Archive/File: people/i/irving.david/libel.suit/transcripts/day014.08
Last-Modified: 2000/07/20

   MR RAMPTON:  I am sorry, I am a little bit at sea, Mr Irving,
        because this has only just been brought to my attention.
        You were asked some questions in an IHR conference on 4th
        September 1983 -- I am telling you this as a fact because
        I have the printed version in front of me -- and the
        question was: Could you give your reaction to the recent
        book by Gerald Fleming, "Hitler und die endlosung", so we
        are talking about the same thing, are we not?
   A.   Yes.
   Q.   Then you say this.  I have not been able to edit it
        because I have only just been shown it. "Yes, Gerald
        Fleming, frightfully nice, he and I were face to face once
        on the David Frost programme" -- again it does not seem
        to be much of an answer to the question -- "for an hour
        and a half in England on television.  He was not able to
        prove me wrong then.  He has ever since felt mortally
        wounded by the fact that he was not able to prove me wrong
        in front of" -- goodness me, this is all about the

.          P-65

        television audience.
   A.   I am failing to answer a question, am I?
   Q.   Yes, you are.
   A.   Yet again.
   Q.   Because you were asked the question, what do you think of the book?
   A.   Well, I probably did not want to admit that I had not read it.
   Q.   The reviewers admit in reviewing his book that he has not
        found the evidence that I am wrong, that he has not found
        documentary proof.
   A.   That is exactly what I just said 17 years later.  My
        memory is not all that bad.
   Q.   "His book in fact is a lie"?
   A.   Yes.
   Q.   How on earth can you say that about a book you have not read?
   A.   I have read the reviews.  The book was written as an
        attempt -- the book has been written specifically, it says
        in the introduction, this is an attempt to answer David
        Irving.  The whole reason he wrote the book was to answer
        my book "Hitler's War".  I read the reviews by Tom Bower
        and numerous other people and they say this book has
        failed to refute David Irving.
   MR JUSTICE GRAY:  I am sorry, I am going to come back to what
        seems to be perhaps more important.  I had the impression,

.          P-66

        and it is a long time ago now that we had evidence about
        it, that you accepted that Hitler was kept informed about
        the shootings by the Einsatzgruppen?
   A.   You are absolutely right, my Lord.  Certainly as far as
        the Russians Jews were concerned, and the non-German Jews
        were concerned.
   MR RAMPTON:  My Lord, I am on the question whether Mr Irving
        was telling the truth when he said first time around that
        he had never seen this document.
   A.   I can tell you I have never seen this document before in
        my life.
   Q.   Mr Irving, laughing will not help.  I am going to read on
        what you said at this IHR conference shortly after the
        book was published.  "The book is a lie because the book's
        title is 'Hitler and the Final Solution' when underneath
        is a subtitle in quotes, 'it is the Fuhrer's wish...'".
   A.   It is the Fuhrer's order, yes.
   Q.   "As though this is from some document.  In fact it is
        not.  This is just what some Nazi big wig after the war,
        sweating and pleading for his life in the dock at
        Nuremberg or somewhere else, tried to claim that it was
        the Fuhrer's wish that this should be done. This is
        precisely the kind of evidence which I am not prepared to
        accept.  It is a well-written book.  He has done a lot of
        research but he constantly mixes first, second and third
        order evidence in a completely reprehensible way".

.          P-67

   A.   Yes.
   Q.   You did not read the book?
   A.   This is precisely what the reviewer said.  Actually,
        exactly what the reviewer said about the book.  I can
        produce to you tomorrow the reviews by Tom Bauer and
        Gordon Craig and the other reviewers of the Gerald
        Flemming book.
   Q.   Mr Irving, was there in your discovery ----
   A.   And also in correspondent with me he told me what he was
        going to base his subtitle on, namely a particular
        statement by a particular General.  Every time he found a
        new document, he would write me a triumphant letter.
        I remember that one particularly.
   Q.   Mr Irving, was there in your third supplemental list of
        documents two editions, one in German -- no, sorry, an
        edition of a German book by a man called Koegon and
        others?
   A.   Eugene Koegon, yes -- a murderer.
   Q.   And you know that its German edition is called "National
        Sozialistische Massentugenturm Durch Giftgas"?
   A.   That is right.  Koegon is on the United Nations "Wanted"
        list for mass murder.
   Q.   What is the point of that remark?
   A.   Well, I am just trying to, shall we say, equalify the
        author of this work so that you know what kind of
        credentials he has.

.          P-68

   Q.   I am not interested in the very least in Mr Koegon's
        credentials.  He has not brought an action for damages for
        libel against my clients.
   A.   Well, just in case you rely on anything Mr Koegon wrote.
   Q.   No.  Have you a copy of the English edition published in
        New Haven in 1993?
   A.   That I do not know offhand, probably not.
   Q.   It has been disclosed in your supplemental list of
        documents.
   A.   Well, then, it is probably on my book shelf, yes.
        I certainly would not have purchased it.  Somebody must
        have handed it to me.
   Q.   You what?
   A.   I would not have purchased it.  Somebody must have sent it to me.
   Q.   You would not have purchased it?  So that is another book
        you will never have read?
   A.   Oh, yes.
   Q.   You mean you will not have read it?
   A.   Highly unlikely that I would have read it and I can say
        for certain I have not read his book.
   Q.   You see, it contains printed out in full -- if you are
        interested in this subject, of course ----
   A.   Yes.
   Q.   --- what the people were doing to the Jews in that part of
        Eastern Europe during 1941, '42 and'43, if you are

.          P-69

        interested in that subject, it contains printed out in
        full the RSHA letter of 5th June 1942 which recites that
        they have managed to process 97,000 people in gas vans at
        Chelmo.  Do you remember that document?
   A.   Yes, the incredible -- 97,000 people in how many weeks,
        five weeks?
   Q.   Five weeks.
   A.   That is approximately 40 people her hour per van.
   Q.   You accepted it.  I am not going back to that, Mr Irving.
   A.   Well, we are going to be questioning your experts about
        those figures when the time comes.
   Q.   You may do whatever you like with my experts ----
   A.   I remember the document clearly.
   Q.   Provided, Mr Irving, you let them finish their answers.
        Mr Irving, that document, you accepted when I was
        cross-examining you earlier in this case ----
   A.   It is a genuine document.
   Q.   Yes, and you accepted that it showed that, so far from
        being an experiment on a small scale, this was a
        systematic and large scale operation?
   A.   Well, we are going to be looking at the figures later on,
        as I say.
   Q.   Mr Irving, you have already accepted that.
   A.   Do not start brow beating me about the figures.  I have
        accepted the document is genuine, but we are going to be
        looking at the figures when your experts are standing

.          P-70

        here.
   Q.   If we need to go back, Mr Irving, to see what you actually
        said, we will, but that is not the point.  You denied ever
        having seen that document before?
   A.   Yes.
   Q.   But you have a copy of the book in which this document is
        actually printed?
   A.   And?
   Q.   Are you interested in this period of history or not?
   A.   I am not interested in that aspect of the history, no.
        I am interested in Adolf Hitler's personal role in
        decisions taken during World War II.
   Q.   And you do not think the question whether or not these
        gassings and shootings in the East were large scale and
        systematic has anything to do with Hitler's role, is that
        is right?
   A.   Mr Rampton, I do not know if you have ever written a book
        in your life.  You probably have.
   Q.   As a matter of fact, I have.
   MR JUSTICE GRAY:  We have had this before, yes.
   MR RAMPTON:  It is a very small book and not a very good one,
        but it does exist, yes.
   A.   Well, I can believe that.
   MR JUSTICE GRAY:  Come on, it is ----
   A.   But the time comes when you have ----
   MR JUSTICE GRAY:  --- degenerating.

.          P-71

   A.   Well, that was well deserved modesty on his part.  The
        time when you are writing a book when you have to decide
        what to leave in and what to keep out if the book is not
        going to be 2,000 pages long with 8,000 pages of sludge in
        the middle.  If you are writing a book about Adolf
        Hitler's command of the war and his command decisions,
        then really what happens in detail, the crimes committed
        by these gangs of gangsters on the Eastern Front, you have
        to decide to leave the detail out otherwise your readers
        will not see the wood for the trees.
   MR RAMPTON:  So we have now two books in your possession, one
        was sent to you by the kindly -- is he Professor Fleming?
   A.   I think he probably sent it to me himself.  Yes, I think
        he actually dedicated it to me.
   Q.   And one which either somebody sent you, you certainly
        would not have bought a book by the mass murderer
        Mr Koegon?
   A.   That is what surprises me.  You say it is in my book shelf
        and I am sure nobody planted it there, but ----
   Q.   It is in your discovery, Mr Irving.
   A.   But, for the life of me, I never knew I had that book in
        my book shelf.
   MR JUSTICE GRAY:  Can we just go back to Professor Fleming's
        book for a while?  Correct me if have this wrong,
        Mr Irving, you are saying that what you said at IHR press
        conference was derived from the reviews, not from your

.          P-72

        reading of the book.  One of the things that you said was
        that Professor Fleming is given to citing second and
        third-hand documents?
   A.   Yes.
   Q.   So your evidence is that that also would have come from
        one or other of those two reviews?
   A.   Well, and from the fact that he and I were in almost daily
        correspondence at that time and also on the telephone, he
        would be constantly on the telephone to me, telling me
        about his latest discoveries and latest finds and what he
        was doing and what he was writing.
   Q.   I thought your evidence earlier on was that what you had
        said came from the reviews.
   A.   Well, and from the reviews, yes, but you asked me, my
        Lord, if I have understood correctly, whether my statement
        to the IHR was based only on the reviews, and I was saying
        that those and the personal communications I had with him
        on a daily basis and, indeed, a very, very thick file of
        correspondence with him indeed, mostly handwritten on his part.
   MR RAMPTON:  There is one more book I am going to ask you
        about, Mr Irving.  Do not take it from my silence that
        I accept a word of what you say.  The coincidence is too
        great, if I may say so.  There is another book.  Do you
        remember Gertz Bergander's book about Dresden?
   A.   Indeed, yes.

.          P-73

   Q.   You told us yesterday you have never read that either, did
        you not?
   A.   Certainly I never read it from cover to cover, no.
   Q.   I asked you twice.
   A.   Yes.
   Q.   I asked you, "Have you read this 1977 book of his?"
        Answer,"No, I have not".
   A.   Can I enquire what you mean by "read"?  Do you mean
        sitting down and opening at page 1 and reading through or
        dipping into it to look for a fact or item?
   Q.   The context was that you had not read it in such a way as
        to be able to evaluate the figures he gave.
   A.   I want to be precise about the answer I give here, so I
        know what you mean by "read".
   Q.   You actually interrupted a question -- not for the first
        time -- that I was asking.  I will read the whole
        passage.  My Lord ----
   MR JUSTICE GRAY:  Page.

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