Archive/File: people/i/irving.david/libel.suit/transcripts/day032.15
Last-Modified: 2000/07/25

                  During his slide-show, Professor van Pelt told
        us that one cardinal piece of evidence in this drawings
        was the relocation of an internal double-door which sealed
        off Leichenkeller No. 1 from the interior of the building,

.          P-175
        from the inside of the Leichenkeller doorframe to the
        outside.  The door was moved in the drawings from the
        inside of the wall to the outside.  I pointed out that in
        the new layout, the doors were shown as being actually
        rebated into the doorframe and I suggested to the witness
        that this was indicative of a gas-tight door being fitted
        as in any standard air raid shelter design.  Air raid
        shelter doors are routinely fitted outside the shelter, to
        open outwards, so as to withstand blast.  Neufert, which
        is the wartime architects' handbook, bears this out.

                  The witness seems not to have considered this
        possibility.  As Mr Rampton again mentioned, the doors
        allegedly found around the Birkenhau and Auschwitz sites
        subsequently are fitted with peep holes.  But I say that
        that is the standard air raid shelter design complete with
        the obligatory peep hole that is fitted to air raid
        shelter doors.  The amendment of the drawings to provide
        for an external door, leading from the far end of the
        subterrranean morgue to the open air, Leichenkeller No. 1,
        was also consonant with its dual use as an air raid
        shelter, and I put this to the witness on Day 11, as was
        the relocation of the main entrance staircase from the
        back of the building to the street-side.  Among the
        architectural drawings provided to us from the Auschwitz
        archives is one entitled "Modification of the old
        Crematorium", namely crematorium No. 1 in Auschwitz,

.          P-176

        subtitled:  "Air Raid Bunker for SS Station HQ with an
        Operating Theatre".  So such modifications of the morgues
        to provide air raid shelter capacity were clearly nothing
        extraordinary.  Mr Rampton made a lot of the order for the
        doors with peep holes both during the hearings and this
        morning, but peep holes were standard fittings, not only
        on the gas-tight air raid shelter doors, but also on the
        delousing facilities.  Jean-Claude Pressac prints
        photographs of two such doors on the "Canada" delousing
        chamber at Birkenhau.

                  Looking specifically at the possible use of
        crematorium No. II and the underground basement area as
        being adapted for future air raid shelter use:
        Crematorium No. II, like its mirror image Crematorium
        No. III on the other side of the road, was originally
        designed as a state-of-the-art crematorium, possibly not
        just for the camp but for the whole catchment area of
        Auschwitz which had for centuries been an area of
        pestilence and plague.  No expense was spared in its
        design.  This was German tax-payer money and they did not
        care.  The best equipment and architects were used on what
        was clearly a permanent facility.  Building the morgue,
        the mortuary, underground, instead of above ground,
        increased construction costs by several times, but
        provided for keeping the morgue cool during the baking hot
        Central European summers.  Had the building been designed

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        from the start as a human slaughterhouse, it would
        certainly not have been designed on several levels with
        resultant handling problems.  Slaughterhouses are normally
        built on one level.

                  We saw in Professor van Pelt's slide- show the
        pouring of the concrete roof, the roof slab, of the
        subterranean Leichenkeller No. II; the roof was
        undoubtedly much the same as Leichenkeller No. 1 with a
        six inch reinforced steel mesh.  This undoubtedly made the
        new building one of the most robust on the site:
        certainly more robust and fireproof in an air raid than
        the flimsy wooden horse-barracks in which the prisoners
        and slave labour were housed.

                  We were told by Mr Rampton this morning this
        seemed improbable to establish an air raid shelter
        facility for the SS who were 1.5 miles away.  Well, the
        early warning posts were in Holland, and they were
        probably 1,500 miles away.  So they would provide more
        than adequate time for the SS to gallop that 1.5 miles to
        this building with the concrete roof.

                  The captured Bauleitung records of Auschwitz
        housed in Moscow confirm that from mid 1942 onwards they
        began to consider the construction at the camp of
        shelters, splinter trenches, and other ARP, Air Raid
        Precaution, measures.  To be fair to the witness, when
        these Moscow catalogue entries were put to Professor van

.          P-178

        Pelt he seemed unfamiliar with them.  After the air raids,
        our British air raids, on Cologne, Rostock and Lubeck -
        that was in March/April 1942 - the German High Command
        recognized the likelihood that air raids would spread
        across Poland and Central Europe, and they ordered the
        construction of extended ARP facilities throughout the
        occupied Eastern territories insofar as they can within
        bomber range.  Existing basements, this document said,
        were to be converted into shelters, and anti-gas equipment
        provided, and personnel trained in anti-gas warfare, as
        gas attack was widely expected.  I have given your
        Lordship the reference.  I put the document to Professor
        Longerich and on Day 10 I said to him: "[...] the Defence
        rely on a number of photographs of doors found scattered
        around the compound of Auschwitz and Birkenhau, and we
        will show that these are standard German air raid shelter
        doors complete with peep holes".  And, my Lord, I
        have provided photographs of such air raid shelter doors
        in various bundles.

                  These precautions were not in vain.  In May
        1943, there was an air raid on the nearby Auschwitz Buna
        plant.  This is reflected in the Auschwitz documents.  At
        least one of the American aerial photographs that I
        produced to the Court, the black and white photographs,
        the big ones, and to the witness, Professor van Pelt,
        shows a stick of heavy bombs just released by the plane

.          P-179

        that took the photograph descending over the camp.  By the
        end of the war, there was also an anti-aircraft unit
        assigned to defending the region, as shown by the
        reference in Judge Staglich's membership of the Flak unit
        that manned it.

                  Your Lordship will also remember that during his
        slide-show, van Pelt showed the court a series of most
        interesting computer-generated "walk-through"
        reconstructions of the interiors of Crematorium IV and V.
        Your Lordship had actually memorized the dimensions of the
        shutter, the wooden shutter, of 30 centimetres by 40
        centimetres.  There were also said to be steps leading up
        to the openings.  The wartime civil defence journal
        Luftschutz shows precisely this arrangement of gas type
        shutters and steps as a standard air raid shelter feature
        designed for the event of gas warfare.

                  I put this fact to the witness van Pelt: "Would
        you agree that those shutters that have been found in the
        Auschwitz camp are, in fact, standard German air-raid
        shutters supplied by manufacturers to a standard design?"

                  The eyewitnesses stated that thousands of
        victims were gassed in these rooms, however, and their
        bodies burned in large pits to the building's rear.  But
        the contemporary air photographs taken by the Americans
        show no such pits, nor are they evident today.  Confronted
        with what your Lordship has yourself referred to as the

.          P-180



        lack of documentary evidence for the gassings, Professor
        van Pelt could only offer the suggestion that the use of
        gas chambers at Auschwitz and Birkenhau was a "moral
        certainty".  Three times in his report, three times in his
        report, he fell back upon that semi-religious phrase.  The
        available proofs certainly do not support the belief that
        gassings there occurred on a mass scale.

                  If I can just fill in what I have not said
        there?  Of course, I do accept that there were gassings on
        a small scale at Auschwitz in the buildings identified as
        bunkers I and II which were houses which have since been
        torn down.

                  I will not dwell long on the uniformly poor
        evidentiary basis on the other extermination camps, known
        to the Court as the Operation Reinhard camps - Belzec,
        Sobibor and Treblinka.  Here we do not have even the
        "moral certainty" which comforted Professor van Pelt.
        I can only challenge here the scale and the systematic
        nature of the alleged gassing of more than one million
        people in these centres.  The Defendants' own witness,
        Professor Browning, admits that the documentation for
        these camps is "scant", that is his word, and I place
        great weight on that admission.  Here, the expert cannot
        find even one contemporaneous document.  He relies upon
        the eyewitnesses - men of the ilk of Kurt Gerstein, Jan
        Karski, Adolf Eichmann and Rudolf Hoss.  The fictional

.          P-181

        elements in their statements - your Lordship will remember
        the "130 foot high mountain of clothes" which Professor
        Browning in his first draft skipped over, the
        "electrocution chambers" and the "steam chambers", the
        deliberately inflated death rolls which would otherwise
        shriek their warnings to critical researchers - are either
        ignored or suppressed in order to maintain appearances.

                  My Lord, there is an impressive (and we are both
        agreed on this, all parties) level of documentation which
        demonstrates that the liquidation by shooting of hundreds
        of thousands of Jews, probably over a million, by the
        Einsatzgruppen, but there is nothing of equivalent value
        for the Operation Reinhard camps.  One word, Why?
        justifies the revisionist's scepticism.

                  The Walter Fohl letter produces a similar
        response from the experts.  Found in his Berlin Document
        Centre personnel file, this man, who is in charge of a
        resettlement office at Krakow, is seen writing on June
        21st 1942 to his SS comrades as follows:

                  "Every day, trains are arriving with over 1,000
        Jews each from throughout Europe", in Krakow, passing
        through.  "We provide first aid here, give them more or
        less provisional accommodation, and usually deport them
        further towards the White Sea or to the White Ruthenian
        marshlands, where they all - if they survive (and the Jews
        from Kurfurstendamm or Vienna or Pressburg certainly

.          P-182

        won't) - will be gathered by the end of the war, but not
        without first having built a few roads.  (But we're not
        supposed to talk about it)."  An extraordinary document.

                  The expert witnesses, unable otherwise to
        explain this document, dismissed it as obvious
        "camouflage" talk.  But why should Fohl use camouflage
        when writing to his SS comrades?  As I pointed out to
        Dr Longerich, Reinhard Heydrich himself had spoken of the
        White Sea option a few days later, on February 4th 1942 in Prague.

                  It was noticeable elsewhere that none of the
        experts was willing to give documents their natural
        meanings when they did not accord with their views.  It is
        a clear case of manipulation, in my view.  The Ahnert
        document, recording a meeting at the RSHA in Berlin, under
        Eichmann, on August 28th, 1942, was another example.
        There was talk of the need for the deportees, August 1942,
        to be provided with blankets, shoes, eating utensils
        before dispatch to Auschwitz.  Eichmann requested the
        purchases of barracks for a Jewish deportee camp to be
        erected in Russia, with three to five such barracks being
        loaded aboard every transport train.  In each case,
        because the document did not accord with their
        "exterminationist" views, the expert had failed to pursue
        it.  Dr Longerich, who included it as an appendix in one
        of his books, had forgotten it even existed when

.          P-183

        I cross-examined him about it.

                  Coming now towards the end of my submission, my
        Lord, the allegations of racism and anti-Semitism.  I have
        to address the allegations of racism, although I have the
        feeling that your Lordship is not over-impressed by them.

   MR JUSTICE GRAY:  Do not get feelings one way or the other
        about any part of the case, Mr Irving.  It is a trap.

   MR IRVING:  It was a good try.

   MR JUSTICE GRAY:  On the other hand, it is a matter for you
        because I am letting you say pretty much what you want to
        say, I know because I have them now provided very
        conveniently, exactly what it is that is relied on by way
        of anti-Semitic statements, racist statements and so on.

   MR IRVING:  I shall definitely make some response therefore.

   MR JUSTICE GRAY:  Yes.  I mean you can deal with them
        generally, if you like, rather than going through them, as
        it were, one by way.  I appreciate you do not go through them all.

   MR IRVING:  I have not gone through them one by one, my Lord.
        In fact I have not even read them.

   MR JUSTICE GRAY:  I offer you the opportunity of making general
        answers to those submissions rather than by reading it all
        out.  It is entirely up to you.

   MR IRVING:  I do not read them all out, but I shall certainly
        deal with my arguments.  The Defendants have resorted to
        the allegations that I am anti-Semitic and racist.  It may

.          P-184

        be that they are going to pay dearly for those remarks.
        Mr Rampton's highly paid experts have found one 1963 entry
        in my diary, four lines written 37 years ago, about a
        visit to my lawyer Mr Michael Rubenstein to discuss a
        satirical magazine article which I had written, after
        which visit I commented: "Thick skinned these Jews are".
        This is all that they could find from the millions of
        words in my diaries available to them by way of
        anti-Semitism.  Twenty million words of diaries and they
        found "Thick skinned these Jews are".  When I remarked on
        March 2nd in court, my Lord, upon the obvious paradox that
        an alleged anti-Semite would have retained Michael
        Rubenstein as his solicitor and respected advisor for 20
        years, Mr Rampton's comment, which your Lordship may well
        remember, was:  "Many of my best friends are Jews too,
        Mr Irving".  This stock line does not disguise the paucity
        of his evidence against me.

                  In further support of this contention they have
        taken isolated remarks made in lectures and speeches for
        which they have transcribed around half a million words.
        My Lord, I trust that your Lordship will in each case
        consider the context in which the remarks are made.

   MR JUSTICE GRAY:  Of course.

   MR IRVING:  And also the broader surrounding countryside, if
        I may put it like that.  What I would ask your Lordship to
        do is to take the ugliest example, whichever your Lordship

.          P-185

        deems that to be, reach up for the full transcript of
        whatever that speech was, and ask yourself why I have put
        that remark in and see what else is in that speech.  Then
        I submit that the alleged anti-Semitic remark fails into
        insignificance, if it is even taken to be anti-Semitic at
        all.

                  For 30 years, as I set out earlier in this room
        this afternoon, I have found myself subjected to vicious
        attack by bodies, acting, as they freely admit, as Jews.
        For 30 years I endeavoured to turn the other cheek and did
        nothing about it.  I hope I succeeded.  Mr Rampton drew
        attention to the fun I poked at Simon Wiesenthal.  I made
        a joke in a public meeting about his, an explicit joke
        I made about his other than good looks, if I can put it
        like that.  Mr Rampton called that remark "anti- Semitic".
        It was not.  It was a joke about the man's looks, of the
        same genre that Mr Rampton made when he enquired
        rhetorically of Professor Funke whether a certain
        outer-fringe Swedish revisionist seen in one video shown
        to the court with long blonde hair was a man or woman.  It
        is exactly the same kind of throw-away remark.

                  In view of the manner in which the two Simon
        Wiesenthal centres have been abusing my name in their fund
        rasing leaflets, and endeavouring to destroy my own
        livelihood, the court might think that my fun-making,
        while tasteless, remark was not undeserved, possibly it

.          P-186

        was even rather reserved.  It was not anti- Semitic.
        Mr Wiesenthal is no more immune from criticism either as a
        person or as a public figure than I am.

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