Archive/File: people/i/irving.david/libel.suit/transcripts/day016.09 Last-Modified: 2000/07/20 Q. Yes. But in each one were they all the same size? A. No, this is all four together. Einsatzgruppen A was I think the largest at 900, Einsatzgruppen B was probably the smallest at 600. Q. Their tasks were not just killing people, were they? They . P-61 had tasks? A. Yes. Q. Can you specify to the court what the other tasks of the Einsatzgruppen were, apart from killing people? A. They were to, well, kill others than Jews. They were to capture Soviet function areas, communist party members and they were to be killed, they were to secure left behind documentation, particularly trying to get NKPD documents or communist government documents, so they were to take likewise what was called all preventative measures against potential enemies. Q. Rather like CIC after the Second World War? A. Well to uncover if agents had been left behind the retreating armies. Q. Rather like the CIC, the Counter Intelligence Corps of the American Army after the Second World War, except for the killing operations, of course? A. I do not know what the CIC was exactly. Q. Are you familiar with the Sonderkommando Kunsberg, for example, the operations they carried out raiding Foreign Ministry buildings after the fall of Prague and Belgrade and so on, capturing documents? A. Securing documents was one function. Q. Quite an important function, was it not, of the Einsatzgruppen? They had an intelligence gathering function? . P-62 A. They do not refer too often in the documentation. This does not seem to have been a priority, but it was something, when they did it, they boasted about it. Q. Professor, I disagree with you on that. If you were to read the event reports of the Einsatzgruppen, you will surely find that their killing operations are only one paragraph, and that they have other paragraphs detailing in some detail, describing in some detail, the intelligence gathering operations in which they were involved and other routine police rear area operations? A. The reports are very long and the killing of Jews is usually one section within that much longer report. Q. Dealt with in a very callous manner, just 20,000 Jews were shot. A. It is usually done fairly briefly. Q. Have you ever tried to do a back of the envelope calculation on the feasibility of these killing operations, given the limited number of personnel who would have been available and the limited number of trucks that they had and the primitive nature of their trucks? Do you remember reading in any of these reports about how their horse drawn carts had broken an axle and that kind of thing? A. I do not remember a report on a broken axle, but I do remember reports where they deal with manpower problems, so that by late July they have gotten permission to raise . P-63 auxiliary units in the area, that they often refer to the co-operation of the Army in providing people for cordons, that according to the preinvasion agreement between the Army and the SS, the Army was to provide logistical support so, when they needed extra trucks and this kind of thing, the Army was expected to provide them. So that when we say that an Einsatzgruppen operation involved a kommando, that is not the only manpower that is involved. What we have found from the newer documentation from the Soviet Union is the degree to which the Einsatzkommando has since wanted to hog all the credit. Now that we see more documents, we can see that others were involved too. Q. The Soviet archives have been very important, have they not, the former Soviet archives? A. They have been important in fleshing out what happened in the Soviet Union. I do not think they have transformed our understanding of what happened elsewhere in Europe a great deal. Q. I have read your report with enormous interest, because of course I am not a Holocaust expert, but I have shown particular attention to the sources that have been used, the archives in Minsk you refer to? A. Minsk, Riga, Moscow. Q. How long have these archives been available to the average run of the mill incorrigible revisionist historian who wants to go and do research in them, do you think? Ten . P-64 twenty, thirty years or quite recently? A. I have not worked in them. Gerald Fleming, I believe, got into the Riga archives very early on, and he has kindly provided me with my first documents out of these areas. So that it was possible to get into some of them. It was also possible in the Zentralstellar in Germany to look at copies of documents that they had gotten from the Soviet Union much earlier. Q. In Potzdam? A. No Ludwigsberg outside Stuttgart. Q. West Germany? A. Yes. They had gotten what we now see, in a sense the cream of the crop. They had in fact seen many of these documents and brought photocopies back to Ludwigsberg. We had seen a number of the documents that then we found out were either in the secret archives or somewhere else. Historians could now see the whole pack. What you had was the selection in Ludwigsberg of selected documents. Q. Let me try to zero in what you just said. MR JUSTICE GRAY: Before you do that, Mr Irving, I am so sorry to interrupt because I am trying not to. It is difficult being interrupted, but I just want to see where we are getting with this. We know that you accept that the Einsatzgruppen killed probably hundreds of thousands. MR IRVING: We are looking at numbers, now, my Lord. MR JUSTICE GRAY: Let me make sure I am understanding where we . P-65 are going -- killed hundreds of thousands of Jews. It may well be that what you are suggesting at the moment is that those reports were exaggerated. But surely, for the purposes of this case, what really matters is that going back to Berlin were reports giving the numbers that they gave, because at this stage in the case we are really on how high the knowledge went, and was there a systematic programme in place. MR IRVING: I am very familiar with what Mr Rampton is trying to get out of this case, my Lord. MR JUSTICE GRAY: Do not worry about what he is trying to get out of the case. I want to make sure that I know where we going with the cross-examination. MR IRVING: I will put my cards face up on the table then, which I was hoping not to have to do as early as this in the cross-examination. MR JUSTICE GRAY: You must in order to answer my question and I am sorry to interrupt. MR IRVING: We are looking at the August 1 1941 document. That is at the bottom of this particular alley, the document with which your Lordship is familiar. MR JUSTICE GRAY: That is rather my point. I am sorry to interrupt you. All right, maybe a lot of the Jews were fleeing over the Urals and they were being shot by the Soviets. MR IRVING: That is not that document. The fleeing Jews and the . P-66 question of the killing capacities, the manpower, the personnel, the trucks base and so on, goes purely to the matter that Richard Evans has raised. Your Lordship will be familiar with the fact that Richard Evans has suggested four criteria for what a Holocaust denier is. A Holocaust denier is somebody who says Hitler did not know; a Holocaust denier is somebody who says the figures were less, and that is what this is about, that particular matter. I am entitled to suggest that the figures have been exaggerated and now unfortunately the Professor knows precisely what I am after. MR JUSTICE GRAY: All right. If you concede as much as you do concede, I wonder whether there is a great deal of scope for debate on this particular topic. MR IRVING: The figures are important, my Lord, I do suggest, because there was undoubtedly an appalling massacre on the Eastern Front. I do not deny it. No sensible historian does deny it, rather. I am not going to be shot down by Mr Rampton for suggesting the figures are not as large as they have been made out to be and there is room to suggest that, whatever one has conceded, I rather dispute the word conceded, it is a position I have always adopted, the figures are smaller than have been commonly suggested. I will not pursue this much further. MR JUSTICE GRAY: No. It is really just to clarify my thinking but thank you for that answer. I appreciate that . P-67 dimension. MR IRVING: Interesting though all this is, and nothing would please me more than to have a long conversation with Professor Browning, this is the court's time and I am acutely aware of that. MR JUSTICE GRAY: That is what I am conscious of, too. MR IRVING: Where was I? MR JUSTICE GRAY: I am sorry, I interrupted your flow. A. I believe we were talking about documents that an historian would have had access to in the 1980s as opposed to after 1989. MR IRVING: Yes. In other words, it should not really be held against a historian if he has not gone and worked in Minsk and Riga and these other places in your view? A. A number of those key documents in fact were by the 1970s, and in the Zentralsteller some copies were in the Institute in Munich. They are cited in books and at various conferences, and then we find that they were part of a larger file. But many of the key documents were available before 1989. Q. I understood you to say that the German official or semi-official historical institutes had privileged access to Russian collections which are not immediately made available to other historians? A. No, not the historical institutes, the German judiciary in the process of trying Germans, most of which took place in . P-68 the 60s and 70s, did have access, and that they in turn at Ludwigsberg allowed historians to come and see their documents.
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