Archive/File: people/i/irving.david/libel.suit/transcripts/day002.11 Last-Modified: 2000/07/20 A. I think the choice of words between their statements and my documents is not by happen chance, I think they have chosen the word "statement" deliberately because they intended to put to me self-serving statements made by people in various war crimes trials under whatever conditions against the documents which I have obtained. Q. Yes. Now the next criticism really relates, I think, to mainly to the way in which you dismiss some sources which do not say what you want them to say. A. I am sure your Lordship is also a bit baffled as to what they are getting at here, I am sure Mr Rampton will assist us when he comes to the cross-examination. If they are saying I do not put in adequate apparatuses in my book saying what sources and archives I have used there are several reasons for that. Q. I think the key phrase in that criticism is "double standards"; I think what is said against you is that you are inclined to adopt uncritically some source material . P-192 because it suits your agenda, as they put it, whereas you dismiss -- A. I accept -- Q. -- more reliable evidence because it does not fit in with your agenda? A. -- I accept that that is a valid criticism, my Lord. AGP Taylor said the same to me once. He said, when you are looking at the Final Solution you are asking for a document, when you looking at what happened to General Sikorski you are quite happy to make allegations without a document. There are answers you can give. It is a valid criticism, but I am not going to say it is a "correct criticism". Q. Can you explain what you mean by that. A. They are entitled to make that criticism on their perception of the way history is written. If I take that specific example, that there is no document -- I point out there is no document showing that Hitler even knew about Auschwitz, whereas when I wrote about the death of General Sikorski in a book published in 1967 I am accused of having said it was probably sabotage even though there is no documentary evidence to suggest it was. This is I think an acceptable distinction because we are after all the victor nation; all our records are intact. We lost none of our records through World War II. We were not invaded by the Red Army; our archives were not bombed and . P-193 blasted and burnt to pieces. Our archives are intact. We now no longer have a 50 year rule, and so we would be entitled to expect to find as a result of our having had unconditional surrender from the Germans and total insight into their archives we would expect to find the record relating to Hitler, then we would not expect to find in the British Secret Service archives, which, of course, are only the archives which are still closed in this country. That became a bit convoluted, if I had a second chance I would say it again slightly differently. Q. I think I understand what you are saying. You are really saying that because the German archive is incomplete - - A. Yes, we have total insight into the German archives such as they have survived by virtue of unconditional surrender which we did not have at the end of World War I, but we certainly had at the end of World War II. There are no German archives that were withheld from the invading forces. So after over 50 years we would be entitled by now to have found the document that proves me wrong, whereas we are not entitled to expect to find records about General Sikorski, even now, because it would have been a Secret Service matter and Secret Service files are closed for at least the next 100 years. So it looks like a double standard to start with until you realise you are looking at two different . P-194 theatres of operation. But, again, if they want to put specific examples to me, some I will concede, and most I will not, probably. Q. -- well, I think before we move on to the next point we will adjourn and resume, if you will, please, at 2 o'clock? (Luncheon adjournment) MR JUSTICE GRAY: Mr Irving, can I before we resume with your evidence just ask Mr Rampton something, if you will forgive me? It is a logistical question, Mr Rampton. Assuming you are going to be starting to cross-examine this afternoon ---- MR RAMPTON: Yes. MR JUSTICE GRAY: --- I am wondering whether I have all the files that I ought to have here because what I do not want to find happening is that you ask a question in relation to a document that I do not have a copy of. Are you able to help? MR RAMPTON: Can I just say, I do not know how long I will get, but assuming it were an hour or so, your Lordship would need the copy of Mr Irving's opening which you should have already. MR JUSTICE GRAY: I have. MR RAMPTON: And files D2(i), (ii) and (iii). MR JUSTICE GRAY: I have all of those too. MR RAMPTON: The only other thing that your Lordship would need . P-195 would be Professor Evans' report if we got as far as that. MR JUSTICE GRAY: I have that. Thank you very much. I thought I had better check? A. My Lord, before you resume your examination or your questioning, can I raise just two points? Q. Of course, yes. A. I drew your Lordship's attention to a newspaper, a leading article which appeared in The Independent this morning. Q. Which I have read. I cannot lay my hands on it at the moment? A. I have it here, my Lord. I personally found it pushing the envelope of what is permissible, but maybe, in view of the fact that either I am a litigant in person or we are sitting without a jury, this kind of comment is permitted. MR JUSTICE GRAY: I think the position really is this, Mr Irving. I understand what you say, but I can really only intervene if I were to take the view that in some shape or form it amounts to a contempt. I do not. I am fairly clearly of that view. But if it helps at all, I totally disregard it. A. Thank you very much, my Lord. Q. I think I will not say any more about it. A. My Lord, you asked in one of your questions whether I had compared or weighed casualties against casualties, atrocity against atrocity. I have referred to the final paragraph of my "Destruction of Dresden" book, and, my . P-196 Lord, the bundle which I handed you this morning which I believe is on the desk in front of you at this end, the thin bundle, is that it, bundle B on page 5. Q. Yes, this is the new bundle. A. That is the new one I gave you this morning. It is selections from the books. You already have the entire books. Q. Yes, you mentioned that. A. If you look at page 5, my Lord, big figure 5, at the foot of the page, there is this paragraph: "On 13th February 1946, the former Commander in Chief of RAF Bomber Command sailed from Southampton on the first stage of his journey. That night throughout eastern and central Europe at 10.10 p.m. the church bells began to peal. For 20 minutes the bells ran out across the territories now occupied by a force as ruthless as any that the bomber offensive had been launched to destroy. It was the first anniversary of the biggest single massacre in European history, a massacre carried out in the cause of bringing to their knees a people who corrupted by Naziism had committed the greatest crimes against humanity in recorded time". That is about as close as I have ever got to weighing atrocity against atrocity, my Lord, and that was in my first book. Q. I am just puzzled by the date. . P-197 A. Well, it is the first anniversary of the Dresden raid, my Lord. Q. I see. A. This is why the bells are ringing. Q. I see. It was the Commander in Chief of Bomber Command setting out that misled me. A. The second page I would draw your Lordship's attention to concerns the adjutants. You asked whether I had made use of that information I obtained from the adjutants about Buchenwald inmates to be liquidated. Page 99, my Lord, by chance, is one of the pages that I included in the selection. Q. Tab 4, the last page. A. It is big figures 99 at the bottom of the page. The third paragraph, my Lord, is: "As American troops advanced across ... Hitler was confronted with the problem of the concentration camps. Goring advised him to turn them over intact and under guard to the Western allies who would sort out the criminals from the foreign labourers and Russian prisoners thus preventing hoards of embittered ex-convicts from roaming the countryside and inflicting additional horrors on the law-abiding. Hitler did not share Goring's trust in the enemy. Sitting casually on the edge of the map table after one conference, he instructed Himmler's representative to ensure that all inmates were liquidated or evacuated before the camps were . P-198 overrun." The footnote at the back of the book which I could show you if my Lordship is interested, because I have the book here, says the source of that information is the SS Major, who was Himmler's Adjutant's Adjutant, who has, however, requested that his identity be withheld. Some of these people at the time I wrote that book were still nervous about being identified, but he was the source. Q. But he is no longer nervous? A. I am sure he has no nervousness now, my Lord, because the years has passed, but he was the source and that was the episode which I recounted to you. You asked if I used it. In my submission, I have used it exactly as it should have been used and at the proper length. Q. Is this the 1991 edition or the 1977? A. That is the very first edition, my Lord, 1997. If your Lordship is interested, I can certainly produce almost identical pages from the subsequent editions. Q. No, do not bother. Thank you very much. Yes, now anything else or shall we resume? We are still on the topic of Hitler's Adjutants. I think you have dealt with criticisms (i), (ii) and (iii)? A. Double standards. Q. And the next one is, at any rate, self-explanatory? A. I distort, suppress, manipulate evidence, but until they . P-199 give chapter and verse, I cannot say. "The Plaintiff claims falsely that all of Hitler's surviving adjutants, secretaries and staff had uniformly testified that the extermination of the Russian or European Jews was never mentioned at Hitler's headquarters. That claim is contradicted by the evidence, my Lord. I shall be interested to see what the evidence is to which they are referring. Q. Just pause a moment. Do you accept that you have made the claim that all the Hitler surviving adjutants and so on have uniformly testified that the extermination of the Russian or European Jews was never mentioned at Hitler's ---- A. I think the full extent of the statement was that they have been frequently questioned ever since the war both by American and British interrogators and by others in between and certainly by myself on each occasion, and each of them has said that this systematic extermination of the Jews, or whatever -- what is it -- the extermination of the Russian or European Jews was never mentioned at Hitler's headquarters, that it was never mentioned in their presence. Obviously, they can only testify to what they personally witnessed and that was all I was interested in. Q. Yes, but the point I was on really was this, you have made that claim? . P-200 A. I have made that claim. Q. You say it is a true claim? A. I have maintained that it is true claim. If, however, the Defendants produce new evidence that it is false, I will accept that evidence, but that does not amount to my having distorted and manipulated. They would have to show that evidence was on my desk within my four walls, so to speak.
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