The Nizkor Project: Remembering the Holocaust (Shoah)

Shofar FTP Archive File: people/i/irving.david/libel.suit/transcripts/day019.18

Archive/File: people/i/irving.david/libel.suit/transcripts/day019.18
Last-Modified: 2000/07/24

   Q.   Is 48,000 a number that you had seen regularly in
        connection with air raid victims in Hamburg, that
        operation, the fire storm raids?
   A.   No.  I go into this in the same paragraph, that the
        probable number, the generally agreed number is between
        35,000 and 40,000, that 74,000, or nearly twice 74,000 as
        you put in a letter to The Spectator in 1989, is a wild
   Q.   So you rely entirely on that letter to The Spectator, do you?
   A.   No, 50,000, I do not know where you get the figure from.
        It is plucked out of the air of 48,000.
   Q.   So in 1989 you say he put it far higher than I did,
        claiming that, while 74,000 people had died at
        Auschwitz, "nearly twice as many died in the July 1943
        RAF Dacken Hamburg"?
   A.   That is right.
   Q.   That is the quotation from my letter to The Spectator, is it?
   A.   Yes.

.          P-161

   Q.   Can we have a look at that letter to The Spectator; it
        worth having a look at?
   MR JUSTICE GRAY:  Where do we find it?
   A.   It is in your bundle.
   MR IRVING:     It is not in my letter.  I do not know.  If
        are lucky, it is in the bundle.
   MR JUSTICE GRAY:    Well, I think we will get it from E12,
        312, will we not?
   MR IRVING:  I do want to see it.
   MR JUSTICE GRAY:  Yes, I think that is fair.
   MR IRVING: Otherwise, I can tell you from memory what the
        actual quotation is.
   A.   I have to see it, I am afraid.
   Q.   You have to see it, you are afraid?
   A.   Yes.
   Q.   Otherwise, I will tell you from memory and I will
        the letter in tomorrow.  There is only one word
   MR JUSTICE GRAY:  Can anyone on the Defendant's side help?
   MR RAMPTON:  We are trying, my Lord; it is a chase to find
        Irving's documents.
   MR JUSTICE GRAY:  The trouble is if we come back to it then
        have to start all over again, that is the problem.
   MR RAMPTON:  I agree.  Let me put it like this.  If the
        "as" was in after the word "many", would that change
        meaning of that sentence?
   A.   Yes, of course it would.

.          P-162

   Q.   If it said, "nearly twice as many as died in the July
        air raid", would that change the meaning?
   A.   Yes, of course.  That would make it 30, 37, is that
   Q.   Would it totally deflate the point of the whole
        and the paragraph before, as far as exaggerating air
        figures goes?
   A.   No, it would not, because you describe, you give the
        number as nearly 50,000 on page 441 of Goebbels.
   Q.   Is not the commonly accepted figure for these series
        air raids on Hamburg 48,000?
   A.   No.  It is between 35,000 and 40,000.
   Q.   On page 2, I am sorry, the next page, 112, line 2, you
        31,647 dead had been found?
   A.   Yes.
   Q.   And you are familiar with the pictures of what it
        like inside bunkers?
   A.   Yes, indeed.
   Q.   The flat tyres, the little heaps of ash which had been
        human beings?  Have you seen the photographs on the
        streets of the heaps ash?
   A.   Indeed I have.  I take it that that is why official
        estimates at the time put the total as somewhat higher
        35,000 or even 40,000.
   Q.   And you have never seen a figure of 48,000?
   A.   Only in your work.

.          P-163

   Q.   Have you read the official history of the strategic
        offensive against Germany by Nobel Frankland and
   A.   No, but I am relying here on work produced in Hamburg
        Hamburg historians.
   Q.   You do accept, though, that if my version of that
        quotation is correct and you accidently or otherwise
        omitted the word "as", your entire argument that I
        doubled the number of people is unjustified and you
        going to have to withdraw that, are you not?
   A.   Yes, because, as I say here, I cite it from Eatwell.
   Q.   So we will put the blame on Professor Eatwell?
   A.   Well, if indeed the word "as" is missing.
   MR RAMPTON:  We cannot find it in the Eatwell documents.  I
        sorry, it is not in the Evans' documents.
   MR JUSTICE GRAY:  In Eatwell book?
   A.   No.  It is in an article.
   MR RAMPTON:  We will check that.
   MR IRVING:  I have the actual original Spectator letter at
        home.  I know that, my Lord, I was looking at it last
   MR JUSTICE GRAY:  Bring it in if you would not mind.  We
        not going to be able to track it down today.
   MR IRVING:  If your Lordship thinks it is relevant.
   MR JUSTICE GRAY:  I think in fairness to you, if Professor
        Evans has misinterpreted what you said, I think it is

.          P-164

        right that I should know that.  I do not think this is
        point that is at the heart of the case, but in
fairness to
        you, you ought to have the opportunity to show it to
   MR IRVING:  It is at the heart of the allegation that I
        double air raid figures to make a point.
   MR JUSTICE GRAY:  Well, that is one aspect of a broader
        that Professor Evans is making ----
   MR IRVING:  Yes.
   MR JUSTICE GRAY:  -- about what is described, rather
        inappropriately, as moral equivalence.
   MR IRVING:  Also it is useful at various other levels all
        way down to how easy it is to make simple errors that
        totally innocently reverse the meaning of a document.
        This literally reverses the meaning of that particular
        document, the one word.
                  So all the rest of that paragraph about the
        probable number, therefore, is between 35,000 and
        (I am on page 112 like 7), "Irving's wildly invariably
        categorical statements of 48,000", just like today I
        say 48,000, nearly 50,000 or nearly twice 74,000, that
        course is the wrong bit, is it not?
   A.   If that is that true of course it is wrong, yes, and I
        would withdraw it.
   MR JUSTICE GRAY:  I really think we have probably got
        everything we possibly could out of that paragraph.
   MR IRVING:  Moving on to the next paragraph, we are now

.          P-165

        with the number of people who I suggested
        can be shown as having died in Auschwitz, in the last
        I say: "Around 100,000 dead in that brutal slave
        camp", and, Professor, you take exception to that
        sentence, do you not?
   A.   Yes.
   Q.   You think the figure should be much closer to 1
   A.   About that, yes.  Slightly more.
   Q.   No doubt 20 years ago you would have said the figure
        be closer to 4 million?
   A.   Not 20 years ago, no.
   Q.   No?
   A.   I do not think so.
   Q.   So you would have discounted what the memorial said?
   A.   We have already been through this, but that was the
        product of immediate postwar circumstances when not a
        great deal was known.
   Q.   You do not just go with what the prevailing wind
        is the latest figure; you do your own independent
        about it?
   A.   I am not a specialist on Auschwitz, Mr Irving.  So
        I accept what is the general consensus of scholarship
        this issue.
   Q.   Yet if anybody does try to analyse the figures on the
        basis of other sources than what the memorial says or

.          P-166

        the Auschwitz State Museum says or what Sir Martin
        says, he is a denier?
   A.   Well, it is not a question of just what they say.
        is a very large, substantial amount of work.  This
        has been spent several days going through a whole mass
        evidence about Auschwitz.
   Q.   Yes, but it is the word "analyse" I am looking at.  If
        look at page 113, paragraphs 13 and 14, I say:
        who wants to analyse any part of the Holocaust story
        dismissed and smeared as an anti-semite or at the
        end of the scale a pro-Hitler apologist and a Nazi
        apologist."  You then comment in paragraph 14:
        here is a synonym for refute or deny"?
   A.   Yes, that seems to me it is.  It is a euphemism.  You
        very careful to avoid the word "denial" as much as you
        can, or you have been in what you have written and
        about the Holocaust, but clearly as it stands this
        statement is absurd.  Historians are analysing the
        Holocaust story all the time.
   Q.   But are they?
   A.   It goes on massively.
   Q.   Are they analysing figures all the time?
   A.   Yes.  There is an enormous amount of work that is in
        progress.  There are hundreds of historians working on
        this.  There are large institutions which are devoted
        analysing all different parts of the Holocaust story,

.          P-167

        nobody is dismissing them as anti-semites or Nazi
        apologists.  What you have here is "analysed" as a
        euphemism for "deny".
   Q.   So analysing is all right until we look at the figures
        then it becomes denial?
   A.   No.  Historians are looking at the figures all time.
   Q.   What kind of historian do you have to be then to avoid
        that word "denial"?  Do you have to avoid my name or
        you have to be left-wing or what?
   MR JUSTICE GRAY:  This is semantic.  We know what the
        definition of Holocaust denier is as contended for by
        Defendants.  The issue we are trying to explore is
        you, Mr Irving, fit that definition.  I really think
        semantic discussions of this kind are unhelpful.
   MR IRVING:  I was scene setting with a broad brush, and now
        are going to start getting out the small sable and
        painting in some of the detail.
                  Professor, if there are either logical
        calculations that you make or there are bodies of
        documents that you can make which would enable one to
        reassess the figures, I am avoiding the word "analyse"
        now, but to reassess the figures, would that be a
        justifiable exercise for any historian of whatever
   A.   Yes, certainly.  For example, new material is becoming
        available or has become available since the collapse
        the Soviet Union in East European archives which has

.          P-168

        helped in reassessments.
   Q.   Yes.  In about 19899 Soviet Union released the death
        books, did they not, of Auschwitz relating not to all
        years but some of the years?
   A.   That is right, yes.
   Q.   Would you expect these death books, the registers of
        deaths of people in Auschwitz, to have provided some
        of impetus to this calculation?
   A.   They are certainly a significant document, yes.
   Q.   I am avoiding the use of the word "analyse".  It would
        justifiable to look at those records for any person
        try to do some kind of meaningful calculation and try
        work out whether these were comprehensive,
        all-encompassing death books, or whether they were
        part of the body of Auschwitz or what?
   A.   Indeed, yes.  You have to remember, of course, that
        large numbers of people who were taken straight to the
        chambers on their arrival at Auschwitz were not
entered in
        the camp registers, and so do not appear in the death
   Q.   This is an important part of the Holocaust history, is
        not, the notion that a large number of people arrived
        the camp, were unloaded and were sent straight to
        deaths in the gas chambers, is that correct?
   A.   I think, yes.
   Q.   What kind of people were they?

.          P-169

   A.   It is described as more than a notion.
   Q.   What kind of people were then selected for death?
   A.   Well, I am not an expert on Auschwitz, but my
        understanding is that the process of selection
        tended to take into the camp or register in the camp
        who were considered to be capable of working and those
        were not, particularly women and children, were sent
        the gas chambers.
   Q.   Women and children were sent to the gas chambers.
        Professor, will you have a look at page 35 I think it
        in my bundle, the little bundle you were handed this
        morning?  It is another of these pictures speaking
        than words things again.  Is that a photograph showing
        people standing behind barbed wire?
   A.   Indeed, yes.
   Q.   What kind of age are those people?
   A.   It is very difficult to say.  They look like -- it is
        difficult to say.  One or two children, some
   Q.   Does the caption provided by Associated Press say:
        is somebody standing among a group of children?
   A.   Indeed, yes.
   Q.   When the camp was liberated by the Red Army?
   A.   Yes.
   Q.   Why would they have had children in the camp?
   A.   There could have been any one of a number of reasons.
        I mean some children were retained for medical

.          P-170

        experimentation, that is a particular reason.  There
        numbers of allegedly or so-called pure bred gypsy
        who were kept.  There were a number of reasons.
   Q.   Is there any indication on the caption that these were
        experimental ones or the gypsy ones?
   A.   I really could not say.

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