Archive/File: people/i/irving.david/libel.suit/transcripts/day019.13
Last-Modified: 2000/07/24

   Q.   None at all?  You know that you are not allowed to, do you not?
   A.   I do indeed, yes.
   Q.   Can I ask you to go to page 89 of your expert report
        please, looking at paragraph 5:  "The murder by shooting
        of thousands of Jews is not the same as the extermination
        by shooting, gassing starvation and deliberate neglect of
        millions of Jews which forms an essential part of the
        Holocaust as conventionally understood".
   A.   Yes.
   Q.   No doubt you mean the shooting or gassing or starvation or
        deliberate neglect -- is that right?
   A.   Yes, of course.
   Q.   You do accept that I have written in most of my books, in
        recent years certainly, about the shootings in a way which
        makes it quite plain that I do not deny that they took place?
   A.   Yes.
   Q.   So we are limiting really the allegations of Holocaust
        denial to the more narrow front of the fact that I call

.          P-114



        into doubt the existence of gas chambers for mass
        extermination of Jews.
   A.   I think that is one very important element in it.  As
        I say here, there are a number of different elements
to
        Holocaust denial.  One of them is what I call here the
        extermination by shooting, gassing starvation and
        deliberate neglect of millions of Jews, plus the
        systematic nature of this, plus the number, the
millions
        of Jews as opposed to thousands, as I put it there,
and
        the allegation of the fabrication of evidence for the
        Holocaust as conventionally understood.  All those
things
        belong together, as I said this morning.
   Q.   I am moving forward now into the hundreds, I think.  I
did
        ask you -- this is a written question, in fact page
91.
        You commented once or twice on the index to my books.
   A.   Oh, yes.
   Q.   You say that you write the index of your own books?
   A.   Yes.
   Q.   Do you accept that most reputable publishers in fact
have
        the index prepared by an outside indexing
professional?
   A.   No.  Not in the case of scholarly works of history.
My
        experience in research books authors, historians, are
very
        keen to index their own books.  In any case, my
comment on
        indexing is simply because, in your written reply to
the
        Defence, you draw attention to index entries in your
        books, so I assume that that meant that you accepted
that

.          P-115



        they were genuine, and accept some responsibility for
        them.  Otherwise you would not have drawn attention to
        them.
   Q.   But you do accept that, in the case of all my books
with
        the exception of one, I have no part in the
preparation of
        the index?
   A.   If you say so.
   MR JUSTICE GRAY:  How does that work?  I am asking you
because
        you are the witness.  How easy is it for the writer of
        Hitler's War, for example, to get somebody else to do
his
        index?
   A.   I think, my Lord, correct me if I am wrong, what would
        happen is that an author would simply say to the
        publisher, well, employ a professional indexer, and
there
        are such individuals, and take the money off my
royalties,
        something like that, to pay the fee.
   Q.   I follow how it might work financially, but what I do
not
        understand at the moment is how the professional
indexer
        is going to know what to put in the index.
   A.   Well, that is a problem.  They are professional
indexers
        so they use their own judgment as to what is important
and
        what is not.  You start with place names, person
names,
        and then a number of subjects that you think are
important
        in the book.
   MR IRVING:  As the author of some 30 books, perhaps I can
        explain to your Lordship that there is a professional

.          P-116



        society of indexers and there is actually a British
        Standard for indexes, believe it or not.  The wise
author
        is well advised to leave the index to the
professionals
        rather than to attempt to do it himself.  The only
book
        that I have indexed in fact was The Destruction of
        Dresden, the recent edition?
   A.   I disagree with that.  I think a wise author should
index
        his or her own books.  It is a way you maintain
control
        over what the index says.
   Q.   Except you cannot draw conclusions from the content of
the
        indexes of my books as to the author of those books,
if
        I say that the author did not write the index.
   A.   Mr Irving, you are the one who drew attention to the
index
        in your reply to the Defence of the second Defendant.
You
        cite index entries as evidence of what you write about
the
        Holocaust.  That is the only reason why I use the
index so
        you yourself rely on them.
   Q.   I do not want get sucked into this particular morass.
        Will you agree that the only reason the index was
cited
        was to draw the attention to pages that were there by
        reference and not to the actual index itself?
   A.   Indeed, yes.  Obviously.
   Q.   If you now have a look please at page 93, just going
back,
        you refer to the fact that these editions of Hitler's
War
        were published under the same cover, line one?
   A.   Yes.

.          P-117



   Q.   And you will agree with me, do you not, that you
comment
        frequently on my having omitted things from the later
        edition of my book, that passages were omitted?
   A.   Yes, in particular references to the Holocaust.
   Q.   Would you accept that Hitler's War in the first
edition
        was 959 pages long, that is this edition, the first
        edition, and that The War Path was 328 pages, and that
the
        1991 all in one edition was less than a thousand
pages, so
        there must have been substantial abridgement in order
to
        fit them all into one volume?
   A.   Indeed, yes.  It is not the fact of abridgement that I
am
        commenting on but what is excised.
   Q.   Will you accept that, in the course of abridgement, by
        virtue of the task of abridgement, things get omitted?
   A.   Indeed, yes, of course.  That is what abridgement is.
   Q.   Page 93, paragraph 1, two lines from the end, you say,
the
        liquidation programme and the systematic murder
        are 'notions' as much as Hitler's knowledge of them.
Are
        you suggesting that the word 'notions' is mine?  You
put
        it in quotation marks.
   A.   Yes.  I quote you here saying that Hitler made
statements
        in 1942 and 3 which are incompatible with the notion
that
        he knew the liquidation programme had begun and that
        Europe's Jews had been systematically murdered.
   Q.   Will you accept from me that a digital search of the
text
        for the word "notions" found it only once in a 1940

.          P-118



        reference to the French campaign?
   A.   Well, "notion" is in the singular.  That is why the
plural
        failed.
   Q.   Notion or notions.  In other words, once again, you
put a
        word in quotation marks as though it is by me which is
not
        actually by me.  It is just your word.
   A.   I am sorry, it is.  It is your word.
   Q.   Well, I am just saying it is not, because I have done
a
        word search on the entire text and it is not in there.
        Will you now carry on to page 93, the last line, that
        I have removed all mention of the word 'extermination'
        from the book.
   A.   I have to say I do not accept that.  I am quoting your
        words there, the notion that you knew a liquidation
        programme had begun.  It is in the introduction to the
        1991 edition.
   Q.   Would you look at the last line of that page, please,
the
        introduction to the 1977 edition of the book?  I am
sorry,
        in the later edition of the book, I have removed all
        mention of 'extermination', is that correct?
   A.   I am trying to find this.  Where is it?
   Q.   The last line of page 93 and the first line of page
94.
   A.   The introduction?  Yes.
   MR RAMPTON:  My Lord, I intervene to correct an error by
        Mr Irving, no doubt perhaps not for the last time.
Page
        90 of the introduction to Hitler's War, first complete

.          P-119



        paragraph, "On several occasions in 1942 and 1943
Hitler
        made in private statements which are incompatible with
the
        notion that he knew that a liquidation programme had
        begun".
   MR JUSTICE GRAY:  I think that is right, Mr Irving, is it
not?
   MR IRVING:  Yes.  Will you now go to the last line of 93
and
        the first line of 94, where you say that I have
removed
        all mention of the word 'extermination'?
   A.   No.  I do not say that.
   Q.   All mention of ----
   A.   The introduction -- let me read those sentences.  The
        first reference in the introduction on pages 17 to 21
is
        the defence of Irving's views of Hitler.  "It has
already
        been pointed out above how it differs from the
        corresponding introduction to the 1977 edition of the
book
        in removing all mention of the extermination of the
Jews".
   Q.   Will you accept that the word 'exterminate' or
        'extermination' occurs 29 times in that book?
   MR JUSTICE GRAY:  It depends in reference to who.
   A.   It is the introduction I am talking about.
   MR JUSTICE GRAY:  I did not hear your answer, Professor
Evans.
   A.   I am referring to the introduction.  I am not claiming
        that the word does not occur in the whole book.
   MR IRVING:  At page 96 you refer to the fact that from the
        second edition of 1991, the 1991 edition, looking at
the
        first line of paragraph 7, "Even more strikingly the

.          P-120



        testimony of Morgen and Lorenz and the Slovak Jews has
        entirely vanished".
   A.   Yes.
   Q.   Which Slovac Jews are you referring to?
   A.   Verba and one other.
   Q.   Verba and Wetzler, is that correct?
   A.   Yes.
   Q.   Is it possible that I had learned something between
the
        two editions that made me totally distrust the
evidence of
        Verba?
   MR JUSTICE GRAY:  How can he know that unless you put what
it
        was?
   MR IRVING:  Thank you, my Lord, for inviting this.  Will
you
        turn to the little bundle, please?
   A.   I can cut this short.  I footnote this.  I explain in
        footnote 14 on page 97, since having written this book
in
        1977, you said, "I understand that that Slovac report
is
        open to some question", so I point that out.
   Q.   Yes.  It was not just open to some question.
   A.   Well, that is what you said.
   Q.   Could you go to pages 4 and 5 of the little bundle F?
        This goes to a rather wider issue in fact than just
the
        footnoting.  Pages 4 and 5 of the little bundle F, is
this
        an article from the Toronto Star as reproduced on my
        website?
   A.   It is an article in your website.  It is not
reproduced in

.          P-121



        the original.  It is not a photocopy.  It is copied.
   Q.   Does it purport to be reproduced from an article from
the
        Toronto Star dated January 24th 1985?
   A.   It does purport to be that, yes.
   Q.   Is the headline, "Book an artistic picture, survivor
never
        saw actual gassing deaths"?
   A.   That is the headline, yes.
   Q.   Is it an account of testimony given by the afore
mentioned
        Verba in the Toronto trial of Zundel in which, under
        cross-examination, Verba, and this is the indented
        passage, "yesterday admitted he was never inside that
        particular bunker" and Verba had seen, it was the roof
he
        had seen of the mortuary and not a gas chamber. That
is
        the indented passage.
   A.   That is right, yes.
   Q.   Does the rest of the article suggest that Verba was
not a
        very reliable eyewitness of what he claimed to have
seen
        or reported on?
   A.   It suggests that there are some aspects of what he
        original originally said were not reliable but he
insists
        that others were, according to the article.
   Q.   Yes.  I am sure, if he had been in Auschwitz as he
        undoubtedly was, he was able to testify to certain
aspects
        of what he had seen, but on the important issue of the
        goings on in gas chambers, it turned out he was not an
        eyewitness and was therefore in no sense reliable as a

.          P-122



        witness.  Is that correct?
   A.   Yes.  I do point that out in the footnote, as I have
had
        said.  You understand it is open to some question.  It
        seems to me a fair comment.
   Q.   Your Lordship will appreciate that the reason I have
        brought that to your Lordship's attention is it goes
to
        the question of eyewitnesses again.  This was an
        eyewitness of crematorium No. 2, the big building.  It
        turns out that he collapsed under cross-examination in
        Toronto.  Under that circumstance was I right
therefore in
        later editions of the book to omit his testimony or
        reference to it?
   A.   It depends rather on what testimony you were omitting.
        For example, he does say that he heard things from
        reliable sources, that he insisted he had made accurate
        estimates of the number of murder victims, and so on.
        But, if those passages which you omitted concerned those
        which he himself admitted were wrong, then of course you
        were right to omit them.
   Q.   Thank you.  Can we now go to page 100, where we are now
        dealing with my biography of Hermann Goring.  Do you have
        that in paragraph 1?
   A.   Indeed, yes.
   MR JUSTICE GRAY:  Are we leaving Hitler's War?

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