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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