Archive/File: people/i/irving.david/libel.suit/transcripts/day024.02 Last-Modified: 2000/07/24 Q. A spectacular task. So that gives you a very good overview over the whole of the domestic life of Nazi Germany? A. I think it gave me a good insight into the day to day operation of the bureaucracy in the Nazi State. Q. And into the kind of language they used? A. Yes, of course. Q. And into the hierarchy and the various rivalries and disputes? A. Exactly. Q. Was friction between the top Nazis a major element of the Third Reich? A. Absolutely. Q. [German] -- in other words ---- A. Yes. Q. --- jealousies between the different ministries and agencies? A. In-fighting and these things, yes. Q. Would you, from your knowledge of other governments, think it was more or less than other governments around that . P-10 time, British government or the American government, or was it something extraordinary, the degree of ---- A. I made point in the book I wrote on the Party Chancellery that I think this exceeded the normal of in-fighting you find in all governments. It is a special case here. Q. Yes. When you worked in the Institute of History, who was the director at that time? Was it still Martin Broszat? A. At this time it was Martin Broszat until his death in 1989. Q. He had a very great reputation, did he not, and he is still greatly admired by German historians? A. Yes, I think so. Q. Were you familiar with all the collections of documents in the Institute files? Did you work in the archives at all? A. Not all the files. I mean, the Institute has an enormous collection of files, but I know some of them. Q. Yes. Was Dr Hoff still there, Anton Hoff, the archivist? A. No, I think he died in 1883. Q. 1983? A. 1983, sorry. Q. Just before you came? A. Yes. Q. It is a very friendly atmosphere there at the archives, at the institute? A. I think they were friendly to me. I do not know ---- Q. They are very co-operative, are they not? They do not . P-11 hold things back very much apart from own private collections? A. I cannot make such a general statement. Q. In fact, you probably had quite a lowly position there, did you not? You were a newcomer and you were working in the Institute? A. I have no difficulties in actually getting access to the collection but I cannot make a general statement on that. Q. Did you ever take the opportunity to look at what is now ED 100, the collection of my documents which is in the Institute? A. I think I have seen some of the ED 100 files, but I cannot say that I have a complete overview. Q. Yes. A. I have seen some of them yes, but at the moment I cannot recall every document I have seen in the Institute. Q. I am just going to give you a list of names of collections of diaries. I am sorry, you have a copy of this already. I ought to give a copy to his Lordship, perhaps. (Same handed) just on the back of that there is a blue column called Hitler's People. Do you have that if you turn it over? There is a list of names of diaries that I used when I wrote my book Hitler's War, which are now in the archives. I have added to those since then but I just pick out a few names. Canaris: Would that be a valuable source? . P-12 A. At the moment I cannot recall the Canaris diaries. I am not able to comment on every item, but I think some of them are of course important. Q. Some are more important and some are less important? A. Yes. Q. Dr Longerich, I am not trying to trick you. I am just at this stage trying establish -- I will give a little warning if I am going to try and trick you. MR JUSTICE GRAY: Mr Irving, do I get anything more from than that -- is this the new edition that is coming out shortly. MR IRVING: No, this is the second edition, my Lord, but I just wanted to comment on the fact I wondered whether he had taken the trouble to look at these very important collections of diaries that are in my collection, either for his own work or in the expert report. MR JUSTICE GRAY: Can you put it as a single question rather than the whole lot? MR IRVING: Yes. Did you use the diary of Walter Havel? A. I looked at the transcripts. I think it is in England, is it not, the original? I looked at the transcripts at one stage but not for the Party Chancellery. I think I looked at the Bormann, it is more a calendar. Q. The calendar? A. Yes. Q. Which I have now provided to the Defendants. The Walter . P-13 Havel diary does contain one of these episodes July 1941, does it not, where Hitler describes the Jews as a bacillus? A. I cannot recall this particular passage, I am afraid. Q. When you drew up this glossary of meanings of words, which, I must say, I find very useful indeed, and this goes purely to the conduct of the case, when did you start writing that approximately? A. I think it was in December last year. Q. In December last year? A. Yes, I tried to use the Christmas holiday to do it. Q. When did you complete it? A. I think it was actually in January think. Q. You completed it in January? A. Yes, January I think. Q. Yes. When were you asked to do it by the instructing solicitors in this case? A. I think they wrote me an e-mail. I think it was in November, but I could not start immediately to work on it because I had other obligations. So I am sure I started to work on it at the end of the Christmas holidays. Q. You got a letter of instruction? A. I think, as far as I recall this, I got an e-mail. Q. Yes. So you got an e-mail sometime in November, you began writing in December and you completed it in January? A. Yes, that is right. . P-14 Q. Any idea when in January you completed it? A. I think it was more through the end of January, probably on the first days of February, I cannot recall. MR RAMPTON: I can help, I think, because now it comes out of Dr Longerich's hands, as it were. It came in its first version in German, which, since I was the person who requested it, I think in November is right, maybe even October, and was useless to me. So it had to be translated. It came back and the translation was, to say the least, unsatisfactory. Then it had it go back again, and what we now have emerged in the course of the last few days. MR IRVING: Yes. MR JUSTICE GRAY: Mr Irving I am not unsympathetic to the fact that you are having to deal with this at pretty short notice because it came to you very, very late in the day. MR IRVING: Of course I accept Mr Rampton's explanation but it was delivered to me on Friday evening and, if it turns out he completed it in January, I would have wanted to know what the reason for the delay was. MR JUSTICE GRAY: If you want to say you want Dr Longerich to come back at some later stage because you want to ask some further questions, you would be pushing at an open door. MR IRVING: I fully accept Mr Rampton's explanation about translation difficulties. During your professional career, Dr Longerich, . P-15 as you say in your curriculum vitae on page 3 of your report, you have received research grants from the German Historical Institute in London, and from the Deutsche Forschungsgemeinschaft and also from Yad Vashem? A. Yes, that is true. Q. Are you still in debt to Yad Vashem in any way? A. I started to work on the project. The project has not yet been completed. The relationship, there is no contract between us and in this sense, it is not a book contract or something like that, but I still have to complete this project we started a couple of years ago. Q. I do not want to know any figures or quantum. Does this mean to say they paid you in advance for something and you are still working on it? A. No. They paid me for ten months actually. It enabled me to live in Israel for ten months. Q. As you say in this ---- MR JUSTICE GRAY: What will you be doing for them? What will you be researching? A. We started to work on a project, a documentation about the deportation of the Jews from Germany to Minsk and Riga and I had a partner there. We started to collect the documents, but unfortunately the work has not been completed yet. It is actually a major project and has not been completed yet. MR IRVING: The Eastern European archives have turned out to be . P-16 particularly fruitful, is that right? A. Absolutely, yes. Q. Is it to be regarded as a great tragedy they have only recently in the last ten or 15 years become available to historians? Is that right? A. I cannot comment whether it is a tragedy. It is a fact that it has become available in the last years. Q. They were not available at the time I wrote my first edition of the Hitler biography in the 1960s? A. With some exceptions. It was always possible to get some of the documents out of the archives. For instance, there is a large collection of documents in the German Central Agency for the Prosecution of Nazi Crimes. They actually managed to get a large collection from this material in the 1960s. There is also a large collection in the Bundesarchives archive and individual researchers had the chance to see not the whole archives but some of the documents. Q. If I can just dwell briefly on the files in the Zentralestelle, which is presumably the ZST source? A. Absolutely, yes. Q. You did not identify that in your report, did you? A. I think there is a list of abbreviations and it should be there. Q. The documents provided by the Eastern European archives to the German Zentralestelle, which is a prosecuting archive . P-17 -- could I put it like that? A. It is the house archive of this agency. They have their own library and their own archival collection. Q. At Ludwigsburg? A. Yes. Q. Is it specifically collected for the purpose of carrying out prosecutions of German and other citizens for war crimes? A. That is the main purpose of the whole institution and of course mainly some historical background. Q. They have very valuable collections of documents there, do they not? A. They have a very good collection, yes. Q. That is where Dr Goldhart worked, for example? MR JUSTICE GRAY: Mr Irving, do you think we should move on from the archives? MR IRVING: I just want to ask one question which makes the point clear, my Lord. Is it apparent to you that, if an archive has been collected for the purposes of prosecution, it is less likely to include defence material, if I can put it like that? A. Well, you can use this material in different ways. I do not say that they had a complete set of documents from the Russian archives. It is certainly a selection. I did not select it. I do not know who selected it and who made the decision about this, so I should be very careful to make a . P-18 comment on that. Q. You would always bear in mind using such archives that you are only seeing one side of the picture and not necessarily the other side? A. I think it is difficult to say because they were interested. They did a lot of work in this Zentralestelle during the 1950s and 60s, and they actually had historical expertise there because they actually worked on the historical background. I would not say that they were only interested in this aspect of prosecution. I think they had to collect the historical expertise which was not available at this time and could not be provided by historians. So I would be cautious to make such a statement about this collection. Q. I see on page 5 of your report that you are an expert, or you have written about the Wannsee conference? A. Yes, I gave the annual lecture in 1998 at the Haus of the Wannsee conference and this published as a booklet.
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