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Last-Modified: 2000/07/24

   Q.   Have you ever compared the Kaiserhof edition, in other
        words, the published edition with the original handwritten
        edition as published now recently?
   A.   I have, yes.
   Q.   Have you evidence for saying that they were monkeyed
        around with?
   A.   Yes, yes, yes.
   Q.   Apart from changing "Hitler" to "Fuhrer" and various
        obvious cosmetic changes?  Can you give one example?
   A.   Large amounts were left out, of course, lots about

.          P-154

        Hitler's -- Goebbels' private life were left out.
   Q.   Is that monkeying around?
   A.   Of course it is, yes.
   Q.   Would you now go, please, to page 284 ----
   A.   Oh, back again.
   Q.   --- where we come to a more obvious example of what I am
        getting at?  The first line of page 284 of your expert
        report:  "Other evidence supports the diary", you begin
        this paragraph.  "On the afternoon of 10th November, after
        he had reported to Hitler, Goebbels informed the Nazi
        Party chief of Munich-Upper Bavaria that the pogrom was to
        be terminated and added" -- so this is a message, right?
   A.   Yes.
   Q.   Of the Adjutant to the Gauleiter recording this?
   A.   That is right, yes.
   Q.   And he adds:  "'The Fuhrer sanctions the measures taken so
        far and declares that he does not disapprove of them'"?
   A.   Yes.
   Q.   Now what do you infer from the way that has been put in
        that message?
   A.   Double negative?
   Q.   Apart from the grammatical observation?
   A.   It is pretty clear to me.
   Q.   Do you infer that there is a belief in certain quarters
        that Goebbels is alibiing in here, that he is saying that
        he acted on Hitler's behalf?  Why would this have been

.          P-155

        recorded, do you think, in this form?
   A.   Because Hitler's views were important in the Third Reich,
        it seems to me.
   Q.   So Goebbels has informed the Nazi Party chief of Munich,
        who would normally have no reason to believe otherwise,
        and said, "Oh, by the way, everything we did last night is
        OK.  It is in line with what the Fuhrer wanted", and this
        is not an unusual message, in your view?
   A.   Yes, I mean, it seems a reasonable thing to say, "The
        Fuhrer sanctions the measures taken so far".
   Q.   You do not read into this exactly the same as he is
        putting in his diaries ----
   A.   It puts them, it puts the recipients in the clear as to
        what they had done which they must have been, obviously,
        very worried about since there was a great deal of talk
        about involving the State prosecution and so on, as we
        have seen from the Party tribunal report.  There must have
        been a great deal of concern about it amongst those who
        carried them out.  After all, these were beatings up,
        murders, massive destruction of property, arson, looting,
        all these sorts of things.  So it seems to me important
        that the people who had done this were reassured in the
        eyes of the Nazi leadership that Hitler sanctioned the
   Q.   This is a document that you accept at face value without
        the slightest textual criticism or content criticism at

.          P-156

        all?  You do not ask yourself why that odd sentence is in it?
   A.   I have just given my criticism, as it were.
   Q.   In other words, your criticism is no criticism.  You
        accept it at face value?
   A.   Well, criticism in the sense of critique or source
        criticism when you ask why a document has been issued.
   Q.   You do not say to yourself:  "This is exactly the same
        kind of thing as Goebbels writes in his diaries, saying
         'What we did was entirely with the Fuhrer's consent'" and
        you say to yourself, "Why does he write that in his diary then?"
   MR JUSTICE GRAY:  Mr Irving, you have put that question several
        times.  I know the question, I understand your point.
   A.   The answer is because it is true.
   MR IRVING:  Well, page 289, paragraph 3.  We are now on the
        meeting on November 12th 1938 in the Reich Air Ministry
        building under the chairmanship of Hermann Goring as head
        of the four year plan.  This was the meeting at which the
        punitive measures were discussed and agreed between the
        various ministers.  Dr Goebbels is present, is he not?
   A.   Yes.
   Q.   Yes.  You say that Goebbels in his diary writes, "I am
        co-operating splendidly with Goring".  Does that strike
        you as being an accurate reflection of the relationship
        between the two on that day and at that time?

.          P-157

   A.   Yes, because the measures which Goring sanctioned were
        those which Goebbels put forward and which, indeed, had
        been suggested by Hitler in their meeting at the Osteria
        restaurant according to Goebbels' earlier diary.
   MR JUSTICE GRAY:  Do you mean a whitewash?
   A.   No, these are the -- sorry, my Lord.
   Q.   I am not quite sure what we are talking about.
   A.   What we are talking about here are the economic measures
        which on 12th November this conference was held to impose
        all the economic measures, a huge fine preventing the Jews
        from getting any insurance payments for the damage caused,
        and then a whole series of further measures about which
        I quote on page 290 about banning them from being in
        various public places, trains and all the rest of it.
        That is what we are talking about.  There is a legal
        wrapping up.
                  This is exactly what Goebbels says, as we see
        when he says in the kind of closing, the message to "Shut
        it all down, stop the actions, we are now going to take
        the legal road", and this is the legal road that he is
        talking about.
   MR IRVING:  Now we get back to the Goebbels diary where
        Goebbels describes this meeting in the most glowing terms
        of cordial relationship between him and Goring, would that
        be a fair description?
   A.   He says, "I am cooperating splendidly with Goring.  He's

.          P-158

        going to crack down on them too.  The radical line has won".
   Q.   Is that a fair and accurate reflection of what is
        contained in the verbatim transcript of that meeting?
   A.   It is a -- it is a very accurate summary of what
        transpired at the meeting, that is to say, that Goebbels'
         -- that Goring was persuaded, if he needed persuading,
        that there should be a crack down in the legal and
        economic sense on the Jews, as suggested by Hitler in the
        Osteria restaurant put forward by Goebbels.
   Q.   Are you familiar with the fact that Goring was livid with
        Goebbels for this pogrom that he had started because of
        the costs that it had inflicted on the German economy
        which he was now going to have to make good and the damage
        to the broken glass that they were going to have spend
        foreign currency on, and the insurance costs that the
        German insurance companies were going to have to meet?
        Are you familiar with those passages in that meeting?
   A.   Of course I am.  I quote them in the next paragraph,
        Mr Irving.
   Q.   Are you familiar with the fact that Goering sneered and
        said, what we need here is a little bit of public
        enlightenment?  What was that a reference to?
   A.   Mr Irving, I am not saying----
   Q.   Can you answer the question, please?  What was that a
        reference to?

.          P-159

   A.   No, I am not saying ----
   Q.   Can you answer the question, please?
   A.   I am not saying ----
   Q.   Can you answer the question, please?  What is "public
        enlightenment" a reference to?
   A.   I am not saying, Mr Irving, that there were no minor
        disagreements between the two.  I refer to these in
        paragraph 4 on page 289 to 90.  I am not claiming that
        Goring and Goebbels were bosom pals.  The relationships
        between the leading people in that gang of ruffians were,
        as one would expect, not particularly polite or loving or
        courteous.  Nevertheless, the fact is that his statement,
        "I am cooperating splendidly with Goring.  He is going to
        crack down on them too.  The radical line has won", is
        absolutely correct.  That is what happened.  Goring says,
        as I quote, "I would have preferred it if you had beaten
        200 Jews to death and had not destroyed such valuable
        property".  Nice of Hermann to say that.  "Once the
        property was damaged, however", I go on, "Goring ensured
        that the meeting took maximum financial advantage of the
        events for the Nazi state".  I quote a long example for
        this disgusting collection of people.
   Q.   If you were going to quote a long example, would it not
        have been better to quote an example of the outrage that
        Goring expressed at Goebbels for having inflicted this
        economic disaster on Germany at this time in their

.          P-160

        fortunes ----
   A.   You quote them to me.  I refer to it.  I make it quite
        clear that Goring says that he had rather that the
        property had not been destroyed.
   MR JUSTICE GRAY:  If we are really going to spend time on this,
        Mr Irving, I think you ought to put what outrage it was
        that Goring expressed.
   MR IRVING:  My Lord, this witness has claimed -- am I right,
        witness, have you read the whole transcript of this
        meeting, such as it exists?
   A.   Yes, this is the Nuremberg document.
   Q.   Is it right that the transcript is not complete, that it
        is like every ten pages missing?
   A.   You will have to show me that, I am afraid.
   Q.   It is a well-known fact about this transcript, is it not?
   A.   I will not accept your----
   MR JUSTICE GRAY:  Mr Irving, did you hear what I said?  It was
        that, if you are suggesting that Goring expressed outrage,
        it would be -- I do not ask you to go to the document,
        just say what it was you say he said.
   MR IRVING:  Your Lordship will remember that I three
        times asked the witness to answer a question, which is
        what is the reference to public enlightenment?
   A.   Yes.  That is a reference to Goebbels.
   MR JUSTICE GRAY:  Mr Irving, are you paying any attention to
        the question I just asked you?  What was it that Goring

.          P-161

        said that you say was an expression of outrage on his part?
   MR IRVING:  I will be a bit more full in that question then.
   MR JUSTICE GRAY:  It is not full.  It is a question of being
        specific.  If we are going to spend time on this.  I think
        this is a tiny point myself.
   MR IRVING:  It is, except the fact that he says that I have
        commented that this diary entry was written with less than
        total honesty.  It was a diary entry suggesting glowing
        relations between these two Nazi gangsters.
   MR JUSTICE GRAY:  I have got the point, Mr Irving.
   MR IRVING:  It is quite obvious from the transcript, which this
        expert witness has read, that exactly the opposite is true
        that in fact they were at each other's throats throughout
        the meeting.
   MR JUSTICE GRAY:  Which is why I asked you, and this is the
        fourth time I have asked you, to put to the witness in
        general terms what it was that Goring said which you said
        amounts to outrage on his part.
   MR IRVING:  Is it right that Goring expressed outrage at the
        fact that the Reichskristallnacht, for which he held
        Goebbels responsible, had inflicted colossal economic
        damage on the German economy by virtue of the insurance
        damages, the damage to the plate glass windows that had to
        be purchased now with hard currency from Belgium, the
        damage to the German international prestige and so on, and

.          P-162

        he made no secret of his dismay and he sneered at
        Goebbels, what we need here is some public enlightenment,
        which is a reference to Goebbels' full title as
        Reichsminister of propaganda and public enlightenment, is
        that correct?
   A.   It is perfectly correct, Mr Irving.  Let me point out who
        had to pay for all this damage as a result of this
        meeting.  It was the victims themselves who had to pay.
   Q.   That not the point of the question.
   A.   It was the Jews who had to pay.
   Q.   The point of the question is that you said that----
   A.   That is exactly the proposal that was worked out by
        Goebbels and Hitler at the Ostrea restaurant, and whatever
        quibbling and cavilling and nasty remarks, sneers that
        Goring made against Goebbels, that is the outcome of the
        meeting.  That to me is "splendid co-operation".  I cite
        on page 290 a lengthy extract of the kind of disputes that
        they had.  It is quite clear that they were not
        particularly fond of each other.
   Q.   It is true, is it not, that you also suppressed the
        extracts which show anything but cordial relations between
        the two in that meeting?
   A.   Not at all.
   MR JUSTICE GRAY:  You have asked that question very many
        times.  I really think this is such a tiny point.
   MR IRVING:  I have closed my file, my Lord, because we are now

.          P-163

        going to move on to the chain of evidence, which is a
        useful way of spending the remaining hour of this
        afternoon, I think.
   MR JUSTICE GRAY:  What are we going to move on to?

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