Archive/File: people/i/irving.david/libel.suit/transcripts/day010.16
Last-Modified: 2000/07/20

   MR IRVING:  Each time, right?
   A.   Each time, and all the 30 dwelling barracks in Auschwitz
        would take 360 and 600 kilos of Zyklon-B.  Then there were
        also workshop storage barracks, and they would have taken
        240 to 400 kilos, which means that the complete delousing
        of the camp (and we are now talking about Auschwitz 1 and
        Auschwitz 2) would have taken between 1750 and 2,900 kilos.
                  Now, on the basis of this comparison with these
        other camps, I had established that an amount of 9,000
        kilos for Zyklon-B for Auschwitz in 1943 would have been
        within the kind of range of the possible.  It would be the
        high end, but I would not have been surprised to see so much.
                  This means that if we take that 9,000 as a kind
        of bench mark of what a normal -- Auschwitz under normal
        conditions would have used, then we can have at least two

.          P-134



        complete delousing of all the barracks in the camp in
        1943.
                  Now, I take two eyewitness testimonies which is
        one from Helen Zipitehau who was in the women's camp from
         -- a Slovac Jew -- 1942 until the liberation in 1945.
        She remembered three our four of these large delousings of
        the whole women's camp in her two-and-a-half year stay.
        Then Dr Ziegsmund Bendel in the Tesch trial declared that
        he has only one delousing of the barracks during his 13
        month stay in Auschwitz.  This is the kind of
practical
        information we have about how many times.  I mean, I
do
        not have any more information on that.
                  It seems then that the 1750 to 2,000 -- that
        this let us say two or three, maybe two delousings in
1943
        of the whole camp would still bring us below the 9,000
        kilos of Zyklon used after all the gas chambers have
been
        working every day, the delousing gas chambers, and
        basically we have had the delousing of the blocks.
                  I must make one kind of -- a particular
        thing must be noted, that if in the German document
        sometimes there is talking about the "Entlausung des
        Blocks", it means that the people in the block are
going
        to be taken to be deloused.  There is particular
things.
        It says that block 11 was "entlaust" which means
everyone
        was taken to be BW5A, the delousing building in the
        women's camp, or so on.

.          P-135



                  This means then when we go to page 29 that I
say
        that 9,000 given these two, these very infrequent
        delousings of the whole camp, that those 9,000 kilos
of
        Zyklon-B which I originally established on the basis
of
        comparison with other camps seems to be on the high
side
        but within the ball park of what Auschwitz would have
        needed for its normal concentration camp purposes.
                  So then the question is, what are these
other
        3,000 kilos of Zyklon-B going to be used for?  What
other
        kind of needs did Auschwitz have for Zyklon-B which
were
        not to be found in other concentration camps?
   MR JUSTICE GRAY:  That, I think, probably completes your
        answer.  It is a long answer, but it was very helpful
and
        very clear to me.  So back to Mr Irving.
   MR IRVING:  My first question is you have, of course, read,
        have you not, the testimony and supporting evidence in
the
        trial of Bruno Tesch whose company was the main
        distributor East of the Elf for Zyklon-B?
   A.   I told you before that I have read parts of the trial
and
        part of testimony.  In detail, they are the testimony
of
        Alfred Zamm.
   Q.   This question is not meant to be the least bit
offensive,
        but you are not an expert in disinfestation, are you?
   A.   No, I am not.
   Q.   The company of Tesch and Stavanacht were, in fact, the
        leading disinfestation experts in the whole of Europe

.          P-136



        which is why their Managing Director found himself on
the
        end of a British rope in 1946?
   A.   I do not think that is why he found himself on the
rope,
        but they were the leading firm, yes.  They developed
the
        procedure.
   Q.   The record of the trial shows that both he and his
fellow
        convict, Weinbarer, repeatedly visited these camps and
        checked what was going on and trained the local staff
in
        the proper application and use of these pesticides and
        fumigating agents, these materials, is that not right?
   A.   I remember that in the transcript of what I read that,
        indeed, there is a mention of these visits, but I
would
        not comment in detail since I do not have them in
front of
        me.
   Q.   Is it not right that during the trial, which is
recorded
        verbatim -- it is in the Public Record Office, in fact
--
        the accountant of the company was required to produce
the
        records on which you have partially based your
        calculations showing precisely what the deliveries of
        Zyklon-B to Auschwitz were during the years concerned
for
        precisely the same exercise that we have been doing in
        court today?
   A.   That exercise has not been done.
   Q.   In the Tesch trial?
   A.   At the trial, at the trial they did not do this
exercise.
   Q.   Have you read the letters of clemency that were
submitted

.          P-137



        to the court after the death sentences were passed?
   A.   I have not.
   Q.   Yes.  Well, then we are in a difficulty.  Will you
take it
        Bruno Tesch, the Managing Director, when confronted
with
        the figures of Zyklon-B delivered to the Auschwitz
camp,
        and doing the calculation of how many sets of clothing
had
        had to be fumigated on a regular interval, on a
regular
        basis, and how many barrack buildings had had to be
        fumigated and disinfested, expressed astonishment that
        they managed to do the task with as little as 12
tonnes in
        that one year concerned?  He said that on these
figures
        they would have had nothing left whatsoever for any
kind
        of sinister purposes, and that this is very clearly
stated
        in the trial and in appeals for clemency?
   A.   I cannot comment on what Mr Tesch said.  What I can
        comment on is the fact that the amount of Zyklon being
        delivered to other camps was so much smaller than
        Auschwitz that I think this is a more interesting road
to
        pursue.
   Q.   That was, of course, the point of my interruption
which
        his Lordship quite properly reproved me for, when
        I pointed out that Auschwitz was receiving very large
        quantities of pesticide for a certain reason which you
set
        out so admirably in your first book, namely, that
        Auschwitz had been built in the middle of an area
which
        had traditionally over the centuries attracted typhus

.          P-138



        plagues, and it was the heart of a terrible typhus
plague
        in 1942?
   A.   I do remember what is in my book without actually
having
        to consult it.  I never say anywhere in the book that
        Auschwitz was a place which was suffering typhus
plagues.
        I only mentioned the issue of climate actually in the
        discussion of an introduction of Jan Sehn to his
report on
        Auschwitz where Jan Sehn makes a very big point of it,
and
        where I say actually I disagree because Jan Sehn in
some
        way tries to create a context of unhealthiness for the
        place as if the Germans had chosen Auschwitz with this
in
        mind.  I say this, obviously, is not supported by
        historical evidence.
   Q.   Had Auschwitz ever been used as a disinfestation
centre
        for transients in previous generations or before the
Nazis
        came?  Had they used it -- it was right on the border
of
        the Austro-Hungarian Empire, was it not?
   A.   Yes.  This is part of my research in the past has been
        actually on the origin of the camp, and the Sturmlager
was
        originally created as a labour exchange.
   Q.   Yes.  It had all the appropriate installations there
for
        fumigating the transients, did it not?
   A.   They had no installations whatsoever for the
fumigation of
        transients.
   Q.   Not for preparing them in this manner?
   A.   I mean, one of the big problems was, of course, that

.          P-139



        Zyklon did not exist at the time, at the time that
when
        the camp functioned there were also no steam
installations
        or hot air installations.
   Q.   Have I read your book entirely wrongly then when you
        suggest that the transients were held in Auschwitz for
a
        while and subjected to appropriate measures to make
sure
        they were fit for travelling into a cleaner part of
        Europe?
   A.   I have -- I think you are confusing two things.  I can
see
        where the confusion comes from.  There is one quote I
make
        a general, in the book, a general kind of description
of
        the movement of Eastern European Jews who go to
America
        and who cross the border and at a certain moment are
going
        to be -- their clothing is going to be deloused one
way or
        another.  It does not say what way it is.  It is an
        account of a girl called Mary Anton who panics ----
   Q.   I remember this, yes?
   A.   --- at this thing, so that is the one account which is
        there.  The second account is about the use of ----
   Q.   Because they are taken off the train and sent in to be
        washed, am I right?
   A.   Yes, and she gets very nervous about that.
   Q.   She says, "Oh, my God, they are going to gas us"?
   A.   No, "to kill us", not "gas us"; and those facilities
        existed, some of them at the border and also they
existed
        in the harbours of Bremen and Hamburg.

.          P-140



   Q.   When was that?  Roughly what year was that?
   A.   This was 1880s, 1890s.
   Q.   So it has been a problem over the decades, there has
been
        a problem in that region?
   A.   I mean, the German ----
   Q.   It is a very swampy region, is it?
   A.   No, I mean, but this was happening all over the East,
that
        people who were, that Jews, migrants who were leaving
the
        Russian Empire were subjected to German hygienic
measures
        as they crossed the border or came into the harbours
of
        Bremen and Hamburg where they were placed in
quarantine.
        There were special areas of the harbour where these
Jews
        were quarantined.  There were these kinds of
        installations.  However, Auschwitz was slightly
different
        because while Auschwitz, at the one side, had these
        transmigrants who went over the border there, because
it
        was a border town, the camp was not created with that
in
        mind.  The camp was created, the Sturmlager was
created to
        very specifically house transmigrant workers who all
        converged on Auschwitz in March and April of every
year
        looking for seasonal work in Germany.  There were only
        three little hotels in the town, and the hotels said
these
        people were living on the street, and there were 10 or
        15,000 people living on the street.
                  So, the Austrian Government decided to
create a
        centre at the border where these people could be
housed

.          P-141



        and where then also German agents for the various
        employment opportunities, like the Jungkris(?) in the
        estates, could come, send people on and then the most
        important function there was to actually check if all
the
        young men had done their military service and were
allowed
        to leave the country.
   Q.   And that was Auschwitz, right?
   A.   That was in Auschwitz.
   Q.   Yes.  Just to round off this topic of the Zyklon
        consumption figures, you have done very interesting
        calculations, and I have to admit they are admirably
done,
        the calculations.  You arrive overall at the end of
these
        very lengthy and complicated calculations at a
probable
        consumption of nine tonnes?
   A.   Nine tonnes in the camp in 1943, yes.
   Q.   As opposed to the 12 tonnes that we know to have been
        delivered.  Is this a meaningful difference, in your
view,
        in view of the fact that you are totally inexperienced
in
        pest control?
   A.   I invite other people to redo the calculations again.
        I thought that, as far as an historian, I must say
that
        using the maximum delousing capacity of the camp and
the
        maximum -- and how much it will take on the basis of
        German documents to delouse the whole camp ----
   Q.   Does it make any allowance for inefficiencies of any
        measures anywhere?  Does it make your usual engineer's

.          P-142



        allowance for inefficiencies somewhere or mistakes?
   A.   I think that I have made a very generous assumption in
the
        amount of Zyklon-B which was being used.
   Q.   Or for quantities being sent on to the satellite
camps?
        These are things which you did not -- in my
submission,
        there is no significant difference statistically over
that
        range of calculations and figures and, given the
        uncertainty of the starting points between nine tonnes
and
        12 tonnes, on the one hand, is that correct?
   A.   Nine tonnes can be justified, but it is a very high
number
        because I am assuming two complete delousings of the
camp,
        of all the buildings in the camp, per year.
   Q.   If you had assumed three, of course, you would have
come
        over 12 tonnes, would you not?
   A.   No, I would come over nine tonnes.
   Q.   Yes.  You said you were just assuming two?
   A.   Not over 12 tonnes.  But at a certain moment the
question
        is how many delousings of the whole camp were
operated.
   Q.   We just have two eyewitnesses, is this correct, who
        suggests that -- one of them was one of the
eyewitnesses
        to whom, I have to say, I attach little credence and
the
        other one I may or may not be correct in saying she
only
        records three or four, is that correct, in the time --
--
   A.   During her whole time in the camp.

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