 'presence'".
                  Those statements were false, were they not,
        Mr Irving?
   A.   At the time I made them, they were absolutely correct,
        yes.  They were not false.  I have the photographs.

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        I have not yet introduced the photographs I am referring
        to, but I have them ready.
   Q.   Mr Irving, we showed in this court, oh some time ago now,
        video tape of you standing on a platform with a National
        Alliance banner by your left shoulder, did we not?  That
        was film taken by the Australia film crew, was it not?
   A.   You showed a video tape of me in a room, on one wall of
        which was a banner, which has been pointed out to me in
        this courtroom as being a National Alliance banner.  I do
        not suppose a single person in this courtroom would be
        able to tell you what a National Alliance banner looks
        like, and that is the position of most English people.
   Q.   Except, may I suggest, you, Mr Irving.  Could the witness
        be given RWE 1, and be asked to turn to tab 2?
   A.   Shall I get my own file?
   Q.   No.  Somebody must do it for you.  The first document in
        this section of the file, Mr Irving, is a letter dated 3rd
        February 1990.  It has on its left-hand side a sort of symbol?
   A.   Yes.
   Q.   On the right-hand side it says in large, emphatic black
        ink: "National Alliance, PO Box something or other, Palma,
        Ohio", does it not?
   A.   Yes.
   Q.   "Hello David", it says, "I have arranged for you to speak
        on Wednesday, June 3rd, 7.30 p.m. at the Croatian Home in

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        Cleveland.  Enclosed is a map, Croatian Home", and then
        the address.  "You are welcome to stay again at the
        residence of Mark Wavra", I think it is, in somewhere or
        other and then the telephone number is given?
   A.   Yes.
   Q.   "Stay in touch and call me if need be."
   A.   Yes.
   Q.   That letter, I suspect, comes from your discovery, I do
        not know?
   A.   Almost certainly, yes.
   Q.   Yes, so is this letter a forgery?
   A.   No.
   Q.   Well, how do you explain it?
   A.   Well, if you would like to ask me specific questions?
   Q.   How do you explain this letter in the light of the answers
        you gave us on paper?
   A.   Would you ask me a specific question?
   MR JUSTICE GRAY:  It looks like a letter from an official of
        the National Alliance because it has "National Alliance"
        at the top, and it looks as if you have a prior
        relationship with the writer, Gliber, is that the point?
   A.   Can I draw your attention to the second sentence of my
        answer No. 25?  It might be that on occasions a gentleman
        who was a member of the National Alliance offered to
        organize a lecture for me, in other words, he undertook to
        find a suitable room.  Is that the kind of letter you

.          P-41

        would expect in response, describing the room that he has
        offered, that he has provided?  No reference that it is
        going to be a National Alliance function; he is just using
        his own notepaper?
   MR RAMPTON:  "I have no association with a body known to the
        Defendants as the National Alliance as such, or
        whatsoever.  I do not agree that I have spoken at any
        National Alliance meetings".  Those were false statements,
        were they not, Mr Irving?
   A.   Still completely true.  This is not an association with a
        body.  He is not writing in official capacity to me.  He
        is writing to me as a personal friend.  I do not know why
        he used that notepaper.  It was not a National Alliance
        function, and if you asked me 10 years later, do
        I recognize that logo on the top left-hand corner, I do
        not recognize it; and if you had asked me even between the
        time we saw the video and now, I could not have drawn it
        from memory, let alone 10 years later.  Can you draw from
        memory the logo of the Automobile Association, just to
        give one example?  I do not know.
   Q.   I have not finished, Mr Irving.  Do not be too hasty.
   A.   That is why I asked you to ask specific questions rather than...
   Q.   The specific question is you know perfectly well who the
        National Alliance are and you always have done?
   A.   I now know who they are, yes.

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   Q.   No, no.  You always knew who they were.
   A.   That is a different question, is it not?
   Q.   You have cooperated with them willingly.  You agreed to
        speak at meetings hosted or organized by them in the full
        knowledge of who they were, did you not?
   A.   The answer is, no, I did not.  I am talking in the past
        tense.  I know now who they are because I have now read a
        lot of literature provided by the Defendants about them.
        At the time that, at all material times, I was not aware
        who the National Alliance were, I was not aware of what
        their logo looked like, the fact that somebody had some
        kind of logo on the top left-hand corner of letters
        certainly is not going to embed itself in my
        consciousness.  Why should it?
   Q.   I will tell you why in a moment.  Turn over to page 2,
        please.
   A.   Yes.  Is there any logo on this letter?
   Q.   No, there is no logo ----
   A.   Is there any "National Alliance" heading on the letter?
   Q.   Please be patient.  You will see how the matter develops
        very shortly.  This is dated 15th September 1995.  It
        comes from somebody called Erich Gliber?
   A.   The same man.
   Q.   What?
   A.   The same man, yes.
   Q.   No.  Is it?

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   MR JUSTICE GRAY:  Yes, the same man.
   MR RAMPTON:  Oh, yes, the same man, the same fellow.  This time
        you are going to be speaking at Lithuanian Village in
        Cleveland as opposed to Croatian Home in Cleveland.
   A.   Do you want to make anything out of that?  I mean, you
        appear to be emphasising those words as though you were
        attaching importance to.
   Q.   I do, perhaps, Mr Irving.
   A.   Do I detect any xenophobia there?
   MR JUSTICE GRAY:  Mr Irving, answer the questions.
   MR RAMPTON:  Perhaps you can help us.
   A.   I have nothing against Croatians or Lithuanians.
   Q.   No, during the war the Croatians were one of the Nazi
        puppet governments, were they not?
   A.   Is that the point you are trying to make?
   Q.   Answer my question, please, Mr Irving.
   A.   The Croatians?
   Q.   Yes.
   A.   There was a puppet Croatian government, yes.  There was a
        puppet Belgian Government and a puppet Dutch Government,
        yes.
   Q.   But the Croatians -- I do not want to go too far down this
        road -- it is right were enthusiastic supporters of the
        Nazis, were they not?
   A.   All the Croatians?  I do not know.
   Q.   No, no, the Croatian Government.

.          P-44

   A.   Well, the puppet government was.  That is what puppet
        governments do.  There were puppet Marxist governments.
   Q.   And during the war in Lithuania, as we have seen,
        Reinhardt Heydrich saw Lithuania, amongst other places in
        the Baltic states, as being a fertile source of
        anti-Semitic problems, did he not?
   A.   I think most of the Eastern European countries were, yes.
   Q.   Do you know why these places are called "Croatian Home"
        and "Lithuanian Village"?
   A.   I think they had -- if you look in one of the photographs
        which I will present to the court, there is actually a
        Croatian banner hanging on the back wall.  It is rather
        like the British Legion.  The veterans who live in that
        area, in the Cleveland area, there are a lot of these
        ethnic minorities, and I have got nothing against ethnic minorities.
   Q.   No.
   A.   But they have their own meeting place, their own social
        halls and so on.
   Q.   Now, the next page over, page 3 in the circle in
        handwriting at the bottom of the page, is from what?
        There will be an index somewhere.
   A.   I have no idea at all.  Never seen it.
   Q.   It is from the National Alliance bulletin, yes.  It is a
        very bad photograph and one could not tell it was a
        photograph of anything at all in the top right-hand

.          P-45



        corner, and it is captioned "David Irving lecturing at
        Cleveland.  A fund raising activity for the Cleveland
        unit."  Under "Cleveland activity", the cross heading in
        the middle column says:  "On October 1st, the Cleveland
        united hosted", sorry, just looking for a date, "October
        1st, the Cleveland unit hosted a very successful lecture
        by the British historian and revisionist author, David
        Irving.  More than 100 tickets were sold at $10 each.
        After paying Mr Irving's $500 fee and the modest rent for
        the hall, the unit had a profit of approximately $400.  To
        this was added the income from sales of Alliance books and
        from a bake sale".   Drop down, please, to the bottom of the page.
   A.   From a bake sale organised by the unit's women -- a very
        dangerous body, obviously!

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