Archive/File: people/i/irving.david/libel.suit/transcripts/day010.22 Last-Modified: 2000/07/20 MR IRVING: It is a useful exercise. It is bottleneck in the operation which does give us a chance of arriving at some kind of concrete results. A. I would of course be quite pleased if somebody who knows, . P-188 if we got some more specific data about, you know, how long it would take for this elevator to come up, because obviously if we are 50 per cent wrong, then we suddenly have the bottleneck and there cease to be a bottleneck or not. Q. Just as in the calculation you made earlier on the Zyklon use? A. I took a very generous, very generous I think amounts for delousing. Q. We have those figures and I will supply them to you within the next 24 hours, the actual carrying capacity of the lifts, the various models, the size and so on and the actual speed in minutes and seconds that it would take to lift that distance. MR JUSTICE GRAY: We are comimg back to that on Friday. So let us leave that and get on. MR IRVING: My Lord, I just want to conclude by putting a number of general questions to the witness, if I may, which is, you will be glad to hear, off these very, very minute questions in the broadest possible terms now. You had a colleague working with on your book, did you not, Deborah Dwork? A. Yes. Q. She is now a very famous Professor, is she not, at the Clark University? She has a Chair of Holocaust studies? A. Holocaust history. . P-189 Q. Holocaust history. Without wanting to sound tasteless about it, it has become quite an industry, a very well funded industry, has it not, this Holocaust education business? She writes in her own papers that she has received $5 million a year for funding her Chair and very enterprises? A. She has been able to set up this Institute by this money donated by various donors, yes. Q. I am only asking these questions because you re one of the world's leading Holocaust scholars and you are probably in the best position to educate the court about these matters. It has become big business and it is not just I who say this; a number of other far more learned people than I myself have said this. The Chief Rabbi of England said it once. A. Mr Irving, I think that I am here as an expert on Auschwitz. If you want to have testimony as a member of the general public, and I am not one of the chief Holocaust historians, I am actually a cultural historian who was worked on Auschwitz, as a member of the general public I can answer. I do not know if the Judge will be very interested in my opinion. MR JUSTICE GRAY: I am interpreting this question as suggesting that your co-author was, effectively, delivering the goods on the Holocaust, that is to say exaggerating it, because she was being paid so well to do so. . P-190 MR IRVING: This is a very tactful way of putting it, my Lord. MR JUSTICE GRAY: It was not intended to be particularly tactful. MR IRVING: This was the inference I am trying to draw. I am trying to find the justification for the word that is frequently used about my own endeavours as being "dangerous". To what or whom am I being a danger? The only interpretation I can put on it is the fact that I am endangering people like Deborah Dwork who have made it quite a lucrative business, if one can regard being in education as being a business. Certainly she makes $5 million a year for her Holocaust centre out of the Holocaust and the history of the Holocaust and teaching the Holocaust. There are all sorts of profitable side lines in publication of books and so on. This is what makes me into a danger, apparently, that if it turns out that this building here has no holes in the roof, then a large number of eyewitnesses have lied, and the whole mass extermination chamber part of the story collapses as securely as that roof has done. MR JUSTICE GRAY: Does Professor Dwork manipulate the evidence because she is making so much money out of her Chair? A. I will take your guidance on what I should answer and what not. Q. Answer it shortly. A. May I point out, first of all, that this is money she . P-191 raises for the Institute. MR IRVING: It is not for herself personally of course. I made that quite plain. A. Yes. This is money which is raised to create Chairs. To provide students with scholarships, to build up a library. So in that sense I do not think that Professor Dwork at all profits from this. I also would like to point out that when Professor Dwork wrote this book with me, Professor Dwork was not a Professor of Holocaust history at Clark University. That in fact the sum total of support we got for this project to write the book on Auschwitz was 40,000 Canadian dollars which translates at the moment to œ15,000 which I got from the Canadian Government, and that is all the support that went into writing that book. MR IRVING: The obvious question then is would she have been given a Chair in anything if she had not written the book, let us put it that way round? A. My Lord, I do not see it is relevant. If you think it is relevant I will answer the question. MR JUSTICE GRAY: It has a sort of a relevance but not in terms of your evidence. MR IRVING: Yes. I will abandon that line of argument, my Lord. I just wanted to establish the fact somehow that I am considered to be danger to something, and the word danger is what puzzles me. I am not a member of the IRA. . P-192 I do not go round blowing up cars. So what am I danger to? I tried to put some flesh on to that particular matter. MR JUSTICE GRAY: Right. Next general question. MR IRVING: Next general question, have you had the opportunity to work in the Moscow archives? I do not know the answer to that. A. I have worked on the basis of the microfilms which were made at the same time that I had to work on this. Q. Yes. Have you worked in the national archives in Washington? A. I have been once there, but not really. I have not really worked in the national archives. Q. That really surprises me. You aware, of course, that the national archives in Washington have I suppose the largest collection of captured German records including in relation to the SS and Auschwitz? A. Yes, I am aware of that, and also I am aware that many of them have been made available. I am aware of the fact that one uses the archives which are useful for one's work. It happens to be that the archives, you know, when one works as an historian there are various particular things one researches for which one needs to go to the archives, because the documents are not available and one wants to see those particular archives. You want to see the documents in situ. In this case these are the . P-193 Auschwitz construction documents. Very important in my book, or in our book since the name of Deborah Dwork has been mentioned now, was the archive in Koblenz and to a lesser extent -- this is the German Federal archive in Koblenz and to a lesser extent, for example, the Berlin Document Centre and the archives of the court in Vienna. These were the archives where the unpublished documents were all stored. For other things, more general information, I rely sometimes on documents as they are produced in facsimile and sometimes even on documents as they are ---- Q. Can I halt this avalanche just there? We are still at the national archives in Washington. In May 1997 I believe I wrote you quite a lengthy letter? A. You wrote it. I never received it. Yes. Q. You never received this letter I wrote to you? MR JUSTICE GRAY: What did it say? MR IRVING: It is a six-page peon of praise of his book, my Lord, drawing his attention to certain documents and archives and inviting his comment on matters of history, in the way that an historian should. I wrote to him - - your address is and always has been at all relevant times presumably the Head of the Department of History? A. No, I am not. Q. But you have been at the University Waterloo, have you not? . P-194 A. Yes, but I am in the architectural school. I am not in the Department of History. Q. If a letter is addressed to you at the University of Waterloo and properly stamped and posted, then there is every likelihood that it will reach you, is there not? A. I can only tell, and I am still under oath, that I never received this letter. MR JUSTICE GRAY: This is one question I am not going to decide. A. I only learned of it a year ago when people pointed it out to me on the web. MR IRVING: Are you aware that that letter has been posted on my web site for the last two years? A. It happens that I am not very experienced with the web. Only somebody told me last year when I was already started to get involved in this case that it was posted on the web, and of course since I was already engaged on actually starting to work on this there was no way I could respond to it. Q. Are you going to make complaints at the University of Waterloo that letters properly addressed to you, properly addressed to your department, are not ---- MR JUSTICE GRAY: I think we have all got other things to worry about than this wretched letter, if I may say so. MR IRVING: Very well. Is it not a pity that the letter did not reach you in view of the fact that it contained . P-195 pointers to historical records that would have been of the utmost most information and assistance to you? A. The book was published in 1996. So your letter is a year late after that. I do not know which particular documents you point to. If you want to provide me with a copy of the letter I will comment on these points. Q. There is a copy of the letter in the bundle which I gave his Lordship yesterday. If I can summarize without looking for it, it drew your attention, for example, to the interrogations of Rudolf Hirst which up to that point you had made no attempt to read in the national archives in Washington. You had written the book about Auschwitz but you made no attempt to read the verbatim interrogations of the commandant of Auschwitz? A. May I point to your Lordship that these transcripts of the interrogations Rudolf Hirst were actually published in facsimile I think in 1970 and I did read those facsimile reproductions. Q. And yet there is not a trace of them in your published volume? A. But it seems to be that as one would want to use Rudolf Hirst as a source, and I did not use every single word Rudolf Hirst said. There are much better sources than the interrogations. For example, his later memoirs and his essay on the Final Solution which he wrote in Poland are, in fact, places where he himself tries to put he whole . P-196 thing together. Certainly the Auschwitz book was not a history of what happened to the formation of knowledge about Auschwitz after the war. I do not deal with hat in the book. I did deal with it in this book, as you know. So I do not think that you can draw any conclusion of what is included in the book of what I consulted or not consulted. Q. Well, you gave very detailed footnotes indeed, did you not? You are writing a book about Auschwitz and yet you make no reference at all to having had in front of you, as you say, the entire transcripts of the integration of the Commandant? A. Mr Irving, I just want to ask you, if at a certain moment -- I have looked in making this book at 10,000 documents and ultimately I used 1,000 of them in the book. You are not going to write 9,000 footnotes of actually mentioning the documents which you have not used. Q. I can sympathise with you because I am frequently in the same position, but sometimes there are collections of documents that are so important that I have to say you ought to have used them? A. Then I am very happy I am not your graduate student. MR JUSTICE GRAY: Let me try to break into this. My recollection is, I am probably wrong about, is that when you deal with Rudolf Hirst in your report you deal with the interrogations as well as what he says?
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