Archive/File: people/i/irving.david/libel.suit/transcripts/day009.20
Last-Modified: 2000/07/20

   MR JUSTICE GRAY:  Page 183, just complete it to the end of 184.
   A.   "The sides of these pillars which went up through the roof
        were of heavy wire mesh.  Inside this grid, there was
        another other fine mesh and inside of that further very

.          P-176

        fine mesh.  Inside this last mesh cage there was a
        removable can that was pulled out with a wire to recover
        the pellets from which the gas had evaporated.  Besides
        that in the gas chamber there were electric wires running
        along the two sides of the main beam supported by the
        central concrete pillars.  The ventilation was installed
        in the walls of the gas chamber.  Communication between
        the room and the ventilation installation proper were
        through small holes along the top and bottom of the side
        walls.  These lower openings were protected by a kind of
        muzzle, the upper ones by whitewash perforated metal
        plates", and these are plates, some of six were found and
        analysed by the Krakau Forensic Institute.
   MR IRVING:  That is your presumption?
   A.   That is my presumption.
   Q.   You have no reason for saying that, saying that these are
        identical, other than your presumption?
   A.   It seems that the description of these plates is exactly
        the same, of the ones which were analysed in Krakau.
                   "The ventilation system of the gas chamber
was
        coupled to ventilation ducts installed in the
undressing
        room.  This ventilation system, which also served as a
        dissection room, was driven by electric motors in the
roof
        space of the crematorium.
                  "The water tap was in the corridor and a
rubber
        hose was run from it to wash floor of the gas chamber.
At

.          P-177



        the end of 1943 the gas chamber was divided in two by
a
        brick wall to make it possible to gas smaller
transports.
        In the dividing wall there was a door identical to
that
        between the corridor and original gas chamber.  Small
        transports were gassed in the chamber furthest from
the
        entrance from the corridor.
   MR IRVING:  I would like to stop you there, if I may, and
now
        ask you what Taiber has actually told us about the
gassing
        procedure.
   MR JUSTICE GRAY:  We have not quite finished yet.  Can we
just
        go to the middle of 184, and then that is a convenient
        point I think to ask that question.
   MR IRVING:  Very well, my Lord, yes.
   A.   "The undressing room and the gas chamber were covered
        first with a concrete slab and then with a layer of
soil
        sown with grass.  There were four small chimneys, the
        openings through which the gas was thrown in that rose
        above gas chamber."
   Q.   So this is the roof we are looking at on these large
        colour photographs, is that correct?
   A.   Yes, or the remains of the roof to be very precise.
        "These openings were closed by concrete covers with
two
        handles."
   Q.   Not wooden, concrete covers?
   A.   That is what it says, yes.  "Over the undressing room
the
        ground was higher than the level of the yard and
perfectly

.          P-178



        flat.  The ventilation ducts led to pipes and the
chimneys
        located in the part of the building above the corridor
and
        undressing room.  I would point out that at first the
        undressing room had neither benches nor clothes hooks
and
        there were no showers in the gas chamber.  These
fittings
        were not installed until Autumn 1943 in order to
        camouflage the undressing room and the gas chamber as
a
        bathing and disinfestation facility.  The showers were
        fitted to small blocks of wood sealed into the
concrete of
        the gas chamber.  There were no pipes connected to the
        showers from which no water ever flowed.
                  "As I have already said, there was a lift in
        the corridor or rather a goods hoist.  A temporary
hoist
        installed pending delivery of the electric lift to
carry
        the corpses to the ground floor." End of quotation.
   Q.   That final paragraph is quite interesting, is it not,
        because we now have the documents giving the actual
dates
        for the arrival of the provisional lift.  I believe it
was
        finally ready in September 1943, is that correct?
   A.   No, it was ready in March.  The history of the lift is
a
        very confused history, because they did not get the
lift
        they wanted.  They had the lift installed originally
for
        750 kilograms carrying capacity, and then they tried
to
        improve on that one, since it did not seem to be
enough,
        by doubling the cables on which this lift, it was
        basically a kind of building site hoist, so that it
could

.          P-179



        carry 1500 kilograms.  This was all in something like
        March 1943.
   Q.   Very well.  So we have heard the description from
Henrich
        Taiber of the liquidation procedure.  On what other
        eyewitnesses did you base the ----
   MR JUSTICE GRAY:  I am sorry I will have to interrupt you,
        Mr Irving.  I think if you have a case to put in
relation
        to Taiber, that he is unreliable or that for some
reason
        his account is not to be credited, I think it is right
        that you should put it.
   MR IRVING:  Very well.
   MR JUSTICE GRAY:  It may be your case is simply that all
the
        eyewitnesses are to be treated with caution and you go
no
        further.
   MR IRVING:  I was go to treat them all summarily, in the
same
        manner, and just ask the simple question, did they all
        give the same description in broad terms of people
going
        up on the roof opening these manhole covers, pouring
the
        cyanide capsules in.  If I may ask the question like
that,
        the eyewitnesses that you have, Taiber, which other
ones
        would you rely on?
   A.   In this case, as you mentioned Broad describes seeing
it
        from some distance.  Then later there are eyewitnesses
who
        have been, other sonderkommando who would have made
        statements later, in 1960s, and of course Muller with
his
        original statement for 1946 which is in the book by
Kuhler

.          P-180



        and then ----
   Q.   Of course if they make their statements in the 1960s
there
        is the danger of cross-pollination, is there not?
   A.   That is why I limited myself at the moment for this
        particular case to look at the very early ones.  I
must
        say that as an historian I am quite delighted to find
        people who seem to be as observant as Mr Taiber
actually
        as a witness giving with very fresh this thing in his
        memory his statement in May 1945 to Judge Sehn.
   Q.   It is almost as though Jan Sehn held the blueprints in
        front of him and said: "So they went from here, to
there,
        through this door and then this and this and this
        happened", is that right?
   A.   I do not know.  I mean I do not know what happened.  I
do
        not know what happened in that room.  Certainly the
Taiber
        testimony is largely convergent with the blueprints.
        However, when Taiber starts talking about, for
example,
        either the gassing procedure or the incineration
procedure
        of course, then that is not in the blueprints and very
        important the wire mesh columns are not in the
blueprints
        either.  We have that from a different source.
   Q.   So these wire mesh columns, so it is plain what we are
        saying, what size were they?  We have not nailed it
down.
        In rough terms 10 inches across from side to side?
   A.   They were probably, I mean again I want to try to find
        Kuhler, but they were probably the same thickness as
the

.          P-181



        structural columns supporting the roof.
   Q.   Which is quite a substantial size.  These wire mesh
        columns that are going to go up to the roof where the
hole
        is through which the cyanide capsules are being
poured?
   A.   Yes.  Yes.
   MR JUSTICE GRAY:  Before we have leave Taiber, I am sorry
to
        interrupt you again, Mr Irving, he gives a detailed
        account of the incineration procedure which you have
set
        out at page 186 of your report, is that right?
   A.   Let me just get to 186.
   MR RAMPTON:  Is the witness looking for Kuhler, in which
case
        I can tell him where it is?
   MR JUSTICE GRAY:  I am asking him to look for something
else.
   MR RAMPTON:  I am sorry. It is 196 to 198 and 516 to 517.
   MR JUSTICE GRAY:  We will have to deal with Kuhler
tomorrow.
   MR IRVING:  I only wanted to know roughly what size of wire
        mesh we are talking about, what the width of this
column
        going up to the ceiling was.  We have probably got a
        pretty clear picture of kind of thing it was; larger
than
        a drainpipe.
   A.   Yes.  Kuhler says these columns were around 3 metres
high
        and they 70 metres square.
   Q.   70 metres?
   A.   70 centimetres.
   Q.   The wire mesh columns?
   A.   Yes.

.          P-182



   Q.   70 centimetres is of the order of 2 feet 6 inches?
   A.   Yes, a little less, 2 feet three inches.
   Q.   So this hole in the roof or these holes in the roof,
how
        many wire mesh columns were there, four?
   A.   Four.
   Q.   So the holes in the roof would have been up to 2 foot
6
        inches across?
   A.   Absolutely not, because the whole column may be 2 feet
4
        inches, but Zyklon-B is only introduced right in the
        centre piece.  The centre piece, we have concentric
        columns, so ultimately the centre piece can be a
rather
        narrow thing, so the hole through the roof could have
been
        a relatively narrow pipe.
   Q.   But we are told here he had a concrete cover with two
        handles covering this whole, which rather suggests
        something larger than a tennis ball?
   A.   But the concrete cover, we have a picture of these
actual
        chimneys in the documents.  Of course you do not when
you
        create this pipe which comes up out the centre of the
wire
        mesh columns, of course you take a larger kind of
little
        chimney around it.
   MR JUSTICE GRAY:  As a funnel?
   A.   As a funnel, yes.  Like a chimney itself always is
wider
        than the actual smoke channel going through it.
   MR IRVING:  Yes.  So you are saying there was a relatively
        small hole or four small holes smaller than 2 foot six

.          P-183



        inches across then, and after they had spent all this
        money building this underground crematorium with all
the
        problems of damp that is implicit in that, somebody
was
        allowed to come along after the event, because it was
not
        included in the drawings, and knock holes in right
next to
        the supporting pillars?
   A.   I did not say that.  The crematorium roof, as we know
from
        other documents, there were problems with finishing
the
        crematorium, roofs of the Leichenkeller, in December
of
        1942 and January 1943.  We actually have photos of the
        completion of the roof.
   Q.   But this is not the question.
   A.   May I finish?  No, but the thing is you assert that
        they knocked holes inside the roof of the gas chamber.
   Q.   Through the roof.
   A.   That did not happen.
   Q.   Through the roof?
   A.   Through the roof.  Well, the modification and design
had
        been made before that roof was completed.
   Q.   What modification?
   A.   The roof of the gas chamber, or morgue No. 1, and the
roof
        of morgue No. 2, later the undressing room, were only
        completed in December and January, in December 1942
and
        January 1943, by which time the modification of the
        building into a genocidal extermination machine had
        already been decided on.  But they did not have to
make

.          P-184



        holes in the roof because the roof was not yet
complete at
        the time.
   Q.   But if you were an architect, and neither of us is an
        architect, and some SS Rottenfuhrer comes along and
says,
        "I am going to knock four holes in the roof right next
to
        the supporting pillars", what would you have told that
        man?
   A.   May I just point out that if we look here at, for
example,
        that column and that column, there is a beam
supporting,
        connecting the two columns.  Of course it is going to
be a
        real problem when you go right through the beam you
weaken
        the beam.  That is one of the reasons that these
columns
        are placed next to the column, so that they do not
        challenge the structural integrity of the main beam.  If
        they had been -- may I point it out?
   MR JUSTICE GRAY:  Yes.  I think I understand what you are saying.
   A.   I am just going to make a drawing here.  This is the gas
        chamber.  The columns are right here.  The structural beam
        sits right on top of that.  So your point is absolutely
        valid if you put the columns right there, but if you put
        the grid columns right here, then there is absolutely no
        structural, the structural integrity of the roof is in no
        way challenged.

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