Archive/File: people/i/irving.david/libel.suit/transcripts/day017.09 Last-Modified: 2000/07/20 MR JUSTICE GRAY: I appreciate that, but you know what I mean. I have had rather less long. So can you just help me who Greiser was? A. Greiser is the head of---- MR IRVING: The Gauleiter of the Warthegau. A. Gauleiter of the Warthegau. Lodz and Chelmno are located in the Warthegau. MR JUSTICE GRAY: Thank you. MR IRVING: The second document is the one -- you must help me on this -- with the 97,000 figure in it? A. I believe it is June 6th 1942. MR RAMPTON: June 5th? A. June 5th. MR IRVING: 1942, correct. MR RAMPTON: Perhaps in this case we should maybe get the document. MR IRVING: I agree. There are two rather odd features about the document I want to draw your Lordship's attention to. MR RAMPTON: It is in the second volume. MR JUSTICE GRAY: I hope it is in J or L. . P-75 MR RAMPTON: I think it is in the main bundle now. MR JUSTICE GRAY: If Greiser's letter is there too, then I would quite like a reference to that at the same time. MR IRVING: Do you have the actual document in front of you? MR JUSTICE GRAY: Just a moment. Let us catch up.. A. No, I do not. MR RAMPTON: One starts at page 92 of the new Browning file which is Greiser's letter. MR JUSTICE GRAY: You tell me about a new Browning file. I feel I am the last to know about it. MR RAMPTON: Tab 7, I am sorry. MR IRVING: My Lord, meanwhile I can tell you what I am aiming at here. MR JUSTICE GRAY: Let us pause a little, Mr Irving. You have to be patient with us. MR RAMPTON: Then the motor pool letter, the 97,000, is on the following page, I hope, 93 to 97. MR JUSTICE GRAY: I think I may have misunderstood. Are we in tab 7 of L1. MR RAMPTON: Tab 7 of L1. MR JUSTICE GRAY: Page 97. MR RAMPTON: Starting at page 92, that is Greiser to Himmler of 1st May in a printed form. We have not got a copy of the original. MR JUSTICE GRAY: Yes. And the other one, Mr Rampton? MR RAMPTON: Then the very next page, 93, is the 97,000 letter . P-76 of 5th June 1942. MR JUSTICE GRAY: Thank you. MR IRVING: I am just going to wave one little flag about the document's oddities. This is the document containing the 97,000 figure, correct? A. Correct. Q. Do you see at the top it says "Einzigste Ausfertigung" in German? A. Yes. Q. Have you ever seen that designation on a document anywhere else in your entire archival experience? A. I do not recall seeing it. Q. Yes. "Einzigste Ausfertigung" which means the "onlyest" copy. A. Yes, the motor pool sergeants were not terribly literate. Q. I take that point. Can you see that the document begins with the sentence: Beispielsweise, for example? The very first sentence in the document. A. Yes, it says, "seit December", yes. MR JUSTICE GRAY: I am sorry, I have not got that. Where are you? MR IRVING: In the very first sentence of the document, my Lord. MR JUSTICE GRAY: "Seit December". MR IRVING: The one with 97,000 figure in it. MR JUSTICE GRAY: Since December. . P-77 MR IRVING: No. The word I am looking at is "Beispielsweise". It is a letter beginning with the phrase, for example, "Beispielsweise", it is just lifted out of the middle of nowhere. Have you ever received a letter from somebody beginning with the word "Beispielsweise", Professor Browning? A. No. Q. Or "for example"? A. But I think to have to realize Mr Schuss was not a college graduate, that these are people who are working in the motor pool in Berlin, and that the tone, as I see it, is someone who is trying to emulate what he thinks is proper bureaucratic German and he in fact is someone is not a bureaucrat, he is a mechanic. Q. He was not stupid because, as you say, he was the only one who was not punished in this entire horrible affair. A. You have to remember that "Beispielweise" comes after the subject, which is they are talking about technical changes. Q. Yes. A. I presume that this is a result of a conversation people have had, there has been a meeting. Q. Yes. A. And someone has said, write it up. Q. OK. A. We get a very ---- . P-78 Q. Can you do a rough calculation of how many people were being killed per van per day? MR JUSTICE GRAY: Just pause, Mr Irving. If I may say so, you must just let me absorb the points you are making. MR IRVING: I am just planting suspicion. MR JUSTICE GRAY: You are casting doubt on this, partly because it has "Einsigste Ausfertigung" on the top and I understand that, but I am not sure I am really following your point on "Beispielsweise". MR IRVING: It is an unusual turn of phrase to start a letter with, my Lord. MR JUSTICE GRAY: Why is it unusual? He is picking three trucks, is he not, to give an example of the sort of numbers that are being processed if that is the right word, in the special trucks. MR IRVING: I agree, my Lord, but you would normally expect that in the second paragraph of a letter. In the first paragraph he says, well, we are going to have troubles doing this, that and the other, troubles with the trucks, the exhaust hoses are getting corroded and all the rest of it, for example, but in fact his letter begins with the word "for example". This is the oddity about it. But I can do no more than ---- MR JUSTICE GRAY: You rely on that as an indication that this is not an authentic document? MR IRVING: I am trying to plant a seed of suspicion in your . P-79 Lordship's mind, that is all. MR JUSTICE GRAY: You are not succeeding at the moment because I would have thought, if you are trying to create a document that is going to deceive anybody, you would not do what you say is something obviously inappropriate, which is to refer to an example in the first paragraph. MR IRVING: It would be improper for me to do anything else. Mr Rampton will object if I do anything else because I have already stated that I fully accept that this document refers to the homicide of large numbers of human beings in gas vans. MR JUSTICE GRAY: Where are we going? MR IRVING: We are going to look at the number, my Lord, the 97,000. MR JUSTICE GRAY: So you accept this is an authentic document? MR IRVING: For the purposes of this morning, yes. MR RAMPTON: I do have to know sooner or later, and so does your Lordship, whether Mr Irving accepts for the purposes of this trial that this is an authentic document. If it is a forgery, we need to know why he says it is a forgery. MR JUSTICE GRAY: You do not say it is a forgery? MR IRVING: No. MR JUSTICE GRAY: Then we can forget about Beispielsweise, can we not? MR IRVING: But it also helps to address the court's attention to the fact whether this witness had competently . P-80 questioned the integrity of the documents we are confronted with. MR JUSTICE GRAY: It is not a valid criticism of him if you do not question it. MR IRVING: I personally would question it but not for the purposes of this morning's hearing. Shall we just proceed to the number? MR JUSTICE GRAY: Let us do the numbers. 97,000 -- what is wrong with that? MR IRVING: I am sorry about that detour. 97,000 people killed in three vans in what space of time? A. From December to June, this would be six months, by my calculation. Q. Six months? A. Yes. Q. Are these regular German army diesel trucks, five ton trucks or something? A. They refer to two and then a third, and I think they had -- we do not know the capacity of two of them because they were not either the Opal or the Saurer trucks. They were apparently converted Renault. Then they brought in a Saurer truck, which is the biggest model and could carry I think 50 to 80 people. The Opal was 30 to 50. We do not know the capacity of the actual two trucks that were---- Q. From the descriptions we have, it did not actually do it . P-81 on the spot. They were loaded aboard, the victims, and they were driven off into the country side for a couple of hours and then they were gassed on the way? A. No. As best we can tell they loaded them, gassed them there, or for a while ran the engines, and then drove them off. Q. Yes. A. So it was not a long way from Chelmno to the forest. I think it is two kilometres or 3 kilometres. Q. I have read 20 kilometres. A. That is not correct at all. I have driven it myself. It is not far, and one would have to do a considerable amount of the time needed to kill the people, one would have to remain in the courtyard unless you wanted to run the engines for a prolonged period after you arrived in the forest camp. Q. Have you ever calculated the quantities of gasoline or petrol that would be needed for these kind of trips? A. Not knowing the fuel consumption of the various truck models, no, I have not made a calculation. Q. Does it strike you as being a very economical way of killing people? A. I think this camp was probably very inexpensive to run in comparison to what they were taking in, property and getting in labour from the Jews in Lodz. My guess is that this was an infinitesimally small part of their budget. . P-82 Q. If they had just the three trucks and this length of time to do it in, and they had the problem of persuading the people to get into the truck, and loading them up, driving off, waiting for the gas to have its effect, then unloading them at the other end and cleaning up the mess so that the next cargo did not have any suspicions, there must have been quite a substantial turn around time? A. The trucks made return trips each day. In fact, we know with just one truck at the Semlin camp, it took about two months, with just one trip a day and occasionally two, to gas the 7,000 people there. So, with three trucks operating on a shorter run, they did not have to drive all the way through Belgrade to the far side, which is what happened in Semlin. I did the calculations for Semlin. Q. You have done the calculations? A. Yes. I have not done them for this. Q. Does the 97,000 not strike you as being wrong by a factor of two or three? A. Absolutely not. It does not strike me as wrong at all. Q. It depends strictly on what the capacity of the trucks would have been, what the turn around time was, whether they were really efficient, whether they worked 24 hours a day and whether the trucks had any down time. A. From the witness reports the trucks made numerous trips each day, the drivers traded off so that they in fact operated continually during the day. . P-83 Q. Around the clock 24 hours a day? A. Not 24 hours, through the day. Q. Yes. MR JUSTICE GRAY: It is pretty distasteful, but may I ask this question? How many people were there in a gas van when they were being gassed? How many people could be accommodated? A. We do not know for Chelmno because it is a different truck. There is a Saurer truck, one Saurer truck was at Chelmno. That is the one that exploded. Then they had two converted Renault French military trucks that they turned into gas vans, so we do not have a knowledge there. The small truck that they produced, the Opal Blitz, was the smallest. The Saurer could carry 50 to 80 people, the Opal Blitz was 30 to 50. So, even if the Renault was smaller than the Opal, which probably as a military truck it was larger, would be in between the two. Q. That is the order of magnitude? A. Yes.
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