Archive/File: people/i/irving.david/libel.suit/transcripts/day013.14
Last-Modified: 2000/07/20

   Q.   --- I have asked Miss Rogers to try to find the page in
        tab 1 of the file?
   A.   What tab are we now on?  I am now lost.
   Q.   I am sorry.  I am at page 8 of the table at the moment.
        I am just searching for the reference in the Corgi
        edition.  Thank you very much.  My Lord, it is page 9 of
        tab 1.
   MR JUSTICE GRAY:  When you say tab 1, do you mean tab 3?
   MR RAMPTON:  Yes, I am sorry.  I will find it in my own copy.
   A.   Perhaps you can help me -- what are we actually looking at now?
   MR JUSTICE GRAY:  I thought we were looking for the Red Cross--
        here we are, yes.  In the middle.
   MR RAMPTON:  I have found it.
   A.   In the middle of what?
   MR JUSTICE GRAY:  Sorry, tab L1, tab 3, page 9.
   MR RAMPTON:  Page 9, and this is page 225 of your 1966 Corgi
        edition, and in the middle of the paragraph which
        begins "shortly after", you write this:  "On 22nd February

.          P-121

        1945, nine days after the attacks during the tour of
        allied prisoner-of-war camps in the Dresden area,
        Mr Walter Kleiner, the Swiss leader of an International
        Red Cross delegation, was in the presence of witnesses
        informed by the Dresden City Commandant, General Karl
        Mehnert, that the current death roll was 140,000." Where
        can that come from, Mr Irving?  It did not come from
        Mr Kleiner, did it?
   A.   No, Mr Kleiner was dead at the time.
   Q.   And it did not come from the Red Cross either, did it?
   A.   Not at that time, but, I mean, without going back to my
        files and looking for this, I certainly would not have
        invented that passage.  There are two possible sources.
        Either the Red Cross published a report which the person
        who made the response to me was not familiar with and
        I relied on that.  That is one possibility.  Or possibly
        one of the prisoners in the prison camp who kept diaries
        (and I had some of their diaries) was a witness of it.
   Q.   Well, I am sure you will produce them if you still have
        them.
   A.   Right.
   Q.   But you cannot tell ----
   A.   OK, no, I can see what this is.
   Q.   Well, tell us then.
   A.   This is derived entirely from the Funfack letter, quite
        clearly.

.          P-122

   Q.   Did Funfack say anything about what Mehnert had told
        Kleiner?  Funfack reported to you what Mehnert, his chum,
        had said to him, did he not?
   A.   Let us go back and see the letter then.
   Q.   Or have I misunderstood that?
   MR JUSTICE GRAY:  Can you just go a little slower -- where is
        the Red Cross letter?
   MR RAMPTON:  I am sorry.  The first one did not reproduce, but
        the second one we do have, and I will give your Lordship.
   MR JUSTICE GRAY:  I could not find -- I was scrolling back and
        I cannot find the reference.
   MR RAMPTON:  It is page 43 of tab 1.  That one did reproduce.
   MR JUSTICE GRAY:  Tab 2?
   MR RAMPTON:  2.  Tab 1 is Hungary.  I am so sorry.  Tab 2.  It
        is dated 17th February 1965 and the first paragraph says:
         "There were no POW camps in Dresden itself.
        Consequently, Mr Kleiner's reports did not even allude to
        the air raids on the town.  Moreover, the ... (reading to
        the words) ... is only to hand its delegates reports to
        the detaining power of the prisoners power of origin",
        whatever that means.
   MR JUSTICE GRAY:  Right, so it did not come from there.
   MR RAMPTON:  It did not come from them.
   MR JUSTICE GRAY:  So the question is where it did come from.
   MR RAMPTON:  Well, Mr Irving says Funfack.  If one looks back
        at page 42 ----

.          P-123

   A.   Well, I suggest Funfack.  Can I interrupt my own train of
        thought at that point and say the two following things?
        We have in this file approximately 100 pages of paper, do
        we not, which is a selection of, I suppose I had four
        microfilms of paper, 8,000 pages of paper were before you
        when you did your discovery, inspection of my discovery.
        So you selected 100 pages from 8,000 pages of paper,
        right?  There is a clue to what the source is if you go
        back to page 42A under tab 2.  If you read the second paragraph?
   MR RAMPTON:  I have not got that.
   A.   It is the letter which I wrote to the International Red
        Cross on January 27th, 1965:  "On about 22nd February, a
        representative of the International Red Cross visited
        Dresden to ascertain, among other things, the fate of the
        prisoners-of-war in the City.  The American Government
        kindly quoted to me details from the report your officer
        wrote."  Now, that report, of course, is not in the
        discovery as is before the court.
   Q.   Carry on en.
   A.   Has your Lordship the passage?  "I have just today learned
        from a leading Medical Officer in Dresden at the time that
        during visit of your officer, which he recalls as having
        been from 22nd to 26th February, all the casualty figures
        for Dresden were made available to your Officer, the Red
        Cross Officer".

.          P-124

   Q.   Is that a reference to Dr Funfack?
   A.   That is to Dr Funfack, yes.
   Q.   Where is the communication from Dr Funfack which he says
        that he got the figures from the Red Cross or the Red
        Cross gave figures to Kleiner -- I am sorry.
   A.   The figures -- Funfack told me, is this correct?
   Q.   Funfack told you that Mehnert had told him.  That is stage I?
   A.   That Mehnert and Fetscher had told him these two figures?
   Q.   Yes.
   A.   Right, so those would be the figures that would have been
        given on that date to the International Red Cross visitor,
        Mr Kleiner.
   Q.   But I want to know who told you that during the visit of
        Kleiner all the casualty figures for Dresden were made
        available to Kleiner.
   A.   The American Government report.
   Q.   No.  "I have today from a leading Medical Officer in
        Dresden at the time that during a visit of your Officer
        all the casualty figures for Dresden were made available
        to your Officer".
   MR JUSTICE GRAY:  That must be information from Funfack?
   A.   That is correct, but I am referring to this letter dated
        January 27th which states originally, "The American
        Government has kindly quoted me details from the report
        your Officer wrote and you have not produced that".

.          P-125

   Q.   But that is nothing to do with it.  That is before the
        semicolon.  I do appreciate your difficulty, Mr Irving,
        because you are being asked to produce the source for
        something out of a ----
   A.   35 years ago.
   Q.   --- very, very large quantity of documents.
   A.   With respect, I see little difficulty.  This is quite
        clearly sufficient material to identify the circles from
        which the information came which I wrote that paragraph
        on, namely there is an American Government report citing a
        report by the International Red Cross Officer, Mr Kleiner;
        that Mr Kleiner has visited Dresden and toured camps in
        and around the City; during that tour he has been told
        figures by Mr Funfack, as Mr Funfack recalls; Mr Funfack
        tells us in that letter what the figures were that he knew
        from the City Commandant and from the Civil Defence Chief,
        Fetscher.
   MR RAMPTON:  Where does Dr Funfack say that he gave Mr Kleiner
        the figures -- because that is what this letter says.
   A.   We have three Funfack letters to rely on.  Which is the
        Funfack letter that refers to the International Red
        Cross?  If you know that, that would be of use.
   MR JUSTICE GRAY:  Funfack's letter to the Red Cross or
        referring to the Red Cross?
   A.   Referring to the visit from the Red Cross.
   MR RAMPTON:  It is probably this one on 19th January.

.          P-126

   MR JUSTICE GRAY:  Page?
   MR RAMPTON:  I do not know; it is in German.
   MR JUSTICE GRAY:  What?
   MR RAMPTON:  Sorry, it is in German.
   MR JUSTICE GRAY:  No, but it has a page number, 41.
   MR RAMPTON:  Yes, sorry, my Lord, yes.  It starts on 41 and
        finishes at ----
   MR JUSTICE GRAY:  It is hopeless.  I mean, not only are these
        almost illegible, but they are in German and why should
        one have to plough through them?
   A.   My Lord, I have read it actually during the lunch hour and
        there is the reference to the International Red Cross
        visit.
   MR JUSTICE GRAY:  I know, but I am complaining on my own
        behalf, you see, rather than yours.
   MR RAMPTON:  I complain on my behalf as well.
   MR JUSTICE GRAY:  Well, why does somebody not do something
        about it?
   MR RAMPTON:  There are two reasons for that, (a) because I do
        not believe it is necessary because there is not any
        connection in Funfack's letter between the Red Cross and
        what Mehnert's version of the figures was, according to
        Funfack.  Once again, Mr Irving has made a bridge where
        none exists.  You have made a bridge a between Funfach and
        the Red Cross.
   MR JUSTICE GRAY:  Well, he is having difficulty (as I am) in

.          P-127

        even reading this document, let alone seeing what it
        actually means.
   MR RAMPTON:  The other reason, my Lord -- I will be quite
        honest about it -- unless it is strictly necessary, we do
        not translate things if they are already in an expert's
        report.
   A.   But you see one example of where your expert has left out
        a very relevant fact, namely that in the very next
        sentence ----
   Q.   Which is what?
   A.   --- my source was telling me about 180,000 dead as
        reported by the City Commandant on February 22nd and
        170,000 dead as reported by Iring Fetscher, the Chief of
        the Civil Defence Organisation, and because that goes very
        closely to the 202,000 contained in the Grosse report,
        your expert left it out.
   Q.   Very good point, Mr Irving.  Take it up with Professor
        Evans.  My Lord, on page 533 of Evans you will find the
        relevant passage from Funfack's letter translated.
   MR JUSTICE GRAY:  I know it is there, but what we are looking
        for is to see whether there is anything about the Red
        Cross in this letter.
   A.   Oh, we have it, my Lord.  It is on page 42, and I am sorry
        to disappoint Mr Rampton.
   MR RAMPTON:  No, it does not disappoint me.  You are wrong,
        Mr Irving.

.          P-128

   A.   The City Commandant ----
   MR JUSTICE GRAY:  What are you looking at?  Come on, let us
        get  ----
   A.  "The City Commandant, General Mehnert, spoke on or about
        22nd February 1945 of 140,000 dead, Professor Fetscher of
        the Civil Defence Organisation of 180,000" ----
   Q.   Yes, but that has got nothing to do with ----
   A.   --- "but I have never seen written records of that.
        I attach great importance to the fact, to the facts in
        order to pay justice to the truth.  Best of all, the
        delegate of the International Red Cross should know the
        facts who visited Dresden on about 22nd to 26th February
        under the leadership of a Swiss gentleman and to whom all
        the figures were placed at the disposal of."
   MR RAMPTON:  So you infer from that, do you?
   A.   Oh, yes.  Oh, yes.  Remember, we are writing a book on a
        very ----
   Q.   That is fine.
   A.   --- very little known document in history.  We have a 50
        year rule on the records of the British in force at that
        time.  Dresden is behind the Iron Curtain.  I am doing my
        little best.  I think I have got very close to it with
        this one document where I am dealing with the man who was
        the Deputy Chief Medical Officer and who gives me figures
        given to him by his best friend, the City Commandant of
        the Chief of the Civil Defence, and he says, "We passed

.          P-129

        them on to the International Red Cross delegate".  I then
        contacted the International Red Cross who told me the name
        of the gentleman.  The American Government had the report
        of this delegate.
   Q.   So you have converted that letter and what you were told
        by the Americans into this proposition, if I may call it
        that ----
   A.   At set out in that paragraph of the book, yes.
   Q.   --- Mr Irving, that the Red Cross were told or Mr Kleiner,
        the Swiss leader of the Red Cross delegation, was told by
        General Mehnert that the current death toll was 140,000?
   A.   Yes, because that is the figures that Funfack is referring to.

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