Archive/File: people/i/irving.david/libel.suit/transcripts/day007.18 Last-Modified: 2000/07/20 Q. Yes, Mr Irving. We will continue, shall we? I think I was at the words: "But Mr Zundel has used the scientific methods and, taking this as a starting point, I have now begun over the last few months going round the archives, with a completely open mind, looking for the evidence myself because, if Auschwitz, just to take that one cardinal tent pole of the case, itself was not an extermination factory, then what is the evidence that it was?" I do not understand that sentence but I understand the sense of it. "This is one thing I have to look at. How did all the evidence come into existence? It is an interesting case because we all now accept that the media . P-153 knows, everybody knows, it has become a matter of common experience, judicial notice has been taken of the fact that Auschwitz was an extermination camp. So what is the evidence that it was? If you then start going all your way back down the pipeline to find out where this evidence comes from, you come up with one or two or three documents and eyewitness accounts and that is all." Now, that was your account of the state of the evidence regarding the proposition that Auschwitz was a totas fabrik in August 1988, some five months after the end of the Zundel trial. A. Yes. Q. You had not even bothered going to look at the archive in Auschwitz, had you? A. I think I did not say here that I went to the Auschwitz archives. Q. You said you had been round the archives with a completely open mind looking for the evidence. A. Yes. Q. You tell your audience that all you come up with is one or two or three documents and eyewitnesses accounts and that is all. A. Let me explain to you the situation at the time as I understand it, archively speaking. The Soviet archives were not opened until 1990, I believe I am correct in saying. . P-154 Q. I am listening. Please continue. A. I do not like talking to the back of counsel. MR JUSTICE GRAY: It happens all time in court. It has to. It is not rudeness or anything else. It is just the way of the world. A. I promise I will not turn my back on people when they are speaking to me. Q. Just carry on with your answer, please. A. Soviet archives had not been opened at that time. Poland was still behind the iron curtain. The wall had not come done. Am I making my point? MR RAMPTON: No, not in the least bit. A. Which of those sentences did you not understand? Q. I understood the first sentence, which was completely irrelevant because we are in 1988. I am not interested in Moscow. I asked you about the archive at Auschwitz so leave Moscow out of it. A. Our present state of information about Auschwitz, the superior information we now have about Auschwitz, comes primarily from the fact that the Russians, when they arrived in Auschwitz, captured the records of the camp intact, particularly the construction records of the camp, which therefore went to the Moscow archives. Poland, where Auschwitz is situated, was behind the iron curtain. Q. I am getting some information. Continue. Yes? A. Principal archives which were being used by historians at . P-155 this time were in the national archives in Washington, and the German Federal archives, to which I at that time still had access, not having been banned from them by the German government in the interests of German people. Q. Are you familiar with the work which you disparagingly call the French country chemist, Jon-Claude Presac? A. I am not familiar with his work, no. Q. You know who he is, do you not? A. Yes. He wrote this being volume on the desk. Q. He did indeed. Do you know that he went to the archive in Auschwitz in 1982 and 1983? A. Maybe they found favour in him which they did not find in me. Q. You never asked? A. I am not a Holocaust historian, Mr Rampton. At this time in 1988 I was writing, if I remember correctly, the latest edition of the Hermann Goring biography or I was working on the second volume of my Winston Churchill biography, neither of which would have required me to go to Auschwitz. Q. You cannot have it both ways. You cannot have it that Auschwitz did not exist and you cannot have it that there is no evidence in the archive if you have never looked. A. If I say I have been round the archives, I am not saying I have been round all available archives, including those had Poland and elsewhere. I am saying I have been round . P-156 the archives, which at that time is perfectly true. I might even have gone to the Public Records Office to see what they had. Q. You might have been round the archives of the Royal Botanical Gardens in Kew, for all I know. A. I find that a cheap remark. Q. Of course it is cheap, but this is a very cheap---- A. Which you say is a matter of great sensitivity to the Jewish people. Q. This is a very cheap fraud that you have perpetrated on the 50 or so people in this room because what you are telling me is that you have looked everywhere and all anybody can come up with is two or three documents. A. I have not said I have looked everywhere. This is again your manipulation of the sentence, your rather superfluous gloss. To look everywhere you need to spend the kind of money that your team has spent. MR JUSTICE GRAY: Can I put it a different way round? Which were the archives that you had spent a few months going round? A. I do not want to be ambushed by references from my own diary, but I would suspect, from the way I put that sentence, that I went to the German Federal Archives and I went to the national archives in Washington, and possibly to the Hoover library in California where they also have a certain amount of material relating to this. . P-157 Q. So you have done a fair amount of research into the Holocaust, or into Auschwitz? A. Yes, but not specifically for that. I would have gone there for other purposes and I would then have called up roles of microfilm of Heinreich Himmler's papers which are in great abundance in the national archives and I would have looked at some of the Nuremberg documents. But I had not travelled there specifically to research the Holocaust. At this time I was researching probably Winston Churchill Volume 2. MR RAMPTON: So, when you said on page 6 that in relation to Hitler you had been round the archives of the entire world, we have to exclude Auschwitz from that, do we not? A. Can I see the exact reference? Q. Yes, of course you can. You are talking about Hitler and his knowledge of whatever, I do not know, Auschwitz I suppose, five lines up from the bottom? A. Because I worked in the archives of the entire world, including the public archives here in Wellington Street. That shows as Ottawa, by the way. Q. Please do not give us a list. The entire world is the entire world, but apparently does not have Auschwitz in it. A. It did not have anything behind the iron curtain and the people who were in the audience at that time would have realized that. . P-158 Q. Oh, I see. So they would not have been in the least bit deceived? A. Mr Rampton, you have to put yourself back to 1988 before the wall came down. Q. I do not think so, because I am told that the archive at Auschwitz was readily accessible to anybody with the proper credentials, that is to say I am an historian, please may I have a look because I intend to write a serious piece of research about this, before I go public on what it was or was not. A. So we are coming back on to the negligence argument again? MR RAMPTON: No. MR JUSTICE GRAY: The picture I have, and I think we probably need to press on a little bit, is that Auschwitz may or may not have been accessible to somebody like yourself, but you never in fact enquired about getting access to the Auschwitz archive? A. I ought to have but did not. If I was going to write about Auschwitz and the Holocaust then I ought to have but did not. Q. That is a fair summary of factual position? A. Yes, with the rider that I added, my Lord, that if I intended to write about the Holocaust, then I would have done that and ought to have done it. MR RAMPTON: I add to this, and you not only deliberately . P-159 decided not to go to Auschwitz because you were not interested in finding the truth before making these statements ---- A. Deliberately decided not to? Q. Yes, deliberately decided not to. You made a deliberate decision. If you were the slightest bit interested in the truth about Auschwitz, you would have gone there. A. If I was writing a book about Auschwitz and the Holocaust, then I would have gone there. When I became deeply involved in it, thanks to this litigation, and I tried to go to Auschwitz, then I was banned from entry, the only person in the world who has so far been banned, apparently. Q. That was recently, Mr Irving. MR JUSTICE GRAY: There we are. MR RAMPTON: What is more, Mr Irving, what is important about this very early speech in your Holocaust denial career, is that you actually deliberately misled your audience in Toronto or Ottawa or wherever it is into believing that you had done the research and had found that there was no evidence. A. I can only repeat what I previously said, Mr Rampton, that my audience were not stupid and they knew that the iron curtain was still standing at that time, even if you have forgotten it. MR JUSTICE GRAY: Is that the lot from that speech? . P-160 MR RAMPTON: That is all I want from Toronto/Ottawa, whichever it be. A. There is, of course, a great deal more in that speech, my Lord, which your Lordship may well read later on. The reasons why one is sceptical about the report by the two Slovac Jews, for example, and so on. I am not just speaking off the top of my head. It is quite clear, I think, by that time that I went to the Reisaltz Library and had a look at the origins of the war refugee board and its entire file on that report and so on. It is a bit deceptive really just to take these single paragraphs out and hold them up. MR JUSTICE GRAY: We may have to have more discussion about the mechanics of dealing with the contextual points that you want to take. MR RAMPTON: I quite agree about that and, as I think I have already said at some time in this case if not just now, one of the problems with this sort of an exercise is that there is a danger that the most innocent selectivity can lead to distortion. I do not want that to happen. I do not want to skin this cat by a false case, if you see what I mean. MR JUSTICE GRAY: I follow that. This is not a criticism and please do not think it is, but we have taken, I do not know, three quarters of an hour on one relatively unimportant speech, and I do not think we can do that with . P-161 all of them, can we? It really is not a criticism. This is very difficult. MR RAMPTON: I realize that. I would make the complaint, if I had to, that I never get an answer to my question. MR JUSTICE GRAY: I am not being critical either way. MR RAMPTON: I get a speech, and that is one of the reasons why it takes such a long time. MR JUSTICE GRAY: I did suggest prime examples. MR RAMPTON: That is quite a prime example, in our submission. MR JUSTICE GRAY: I think the answer is a selection of prime examples, followed by a marked up list of those that are relied on, and then and then we will work out how best to allow Mr Irving to take the context. MR RAMPTON: My Lord, I think I already read some of the most important parts of the press conference announcing the publication of the Leuchter report. MR JUSTICE GRAY: Can you give me the reference? MR RAMPTON: That is tab 5 of same file. A. If you had listened, with respect, to what I said about weighting the verbal utterances less heavily in the written books and so on, perhaps we would have avoided part of this misery.
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