Archive/File: people/i/irving.david/libel.suit/transcripts/day002.04 Last-Modified: 2000/07/20 It says here in about 1975 Adolf Hitler's Private Secretary, the late Christa Schroeder, gave me a small pencil sketch, a self-portrait of Adolf Hitler, which he had retrieved from his desk in the last days of the war. She gave it to me as a gift and I keep it. I do not, of course, have any kind of portrait of Adolf Hitler on my office hanging on the wall in the way that has been described. Am I proceeding in the correct manner? Q. Yes, I think this is exactly what I think is the right way of proceeding. A. I consider myself to be an expert on the careers of the principal Nazi leaders, including specifically Adolf Hitler, Goring and Dr Josef Goebbels. I am an expert on the archives about these people. I am expert on the current state of research into German and other wartime persecution and liquidation of the European Jewish communities. Q. You said yesterday -- I am sorry to interrupt you-- that you did not regard yourself as being an historian of the Holocaust, can you just in your evidence ---- A. This is true. Q. --- explain what you mean? A. There is a subtle difference. I am an expert in the state of research but not on their findings, so to speak. I am . P-131 an expert on the way they go about their research, but not so much on the actual details of the Holocaust, and so on. Q. When you say "they", who do you mean by "they", the Defendants? A. No, my Lord. I am sorry, I should have made myself clear. I mean the Holocaust historians, the historians who specialize in that topic. Q. Yes. A. Over the years I have collected a very large archive of original documents and copies of original documents, like private diaries and papers like that, from the top Nazi leaders using various techniques and methods, all entirely legal and, as part of my technique, I would then donate these papers immediately to the suitable archives so they are immediately available to other historians. My views upon politics are on page 1047. Q. Yes. A. The Defendants have chosen to refer to my politics and they wrongly categorise them. They say that I am extreme right-wing or something like that. I have never belonged to a political party, left or right, except I think I joined the Young Conservatives at University. My father stood as a Labour candidate in the 1945 General Election. I voted for Sir James Goldsmith, my Lord, if I can make that point in the last election, in other words, neither one nor the other. I regard myself . P-132 as a laissez faire Liberal. In other words, I do not really care much about politics so long as they spend the money on hospitals rather than Millennium Domes. I have a family reason for saying that. I do not look down on any section of humanity, either coloured immigrants, I have regularly employed them, or females. Your Lordship will appreciate the reasons why I make these points. I have five daughters, in fact -- I am sorry, I had five daughters. I do not look down on the mentally or physically disabled. I admit to having little patience with smokers and none at all with drug abusers. This is not to say that I have applauded -- I have to state this because I will probably be asked about it -- I cannot say that I have applauded the uncontrolled tide of commonwealth immigration into this country. Like most fellow countrymen of my background and vintage, I regret the passing of the Old England. I sometimes think, my Lord, that if the soldiers and sailors who stormed the beaches of Normandy in 1944 could see what England would be like at the end of this century, they would not have got 50 yards up the beach. I think they would have given up in disgust. Q. You said you are getting towards paragraph 23 of your witness statement, 1048? A. My reputation as an historian. . P-133 Q. You said you wanted to develop that and I think now is probably the appropriate time to do that, if you want to. A. I have, of course, a very large collection of ring binders of Press clippings which have been made available to the Defendants and in which they have not shown the slightest interest. Reviews in all the leading newspapers of the world of the books that I have written. I believe I have written about 30. I could have produced all those reviews to the court, but if I just summarize and say that they are largely very favourable reviews, the kinds of reviews that made publishers line up to publish my books until the turning of tide. Obviously, there were some reviews that you could describe as the curate's egg, but, by and large, the reviews were exceptionally favourable. It may be said that the reviewers were not as clever, perhaps, as the expert witnesses whom the Defendants have summoned for this case. That may be one argument; maybe they had not seen though me, perhaps. Arguments like that will be advanced, but I submit this is not the case. These were book reviews written by experts in their own field, like Captain Steven Roskill who was an eminent naval historian, Professor MRD Foot, who is another official historian, Professor Sir Frank Hinsley. If I just summarize it as briefly as that, my Lord? Q. Yes, I think that is sufficient. . P-134 A. If you wish to question that, of course, I will be quite happy to put in all the evidence to support the contention, but Defendants have not shown any interest in these statements. Q. Can you help me because I have not alighted on them. Are they in one of the files? A. They were within my discovery. They were disclosed to the Defendants in proper form. Admittedly, I did not do an index of the entire set, but they were shown 16 ring binders full of chronologically organized, properly pasted up reviews and Press clippings in which, who knows, they might have found some goodies they could have used against me, I do not know, but they did not bother with them. Q. Take your own course, Mr Irving, but do you now want to deal with the publication of "Denying the Holocaust"? A. The publication of the book. I paid no attention to that book, my Lord, until 1996. It did not come into my ken until 1996. I believe it was published in 1994, but in April 1996 we published in this country my book the Goebbels' biography, "Goebbels. Mastermind of the Third Reich". Your Lordship will be aware this is the only book that I requested that your Lordship study in some detail because it is a book that I am particularly proud of. When we began marketing that book in the United Kingdom, which meant literally that I and my publisher imprint rented a van and visited approximately 980 . P-135 bookstores up and down the length and breadth of the country, which is a very enjoyable exercise. I do not do it out of tedium; it is very interesting to visit the bookstores and their managers. We marketed the book directly to them and we sold many thousands of copies in this manner, but we came across the phenomenon that in a number of bookstores, particularly in the Waterstones chain, the head of the history department took an aversion to me. After visiting a number of the bookstores, it became quite plain that the reason for the aversion to me was the fact that they were selling the book "Denying the Holocaust", published by the first Defendant and written by the Second Defendant. This book was being believed by Waterstones or by their employes and by, no doubt, other bookstores too. It was causing me considerable concern because these bookstores were thereupon refusing to stock my books. So I thereupon during that tour began to purchase copies of "Denying the Holocaust" as evidence that the book was on sale within the jurisdiction. I put the publishers on notice. I put the author on notice. I put certain of the book sellers themselves on notice because under the Defamation Act anybody in the distribution chain can be held liable for the peddling of libels. I subsequently, of course, separated those -- . P-136 I discontinued the action against the book sellers for reasons that need not occupy the court. At the beginning of September 1996, which is that same year, which had been a very harrowing year for me, as I had seen my American publishers, St Martin's Press, in conjunction with my big American publisher, Doubledays, simultaneously deciding, we now learn, upon representations made by the Second Defendant not to go ahead with publication of my Goebbels' biography, I decided that I had no recourse but to take libel action against this book which was, obviously, part of the cause of my problem. So I issued the writ, after taking usual procedural steps, the letter before action and so on, I think it was dated September 6th 1996. Q. Yes. Now, you have selected for complaint a number of particular passages from the book and I think it would be appropriate if you were to deal with them, and where you best find them, I do not know, but certainly they are to be found in your Statement of Claim, but it may be you would rather deal with it in some other way. A. May I return my papers and collect the Statement of Claim? Q. Yes, of if you point out where they are, perhaps somebody can do it for you rather than having you go backwards and forwards? . P-137 A. They are in the ring binder. Q. Thank you very much. A. My Lord, I was defamed and libelled on a number of pages in the book. I do not propose to read out, unless your Lordship wishes otherwise, the specific passages. Q. No. You are entitled to take your own course about that but I think what you ought to do is just give an indication of ---- A. I will read out ---- Q. --- why you object to the passages that you have selected for complaint. A. If I go to paragraph 9 of the Statement of Claim which is "The natural or ordinary meaning of the words complained of"? Q. Yes. A. I contend that the passages meant, and were intended to mean and understood to mean, firstly, "that the Plaintiff", meaning myself, "is a dangerous spokesperson for Holocaust denial ... for denial forces who deliberately and knowingly consorts and consorted with anti-Israel, anti-Semitic and Holocaust denial forces and who contracted to attend a world anti-Zionist conference in Sweden in November 1992, thereby agreeing to appear in public in support of and alongside violent and extremist speakers, including representatives of the violent and extremist anti-Semitic Russian group, Pamyat, and of the . P-138 Iranian-backed Hezbollah and of the fundamentalist Islamic organization Hamas and including the black Muslim leader Louis Farrakhan, born Louis Eugene Walcott, who is known as a Jew-baiting black agitator, as a leader of the US Nation of Islam, as an admirer of Hitler and who is in the pay of Colonel Gaddafi". My Lord, the wording that I use in this is, of course, very closely related to the wording used in the work complained of. I have not chosen those words myself. I have merely distilled them out of the Defendant's text and adhered as closely as possible to the original wording. Q. Yes. You are just paraphrasing really? A. I am not even paraphrasing, my Lord. I am gluing the words together into a complaint form using the words actually used by the Defendants in the work complained of. Q. That is what I meant by "paraphrase".
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