Archive/File: people/i/irving.david/libel.suit/transcripts/day013.16
Last-Modified: 2000/07/20

   Q.   ---- "Which I received today.  Your compliments on my
        English are undeserved but Cassell's Dictionary being
        rather a help, I think I had better continue writing in
        English".  Then I am afraid it gets harder and harder.  Is
        there anything in that letter which betrays a good reason
        not to accept the evidence of Mr Miller, given that he is
        not after all writing under the heel of the communists of
        East Germany?
   A.   This is the second letter, not the first letter of course.
   Q.   No, but answer my question.  I cannot read the first
        letter.  It is blank.  Is there anything about that letter
        which makes you suspicious of his veracity?
   A.   His veracity?
   Q.   Yes.
   A.   I do not think he is deliberately lying, no.
   Q.   No.  so there is no reason to suspect his good faith?
   A.   Yes.
   Q.   Is there any reason to suspect that he is not telling what
        is accurate?
   A.   He is telling me what his recollection is of the events to
        the best of his ability, given what he admits is a poor
        recollection of details.

.          P-140

   MR JUSTICE GRAY:  Names.
   A.   Well, names, etc.
   MR RAMPTON:  Names, and the effect of his evidence is twofold.
        First, that the amount of dead persons that they had
        managed to count by I think the middle of March was
        30,000.
   A.   I would say may well be the result of cross pollination
        from the fact that this was the figure which was always
        stated in the western media and in the East German media.
   Q.   He writes in the middle of March 1945, "Our task was
        almost completed.  The town was free of corpses.  My
        records at the clearing staff showed 30,000.  If you
        assume that the amount of dead, completely burnt, etc.
        would reach 20 per cent, the total figure of victims will
        not exceed 36,000".  Then he goes on to explain in quite a
        lot of detail in the second letter how it was impossible
        that 68,000 corpses could have been burnt in the Altmarkt,
        does he not?
   A.   Are you referring to the second letter of February 25th?
   Q.   Yes, February 25th, PS, which is set out on page 539 to 40
        of Evans' report.
   A.   There is nothing on this letter of February 25th by nature
        of a PS, and there is no reference to those figures.
   Q.   Well, then poor Professor Evans must have made it up.
   MR JUSTICE GRAY:  Well come on, no.  In a post script typed a
        day later.

.          P-141

   MR RAMPTON:  Yes.
   A.   It is not on these pages I have here.
   MR JUSTICE GRAY:  No.  I suspect that is the explanation.
   A.   Again, I can only talk in generic terms and say that
        I collected several thousand letters of this nature when
        I wrote the book, far more material than I could possibly
        use, and I would be looking for specific pointers in an
        instinctive way as to which letters were written.  I think
        it is acceptable, it is common knowledge that some people
        have better memories than others.  Some people have better
        short term or long term memories than others.  They can be
        the same age, but their memory differs from person to
        person.  I would have been looking for people who had
        specific information about specific events rather than
        more general information.
   MR JUSTICE GRAY:  I am sorry, Mr Irving, for interrupting, but
        I cannot understand how you could get more specific
        information then the information from Mr Miller, whose job
        it was to compile records, that his records at the
        clearing staff showed 30,000 corpses.
   A.   That is the only specific information contained in it.
   Q.   What more can you want than that?
   A.   If I was to sit down and type an index card on that
        letter, that is all it would contain.  I would say, it
        says he was a member Aufrollungskommando based on such and
        such a place, recalls figure 30,000.  Against that I would

.          P-142

        set the fact, well, this is the figure which all the West
        German Press says, this is the figure that the East German
        Press says, it does not really advance the cause of our
        knowledge.  I would clearly recognize that as being an
        echo of what this man is reading in the press, my Lord, at
        that time.
   Q.   So he is a liar, then?
   A.   No, a liar is somebody who wilfully ----
   Q.   But he says, "My records at the clearing staff showed
        30,000 corpses".  That is a lie if what he really means
        is, "I read in the press the other day that it is
        30,000".
   A.   I agree.  I think he is fantasizing slightly.
   MR JUSTICE GRAY:  He is fantasizing?
   A.   Yes.  We remember that Ada Bimko also remembered seeing 4
        million in the Auschwitz record that she read.
   MR RAMPTON:  Mr Irving, we know, with the wonderful benefit of
        20.20 hindsight, that, so far from Mr Miller being a
        fantasist, he actually got the figure more or less spot
        on, did he not?
   A.   His figure compares very closely with the figure contained
        in the police chief's report.
   Q.   And in the genuine TV 47, and in Reichert's book, and
        everywhere else you want to look, the true figure is
        somewhere between 25 and 35,000 at the maximum, is it not?
   A.   Except for the fact that, if you look at that little

.          P-143

        passage sideways on the letter, page 2, he says, "by the
        way, the figures of dead were reported every day to a
        central air defence staff in Berlin".  Now, I am quite
        familiar with those records and there is no such figures
        reported from Dresden over that period.  It is that kind
        of thing that would have lit a little alarm light in my
        brain.  That is exactly the kind of place that I was
        looking for data like this, and had there been daily
        reports coming from this Aufrollungskommando in Dresden,
        I would have seen them.
   Q.   Now I wonder ----
   A.   I admit 20.20 hindsight is very nice, but we are not
        blessed with it.
   Q.   No.  I only said that in the poor man's defence.  For all
        I know, he is sitting in Ingoldstadt on the Donnau,
        reading books of this case.  You accuse him of being a
        fantasist.  As it turns out, his information was almost
        precisely accurate.
   A.   Well I said this in response to his Lordship's suggestion
        that I was imputing that the man was a liar, and I thought
        that that was going too far, the fact that he said that
        they kept records, and the fact that he said, "we had
        30,000", I would not----
   Q.   He was right.
   A.   I would not have said that this was evidence of lying.
        I would suggest that this was evidence of the fact that

.          P-144

        yes, he was telling the truth about keeping records and
        that he then tacked the figure of 30,000 on because he
        knew that was the newspaper figure.
   Q.   I am sure he will be delighted to read that in the
        newspaper.  Mr Irving, I am going to leap ahead, if
        I may.
   A.   Perhaps one day I shall bring my entire Dresden records to
        court and then his Lordship can see how many thousands of
        pages these are selected from.  This is a very easy
        exercise to perform, if you want just want to suggest that
        someone is suppressing documents.
   Q.   My Lord, I am now turning to page 9.  I am going to the
        early summer May 1966.  Have you got that, Mr Irving?  It
        helps to follow the chronology?
   A.   We are back on your tabulation.
   Q.   Yes.  I do not know whether Boberacht's discovery of
        situation report 1404 was communicated to you.  Was it?
   A.   As I mentioned earlier today, I received both those
        documents in the same post on my return from abroad.
   Q.   In May 1966?
   A.   Yes, both the East German one and the West German one.
   Q.   Right.  Which is which of those?  Boberacht is East
        Germany, is he?
   A.   Boberacht was the head of the West German archives.
   Q.   His figures were 18,375 current death roll up to 22,345,
        expected death roll 25, and 35,000 missing, yes?

.          P-145

   A.   Yes.
   Q.   Whereas the one from East Germany, we do not have the
        figures here but I know what they are and I am sure you
        do.  So that up to early 10th March 1945 there were 8,735
        dead, 2,212 badly wounded, 13,718 slightly wounded, and
        350,000 homeless and long term re-quartered, did it not?
   A.   Yes.
   Q.   Upon receipt of those documents you must have given this
        problem some very considerable thought, did you not?
   A.   I discussed them with my London publisher.
   Q.   You wrote a letter to The Times?
   A.   My London publisher advised me to keep quiet about them.
   Q.   Never mind.
   A.   This is quite important.
   Q.   Oh no, Mr Irving ----
   A.   He said, you will do yourself discredit if you let people
        know that there are figures that dispute yours.
   MR JUSTICE GRAY:  But you form a judgment.  You do not do what
        your publisher says?
   A.   If you are dependent upon your publisher for your entire
        livelihood, sometimes you do, my Lord.
   MR RAMPTON:  So much more so, Mr Irving, if I may be a little
        cynical for a moment, if you should go on trumpeting the
        200 to 250,000 figure, and these two documents should be
        brought forth by somebody else.  Much better to come clean
        to protect yourself.

.          P-146

   A.   This was one argument I used to the publisher, of course.
   Q.   Quite right, too.  You wrote to The Times.  I am not going
        to read it out.  On 7th July, it is at page 56 of this tab
        2, you said that, in effect, you thought that the original
        TB47 figures were falsified and that you had no interest
        in promoting -- this is the last paragraph -- "or
        perpetuating false legends and I feel it is important that
        in this respect the records should be set straight".
   A.   I do not refer to TB47 in this document, of course.
   Q.   No, but that is what you mean, is it not?
   A.   But you implied that I did.
   MR JUSTICE GRAY:  Well, you do eat humble pie.  One does not
        want to skim over this letter so quickly.  In the second
        paragraph you do say you are to blame for all this, you
        got it wrong.
   MR RAMPTON:  Yes.  Quite right.
   A.   Yes.
   Q.   You say at the end of the third paragraph -- Mr Irving,
        sometimes it is not good to be too much of a trainspotter
        -- "Two years ago I procured from a private East German
        source what purported to be extracts from the police
        president's report" -- that is the forged TB47, is it not?
   A.   Yes, that is correct.
   Q.   -- "quoting the final death roll as a quarter of a
        million.  The other statistics it contained were accurate
        but it is now obvious that the death roll statistic was

.          P-147

        falsified, probably in 1945".
   A.   Yes.
   Q.   That is a reference to TB47.
   A.   Yes.
   Q.   And a recognition that it was a forgery?
   A.   That is correct.  No, that the figure was falsified.
   Q.   Yes.  I agree.
   A.   The document was genuine but the figure was falsified.
   Q.   Sure.  That is what you do if you are a reasonably good
        liar or forger.  You get as close to the truth as possible
        but falsify the crucial fact.  Now, in August 1966 you
        were ----
   A.   Can I just draw your Lordship's attention to the fact that
        what you are looking at on that page 56 is not the actual
        page from The Times, which actually looked like this - ---
   MR JUSTICE GRAY:  What is the point?
   A.   That I went to the trouble of having 500 copies of that
        letter printed at my own expense.
   Q.   I see.
   A.   That is what you are looking at there.  I wonder how many
        historians would actually do something like that and sent
        it to historians around the world to correct the error
        that I thought I had made.
   MR RAMPTON:  That is what is troubling me, Mr Irving.
   A.   I am sure.
   Q.   No, for quite a different reason.  In August 1966 an

.          P-148

        Italian edition of your book was about to be published,
        was it not?
   A.   Yes.
   Q.   Can you please turn to page 65 of this tab?  My Lord, I am
        now on page 10 of the tab.  You wrote to your Italian
        publisher, a Miss Calabi on 28th August 1966:  "Dear
        Miss Calabi, thank you for your letter.  I have now
        written out the few alterations that are ideally necessary
        for my book, The Destruction of Dresden, in the light of
        the new documents I have obtained from Germany." Those
        are the two documents we have just been discussing, are
        they not?
   A.   Yes.

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