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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