Archive/File: people/i/irving.david/libel.suit/transcripts/day019.06 Last-Modified: 2000/07/24 Q. Then you left out the explanatory bit? A. No. "Even the most erudite and hard working historian", I . P-47 say, "is never going to obtain 100 per cent truth. He is only going to approximate it", and that, I think, gives the sense of what you are saying. I come back to the point, I echo the point that you have made about your own work, this report is already 740 pages long, and in this quotation, I think I give the essence of what you are saying there. Moreover, of course, I do put the ellipse in, three dots, to tell the reader that I am leaving something out there so the reader can do, as you have done, go back and cheek the speech and see if I have left anything out that I should not have left out. That is not the case in quite a number of the cases in which you abbreviate quotations from the original sources, as I have shown in my report. Q. Yes, but ---- MR JUSTICE GRAY: But it is fair to say Mr Irving does go on really to say he is one of those writers who does try to get the extra 10 per cent and get 100 per cent accuracy? I think that is the burden of the passage as a whole. A. Yes, indeed, yes. MR IRVING: Unfortunately, not everyone has our patience to go and look up the original document to see what has been replaced by the three dots. There is another passage, while you still have that H1 in front of you, please, can I ask you to go to page 106 of H1(i)? This has a rather . P-48 more important kind of material that has been left out of the indented paragraph? A. Yes. Q. In the middle of page 41 of the expert report, my Lord. MR JUSTICE GRAY: Yes, I have it. MR IRVING: Your Lordship will see that the witness has omitted all the reference to the organized campaign of window smashing and so on that went on around this country to persuade Waterstones not to stock my books and other booksellers. He then goes on to mock me for suggesting that there is a campaign, having cut out the material relating to it out of the quotation. A. Sorry, where do I mock you? Q. Page 42 at 254: "Irving does not appear to believe that other historians can rise to the challenge; rather he believes that there is an international campaign organized by the Jewish community in many countries to stop him from speaking and selling his books"? A. Well, that is my sense of what you believe. I do not see anything mocking in that. I am trying to convey your own point of view there. Once again, of course, in this passage that you mention, there are ellipses to denote that I have omitted some material, and really what I am trying to do here is to describe your view of history. I am not really concerned with all the details that you give here about the campaign which you allege is being . P-49 conducted against your work. That is not what I am concerned with. Q. Here you go on about the campaign I allege has been conducted against my work, but you have deprived his Lordship of knowing details of what that campaign is; the fact that there was an organized campaign of window smashing in the big book stores to persuade them not to stock my books. A. How is that relevant to my report? I really do not see it. Q. Because you say (as you have just said) that I allege there is a campaign and you say in paragraph 2.5.4 that I seem to believe that there is a campaign to stop me selling my books, and yet you have cut out of that quotation concrete evidence of the campaign that has been going on? A. But it is not my concern in this report to deal with the campaign. I have given your view here that there is a campaign, and I think in the context of a report which is about your treatment of historical subjects, that that is enough. If I went, if I had gone in this report into every issue like that, it would have been enormously long and I really do not think that is relevant to what was asked to do. MR RAMPTON: I should intervene. Mr Irving actually misread the report. It is only so that it gets on the . P-50 transcript. The report actually did not say "he seems to believe". MR JUSTICE GRAY: "He believes". MR RAMPTON: It says "he believes". MR JUSTICE GRAY: I did notice that. MR IRVING: If had omitted any reference to book burning from a passage about the Nazi activities in 1933, that would have been duplicitous, would it not? A. It depends what you are trying to write about the Nazi activities in 1933. Q. They were suppressing books that they disapproved of. A. If you are writing a dissertation about the Nazi policy towards the Civil Service or the Nazi policy towards the Bau(?) in 1933, then I do not think book burning would necessarily have been a relevant consideration. Q. If I had omitted the book burning in Berlin in March 1933 from my Goebbels' biography, then this would have been duplicitous, would it not, and if I had just said, "Well, that did not really belong"? A. That is certainly true since Goebbels was centrally concerned with it. Q. If I had omitted the window smashing, which is very apposite, from the Kristallnacht, that would also have been duplicitous, would it not? A. Absolutely, yes. Q. So why is it not duplicitous that you omitted that passage . P-51 from that passage you quoted? MR JUSTICE GRAY: I understand your point, but the fact is in paragraph 254 Professor Evans does refer to your belief that there is an international campaign to prevent you from speaking and selling your books. So he is not actually concealing it, is he, in his report? Anyway, I understand the point, but let us go on to the next point. MR IRVING: Many paranoid people have beliefs which are not supported by evidence, my Lord, but if there is a campaign of window smashing which is in the discovery, which is in the documents before the court, the witness should not have cut it out of the part that he quotes. MR JUSTICE GRAY: I understand that is the criticism you make of him, yes. MR IRVING: That is my submission. That I regard as earning all the adjectives that have been heaped on me by this witness. (To the witness): In that same paragraph, 254, we are back to your report, Professor. You say: "Irving does not appear to believe that other historians can rise to this challenge, rather he believes there is an international campaign ordered by the 'Jewish community (our traditional enemies)'"? A. Yes. Q. What entitles you to equate those two as though I had said . P-52 that the traditional enemies of the truth or free speech are the Jewish community? A. Well, on your website you list, you have a section where you list the traditional enemies of free speech. Q. Which includes the Jewish community leaders, yes. A. Nearly all of them. I think there is only one organization there which is not a Jewish organization. Q. But you put the words "Jewish community" in quotation marks as though you are taking it out of some document of mine? A. I did not want to imply that there was a Jewish community in that sense. That is why I put it in inverted commas. Q. You refer quite correctly to my website where I have a menu of traditional enemies of free speech, some of whom are specific organizations which are Jewish in character? That is correct? A. Nearly all of whom -- all apart from one. MR JUSTICE GRAY: Have you got the reference for this either in your own report or in the website file because I would quite like to see it if the point is being taken. It is difficult ---- MR RAMPTON: My Lord, I ---- A. It is page 168 of my report, my Lord, where I detail a number of cases where Mr Irving has equated -- I quote here a speech in 1992: "'Our old traditional enemies ... (are) the great international merchant banks are . P-53 controlled by people who are no friends of yours and mine', who were 'annoyed' friend by" ---- MR IRVING: What paragraph is that? A. 168, paragraph 50. Q. Is there an ellipsis in the middle of that? A. Yes. Q. Will you please look at the document and see the four sentences, three fullstops, four semi-colons and 86 words that those three dots represent? A. Could you direct me to ---- Q. And see if that is a genuine quote? A. --- the document, please? MR JUSTICE GRAY: Yes. That is fair. MR IRVING: That is the document, I am very familiar with that quotation. A. Could you direct me to it, please? MR IRVING: This is highly illuminative and illustrative of this witness's methods. MR RAMPTON: I think it is the Clarendon Club. I think your Lordship has probably already seen that, in fact. Unfortunately, mine is not here. MR JUSTICE GRAY: D2(ii). MR RAMPTON: Yes. It is K4, tab 5, Clarendon Club. MR JUSTICE GRAY: I am not sure this is actually going to be the answer to the question, but that may be wrong. MR IRVING: The question is what do those three dots represent? . P-54 A. K4? MR RAMPTON: K4, tab 5. A. Yes, 5, I have that. MR RAMPTON: This is the Clarendon Club in September 1992 which I think is the reference we have here? A. "Our old traditional enemies". MR JUSTICE GRAY: Bottom of page 3 of 13. A. Yes. Right, shall I read that out, if you would not mind? MR JUSTICE GRAY: Yes. MR IRVING: My first question is ---- A. May I read that out then? MR JUSTICE GRAY: He is just going to read it first and then ask the question. A. It is about Andrew Neil, the Editor of the Sunday Times, and the Goebbels' diaries which he was publishing in your -- from you, and that he had come under pressure "'from our traditional enemies, pressure not just from the advertising industry, pressure not just from the self-appointed, ugly, greasy nasty, perverted representatives of that community, he came under pressure from the international community too because the Sunday Times, like many other newspapers, needs international capital to survive and the international capital is provided by the great international merchant banks, and the great international banks are controlled by people who . P-55 are no friends of yours and mine'". MR JUSTICE GRAY: That appears to be Andrew Neil speaking. MR IRVING: What I am looking at is what those three dots represent which is not just ---- MR JUSTICE GRAY: Pause a moment. We will get to that in a second. A. I take that to be Mr Irving's paraphrase and version and gloss on what Mr Neil was saying. MR JUSTICE GRAY: So the answer is yes, but it is a gloss? A. A very heavy gloss, my Lord, I think, and it goes on to say, "And Andrew Neil found that these 60 foot long posters had annoyed these people, and they put immense pressure on him, and we know this because from all over the world I have been getting press clippings", and so on and so forth. MR IRVING: Where do the three dots end and the sentence resume? A. "'... are the great international'" -- "our old traditional enemies are", it is three lines up from the bottom of page 3 and the sentence resumes four lines down from the top of page 4, so that is, five lines are omitted there. Q. My point is, my Lord, that when you see three dots in the middle of a sentence like that, you are entitled to assume that a few words have been left out of a sentence, not that two words have been taken from one sentence and then . P-56 sentences later they have been glued on to. MR JUSTICE GRAY: Well, I think the point, and bear in mind we are not really concerned with your criticisms of Professor Evans, rather the other way round, but the point is whether anything has been left out that materially affects what is quoted. It seems to me that in this particular instance what has been left out by Professor Evans really makes no difference. Indeed, in many ways he might have made his point more strongly if he had put in what he had left out, the reference to "the self-appointed, ugly, greasy, nasty, perverted representatives of that community". MR IRVING: I agree, my Lord, but my point is that if I had adopted that kind of abbreviation in a paragraph, and I had cut out three or four sentences, full stops, semi-colons and 86 words and replaced them by three dots, it would have been completely reprehensible and it would have been rightly pounced on by all the witnesses in this case. MR JUSTICE GRAY: I would not have thought it was reprehensible unless it did some injustice to what remains quoted. MR IRVING: If I can put it another way? If I were an editor in a reputable publishing house and I caught one of my authors doing that, then I would sit on him like a tonne of bricks and say, "You cannot do this".
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