Archive/File: people/i/irving.david/libel.suit/transcripts/day020.11
Last-Modified: 2000/07/24

   Q.   Do you agree that it is a well-financed campaign?
   A.   I am trying to -- can I just say what I say in the report,
        because that will make it much simpler to answer.  In the
        preface to the English edition of the Leuchter report you
        wrote:  "Nobody likes to be swindled, still less where
        considerable sums of money are involved".  You go on to
        say:  "Millions of honest, intelligent people have been
        duped by the well financed and brilliantly successful post
        war publicity campaign which followed on from the original

.          P-93

        ingenuous plan of the British Psychological Warfare
        Executive (PWE) in 1942 to spread to the world the
        propaganda story that the Germans were using 'gas
        chambers' to kill millions of Jews other 'undesirables'."
        I go on to say then that this is the typical Holocaust
        denier's argument that the "myth" of the Holocaust has
        been kept going by a "well-financed" campaign in order to
        legitimize the paying of German reparations to the State
        of Israel.  Quite clearly, I do not accept that everyone
        who has written about the gas chambers in Auschwitz and
        elsewhere, and the Holocaust, the extermination of the
        Jews, has been financed in order to legitimize the paying
        of German reparations to the State of Israel.  I think
        that is an appalling slur on the large numbers of decent
        and serious scholars who have devoted a large amount of
        their lives to doing this.  I think it is a
disgraceful
        remark.
   Q.   I must insist that you answer my questions briefly
because
        I ask the questions and then I am the one who gets
into
        trouble when you answer at such length.
   A.   Yes, Mr Irving, but your question did not make it
clear
        what I was saying in my report.  I felt it necessary
to
        say what I was saying.
   Q.   Have you heard of the phrase "instrumentalization of
the
        Holocaust"?
   A.   I have certainly heard of that, yes.

.          P-94



   Q.   Can you answer in two or three lines what you
understand
        by the phrase "instrumentalization of the Holocaust"?
   A.   It is an accusation sometimes levelled at people who
make
        a reference to the Holocaust and are accused of doing
so
        for ulterior motives.
   Q.   Is this the allegation that somebody like Norman
        Finkelstein makes?
   MR JUSTICE GRAY:  I do not really think that matters.
   MR IRVING:  Page 168, paragraph 50, line 3, those three
dots,
        you agree, stand for 58 words, five commas, two full
stops
        and a colon, is that right?
   A.   I think we have already been through this.  I do not
think
        that is right, actually.
   MR JUSTICE GRAY:  We are not going to count the full stops.
        Come on, Mr Irving.  You have made your point about
        selective quotation.
   MR IRVING:  Page 51:  This goes to the anti-Semitism
element,
        I suppose, does it not?
   A.   Paragraph 51.
   Q.   Yes.  I have made a speech in 1992 and you take
exception
        to my description of the Board of Deputies, and the
words
        that I use.  Is any criticism of an organization like
that
        permissible, do you think?
   A.   I do think it is rather over the top to describe the
Board
        of Deputies of British Jews as cockroaches.
   Q.   If you are familiar with the methods that they have
used

.          P-95



        to try to destroy a professional historian's career
and
        family, would that professional historian be entitled
to
        use pretty colourful language to describe these people
who
        are secretly trying to destroy him?
   A.   That is a very hypothetical question.  I think what
you
        are saying there is that the Board of Deputies of
British
        Jews have been engaged in a secret campaign to try and
        destroy your livelihood.
   Q.   That is what I said.  If the intention is to destroy
an
        author and his family and his career and livelihood by
        underhand methods or by whatever methods, is he not
        entitled to defend himself and use occasional lurid
        language?
   A.   I would have to first of all see evidence to persuade
me
        that such a secret dastardly campaign had been carried
        out.  I do not want to answer a hypothetical question
of
        that nature.  I do think that professional historians
        should be reasonably measured in their language.  I do
not
        think that is an appropriate word to use.
   Q.   If the court is shown a document showing that at this
        precise time that body was contemplating putting
pressure
        on that author's publisher to stop publishing his
books
        and thereby destroy his career and livelihood, and
they
        were doing it behind armour plated doors in their
        headquarters ----
   MR JUSTICE GRAY:  Show the witness the document and then we
can

.          P-96



        see.
   MR IRVING:  May I do so, my Lord?
   MR JUSTICE GRAY:  Yes, of course.
   MR IRVING:  Would you go to bundle E?
   A.   I am not sure I have this.
   MR JUSTICE GRAY:  Bundle E.  No, you may well not have.
   MR IRVING:  I am looking for the document.  Page 82 in the
        bundle called Global.
   A.   This is a meeting on 12th December 1991, Education and
        Academic Committee?
   Q.   The Education and Academic Committee of the Holocaust
        Educational Trust.  Can you read item No. 6 please?
   A.   "David Irving.  Concern was voiced over the
publication of
        the second edition of Hitler's War.  There was debate
over
        how to approach Macmillan publishers over Goebbels
Diary.
        It was agreed await news from Jeremy Coleman before
        deciding what course of action to take".
   Q.   I am not going to go into the remaining documents in
that
        bundle, Professor Evans, but, if I put it to you that
this
        is evidence and that other documents will be submitted
to
        court later on, the pressure that was put on my
publishers
        by this body, which is part of the Board of Deputies,
        which was meeting at their headquarters, am I not
entitled
        to use that kind of language to describe these people?
   A.   Well, to be quite honest, no.  This is a meeting of
five
        people, Mr Coleman, Professor Gould, Professor
Polonski,

.          P-97



        Mr Nyman and Dr John Fox.  It is not a meeting of the
        Board of Deputies of British Jews.  Where it takes
place
        I think is pretty immaterial.  It says that there is a
        debate, but they agreed that they are not going to do
        anything.  So I do not think that is justification for
        calling the Board of Deputies of British Jews
cockroaches.
   MR RAMPTON:  What is more, there is another thing needs to
be
        pointed out.  That document, which is the first time I
        have seen, is dated 12th December 1991.  It is
predated
        therefore by some months by what Mr Irving said, which
        apparently was said on 5th October 1991.
   MR IRVING:  Are you ----
   A.   It post dates it?
   MR RAMPTON:  Yes.  The document post dates the Irving
statement
        about cockroaches.
   A.   You said predates.
   MR RAMPTON:  I am sorry.
   MR IRVING:  I do not want to hold up the court at this
point,
        but will you accept that that bundle you are holding
        called Global is about three inches thick, and
contains
        many hundreds of documents?
   MR JUSTICE GRAY:  That is not a terribly illuminating
question.
   MR IRVING:  My Lord I do not really want to read through
all
        the other documents.
   A.   It is not a very contentious statement.
   MR JUSTICE GRAY:  No, I am not asking you to.  Anyway, I
think

.          P-98



        we will move on.  You have put that document.
   MR IRVING:  Precisely.  Witness, will you accept that, on
the
        balance of probabilities, there are other documents of
        that nature in that bundle?
   MR JUSTICE GRAY:  If I may say so, Mr Irving, we must do
better
        than that.
   MR IRVING:  Mr Rampton has suggested that this was it, and
so
        what.
   MR JUSTICE GRAY:  What it comes to is, if there was in
        existence a document prior to what you said about the
        British Board of Deputies being cockroaches, which you
say
        justifies you having said that, then put it to the
        witness.  If you have not got such a document, move
on,
        please.
   MR IRVING:  I shall put it to the court in due course, my
Lord,
        the whole bundle, as your Lordship is familiar.  If an
        author is aware that such a campaign is being
conducted
        against him by a body of whatever class or colour or
race
        or religion, is he entitled to use lurid language in
        private?
   MR JUSTICE GRAY:  You have asked that question many times
        before and that is a comment.  You have not
established
        the factual premise for it, so can you move to the
next
        topic, which means going beyond page 168.
   MR IRVING:  My Lord, you say I have not established a
factual
        premise.  To do that I would have to go back to the
bundle

.          P-99



        and I do not want to do that at this point.
   MR JUSTICE GRAY:  In that case you cannot ask the question.
   MR IRVING:  The final five lines of that same paragraph:
"In
        April 1998 Mr Irving spoke of American Jews 'moving
into
        the same positions of predominance and influence'",
and so
        on, that they held in the Weimar Republic.  This is a
        quotation, is it not, from my diary in April 1998?
   A.   From your website.  Published on your website.
   Q.   It is a quotation from my diary in 1998?
   A.   Published on your website.  In other words, it is free
to
        anybody to access, which is what we did.
   Q.   Have you had access to all my private diaries?
   A.   I did not need access to your private diaries to get
hold
        of this quotation.
   Q.   Will you answer the question?
   A.   May I read the whole quotation first to establish what
we
        are talking about?
   Q.   Just answer that question.  Have you had access to my
        diaries?
   A.   I am sorry, I want to read the whole quotation to get
        clear what we are going to see, then I will answer
your
        question.
   Q.   Will you answer the question first?
   A.   In April 1998 he spoke of American Jews'moving into
the
        same positions of predominance and influence..."
   Q.   My Lord, will you instruct the witness to answer
questions

.          P-100



        put to him?
   MR JUSTICE GRAY:  I am despairing.  Would you let the
witness
        -- and then you can ask the question.  Read it out
        please.
   A.   "In April 1998 he spoke of American Jews 'moving into
the
        same positions of predominance and influence (media,
        banking, business, entertainment, and the more
        lucrative professions like law, medical and dentistry)
        that they held in Weimar Germany, which gave rise to
the
        hatreds and the resulting pogroms; and that this being
so,
        twenty or thirty more years might see in the USA the
same
        dire consequences as happened in Nazi Germany".
Extract
        from Irving's personal diary April 13, 14th 1998, on
        Irving's Focal Point website.  The answer to your
question
        is yes, I have had access to your personal diaries.
   MR IRVING:  Do you have any reason to suspect this is not a
        genuine diary, what is on my website?
   A.   I think it is as genuine as the Anne Frank diary, yes.
   Q.   I will repeat the question.  Do you have any reason to
        believe that this is not a genuine diary extract?
   MR JUSTICE GRAY:  The answer is no.
   A.   The answer is no.  I answered it.
   MR IRVING:  Will you go to page 88 of the bundle which is
F?
        My Lord, the purpose of this is purely to point out,
not
        words left out but surrounding material left out.
   MR JUSTICE GRAY:  Yes, context.

.          P-101



   MR IRVING:  Is this the diary as reproduced on my website?
   A.   It looks like it, yes.  I have downloaded on 15th
February
        2000.
   Q.   So it is a description of a lecture that I delivered
to
        students at the University of Washington State in
Pulman
        in 1998?
   A.   Yes, seems to be.
   Q.   The questions are the best part as usual, a German
girl
        student a quiet well spoken 20 year old, the Federal
        Republic's equivalent of a Rhodes scholar.  I carry on
now
        to the next paragraph.  The paragraph begins:  Several
        coloured students are there mostly training to become
        teachers.
   MR JUSTICE GRAY:  This has nothing to do with the context
of
        what Professor Evans quoted.  It is completely
irrelevant.
   MR IRVING:  They are bright and friendly.
   MR JUSTICE GRAY:  I have read it all.  The context?  This
adds
        nothing and subtracts nothing.  What is the point,
        Mr Irving?  Why are we looking at this?
   MR IRVING:  I am putting this in connection with the
allegation
        of racism.
   MR JUSTICE GRAY:  What, about several coloured students
being
        present?
   MR IRVING:  "Several coloured students were there, mostly
        training to become teachers.  They are bright and
        friendly".

.          P-102



   MR JUSTICE GRAY:  I see.  I thought we were looking at this
for
        context of what Professor Evans quoted.
   MR IRVING:  I used the eye witness testimony of General
Walter
        Bruns, which your Lordship is familiar with.  I read
out
        the whole of that document to these students, which
goes
        to the Holocaust denial issue.  This is a typical
speech
        by me to university students who are a bright and
friendly
        lot, and we have had just this one passage taken out
of
        context when a Jewish Professor from the floor asked
        questions and I put to him my take on the present
        situation in the United States.
   A.   Well, I do think that that is completely irrelevant.  If
        you want a little bit more, the context is:  "One
        questioner addresses the issue that I had raised in
        discussing the Daniel Goldhagen thesis, that if I were a
        Jew I would want to see an answer to the vital question
        why the Jews are so hated within only a few years of their
        arrival in each host country.  He points out that the Jews
        have now been in the United States in strength for 50
        years yet they are not hated.  I reply that, on the
        contrary, my own perception is that they are moving into
        the same positions", and so on and so forth.  That is the
        context.

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