Holocaust Denial on Trial, Trial Transcripts, Day 3: Electronic Edition

Pages 1 - 204 of 204


 1IN THE HIGH COURT OF JUSTICE
1996 I. No. 113
QUEEN'S BENCH DIVISION
 2Royal Courts of Justice
 3Strand, London
 4 Thursday, 13th January 2000
 5
 6Before:
 7MR JUSTICE GRAY
 8
 9B E T W E E N: DAVID JOHN CAWDELL IRVING
10Claimant -and-
11(1) PENGUIN BOOKS LIMITED
12(2) DEBORAH E. LIPSTADT
13Defendants
14The Claimant appeared in person
15MR RICHARD RAMPTON Q.C. (instructed by Messrs Davenport Lyons and Mishcon de Reya) appeared on behalf of the First and
16Second Defendants
17MISS HEATHER ROGERS (instructed by Davenport Lyons) appeared on behalf of the First Defendant Penguin Books Limited
18MR ANTHONY JULIUS (of Mishcon de Reya) appeared on behalf of
19the Second Defendant Deborah Lipstadt
20
21(Transcribed from the stenographic notes of Harry Counsell
& Company, Clifford's Inn, Fetter Lane, London EC4
22Telephone: 020-7242-9346)
23 PROCEEDINGS - DAY THREE
24
25
26

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 1 < DAY 3 Thursday, 13th January 2000
 2MR DAVID IRVING, Recalled.
 3 MR JUSTICE GRAY:     Yes, Mr Irving?
 4 MR IRVING:     May it please the court, with your Lordship's
 5permission, I have brought the bundle of the documents
 6that we were referring to last night. Unless your
 7Lordship would see any reason against, I propose rapidly
 8stepping through these documents, pausing at the ones
 9which are significant as far as we can determine so far
10from the direction and thrust of the cross-examination.
11 MR JUSTICE GRAY:     Yes. You are in the middle of your
12cross-examination. So, in the ordinary way, we will wait
13and see when the documents became relevant to Mr Rampton's
14questions.
15 MR IRVING:     They have been in discovery throughout, my Lord.
16 MR JUSTICE GRAY:     I follow that. But I suspect most of them
17are going to become relevant to the answers you are going
18to be giving to some of the questions Mr Rampton
19is asking.
20 MR IRVING:     I do apprehend it will be useful to the court, I
21appreciate that it is your Lordship's court, but I believe
22it will be useful.
23 MR JUSTICE GRAY:     You may well be right. I cannot really tell,
24I have only glanced at it. Shall I ask Mr Rampton --
25because he is cross-examining, so, on the face of it, he
26has the right to continue to cross-examine.

   P-2



 1 MR RAMPTON:     I have no objection. In a sense, it is either
 2evidence-in-chief in anticipation of cross-examination, or
 3it is what one might call "premature re-examination".
 4 MR JUSTICE GRAY:     Yes.
 5 MR RAMPTON:     One way or the other it is going to make no
 6difference.
 7 MR JUSTICE GRAY:     If you are happy I will not stand in the way.
 8     Before that happens I wonder if I could mention
 9one or two administrative points? The first is, I think
10we are all agreed through nobody's fault, this is not a
11very suitable court and I am very concerned that there are
12members of the public who, I think, are not able to get in
13and listen and want to. Having made enquiries, as I said
14I would, I think there are two possible courts to which we
15could move which were not available or were not thought to
16be available when we started. One is court 73, which
17I have looked at and looks to me to be much better than
18this in almost every respect. There is, apparently,
19another one, which is in Chichester Rents in Chancery
20Lane, which is even bigger. I think I would have some
21slight personal preference for 73, but what I wanted to
22ask you is that I think we should move anyway, because
23this is not satisfactory and it seems to me, unless you
24are going to tell me there are insuperable problems,
25tomorrow is the day to do the move. Are you in agreement
26that that is the right thing to do?

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 1 MR IRVING:     I would have suggested doing it over the weekend
 2although I have no logistical problems myself --
 3 MR JUSTICE GRAY:     Well, I think they have a lot of problems
 4ahead of them, but I think it is better to do it now than
 5to struggle on and regret it every day from hereon.
 6 MR RAMPTON:     That would suit us awfully well, if we could make
 7a fresh start in what I call a "proper big court" on
 8Monday morning.
 9 MR IRVING:     Not a fresh start.
10 MR JUSTICE GRAY:     We will decide -- not a fresh start.
11 MR RAMPTON:     No, thank you.
12 MR JUSTICE GRAY:     We will decide during the course of today
13which it is going to be and, obviously, let you know. We
14will take it that on Monday we will be in a different
15court.
16 MR RAMPTON:     May I ask where exactly 73 is?
17 MR JUSTICE GRAY:     It is where all those new Court of Appeals
18are.
19 MR RAMPTON:     In the East Building.
20 MR JUSTICE GRAY:     Yes.
21 MR RAMPTON:     In the end I would have to say, my Lord, it is a
22matter for you.
23 MR JUSTICE GRAY:     I think it is, if you have strong feelings.
24 MR RAMPTON:     No, I do not know Chancery Lane much at all
25anyway.
26 MR JUSTICE GRAY:     That is point one.

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 1     The next relates to the TA Law Transcripts which
 2are being done. Really, I think I am saying this on
 3behalf of the lady who is doing the transcribing. She is
 4having the most appalling task. She is here all day, and
 5she is by herself, as it were. It would help her if we
 6could slightly slow down. Mr Irving, you speak fairly
 7rapidly anyway. That is not a criticism at all.
 8 MR IRVING:     I thought I was speaking slowly.
 9 MR JUSTICE GRAY:     If you can bear in mind there is somebody
10trying to take down what you say, if we can try to
11remember to spell out the German names when they crop up
12for the first time. That is going to make everybody's
13life much easier.
14     There is one other point on the transcripts.
15The Day 2 transcript starts at page 104. My own feeling
16(and I do not know whether you share it, Mr Rampton) is
17that it would be better if every day started at 1, so you
18have Day 2, page 1, rather than page 104. I am told that
19is physically possible. So that is what I think we will
20have in the future.
21     That is all that I wanted to raise except that,
22Mr Irving, I have seen (and I do not know whether
23Mr Rampton has) your letter about the letter to me about
24the article in the Stuttgart press. Do you know about
25it?
26 MR RAMPTON:     No.

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 1 MR IRVING:     I was going to ask, my Lord, I might, having given
 2the Defendants time to consider it, if I might address the
 3court briefly on the matter after the lunch adjournment?
 4 MR JUSTICE GRAY:     If you would like to do that, that is fine.
 5Mr Rampton?
 6 MR RAMPTON:     I have no comment until I have seen it.
 7 MR JUSTICE GRAY:     I do not suppose you will, even when you
 8have.
 9 MR RAMPTON:     I see. My Lord, the only thing I would mention
10about the transcript, I do not know what the cure is. Is
11that, normally speaking, of course, one can deduce what it
12was, but here and there -- this is not a criticism of the
13transcriber, far from it -- one sees in square brackets
14the word "German" which represents something that has been
15said in German. That is going to repeat itself
16indefinitely in that case. I do not know what cure is.
17Whether the word should be spelt out each time. It is a
18terribly laborious way of dealing it, or whether we supply
19at some stage when it is important a list of what we
20suppose was the word used. As I say, most of the time one
21can deduce it.
22 MR JUSTICE GRAY:     Is it actually going to be all that much of a
23burden to spell it out or, at any rate, spell out the key
24words in the document? I am thinking yesterday
25"liquidierung". One can spell that out.
26 MR RAMPTON:     There is going to be more of that today.

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 1 MR JUSTICE GRAY:     I follow.
 2 MR RAMPTON:     Perhaps spell it out?
 3 MR JUSTICE GRAY:     I am inclined to think so. I think that is
 4the best way. It is going to slow things down. Would you
 5prefer it, both of you?
 6 MR RAMPTON:     Yes.
 7 MR JUSTICE GRAY:     It is going to slow things down, but it needs
 8to be done that way. So, Mr Irving, would you like to
 9take me through the...
10 MR IRVING:     Page 1, my Lord, this is a letter -- the sole
11purpose of this letter is that it indicates the date when
12I really made use of the Himmler telephone notes, being
131974; some 25 years ago, 26 years ago.
14 MR JUSTICE GRAY:     Can I just ask you this? You there
15transcribe judentransport, J-U-D-E-N-T-R-A-N-S-P-O-R-T, in
16the singular, and that is in 1974.
17 MR IRVING:     We have check the original in the German. You are
18absolutely right, my Lord. You are absolutely right.
19 MR JUSTICE GRAY:     Right.
20 MR IRVING:     In a very vague, and, of course, I am still
21considering myself to be under oath as I make these
22remarks, in a very vague way my recollection is that time
23I regarded the word "transport" as not just meaning like a
24transport train or one consignment, or a transport ship in
25the way that you would talk about a convoy of 26
26transports but also in the sense that transportation.

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 1I consider that the words judenstransport meant
 2"transportation of Jews".
 3 MR JUSTICE GRAY:     Yes, I note that you make that point.
 4 MR IRVING:     This is an alternative inference but now I am quite
 5happy to accept that this particular discussion from
 6external evidence only referred to one particular
 7transport of Jews, and I am indebted to your Lordship for
 8having reminded, or took me back into the mind set of 26
 9years ago.
10 MR JUSTICE GRAY:     Yes.
11 MR IRVING:     As you know, my presumption is, I will just read
12the middle paragraph that Hitler had become an active
13knowledge bearer or accomplice in the destruction of the
14Jews only in 1943. This is of course a translation of the
15following page, my Lord. From the attached page, which is
16a facsimile, which we will see in a minute, it is evident
17that Himmler, arriving at midday on November 30th, 1941,
18in the Wolf's Lair, which I explain was Hitler's
19headquarters in East Prussia, after a brief conversation
20with Hitler immediately had to telephone Heydrich in
21Prague, and then comes the phrase, "judentransportest aust
22Berlin keine liquidierung", which I believe the shorthand
23writer already had from us.
24     If you take this in conjunction with various
25other entries, e.g. that of 17th November 1941, in which
26Heydrich informs the Reich Fuhrer, that is Himmler, on

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 1conditions in the general Uberman, Poland.
 2 MR JUSTICE GRAY:     That is SS Reich Fuhrer.
 3 MR IRVING:     Well, Reich Fuhrer SS would be the full title.
 4There was only one Reich Fuhrer in German -- conditions in
 5the general government Poland-geting rid of the Jews,
 6Beseitigung, this can only indicate that Himmler has been
 7rapped across the knuckles by Hitler. This conversation
 8note has until now evidently slipped through the fingers
 9of the historical research community, as you might call
10it.
11     Then the other two lines at the bottom are not
12without interest in the chain of documents I refer to, my
13Lord. Himmler had to issue a similar "holt" order in
14April 1942 on account of the liquidation of the gypsies,
15again after a brief visit to Hitler. "I thought this
16might be of interest to you." You will see that document
17too, my Lord, in this bundle. Because it is false to try
18and draw inferences from one document without looking at
19other documents in the series. I appreciate in court it
20is difficult to do this.
21     My Lord, the next document I am going to draw
22your Lordship's attention to is 03 at the foot of the
23page. This is another document that was in discovery.
24 MR JUSTICE GRAY:     I have read that. That is you asking
25Professor Hinsley whether he has any more information.
26 MR IRVING:     Yes, my Lord, except that at that time it does

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 1indicate at that time he did not have the German
 2originals.
 3 MR RAMPTON:     I am sorry, Mr Irving. I beg your pardon. May
 4I intervene to ask your Lordship to insert it in that
 5bundle? It comes from Mr Irving's discovery. There is no
 6mystery about it. Professor Hinsley's reply.
 7 MR JUSTICE GRAY:     It was not there.
 8 MR RAMPTON:     Yes, we have it now.
 9 MR IRVING:     I could not find it last night, my Lord. In is
10Professor Hinsley indicates that he has obviously not yet
11seen himself the German originals of the British
12intercepts.
13 MR JUSTICE GRAY:     Yes.
14 MR IRVING:     It is quite interesting.
15 MR JUSTICE GRAY:     The postscript is perhaps of some
16significance.
17 MR IRVING:     It is interesting the British Official Historian
18and British Secret Service had either not been allowed to
19see or had not found in general chaos the documentation,
20these are the originals, which are now in the Public
21Record Office. But the German originals are very, very
22informative in their scope, breadth and depth.
23     That, my Lord, is 04. This is the first of the
24notes of the telephone conversations from Himmler's
25telephone log to the Chief of the SS, and the one on which
26I rely is the one timed 12.15. It is the fourth

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 1conversation. I am afraid I have not attached a
 2translation of it, but I will do a translation on reply on
 3the one or two lines that matter. It is a 15 minute
 4conversation with Heydrich who on that day was in Berlin.
 5We do not know who initiated the conversation, my Lord,
 6but Heydrich phoned Himmler or Himmler phoned Heydrich.
 7We never see them. We have to infer. Conference with
 8Rosenberg, conditions in the government general, getting
 9rid of the Jews, beseitigung of the Jews, and then the
10third line -- the fourth line rather, juristen
11nuralseerater, roughly lawyers just as advisers.
12     Nothing else on that page to which I will
13refer. Merely it shows there were conversations going on
14between these two gentlemen on liquidation or getting rid
15of the Jews.
16 MR JUSTICE GRAY:     What is the significance for my purpose of
17that?
18 MR IRVING:     It is the context in which the principal document
19is embedded, my Lord. The inference that has been drawn
20against me is that I have one cardinal document and
21I would go around the world waving this document and
22saying "here it the proof". It is, in fact, showing that
23they were constantly talking about getting rid of the
24Jews, using --
25 MR JUSTICE GRAY:     There is no issue, is there, that that was
26something that both Himmler and Heydrich were intent upon

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 1doing.
 2 MR RAMPTON:     Yes. The word " beseitigung" is interesting. You
 3can look at it either this way or that way, literally as
 4getting rid of, which can be sweeping under the carpet or
 5liquidation. I am quite happy to accept that here they
 6were talking about liquidation, these two gentlemen. It
 7now becomes more interesting, my Lord, on page 5.
 8 MR JUSTICE GRAY:     Can you just let me highlight?
 9 MR IRVING:     We come to the intercepts and Mr Rampton does not
10wish me at this point to bring in this material. I am
11quite happy to turn the page, but I think it is useful to
12bring it in all in chronological sequence.
13 MR JUSTICE GRAY:     When you "intercept" --
14 MR IRVING:     This is the Bletchley Park intercept of the --
15 MR JUSTICE GRAY:     Messages to Berlin.
16 MR IRVING:     Messages between Berlin and the Eastern Front for
17police commanders, and also a whole number of other SS
18units, but these are the ones I rely on.
19     No. 35 is a message addressed from Berlin on
20November 17th, that same day as the previous conversation,
21to the commander of security police, Dr Lange, L-A-N-G-E,
22in Riga, concerning, and I use the next word in original
23German -- these are my translations, concerning the
24evakierung of the Jews. "Evakierung", my Lord, is one of
25those words we will probably tussle over. The literal
26translation is "evacuation", but I am perfectly ready to

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 1accept for the purposes of this action that "evakierung"
 2is occasionally used by the SS as a euphemism for a more
 3ugly means of disposing.
 4     But in this particular case what is significant
 5is that the man in Berlin is telling the recipient in
 6Riga, on November 17th, in other words, that same day, at
 76.25 p.m., transport train No. DO 26 has left Berlin for
 8Kovno or Kornas, with 940 more Jews on board. That was
 9usually the rough size of each train load of Jews, about
101,000 Jews. Transport escorted by two Gestapo and 15
11police officers. Transport commander is Criminal
12Overassessor Exner, the man's name, who was two copies of
13the transport list with him. Transport provided with
14following provisions, and this is interesting part, my
15Lord, 3,000 kilogrammes of bread, three tonnes of bread
16for a two or three day journey. 27 kilogrammes of flour,
17nearly three tonnes of flour; 200 kilogrammes of peas; 200
18kilogrammes of nutriments; 300 kilogrammes of corn flakes;
1918 bottles of soup spices. They continue in the next
20message; 52 kilogrammes soup powders, 10 packets of
21something or other, we do not know; 50 kilogrammes of
22salt; 47,200 Reich Marks in crates. Signed Gestapo
23Headquarters, Berlin. Quite an interesting document, my
24Lord. It is the first kind of thing we come across in my
25view to show that these trains were actually
26well-provisioned. It is a bit of a dent, a tiny dent in

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 1the image that we have, the perception, as Mr Rampton
 2calls it, of the Holocaust today.
 3     The next one, page 6, is a message intercepted
 4on 20th November. It is unimportant for our purposes on
 5what day it was decoded. It was decoded 10 days. It
 6takes 10 days to decode it. The actual message is dated
 7three days later, 20th November 1941, again, dressed do
 8commander of order police and the SS in Riga, concerning
 9evacuation of Jews. The same kind of thing, transport
10train No. DO56. Has left Bremen, destination Minsk with
11971 Jews on 18th November. Escort command regular police
12Bremen, transport commander Police Meister Bockhorn,
13B-O-C-K-H-O-R-N, is in possession of two lists of names
14and 48,700 Reich Marks in cashiers' credits. Jews are
15well-provisioned with food and appliances.
16     My Lord, on the next page you will see the
17actual intercept, page 7 is what the actual intercept
18looked like. They are headed "Most Secret". It is the
19second paragraph, my Lord.
20 MR JUSTICE GRAY:     "Most secret" is put on at Bletchley, is it
21not?
22 MR IRVING:     Indeed, of course. There is no indication on the
23intercepts themselves, as intercepted here, what security
24classification they have. But I want to draw attention
25only to the word "gerat" in the fifth or sixth line of the
26intercept, which means appliances. Any German speakers in

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 1the room I am sure would agree the word "gerat" is the
 2tools of the trade, roughly, they are being sent to the
 3East with food, with provisions, and with the tools of
 4their trade.
 5 MR JUSTICE GRAY:     You have translated that as what?
 6 MR IRVING:     Appliances. It is a rough cover all, tools of the
 7trade would be a little bit too specific, I am sure
 8Mr Rampton will probably eventually object. But the sense
 9of gerat, if a cameraman comes into this room he would
10bring his gerat with him, his appliances with him.
11     The next one is No. 15, I rely on this because
12it shows in the first line, I am sorry I am still on page
136, my Lord, the second message on page 6 SS Obergruppen
14Fuhrer Jeckelm, transferred from Kiev to Riga. So that
15was the day this criminal was transferred to Riga, round
16about November 20th, and in fact it is a pretty low level
17message. They are worried about what happened to motor
18cars and things like that if I remember correctly.
19     If we can now turn straight over to page 9, my
20Lord, I took the trouble during the night to dig out of my
21files, the war diary of Hitler's headquarters, which
22I have. These are all my documents. All my documents
23when I obtained them for the book, I had bound in these
24volumes because I anticipated perhaps Mr Rampton would
25say, well, we have no proof that Hitler was in his
26headquarters, that he was at home on the day of crucial

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 1message November 30th.
 2 MR RAMPTON:     No, he would not say that, my Lord, because
 3Himmler recalls that he had lunch with Hitler on that day.
 4 MR IRVING:     Well, I am just dotting the Is and crossing the Ts.
 5 MR JUSTICE GRAY:     The point is not made, so we need not trouble
 6with that.
 7 MR IRVING:     It also talks about the arrival of the Fuhrer's
 8train that very morning. On the following day is the
 9photocopy from the page of war diary at Hitler's
10headquarters. We then come to the crucial document we
11were talking about yesterday evening, which I ...
12 MR JUSTICE GRAY:     I still have your copy of that.
13 MR IRVING:     I put it in the bundles for sake of completeness.
14It is referred to in the third conversation. I draw
15attention only to the first lines, which says: "Telephone
16conversation on November 30th 1941". The next line "Wolf
17stanche" means Wolf's Lair. The next line "ausdemzung" it
18means from the train. Himmler is still in the train going
19to Hitler's headquarters.
20     Three lines down, ausdembunker, from the bunker,
21he is at the bunker now, in the Wolf's Lair, 13.30 he
22telephones Heydrich, as we know only the third and fourth
23line of the notes are important, "Jew transport from
24Berlin, no liquidation".
25 MR JUSTICE GRAY:     Yes.
26 MR IRVING:     If I may proceed now to page 13, my Lord. This is

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 1the one that I am alleged mysteriously to have misread and
 2the implication being I deliberately misread it or
 3deliberately changed word the Gerhartens Fuhrer (?) into
 4"juden", which would be quite a feat.
 5     My Lord on the page 13 the question of the line,
 6the contentious line is third from the bottom, haben
 7zubleiben.
 8 MR JUSTICE GRAY:     Have to remain.
 9 MR IRVING:     You will notice, my Lord, the word "haben" has
10obviously been retyped, a bit of squeeze getting it in.
11It was retyped by my when I realized my error in
12transcription. That typewriter was disposed of some or
13ten or 15 years ago. That is how early I realized my
14error. I do not know if it is significant one way or the
15other, it may count against me. I do not know.
16     It is also significant to see in the following
17line, my Lord, I have written the words "truppenschuhe",
18and this is another misreading by me.
19 MR JUSTICE GRAY:     It does not really matter, does it.
20 MR IRVING:     My Lord, I am just trying to say as you will see
21from the next page, which I now ask you to turn.
22 MR JUSTICE GRAY:     Before you leave that, I thought there was
23another point made on this document, which is your
24translation of the words --
25 MR IRVING:     That is Verwallueys Fuhrer.
26 MR JUSTICE GRAY:     Am I not right about that?

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 1 MR IRVING:     This was the point Mr Rampton sought to make, and
 2I corrected him, my Lord, and said that was not the word
 3that I misread. It was the word on the following line
 4haben, which I misread as Juden, and this is why I was
 5going to ask your Lordship, respectfully, to turn to the
 6next page, page 14, where you will see the words in
 7question, three lines from the bottom on the right, that
 8is the quality of the original I was working from. I do
 9not know if your copy is highlighted, the crucial word is
10not perhaps...
11 MR JUSTICE GRAY:     Yes, it is. What did you originally
12transcribe that as?
13 MR IRVING:     Juden, I would submit this is a perfectly
14reasonable kind of mistake to make. If I was to labour
15the point I would draw your Lordship's attention to all
16the other versions of the word "Juden" that are correct,
17you will see they are very similar indeed in the German
18Gothic handwriting.
19     So what we have, my Lord, to recap at this
20point, November 30th Himmler for some reason in a
21telephone conversation with Heydrich saying that train
22load of Jews from Berlin is not to be liquidated.
23I believe that is a fair expansion of that sentence.
24     On the following day he has that telephone
25conversation with SS Gruppen Fuhrer Poll, I am back on
26page 13, at 4.45 p.m. They touch on Depervartens (?)

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 1Fuhrer, but more important now is the conversation, again,
 2with Heydrich about the same time as the previous one, on
 3the previous day, 13.15 on that page 13. He has a
 4conversation with Prague first of all about his scribes,
 5the female scribes and, secondly, "executionen", like
 6"executions", in Riga. I am sure I do not have to
 7translate that. So it is now very much in the air that
 8something has gone on in Riga, my Lord.
 9     On page 15, that same day, we are well in the
10chronology, my Lord, this is a telephone conversation at
117.15 a.m. on that Monday morning, December 1st, 1941.
12This is coming from Jeckelm to Berlin. This is a very
13ugly one indeed, my Lord. He is saying in English:
14"I need by next available air courier 10 Finnish",
15Finland, in other words, "military pistols with two drum
16magazines each. Execution of sonder aktionen", special
17actions, S-O-N-D-E-R A-K-T-I-O-A-N, "request radio
18telegramme reply. Senior SS and Police Command, North
19Russia".
20 MR JUSTICE GRAY:     Who is this addressed to in Berlin then?
21 MR IRVING:     The main leadership Hauptamt, would be the body
22concerned with the procurement of such armaments. The
23significance of this, my Lord, if you remember the
24harrowing description by General Bruns of the shootings on
25the edge of the pit where the men were using machine guns,
26tommy-guns, and he has run, he has not enough tommy-guns,

.   P-19



 1he needs more. You can see the actual intercept of that,
 2my Lord, on the next page.
 3     What is the answer he gets? Page 17, again my
 4translation my Lord, Himmler himself contacts him, either
 5in person, that is the second message, or through his
 6Adjutant, Grothmann (who is still alive in Germany now).
 7He sends this message to that same criminal, Jeckelm, at
 87.30 p.m. on December 1st: To SS Obergruppenfuhrer
 9Jeckelm, Senior SS and Police Commander, Osla, Riga.
10Reichfuhrer SS Himmler summons you to him for a conference
11on December 4th. Please state when you will arrive here
12and by what means you will be travelling". In other
13words, he had been summoned urgently to the Headquarters.
14The very next message explains what is going to happen.
15"SS Obergruppenfuhrer Jeckelm" -- this is the message we
16dealt with yesterday, my Lord -- "The Jews being outplaced
17to Osland", to the Baltic, "are to be dealt with only in
18accordance with the guidelines laid down by myself and/or
19by the ... (reading to the words) ... on my orders.
20I would punish arbitrary and disobedient acts", signed
21Himmler. A most incredibly important message, I think,
22for many reasons. He is not talking about a Hitler order
23here. He is saying: "The guidelines issued by me", by
24Himmler, "or by the Reichssicherheits Hauptamt" who is
25Heydrich", his telephone conversation partner. Jeckelm,
26out on the Eastern front, has overstepped the guidelines.

.   P-20



 1He started shooting thousands of Germans. He had been
 2summoned to Himmler's headquarters, to Rastenburg, in East
 3Prussia to account for himself.
 4 MR JUSTICE GRAY:     Where do we find the guideline?
 5 MR IRVING:     My Lord, we will hear in the course of this trial
 6that these intercepts are not wall to wall. We do not
 7have everything that they sent. There is an enormous mass
 8of trivia, people whose cars have been towed and that kind
 9of thing, people whose wives have died. Occasionally
10embedded in the trivia, like in a goldmine, in the slurry,
11there are diamonds like this.
12     The incredible thing is, although this document
13has now been in the public domain for about five or six
14years, the historians and the world have not leapt on this
15document and said,"Irving was right. This proves that the
16Fuhrer's headquarters were not only indignant, but were
17calling people to account. In the way that the wars are,
18although he is brought back from the Front and he is
19wrapped on the knuckles, he is sent back to the Front to
20carry on with his job. He is not dismissed from service;
21in rather the same way as I know General Patten, for
22example, went to the Front when General Patten had been
23liquidating prisoners. He was called before Eisenhauer
24and called to account. He was put on ice for two or three
25months and then he was given command of one of the best
26armies, the 3rd American Army, because good men are hard

.   P-21



 1to come by in a war. That is, undoubtedly, the way the
 2Nazis viewed this criminal.
 3     May I proceed, my Lord?
 4 MR JUSTICE GRAY:     Yes, thank you.
 5 MR IRVING:     We can see on page 21 the arrival of the
 6unfortunate criminal, the arrival of the unfortunate
 7criminal, SS Obbergruppenfuhrer Jeckelm in Himmler's
 8appointment book, in other words, at Hitler's
 9headquarters. One notices at 1300 they are driving over
10Hitler's headquarters. Then Himmler visits the barber and
11the dentist. He sees Hitler at 5 p.m. and at 7 p.m. he
12sees other SS Generals. At 8 p.m. he has dinner in part
13of Hitler's headquarters with Jeckelm and at 9.30 he hauls
14Jeckelm over the carpet, the Jewish question, the SS
15brigade, economic business. So that is the actual visit.
16 MR JUSTICE GRAY:     Would it be a fair interpretation of this
17document that the original plan was that Jeckelm should be
18present with Hitler and Himmler at 5 o'clock in the
19afternoon?
20 MR IRVING:     I cannot be specific on that, my Lord.
21 MR JUSTICE GRAY:     It looks like it, does it not?
22 MR IRVING:     I do not want to speculate, but these are grey
23areas. The documents do not tell us everything we would
24dearly love to know. What we do know is the final two
25pages I put in the bundle. My Lord, you will see that the
26last page has some red print on the bottom, the very last

.   P-22



 1page. This is the German, I would say, official
 2transcript of Himmler's diary which, my Lord, the
 3Defendants also have on the desk in front of them. It is
 4published this year. It is enormously expensive. It is a
 5very good and highly dependable transcription of Himmler's
 6diaries and appointment book.
 7     They put that in as a footnote at 104,
 8I believe, in which they say: "After these signals were
 9exchanged", which, oddly enough, they do not elucidate to
10the degree that I have, "the killings of German Jews
11stopped for many months". I have no further submissions
12to make about these documents.
13 MR JUSTICE GRAY:     You have lost me a little. Where do I find
14after these messages ----
15 MR IRVING:     The very last line of the red text. This is the
16comments by the editors, who are a team of German
17historians, on the Himmler diaries which they have
18annotated most expertly, and they too have drawn finally
19on these two mysterious messages that we intercepted.
20 MR JUSTICE GRAY:     But the point that may be made, I do not
21know, on this is that it is the mass shootings of German
22Jews that ceased.
23 MR IRVING:     I agree, my Lord. This is why I have been very
24careful to make a distinction in my evidence and, indeed,
25in my books.
26 MR JUSTICE GRAY:     That suggests to me -- tell me if I am wrong

.   P-23



 1about this -- that the guidelines mentioned in the earlier
 2message were guidelines relating to German Jews.
 3 MR IRVING:     This is quite possible, my Lord. I would only ask
 4you in reading, as undoubtedly you will, and re-reading
 5passages from my books on which the Defendants seek to
 6rely, you ask yourself this question, has Mr Irving, the
 7so-called Holocaust denier, at any time implied that this
 8kind of massacre did not go on, and that it was systematic
 9and it was carried out on guidelines from above?
10 MR JUSTICE GRAY:     Yes.
11 MR IRVING:     But you will notice that Mr Himmler talks about
12"orders that I have issued and the Reichssicherheits
13Hauptamt". He never says, "On the Fuhrer's instructions"
14which, obviously, there would be a strong temptation in a
15message like this to say, "You have not only upset me, but
16you have put Adolf's nose really out of joint".
17     So, I mean, obviously, I am going to submit that
18if documents like this exist of a quality like that, to
19imply that I was speaking off the wall in some way with no
20kind of documentary basis for the submissions that I make
21in my books, it would be unfair, unjust and perverse.
22 MR JUSTICE GRAY:     Yes. You have taken me through, and thank
23you for that ----
24 MR IRVING:     I ----
25 MR JUSTICE GRAY:     --- this little bundle. I am making this
26point at this stage because it is going to crop up time

.   P-24



 1and again. I am rather anxious not to have little one
 2issue bundles cropping up at odd stages because, frankly,
 3in a case of this length, it is all going to get lost and
 4tangled. I imagine that all these documents are in one or
 5other of the existing files.
 6 MR IRVING:     They are in this cover, my Lord, but not in such
 7pristine condition as that. I want to very great trouble
 8last night to prepare this particular bundle in the hope
 9that you would say to yourself, well, if he was able to
10come up with evidence like this on this matter, no doubt
11he will be able on any other matter ----
12 MR JUSTICE GRAY:     Do not misunderstand me. I am not critical.
13I think it is helpful to have a bundle prepared like this,
14but what I need to be sure of is that I know where these
15documents can be found in the existing files. What I will
16ask somebody on the Defendants' side to do, if they would
17be good enough, if they can do this, is to provide me with
18the cross-reference. Could you ask somebody to do that?
19 MR RAMPTON:     We will think about that. The trouble is at the
20moment that our files are ordered according to the
21experts' reports.
22 MR JUSTICE GRAY:     Yes, but most of these documents would be
23relatively easily traced?
24 MR RAMPTON:     Most of them, I think, are referred to in the
25expert reports anyway. Whether they are copied in quite
26that form, I am not sure; I think probably not.

.   P-25



 1 MR JUSTICE GRAY:     You see why I need to have what I am asking
 2for.
 3 MR RAMPTON:     Yes, I do. My immediate idea is just to put them
 4with a separate numeration at the back of Professor
 5Browning or that report. It is apparently ----
 6 MR JUSTICE GRAY:     I think that is not a bad idea, to put them
 7into J, otherwise there is going to be proliferation of...
 8 MR IRVING:     My Lord, I am using an alphabetical system which
 9requires that there are going to be less than 26 such
10files over the entire case that I would anticipate putting
11in of this nature. If you will bear with me, the reason
12I called this just "Himmler" is that I was intending to
13produce further documents, for example, the Schlegelberger
14series (which I am sure your Lordship is familiar with).
15I would also put that into that binder. So there will
16just be an Irving series, Irving A, Irving B, Irving C.
17This is, after all, my case, my Lord, and I do not want my
18structure to be subsumed into the case for the Defendants.
19 MR JUSTICE GRAY:     I entirely agree with that. This may all
20seem very boring, but, believe me, in a case like this you
21----
22 MR IRVING:     "Boring" is not a word I would use.
23 MR JUSTICE GRAY:     --- really do have to watch the sort of
24housekeeping. Just so that everybody knows where I have
25it, I am putting it into J.
26 MR RAMPTON:     Tab C.

.   P-26



 1 MR JUSTICE GRAY:     I have not got a tab C.
 2 MR IRVING:     My Lord, I would propose that we now continue where
 3we left off last night.
 4 MR JUSTICE GRAY:     I am going to treat what you have told me in
 5the last 20 minutes or so as being part of your evidence,
 6although you told me from counsel's bench. It is up to
 7you; I think you probably ought to go back, if you would
 8be good enough, into the witness box.
 9     Cross-examined by MR RAMPTON, QC, continued.
10 THE WITNESS:     My Lord, there is just one other document there
11that I forgot to refer to and this is No. 23. I will just
12read it out to you. There is no need for your Lordship to
13see it.
14 MR JUSTICE GRAY:     I had better follow it.
15 A. [Mr Irving]     A telephone conversation of exactly the same kind from
16Himmler's telephone log: On Hitler's birthday, at midday
17with Heydrich, again that is H-E-Y-D-I-C-H, a
18conversation with Heydrich in which the last line reads:
19"Kindly", "Keine vernichtungd. Zigeuner", K-E-I-N-E
20V-E-R-N-I-C-H-T-U-N-G-D. Z-I-G-E-U-N-E-R.
21 Q. [Mr Justice Gray]     That is "gypsies", is it not?
22 A. [Mr Irving]     That is right, my Lord.
23 Q. [Mr Rampton]     How would you translate "vernichtungd"?
24 A. [Mr Irving]     Literally "destruction" and that is how I will leave it.
25"No destruction of the gypsies"; the significance being
26that on this day at mid-day, Himmler is with Hitler

.   P-27



 1celebrating a birthday party. It was Hitler's birthday,
 2April 20th. Once again he has had to telephone his chief
 3executioner, so to speak, Heydrich, and say, "The gypsies
 4are not to be liquidated" and yet they were liquidated.
 5 Q. [Mr Rampton]     You say Himmler was with Hitler at 12 o'clock?
 6 A. [Mr Irving]     Quite definitely. It was Hitler's birthday and I would be
 7happy to lead evidence to prove that, but I am sure
 8Mr Rampton will not dispute that the head of the SS ----
 9 Q. [Mr Rampton]     And this is a phone call to Heydrich from Himmler?
10 A. [Mr Irving]     It is a telephone conversation between them.
11 Q. [Mr Rampton]     Yes, I take that point.
12 A. [Mr Irving]     Of significance, it is one more document in that chain
13that I occasionally refer to.
14 MR JUSTICE GRAY:     Thank you.
15 MR RAMPTON:     Yes, as to that, Mr Irving, the "no liquidation of
16the gypsies", again that was before there was any meeting
17between them, was it not, on that day, which is 20th April
181942, Himmler's log said that he met Fuhrer at 12.30?
19 A. [Mr Irving]     This may well be. It may well be what his log says.
20 Q. [Mr Rampton]     Whereas the telephone call is at noon, I think.
21 A. [Mr Irving]     Yes.
22 Q. [Mr Rampton]     Rather like 30th November?
23 A. [Mr Irving]     Yes.
24 Q. [Mr Rampton]     1941?
25 A. [Mr Irving]     Yes.
26 Q. [Mr Rampton]     Can we go back to 30th November 1941, please? Did you get

.   P-28



 1a transcript of your evidence of the proceedings
 2yesterday -- have you got a copy that looks like this,
 3Mr Irving?
 4 A. [Mr Irving]     Yes I have.
 5 Q. [Mr Rampton]     With a quarter page like that?
 6 A. [Mr Irving]     Yes.
 7 Q. [Mr Rampton]     Could you turn, please, to the page numbered 289? It is
 8the top left-hand block on one of the pages.
 9 A. [Mr Irving]     Yes.
10 Q. [Mr Rampton]     I was asking you if you remember why it was that you had
11translated "Judentransport", a singular word, as Jews in
12general?
13 A. [Mr Irving]     Yes.
14 Q. [Mr Rampton]     You had said, you can see it there, can you not, that it
15was a silly misreading of the word. You said at line 19:
16"I admit I made a mistake in the transcription"?
17 A. [Mr Irving]     Yes.
18 Q. [Mr Rampton]     This was your sworn evidence on oath yesterday?
19 A. [Mr Irving]     Yes.
20 Q. [Mr Rampton]     Now would you please turn to the first page of your new
21bundle?
22 A. [Mr Irving]     Yes.
23 Q. [Mr Rampton]     The translation you have made for us kindly ----
24 A. [Mr Irving]     Yes.
25 Q. [Mr Rampton]     --- 23rd January 1974, where you have transcribed it
26correctly?

.   P-29



 1 A. [Mr Irving]     Yes.
 2 Q. [Mr Rampton]     The answer you gave yesterday was wrong, was it not?
 3 A. [Mr Irving]     That is correct.
 4 Q. [Mr Rampton]     Why was it wrong, Mr Irving?
 5 A. [Mr Irving]     Because we are talking about events almost 30 years ago.
 6I was writing this book 32 years ago. I received these
 7documents 35 years ago. I probably transcribed it, as you
 8can see from the letter, round about 1974. It is very
 9difficult to put myself back into my mind set of 25 or 26
10years ago.
11     You asked me what the reason for that was and
12my first presumption was that I misread the word, but ably
13challenged by his Lordship, questioned by his Lordship, on
14this matter, I recalled also that at the time I looked at
15it, the word "transport", "Judentransport", to me also
16could be translated as "transportation of Jews". Indeed,
17it can be translated that way and I refined it later on
18when I was informed by Dr Flemming, as he then was, who is
19an expert on the Holocaust, that there was one very clear
20train load of Jews to which reference was being made.
21That is so, I think, an accurate answer which should
22really replace yesterday's answer.
23 Q. [Mr Rampton]     I dare say it should, Mr Irving. Whether I accept it, of
24course, is quite another question, even in its remodelled
25form.
26 A. [Mr Irving]     Yes.

.   P-30



 1 Q. [Mr Rampton]     The answer is, of course, that I do not. Mr Irving,
 2I would like you to think a little bit about what you have
 3just said. You heard me open this case on Tuesday
 4afternoon, did you not?
 5 A. [Mr Irving]     Yes.
 6 Q. [Mr Rampton]     Yes. You have to say "yes" just for the recording. That
 7is all. Nodding or so will not do. You had a copy of the
 8written document that I read out, did you not?
 9 A. [Mr Irving]     Which document are you referring to?
10 Q. [Mr Rampton]     My opening statement in this case?
11 A. [Mr Irving]     Yes.
12 Q. [Mr Rampton]     That was on Tuesday afternoon.
13 A. [Mr Irving]     Yes.
14 Q. [Mr Rampton]     You realized then ----
15 A. [Mr Irving]     Yes.
16 Q. [Mr Rampton]     --- that this is one of the points that I was going to
17make against you, did you not?
18 A. [Mr Irving]     Yes, that has been repeatedly made, yes.
19 Q. [Mr Rampton]     It has been repeatedly made, has it not? Yet, when you
20come into the witness box to answer questions on oath, you
21simply pluck an explanation out of the air, do you not?
22 A. [Mr Irving]     Mr Rampton, may I explain to you that in the last four
23days I have had six hours sleep? Is this a satisfactory
24answer to why one occasionally makes slips of the memory
25in the witness box? If not, then I will go into it in
26greater detail.

.   P-31



 1 Q. [Mr Rampton]     What is the truth, Mr Irving? You did not misread it,
 2that is clear.
 3 A. [Mr Irving]     Yes -- not this particular word.
 4 Q. [Mr Rampton]     No. So yesterday's answer was a false answer.
 5 A. [Mr Irving]     Misinterpreted.
 6 Q. [Mr Rampton]     You now say, "Well, I may have mistranslated it, but my
 7translation was, on the face of it, legitimate"?
 8 A. [Mr Irving]     Well, in this case it is not a translation that is needed,
 9it is an interpretation because it is a cryptic word.
10"Transport" can mean several different things. There are
11many words that can mean several different things, and you
12have to look at the context and you have to take other
13documents and possibly later information into account in
14arriving at which of those words is the correct
15translation. None of the words would be a wrong
16translation at the time you first make it. You then
17refine the translation on the basis of external evidence.
18 Q. [Mr Rampton]     Would not a more natural way of putting it in German to be
19to put it in the plural "Judentransporte" with an "e" on
20the end?
21 A. [Mr Irving]     It can also be done that way, yes.
22 MR JUSTICE GRAY:     Would part of the context be that there did
23happen at this time to be a train load of Jews setting out
24from Berlin to Riga?
25 A. [Mr Irving]     There were many train loads sitting out. By this time, by
26November 30th, there had been five trainloads of Jews

.   P-32



 1heading for Riga or Minsk.
 2 Q. [Mr Justice Gray]     Over what sort of period?
 3 A. [Mr Irving]     One week, round about that time -- no, I am sorry, two
 4weeks would be a closer approximation. They were given
 5numbers, "D" for Germany, "O" for East or German, rather,
 6and "O" for East. That is what the numbers in the
 7intercepts are.
 8 MR RAMPTON:     Mr Irving, another of the things that you and
 9I disagreed about yesterday was your unequivocal
10categorical assertion in your various publications that
11that order from Himmler to Heydrich on that day was given
12at the instigation of Hitler. You say it was, or at least
13that is a reasonable inference; you called it a "judgment
14call", I think, did you not?
15 A. [Mr Irving]     I called that, the reason I used it, or referred to it in
16that -- I think we ought to see the actual wording
17I used. If you say that I said it on a number of
18occasions, it would be helpful to see the actual wording
19that I used.
20 Q. [Mr Rampton]     For example, let us just look at how you put it in
21"Hitler's War 1991". My Lord, that is bundle D1(v). It
22is in two halves. This is the second half. At page 427,
23Mr Irving, if you are using the published edition?
24 A. [Mr Irving]     I am just looking at the 1977 one to pre-empt you.
25 Q. [Mr Rampton]     We will look at that first, if you will. I think there it
26is round about 300 and something.

.   P-33



 1 A. [Mr Irving]     At 1.30 p.m.
 2 Q. [Mr Rampton]     Well, his Lordship may not have it.
 3 MR JUSTICE GRAY:     Yes, I have.
 4 MR RAMPTON:     Have you got 1977, my Lord? 332.
 5 A. [Mr Irving]     Yes. I think, with respect, it makes more sense to take
 6it from the chronology that I wrote the various editions.
 7 Q. [Mr Rampton]     I was not actually going to look at all the references,
 8but if you wish me to do so, I do not mind in the
 9slightest.
10 A. [Mr Irving]     Well, it is like a building, the way a building changes
11over the years, that tells us something also.
12 Q. [Mr Rampton]     "Himmler's personal role is ambivalent. On November 30th
131941, he was summoned to the Wolf's Lair for a secret
14conference with Hitler in which the fate of Berlin's Jews
15was clearly raised". Pause there. What evidence that
16Himmler was summoned to the Wolfsschanze the Wolf's Lair?
17 A. [Mr Irving]     My very great expertise on this matter.
18 Q. [Mr Rampton]     What?
19 A. [Mr Irving]     My very great expertise on this matter. Do you wish me to
20elaborate?
21 MR JUSTICE GRAY:     Yes, I think you had better; I am not quite
22sure I understand the answer.
23 MR RAMPTON:     I asked for evidence, not expertise.
24 A. [Mr Irving]     Well, the evidence is that if you go to the archives and
25work through the files of Hitler's Chancellory, you will
26find every year, two or three times, the head of his

.   P-34



 1Chancellory, Hans Lammers, issued an edict to all the
 2Reich ministers and all the senior Nazi officials
 3informing them that nobody was permitted to visit Hitler,
 4just ringing the door bell and saying, "Mein Fuhrer, can
 5I drop in and see you for a moment?" They had to have a
 6specific summons and invitation because Hitler was
 7constantly being beseiged by junior and senior officials
 8who were ringing his doorbell in that way and asking to
 9see him. Eventually, it had to be forbidden, first of all,
10by Lammers and then by an edit of Martin Bormann. So you
11could not visit Hitler unless you were summoned.
12 Q. [Mr Rampton]     Mr Irving, I am not going away from that topic, believe
13me, I am not, but it may be we had better get this sorted
14out earlier rather than later in this case. Where do you
15place Himmler in the Nazi hierarchy?
16 A. [Mr Irving]     Nowhere in the hierarchy that it would just turn up on
17Hitler's doorstep.
18 Q. [Mr Rampton]     Please, we will come to that I promise I not leaving the
19topic, where do you put him?
20 A. [Mr Irving]     He had the rank of a Reichsminister, the rank of
21Reischminister was equivalent to a field marshal, so it
22would be the equivalent rank of four star general. He had
23Hitler's ear, he took orders directly from Hitler, there
24was no intermediary, is that sufficient?
25 Q. [Mr Rampton]     -- yes, I am going to go a little bit further. This is
26not hostile interrogation, Mr Irving, this is an attempt

.   P-35



 1to see if we can agree on some broad general facts which
 2may be of use in this case. Himmler was, was he not, one
 3of the original putschists of 1923?
 4 A. [Mr Irving]     He is there to be seen marching in the ranks.
 5 Q. [Mr Rampton]     Wearing Nazi uniform.
 6 A. [Mr Irving]     One of the old guard.
 7 Q. [Mr Rampton]     Have you read Ian Kershaw's book?
 8 A. [Mr Irving]     Whose?
 9 Q. [Mr Rampton]     Ian Kershaw's book?
10 A. [Mr Irving]     I do not read books.
11 Q. [Mr Rampton]     You do not read books. Of course not. He is one of old
12guard, is he not?
13 A. [Mr Irving]     Yes.
14 Q. [Mr Rampton]     So was Goring?
15 A. [Mr Irving]     Yes.
16 Q. [Mr Rampton]     And so was Goebbels?
17 A. [Mr Irving]     On and off, if you see what I mean.
18 Q. [Mr Rampton]     Yes, I do see what you mean. Is there anything which
19leads you to suppose --
20 A. [Mr Irving]     In connection with Goebbels, of course, he was not one of
21the putschists, he came in several years later.
22 Q. [Mr Rampton]     -- Rosenberg was perhaps, I do not know. Is there
23anything you know of that prevents one from supposing that
24Hitler might have telephoned as he apparently was able to
25use the telephone on the train, was he not?
26 A. [Mr Irving]     Himmler, you are talking about?

.   P-36



 1 Q. [Mr Rampton]     Himmler I mean, telephoned the Wolf's Lair and said "can
 2I come and talk to you about something"?
 3 A. [Mr Irving]     No reason to suppose that at all, yes.
 4 Q. [Mr Rampton]     So why you do use the word "summon"?
 5 A. [Mr Irving]     Because then Hitler would have said "all right, come and
 6see me".
 7 Q. [Mr Rampton]     You see in the context, do you agree, the word "summoned"?
 8 A. [Mr Irving]     Yes.
 9 Q. [Mr Rampton]     Means that he is being summoned in order to discuss the
10fate of the Berlin Jews?
11 A. [Mr Irving]     In the context.
12 Q. [Mr Rampton]     Yes. Amongst other things, perhaps?
13 A. [Mr Irving]     No, I disagree with you Mr Rampton, on November 30th, he,
14Himmler was summoned to the Wolf's Lair for a secret
15conference with Hitler at which the fate of Berlin's Jews
16was clearly raised.
17 Q. [Mr Rampton]     By whom?
18 A. [Mr Irving]     We do not know.
19 Q. [Mr Rampton]     Then you go on, at 1.30 p.m. Himmler was obliged to
20telephone from Hitler's bunker?
21 A. [Mr Irving]     Yes.
22 Q. [Mr Rampton]     Who could have obliged, that is to say compel, Himmler to
23do such a thing?
24 A. [Mr Irving]     His own inner conscience.
25 Q. [Mr Rampton]     That is what it was, was it?
26 A. [Mr Irving]     That is why I used word "obliged" otherwise I would have

.   P-37



 1said "ordered".
 2 MR JUSTICE GRAY:     The reality of the way, would you not
 3accept, Mr Irving, of the way it is put in your book is
 4that the reader is going to infer that that was an order
 5from Hitler to him?
 6 A. [Mr Irving]     My Lord, I use my words with utmost care when I write
 7passages like that. I will go backwards and forwards over
 8them looking for a word which I considered to be justified
 9by the evidence but not implying or imputing or inferring
10too much. If I used the word "obliged" then it was
11because I hesitated to use the word "order" but for some
12reason he made the telephone conversation. He did not
13wait until he got back to his own headquarters, he
14immediately phoned Heydrich from Hitler's bunker without
15even getting over to the local phone box, he phoned
16Heydrich with these instructions saying "stop the
17killing".
18 MR RAMPTON:     That is what you intended to convey in that
19passage of that page of Hitler's War 1977?
20 A. [Mr Irving]     That is all that I felt it was safe to convey on the basis
21of the very skimpy evidence I had at that time. At that
22time, of course, I did not even have the decodes, but now
23the decodes confirm me.
24 Q. [Mr Rampton]     So you say. Let us turn to page (xiv) of the introduction
25to this book, may we?
26 A. [Mr Irving]     Yes.

.   P-38



 1 Q. [Mr Rampton]     Perhaps for completeness start at the bottom of page
 213: "Many people, particularly in Germany and Austria had
 3an interest in propagating the accepted version of the
 4order of one mad man originated the entire massacre." We
 5are talking here about Holocaust in the old sense, old, in
 6the Irving history.
 7 MR JUSTICE GRAY:     I am so sorry, Mr Rampton, I am lost, page
 813.
 9 MR RAMPTON:     (Xiii) of the introduction.
10 MR JUSTICE GRAY:     Thank you.
11 MR RAMPTON:     I will start again. Last two lines bottom of page
1213: "Many people, particularly in Germany and Austria had
13an interest in propagating the accepted version that the
14order of one mad man originated the entire massacre." That
15is to say the massacre of the Jews, those are my words, my
16Lord. "Precisely when the order was given in what form
17has admittedly never been established. In 1939? But the
18secret extermination did not begin operating until
19December 1941. At the January 1942 Bunzig conference?
20But the incontrovertible evidence is", note those words,
21Mr Irving, in the light of your recent answers, "the
22incontrovertible evidence is that Hitler ordered on
23November 30th 1941 that there was to be 'no liquidation'
24of the Jews (without much difficulty I found in Himmler's
25private files his own handwritten note on this)." In the
26light of that, Mr Irving, would you care to revise the

.   P-39



 1answers you gave a moment ago?
 2 A. [Mr Irving]     No.
 3 Q. [Mr Rampton]     Well, what do those words mean? Do they speak for
 4themselves or do they not, that I have just read?
 5 A. [Mr Irving]     I have done exactly what any normal editor would do, you
 6present the evidence and then you draw conclusions.
 7I present the evidence in the body of the book. I even in
 8this one case print a facsimile of the document which is
 9pivotal to this particular argument and then in the
10introduction (as a good author should) I put my principal
11conclusions. Here I am putting my principal conclusion as
12the author, David Irving, that I draw the conclusion from
13this episode that Hitler had intervened to stop -- and
14here is the error, the liquidation of the Jews. What
15I should have written is "the liquidation of a transport
16of Jews". That was the state of my knowledge at the time
17I wrote this version of this book. Subsequently of course
18I amended it.
19 Q. [Mr Rampton]     I think you told me yesterday that the only evidence you
20had for the order of Hitler was that Himmler was there at
21the time?
22 A. [Mr Irving]     The only evidence that I had for an order of Hitler?
23 Q. [Mr Rampton]     Yes, was that Himmler was at the Wolfsschanze at the time?
24 A. [Mr Irving]     I think we would have to see exactly what I testified
25before I would agree to that brief summary.
26 MR JUSTICE GRAY:     I think it is right, but if you want to be

.   P-40



 1referred to it then no doubt you should be.
 2 MR RAMPTON:     A summary?
 3 A. [Mr Irving]     I hate to agree with vulgarised versions of what I
 4testified.
 5 MR JUSTICE GRAY:     Let us have a look and see what you did say.
 6 MR RAMPTON:     My Lord, one could start at line 20 on page 285
 7perhaps?
 8 A. [Mr Irving]     285?
 9 Q. [Mr Rampton]     285, line 20, I am trying not to take too much of it.
10I suppose it really begins at line five on page 285, but
11I hope I summarized it fairly?
12 A. [Mr Irving]     I do not think you did, but I will certainly stand by what
13I stated on those two pages.
14 MR JUSTICE GRAY:     Look at line 286, line 3 and onwards.
15 MR RAMPTON:     Yes, please.
16 A. [Mr Irving]     This is the question, of course, and not the answer.
17 MR JUSTICE GRAY:     Yes, but there is an answer after the
18question.
19 MR RAMPTON:     At line nine there is an answer.
20 A. [Mr Irving]     Yes.
21 Q. [Mr Rampton]     My summary was a fair one. There is no evidence beyond
22the fact that Himmler was at the bunker that day and had
23lunch with Hitler an hour later, is there?
24 A. [Mr Irving]     Evidence for what?
25 Q. [Mr Rampton]     For an order from Hitler that Jews -- that the train load
26of Jews, let us stick with that for the moment?

.   P-41



 1 A. [Mr Irving]     This is --
 2 Q. [Mr Rampton]     Should be not liquidated?
 3 A. [Mr Irving]     -- I do not mean this offensively, but this is the common
 4sense interpretation of the evidence lying before us,
 5rather the perverse interpretation. We will always has
 6versions or two interpretations, one is the obvious one,
 7which is -- and the other is the perverse one. The
 8obvious one is if Himmler goes to Hitler's headquarters
 9and is handed a phone at some time on his way out and he
10then has to make phone call to Heydrich saying, "stop
11killing the Berlin Jews", then there is some close
12connection between that and the fact he has seen Hitler
13that day.
14 Q. [Mr Rampton]     That is a possible interpretation, we in this court, and
15I do not know about the court of history, we in this court
16when we say "evidence" we mean "evidence" not "inference".
17 A. [Mr Irving]     The issues that are being pleaded are mistranslation, or
18distortion, deliberately mistranslation, distortion,
19manipulation and I do not think that the particular avenue
20we are going down leads in the --
21 Q. [Mr Rampton]     I will put it bluntly to you and then I will leave it, you
22can deny it, because you will deny it, I am sure; (a) you
23deliberately mistranslated it, you inflated from one train
24load into Jews generally, that is number one; and (b) you
25inserted an order from Hitler for which there was no
26evidence?

.   P-42



 1 A. [Mr Irving]     -- I will take those two allegations seriatim; that
 2I inflated it deliberately, there is not a shred of
 3evidence for that. The evidence is quite clear, that as
 4soon as Dr General Flemming brought to me the evidence
 5there was one train load of Jews which was in trouble that
 6day, I immediately and in subsequent editions of the book
 7revised it to the narrow interpretation of the word
 8"transport" rather than the wider interpretation.
 9 Q. [Mr Rampton]     And you are sticking with the Hitler order answer?
10 A. [Mr Irving]     As being the reasonable rather than perverse analysis of
11the documents at that time before us. I emphasise of
12course it has now been very amply confirmed by the
13intercepts I read out in my bundle this morning.
14 Q. [Mr Rampton]     Very well, then, we must look at another document. This
15is one of your documents?
16 MR JUSTICE GRAY:     Before you do can I ask one rather mundane
17question.
18 MR RAMPTON:     Yes, of course.
19 MR JUSTICE GRAY:     But I think you will understand why I ask it,
20Hitler's headquarters or the Wolf's Lair, how big a
21building or collection of buildings was that?
22 A. [Mr Irving]     At that time it was not a big formidable complex which
23exists today, huge concrete bunkers. There were one or two
24air raid shelters, but it was mostly in the form of wooden
25barracks scattered around in a compound of a 2 or 3
26kilometres area with minefields and forests.

.   P-43



 1 Q. [Mr Justice Gray]     How many people would work there?
 2 A. [Mr Irving]     Probably in the order of one thousand people including all
 3the escorts and security. It had various inner areas and
 4so called "sperrkreise", which were the security zones and
 5he was in security zone A. But if it is ausdembunker,
 6from the bunker, then it is from Hitler's bunker.
 7 MR JUSTICE GRAY:     By which you mean an office or --
 8 A. [Mr Irving]     No, Hitler --
 9 Q. [Mr Justice Gray]     -- a part of the compound where Hitler was himself based?
10 A. [Mr Irving]     -- in the security zone A there was the bunker in which
11Hitler resided, lived and conducted his conferences.
12Later on it was massively reinforced after the Allied air
13raids started.
14 MR RAMPTON:     This is all on the same topic, Mr Irving, so that
15the document you are will next need is to be found in
16bundle D8(iii), somebody will give it to you (same
17handed).
18 A. [Mr Irving]     Very well.
19 Q. [Mr Rampton]     The page I want is 1042.
20 A. [Mr Irving]     Yes.
21 Q. [Mr Rampton]     At the same time could I give you and his Lordship --
22I have composed a page of the reprinted Himmler logs for
23Sunday 30th November 1941 and Monday 1st December 1941,
24I have taken from that Witte book. I have taken out the
25footnotes because I wanted the text. I wanted the text to
26appear unvarnished. First of all would like you to look

.   P-44



 1at the page in D8(iii) page in D8(iii), 1042. This is
 2taken from your website; do you recognize it?
 3 A. [Mr Irving]     Yes.
 4 Q. [Mr Rampton]     You do, Mr Irving. At the bottom of the page the last
 5entry starts: Meanwhile another page from the Himmler file
 6in the Moscow archives obtained by David Irving on Sunday
 7May 17th 1998, reveals the Reischsfuhrer's appointments
 8for November 30th 1941, see above. The day of the
 9telephone call with Heydrich".
10     Turn over now to page 1043.
11     "This suggests that Mr Irving's original theory
12that Himmler discussed the matter with Hitler before
13phoning Heydrich is wrong. Himmler saw SS Sturmbannfuhrer
14Gunther d'Alquen, a journalist, from 12 to 1 p.m.
15(Reisebericht uber SS Pol Division [that is short for
16politzei] u. [that is an abbreviated U stop]
17Totenkopfdivision) then worked for an hour
18('gearbeitet') during which he made the phone call,
19received General Dietl from 2 to 2.30 p.m." I will not
20bother to read the next bit.
21     "And only then, at 2.30 p.m., went for lunch
22until 4 p.m. with Hitler ('Mittagessen b. Fuhrer') that is
23short for bei, yes ?
24 A. [Mr Irving]     Yes.
25 Q. [Mr Rampton]     That is your account, must postdate the 17th May 1998,
26must it not? According to that entry anyway it does, if

.   P-45



 1you look at the first page?
 2 A. [Mr Irving]     Yes. I did not understand the question, last question, it
 3was what?
 4 Q. [Mr Rampton]     Well, if you say that you arrive at this conclusion in
 5consequence of the discovery of a Himmler, a file page on
 617th May 1998, this, what shall we say, "confession" must
 7postdate that, must it not?
 8 A. [Mr Irving]     Perhaps I should explain to his Lordship, if your Lordship
 9is wondering why it is written in the third person. This
10is a page.
11 MR JUSTICE GRAY:     I do not think that matters at all.
12 A. [Mr Irving]     No, right. But in other words I wrote that. This is what
13is important.
14 Q. [Mr Justice Gray]     I follow you wrote it.
15 MR RAMPTON:     I had assumed you wrote that. This is why I called
16it a confession.
17 A. [Mr Irving]     Confession implies that something is wrong.
18 MR JUSTICE GRAY:     Put the substance, Mr Rampton.
19 MR RAMPTON:     It is quite inconsistent with the version you have
20been giving us in this court?
21 A. [Mr Irving]     It is absolutely consistent with my methods as an
22historian as saying here is one version, but the audience
23should know there is an alternative version. This is
24absolutely consistent with -- you remember how I sent that
25letter to The Times in 1966 saying there are other figures
26on Dresden and it is right that the public knows this.

.   P-46



 1I know it is unusual for historians to do this, but I do
 2that kind of thing.
 3 Q. [Mr Rampton]     But you did not say, but on reflection I think this
 4suggestion that I was mistaken is probably wrong, and
 5I adhere to my original thesis that it was a Hitler order?
 6 A. [Mr Irving]     I draw attention to the first two words on page 1043 "this
 7suggests".
 8 Q. [Mr Rampton]     I know that?
 9 A. [Mr Irving]     It does not say "this confirms" or "proves".
10 MR JUSTICE GRAY:     But to be blunt about it, Mr Irving, what
11I think is the suggestion made on the basis of your
12website entry is that it was because a journalist tipped
13off Himmler what had been going on that the message went
14out to Riga; have I understood it correctly?
15 A. [Mr Irving]     I think I would be reading very much between the lines, my
16Lord.
17 Q. [Mr Justice Gray]     That is what you are saying here, is it not, Mr Irving?
18 A. [Mr Irving]     No, not at all. I am saying exactly what happened. What
19his timetable was.
20 MR RAMPTON:     Mr Irving, the position is this, you quite
21properly in this website entry recognize the possibility,
22I would say the probability, it does not matter, that your
23original thesis, that it was an order from Hitler was
24wrong, do you not?
25 A. [Mr Irving]     Well, you say "probability" and "possibility"; I would say
26what I am saying here is it is important that the learned

.   P-47



 1public, academics and others who are accessing this
 2website realize there are documents which indicate a
 3discrepancies in The Times. However, we should not lay
 4every word on the gold balance, as the Germans say,
 5because it is quite possible and indeed highly probable
 6that as soon as Himmler arrived at Hitler's headquarters
 7he did not go and have a shower or something, he went
 8straight in to see the boss, and said "boss I am here,
 9what time shall I come past" and the boss said "oh by the
10way Heydrich I will have to tear a strip off you because
11of what is happening at the Eastern Front".
12 Q. [Mr Rampton]     Mr Irving, who reads these books of yours? Do not take
13that as a suggestion that nobody does, at all, I do not
14mean that, but who are they aimed at?
15 A. [Mr Irving]     How would I know.
16 Q. [Mr Rampton]     Who do you write your books for? When are you writing a
17book, if I write something to my wife I do not use the
18kind of pompous language I use in court, I hope. So you
19know, you have an audience?
20 A. [Mr Irving]     Obviously, I am trying to write for as wide an audience as
21possible so that it is both learned enough for the
22academics to use as a source book, in the case of the
23Goebbels biography but also entertaining enough for the
24general public to look at and read from end to end without
25putting it down at the end of a chapter.
26 Q. [Mr Rampton]     Exactly. It is meant to be readable and it is also

.   P-48



 1scholarly and authoritative, is it not?
 2 A. [Mr Irving]     Yes.
 3 Q. [Mr Rampton]     All three of those things. Do you not think, Mr Irving,
 4that the respectable approach to this problem of the
 5Himmler telephone call, for problem it is, historically?
 6 A. [Mr Irving]     Yes.
 7 Q. [Mr Rampton]     Would have been to put both possible "theories", as you
 8call them, in this website into your book?
 9 A. [Mr Irving]     Well, here you have another time discrepancy, Mr Rampton,
10because the book was delivered to the publishers in 1995,
11and this Moscow diary came to my hands in 1998, three
12years, so it would have been quite a feat of imagination
13to imagine what was in the archives and I had not at that
14time seen.
15 Q. [Mr Rampton]     No, but you had assumed without more, had you not?
16 A. [Mr Irving]     This is not the point you were just trying to make, you
17were trying to imply I concealed what I knew, which would
18fall within the grounds of manipulation and
19mistranslation.
20 Q. [Mr Rampton]     What I put to you is this, that you inserted an order from
21Hitler without evidence?
22 A. [Mr Irving]     I inferred an order from Hitler with very strong evidence.
23 Q. [Mr Rampton]     You state it as a categorical fact?
24 A. [Mr Irving]     In my introduction to the book, yes, I draw conclusions.
25 Q. [Mr Rampton]     And also in the text, if I may say so.
26 A. [Mr Irving]     No, in the text I state exactly what the documents say.

.   P-49



 1 Q. [Mr Rampton]     And you mistranscribe the word Judentransport so as to
 2make Hitler appear the more merciful because that is what
 3it is about?
 4 A. [Mr Irving]     No, I applied the wider interpretation of the "transport"
 5rather than the narrow interpretation, which one could
 6subsequently apply once one knew more about the history of
 7that particular train load.
 8 Q. [Mr Rampton]     You do not agree now that you have been caught out by the
 9full entry in the Hitler log?
10 A. [Mr Irving]     Mr Rampton, historians are constantly being caught out by
11fresh documents that come into their purview and one is --
12I am personally very satisfied how infrequently I am
13caught out. I the entire Goebbels biography initially,
14for example, without access to the diaries in Moscow.
15I was pleased to find out how much I managed to work out
16correctly from secondary sources. So it is with
17particular episode, the decodes only came into our
18possession within the last four or five years and yet they
19confirmed exactly what I inferred 20 years, 25 years ago.
20I do not think it is a question of being caught out. If
21one revises and updates information it is not because one
22has been caught out, with all pejorative implications.
23 Q. [Mr Rampton]     I am afraid they are pejorative. I would like to know why
24you say that the decodes (we will go it now, I will come
25back to where I was in a moment) why the decodes confirm
26your account?

.   P-50



 1 A. [Mr Irving]     I think I have gone through the little bundle this morning
 2in some detail, I am glad I did.
 3 Q. [Mr Rampton]     You show me the decode, I suppose mean the one on page 17?
 4 A. [Mr Irving]     December 1st.
 5 MR JUSTICE GRAY:     Mr Rampton, you are moving to a slightly
 6different topic, may I ask one more question?
 7 MR RAMPTON:     Yes.
 8 MR JUSTICE GRAY:     It is back to your website, looking at it
 9now, forget what you have written in the past, but looking
10at it now, it is obvious that there was some sort of
11discussion or meeting between Himmler and the journalists;
12is that not right?
13 A. [Mr Irving]     My Lord, I regard this meeting between Himmler and the
14journalist as being a matter of very low priority, I just
15put it in purely because it shows what he was doing that
16morning. It never occurred to me that Gunther d'Alquen
17who is in fact still alive, I believe -- no, he died three
18or four months ago in fact, that he would brought to
19Himmler any kind of serious information about was going
20on. I have never heard that implied or inferred.
21D'Alquen has been questioned on very many occasions, both
22by the courts and by journalists, and I am sure that that
23kind of information would have come into my possession, if
24it had had I would have immediately used it.
25 Q. [Mr Justice Gray]     The entry does suggest that this journalist did have some
26news to give to Himmler, does it not?

.   P-51



 1 A. [Mr Irving]     I shall go straight home and change the wording of the
 2entry, my Lord, because was that not what I intended as
 3the author of this passage.
 4 Q. [Mr Justice Gray]     What is Reisebericht?
 5 A. [Mr Irving]     It is a travel report. He has been travelling around,
 6presumably on the Eastern Front and he comes back to
 7Himmler. He reports back to Himmler, tells him what he
 8has seen, when he visited the SS police divisions and
 9whatever --
10 Q. [Mr Justice Gray]     How would you translate Totenkopfdivision?
11 A. [Mr Irving]     -- Death's Head Division, which is a division on the
12Eastern Front which was not connected, as I understand it,
13with the killing operations, it was actually operating on
14the Eastern Front. I am prepared to be corrected on this
15but I believe that the Death's Head Division was one of
16the elite SS divisions which was fighting on the Eastern
17Front at Moscow at this time of course in severe
18difficulties.
19 Q. [Mr Justice Gray]     Yes, thank you very much. I am sorry, Mr Rampton.
20 MR RAMPTON:     It is of no matter, my Lord.
21 THE WITNESS:     I would be very willing to write material in
22between the lines here if I thought it assisted the
23evidence that on this particular case, on the balance of
24probabilities beyond putting the name in, that is all one
25can safely do. But your Lordship will notice that I do
26not hesitate to publicise information which is possibly

.   P-52



 1hostile to my own interests.
 2 MR JUSTICE GRAY:     I see that.
 3 MR RAMPTON:     The original of I imagine the two documents that
 4you are talking about when you are talking about the -- is
 5on page 20 of your little bundle; do you have the little
 6bundle there?
 7 A. [Mr Irving]     Yes.
 8 Q. [Mr Rampton]     Items 24 and 25; is that right?
 9 A. [Mr Irving]     24 and?
10 Q. [Mr Rampton]     25, items 24 and 25 on page 20?
11 A. [Mr Irving]     Is this April 20th, you are talking about?
12 Q. [Mr Rampton]     No, I am sorry, this is the summons to Jeckeln?
13 A. [Mr Irving]     Would you give me the page number.
14 Q. [Mr Rampton]     Page 20.
15 A. [Mr Irving]     Yes.
16 Q. [Mr Rampton]     Items 24 and 25.
17 A. [Mr Irving]     I see, this is actual the intercepts.
18 Q. [Mr Rampton]     Yes, we go back to page 17 for the English.
19 A. [Mr Irving]     Yes.
20 Q. [Mr Rampton]     It is quite clear, is it not, I mean I agree with you,
21that Himmler was very cross with Jeckeln for what had
22happened?
23 A. [Mr Irving]     For overstepping the guidelines.
24 Q. [Mr Rampton]     Sure. We do not know what guidelines are you tell us?
25 A. [Mr Irving]     I do not know what the guidelines are, no.
26 Q. [Mr Rampton]     It is common ground for once between you and me and the

.   P-53



 1people who inform me, teach me, educate me, that following
 2that incident because no doubt the meeting took place
 3between Himmler and Jeckeln on 4th December 1941, yes?
 4 A. [Mr Irving]     Yes.
 5 Q. [Mr Rampton]     Probably following receipt of the telegram or whatever it
 6was on the 1st December.
 7 A. [Mr Irving]     Mr Rampton, may I remind you of the very lengthy Bruns
 8Report I read out.
 9 Q. [Mr Rampton]     I am coming to that.
10 A. [Mr Irving]     Can I answer.
11 Q. [Mr Rampton]     Certainly remind me of that if you wish, yes.
12 A. [Mr Irving]     Yes. In which there is talk in the Bruns Report of Bruns
13saying we sent an urgent message to Hitler's Headquarters,
14how could we do it, then the word comes back to the Riga
15front to the young SS man, he said, we received orders,
16this kind of thing has to stop. This is the kind of
17extraneous information one takes on board when one draws
18inferences from documents.
19 Q. [Mr Rampton]     Mr Irving, I think sometimes you set traps for yourself.
20 A. [Mr Irving]     I try not to.
21 Q. [Mr Rampton]     Actually what Bruns said was mass shootings on this scale
22have got to stop, this has to be done more discreetly?
23 A. [Mr Irving]     Yes.
24 Q. [Mr Rampton]     That is quite different?
25 A. [Mr Irving]     That is what the local SS officers said to him.
26 Q. [Mr Rampton]     It is quite different, is it not, it is not the same thing

.   P-54



 1at all?
 2 A. [Mr Irving]     They wanted to carry on, yes, they wanted to carry.
 3 Q. [Mr Rampton]     No, no, Bruns's report of the order through the mouth of
 4Altemeyer was that the order which had come from Berlin
 5was that mass shootings of this kind on the scale have to
 6stop, that has to be done more discreetly?
 7 A. [Mr Irving]     This is Bruns' version four years later of what the 22
 8year old SS officer who wanted to carry on killing Jews
 9told him. He said, we have gone been told by East Prussia
10we have to stop, however, the way he phrased it was, they
11have to stop on this scale and we are going to carry on
12doing it in a more discreet way because that is what they
13wanted to do. But of course they did not, they did not
14carry on, they stopped, as that footnote shows.
15 Q. [Mr Rampton]     We will come to it in a moment. They did stop for a
16time. They stopped doing what Himmler did not like that
17Jeckeln had done which was mass, if you like, semi public
18shootings of people as they go off the trains?
19 A. [Mr Irving]     The footnote which I printed at the end of bundle says
20"the killing of German Jews stopped for several months
21after this exchange".
22 Q. [Mr Rampton]     Yes, that is common ground between you and me, the killing
23of German Jews by this method. Maybe it stopped --
24 A. [Mr Irving]     Mr Rampton, you are putting words in which do not exist --
25 Q. [Mr Rampton]     -- we are coming to your use, I add, your use of the Bruns
26evidence in a moment, but before we do that, I want you to

.   P-55



 1look at these two messages, these two intercepts. There
 2is no evidence in that of any intervention or
 3participation by Hitler, is there?
 4 A. [Mr Irving]     -- no.
 5 Q. [Mr Rampton]     It is all between Himmler and Jeckeln?
 6 A. [Mr Irving]     Yes.
 7 Q. [Mr Rampton]     If you look at the log for the 1st December 1941, I have
 8given you the composite version, having lost --
 9 A. [Mr Irving]     Composite version, yes. This is a composite because it is
10made up from three or four different sources by the
11editors.
12 Q. [Mr Rampton]     -- by "composite" I meant composed from different pages in
13the book.
14 A. [Mr Irving]     Yes, December 1st.
15 Q. [Mr Rampton]     December 1st. We see when he is making a telephone call
16he puts "T" is that the editors or is that Himmler?
17 A. [Mr Irving]     That is the editors who put that.
18 Q. [Mr Rampton]     That is the editors. At quarter past one on the 1st there
19is an entry, it must be a telephone call because Heydrich
20is in Prag?
21 A. [Mr Irving]     It is in my bundle two.
22 Q. [Mr Rampton]     The German for Prague is P-R-A-G I take it; is that right?
23 A. [Mr Irving]     Yes.
24 Q. [Mr Rampton]     At quarter past 1 he rings SS Obergruppenfuhrer Heydrich
25in Prag?
26 A. [Mr Irving]     If I may interrupt, we do not know he rang Heydrich, all

.   P-56



 1we can say is there was a conversation.
 2 Q. [Mr Rampton]     Heydrich might have rung him, of course?
 3 A. [Mr Irving]     Yes.
 4 Q. [Mr Rampton]     The first word is scribedamen; is that secretaries?
 5 A. [Mr Irving]     That is correct.
 6 Q. [Mr Rampton]     They have a talk about secretaries, it seems, then they
 7talk about the executions in Riga?
 8 A. [Mr Irving]     Yes.
 9 Q. [Mr Rampton]     Is there any inconsistency in that entry and the
10suggestion that what they actually talked about was the
11fact that Jeckeln had not followed the guidelines because
12he was doing it too publicly?
13 A. [Mr Irving]     That is perfectly consistent. I might add this is the
14document 24 in -- I am sorry, document No. 14 in my
15bundle, the original.
16 Q. [Mr Rampton]     Yes. You see there is no evidence in that that that phone
17call to Heydrich, or from Heydrich, is in any way involved
18or prompted by Hitler, is there?
19 A. [Mr Irving]     No, none at all, but you are setting a trap for yourself
20I am afraid.
21 Q. [Mr Rampton]     Why?
22 A. [Mr Irving]     Because if I may refer back to the second of the messages,
23page 17 in my bundle, one in which Himmler contacts
24Jeckeln on December 1st and reads the riot act to him.
25 Q. [Mr Rampton]     Yes, we looked at that.
26 A. [Mr Irving]     It says: "The Jews being outplaced to the Ostland are to

.   P-57



 1be dealt with only in accordance with the guidelines laid
 2down by myself and/or by the Reichssicherheitshauptamt on
 3my orders." No mention of Hitler here.
 4 Q. [Mr Rampton]     No.
 5 A. [Mr Irving]     So this is vitally important to me. I rely on that to
 6prove that Hitler was not involved in this order. The
 7ordering procedure was not Hitler's. The guidelines were
 8not Hitler's.
 9 Q. [Mr Rampton]     Mr Irving, one would not expect, given the way in which
10Hitler's so-called orders and, they are very rarely
11orders, they are more often just an airy speech at some
12dinner table, the words "Hitler's orders" in quotes, were,
13as it were, dispersed down the hierarchical column of the
14Nazis, you would not expect Hitler to issue precise
15guidelines about how the Jews were to be treated on
16arrival or how they were to be killed, would you?
17 A. [Mr Irving]     This is your, evidence you are leading or a question?
18 Q. [Mr Rampton]     I am putting it to you that that is right, is it not?
19 A. [Mr Irving]     I rely only on my interpretation of this document that
20Himmler in a secret message says, they are my order and my
21guidelines and you have contravened them. When the
22temptation would surely have been to say you have
23contravened the Fuhrer's orders and the Fuhrer's
24guidelines, which is a very strong point I would make
25because this is the centre point of my own contention.
26 Q. [Mr Rampton]     Do you not think that in light of Bruns's evidence the

.   P-58



 1guidelines were whatever you do you must make sure it does
 2not come to public attention because public opinion in
 3Germany will not stand for it if it does, and that that is
 4precisely what was discussed between Himmler and the
 5journalist on the train or wherever it was on the 30th
 6November?
 7 A. [Mr Irving]     I think that public opinion in Germany would have stood
 8from it from what I know of the Germans -- most Germans
 9would not have batted a eyelash at the knowledge that
10these mass killings of the Jews were going on.
11 MR JUSTICE GRAY:     Well, they were German Jews, I think you
12agreed earlier on?
13 A. [Mr Irving]     German Jews.
14 MR RAMPTON:     They were Berlin Jews.
15 A. [Mr Irving]     Yes, there was certainly nothing that would have caused
16the Germans problems on the scale that the euthanasia
17killings were causing in public morale problems. Maybe my
18interpretation of the morale in Germany is wrong, you will
19lead evidence later on to contradict me.
20 Q. [Mr Rampton]     I think that probably is right.
21 MR JUSTICE GRAY:     I am not sure I follow the logic of that, the
22euthanasia programme did cause unrest to use a neutral
23term?
24 A. [Mr Irving]     It caused so much unrest, my Lord, that Hitler had to
25intervene and stop it.
26 Q. [Mr Rampton]     Would not the shooting of large numbers of, to put it

.   P-59



 1bluntly, healthy Jews, have caused even more unrest, or at
 2any rate as much unrest?
 3 A. [Mr Irving]     They are very -- they are parallel programmes and in very
 4many senses. A lot of the killing operations were
 5conducted by the same organizations and the same experts,
 6but the campaign of Dr Goebbels against the Jews,
 7propaganda campaign had, been conducted with very much
 8more vehemence and personal commitment by Dr Goebbels and
 9it had converted a large element of the German, population
10in my opinion, to anti-Semitism of a vicious and poisonous
11degree. Whereas his attempt to achieve the same results
12against the crippled and disabled had been limited just to
13one or two films and articles. There a film called "Ich
14Klagean", which was a film about the -- it was a film in
15which the mentally disabled and crippled were portrayed in
16a repulsive manner so the public would accustom themselves
17to idea of putting them out of the way, and this kind of
18propaganda totally failed with the German public. The
19doctors went along with it but the general public when
20they found out about it resisted very strongly euthanasia
21killings. Whereas the Jews were considered to be,
22I think, in Germany fair game as a result largely of
23Dr Goebbels' propaganda.
24 Q. [Mr Rampton]     How good is your facility with Heinrich Himmler's spidery
25Gothic handwriting?
26 A. [Mr Irving]     The handwriting on these pages is not only Himmler, it is

.   P-60



 1also his Adjutant who still alive in Munich.
 2 Q. [Mr Rampton]     Never mind. Let us be precise then and put impersonally,
 3with the spidery handwriting, Gothic handwriting on these
 4pages?
 5 A. [Mr Irving]     On these pages, I will have a shot at it, Mr Rampton.
 6 Q. [Mr Rampton]     No, I just wonder how used you are to looking at it.
 7 A. [Mr Irving]     Not recently, but over the last few nights I have had to
 8strain my eyes once again, thanks to your imputations.
 9 Q. [Mr Rampton]     When did you first see these pages which, apparently, you
10did not see the whole of the page for 30th November 1941
11until 17th May 1998, is that right?
12 A. [Mr Irving]     He maintained three separate continuous records. He kept
13the pocket diary. Those pocket diaries are scattered
14around the world. Some are in Israel now, some are in
15Russia. I found two in the United States and gave them to
16the German government.
17     He also maintained a telephone log which was a
18sheet of paper on his disk, like the ones in front of us,
19on which he would write down on one side the name of the
20person he was talking to and on other side what they were
21talking about. Either he or his adjutant would also keep
22a daily agenda of whom he was to see and when and what
23they would talk about or what they had talked about.
24     The fourth series of documents by Himmler you
25will also run into is when he went to see Hitler, he would
26write down on a sheet of paper his discussion points.

. P-61



 1 Q. [Mr Rampton]     We are coming to one of those later on today, Mr Irving.
 2Can you turn to page 12?
 3 A. [Mr Irving]     I should also explain that these are on microfilm
 4originally in the United States which is the way I used
 5them and accessed them originally in the 1970s.
 6 Q. [Mr Rampton]     I wan to be clear what it was you had seen when you wrote
 7your books. Can you turn to page 12 in your little
 8bundle?
 9 A. [Mr Irving]     Right. This is the telephone conversations of November
1030th.
11 Q. [Mr Rampton]     Bear with me, if you do not mind, just allow me to ask
12some questions. What is this a page a copy of? Page 12?
13 A. [Mr Irving]     I just stated that he would have on his desk a sheet of
14paper on which he would either type or insert in
15handwriting the words "telephon gesprach" which is
16T-E-L-E-P-H-O-N G-E-S-P-R-A-C-H.
17 Q. [Mr Rampton]     So that is his what we can ----
18 A. [Mr Irving]     This is his telephone log.
19 Q. [Mr Rampton]     What we could perhaps imprecisely call his telephone log?
20 A. [Mr Irving]     Yes.
21 Q. [Mr Rampton]     Would you turn over then to ----
22 A. [Mr Irving]     I was the first person to find and make use of these.
23 Q. [Mr Rampton]     That is as may be.
24 A. [Mr Irving]     Well, it is important.
25 Q. [Mr Rampton]     On page 14?
26 A. [Mr Irving]     Page 14, yes.

.   P-62



 1 Q. [Mr Rampton]     I ask the same question: is that the same document? It
 2looks different.
 3 A. [Mr Irving]     It looks different because that is a photocopy from my
 4blue volume of these which is on the desk at the other end
 5of your bench.
 6 Q. [Mr Rampton]     I see.
 7 A. [Mr Irving]     Whereas the page previously, when I used it as a facsimile
 8in my book "Hitler's War", I had it rephotographed by the
 9German Government from the original in their archives as a
10photograph rather than as a photocopy.
11 Q. [Mr Rampton]     So, looking at page 14, somebody has typed "telephon
12gesprach Reichsfuhrer SS" from 1st December 1941?
13 A. [Mr Irving]     Yes.
14 Q. [Mr Rampton]     Who typed that?
15 A. [Mr Irving]     That was typed by his adjutant. A blank sheet of paper
16would be typed for him and laid before him with that
17heading already prepared.
18 Q. [Mr Rampton]     But the other one, the earlier one, has not got that?
19 A. [Mr Irving]     He did not have it, no. That is taken straight off the
20microfilm. I can show that to you on the bound volume.
21 Q. [Mr Rampton]     I follow that. Let us understand it. The second one is
22the thing that he probably keeps in his office?
23 A. [Mr Irving]     I do not think so. He would sometimes use a presheet --
24pretyped sheet that his adjutant had typed and sometimes
25he would just a take a blank sheet of paper if he was in a
26hurry and write the headings himself.

.   P-63



 1 Q. [Mr Rampton]     Which may be something of the character of the first one.
 2 A. [Mr Irving]     That is correct. They are all in the same file, those
 3ones.
 4 Q. [Mr Rampton]     What I want to know is what you had when you wrote your
 5books. Was it this these two sheets of paper?
 6 A. [Mr Irving]     I had those two sheets.
 7 Q. [Mr Rampton]     You did not have the fuller version which we can now
 8compose?
 9 A. [Mr Irving]     It is not a question of the fuller version. The other
10page that you are referring to was not his telephone log,
11but his daily agenda, his appointment book, which is in
12Moscow and which only became available in 1998.
13 Q. [Mr Rampton]     We really would get on quicker if you would let me finish
14the question. I said the fuller version which we can now
15compose from different sources. As the editors of the
16Witte book have done, they have used a number of different
17sources to make a diary for the day.
18 A. [Mr Irving]     Well, they have. They have constructed an artificial
19diary, yes, a calendar.
20 Q. [Mr Rampton]     Exactly, but in the days when you were writing your books,
21the books which we are talking about, this is all you had,
22was it?
23 A. [Mr Irving]     Yes. The Witte book, which is the one to the left of your
24box ----
25 Q. [Mr Rampton]     That is new, that one?
26 A. [Mr Irving]     Yes. It costs about £70 -- not as much as law books, of

.   P-64



 1course, but still quite expensive.
 2 Q. [Mr Rampton]     I did not buy it.
 3 A. [Mr Irving]     It was only published last year. I only obtained it about
 4four months ago.
 5 Q. [Mr Rampton]     Well, now this is not in any sense a trick or an
 6examination question or anything. Can you look at page
 712?
 8 A. [Mr Irving]     Yes.
 9 Q. [Mr Rampton]     And the last entry which I think is probably quarter past
106 -- it might be anyway, might it not?
11 A. [Mr Irving]     The last line or the last entry?
12 Q. [Mr Rampton]     No, the last entry.
13 A. [Mr Irving]     6.15.
14 Q. [Mr Rampton]     It looks like it, does it not? Then across the line?
15 A. [Mr Irving]     "SS Gruppenfuhrer ... Berlin".
16 Q. [Mr Rampton]     What is the first word of the entry in the right-hand
17column?
18 A. [Mr Irving]     "Transport Nachersatz".
19 Q. [Mr Rampton]     It is the "a" of transport which I ask you to look at.
20 A. [Mr Irving]     Yes, that is the real problem.
21 Q. [Mr Rampton]     No, it is not.
22 A. [Mr Irving]     It is because the "a" looks exactly like the "e" in Gothic
23handwriting.
24 Q. [Mr Rampton]     Exactly. In fact, you might think to an English eye it
25looks like a "u"?
26 A. [Mr Irving]     No.

.   P-65



 1 Q. [Mr Rampton]     "Trunsport"?
 2 A. [Mr Irving]     I will explain why it does not.
 3 Q. [Mr Rampton]     No, no.
 4 A. [Mr Irving]     Well, no, please.
 5 Q. [Mr Rampton]     It might be thought to an English person -- just bear with
 6me, answer my person -- it might be thought to look like a
 7"u", might it not?
 8 A. [Mr Irving]     Yes. My Lord, do you have the facsimile in front of you?
 9 MR JUSTICE GRAY:     Yes. I am following.
10 MR RAMPTON:     Now could you turn to page 14, please?
11 A. [Mr Irving]     14, yes.
12 Q. [Mr Rampton]     In fact, that thing that looks like a "u" to an English
13person in "transport" is an "a", is it not?
14 A. [Mr Irving]     Yes.
15 Q. [Mr Rampton]     Now look at the word which you say you mistranscribed as
16"Juden" which is three lines up from the bottom of the
17right-hand column ----
18 A. [Mr Irving]     Yes.
19 Q. [Mr Rampton]     --- on page 14.
20 A. [Mr Irving]     Yes, I have it.
21 Q. [Mr Rampton]     It is plainly "haben"; it is the same thing, it is an "a",
22is it not?
23 A. [Mr Irving]     That is what we call Monday morning quarter back ring. It
24is somebody who knows what the answer is. If I had given
25this page to you, say, six months ago, Mr Rampton, and
26said, "Would you mind reading that word?"

.   P-66



 1 Q. [Mr Rampton]     I would not have had a clue. I cannot read hardly any of
 2it.
 3 A. [Mr Irving]     That was the position I was in 34 years ago when I looked
 4at this.
 5 Q. [Mr Rampton]     Why? But you have never gone back to it?
 6 A. [Mr Irving]     I must have gone back to it in the 1970s because I retyped
 7it on my transcript.
 8 Q. [Mr Rampton]     The third letter, you think that is a "d" or you thought
 9it was a "d"?
10 A. [Mr Irving]     If you look at the word "Juden" which I would ask you to
11look at variously, for example ----
12 Q. [Mr Rampton]     We will look at it on page 12, if you want?
13 A. [Mr Irving]     Yes. About eight lines from the bottom. In the third
14line of that entry you have "Judentransport", admittedly,
15it is a bit ----
16 Q. [Mr Rampton]     It is obscured?
17 A. [Mr Irving]     --- obscured by the word above it.
18 Q. [Mr Rampton]     I agree.
19 A. [Mr Irving]     But you can already begin to see that there are distinct
20similarities in the outline.
21 Q. [Mr Rampton]     I am afraid I cannot accept that. Anyway, the point is
22this, is it not ----
23 A. [Mr Irving]     Yes, you hasten on, yes.
24 Q. [Mr Rampton]     -- you say, you tell us, that you read that word, that
25entry as reading: "Verwaltungsfuhrer der SS Juden zu
26bleiben"?

.   P-67



 1 A. [Mr Irving]     Yes, and I can produce my contemporary index card on which
 2I made that transcription which shows at that time as
 3"Juden zu bleiben".
 4 Q. [Mr Rampton]     Turn, please, to page 13 of this bundle and there you have
 5it correctly?
 6 A. [Mr Irving]     I have corrected it, yes.
 7 Q. [Mr Rampton]     You tell us to look at the word "haben". One can see if
 8one looks that the letters are squashed?
 9 A. [Mr Irving]     It has been typed in subsequently with tippex, yes.
10 Q. [Mr Rampton]     Yes, or whatever was existing then because you say that
11was retyped on a typewriter which you threw away more than
1215 years ago?
13 A. [Mr Irving]     Well, between 10 and 15 years ago -- an old IBM typewriter
14I had.
15 Q. [Mr Rampton]     Yes, but before 1991?
16 A. [Mr Irving]     Yes.
17 Q. [Mr Rampton]     Now can you take "Hitler's War 1991", please?
18 MR JUSTICE GRAY:     Can I just ask you this, Mr Irving? You are
19fluent in German. If you are trying to write that
20somebody has to stay somewhere, whether it is Jews or
21whoever, you would not say "haben zu bleiben", would you?
22 A. [Mr Irving]     They have to stay, "haben zu bleiben" would be the German.
23Just the same as in English, has to stay, has to remain.
24 Q. [Mr Justice Gray]     Is that right?
25 A. [Mr Irving]     Yes. But, on the other hand, the line "Juden zu bleiben"
26would be also grammatically correct.

.   P-68



 1 Q. [Mr Justice Gray]     That is abbreviation, but if you are using a verb at all,
 2you would say "haben" would be appropriate?
 3 A. [Mr Irving]     Yes, and you could equally well say the word above it
 4which is "Verwaltungsfuhrer" was a line by itself and a
 5topic by itself which is what I assumed it was in the
 6original transcript.
 7 MR RAMPTON:     Can you turn now to Hitler's War on page 427, 1991
 8edition?
 9 A. [Mr Irving]     I do not have it in front of me, but if you would just
10read out the passage.
11 Q. [Mr Rampton]     D1(v). I do not have to read very much. My Lord, page
12427.
13 MR JUSTICE GRAY:     Thank you.
14 MR RAMPTON:     At the end of the last complete paragraph on page
15427 -- is that 1991 you have there?
16 A. [Mr Irving]     You will not believe this, but I am only person who does
17not have a copy of that book. People visit my house and
18they think, "Well, that is nice". It has gone!
19 Q. [Mr Rampton]     1991, volume 2, it is D1(v).
20 A. [Mr Irving]     I would be quite ready to concede what you are about to
21say. We do not really need to go into this.
22 MR JUSTICE GRAY:     I probably ought to know what you are about
23to concede.
24 MR RAMPTON:     Yes. I do not think we should communicate by
25telepathy, Mr Irving!
26 A. [Mr Irving]     Very well.

.   P-69



 1 Q. [Mr Rampton]     Now, we have read the first part of this earlier this
 2morning about "Hitler being obliged to telephone from
 3Hitler's bunker to Heydrich the explicit order that these
 4Jews were 'not to be liquidated'". Then you go on after
 5the semi-colon ----
 6 A. [Mr Irving]     Can you tell me what page you are on?
 7 Q. [Mr Rampton]     I am sorry, 427. I beg your pardon.
 8 A. [Mr Irving]     Yes.
 9 Q. [Mr Rampton]     "... and the next day Himmler telephoned SS Oswohl Pohl,
10overall chief of the concentration camp system, with the
11order 'Jews are to stay where they are'." When that was
12published, you knew it was wrong, did you not?
13 A. [Mr Irving]     Published what.
14 Q. [Mr Rampton]     When that was published, you knew it was wrong?
15 A. [Mr Irving]     No.
16 Q. [Mr Rampton]     Why not?
17 A. [Mr Irving]     When it was published, yes. You must appreciate this text
18you are looking at here was set by the Americans, by the
19American publisher, A1 Books Limited, in probably 1985 or
201986. They published it round about that time, and two or
21three years later, round about 1990, we approached the
22English publishers and had this American edition
23photographed and what is called offset, and reprinted in
24our own edition which Mr Bateman is holding there, what
25you call the 1991 edition.
26So there is very little connection between the

.   P-70



 1actual year given as the year of publication and the date
 2when text goes into its final cast in stone form.
 3 Q. [Mr Rampton]     Tell me that chronology again, Mr Irving. It is rather
 4interesting. When was the American edition of this work
 5written?
 6 A. [Mr Irving]     Written or?
 7 Q. [Mr Rampton]     Written.
 8 A. [Mr Irving]     I have to piece it together from extraneous information.
 9I was in Quay West, I was in Florida. It would have been
101985 and 1986 because I did it before I wrote the Rudolf
11Hess book which was 1987 published, so it was 1985.
12 Q. [Mr Rampton]     So when were the references to the Holocaust removed from
13it?
14 A. [Mr Irving]     The references to the Holocaust?
15 Q. [Mr Rampton]     Yes.
16 A. [Mr Irving]     That is a good question. That is a good question because
17that would, in fact, bring it forward to 1988.
18 Q. [Mr Rampton]     Oh, really?
19 A. [Mr Irving]     Yes.
20 Q. [Mr Rampton]     You see, Mr Irving, let me put my cards on the table, as
21I habitually do, your Holocaust conversion, if I can call
22it that, happened as a result, largely speaking, perhaps,
23of your encounter with Mr Leuchter and his laboratory
24analyses?
25 A. [Mr Irving]     Reading the laboratory reports, yes, which was April 6th
261988.

.   P-71



 1 Q. [Mr Rampton]     1988?
 2 A. [Mr Irving]     Yes.
 3 Q. [Mr Rampton]     As a consequence of that, we have been told by you, not in
 4this court but elsewhere and you will, no doubt, confirm
 5it in due course, this book in that respect ----
 6 A. [Mr Irving]     So the sequence of books is different. I wrote the Rudolf
 7Hess book first and then I went to revise this.
 8 Q. [Mr Rampton]     If you say so.
 9 A. [Mr Irving]     Yes.
10 Q. [Mr Rampton]     It was radically altered in that respect as compared with
11the 1977 edition?
12 A. [Mr Irving]     Taking out the word "Holocaust", yes.
13 Q. [Mr Rampton]     Now, here you have an entry, also as you know accept ----
14 A. [Mr Irving]     Yes.
15 Q. [Mr Rampton]     --- completely wrong, but it does not ----
16 A. [Mr Irving]     Yes, but is it not exactly the same wording?
17 Q. [Mr Rampton]     It does not get changed. It is exactly the same wording.
18 A. [Mr Irving]     In other words, I have not actually actively put in
19something; I have just left something to stand.
20 Q. [Mr Rampton]     No, you could have taken it out?
21 A. [Mr Irving]     I could have taken it out, yes. If somebody had come to
22me and had said at the time, "Oh, Mr Irving, by the way,
23do you not remember you misread that word and we have now
24got a better reading", then, believe me, I would have
25taken it out and I would have contacted the Americans and
26changed it. But that is not what happens in real life.

.   P-72



 1 Q. [Mr Rampton]     You came to believe in 1988 that the so-called Holocaust,
 2as you call it, so-called, did not happen?
 3 A. [Mr Irving]     I have never used the phrase "so-called Holocaust",
 4Mr Rampton.
 5 Q. [Mr Rampton]     No, no. I am in the difficulty, as you perfectly well
 6understand, Mr Irving, there is no way in the world that
 7I am going to concede that it did not happen. That is not
 8what this case is about. I call it "so-called" because in
 9your eyes by then it was the "so-called Holocaust"?
10 A. [Mr Irving]     You said the "so-called Holocaust, as you call it".
11 Q. [Mr Rampton]     No. As you characterize it?
12 A. [Mr Irving]     Yes.
13 Q. [Mr Rampton]     Yes -- had not happened so you took steps to have the book
14altered for its second edition to remove the references to
15that ----
16 A. [Mr Irving]     Yes.
17 Q. [Mr Rampton]     --- alleged event?
18 A. [Mr Irving]     Yes.
19 Q. [Mr Rampton]     You did not bother to remove something which was, first of
20all, important and, secondly, completely wrong?
21 A. [Mr Irving]     This is a very subordinate matter in the book. It is a
22piece of secondary information which adds very little to
23the principal argument. The argument turns out now to
24have been correct on the basis of the decodes. This is a
25book of probably half a million words. One word,
26admittedly, I should have changed because I had some years

.   P-73



 1earlier realized that I had misread it. In all the
 2500,000 words it never occurred to me that there may be
 3words which I still had not actually changed yet. You are
 4absolutely right.
 5 Q. [Mr Rampton]     Yes. Then I suggest that your failure to remove it, as
 6you could easily have done, it now appears ----
 7 A. [Mr Irving]     Yes.
 8 Q. [Mr Rampton]     --- was deliberate because you wanted to keep this picture
 9of benign, magnanimous Adolf Hitler holding up his arm to
10save the Jews before the public?
11 A. [Mr Irving]     I do not think so, and I do not think you can suggest that
12just on the basis of that one line. The Jews have to
13remain, have to remain where? Have to remain in
14concentration camps.
15 Q. [Mr Rampton]     Where they are?
16 A. [Mr Irving]     Have to remain in the East, have to remain in the west.
17It is a pretty meaningless sentence as it is.
18 Q. [Mr Rampton]     In that paragraph it is by no means meaningless, is it?
19 A. [Mr Irving]     Yes, but now I would certainly replace it with the decodes
20instead and, in fact, in the latest edition I have. That
21sentence is out and is replaced by absolute diamond
22evidence, the decodes, showing that I am right all the way
23down the line.
24 MR JUSTICE GRAY:     Am I right in thinking that the entry in the
25log was one of what you have described as the "chain of
26documents"?

.   P-74



 1 A. [Mr Irving]     This particular one, I never referred to, not the "haben
 2zu bleiben". It is totally immaterial and unimportant.
 3My Lord, people imagine that books are written in a very
 4precise, military kind of way, but they are written in an
 5extraordinarily ramshackle way. They go back and forth
 6across the Atlantic with all sorts of different people
 7setting their hands to them, including lawyers and readers
 8and experts and sub-editors and publicity people, and it
 9is a miracle that anything finally comes off the end of
10the line.
11 MR RAMPTON:     Mr Irving, you thought it sufficiently important
12an event, and it is in the context of an order from
13Hitler, according to you, the Jews are to stay where they
14are, it is a coder showing, not only did Hitler say that
15they are not to be killed, not to be liquidated, an
16explicit order, but they are actually to stay where they
17are, they are not to be shunted around from one place to
18another and they are certainly not to be brought to places
19of execution. That is why it is there, is it not?
20 A. [Mr Irving]     No. It is there purely because it was the next entry in
21the Himmler telephone log as I had misread it at the time.
22 Q. [Mr Rampton]     And is sufficiently important in your mind for you to put
23an asterisk footnote, is it not?
24 A. [Mr Irving]     Saying that the facsimile of November 30 telephone
25conversation is reproduced as a facsimile.
26 Q. [Mr Rampton]     I imagine the reason you did not -- I do not know what the

.   P-75



 1verb is from "facsimile" -- you did not reproduce a
 2facsimile of the note of 1st December is that you will say
 3that is because it was not sufficiently legible on the
 4copy?
 5 A. [Mr Irving]     This is what you imagine, is it? Is your imagination what
 6you are leading as evidence now?
 7 Q. [Mr Rampton]     Yes. I am asking you, what is the reason why -- you had a
 8lot of pictures in the second edition, did you not?
 9 A. [Mr Irving]     In the 1991 edition?
10 Q. [Mr Rampton]     Yes.
11 A. [Mr Irving]     Yes.
12 Q. [Mr Rampton]     Why did you not put a facsimile of this message in?
13 A. [Mr Irving]     I had something like 3,000 pictures to draw upon,
14Mr Rampton, and it is a judgment call which photographs
15you use. One facsimile of a first line document where an
16order is going out, "the transport of Jews not to be
17liquidated" is for more important than a meaningless
18sentence like "had to remain".
19 Q. [Mr Rampton]     Now, I want to go to, if I may ----
20 A. [Mr Irving]     But I would like just to round up that argument between us
21by saying that I do not think that you have established
22that I have deliberately manipulated or deliberately
23distorted or deliberately mistranslated anything. It is a
24sin of omission. The sin of omission is that I should
25sometime five years down the road, having realized the
26misreading, it should have occurred to me that one word

.   P-76



 1had been misinterpreted or misread and that I should take
 2that out of the 500,000 other words.
 3 Q. [Mr Rampton]     I will be clear about it, Mr Irving, I will lay it out for
 4you. You can deny it. It is not my function at this
 5stage to persuade his Lordship that I am right. That
 6comes later on. You invented a Hitler order. You
 7deliberately inflated it into an order to protect the
 8whole of the Jews?
 9 A. [Mr Irving]     I have not invented a Hitler order, Mr Rampton. I have
10hypothesized the Hitler order in the way that a scientist
11should and I have then supported the hypothesis with
12evidence.
13 Q. [Mr Rampton]     Mr Irving, this is one occasion on which a "yes" or "no"
14will do. You invented it in the sense that you made an
15hypothesis (and I do not say it is an unreasonable
16hypothesis) you made it into a categorical assertion of
17fact. Now, do you agree with that or not?
18 A. [Mr Irving]     Yes, in the introduction.
19 Q. [Mr Rampton]     And do you agree with that as being an irresponsible,
20deliberately deceptive manner for a historian to proceed?
21 A. [Mr Irving]     Quite the contrary on the basis of evidence that I have
22led this morning from my little bundle.
23 Q. [Mr Rampton]     When did you have those Jeckhelm messages?
24 A. [Mr Irving]     The intercepts?
25 Q. [Mr Rampton]     Yes.
26 A. [Mr Irving]     Within the last four weeks I have seen the originals.

.   P-77



 1 Q. [Mr Rampton]     You did not have them at the time when you wrote this
 2book?
 3 A. [Mr Irving]     No, but if you have a clean mind when you set out to write
 4a book, untrammelled by what you have seen on the TVs and
 5on the movies or read in other people's book like that by
 6Mr Kershaw, if you start out with a clean mind and you
 7read documents that meet your criteria, you are probably
 8going to be nudged in the correct path that you arrive at
 9the right conclusions.
10 Q. [Mr Rampton]     It may happen, Mr Irving, from time to time in life that
11you tell what you intend to be a lie and subsequent
12events, that wonderful friend hindsight shows that you
13were telling the truth all along. Mr Irving, we are not
14using hindsight. I am concerned with your state of mind
15when you wrote these books.
16 A. [Mr Irving]     You a tell a lie and it turns out to be the truth all
17along?
18 MR JUSTICE GRAY:     Tell what you intend to be a lie.
19 MR RAMPTON:     Yes, you tell what you intend to be a lie and it
20turns out to be the truth.
21 A. [Mr Irving]     Why would I intend something to be a lie?
22 Q. [Mr Rampton]     Because you are trying to exonerate, exculpate Adolf
23Hitler.
24 A. [Mr Irving]     Well, this is your opinion, Mr Rampton, and I do not think
25that this can be sustained on the evidence.
26 Q. [Mr Rampton]     No. There are four limbs to this which you can say, "Yes,

.   P-78



 1it is right" (which you will not) or "No, it is not right"
 2(which you will). The second limb to this is that you
 3deliberately distorted the original German so as to
 4inflate one transport of Jews from Berlin into the whole
 5of the German Jews?
 6 A. [Mr Irving]     I am not going to respond to that because I have made a
 7response to that argument.
 8 Q. [Mr Rampton]     Exactly. The third step is that you did not misread by
 9accident the word "haben" as "Juden"; you knew all along
10that it was "haben" but you wrote it in as "Jews"?
11 A. [Mr Irving]     I am not going to respond to that because I have stated my
12position very fully on that too.
13 Q. [Mr Rampton]     The fourth proposition is that in any event, on your own
14account, by the time this version of the book, the 1991
15edition, comes out, you know for a certainty, even if you
16did not before, that it was wrong and you deliberately
17chose not to change it?
18 A. [Mr Irving]     On the contrary, you could use the word "deliberate" if
19I put it in at this time. A failure to take something out
20is an omission, a sin of omission, and not a sin of
21commission, if I may put it that way. I respectfully
22suggest that it was a sin of omission and a failure to
23take a word out of 500,000 words is ----
24 Q. [Mr Rampton]     I do not think it matters what words one uses.
25 A. [Mr Irving]     --- it would be improperly and unjustly described as being
26the kind of distortion that you are trying to impute.

.   P-79



 1 Q. [Mr Rampton]     Indeed I do. To allow a falsehood once told to remain on
 2the record is just as reprehensible as to have invented it
 3in the first place, is it not?
 4 A. [Mr Irving]     I object to the word "falsehood".
 5 Q. [Mr Rampton]     Well, it is a false statement.
 6 A. [Mr Irving]     A misreading of a word which is a perfectly legitimate
 7misreading of a word which, I suppose, every person in
 8this room would have read that way if they had been in
 9exactly the same situation.
10 Q. [Mr Rampton]     These books, Mr Irving, are in some sense, are they not,
11history books?
12 A. [Mr Irving]     Which books?
13 Q. [Mr Rampton]     These, the Hitler's War books?
14 A. [Mr Irving]     They are ----
15 Q. [Mr Rampton]     They are meant to be?
16 A. [Mr Irving]     --- works of history, yes.
17 Q. [Mr Rampton]     --- meant to be history books. They are meant to be a
18history of the Second World War seen not through Hitler's
19eyes, I do not mean that, but with an angle on it that
20perhaps others have not treated before, that is to say,
21the Hitler angle. Hitler is at the centre of these books,
22is he not?
23 A. [Mr Irving]     Yes.
24 Q. [Mr Rampton]     You use what in the second edition it appears by the time
25it appears you know to be a false statement of fact about
26history?

.   P-80



 1 A. [Mr Irving]     By the time the second edition appears, it is true that
 2five years earlier I had known that a word had been
 3wrongly read. If you know -- when one publishes
 4successive editions of the book, if one is in the
 5fortunate position that I am, you are in the position that
 6you can, if you have the chance, constantly upgrade and
 7update and polish and refine. The latest edition that we
 8put out, before it goes to the printers, I have had it on
 9the Internet for the last six weeks, and I have invited
10people around the world to spot errors precisely like
11that, and I have increased the reward to a present $8 per
12error. I have had to shell out 2 or $3,000 already. I am
13not in the least bit ashamed because one wants to turn out
14a work that is as perfect and as error free as possible;
15but even so, errors go in. There is a very famous case
16where a man did exactly the same and he offered a very
17large reward if anybody could spot a typographical error
18in a book that he had produced, and it turned out that the
19very title on the title page had been -- can I point out,
20Mr Rampton, another very serious error?
21 Q. [Mr Rampton]     I am listening; it is just that I have to get ready for my
22next question. Do continue, yes.
23 A. [Mr Irving]     I will continue rambling on. There is a very serious
24error in the book "Hitler's War" which is before you, the
251991 edition, and this is that my name does not appear on
26it. That you would consider is a most serious error that

.   P-81



 1an author can face, that his name does not appear on his
 2own book.
 3 Q. [Mr Rampton]     It depends, rather, on one's point of view, Mr Irving,
 4I would have said. Mr Irving, can we turn please to --
 5what is that? That seems to have your name on it but maybe
 6this is the wrong edition.
 7 A. [Mr Irving]     Not on the jacket, but actually in the book, Mr Rampton,
 8you will not find it.
 9 Q. [Mr Rampton]     I have not, I confess, looked, nor do I think I ----
10 A. [Mr Irving]     I mean, I confess that I am the author for the purposes of
11this action.
12 Q. [Mr Rampton]     Nor do I think that I will spend the court's time doing it
13now. Thank you very much. Mr Irving, I want to return to
14General Bruns. How do you pronounce it, in fact?
15 A. [Mr Irving]     Bruns, B-R-U-N-S.
16 Q. [Mr Rampton]     With no umlaut though?
17 A. [Mr Irving]     No umlaut.
18 Q. [Mr Rampton]     If that is the right word. Do you have your two-page
19English translation?
20 A. [Mr Irving]     I think I know it virtually off by heart.
21 Q. [Mr Rampton]     I would rather you had it.
22 A. [Mr Irving]     It is in my opening statement. I have it, yes, I have the
23opening statement version.
24 Q. [Mr Rampton]     Maybe I should use that. It will make it easier for
25everybody. I have the TRO version.
26 A. [Mr Irving]     It is on page 22. You say that Bruns' account has

.   P-82



 1verisimilitude?
 2 A. [Mr Irving]     Yes.
 3 Q. [Mr Rampton]     Account of what he said he saw?
 4 A. [Mr Irving]     I marked that because later on under oath in the witness
 5box in Nuremberg he said he had not been there, I find
 6that hard to believe.
 7 Q. [Mr Rampton]     I agree with you, I think it has verisimilitude for what
 8it matters. It is an horrendous account of an
 9unpleasant -- more than an unpleasant event in human
10history. That is not what I am interested in. Given that
11it has verisimilitude, if you look in the middle of page
1222, one of the things that Bruns was overheard saying to
13whoever he was speaking to was this, middle of the
14page: "I told that fellow Altemeyer?" In fact, Altemeyer,
15whose name I shall always remember and who will be added
16to the list of war criminals, listen to me they [that is
17Jews] represent valuable manpower. Altemeyer: Do you call
18Jews valuable human beings, sir? I [that is Bruns said]
19Listen to me properly, I said valuable manpower, I did not
20mention their value as human beings. He said [Altemeyer
21said] Well, they are to be shot in accordance with
22the Fuhrer's orders! I said: Fuhrer's orders? He said,
23yes, whereupon he showed me his orders."
24Now that has never appeared in any of your
25books, has it?
26 A. [Mr Irving]     Too true, yes, absolutely right.

.   P-83



 1 Q. [Mr Rampton]     Why not?
 2 A. [Mr Irving]     I discounted it.
 3 Q. [Mr Rampton]     Why?
 4 A. [Mr Irving]     Because I am familiar with other sources where people
 5claim to be acting on Hitler's orders because it was the
 6ready answer to shut anybody up if somebody came and
 7complained then the senior officer or the other officer
 8would say: "Do not start criticising me, this is the
 9Fuhrer's orders", and I discounted the subsequent sentence
10about "then he showed it to me" for exactly the same
11reason that I discounted the statement at Nuremberg that
12Eichmann claimed that the -- rather Wisliceny claimed that
13Eichmann had showed him the orders. There are no orders.
14They have not been found. We have now been in the
15archives, in and out of the archives of the world for the
16last 50 years, since the end of World War II, 55 years and
17no primary or secondary or tertiary evidence of the
18existence of these orders has been found as regards the
19war years.
20     I concede that in interrogations and in War
21Crimes Trials and elsewhere everyone else is happy to talk
22about Fuhrer's orders but the fact remains had there been
23any such order or any such document, and you are tapping
24this one, this is what I will put in the category of
25"interrogations", had there been any such order, it would
26have surfaced by now.

.   P-84



 1 MR JUSTICE GRAY:     You put this in the category of
 2"interrogations", did you say?
 3 A. [Mr Irving]     It is at the end of war, my Lord, he is in the enemy
 4hands.
 5 Q. [Mr Justice Gray]     He is being surreptitiously...
 6 A. [Mr Irving]     I appreciate that, my Lord, but it is in a grey area. He
 7is in the enemy's power and custody and I draw attention
 8to the line a bit earlier up where he says: "His name
 9I shall always also remember and who will be added to the
10list of war criminals". That is a gentle hint to me that
11perhaps he is not entirely unaware that somebody may be
12listening.
13 MR RAMPTON:     What do you know --
14 A. [Mr Irving]     You must appreciate that, my Lord.
15 MR RAMPTON:     What do you know General Bruns?
16 A. [Mr Irving]     -- what do I know of him?
17 Q. [Mr Rampton]     What do you know of him, yes.
18 A. [Mr Irving]     Only what I know from this document and from the writings
19of Gerald Fleming. I suppose we would describe him now as
20been an anti-Nazi by the time the war ended, but then a
21lot of people were anti-Nazi by the time the war ended.
22 Q. [Mr Rampton]     --- what if they happened to be an anti-Nazi all along,
23there were such people in German during the 1940s, were
24there not.
25 A. [Mr Irving]     Undoubtedly, yes.
26 Q. [Mr Rampton]     Quite a lot of the ordinary army, I am not talking about

.   P-85



 1the SS, who are not army at all, really, were anti-Nazi?
 2 A. [Mr Irving]     Is this the evidence that you are leading, I am not
 3familiar with any statistical basis for that.
 4 Q. [Mr Rampton]     I am suggesting you could give me the answer "yes"?
 5 A. [Mr Irving]     I have not seen any documentary evidence of that. I do
 6not think GALLUP Polls are conducted among the Wehrmacht
 7soldiers who still support Adolf. I always want to see
 8this kind of evidence and if I can just -- if I can just
 9add here we have got very high quality evidence of the
10morale and opinions of the Germans. We have the SD
11stinnungsberichge, which were the morale reports where
12Gestapo agents would hang around in bars listening to what
13people said. We have sacks and sacks of captured mail,
14captured by the Allies when a troop ship were caught or
15when positions were overrun. We know exactly what these
16people were writing. So we are very well informed about
17what was going on. I have never seen any kind of
18statistical analysis.
19 Q. [Mr Rampton]     If this is not an interrogation, which it plainly is not?
20 A. [Mr Irving]     Yes.
21 Q. [Mr Rampton]     And if General Bruns does not know that he is being
22recorded, and if it be the case that he simply is chatting
23to his fellow prisoners in German, which he is, am
24I right?
25 A. [Mr Irving]     While you just read that, may I just add a further point,
26we are dealing here with a 22 year old young man called

.   P-86



 1Altemeyer who has been put in SS uniform.
 2 Q. [Mr Rampton]     I am sorry, Mr Irving, there are times when you may make
 3speeches and times when you must answer my questions, this
 4is one of them; you said yesterday, no, I think this is on
 5Day One?
 6 A. [Mr Irving]     I will come back to what I was about to say when you have
 7finished.
 8 Q. [Mr Rampton]     "This document has, in my submission, considerable
 9evidentiary values... it is not self-serving, the General
10is not testifying in his own interest, he is merely
11talking, probably in a muffled whisper to fellow prisoners
12at a British interrogation centre and he has no idea that
13in another room British experts are listening to and
14recording every word. We also have the original German
15text of this document. I might add my, Lord ... "
16 MR JUSTICE GRAY:     That, I think, was Mr Irving's speech.
17 MR RAMPTON:     That is Mr Irving's speech. That is on page 46 --
18 A. [Mr Irving]     Can I make it easy for you, Mr Rampton, and say I accept
19Altemeyer did say those words.
20 Q. [Mr Rampton]     -- right.
21 A. [Mr Irving]     Or as best as Bruns recalls them.
22 Q. [Mr Rampton]     The whole of Bruns' account in this regard has the ring of
23truth then?
24 A. [Mr Irving]     Yes.
25 Q. [Mr Rampton]     So it is likely also then, is it, one cannot be certain,
26one was not there.

.   P-87



 1 A. [Mr Irving]     It is very likely that the SS officer concerned used those
 2words.
 3 Q. [Mr Rampton]     It is likely also he used the words at the end of this
 4extract on the bottom of page 24 of your opening: "Here
 5is an order, just issued, prohibiting mass shootings on
 6that scale from taking place in future" --
 7 A. [Mr Irving]     Have we now left that previous passage, if so --
 8 Q. [Mr Rampton]     -- I am coming back to it, but I want to try and be
 9consistent, if you are saying that we can believe that
10Altemeyer used the words in the first passage, can we also
11believe that Altemeyer said this: "Here is an order, just
12used, prohibiting mass shootings on that scale from taking
13place in future"?
14 A. [Mr Irving]     -- that I believe.
15 Q. [Mr Rampton]     "They are to be carried out more discreetly."
16 A. [Mr Irving]     That I attach less credibility to.
17 Q. [Mr Rampton]     Why?
18 A. [Mr Irving]     It is the kind of throw away line that soldiers would use,
19particularly in captivity, adding a gag, looking for a bit
20of a snigger from someone, saying not to be done on a mass
21shooting, of course, has to be done a bit more
22discreetly. If I can draw a comparison, you very rightly
23read out a passage of a speech I made in Calgary where
24I protested that I had been called a mild fascist by the
25newspapers and I said I do not like that word "mild" it is
26a throw away line, you are looking for a laugh.

.   P-88



 1 Q. [Mr Rampton]     I do not --
 2 A. [Mr Irving]     You then attach great weight to the fact Mr Irving
 3obviously accepts he is fascist, which is untrue. But
 4these things happen in conversation, Mr Rampton. It calls
 5for judgment and integrity before you use any particular
 6part of a sentence.
 7 Q. [Mr Rampton]     -- no, you misjudge me, Mr Irving, you should re-read what
 8I actually said and you will find what you just said is a
 9misrecollection. However, that matters not in the
10slightest.
11 A. [Mr Irving]     Can I now go back to the previous part you are relying on
12in that, where he says "here are the Fuhrer's orders" and
13he showed it to me.
14 Q. [Mr Rampton]     He did not say that. He said "whereupon --" this is
15important, Mr Irving, you must be accurate, this is an
16important distinction: "Whereupon he showed me his
17orders"?
18 MR JUSTICE GRAY:     That is Bruns speaking, not Bruns quoting
19Altemeyer?
20 A. [Mr Irving]     Altemeyer says, well, they are to be shot in accordance
21with the Fuhrer's orders, Bruns said: Fuhrer's orders?
22Yes, says Altemeyer, whereupon he showed me his orders.
23 MR RAMPTON:     His orders?
24 A. [Mr Irving]     Yes.
25 Q. [Mr Rampton]     That does not mean the Fuhrer's orders, that means
26Altemeyer's orders?

.   P-89



 1 A. [Mr Irving]     I am grateful to you for drawing that to my attention. If
 2you wish to infer from that that he showed to Bruns orders
 3from Hitler, or orders quoting orders from Hitler, because
 4he later on talks about the Fuhrer's orders, can I now
 5comment on that?
 6 Q. [Mr Rampton]     I am not going to comment on a suggestion I have not --
 7I am not going to invite you to comment on a suggestion
 8I have not made.
 9 A. [Mr Irving]     May I nevertheless comment?
10 Q. [Mr Rampton]     No, Mr Irving, you may not. If his Lordship permits it,
11why, yes. My question is a completely different one; my
12question is this, it is credible that Altemeyer said what
13he is here reported as having said?
14 A. [Mr Irving]     Yes.
15 Q. [Mr Rampton]     It is also credible, is it not, that he showed Bruns a
16written order saying that these people were to be shot?
17 A. [Mr Irving]     Yes.
18 Q. [Mr Rampton]     Good, thank you very much. Put those two things together,
19and there is evidence here which needs to be taken into
20account; do you agree?
21 A. [Mr Irving]     Discounted or taken into account, yes.
22 Q. [Mr Rampton]     Take into account, brought to the attention of the public
23or the historians so that they can make up their own minds
24whether or not this is evidence of a Fuhrer order for
25these shootings?
26 A. [Mr Irving]     You are absolutely right .

.   P-90



 1 Q. [Mr Rampton]     Thank you.
 2 A. [Mr Irving]     Can I continue?
 3 Q. [Mr Rampton]     Yes.
 4 A. [Mr Irving]     I have done precisely that.
 5 Q. [Mr Rampton]     Where?
 6 A. [Mr Irving]     On my website.
 7 Q. [Mr Rampton]     Yes, but what about your books?
 8 A. [Mr Irving]     I am not writing books about the Holocaust, Mr Rampton,
 9I am writing books about Adolf Hitler. The book is already
101,000 pages long. If I was to start going into that
11detail then I would be sternly reprimanded by the editors
12saying, Mr Irving, when I wrote the Hermann Goring
13biography, the American publishers came to me and said
14Mr Irving will you please cut out 2,000 lines from the
15printed text. This happens. We do not have a problem
16that our books are too short, we have the problem that our
17books are too long.
18 Q. [Mr Rampton]     Yes. Mr Irving --
19 A. [Mr Irving]     But the entire document is on the Internet and I am the
20one who placed it there.
21 Q. [Mr Rampton]     -- Mr Irving, you have made reference to this Bruns
22testimony in your published books?
23 A. [Mr Irving]     As I said in my opening speech, again and again, it is the
24most harrowing account and element of the Holocaust.
25 Q. [Mr Rampton]     But without ever mentioning either of these verbal
26exchanges in their entirety?

.   P-91



 1 A. [Mr Irving]     Absolutely right.
 2 Q. [Mr Rampton]     Why not?
 3 A. [Mr Irving]     Because this is descending into a level of textual
 4analysis which would bore the pant off an audience, which
 5would be totally out of place in a book about Adolf Hitler
 6for which I am perfectly prepared to discuss here in court
 7if you attach importance to you, but you do not want me to
 8discuss it.
 9 Q. [Mr Rampton]     I am not trying to prove a case about Adolf Hitler one way
10or the other?
11 A. [Mr Irving]     But you will not allow me to discuss it here.
12 Q. [Mr Rampton]     Of course I allow you discuss it here.
13 A. [Mr Irving]     You stopped me.
14 Q. [Mr Rampton]     I interested in why it makes no appearance --
15 A. [Mr Irving]     Because I have reasons for discounting it.
16 MR JUSTICE GRAY:     Discounting bits of it I suppose would be
17more accurate.
18 A. [Mr Irving]     -- I am discounting the bit about being shown the Fuhrer's
19order, or being shown orders implicating Hitler.
20 MR RAMPTON:     Why do you discount it?
21 A. [Mr Irving]     Ah, at last. Because other evidence shows that Hitler had
22not issued the order; firstly I said that nowhere in all
23the documentation of all the world's archives has any such
24order turned up.
25 Q. [Mr Rampton]     That not evidence, that is an absence of evidence?
26 A. [Mr Irving]     It is evidence in a very powerful sense.

.   P-92



 1 Q. [Mr Rampton]     It is a negative piece of evidence?
 2 A. [Mr Irving]     I hate to remind you of the basic principle of English law
 3that a man is innocent until proven guilty; am I right?
 4 Q. [Mr Rampton]     Hitler is not on trial, alas.
 5 A. [Mr Irving]     Is Hitler somehow excluded from this general rule of fair
 6play?
 7 MR JUSTICE GRAY:     I think that is a slightly --
 8 THE WITNESS:     Mr Rampton talks about absence of evidence not
 9counting, all the world's archive are effectively now open
10to us, there has not come forward any collateral evidence
11and as for a 22 year-old SS man's word being believed when
12he has the power of life and death over thousands of Jews
13who have just been ordered shot, this SS man obviously has
14more front than Selfridges, he is going around saying,
15yes, we have orders, I have orders, do not come critising
16me, that is what is going on here. That is the way I read
17that and that is the way any responsible historian should
18read it.
19 MR JUSTICE GRAY:     Let us move on. You accept a lot what is in
20here?
21 A. [Mr Irving]     -- I do indeed.
22 Q. [Mr Justice Gray]     But you do not accept that particular --
23 A. [Mr Irving]     Certainly not to the degree --
24 Q. [Mr Justice Gray]     As it was reflecting the reality?
25 A. [Mr Irving]     -- that one general's recollection of what a 22 year old
26SS man told him in Riga should be taken discounting the

.   P-93



 1negative evidence as Mr Rampton calls it of all the
 2world's archives.
 3 MR RAMPTON:     Mr Irving, I am not going to take you up on that;
 4you can argue with my experts about that if you like.
 5I am interested in the way you write your books. Both in
 6the Nuremberg book, and we will not need to look at them,
 7because we are looking for a black hole, both in the
 8Nuremberg book and in the Goebbels book you mention,
 9either in the text or in a footnote, or both, the Bruns,
10call it what you like?
11 A. [Mr Irving]     Yes, I consider my duty to draw everyone's attention to
12this report.
13 Q. [Mr Rampton]     But nowhere in either of those books do you mention either
14of these exchanges that Bruns reported he had with
15Altemeyer?
16 A. [Mr Irving]     You are repeating yourself, I will repeat the answer.
17 Q. [Mr Rampton]     You repeat your answer, yes, please.
18 A. [Mr Irving]     No, I did not.
19 Q. [Mr Rampton]     No, you did not. You actually have done this with the
20Altemeyer passages; may I show you? Can you find, please,
21file D3(i), I think it is tab 27 that I want. I will tell
22you where to look in a moment, Mr Irving, I just want to
23remind you and his Lordship of what Bruns actually said on
24Altemeyer's return with an order from Berlin after the
25shootings had been reported. "Here is an order, just
26issued, prohibiting mass shootings on that scale from

.   P-94



 1taking place in the future." That is your translation of
 2the German.
 3 A. [Mr Irving]     Yes.
 4 Q. [Mr Rampton]     It is one that I agree with.
 5 A. [Mr Irving]     This is from my introduction?
 6 Q. [Mr Rampton]     Yes, but then it goes on, does the sentence reported by
 7General Bruns: "They are to be carried out more
 8discreetly." That is the full text of General Bruns'
 9words as a report of what he was told by Altemeyer. Will
10you please look at page 415 of the document which is at
11tab 27 which is a written introduction by you in the
12Journal of Historical Review, to your new edition of
13"Hitler's War". At the end of that article there are
14some footnotes on page 415.
15 MR JUSTICE GRAY:     Why are we looking at it there as opposed to
16in the copy?
17 A. [Mr Irving]     That is what I am wondering.
18 MR RAMPTON:     Copy of which book?
19 MR JUSTICE GRAY:     We have the whole of "Hitler's War".
20 MR RAMPTON:     It is not in the book.
21 MR JUSTICE GRAY:     I thought you said it was.
22 MR RAMPTON:     No.
23 MR JUSTICE GRAY:     I thought this was the introduction to the
241991 edition.
25 MR RAMPTON:     Well, I do not think it is. It is an edition
26I have not got, that is why. That is why we have it

.   P-95



 1separately.
 2 MR JUSTICE GRAY:     I follow.
 3 THE WITNESS:     We also have a date on that, January 1989.
 4 Q. [Mr Rampton]     Two dates '76 and '89.
 5 A. [Mr Irving]     That answers the point.
 6 MR JUSTICE GRAY:     Two editions.
 7 MR RAMPTON:     Anyhow, if you look at the footnotes in the right
 8hand column on page 415, footnote 7 says this: "The most
 9spine chilling account of... methodical mass murder of
10these Jews [that is the Berlin Jews] at Riga is
11in ... 1158 in file etc. in the Public Record Office,
12Major General Bruns, an eyewitness, describes it to fellow
13generals in British captivity in April 25th 1945 unaware
14that hidden micro phones are recording every word. Of
15particular significance his qualms about bringing what he
16had seen to the Fuhrer's attention and the latter's [that
17is Hitler's] renewed orders that such mass murders were to
18stop forthwith"?
19 A. [Mr Irving]     Yes.
20 Q. [Mr Rampton]     As an account of what Bruns is recorded as having said
21that is completely dishonest, is it not?
22 A. [Mr Irving]     Does it say that the Bruns account is the only source for
23that final paragraph, that final sentence?
24 Q. [Mr Rampton]     It purports to be an account of what Bruns said, does it
25not, Mr Irving?
26 A. [Mr Irving]     It references the Bruns' file as the source of that

.   P-96



 1material in the main text, and it adds the comment: "Of
 2particular significance his qualms about bringing about
 3what he has seen to the Fuhrer's attention and the
 4latter's renewed orders that such mass murders were to
 5stop forthwith". In other words, that was of particular
 6significance.
 7 Q. [Mr Rampton]     Of particular significance in the Bruns's eyewitness
 8testimony.
 9 A. [Mr Irving]     I do not say that.
10 MR JUSTICE GRAY:     Read it through to yourself again.
11 MR RAMPTON:     Read it through.
12 MR JUSTICE GRAY:     And consider that answer, Mr Irving.
13 A. [Mr Irving]     Of the particular significance his qualms about bringing
14what he had seen to the Fuhrer's attention and the
15latter's renewed orders that such mass murders were to
16stop forthwith. I see no objection to that as being an
17encapsulated version of Bruns's report -- may I read out
18from the Bruns' report the sentences on which I would
19rely?
20 MR RAMPTON:     No, you may not, Mr Irving. I would like you to
21read the whole of that footnote and I shall repeat my
22question, and we will have a "yes" or "no" if you please.
23 A. [Mr Irving]     You will not let me read out these sentences in the Bruns
24report on which I rely?
25 MR JUSTICE GRAY:     In a moment. Just do what Mr Rampton is
26asking at the moment.

.   P-97



 1 A. [Mr Irving]     Very well. "The most spine killing account --"
 2 MR JUSTICE GRAY:     No, read it to yourself.
 3 MR RAMPTON:     Yes, I did not mean.
 4 A. [Mr Irving]     Well, because I am accused of being a Holocaust denier it
 5is interesting that I am repeatedly saying this kind of
 6thing, including in journals like this. You do not me
 7read it out loud?
 8 Q. [Mr Rampton]     I would like you to read it yourself.
 9 A. [Mr Irving]     You do not want public to hear what I wrote.
10 MR JUSTICE GRAY:     It has just been read out.
11 A. [Mr Irving]     Yes, I have read it.
12 MR RAMPTON:     You have read it. Now I will repeat my question;
13do you not agree that read as a whole, as one most read it
14as a whole, not selecting those little bits which one
15would rather ignore, and you are relying on the ones you
16want to be heard, reading that as whole, do you not agree
17that that is a singularly dishonest account of what Bruns
18was recorded as having said?
19 A. [Mr Irving]     I do not agree.
20 Q. [Mr Rampton]     Why?
21 A. [Mr Irving]     Can I now draw attention to the sentences in the Bruns
22Report on which I rely?
23 Q. [Mr Rampton]     Whatever you wish in answer to my question.
24 A. [Mr Irving]     I will summarize them and you can tell me if it is a false
25summary. They had difficulty, he did not want to write
26the report himself, he persuaded a junior army officer to

.   P-98



 1go down the road and have a look and come back and write
 2up what he had seen. The question then was who is going
 3to bring it to the Fuhrer's attention; they work out a way
 4to bring to the Fuhrer's attention involving Vice-Admiral
 5Canaris, shortly the orders come back, such mass murders
 6have to stop. Am I totally wrong in drawing the perfectly
 7justified inference that as a result of this army
 8officer's report being drawn to the Fuhrer's attention the
 9orders come, which we have seen in the intercepts that
10such mass murders have to stop.
11 MR JUSTICE GRAY:     Mr Irving, can I put it to you straight, as
12it were, because this is the suggestion.
13 A. [Mr Irving]     Yes.
14 Q. [Mr Justice Gray]     That what you have said as being of particular
15significance, namely the renewed orders that such mass
16murders were to stop forthwith, totally perverts the sense
17of Bruns' conversation in captivity because Bruns makes
18clear that Altemeyer said that the killings were to
19continue?
20 A. [Mr Irving]     I think I have explained the reason why I discounted that
21part of his remark, my Lord, this was the...
22 Q. [Mr Justice Gray]     Yes, but are you giving particular significance to a
23proposition which is the opposite of what one finds in the
24document?
25 A. [Mr Irving]     The decision of the little man on the spot in Riga is of
26no significance to the argument that Hitler had given the

.   P-99



 1order quite clearly that such killings had to stop.
 2 Q. [Mr Justice Gray]     Yes.
 3 A. [Mr Irving]     Have I made it plain, my Lord.
 4 Q. [Mr Justice Gray]     Yes, you have.
 5 A. [Mr Irving]     Thank you. I think that --
 6 MR RAMPTON:     Do you think, Mr Irving, that if General Bruns
 7were here today he would think what you have done with
 8what he said was fair and honest?
 9 A. [Mr Irving]     -- taken in elements, stage by stage, yes.
10 Q. [Mr Rampton]     Do you? I see. You said it again in that same file you
11have got there, I think it is at -- it is at tab 30, this
12is a paper, I think, presented by you at the Institute of
13Historical Review, a talk given by you?
14 A. [Mr Irving]     A talk?
15 Q. [Mr Rampton]     Yes, a talk, in October 1992, and the passage which
16matters is again an account of the Bruns evidence on page
1724, ignore the stamped number at the bottom of page, 24 of
18the article. I think this is an answer to a question very
19likely. Yes, it is. It is in the bottom part of the
20left-hand column on that page' does your Lordship have it?
21 MR JUSTICE GRAY:     Yes, I have.
22 MR RAMPTON:     This is the last thing, my Lord, I do before the
23adjournment if that is convenient.
24     "But other reports unfortunately have the ring
25of authenticity. Most of these SS officers, the gangsters
26that carried out the mass shootings were I think acting

.   P-100



 1from the meanest of motives. There was a particular SS
 2officer in Riga who is described in the report by Bruns in
 3which Bruns said the difficulty for us was how to decide
 4to draw what he had seen what we had seen to the Fuhrer's
 5attention, and eventually they sent a lieutenant down the
 6road and got him to write what he saw and they sent this
 7report signed by the lieutenant up to the Fuhrer's
 8headquarters through Canaris. Two days later the order
 9comes back from Hitler 'these mass shootings' [in quotes
10notice, Mr Irving] these mass shootings have to stop at
11once so [and this is now you again] Hitler intervened to
12stop it."
13     As a quotation from the evidence of General
14Bruns those words in quotes: "These mass shootings have
15got to stop at once", is a complete perversion, is it not,
16of what Bruns actually said?
17 A. [Mr Irving]     What is the difference?
18 Q. [Mr Rampton]     He said these mass shootings have got to stop at once,
19they have to be done more discreetly?
20 A. [Mr Irving]     The 22 year old SS man allegedly said that to Bruns --
21 Q. [Mr Rampton]     That is what Bruns is reported as having told his fellow
22officers?
23 A. [Mr Irving]     -- yes.
24 Q. [Mr Rampton]     He did not say this, did he, that you have written here?
25 A. [Mr Irving]     I gave the essential part of the information, which was
26that the orders -- we are talking about here the chain of

.   P-101



 1command from Hitler downwards and that the killings were
 2carried out there, the SS officers on the spot and I make
 3this very clear distinction, the gangsters were in the SS
 4who did the killings on the Eastern Front and for that
 5there is any amount of evidence, a lot of which you have
 6in your own files but the evidence of Hitler's involvement
 7is very tenuous and goes in the direction which I
 8indicated from my small bundle. My I also draw your
 9attention to the fact this is a question and answer
10session, Mr Rampton.
11 Q. [Mr Rampton]     Yes, I follow that.
12 A. [Mr Irving]     So there is no script. I am not reading out from a
13document.
14 MR JUSTICE GRAY:     Yes, I think the point on the quotation marks
15is not a fair one given that this is which you said in a
16speech because whoever transcribed it may well have just
17added the quotation marks?
18 A. [Mr Irving]     Not just but obviously when one is answering questions
19from the floor one is giving an encapsulated version of
20the essence of a document as one recalls it.
21 Q. [Mr Rampton]     I follow that.
22 MR RAMPTON:     My Lord, there are two minutes, so it might help.
23 MR JUSTICE GRAY:     Yes, why not use them.
24 MR RAMPTON:     If might help if we looked at the original German
25of Bruns said that Altemeyer had said.
26 A. [Mr Irving]     It does sometimes vary from the translation.

.   P-102



 1 MR JUSTICE GRAY:     Where do we find that?
 2 MR RAMPTON:     It is bundle H1(vii), some of Professor Evans
 3documents?
 4 A. [Mr Irving]     It is actually from my discovery.
 5 Q. [Mr Rampton]     No, I do not know where it comes from.
 6 A. [Mr Irving]     If it has a number written on the top right hand corner.
 7 MR JUSTICE GRAY:     Unfortunately, I have not brought that
 8particular file.
 9 THE WITNESS:     I was the person who discovered this document.
10 MR RAMPTON:     The page, have you got that?
11 A. [Mr Irving]     Not in front of me.
12 Q. [Mr Rampton]     You do not have the German?
13 A. [Mr Irving]     No.
14 Q. [Mr Rampton]     It is 233, which looks to me like the British transcript
15it is the transcript of Bruns' actual words -- before
16I ask the question I must look in the dictionary because
17I have not got my own.
18 MR JUSTICE GRAY:     "Massen" is underlined, is it underlined in
19the translation?
20 MR RAMPTON:     Yes, I do not know who did that.
21 MR JUSTICE GRAY:     No, it looks original.
22 A. [Mr Irving]     It is original.
23 MR RAMPTON:     Shows how important it is, Mr Irving, to go back
24to source, does it not.
25 A. [Mr Irving]     That is a "yes".
26 Q. [Mr Rampton]     Do you know how those transcripts were made? They were

.   P-103



 1secretly recorded, presumably by some hidden microphone.
 2 A. [Mr Irving]     It is still very secret but in the next door room
 3everything was taken down outsize large disks like the old
 4fashioned 78s.
 5 Q. [Mr Rampton]     Now can we assume that this is an accurate transcript;
 6there is no reason to doubt it, is there?
 7 A. [Mr Irving]     They are normally very accurate transcripts. They had
 8research teams who would have extensive catalogues and
 9indices to check on words and names.
10 Q. [Mr Rampton]     Let us look at the German, you will help me when my German
11strays off course as it very likely will, the relevant
12passage is at the bottom of page 233. It is line
13beginning der Altemeyer something triumphantly said
14quotes: "Hier ist eine Vorgugung" that is an order?
15 A. [Mr Irving]     Not necessarily, that is a strange kind of order. It is
16more of an ordinance.
17 Q. [Mr Rampton]     Yes. Here is an ordinance come, just come?
18 A. [Mr Irving]     Yes.
19 Q. [Mr Rampton]     That says, yes?
20 A. [Mr Irving]     Yes.
21 Q. [Mr Rampton]     To the effect that, let us say, shall we, dass?
22 A. [Mr Irving]     Yes.
23 Q. [Mr Rampton]     This kind of or these kinds of "derartige"?
24 A. [Mr Irving]     That kind of, yes.
25 Q. [Mr Rampton]     These kind of?
26 A. [Mr Irving]     Mass shootings.

.   P-104



 1 Q. [Mr Rampton]     Mass shootings, do you hear how I read it, mass shootings?
 2 A. [Mr Irving]     Yes.
 3 Q. [Mr Rampton]     In future, in Zukunft... which means must not take place
 4any more, does it not?
 5 A. [Mr Irving]     Yes.
 6 Q. [Mr Rampton]     "Das soll vorsichtiger gomacht worden"; that means this
 7shall in future be more cautiously or discreetly done?
 8Yes?
 9 A. [Mr Irving]     Very good, Mr Rampton, yes.
10 Q. [Mr Rampton]     Well, not very good, but it is not very difficult, is it,
11two things about it?
12 A. [Mr Irving]     Yes.
13 Q. [Mr Rampton]     It translates not as "shootings on this scale", it
14translates as "shootings of this kind"?
15 A. [Mr Irving]     Yes.
16 Q. [Mr Rampton]     And the word "mass"?
17 A. [Mr Irving]     Yes.
18 Q. [Mr Rampton]     Is underlined. Do you agree that that is likely to
19reflect the transcriber's impression of the emphasis which
20Bruns placed upon that word when he spoke it?
21 A. [Mr Irving]     Yes.
22 Q. [Mr Rampton]     Good. It is a very significantly different version from
23the one you have, if I may use a colloquialism "been
24punting"?
25 A. [Mr Irving]     You mean by leaving off the corollary?
26 Q. [Mr Rampton]     Yes, it fits in with the last part of the sentence, "it

.   P-105



 1must be done more discreetly"?
 2 A. [Mr Irving]     Yes.
 3 Q. [Mr Rampton]     Does it not?
 4 A. [Mr Irving]     Yes.
 5 Q. [Mr Rampton]     Now why do you reject the second half of that message and
 6embrace the first half?
 7 A. [Mr Irving]     We have been over this, but we will attack it from a
 8different angle. We are dealing not with a verbatim
 9transcript of what Altemeyer said, we are dealing with the
10recollection by a German army general four years later of
11what Altemeyer had said. We are dealing with a triumphant
12SS young officer, triumphantly he declaims this. The SS
13were eager to kill Jews. They were very indignant when
14orders had come down from whoever that this killing had to
15stop. They were eager to carry on somehow and so they
16were eager to find some kind of loophole that they allowed
17them to go on bumping off their enemies. So he tells the
18army officer, well, we have the orders but we are going to
19carry on doing it anyway.
20 Q. [Mr Rampton]     Nudge nudge, wink wink, we are going to do it more
21quietly.
22 A. [Mr Irving]     Yes.
23 Q. [Mr Rampton]     It is perfectly plausible.
24 A. [Mr Irving]     I am glad you accept this.
25 Q. [Mr Rampton]     That is quite a different thing from suppressing it
26entirely and perverting its meaning into something

.   P-106



 1different.
 2 A. [Mr Irving]     I do not accept that I have done that.
 3 Q. [Mr Rampton]     Which is what you have done.
 4 A. [Mr Irving]     I do not accept that.
 5 Q. [Mr Rampton]     Very well.
 6 MR JUSTICE GRAY:     Whatever it means, it is not Altemeyer
 7saying, well, we are going, as it were, off our own bat,
 8carry on as before, because the words make it plain it is
 9part of the order that the mass shootings shall be carried
10out more discreetly in the future.
11 A. [Mr Irving]     When I am writing this up, and also when I am talking
12about it, I am not just taking this document into account,
13I am taking into account what we know at both other ends
14and also the killing of the Germans thereupon stopped.
15 MR JUSTICE GRAY:     Yes. Right.
16 A. [Mr Irving]     Thank you.
17 MR JUSTICE GRAY:     Will you show Mr Rampton if you want to
18pursue the Stuttgart business.
19 A. [Mr Irving]     After lunch.
20 MR JUSTICE GRAY:     Provide it to him. 5 past 2.
21 (Luncheon adjournment)
22 MR JUSTICE GRAY:     Mr Irving and Mr Rampton, it is court 73 as
23from Monday. There were problems about Chichester Rents
24that made it unsuitable.
25 MR IRVING:     Thank you very much, my Lord. My Lord, first, one
26minor matter. I have one minor application to make which

.   P-107



 1I would make about this time tomorrow concerning the date
 2of one of the witnesses who is appearing on summons that
 3it would be proper to make to your Lordship.
 4 MR JUSTICE GRAY:     Yes, I know.
 5 MR RAMPTON:     He may mean Monday, may he not, my Lord?
 6 MR JUSTICE GRAY:     Yes, Monday.
 7 MR IRVING:     Thank you very much, Mr Rampton.
 8 MR JUSTICE GRAY:     We are going to review whether we sit on
 9Fridays, but for the moment I think it probably is, in
10everybody's interests to have, not least yours, Mr Irving,
11actually.
12 MR IRVING:     Thank you very much, my Lord. My Lord, you will
13have seen the press clipping which I put to you this
14morning ----
15 MR JUSTICE GRAY:     Yes, I did.
16 MR IRVING:     --- from the German newspaper. I will not read it
17out.
18 MR JUSTICE GRAY:     Have you seen it, Mr Rampton?
19 MR RAMPTON:     Yes, I have.
20 MR IRVING:     It refers to the year 1996. According to this
21press clipping, the German government have asked for my
22extradition to Germany on an allegation, an alleged
23offence that I committed in 1990. The substance of the
24allegation is neither here nor there. I am only concerned
25with the coincidence of time; the fact that after 10 years
26suddenly this should have occurred now, just as our action

.   P-108



 1here is being heard.
 2 MR JUSTICE GRAY:     I do not want to cut you short, but I rather
 3sympathise with your view that it is unlikely to be a pure
 4coincidence, but what on earth can I do about it?
 5 MR IRVING:     Put my mind at rest, my Lord. If we could ask the
 6Defendants whether they have had any advance or prior
 7knowledge in any way at all of this or whether they were
 8contacted at all with the prosecuting authorities in
 9Stuttgart, or whether they contacted the prosecuting
10authorities.
11     The reason I have to say this, my Lord, is
12because, as my discovery shows, one of the bodies which
13I mentioned in my opening statement has corresponded in
14the past with both the German Embassy and the Austrian
15Embassy asking for my arrest.
16 MR JUSTICE GRAY:     I am not going to compel Mr Rampton to stand
17up and give an answer to that question. There are two
18ways in which you can deal with it if you want to pursue
19it, and I do not myself feel that you would be well
20advised to do so, but if you want to pursue it, you can
21either lay the foundations in your own evidence for me
22to draw the inference that it must have had something to
23do with the Defendants -- that is one way of dealing with
24it -- or you can cross-examine whichever of the
25Defendants' witnesses you think would be able to answer
26your questions on this topic.

.   P-109



 1     I appreciate you understand that Professor
 2Lipstadt will not be being called to give evidence so you
 3will not be able to ask her, but there may be other
 4witnesses, I do not know, who are going to be called by
 5the Defendants whom you could ask. But, to be candid, my
 6feeling is that we have quite enough to gnaw on this in
 7this case without really going down what are effectively
 8side alleys.
 9 MR IRVING:     Very well. I did wish to draw it to your
10Lordship's attention in case the morning should arrive
11when this end of the bench was suddenly empty.
12 MR JUSTICE GRAY:     If that were to happen (which I think is
13unlikely) I will do my best to prevent it. Does that
14help?
15 MR RAMPTON:     So indeed would I. Although your Lordship said
16you are not going to compel me to answer, but if I may
17respectfully say so, rightly, Mr Irving did ask me to
18ask. I did ask and the answer is no.
19 MR JUSTICE GRAY:     There you are. You do not have to accept
20that, but that is what you are told.
21 MR IRVING:     Quite clearly, I am sure that Mr Rampton would not
22have made that statement if it was in any way ^^-- I will
23accept that assurance, but I will also advance this
24particular episode as an instance of the kind of hatred
25that I have faced and the problems that I have faced in
26view of the allegations and the repugnant suggestions made

.   P-110



 1by this Defendant and others.
 2 MR JUSTICE GRAY:     You have dealt with that very clearly in your
 3evidence and, of course, I have that well in mind.
 4 MR IRVING:     It has a certain actuality about it which is quite
 5impressive.
 6 MR JUSTICE GRAY:     That is true. Yes, if you would like to go
 7back?
 8 MR DAVID IRVING, continued.
 9Cross-Examined by MR RAMPTON, QC, continued.
10 MR JUSTICE GRAY:     Mr Rampton, have we finished, at any rate for
11the time being, with H17, because if so I will hand it
12back because I have your copy. That is the German version
13of Bruns' statement.
14 MR RAMPTON:     Yes. I am afraid I have not quite finished with
15Bruns. I thought I had, but, as usual, that is the
16trouble with adjournments; things occur to one that one
17might have asked and did not. But, for completeness,
18I will ask. (To the witness): Mr Irving, do you still
19have there the file D3(i) which is the file of published
20articles or talks by you?
21 A. [Mr Irving]     D3(i), yes.
22 Q. [Mr Rampton]     I am looking at tab 30 which is the print of your speech,
23the JHR conference in October '92.
24 A. [Mr Irving]     Yes.
25 Q. [Mr Rampton]     And the questions which followed it. You remember -- you
26need not look it up, but it is on page 24, if you want of

.   P-111



 1tab 30, internal page 24, not final page 24 -- I drew your
 2attention towards the bottom of the left-hand column to
 3the words in quotes as a report of what Bruns had said
 4that Altemeyer had said: "These mass shootings have got
 5to stop at once". Do you remember that this morning?
 6 A. [Mr Irving]     Yes.
 7 Q. [Mr Rampton]     And I think your answer was to this effect, that it was
 8justified anyway but you could not rely on a transcript of
 9an extemporary answer to a question. I am summarizing.
10I am not quoting your words directly.
11 A. [Mr Irving]     On this transcript of my extemporary answer?
12 Q. [Mr Rampton]     Yes, on this example?
13 A. [Mr Irving]     Yes, that it would be -- yes, continue.
14 Q. [Mr Rampton]     Is it right, Mr Irving, that, in fact, before this version
15of your words as printed in this way, you went through
16them and approved them?
17 A. [Mr Irving]     Occasionally I did.
18 Q. [Mr Rampton]     This particular article?
19 A. [Mr Irving]     I am sure, Mr Rampton, you will be able to refresh my
20memory; if I did, then I did.
21 Q. [Mr Rampton]     You have recently told us so in your answers to our
22requests for information.
23 A. [Mr Irving]     I do not want to be specific about this one, and I am not
24being clever, but frequently they would send me a
25transcript to read, and sometimes I would proof read it
26and send it back and sometimes I would not.

.   P-112



 1 Q. [Mr Rampton]     You are right to be cautious, Mr Irving, not because I am
 2setting traps, but because memory is fallible. You served
 3on us, that is to say, our side, something called ---
 4 A. [Mr Irving]     "Answers to requests for information".
 5 Q. [Mr Rampton]     "Some answers".
 6 A. [Mr Irving]     Yes.
 7 Q. [Mr Rampton]     Fair enough because there were only some answers, on 27th
 8December of last year?
 9 A. [Mr Irving]     Yes.
10 Q. [Mr Rampton]     And one of the answers was this. This is No. 13 on page
115, my Lord. It is tab 9 of the main pleadings bundle,
12A1.
13 MR JUSTICE GRAY:     Yes, I do not think I have it.
14 MR RAMPTON:     No, but it does not matter; it is very short. Is
15very short. (To the witness): "In October 1992 I spoke
16at an IHR conference"?
17 A. [Mr Irving]     Is that this one?
18 Q. [Mr Rampton]     Yes. It is the only one I know of in October 1992. "As
19on previous occasions, I attended my booked table and paid
20no attention to the other speakers. Once again
21I corrected the text of my talk before it was published."
22 A. [Mr Irving]     Very well, yes.
23 Q. [Mr Rampton]     Also it is right to say, is it not, that the whole of
24that, including the questions and answers, appears on your
25web site?
26 A. [Mr Irving]     The whole of this?

.   P-113



 1 Q. [Mr Rampton]     Yes.
 2 A. [Mr Irving]     No, it is not correct to say that.
 3 Q. [Mr Rampton]     It is not?
 4 A. [Mr Irving]     No, it is not correct.
 5 Q. [Mr Rampton]     That particular passage does, does it not?
 6 A. [Mr Irving]     Will you give me the web site address?
 7 Q. [Mr Rampton]     Yes, I will. In fact, I had better you see the hard copy.
 8 A. [Mr Irving]     Www.
 9 Q. [Mr Rampton]     File D2(iii). It is HTP.www.fpp.co.uk.speeches.
10Speech ----
11 A. [Mr Irving]     Yes.
12 Q. [Mr Rampton]     --- 111092 HTML?
13 A. [Mr Irving]     In that case, that is correct, but does this particular
14passage also appear on that or just the speech?
15 Q. [Mr Rampton]     Yes, it does. I have the page here. By all means, I will
16pass it up.
17 MR JUSTICE GRAY:     I think you will take that on trust, I
18suspect, will you not?
19 MR RAMPTON:     You can trust me if I say something like that.
20 A. [Mr Irving]     No, the reason I say that is because in some of the
21witness reports things have been said to be on my web site
22whereas, in fact, they are just links on my we site
23somewhere else.
24 MR JUSTICE GRAY:     Anyway, do not let us take more time on this.
25I think it is accepted it is on the web site.
26 MR RAMPTON:     I think the answer is yes.

.   P-114



 1 MR JUSTICE GRAY:     Yes, it is.
 2 MR RAMPTON:     So, first of all, you corrected the transcript of
 3the talk before ----
 4 A. [Mr Irving]     Yes.
 5 Q. [Mr Rampton]     --- it was published and, secondly, you put the whole
 6thing in that form on to the web site?
 7 A. [Mr Irving]     Without in any way reviewing it.
 8 Q. [Mr Rampton]     No, I understand that, but the fact is we can then take it
 9that you have no quibble with the quotation marks around
10the words "These mass shootings have to stop at once"?
11 A. [Mr Irving]     Not the kind of thing I would quibble about, I do not
12think, no.
13 Q. [Mr Rampton]     Quite, good, I an glad to hear. There is one more,
14slightly more substantial point that I want to go back to
15which I apologise for having missed this morning. I am
16grateful it has been drawn to my attention. Have you got
17your 1977 "Hitler's War" with you there?
18 A. [Mr Irving]     1997?
19 Q. [Mr Rampton]     In 1977?
20 A. [Mr Irving]     Yes, I have.
21 Q. [Mr Rampton]     I am apt to '97 when I mean 1977, excuse me.
22 A. [Mr Irving]     This is the English edition of it, yes.
23 Q. [Mr Rampton]     Yes. I think the words are probably the same though, are
24they not?
25 A. [Mr Irving]     The English and American, yes.
26 Q. [Mr Rampton]     Page 332?

.   P-115



 1 A. [Mr Irving]     Yes.
 2 Q. [Mr Rampton]     I am not going to read it again. We have heard it too
 3often. In the middle of the page, there is the passage
 4dealing with the Berlin Jews, is there not?
 5 A. [Mr Irving]     Yes.
 6 Q. [Mr Rampton]     You have written: "The fate of Berlin's Jews was clearly
 7raised". So the context of that passage is, at any rate,
 8foreshadowed as being Berlin's Jews, is it not?
 9 A. [Mr Irving]     The context of the paragraph is the prior responsibility
10of the SS for the murders and not Hitler.
11 Q. [Mr Rampton]     Sure.
12 A. [Mr Irving]     Yes.
13 Q. [Mr Rampton]     But we are talking here in this little bit about a
14discussion about Berlin's Jews between Hitler and Himmler?
15 A. [Mr Irving]     Yes, in that sentence.
16 Q. [Mr Rampton]     Yes. Then you say in the next sentence: "At 1.30 p.m.
17Himmler was obliged to telephone from Hitler's bunker to
18Heydrich the explicit order that Jews were not to be
19liquidated"?
20 A. [Mr Irving]     Yes.
21 Q. [Mr Rampton]     Let me ask you this. You remember what you put in the
22introduction?
23 A. [Mr Irving]     Yes.
24 Q. [Mr Rampton]     When you wrote that, did you mean to say that these Berlin
25Jews or Berlin's Jews in general were were not to be
26liquidated, or that Hitler had made a general prohibition

.   P-116



 1against the slaughter or murder of Jews anywhere?
 2 A. [Mr Irving]     It is nit-picking.
 3 Q. [Mr Rampton]     It is not.
 4 A. [Mr Irving]     What I am about to say is nit-picking.
 5 Q. [Mr Rampton]     Oh, I see.
 6 A. [Mr Irving]     But there is a period after the word "Judentransport aus
 7Berlin", Jew transport from Berlin. In other words, there
 8is a full stop at the end of that and a new line. Then
 9comes the phrase "Keine Liquidierung" as a separate
10phrase. Operating as we were at that time, 1977, totally
11in the darkness about this particular -- we now know a lot
12more, but at that time we were operating totally in the
13darkness. I was going through a jungle of new documents
14that no other historian had set foot in. It was perfectly
15rational to say, is the "Keiner Liquidierung" a phrase
16which is attached to the line above, or is it a separate
17subject; just in the same way, if you look, there are four
18lines in that facsimile. The first one is -- I will say
19it in English so we have no problem -- arrest of
20Dr Jakelius. The next line after a period is "Apparently
21son of Molotoff" or "apparent son of Molotoff". The next
22line is "Jews transport from Berlin", full stop. The next
23line is "No liquidation".
24 Q. [Mr Rampton]     Yes.
25 A. [Mr Irving]     I appreciate that in the light of our present knowledge
26the fourth line clearly refers to the third line. Are you

.   P-117



 1with me, Mr Rampton?
 2 Q. [Mr Rampton]     I am absolutely with you, Mr Irving. Carry on.
 3 A. [Mr Irving]     But in the state of my knowledge in 1977, when I am still
 4in darkest jungle of new documents, it was perfectly
 5reasonable to accept the fourth line as being as detached
 6from the third line line as were the first and second
 7lines from each other and from the rest.
 8 MR JUSTICE GRAY:     So answer to Mr Rampton's question is that
 9you were conveying in that passage what you thought was an
10explicit order relating to Jews generally, not just Berlin
11Jews?
12 A. [Mr Irving]     Based solely on the fourth line with Jews being the topic
13of conversation, my Lord, yes.
14 MR RAMPTON:     I am coming back to that.
15 A. [Mr Irving]     That is why the full stop is so important.
16 Q. [Mr Rampton]     You say that, but it has this possible effect as well
17which is something evidently you did not even pause to
18think about; it might not have had anything to do with
19Jews at all, might it?
20 A. [Mr Irving]     You are absolutely right.
21 Q. [Mr Rampton]     You inflated it on the basis of what one might call a
22speculative inference into a general order against the
23liquidation of Jews in general, did you not?
24 A. [Mr Irving]     I object to the word "inflated". I said that
25I interpreted that line from the clear evidence that the
26previous topic of conversation had been Jews.

.   P-118



 1 Q. [Mr Rampton]     Berlin's Jews?
 2 A. [Mr Irving]     Yes, Jews all the same. I interpreted the fourth line as
 3being a reference to "no liquidation". We now know that
 4this was, in all probability, a reference purely to that
 5train load.
 6 Q. [Mr Rampton]     We do not want to get ahead of ourselves, at least I do
 7not want to get ahead of myself, Mr Irving, though you
 8should not feel sorry for me.
 9 A. [Mr Irving]     Right, but please do not forget that full stop in the line
10above.
11 Q. [Mr Rampton]     Of course I do not forget it. I can see it in the
12original.
13 A. [Mr Irving]     We had a lot of discussion about whether the "K" of
14"Keine" was actually a large "K" or a little "k" among
15historians, believe it or not.
16 MR JUSTICE GRAY:     If you have a full stop, it does not matter?
17 A. [Mr Irving]     Well, people wondered if that was a full stop or a
18blemish, my Lord. This is the kind of level to which one
19sinks.
20 MR RAMPTON:     The fact is, Mr Irving, that full stop or no, the
21first line of those two lines concerns Jews from Berlin,
22as it happens, one transport?
23 A. [Mr Irving]     Well, it concerns Jew transport or transportation from
24Berlin.
25 Q. [Mr Rampton]     The second line, if it is to be read disjunctively from
26the first line, refers to "no liquidation". No

.   P-119



 1liquidation of what? Businesses, gypsies?
 2 A. [Mr Irving]     It would have to be a very perverse mind indeed which
 3accepted there was no connection between the fourth and
 4the third lines, general topic.
 5 Q. [Mr Rampton]     The natural meaning of those two lines taken together,
 6whether you insert the full stop or not, is that there is
 7to be no liquidation of the Jews from Berlin?
 8 A. [Mr Irving]     You say whether you accept the full stop or not; the full
 9stop is there.
10 Q. [Mr Rampton]     No difference. It might have been a ----
11 A. [Mr Irving]     Pardon?
12 Q. [Mr Rampton]     There might have been nothing. It is a note in a man's
13handwritten telephone log.
14 A. [Mr Irving]     I agree. One cannot put it on the gold balance.
15 Q. [Mr Rampton]     If you say, Mr Irving, the "liquidieren" refers to Jews at
16all, then it is most probable, most probable -- I do not
17have to deal in certainties, you see, Mr Irving -- that it
18refers to the Jews referred to in the previous line, is it
19not?
20 A. [Mr Irving]     Yes.
21 Q. [Mr Rampton]     Yes. So why, what was the warrant for your inflating this
22(and I use that word advisedly because it is an inflation,
23objectively regarded) into a prohibition against the
24liquidation of all Jews anywhere?
25 A. [Mr Irving]     I remind you of your previous question; you are saying it
26is most likely that it was, and you are talking in the

.   P-120



 1present tense, but was it most likely in 1977 when I wrote
 2the book or published the book?
 3 Q. [Mr Rampton]     I am looking at the German as it was written in 1941.
 4 A. [Mr Irving]     No, are you asking me was it most probable that the fourth
 5line referred to the third line in the 1960s when I wrote
 6the book? The answer to that is it not so likely, it is
 7not so evident because at that time we did not have the
 8documents that we do now.
 9 Q. [Mr Rampton]     Ignore the extraneous material completely, if you will,
10Mr Irving.
11 A. [Mr Irving]     You cannot when you are writing books.
12 Q. [Mr Rampton]     I will. I am trying to get back to your state of mind in
131970 something when you first wrote this passage which got
14replicated in 1991. I look at what you had in front which
15you told us this morning was just the sheet. You did not
16have the surrounding material. German is an ordinary,
17Western European language. They think like us, they speak
18somewhat like us, and the entry is: "Jew transport from
19Berlin", full stop, "no liquidation". Now, if the
20"liquidation" refers to Jews, it refers to those Jews and
21no other Jews?
22 A. [Mr Irving]     Mr Rampton, you have four topics referred to in that
23conversation, one, two, three and four. One, two and
24three are all totally different topics from each other,
25and it is very reasonable to assume that the fourth topic
26is probably also yet another fourth topic.

.   P-121



 1 Q. [Mr Rampton]     That is interesting.
 2 A. [Mr Irving]     But you say there was no other document before me at that
 3time. Of course, there were the rest of these telephone
 4logs. For example, the reference to "no destruction of
 5the gypsies" which clearly shows the way which decisions
 6are going at the top.
 7 Q. [Mr Rampton]     So you mean the fourth line, "Keine Liquidierung" could
 8refer to the verhaftung of Dr Jakelius?
 9 A. [Mr Irving]     Equally.
10 Q. [Mr Rampton]     What is the verhaftung of Dr Jakelius?
11 A. [Mr Irving]     The arrest of Dr Jakelius. Dr Jakelius, my research has
12established, was an euthanasia doctor in Vienna who had
13been arrested for some reason.
14 Q. [Mr Rampton]     OK. He has been arrested. What is the Angleblich
15Molotoff?
16 A. [Mr Irving]     Somebody who was, apparently, claiming to be a son of
17Molotoff. Molotoff, the Foreign Minister, had no sons.
18 Q. [Mr Rampton]     And then there is the "Judentransport aus Berlin"?
19 A. [Mr Irving]     Then come -- yes.
20 Q. [Mr Rampton]     Then the fourth line is "Keine Liquidierung", so this
21could mean that none of those three groups, categories, is
22to be liquidated. Is that what you are telling us?
23 A. [Mr Irving]     I do not think I said that. I am saying that all four
24lines can be taken separately because the first three
25lines are quite clearly separate topics from each other.
26 Q. [Mr Rampton]     Let us go through it. Plainly, it is an utter nonsense to

.   P-122



 1talk about the "angeblich sohn Molotoff" as being subject
 2to an injunction against liquidation, is it not?
 3 A. [Mr Irving]     Subject to?
 4 Q. [Mr Rampton]     Being subject to an injunction against liquidation?
 5 A. [Mr Irving]     Well, very clearly it is. If somebody was the son of a
 6prominent Soviet leader, they would definitely be kept in
 7a very special confinement.
 8 MR JUSTICE GRAY:     He was thought at one time to have been on
 9that train.
10 A. [Mr Irving]     The usual trick was that a prisoner would be taken and he
11would claim to be Churchill's son or nephew or cousin or
12something like, and knowing that they would not be able to
13kill him. But it would be dangerous to read too much just
14into three words. All we know is that Molotoff had no
15sons and that, obviously, there is no connection between
16the Jakelius and Molotoff.
17 MR RAMPTON:     No, but, of course, there is no full stop after
18"Jakelius" either, is there, so it might be asserted that
19he was arrested because he was pretending to be the son of
20Molotoff, might he not?
21 A. [Mr Irving]     I am not sure how much time the court wishes to...
22 MR RAMPTON:     Well, this is fanciful.
23 MR JUSTICE GRAY:     I am wondering whether we have not thrashed
24through this document sufficiently.
25 MR RAMPTON:     Is it not? The "Keine Liquidierung" refers to the
26"Judentransport aus Berlin" whether there is a full stop

.   P-123



 1or not.
 2 A. [Mr Irving]     This is your opinion, but it is not mine, Mr Rampton, when
 3I am writing my book in early 1970s and ----
 4 MR JUSTICE GRAY:     It comes to this. In the early 1970s you
 5took that, as you now accept wrongly, to have been a
 6reference to Jews generally?
 7 A. [Mr Irving]     At large or at larger than is justified. I took it to be
 8transportation, the transporetation of the Jews as ----
 9 MR RAMPTON:     No, in the introduction it is "at large", not "at
10larger". In the introduction it is all Jews.
11 A. [Mr Irving]     Yes. This was the inference that I drew ----
12 Q. [Mr Rampton]     This is the incontrovertible evidence that Hitler had
13ordered, no liquidation of any Jews anywhere.
14 A. [Mr Irving]     Into account I take when writing that sentence my entire
15expertise based on all the other documents that we have by
16that time already collected, and, of course, now we know a
17great deal more which proves I was absolutely right to
18write what I wrote at that time.
19 Q. [Mr Rampton]     Mr Irving, we are not here to find out whether you were
20right or wrong; if we were, we would be here until the
21next Millennium.
22 A. [Mr Irving]     I doubt it.
23 Q. [Mr Rampton]     No doubt. We are here to test your credentials, your
24honesty and your integrity, as an historian, a chronicler
25of these events. The proposition which I put to you for
26you to deny is that you deliberately distorted the sense

.   P-124



 1of these two lines so as to make the reference to "Keine
 2Liquidierung" without any warrant whatsoever appear to be
 3a reference to Jews everywhere?
 4 A. [Mr Irving]     This sentence would only stand up in court, in my view, if
 5you were able to establish that at the time I wrote those
 6sentences I knew different and better. I think it would
 7be very difficult to make that stand. To show that one
 8makes a mistake in interpreting a translation of the word
 9"transport", that one chooses the wider interpretation
10rather than the narrow narrower definition that we now
11know to be correct from the other documentation, this is
12not a deliberate wilful and perverse distortion or
13manipulation or translation of a document.
14 Q. [Mr Rampton]     I put it to you, Mr Irving, that, on the contrary, it
15quite plainly is -- shall we leave it there -- which you
16deny? Just while we are on the question of full stops,
17since you have raised it, if we go to page 14 in your
18little bundle, we see the rather worse photograph,
19I agree, of the same sort of document that the log for the
20beginning of December, the first day of December?
21 A. [Mr Irving]     Precisely, yes.
22 Q. [Mr Rampton]     Yes, and I do not know, this is not a very good copy, are
23you certain whether or not there is a full full stop after
24word ----
25 A. [Mr Irving]     "SS"?
26 Q. [Mr Rampton]     --- "Verwaltung", yes, "SS"?

.   P-125



 1 A. [Mr Irving]     The second rune, you know what I mean by the rune, the
 2lightening flash that the SS ----
 3 Q. [Mr Rampton]     Yes, SS thing.
 4 A. [Mr Irving]     --- the second rune is right off the photocopy.
 5 Q. [Mr Rampton]     I know.
 6 A. [Mr Irving]     So we cannot tell if there is a full stop or not.
 7 Q. [Mr Rampton]     Have you got the original?
 8 A. [Mr Irving]     I have got it in my volume at the end -- the blue volume
 9marked "Himmler Diary".
10 Q. [Mr Rampton]     Have you got that printed transcript of these documents?
11 MR JUSTICE GRAY:     It is in this file, is it not?
12 A. [Mr Irving]     Well, I am afraid that I do not trust this ----
13 Q. [Mr Rampton]     OK.
14 A. [Mr Irving]     --- to that degree. Let me just explain why I will not
15trust this for being that kind of evidence. On two or
16three occasions I spotted instead of writing "u." for
17"und", they have written out "Und" in full.
18 Q. [Mr Rampton]     My fault entirely. I used the wrong document. One does
19make mistakes. I quite agree. Turn back to page 13 of
20your own documents, will you? This is your carefully
21retranscribed version of the Himmler log?
22 A. [Mr Irving]     Yes.
23 Q. [Mr Rampton]     Where you correct the mistake "Juden" to read properly
24"haben"?
25 A. [Mr Irving]     "Haben" with a small "h".
26 Q. [Mr Rampton]     And there is no full stop after "SS", is there?

.   P-126



 1 A. [Mr Irving]     It would have been highly improper of me to have put a
 2full stop in if there was not one visible on the
 3photocopy.
 4 Q. [Mr Rampton]     Exactly. What would in German the sentence or phrase
 5(because is not really a sentence) "VerwaltungsFuhrer der
 6SS haben zu bleiden" mean -- I mean "Juden zu bleiden",
 7I beg your pardon. What would it mean?
 8 A. [Mr Irving]     Jews to remain.
 9 Q. [Mr Rampton]     No, no. I will read it in English: "Administrative
10officers, leaders, of the SS Jews to remain"?
11 A. [Mr Irving]     Read like that, it would mean nothing at all. It would be
12quite meaningless.
13 Q. [Mr Rampton]     Exactly. It would be a complete nonsense, would it not?
14 A. [Mr Irving]     Yes.
15 Q. [Mr Rampton]     Thank you. Be patient with me, Mr Irving. I am just
16going to a new topic now. Mr Irving, you are conscious,
17I suppose and, in fact, I know you are, that Adolf Hitler
18made a speech I think to Reich and Gauleiters in Berlin on
1912th December 1941. I am still in the same period of
20short period of history.
21 A. [Mr Irving]     4th December?
22 Q. [Mr Rampton]     Yes, 12/12/41.
23 A. [Mr Irving]     Yes.
24 Q. [Mr Rampton]     We know that because there is a report of it in Goebbels'
25diary for 13th December, is there not?
26 A. [Mr Irving]     There is a reference to it.

.   P-127



 1 Q. [Mr Rampton]     Yes. Well, there is rather more than that, I think. Have
 2you got -- have you got your Goebbels book there?
 3 MR JUSTICE GRAY:     The answer is "no" can he be provided with a
 4copy?
 5 MR RAMPTON:     Yes, please somebody give him a Goebbels.
 6 A. [Mr Irving]     It is here. I have it here.
 7 Q. [Mr Rampton]     If you turn to page 383 you see in the first complete
 8paragraph you start like this: "Addressing the... whilst
 9still in Berlin Hitler opted for greater candour. He
10confessed that he had spent sleepless nights... whether he
11was doing the right thing in declaring war on Roosevelt."
12     Then you quote Goebbels: "The Fuhrer" Goebbels
13reported to his diary "is convinced that he would have had
14to declare war on the Americans sooner or later. Now the
15conflict in the Far East drops into our laps as an added
16bonus". "He viewed the battle of the Atlantic" etc. etc.
17down to the end of paragraph "an unavoidable hitch".
18Footnote 72. In footnote 72, which is on page 646, you
19explain that those references are taken from Goebbels
20diary on 13th December.
21 A. [Mr Irving]     That is correct, and that is true.
22 Q. [Mr Rampton]     Yes.
23 MR JUSTICE GRAY:     Mr Rampton, I am sorry, what page?
24 MR RAMPTON:     646, the footnote.
25 MR JUSTICE GRAY:     No, what page in the text?
26 MR RAMPTON:     383, I am so sorry.

.   P-128



 1 A. [Mr Irving]     The second paragraph.
 2 Q. [Mr Rampton]     Then I ask you to note, I will wait until his Lordship has
 3it, I ask you to note on the same page in the second part
 4of the next paragraph these words, because I am coming
 5back to this: "Returning by train on December 16th to the
 6Wolf's Lair" yes?
 7 A. [Mr Irving]     Yes.
 8 Q. [Mr Rampton]     So that you are saying means that -- I take it what are
 9you saying means that Hitler having addressed the
10Gauleiters on the 12th went back to the Wolf's Lair in
11East Prussia on the 16th?
12 A. [Mr Irving]     Yes, I can easily check it from the war diary.
13 Q. [Mr Rampton]     No. I am sure you are right about that, I am not about to
14dispute it, you will be surprised to hear.
15     Could you now please be provided with a copy of
16Professor Evans' report? No, I am sorry that is the wrong
17reference I beg your pardon. Can somebody retrieve that
18mistake by me, and give Mr Irving Professor Longerich.
19 MR JUSTICE GRAY:     This point is dealt with by Evans?
20 MR RAMPTON:     I know it is, but I have not got the reference in
21Evans.
22 MR JUSTICE GRAY:     I think it is page 320.
23 MR RAMPTON:     I have put it away.
24 A. [Mr Irving]     I am looking forward to it actually.
25 MR JUSTICE GRAY:     What?
26 A. [Mr Irving]     I am looking forward to it.

.   P-129



 1 MR RAMPTON:     It is very well known passage in Goebbels diary,
 2or seems to be. Thanks perhaps in part to Mr Irving,
 3I know not. If you have got Dr Longerich's report now,
 4could you turn to page 61 of the first part?
 5 A. [Mr Irving]     Yes, I have it.
 6 Q. [Mr Rampton]     We are on 12th December still. His report reads as
 7follows, at the bottom of page 61, paragraph 17.3: "One
 8day after the declaration of war on the USA on 12th
 9December Hitler addressed the... of the party"; so far is
10that correct, Mr Irving?
11 A. [Mr Irving]     That is correct, yes.
12 Q. [Mr Rampton]     "In this speech he returned once again to prophecy of 30th
13January 1939", that is the one in the Reichstarget about
14the fate of Jews, is it not?
15 A. [Mr Irving]     Yes.
16 Q. [Mr Rampton]     "And now announced the approaching extermination of the
17Jews living under German domination, as we can read in the
18Goebbels diaries."
19     Now please look at footnote 156, and I am not
20going to read it out because that is a strain for me and
21worst still for the transcribers. It is the original
22German. Tell me if it is accurate, your German is very
23good.
24 A. [Mr Irving]     The German text is accurate apart from the fact it has
25transcribed some of the diacriticals incorrectly.
26 Q. [Mr Rampton]     Fair enough.

.   P-130



 1 A. [Mr Irving]     German SZ, things like that.
 2 Q. [Mr Rampton]     You have read it now, have you?
 3 A. [Mr Irving]     I read it and I disapprove of the translation, but we will
 4reach that moment.
 5 Q. [Mr Rampton]     We will come to that because that is over the page, but --
 6 A. [Mr Irving]     It is a tendentious translation.
 7 MR JUSTICE GRAY:     But nothing wrong with the German?
 8 A. [Mr Irving]     -- nothing wrong with German --
 9 MR RAMPTON:     I will come back, because the translation will be
10important many times during in the course of the case.
11Dr Longerich translates it at the top page 62.
12 A. [Mr Irving]     -- he is, of course, German translating into English.
13 Q. [Mr Rampton]     I know he is, but it may be, I know not, you can ask him
14when he comes to court. He had some help. His English is
15pretty good, but not perfect: "As concerns the Jewish
16question the Fuhrer is determined to make a clean sweep";
17what I suggest we do, Mr Irving, is to take out page 61
18and fortunately the German text is on a separate page.
19 A. [Mr Irving]     Right.
20 Q. [Mr Rampton]     As we go through the English you can tell me in answer to
21my questions where you think Dr Longerich has gone wrong
22in his translation.
23 A. [Mr Irving]     Yes.
24 Q. [Mr Rampton]     "As concerns the Jewish question the Fuhrer is determined
25to make a clean sweep" (German spoken)?
26 A. [Mr Irving]     Tabula rasa they say in Latin.

.   P-131



 1 Q. [Mr Rampton]     Maybe, but this is fortunately in these courts we do not
 2speak much Latin any more.
 3 MR JUSTICE GRAY:     No, but it is closer actually, the Latin than
 4the English.
 5 MR RAMPTON:     Probably.
 6 MR JUSTICE GRAY:     That is the point are you making.
 7 A. [Mr Irving]     Yes.
 8 MR RAMPTON:     Yes, a tabular rasa is a blank surface.
 9 A. [Mr Irving]     So I am more accurate than yourself --
10 MR JUSTICE GRAY:     There is no distinction in terms of the sense
11of it, is there.
12 MR RAMPTON:     I do not know.
13 A. [Mr Irving]     -- does the word tabula rasa exist in English?
14 MR RAMPTON:     Yes. It is frequently used by people who do not
15know what it means, as so much Latin is. But if you wish
16tabula rasa is rather a perhaps stronger word than "clean
17sweep".
18 A. [Mr Irving]     Cleansing.
19 MR JUSTICE GRAY:     Do you dispute clean sweep gives sense?
20 A. [Mr Irving]     Not at all, perfectly good line.
21 MR RAMPTON:     "He had prophesied to the Jews that if they once
22again brought about a world war they would experience
23their own extermination." The words in German are (German
24spoken); what do those words mean?
25 A. [Mr Irving]     Well, of course, to translate "vernichtung" as
26extermination is highly tendentious.

.   P-132



 1 Q. [Mr Rampton]     Why?
 2 A. [Mr Irving]     If you look in your yellow dictionary, see what
 3"vernichtung" says.
 4 Q. [Mr Rampton]     I think I will.
 5 A. [Mr Irving]     I have no idea. I am prepared to say meaning No. one is
 6extermination.
 7 Q. [Mr Rampton]     You do not have to say that, Mr Irving. The root of the
 8word is "making to nothing" annihilating, is it not? Let
 9us see what that says. I have very little knowledge of
10German, but it seems to me obvious, but it means,
11according to Langscheidt, annihilate, destroy,
12exterminate, eradicate-shatter.
13 A. [Mr Irving]     It is the third possible meaning and he has chosen the
14third meaning rather than the first.
15 Q. [Mr Rampton]     Did you see a distinction --
16 A. [Mr Irving]     Yes --
17 Q. [Mr Rampton]     In this context -- weight between annihilate and
18exterminate?
19 A. [Mr Irving]     -- I am not going to put the words on the gold balance
20because this is not Hitler speaking, this is Goebbels
21reporting, am I correct?
22 MR JUSTICE GRAY:     No.
23 MR RAMPTON:     Apparently --
24 A. [Mr Irving]     On the following day.
25 MR RAMPTON:     Unless it come from Goebbels diary?
26 A. [Mr Irving]     -- this is Goebbels diary. This is a third person report

.   P-133



 1by Goebbels of what Hitler said the previous day.
 2 MR JUSTICE GRAY:     He is reporting what he recalls him having
 3said.
 4 A. [Mr Irving]     Yes, so it is rather meaningless to attach too much
 5importance to the actual words contained in the diary.
 6 MR RAMPTON:     On the contrary, Mr Irving, often enough in the
 7course of your books you attach a kind of uncritical
 8credulity to the utterances of Dr Goebbels.
 9 A. [Mr Irving]     Yes.
10 Q. [Mr Rampton]     Notwithstanding he is merely reporting what somebody else
11has said. Furthermore why should -- Dr Goebbels in
12December 1941 misreport what his leader had said?
13 A. [Mr Irving]     Because if you had read my book with the assiduity that
14I am sure you have you will remember that Dr Goebbels is
15an evil little genius who is capable of lying in the most
16malicious and perverse verse way and he will translate
17every single statement through his own distorted brain.
18 MR JUSTICE GRAY:     In his own diaries?
19 A. [Mr Irving]     Yes.
20 MR RAMPTON:     Why?
21 A. [Mr Irving]     This is the way people do things. They have a tendency to
22write down things they wished they had heard. If he
23wished to heard Hitler talking about the extermination of
24the Jews, then he would prefer to use that word when for
25all we know Hitler may have used a different one. I have
26no objection at all, Mr Rampton, when you bring to me the

.   P-134



 1verbatim transcripts of which there are any number of
 2Hitler actually said when he says things that are very
 3similar.
 4 Q. [Mr Rampton]     We do not have --
 5 A. [Mr Irving]     We should not rely on this kind of second order evidence
 6on matter of this importance.
 7 Q. [Mr Rampton]     -- you do it repeatedly when it suits your book,
 8Mr Irving.
 9 A. [Mr Irving]     You are accusing me of double standards.
10 Q. [Mr Rampton]     Yes, I am most roundly.
11 A. [Mr Irving]     I disagree. I am very careful with the criteria I apply.
12In a matter like this of such importance I look at the
13actual translations with greatest detail and if they are,
14I mean in law too you have to give somebody the benefit of
15the doubt when they are ambiguities. You certainly do not
16go for the third meaning of the word rather than first
17meaning.
18 Q. [Mr Rampton]     You see, you continually assume that I am using one
19document, one utterance, to prove the guilt of Adolf
20Hitler. In fact I am trying to do neither, Mr Irving.
21What I am trying to do is to suggest to you that the
22convergence of the evidence of which this is just one
23small example.
24 A. [Mr Irving]     Yes.
25 Q. [Mr Rampton]     Is that on the balance of probabilities, as though it were
26a civil case at court, the reasonable historian would say:

.   P-135



 1on the balance of probabilities the evidence is that Adolf
 2Hitler was at the heart of all of this? Do you follow me?
 3 A. [Mr Irving]     It is a rather vague sentence, that Hitler was at the
 4heart of all this.
 5 MR JUSTICE GRAY:     I think it probably clear what Mr Rampton is
 6getting at, can I put a related question, I would be
 7interested to know what your answer is; do you
 8"vernichtung" would be a word that would be likely to be
 9used if what was being talked of was deportation to
10Madagascar or anywhere else?
11 A. [Mr Irving]     I agree it would not and there are definitely cases where
12word "vernichtung" is used in the sense of murder. For
13example, in the German phrase ( German spoken), the
14destruction of people who are not entitled or should not
15be allowed to live. It is quite definitely a killing
16operation, but there are so much better sources where you
17have the actual transcript of what people are speaking
18that I hesitate to waste the court's time looking at the
19kind of document when undoubtedly you have the verbatim
20transcript of what Hitler said where he uses similar words
21or the same words.
22 MR RAMPTON:     Fortunately for everybody, Mr Irving, it is not in
23your hands whether the court's time is wasted. If I try
24to waste the court's time I will be told not to, if I am
25thought not to be wasting the court's I will not be told.
26 A. [Mr Irving]     If I was sitting there wearing a wig I would have jumped

.   P-136



 1to my feet and made this point.
 2 Q. [Mr Rampton]     You have made it.
 3 A. [Mr Irving]     I am wearing my other hat if I say that.
 4 Q. [Mr Rampton]     If you want to invite his Lordship to stop this line of
 5cross-examination please do so.
 6 MR JUSTICE GRAY:     Come on, I think you are not asking me to and
 7if you did, I would not.
 8 MR RAMPTON:     Thank you. Now then you do not like Dr Goebbels
 9use of the word "vernichtung". You are not certain that
10that is a word Adolf Hitler would have used on that
11occasion.
12 A. [Mr Irving]     Well, we know exactly what speech Hitler made on January
1330th 1939, there we have the verbatim text.
14 Q. [Mr Rampton]     Turn back to page 38 of the same report.
15 A. [Mr Irving]     We know exactly what Hitler said there, so why we are
16using a second hand version of a version of it repeated
17four years later.
18 Q. [Mr Rampton]     For the very fact that it was repeated on 12th December --
19 A. [Mr Irving]     Hitler constantly repeated this speech.
20 Q. [Mr Rampton]     -- please, Mr Irving, be patient and listen to my
21questions. Its importance you may agree is that it occurs
22again on 12th December 1941 at the time when the German
23Jews were being transported in large numbers to the East?
24 A. [Mr Irving]     Yes.
25 Q. [Mr Rampton]     Right. If you go back to 811 of Dr Longerich's report you
26find the relevant English of the Reichstag speech on 30

.   P-137



 1January 1939?
 2 A. [Mr Irving]     I know the speech off by heart.
 3 Q. [Mr Rampton]     In that case you will agree that the last words in
 4citation are: (German spoken); which means the
 5annihilation, extermination or eradication of the Jewish
 6race in Europe, does it not?
 7 A. [Mr Irving]     Can we just be absolutely certain what German words he
 8uses.
 9 MR JUSTICE GRAY:     It is same word, take it from me.
10 A. [Mr Irving]     In German, very well, my Lord, yes.
11 MR RAMPTON:     It is at the bottom of the page in German (German
12spoken)?
13 A. [Mr Irving]     In this case I would say that the word "race" implies that
14he is not talking about an actual killing operation and
15certainly January 1939 nobody was talking about killing
16Jews.
17 Q. [Mr Rampton]     What does word "genocide" mean, Mr Irving?
18 A. [Mr Irving]     Genocide?
19 Q. [Mr Rampton]     Yes, genocide.
20 A. [Mr Irving]     An English word genocide?
21 Q. [Mr Rampton]     No, it is not English, it is Latin.
22 A. [Mr Irving]     It is not a Latin word, you mean Latin origin?
23 Q. [Mr Rampton]     Yes. What does it mean?
24 A. [Mr Irving]     You explain to the court.
25 Q. [Mr Rampton]     No, you tell me if you know what it means.
26 A. [Mr Irving]     Killing of people by virtue of their race.

.   P-138



 1 Q. [Mr Rampton]     Yes, it means killing of a race of people.
 2 A. [Mr Irving]     Yes.
 3 Q. [Mr Rampton]     Is it any different from the "vernichtung" of a "rasa"?
 4 A. [Mr Irving]     You destroy races in other ways than killing them. Nobody
 5in January 1939 and I would be very surprised if you can
 6establish the opposite was talking about killing Jews.
 7 Q. [Mr Rampton]     Yes. I am going to go on with this little comparison
 8between --
 9 A. [Mr Irving]     Yes.
10 Q. [Mr Rampton]     -- if you forgive me and as long as I am not told by his
11Lordship it is waste of the court's time, but there is
12little comparison between what Dr Longerich has written in
13English and what the original German of Dr Goebbels diary
14was. We have finished with the word "vernichtung erleben
15geben", which means "they would experience", this was not
16just an empty phrase. The German is: "Das is keine frazig
17vasen"?
18 A. [Mr Irving]     That is correct.
19 Q. [Mr Rampton]     What does that convey to you? This was --
20 A. [Mr Irving]     Dr Goebbels is saying that is not an empty phrase. This
21is not Hitler saying this is an empty phrase, this is
22Goebbels saying it is an empty phrase.
23 Q. [Mr Rampton]     -- so you say.
24 A. [Mr Irving]     Well, this is Goebbels diary.
25 Q. [Mr Rampton]     How do you know it is not a report what Hitler said?
26 A. [Mr Irving]     Let me educate you in the German language. If this was

.   P-139



 1Goebbels saying this is Hitler saying it would have been
 2in the subjunctive. German language reports reported
 3speech in the subjunctive. It would be (German spoken)
 4not (German spoken) I am sure every German in this room
 5would agree with me.
 6 Q. [Mr Rampton]     Everything in the rest of this quotation is not
 7attributable to Hitler; is that your position?
 8 A. [Mr Irving]     We are taking this sentence by sentence; is that correct?
 9 Q. [Mr Rampton]     Let go on, the world war is there, the extermination and
10again the words are (German spoken) that is of Jewry, Jews
11in general if you like, must be the necessary
12consequence. (German spoken)?
13 A. [Mr Irving]     Here he has the same word, vernichtung, but he has given
14it a totally different translation, extermination, am
15I right?
16 Q. [Mr Rampton]     What do you mean?
17 MR JUSTICE GRAY:     No.
18 MR RAMPTON:     I see the two words "extermination" one on top of
19other.
20 MR JUSTICE GRAY:     I think you mean different from the 1939
21translation.
22 A. [Mr Irving]     Yes, but the word that is different of course is Judentums
23what does your Langscheidt tell us about that?
24 MR RAMPTON:     I doubt it has it in, I am not going to bother
25with it.
26 A. [Mr Irving]     Can I ask that you look in Langscheidt because I do not

.   P-140



 1have a copy here.
 2 MR JUSTICE GRAY:     You accept "Jewry" is the right translation?
 3 A. [Mr Irving]     Jewry, Judaism, but not Jews. If somebody talks about
 4wiping out Christianity that would be the parallel, my
 5Lord.
 6 MR RAMPTON:     This is only Dr Goebbels speaking, does it matter?
 7 A. [Mr Irving]     What is the standard dictionary?
 8 Q. [Mr Rampton]     You cannot -- we cannot believe a word Dr Goebbels says,
 9can we?
10 A. [Mr Irving]     This is your Judentums.
11 Q. [Mr Rampton]     I am just looking to see if it is in, it may be Jewry
12collective... there is a choice Mr Irving, which would you
13like to choose?
14 A. [Mr Irving]     Wiping out Jewry, wiping out Judaism, it is not the same
15as exterminating the Jews this is a manipulated
16translation.
17 Q. [Mr Rampton]     It has Jewry?
18 A. [Mr Irving]     He is saying that this is evidence of the wiping out of
19the Jews.
20 Q. [Mr Rampton]     No, look at it "Jewry" big letters, extermination of
21Jewry?
22 A. [Mr Irving]     Extermination of Jewry.
23 Q. [Mr Rampton]     Yes.
24 A. [Mr Irving]     Is not the same as annihilating Judaism.
25 Q. [Mr Rampton]     No, but the two meanings are both there?
26 A. [Mr Irving]     He has chosen once again the tendentious meaning, which

.   P-141



 1highly is disreputable for an historian to do.
 2 Q. [Mr Rampton]     Perhaps that is because it is consistent with the rest of
 3the text?
 4 A. [Mr Irving]     No, it is incumbent upon an historian, just as a lawyer to
 5give the benefit of the doubt to the person you are
 6impugning; am I correct?
 7 Q. [Mr Rampton]     No, you are not correct. Not in this case.
 8 A. [Mr Irving]     In an ambiguity.
 9 Q. [Mr Rampton]     No, there is not ambiguity here --
10 A. [Mr Irving]     There is a total ambiguity.
11 Q. [Mr Rampton]     Mr Irving, I go back: "He had prophecised to the Jews that
12if they", nothing to do with Judaism, "once again brought
13about a world war they would experience their own" that is
14to say the Jews own extermination "vernichtung", the same
15word in the next sentence.
16 A. [Mr Irving]     This is Dr Goebbels, right?
17 Q. [Mr Rampton]     Yes, yes.
18 A. [Mr Irving]     OK.
19 Q. [Mr Rampton]     No, that is Hitler.
20 A. [Mr Irving]     Hitler as reported four years later by Dr Goebbels.
21 Q. [Mr Rampton]     By Dr Goebbels. The world war is there. The
22extermination of Jewry must be the necessary consequence.
23The one flows quite naturally and logically from the
24other.
25 A. [Mr Irving]     In the first case he has taken the third meaning of the
26word. In the second case he has taken the second meaning

.   P-142



 1of the word. In neither case has he taken the primary
 2meaning of the word, primary translation. If I was to do
 3that I think I would be hearing about it shortly in this
 4court.
 5 Q. [Mr Rampton]     Eradication, extermination, annihilation all mean the same
 6thing --
 7 A. [Mr Irving]     I do not think so. I gave an example if one talked about
 8eradicating Christianity, drug addiction, you do not go
 9about wiping out the drug addicts.
10 MR JUSTICE GRAY:     I think I have the point.
11 A. [Mr Irving]     -- I think there is room for manoeuvre on something like
12this and it is incumbent on people not to take the evil
13meaning of a word when there are much better sources.
14 MR RAMPTON:     There is only room for manoeuvre for those who
15want to find room to manoeuvre?
16 A. [Mr Irving]     Like people who pay witnesses for expert cases like this.
17 Q. [Mr Rampton]     I must make a note to prompt you to put that allegation to
18Dr Longerich --
19 A. [Mr Irving]     I shall, to all the witnesses.
20 MR JUSTICE GRAY:     Let us press on with the translation.
21 MR RAMPTON:     This question must be seen without sentimentality
22"die frage ist ohne jede sentimentalat so
23betrachten" correct?
24 A. [Mr Irving]     -- that is a fair translation.
25 Q. [Mr Rampton]     Good. We are not here in order to have sympathy with the
26Jews, "wir sind nicht dasu da, mitlied mit den juden"

.   P-143



 1correct so far?
 2 A. [Mr Irving]     Yes.
 3 Q. [Mr Rampton]     "Sondern nur mitleid mit unserem deutschen volk so haben"?
 4 A. [Mr Irving]     Just to have sympathy.
 5 Q. [Mr Rampton]     Rather we should sympathise with our own German people?
 6 A. [Mr Irving]     A loose translation, but I am not tendentious.
 7 Q. [Mr Rampton]     If the German people have now once again sacrificed as
 8many as 160,000 dead in the eastern campaign, then the
 9authors of this bloody conflict must pay with their
10lives (German spoken) authors?
11 A. [Mr Irving]     Yes.
12 Q. [Mr Rampton]     (German spoken) of this bloody conflict, therefore -- with
13their lives -- account for, must account for or pay for?
14 A. [Mr Irving]     Yes, this is Dr Goebbels.
15 Q. [Mr Rampton]     It may be?
16 A. [Mr Irving]     I am sorry it is, because it is not in the subjunctive.
17If it is not in reported speech. If he was reporting what
18Hitler had said, it would be not "hat" but "ete", that is
19the way reported speech is done in German.
20 Q. [Mr Rampton]     You see no ground for thinking that Hitler said anything
21like this?
22 A. [Mr Irving]     This is Dr. Goebbels' gloss on what Hitler had said.
23 Q. [Mr Rampton]     You think it is just a gloss on what Hitler said. Do you
24think it is a invention?
25 A. [Mr Irving]     That is what the language tells us Mr Rampton it is not in
26subjunctive, so it is not him reporting what somebody else

.   P-144



 1said.
 2 Q. [Mr Rampton]     Could you answer my question.
 3 A. [Mr Irving]     I have given you the answer.
 4 Q. [Mr Rampton]     Do you think it is an invention?
 5 A. [Mr Irving]     Is what an invention? He is writing down his own
 6opinions. Goebbels --
 7 Q. [Mr Rampton]     None of this is attributable to what Hitler said on this
 8occasion when he addressed the Reich and Gau leaders on
 912th December --
10 A. [Mr Irving]     -- Mr Rampton, you do not know and I do not know because
11we do not have a transcript of that speech.
12 MR JUSTICE GRAY:     How much do you say Mr Irving of this little
13snippet is a report of what Hitler said to the gaulieter?
14 A. [Mr Irving]     -- as I say, in all my editions of Hitler's War, Hitler
15made the original speech on January 30th 1939 and he
16repeatedly and ominously repeated and recorded what he had
17said on that occasion, saying I prophecised then and
18I will say it again and those who laughed then they are
19laughing on the other side of their faces now. This kind
20of thing. He said it something like eight or nine times
21during the war on 8th November 1942 and so on.
22 Q. [Mr Justice Gray]     Answer my question.
23 A. [Mr Irving]     It was one of his stock speeches. So I know with a pretty
24fair degree of certainty how much of this quotation Hitler
25actually said because Hitler was always saying the same
26thing and how much is probably Goebbels adding his own

.   P-145



 1private gloss.
 2 MR JUSTICE GRAY:     But this is something, this is in part at any
 3rate a report by Goebbels of what Hitler said in 1941 to
 4the gaulieter?
 5 A. [Mr Justice Gray]     I appreciate that, yes.
 6 Q. [Mr Rampton]     Nothing to do with 1939. My question, if I can ask you
 7for an answer, is how much do you say of this snippet from
 8Goebbels' diary is a report of what Hitler said to the
 9gaulieter?
10 A. [Mr Irving]     I would say half is.
11 Q. [Mr Justice Gray]     Which half? Half in reported speech and half where he
12repeats exactly the kind of sentence that Hitler had said
13so many times before, but what I will not accept is that
14he necessarily used the word vernichtung, when Hitler
15frequently used other equally vague and ambiguous words
16and indeed euphemisms. I am quite happy to accept that.
17And personally I would consider it deeply shocking if an
18historian was to pin any kind of hypothesis just on this
19third order information which is what this actually is.
20I know it has been done quite recently by Dr Christian
21Gerlach who is a young Hungarian historian. He has tried
22to pin a major hypothesis on it, but he is on the wooden
23path as the Germans says, and the fact that the sentences
24are not in the subjunctive makes it quite plain that
25Goebbels is not reporting what Hitler said. We can ask
26Dr Longerich this on the question of language if I am

.   P-146



 1right about the subjunctive.
 2 MR RAMPTON:     You will have the opportunity to do that and you
 3can ask Professor Evans too whose German is probably as
 4good as yours.
 5 A. [Mr Irving]     I doubt it but I would prefer to ask Dr Longerich.
 6 Q. [Mr Rampton]     He wrote it. Tell me this, is it your belief that Hans
 7Frank, Governor General, was a Poland, Eastern Poland, at
 8this meeting on 12th December?
 9 A. [Mr Irving]     He was a Reichsleiter. This was a speech to the
10Garleiters and the Reichsleiter, so the likelihood is that
11he was present.
12 Q. [Mr Rampton]     And the word "vernichtung" is not really capable of what
13we might call being characterized as a Goebbels' invention
14or exaggeration because it was after all the word that
15Hitler used in his speech in the Reichstager in 1939?
16 A. [Mr Irving]     Yes.
17 Q. [Mr Rampton]     So it would not be the least bit surprising if Hitler had
18used the same word on this occasion, would it?
19 A. [Mr Irving]     Yes.
20 Q. [Mr Rampton]     Why?
21 A. [Mr Irving]     The word "vernichtung" is not killing. It is not
22unambiguously killing. It is destruction.
23 Q. [Mr Rampton]     So you say. You say that. I do not know accept that
24answer?
25 A. [Mr Irving]     It is the primary meaning of the word.
26 Q. [Mr Rampton]     Whether you call it extermination or annihilation, which

.   P-147



 1are his two primary senses, it is a literal ----
 2 A. [Mr Irving]     Excuse me, extermination was not the primary sense.
 3 Q. [Mr Rampton]     No annihilation was?
 4 A. [Mr Irving]     It was the third sense. You said extermination or
 5annihilation which are its primary senses. Extermination
 6is not. It is number 3.
 7 Q. [Mr Rampton]     What difference do you see between annihilation and
 8extermination?
 9 A. [Mr Irving]     Can you read out the three meanings?
10 Q. [Mr Rampton]     No, I ask you in English. What difference do you see?
11 A. [Mr Irving]     I have been annihilated by these books but I have not been
12exterminated. Is that sufficient for you?
13 Q. [Mr Rampton]     Yes, and I annihilate you in cross-examination but I do
14not exterminate you, I hope! Of course I see the
15difference. Seriously, Mr Irving, please, annihilation of
16the Jewish race, come, it is not difficult. German is not
17a mystery language any more than English. What does it
18mean, be honest?
19 A. [Mr Irving]     If Adolf Hitler was considering annihilation to be the
20biological liquidation of the Jewish race, why would he
21have been talking the entire time about the Madagascar?
22Plan.
23 Q. [Mr Rampton]     He talked about the Madagascar plan I think as late as
24sometime in 1942 by which time he had already issued an
25order that the Madagascar plan was to be put to sleep?
26 A. [Mr Irving]     He talked about it on July 24th 1942.

.   P-148



 1 Q. [Mr Rampton]     Yes, and it was a dead duck?
 2 A. [Mr Irving]     This is your word, but why would Hitler talk about even in
 3private with his staff?
 4 Q. [Mr Rampton]     Because Hitler it would appears, if one reads his table
 5talk ----
 6 A. [Mr Irving]     He is talking about it in a conversation with Bormann and
 7Himmler, the people who we know were the actual murderers.
 8 Q. [Mr Rampton]     It is not to be taken seriously. It cannot be. The Brits
 9had occupied Madagascar in May of 1942?
10 A. [Mr Irving]     The British had occupied large parts of the world which
11the Germans subsequently reoccupied.
12 Q. [Mr Rampton]     Like Crete. So your thesis is that Hitler had it in mind
13the German Navy would travel all the way to the East Coast
14of Africa, that huge island, and spend a lot of ships and
15men capturing the island so they could put the Jews on it
16in 1942?
17 A. [Mr Irving]     I know I am not supposed to ask you questions, but you are
18not suggesting that the table talks are fake, are you?
19 Q. [Mr Rampton]     No, no that they are fake, no, far from it. On the
20contrary, the table talks are very good evidence of a man
21who sometimes waffles, sometimes deceives, sometimes talks
22at endless length about nothing very much?
23 A. [Mr Irving]     Rather like counsel in this case!
24 Q. [Mr Rampton]     If you say so.
25 MR JUSTICE GRAY:     Do not let us let it descend into...
26 A. [Mr Irving]     Mr Rampton -- my Lord, I am not sure if I can say this,

.   P-149



 1but Mr Rampton rather left the innuendo in the air -- I am
 2not sure if you are returning to this -- but I had this
 3diary passage in front of me and ignored it when I wrote
 4the book.
 5 MR RAMPTON:     Indeed.
 6 A. [Mr Irving]     Are you going to state that?
 7 Q. [Mr Rampton]     I was going to ask you. You can be personal about it if
 8you like, I do not mind, but I am going to ask you whether
 9you knew about this at the time you wrote these books.
10 A. [Mr Irving]     Thank you very much indeed. The answer is no.
11 Q. [Mr Rampton]     Why?
12 A. [Mr Irving]     I did not have it.
13 Q. [Mr Rampton]     You did not have it?
14 A. [Mr Irving]     No. This was part of the diaries that were in Moscow. A
15Goebbels', typical Goebbels' diary entry would run to 70
16or 50 or 100 pages. One Goebbels' diary entry in
17September 1943 is 143 pages of typescript for one day. In
18Moscow, we were extremely limited for our time, the days
19we were allowed to view these pages. I did, by chance,
20look at these pages around the German declaration of war
21on the United States as it was a matter of interest. My
22commission from The Sunday Times was to obtain the
23material relating to Germany's declaration of war on the
24United States, obviously for commercial reasons. I read
25those passages, those pages, copied them down.
26 MR JUSTICE GRAY:     Mr Irving, I just want to make sure I am

.   P-150



 1understanding what the question is directed to. Are you
 2saying that you did not have the passage quoted ----
 3 A. [Mr Irving]     By Longerich.
 4 Q. [Mr Justice Gray]     --- in Longerich ----
 5 A. [Mr Irving]     That is correct.
 6 Q. [Mr Justice Gray]     --- at page 61, 62, when you wrote Goebbels?
 7 A. [Mr Irving]     Indeed, my Lord, yes. I did not have it. It has only
 8recently been published by the Institute of History in
 9Munich. They obtained the diaries in 1992, shortly after
10I obtained take them, and it has taken them six or seven
11years to make them available to the general public.
12I still have not received the volumes that I ordered from
13the publishers.
14 MR RAMPTON:     I am not sure what you did have.
15 MR JUSTICE GRAY:     Can I just pursue this? I am still a little
16bit puzzled. You do make reference though in Goebbels to
17the speech that Hitler made to the Gauleiter?
18 A. [Mr Irving]     Purely because we know that there was a speech from Martin
19Bormann's diary.
20 MR RAMPTON:     You quote from it?
21 A. [Mr Irving]     And because Goebbels being a typical diarist, he kept on
22rambling back and forth as he dictated the diary to his
23Private Secretary, and he kept on coming back to the
24previous day's speech, but not the passage there.
25 MR JUSTICE GRAY:     So what are you saying -- just bear with me
26-- I am trying to follow.

.   P-151



 1 MR RAMPTON:     I am sorry, my Lord. I will shut up!
 2 MR JUSTICE GRAY:     If I can just speak for a minute? Are you
 3saying that what you say about Hitler's speech to the
 4Gauleiters in your book, Goebbels, comes from Bormann's
 5diary?
 6 A. [Mr Irving]     No, my Lord. It comes from a previous passages of the
 7Goebbels' diary. Had I read all 100 pages, I would have
 8stumbled across this paragraph too; but I can make it very
 9easy for your Lordship and for the Defendants by drawing
10their attention to the fact that in my discovery were the
11entire Goebbels' diaries that I obtained from Moscow.
12They could have come to court producing the pages which
13they had found in my discovery, proving that I had had
14them at the time I wrote both Goebbels and Hitler, and
15saying, "Here, he had them here, and yet he ignored them
16when he wrote that", and the answer is they have not done
17so because those pages are not in my documents because
18I did not get them.
19 Q. [Mr Justice Gray]     I am still puzzled. What exactly did you base what you
20write in Goebbels about the Gauleiters speech upon?
21 A. [Mr Irving]     I read the Goebbels' diary for December 13th 1941, just a
22few pages. On each page there would be about 200 pages in
23a big typeface. I read all the pages relating to the
24German declaration of war on the United States which had
25just been made that day; and then Goebbels mentions the
26fact that the previous day Hitler had delivered a speech

.   P-152



 1to the Gauleiters, and he mentions it in the terms that
 2I have quoted in full -- believe me, I quoted everything
 3that I had in my hands when I came back from Moscow
 4because it was interesting material. Had I read on
 5another 30 or 40 pages in the diary for that day, I
 6would probably have come across the full length
 7description, the report of the Gauleiters' speech on which
 8Longerich is relying. But I have not seen it from the
 9Moscow day in 1992 to about the middle of last year when
10it was finally made available and quoted by Christian
11Gerlach in his book and elsewhere. I am still not very
12impressed by it, but I do wish to make the point in case
13it was going to be inferred that I had had the material
14and not made use of it.
15 MR JUSTICE GRAY:     I think I understand.
16 A. [Mr Irving]     It would have been in my discovery and it was not.
17 MR RAMPTON:     How long are these daily entries in Goebbels'
18diary? I have not understood it.
19 A. [Mr Irving]     They vary in length depending on what is happening.
20 Q. [Mr Rampton]     How long is this entry for 13th December? It reports the
21previous day's events. How long is the entry for the
22speech of Hitler?
23 A. [Mr Irving]     I have no idea. I have not seen it.
24 Q. [Mr Rampton]     Well, you quoted from it.
25 A. [Mr Irving]     The previous entry?
26 Q. [Mr Rampton]     No, you quoted from it on page 383 of Goebbels. This is

.   P-153



 1what I find baffling.
 2 A. [Mr Irving]     Yes, but, you see, he kept on coming back to it, something
 3like that he would keep on coming back to as things
 4occurred to him. He is sitting in the room with his
 5Private Secretary, Dr Richard Otte, his chief
 6stenographer, dictating the following morning the events
 7of the previous day and he would keep coming back to
 8something. The diaries were not really intended for
 9publication in that form; they would have been edited.
10I came across an earlier reference to it in the diaries
11which I then have used here; but to this day I have not
12seen any full length description of the Gauleiters'
13speech.
14 MR JUSTICE GRAY:     How do you know it is 30 or 40 pages further
15on?
16 A. [Mr Irving]     Well, presumably it was because, anyway, it was not on the
17glass plate that I had, my Lord. The glass plate would
18have had 45 pages on it. The glass plate was either five
19times five or six times eight, depending on when it was
20made, pages per glass plate, and they were in complete
21disarray. So I would have had the plate which contained
22the bits I used, but not the bits which contained the
23speech on it. I had no commission from The Sunday Times
24to look into this kind of thing.
25 MR RAMPTON:     My Lord, may I take some instructions because
26I have just been given a rather important document?

.   P-154



 1 MR JUSTICE GRAY:     Do you want to have five minutes?
 2 MR RAMPTON:     Yes, I think I need five minutes actually because
 3it is not a document I am not aware of.
 4 MR JUSTICE GRAY:     I think, bearing in mind the transcribers'
 5task, but shall we say quarter past?
 6 (Short Adjournment)
 7 MR RAMPTON:     I am grateful to your Lordship. Can I say this?
 8I will say it to Mr Irving, if I may? Mr Irving, I say
 9two things now and I undertake to come back to it on
10Monday, not more this afternoon because I am not clued up
11enough yet, but I will be. First, I do not accept that
12the failure to use a subjunctive is necessarily a bar to
13the written material being a report of what somebody else
14says in German. You do not have to comment on this.
15I tell you this so that you will know what is coming.
16Second, that the Goebbels' diary entry which you quoted in
17the book is not as long as you said that it was. All
18right?
19 A. [Mr Irving]     I am sorry. I do not understand the second part of that,
20the Goebbels' diary entry which I quoted? The original
21entry you mean?
22 Q. [Mr Rampton]     Yes.
23 A. [Mr Irving]     The original entry from which I quoted.
24 Q. [Mr Rampton]     I do not know because I have not looked at your
25discovery. That is one of the things I want to do, is how
26long is the entry from which you quoted. I also want to

.   P-155



 1find out for certain what proportion of that bears to the
 2whole of the entry?
 3 A. [Mr Irving]     Can I suggest, therefore, that when we resume on Monday
 4I bring the entire December 1941 Goebbels' Diary that
 5I brought back from Moscow with me and can see what I had
 6and what I did not because it was in the discovery and you
 7must have seen.
 8 Q. [Mr Rampton]     I have not seen it, but I am sure we must have it.
 9 A. [Mr Irving]     Well, if you did not see it, it is not my fault. It was
10in your discovery and it was available.
11 Q. [Mr Rampton]     I am not criticising you, Mr Irving. I am quite happy to
12take blame for negligence, idleness, whatever you like.
13     Mr Irving, I want, therefore, to pass away from
14that, if I may, and, if his Lordship will allow me, to
15come back to it on Monday when I have done my homework and
16ask you about something else, which, as you said, it is
17probable that Hans Frank as one of the Reichleiters?
18 A. [Mr Irving]     He was ----
19 Q. [Mr Rampton]     He was General ----
20 A. [Mr Irving]     --- he was a Reichleiter and he would have been of the
21rank to attend that meeting.
22 Q. [Mr Rampton]     Surely he would; he was General Governor, was he not?
23 A. [Mr Irving]     Yes. In fact, he went to Berlin for the meeting, so there
24is no reason to dispute he was there.
25 Q. [Mr Rampton]     The odious (and it is not really meant to be a pun)
26Globocnik was one of his subordinates?

.   P-156



 1 A. [Mr Irving]     Of Hans Frank? At this time he was the Police Chief in
 2Lublin, I believe.
 3 Q. [Mr Rampton]     Yes.
 4 A. [Mr Irving]     Yes -- no, this is not true. The SS was -- they conducted
 5an independent existence in the Government General.
 6 Q. [Mr Rampton]     Right, OK. It does not matter. It is not important.
 7 A. [Mr Irving]     Do you wish me to expand on that?
 8 Q. [Mr Rampton]     No, not now.
 9 A. [Mr Irving]     No? There was no hierarchy bringing the two together.
10The name is Globocnik -- G-L-O-B-O-C-N-I-K.
11 MR RAMPTON:     Odilo Globocnik.
12 MR JUSTICE GRAY:     I think the surname will suffice.
13 MR RAMPTON:     Otherwise known as "Globos". May Mr Irving please
14be provided please with Professor Browning's report?
15 A. [Mr Irving]     Have we finished with Dr Goebbels?
16 Q. [Mr Rampton]     I have finished with that for the moment. As I say, I am
17coming back to that later on. I am trying to keep some
18semblance of chronological order. I am still in December
191941. Have you got Dr Browning there?
20 A. [Mr Irving]     Page 30 and 31?
21 Q. [Mr Rampton]     30 and 31, correct. Dr Browning also quotes the speech of
22Hitler, but in abbreviated form, in other words, he does
23not quote as much of the Goebbels' diary entry as does
24Dr Longerich.
25 A. [Mr Irving]     Yes.
26 Q. [Mr Rampton]     Do you see that?

.   P-157



 1 A. [Mr Irving]     Yes.
 2 Q. [Mr Rampton]     He goes down as far as saying (which you agree is a
 3correct translation, well, I do not know if you do), that
 4was no figure of speech, top of 31, "The World War is
 5here. The Vernichtung", whether it is destruction,
 6extermination, annihilation or whatever, "of the Jews must
 7be the inevitable consequence".
 8 A. [Mr Irving]     Well, that is again a contentious and tendentious
 9translation.
10 MR JUSTICE GRAY:     Well, we have been through that I think
11sufficiently.
12 MR RAMPTON:     We have been through that. That is why I used the
13word "vernichtung"?
14 A. [Mr Irving]     Well, but it is the word "Jews" also that we have to look
15at there, is it not? Destruction of the Jews. But this
16is ----
17 MR JUSTICE GRAY:     That is quite plain because he refers to "des
18Judens", so there really cannot be any argument about
19that, can there?
20 A. [Mr Irving]     No. "[German].. Judentums", no.
21 Q. [Mr Justice Gray]     There is not reference to "Judentums".
22 A. [Mr Irving]     It is the fifth line, so he has allowed himself a lot of
23poetic licence in his translation. My Lord, I have to be
24careful about what I accept here I cannot be heard to
25accept something that is not ...
26 Q. [Mr Justice Gray]     You are quite right. I think I was wrong. You are quite

.   P-158



 1right?
 2 MR RAMPTON:     You were in that respect, my Lord, but not, in
 3fact, in the earlier part of which forms the
 4context. "Zeeda ... [German] ... Vuren" and "ihre" there
 5is "their" which is the Jews' is it not?
 6 MR JUSTICE GRAY:     But in connection with "Vernichtung", it is
 7"Judentum".
 8 MR RAMPTON:     Both have "vernichtung" attached to them.
 9 A. [Mr Irving]     But I believe it is the next part you wish to continue
10with.
11 Q. [Mr Rampton]     It is the next part. It is what Hans frank is reported as
12having said when he got back to the General Government on
1316th December 1941. This is printed in what one might
14call the official common place book, would it be right?
15It is the Tagesbuch. That is an official record, is it
16not, of some kind?
17 A. [Mr Irving]     It is the abridged version of the multi-volumed diaries
18and conference records of the General Governor, Hans
19Frank.
20 Q. [Mr Rampton]     And you have used it yourself?
21 A. [Mr Irving]     I used the original manuscript, yes. I did not use the
22printed edition. It is in my discovery.
23 Q. [Mr Rampton]     You have used this passage?
24 A. [Mr Irving]     I have indeed and I used the original manuscript and not
25the printed version.
26 Q. [Mr Rampton]     Maybe so. At the end of this first page, 31, in

.   P-159



 1translation, perhaps here the German does not really
 2matter, perhaps you will agree. The first complete
 3paragraph at the bottom of -- sorry, last paragraph on the
 4page: "What is to happen to the Jews? Do you believe
 5that they will be lodged in settlements in Osland?" That
 6is the Baltic countries, is it not, Osland?
 7 A. [Mr Irving]     Yes.
 8 Q. [Mr Rampton]     "In Berlin we were told, 'Why all this trouble? We cannot
 9use them in the Osland or the Reichcommissariat either.
10Liquidate them yourselves!'".
11     Then goes on, apparently, Governor Frank: "We
12must destroy the Jews wherever we encounter them and
13wherever it is possible in order to preserve the entire
14structure of the Reich". I would ask you to turn over the
15page, Mr Irving, where at the bottom of page 32 you will
16find the German of ----
17 A. [Mr Irving]     That is what I have just been reading, yes.
18 Q. [Mr Rampton]     Yes. Has Professor Browning translated it correctly?
19 A. [Mr Irving]     Yes. I used a different translation in my own book, but
20this is an adequate translation.
21 Q. [Mr Rampton]     That is right, is it not?
22 A. [Mr Irving]     Yes.
23 Q. [Mr Rampton]     But he has not translated the last two lines on page 32.
24Would you please read those and tell us what they mean?
25 A. [Mr Irving]     Well, it is an incomplete fragment.
26 Q. [Mr Rampton]     He has put an ellipsis?

.   P-160



 1 A. [Mr Irving]     He has put what?
 2 Q. [Mr Rampton]     He has put an ellipsis in, has he not, to show that ----
 3 A. [Mr Irving]     Yes, but it is the second half of a sentence and, as you
 4know, in German, the Germans put their verbs at the end,
 5so it...
 6 Q. [Mr Rampton]     Yes. Be kind enough just to translate what we have.
 7 A. [Mr Irving]     "But if we then undertake incursions which in some way
 8lead to a destructive result or success and, indeed, in
 9connection with the measure -- in connection with the
10great measure which is to be conferred upon at the Reich"
11-- this is a reference to the coming Bunzig conference,
12presumably.
13 Q. [Mr Rampton]     That is right.
14 A. [Mr Irving]     It is a truncated sentence it is difficult to find your
15way into without the beginning. "Vernichtungs Erfolg" is
16the word you want to see. V-E-R-N-I-C-H-T-U-N-G-S
17E-R-F-O-L-G.
18 Q. [Mr Rampton]     Does it mean this, Mr Irving, at any rate the last part of
19that first of the two bottom lines: "It will anyway come
20to a complete or successful destruction", "Vernichtungs
21Erfolg"?
22 A. [Mr Irving]     That would be a rigid and unacceptable translation.
23I would say, "If we succeed in wiping them out".
24 MR JUSTICE GRAY:     Which does "Erfolg" mean?
25 A. [Mr Irving]     "Success", "If we succeed in wiping them out",
26"Vernichtung" or "If we succeed in destroying them".

.   P-161



 1 MR RAMPTON:     A successful wiping out?
 2 A. [Mr Irving]     A successful wipe out, yes, but German sentences you
 3frequently have to break up and recast in order to make
 4them acceptable.
 5 Q. [Mr Rampton]     I am not playing tricks. I will try to find the whole of
 6that.
 7 A. [Mr Irving]     I am trying to help you, Mr Rampton.
 8 Q. [Mr Rampton]     I am being passed ----
 9 MR JUSTICE GRAY:     Can I just be clear? Are you accepting that
10what Hans Frank is recording here is what Hitler said in
11Berlin to the Gauleiter?
12 A. [Mr Irving]     Yes -- no, he has not made a reference to the Gauleiters
13specifically.
14 Q. [Mr Rampton]     I know he has not made a reference to it ----
15 A. [Mr Irving]     No.
16 Q. [Mr Justice Gray]     --- but he says: "In Berlin we were told", and I rather
17inferred that Mr Rampton was suggesting that that was from
18Hitler's speech to the Gauleiter?
19 A. [Mr Irving]     I think it would be quite a dangerous leap to make.
20 Q. [Mr Justice Gray]     Am I wrong about that?
21 A. [Mr Irving]     It is put in ----
22 MR RAMPTON:     No, it is not quite what I had put because I do
23not have the evidence to make that kind of suggestion.
24I am suggesting that while Hans frank was in Berlin,
25somebody told him, and he was there probably amongst other
26reasons for the occasion of Hitler's speech ----

.   P-162



 1 A. [Mr Irving]     Yes.
 2 Q. [Mr Rampton]     -- somebody told him, it might have been Hitler, it might
 3have been Heydrich, that they have to see to the
 4liquidation of the Jews themselves in the East. That does
 5mean that, does it not?
 6 A. [Mr Irving]     I do not think the word they use is "liquidation". He
 7says "wipe out", "If we have a success in wiping them out,
 8destroying them", "Vernichtung", which can done in a
 9number of ways as I gave the instance with Christianity or
10with drug addiction.
11 Q. [Mr Rampton]     I am not sure you are right about that. The word is
12"liquidiet zi selbe"?
13 A. [Mr Irving]     I am sorry, I was looking at the wrong part.
14 Q. [Mr Rampton]     No the quote is: "Man hut uns in Berlin gesagt", "We were
15told in Berlin"?
16 A. [Mr Irving]     Oh, unquestionably, yes.
17 Q. [Mr Rampton]     "Liquidate them yourselves"?
18 A. [Mr Irving]     Yes.
19 Q. [Mr Rampton]     So ----
20 A. [Mr Irving]     And the reason that Browning knows about this is because
21he found this quotation in my books. I am the first one
22to have dug it out.
23 Q. [Mr Rampton]     Brownie points to you, Mr Irving, but the fact is that
24Hans Frank is saying on this occasion when he gets back to
25Poland -- I think this took place in Krakow, did it not?
26 A. [Mr Irving]     His headquarters is in Krakow, yes.

.   P-163



 1 Q. [Mr Rampton]     He is saying: "When we were in Berlin" ----
 2 A. [Mr Irving]     "They told us".
 3 Q. [Mr Rampton]     --- "they told us, 'We can't solve the Jewish problem for
 4you. We can't house them. Liquidate them yourselves"?
 5 A. [Mr Irving]     Yes. Berlin, of course, was the seat of the
 6Reichssicherheits Hauptamt, of Reinhardt Heydrich.
 7 Q. [Mr Rampton]     I know, that is Heydrich's headquarters too.
 8 A. [Mr Irving]     Hitler's headquarters, well, in East Prussia, not in
 9Berlin.
10 Q. [Mr Rampton]     Certainly it is though, whether Hitler took part in those
11discussions or not, I cannot tell you. I do not propose
12that he did. I do not ----
13 A. [Mr Irving]     I think it is a very interesting fragment, a verbatim
14transcript to which one can attach a great deal of
15importance rather than reported third person subjunctive,
16non-subjunctive stuff. This is Hans Frank's actual words
17taken down by a stenographer and that is why I was very
18pleased to quote them in full.
19 Q. [Mr Rampton]     Yes, surely. We are not here necessarily, Mr Irving,
20talking about the Jews that the Einsatzgruppen found in
21Russia; rather the contrary, do you not think?
22 A. [Mr Irving]     The German Jews.
23 Q. [Mr Rampton]     We are talking about two groups of Jews if we are talking
24about Hans Frank and the General Government?
25 A. [Mr Irving]     Yes.
26 Q. [Mr Rampton]     We are talking about German and other Jews, Slavakia or

.   P-164



 1wherever else, French, Dutch, Belgium and so on, that were
 2shipped to East, transported I mean, but we are also
 3talking about the indigenous Jews at Poland, are we not?
 4 A. [Mr Irving]     Primarily at this time the indigenous Jews. I do not
 5think that any major shipment of Jews had started from
 6Western Europe in Poland or the General Government at this
 7time.
 8 Q. [Mr Rampton]     Do you agree that Eichmann said at the Bunzig conference,
 9I think it was he, it may have been somebody else, it may
10have been somebody else who gave the figure, there were
11roughly two and quarter, two and a half million Jews
12living in Poland at that time in early 1942?
13 A. [Mr Irving]     That is almost certainly the right figure, but Eichmann
14did not speak at the Bunzig conference. He just kept the
15minutes as I understand it.
16 Q. [Mr Rampton]     But that is the figure that was given at the Bunzig
17conference?
18 A. [Mr Irving]     I will take your word for it, Mr Rampton.
19 Q. [Mr Rampton]     You have read it. I am sure you have read the protocal,
20the minute or whatever it is. So what Hans Frank is
21saying here is: "The Jews that we are responsible for
22(getting rid of) numbering roughly two and a quarter
23million, we have been told by Berlin we have to liquidate
24ourselves". That is what it is saying, is it not?
25 A. [Mr Irving]     No. What he is saying is: "Do not start dumping Jews on
26us. We have got no room for the ones we have got. Solve

.   P-165



 1your own problems".
 2 Q. [Mr Rampton]     No, "in Berlin we were told"?
 3 A. [Mr Irving]     Yes.
 4 Q. [Mr Rampton]     Not, "I said to the people in Berlin"?
 5 A. [Mr Irving]     Yes.
 6 Q. [Mr Rampton]     "Man hat" is passive?
 7 A. [Mr Irving]     Yes.
 8 Q. [Mr Rampton]     "Uns gesagt" means "they told us in Berlin"?
 9 A. [Mr Irving]     "Why all this bother? Why all this fuss and bother?"
10 Q. [Mr Rampton]     That is right.
11 A. [Mr Irving]     They are talking about what they are going to be doing
12with the Jews that people are talking about now tossing
13out of Western Europe, and Hans Frank has been fighting
14hand and foot at having any dumped in his domain.
15 Q. [Mr Rampton]     Yes. He has been told he has got to do it himself?
16 A. [Mr Irving]     No, he has been you take what you are given. He is
17saying, "I don't want them." I know the background to
18this story, Mr Rampton.
19 Q. [Mr Rampton]     What do the words mean, I am sorry, Mr Irving, I thought
20you had agreed this was an accurate translation?
21 A. [Mr Irving]     It is accurate.
22 Q. [Mr Rampton]     "In Berlin we were told, 'Why all this trouble? We cannot
23use them in the Osterland or Reichskomissariat either.
24Liquidate them yourselves.'"?
25 A. [Mr Irving]     No. No one is talking about shipping Jews from the
26Osterland or the Ukraine into Berlin. The shipment is

.   P-166



 1going other way round.
 2 MR JUSTICE GRAY:     What Mr Rampton is putting to you is that
 3that phrase "liquidate them yourselves" is in effect a
 4direction from Berlin to the General Government.
 5 A. [Mr Irving]     No, sir. I read it differently both in the original and
 6even now. This is Hans Frank recalling what he told the
 7Berliners saying, "Stop dumping your Jews on us, you solve
 8your own problems, you liquidate them yourselves".
 9 MR RAMPTON:     I am going to refer you to the full text of what
10Hans Frank said in a moment. Can you first of all read
11your own version of this, please, on page 428 of Hitler's
12War 1991.
13 A. [Mr Irving]     Can we look at it in the earlier version because it is
14totally unchanged?
15 Q. [Mr Rampton]     No, it is not in the earlier version so far as I know.
16 A. [Mr Irving]     It definitely it is. It is in every book that I have
17written. Which page, Mr Rampton?
18 Q. [Mr Rampton]     If you want the earlier version, I am not sure it is in
19the earlier version, but I will check that. Yes, it is.
20If you want to use the earlier version, first, I have no
21problem with that. Page 332.
22 A. [Mr Irving]     Yes, "Yet the blood purge continued".
23 Q. [Mr Rampton]     Yes. I am waiting for his Lordship's file to emerge.
24 MR JUSTICE GRAY:     Hitler's War.
25 MR RAMPTON:     It is 1977 Hitler's War, my Lord, I think the
26first volume.

.   P-167



 1 MR RAMPTON:     It is I think more or less identical to what is in
 2the 1991 edition.
 3 MR JUSTICE GRAY:     Have you got a reference for that?
 4 MR RAMPTON:     Yes, that is page 427 it starts, the last large
 5paragraph, the last three lines. I will read. It
 6immediately follows the reference to the Himmler telephone
 7note of 1st December. Mr Irving writes: "Yet the blood
 8purge continued".
 9 A. [Mr Irving]     Shall I read it? It is my book.
10 Q. [Mr Rampton]     No, Mr Irving. No, I will read it: "Yet the blood purge
11continued. The extermination programme had gained a
12momentum of its own. Hans Frank announcing to his Lublin
13Cabinet on December 16th 1941, that Heydrich was calling a
14big conference in January on the expulsion of Europe's
15Jews to the East, irritably exclaimed: Do you imagine
16they are going to be housed in neat estates in the Baltic
17provinces! In Berlin' - and with Hitler in East Prussia
18this can only be taken as a reference to Heydrich's
19agencies -" -- I am coming back to that -- "they tell us",
20they, the people in Berlin, "tell us", the people in
21charge in the General Government: Why the caviling?
22We've got no use for them either ... liquidate them
23yourselves!" The "yourselves" are the people in Poland?
24 A. [Mr Irving]     Yes. Well, no, not necessarily. Of course I would just
25like to comment. That is an odd passage for a Holocaust
26denier to put into a book, is it not, this entire passage;

.   P-168



 1somebody who is allegedly denying the Holocaust he puts in
 2this extraordinary passage?
 3 Q. [Mr Rampton]     It is there, is it not?
 4 A. [Mr Irving]     It is indeed, and I am accused of being a Holocaust
 5denier.
 6 Q. [Mr Rampton]     Maybe. Mr Irving, the true sense of that is that Hans
 7Frank was told while he was in Berlin that it was his
 8problem how to liquidate Poland's two or three million
 9Jews, is it not?
10 A. [Mr Irving]     Mr Rampton, I am sure you have read any number of
11transcripts of verbatim conferences. Hans Frank is quite
12clearly not speaking from a prepared script. He is
13addressing a meeting, his mind darting here and there. He
14is giving snatches of what he was told in Berlin by them.
15He is giving snatches of what his retort was. He is not
16telling the stenographer, "close quotes, open quotes,
17close quotes again", and the stenographer is taking it
18down as it said.
19 MR JUSTICE GRAY:     That may be, but you would have to accept,
20would you not, that the way you have recorded this in
21Hitler's War is that Frank was talking about what Berlin
22had told him and the General Government?
23 A. [Mr Irving]     I cannot say, my Lord. I do not know who what is talking
24to whom in that final three words, "liquidate them
25yourselves". It is not evident on the transcript either.
26So I have left it, I saw no reason to be specific in my

.   P-169



 1book as to who was talking to whom. I would have
 2introduced probably an ambiguity one way or the other. So
 3I left it just as it was in the transcript which I thought
 4was the most accurate thing I could do. We do not know if
 5it is Poland talking to Berlin or Berlin talking to
 6Poland.
 7 Q. [Mr Justice Gray]     But if you are disassociating Hitler from what is said, as
 8you plainly are, does that not indicate that you must be
 9seeking to conveying to readers that the instructions are
10coming from Berlin?
11 A. [Mr Irving]     It is unimportant to me, my Lord, which way those
12instructions are coming. It is coming all at the same
13level. Berlin is shrieking at Krakow and Krakow is
14shrieking at Berlin, and Hitler is somewhere else. This
15is a biography of Adolf Hitler. It is not a book about
16the Holocaust.
17 Q. [Mr Justice Gray]     If there were instructions going from Krakov to Berlin
18there would be no point in disassociating Hitler from it?
19 A. [Mr Irving]     Hitler was not in Berlin, my Lord. Hitler at this time,
20December 16th, was in his headquarters in East Prussia.
21 Q. [Mr Justice Gray]     I think you understand the question.
22 A. [Mr Irving]     That is the point I make.
23 MR RAMPTON:     Mr Irving, that simply will not do. In Berlin you
24break off to parenthesize, if I can invent that word, "and
25with Hitler in East Prussia this can only be taken as a
26reference to Heydrich's agencies (in Berlin)"?

.   P-170



 1 A. [Mr Irving]     Yes.
 2 Q. [Mr Rampton]     "They" Heydrich's agencies "tell us: Why the caviling?
 3We" in Berlin "have no use for them either. Liquidate
 4them yourselves", you, the people in Poland?
 5 A. [Mr Irving]     These are your interpolations you are putting in of
 6course.
 7 Q. [Mr Rampton]     No, I am reading your words, Mr Irving?
 8 A. [Mr Irving]     No, I did not put in those interpolations.
 9 Q. [Mr Rampton]     That is what it means though, is it not?
10 A. [Mr Irving]     That is what you submit.
11 Q. [Mr Rampton]     Do you disagree?
12 A. [Mr Irving]     I rest entirely on the way that I quote this very
13ambiguous fragment of stenographic text without making any
14interpolations one way or the other. As I explained in
15the Hitler biography, I did not consider it to be
16necessary really to point out or to try to work out who
17was talking to whom. I found it such an
18extraordinary ----
19 MR JUSTICE GRAY:     So your evidence is, I am sorry to interrupt
20you, that this is capable at any rate of meaning that
21Krakov was telling Heydrich in Berlin "liquidate them
22yourselves", that is your evidence?
23 A. [Mr Irving]     This is the far more logical interpretation, because
24I know from all the other documents at this time that Hans
25Frank was hysterical at the mention that train loads of
26Jews would be sent to the Governor General where he had

.   P-171



 1problems housing and feeding people anyway, and he was
 2saying to Berlin: "Stop trying to shift your problems
 3into Poland. We are not just a dumping ground for your
 4Jews." This comes up in very many of the conferences at
 5that time. There is one particular record I remember
 6taking by Martin Bormann in October 1941, and that
 7emboldens me in putting the alternative interpretation,
 8the alternative arrow direction, shall we say, on that
 9final three words, but rather than get involved in that
10rather irrelevant discussion in this book which is about
11Hitler, I just left this extraordinary fragment of
12stenographic record, this transcript, as it is, because it
13is so pregnant with hatred and brutality and total
14callousness towards human life, and it indicates the kind
15of level at which these decisions were taken and the kind
16of gormless mentality of the people who took these
17decisions who were later quite rightly hanged for it.
18 MR RAMPTON:     My Lord, I am not going to push that particular
19point any further. I am going to come back, perhaps not
20today, to the full text of what Hans Frank said for
21context. I am getting some clever people to translate it
22as I speak.
23 A. [Mr Irving]     Mr Rampton, can I then in that case bring on Monday the
24text I have, which may or not be identical with the text
25that you have.
26 Q. [Mr Rampton]     I think you certainly should.

.   P-172



 1 A. [Mr Irving]     It may be shorter or longer. This is the reason why I say
 2it.
 3 Q. [Mr Rampton]     You certainly should.
 4 A. [Mr Irving]     I have the pages in the original photocopy.
 5 Q. [Mr Rampton]     That is absolutely fine. Bring whatever you like you feel
 6you need to defend yourself with. It is right, is it not,
 7that having written both in 1977, as I say if you want to
 8check it, on pages 427, 428 of 1991 Hitler's War, which
 9I think is identical ----
10 A. [Mr Irving]     Yes.
11 Q. [Mr Rampton]     --- having written "man hat uns gesagt" or "in Berlin" and
12then a quote, on page 386 of Goebbels you write this.
13 A. [Mr Irving]     Yes.
14 Q. [Mr Rampton]     I will read it out: "Hans Frank's Government General was
15flatly refusing to accept any more", Jews that is. "Frank
16had exclaimed irritably at one of his cabinet meetings in
17Krakov that Berlin was telling them they got no use for
18the Jews either, 'liquidate them yourselves', was his,
19that is Frank's, retort?
20 A. [Mr Irving]     Yes.
21 Q. [Mr Rampton]     I notice, and perhaps you did too, as I read that there is
22no reference there to Heydrich's agencies or to Hitler
23being absent, is there?
24 A. [Mr Irving]     We are talking about Berlin and we are talking about Frank
25retorting. Having now advanced something like ten years
26down the road of research and read a very large number of

.   P-173



 1further documents relating to this particular context and
 2these questions, I am that much more certain that the
 3arrow goes from East to West rather than from West to East
 4as far as those three words are concerned.
 5 Q. [Mr Rampton]     Be honest, Mr Irving, in Hitler's War ----
 6 A. [Mr Irving]     Excuse me, I am speaking here on oath, I am being honest.
 7 Q. [Mr Rampton]     I do not believe you are. In Hitler's War the arrow went
 8firmly from West to East. You changed the account for
 9Goebbels, did you not? That is why there is no reference
10to Hitler or to Heydrich in this text?
11 A. [Mr Irving]     I do not accept that contention at all. In Hitler's War
12I gave the transcription exactly as it occurs in the
13records and I left it for the reader to make up their own
14mind. Here I am that much more certain which way the
15arrow went.
16 Q. [Mr Rampton]     Why did you insert in Hitler's War the parenthesis "and
17with Hitler in East Prussia this can only be taken as a
18reference to Heydrich's agencies"?
19 A. [Mr Irving]     This is like an obiter from on high where the judge says
20to the jury, "I think that you need to take account of
21this but of course make up your own mind", and where you
22are telling the reader, well, make up your own mind, here
23is what is what the transcript says, but just in case you
24have forget it, Adolf Hitler lives in East Prussia and he
25is not in Berlin on the day this speech is being made.
26 Q. [Mr Rampton]     He was not in Berlin on 16th December 1941, Mr Irving?

.   P-174



 1 A. [Mr Irving]     Yes.
 2 Q. [Mr Rampton]     Because on 16th December 1941 he went to the Wolf's lair,
 3did he not?
 4 A. [Mr Irving]     He was certainly, at the time that Frank was speaking here
 5Hitler was back in East Prussia.
 6 Q. [Mr Rampton]     On page 383 ----
 7 A. [Mr Irving]     May I also say that if he was referring to Hitler by the
 8use of the word "man", which is the equivalent of the
 9French "on".
10 Q. [Mr Rampton]     I did not say that.
11 A. [Mr Irving]     If he was referring to Hitler then he would have said, "at
12the very highest level we have been told". He would not
13have used the rather offensive "man".
14 Q. [Mr Rampton]     "On" in French, I do not know any German but I have quite
15good French, Mr Irving, "on" in French is not the least
16bit offensive. It is merely a form of expressing a
17passive sense.
18 A. [Mr Irving]     Yes, but he would have been specific. He would have said
19"uns getstella(?)" or [German spoken] but more likely
20"uns getstella(?)" at the highest level.
21 Q. [Mr Rampton]     According to your first version, "Heydrich's agencies".
22 A. [Mr Irving]     Had he wished to refer to Hitler by that, yes.
23 Q. [Mr Rampton]     To what?
24 A. [Mr Irving]     If by the use of the word "man" in Berlin he would not
25have used the very impersonal version of saying "man".
26 Q. [Mr Rampton]     Anyway, you have got Hitler away from whatever Frank was

.   P-175



 1told because you have got him in East Prussia?
 2 A. [Mr Irving]     Continue, yes.
 3 Q. [Mr Rampton]     Yes. In fact he did not go to the Wolf's lair until 16th
 4December, did he?
 5 A. [Mr Irving]     He probably left Berlin on the night of the 15th, took the
 6overnight train back to East Prussia. I could tell you
 7from the Hitler's War, the headquarters' war diary which
 8I have in the blue volume there.
 9 Q. [Mr Rampton]     All I can tell you is that in Goebbels Mastermind of the
10Third Reich on page 383 you write this: "Returning by
11train on December 16th to the Wolf's lair"?
12 A. [Mr Irving]     Yes.
13 Q. [Mr Rampton]     "Hitler dictated a famous order", something like that?
14 A. [Mr Irving]     Yes, but I can tell you whether he left Berlin on the
15night of the 15th or not.
16 Q. [Mr Rampton]     So he was in Berlin when Hans Frank was in Berlin
17receiving this instruction?
18 A. [Mr Irving]     You are now referring to 12th December?
19 Q. [Mr Rampton]     Whenever. He did not leave Berlin until the night of the
2015th or the morning of the 16th. Hans Frank has got to go
21further. He has got to go all the way back to Krakov
22which is further than East Prussia?
23 A. [Mr Irving]     I am sorry to admit I am now totally at sea. Which times
24in Berlin are we talking about?
25 Q. [Mr Rampton]     Hans Frank is reporting what he was told in Berlin. When
26he was ----

.   P-176



 1 A. [Mr Irving]     Yes, by somebody whom we have not identified.
 2 Q. [Mr Rampton]     Maybe, but Hitler was in Berlin at that time?
 3 A. [Mr Irving]     He was in Berlin on, well, he was in Berlin on the 12th,
 413th and 14th definitely.
 5 Q. [Mr Rampton]     Yes, and probably on the 15th as well?
 6 A. [Mr Irving]     Yes, but we do not know if he is referring to Hitler. He
 7says "man". "We have been told in Berlin". Berlin's
 8population is two million.
 9 Q. [Mr Rampton]     I wish you would not make speeches, Mr Irving, but listen
10to my questions. Why was it relevant to observe, if it is
11perfectly certain or more or less certain or as certain as
12an historian would like, that Frank and Hitler were in
13Berlin at the same time, why do you say "in Berlin" close
14quotes, " - and with Hitler in East Prussia this", that is
15to say Berlin, "can only be taken as a reference to
16Heydrich's agencies"?
17 A. [Mr Irving]     In Berlin people tell us -- had it been Adolf Hitler who
18had told him this, he would not have said the slightly
19depricating "in Berlin people tell us", certainly not in
20the company of Reichsministers and Reichsleiters.
21Somebody would have reported back.
22 MR JUSTICE GRAY:     You are slightly at cross purposes. I think
23all that Mr Rampton is putting at the moment is that they
24were in Berlin at the same time?
25 A. [Mr Irving]     This I accept.
26 Q. [Mr Justice Gray]     Namely, Frank and Hitler.

.   P-177



 1 A. [Mr Irving]     This I accept.
 2 Q. [Mr Justice Gray]     So your point on "man" and whether that is significant is
 3a different point.
 4 A. [Mr Irving]     Perhaps I am jumping the gun on that, yes.
 5 MR RAMPTON:     You are. You are not seeing, whether deliberately
 6or not I know not, you are not seeing what I am putting to
 7you. What I am putting to you, and I will put it
 8directly, although I would have thought it was pretty
 9obvious, is that with this little phrase in Hitler's War
10both editions and with Hitler in East Prussia, this can
11only be taken as a reference to Heydrich's agency,
12"continue, they tell us", etc., "to liquidate them
13yourselves". By doing that what are you actually telling
14the reader is that Hitler was not in Berlin at the time
15when Hans Frank was given this instruction?
16 A. [Mr Irving]     I think probably the parenthesis should have been shifted
17forward two or three words to include "also people tell
18us", "in Berlin people tell us", so that i makes it quite
19plain that I am relying on the parenthesis both on the "in
20Berlin" and the rather depricatory world "people tell us".
21 MR JUSTICE GRAY:     That is not quite an answer to the question.
22 MR RAMPTON:     It is not.
23 A. [Mr Irving]     Very well. Yes, I will accept the point which you make,
24yes.
25 MR RAMPTON:     Had you sought historical accuracy, that
26parenthesis would have been attached to December 16th

.   P-178



 11941, would it not, at the top of the page: "Announcing
 2to his Lublin cabinet on December 16th 1941 Hitler was in
 3East Prussia at the time", if it was of any interest to
 4anybody. What you have tried to do, you have distorted
 5the chronology in order to make perfectly certain that
 6Hitler cannot have anything to do with this appalling
 7instruction to Hans Frank?
 8 A. [Mr Irving]     I have not distorted any chronology at all. The dates are
 9perfectly certain. On December 16th, at the time of this
10speech by Governor Frank to his cabinet, Hitler is in the
11Wolf's lair in East Prussia, as I said.
12 Q. [Mr Rampton]     Mr Irving, perhaps you are tired, perhaps I am tired.
13 A. [Mr Irving]     I am not so tired that I do not remember dates that I have
14written in books.
15 Q. [Mr Rampton]     Mr Irving, I am sorry, it is not the problem that you do
16not remember the dates. I am afraid I think you remember
17them only too well. I will try once again then and I am
18going to leave it. Why do you not have the text of
19Hitler's War in front of you?
20 A. [Mr Irving]     I have it open, yes.
21 Q. [Mr Rampton]     428, it does not matter which edition: "Hans Frank
22announcing to his Lublin cabinet on December 16th 1941
23that Heydrich was calling a big conference in January on
24the expulsion of Europe's Jews to the East, irritably
25exclaimed", blah-blah-blah "! 'In Berlin' and with Hitler
26in East Prussia, this can only be taken as a reference to

.   P-179



 1Heydrich's agencies", blah-blah-blah, "liquidate them
 2yourselves."
 3 A. [Mr Irving]     Yes.
 4 Q. [Mr Rampton]     Now that is apt to suggest to any person who is even
 5marginally literate that Hitler was not in Berlin at the
 6time when Hans Frank was and was given that instruction?
 7 MR JUSTICE GRAY:     You have got a "yes" to that already, Mr
 8Rampton.
 9 MR RAMPTON:     I have, have I?
10 A. [Mr Irving]     I fully understand the point you are trying to make and
11that is a narrow interpretation of those words which you
12are trying t slant or guy rope in the direction you want
13them. The point I am making is that Hitler's headquarters
14is historically in East Prussia. The seat of the
15Reichssicherheitshauptamt under the SS is in Berlin, and
16Governor Frank making his speech is in Krakow. When he
17talks about Berlin he is talking about the SS. When he
18wants to talk about Hitler he will say "East Prussia".
19When he says, "in Berlin they tell us this or tell us
20that", he is not talking about a specific meeting or a
21specific event where they have been given these
22instructions. He is just talking about these block heads,
23these mutton heads in Berlin who imagine that life can be
24made so easy that they just put the people on trains and
25send them to Poland.
26 Q. [Mr Rampton]     Yes, Mr Irving. Then why insert the reference to Hitler

.   P-180



 1at all in relation to what Frank was told in Berlin?
 2 A. [Mr Irving]     Because I was trying to put into one terse line of text
 3given the constraints of writing a book that is going to
 4be less than 1,000 pages what I just set out to you in
 5probably ten lines of text.
 6 Q. [Mr Rampton]     Why? What has Hitler got to do with this?
 7 A. [Mr Irving]     This is his Hitler's biography. This is about Adolf
 8Hitler.
 9 Q. [Mr Rampton]     Unless there is evidence that Hitler said this to Frank
10himself, you would not bother even to mention Hitler?
11 A. [Mr Irving]     It may be that ignorant people will assume that because
12Adolf Hitler is the Reichschancellor and his capital is
13Berlin, therefore, the reference to "people" is Adolf
14Hitler. I am trying to make sure that ignorant people do
15not draw the wrong reference.
16 Q. [Mr Rampton]     In order that ignorant people should not have to have it
17explained why it is not likely this order came from
18Hitler, I beg to differ with you about that, but in order
19that ignorant people, as you call them, should have that
20explained to them neatly, you actually tell a neat little
21fib. You get Hitler out of Berlin when in fact he was
22there?
23 A. [Mr Irving]     But there is nothing that is the least bit wrong about the
24sentence I put in there. With Hitler in East Prussia, his
25headquarters were in East Prussia, the references to
26Berlin can only be taken as references to the SS, the

.   P-181



 1Heydrich's agencies, who were in fact wholly responsible
 2for these operations. As we know from other sources,
 3Hitler was intervening constantly to stop these things
 4being done.
 5 MR JUSTICE GRAY:     I have got the point anyway.
 6 MR RAMPTON:     Yes, I am not going on.
 7 A. [Mr Irving]     It is the reference to general geography; not to specific
 8meetings or conferences that you have only recently heard
 9about, no matter how dramatic these discoveries may be or
10made to seem.
11 Q. [Mr Rampton]     Will your Lordship forgive me a moment? May Mr Irving
12please be given bundle H3 (ii). I think these are
13Professor Browning's documents.
14 MR JUSTICE GRAY:     That is one I have not got here I am afraid.
15 A. [Mr Irving]     This is the actual conference.
16 MR RAMPTON:     At tab 11, no sorry.
17 A. [Mr Irving]     10.
18 Q. [Mr Rampton]     It is open at the right place but I just want to identify
19the document.
20 MR JUSTICE GRAY:     Tab 9, page 458.
21 MR RAMPTON:     It is called "Footnote 88" which is the Hans Frank
22extract which is printed in Professor Browning's report at
23paragraph 5.1.13 on pages 31 and 32. He has quoted some
24of that diary, but there is another passage here which
25I would like you to look at in the German, please,
26Mr Irving, while I read slowly a translation.

.   P-182



 1 A. [Mr Irving]     Presumably the second paragraph?
 2 Q. [Mr Rampton]     The first complete paragraph on page 458. This is the
 3Hans Frank so-called "diary". Correct me as soon as I go
 4wrong. No, I will read it once and then when we go
 5through it again you tell me how this translation is in
 6error, if it is.
 7     "For us the Jews are also particularly useless,
 8might be damaging, consumers of food, mouths. We have
 9approximately 2.5, perhaps with those related to Jews and
10all that belongs to that 3.5 million Jews. We can't shoot
11these 3.5 million Jews. We can't poison them. But we
12will, however, be able to undertake interventions which in
13some way lead to a successful annihilation, and indeed in
14connection with the large scale measures to be undertaken
15from the Reich and to be discussed. The General
16Government must become just as free of Jews as the Reich
17is. Where and how that happens is a matter for the
18institutions which we must put into action and create here
19and the effectiveness of which I will report on to you in
20good time."
21     Is that roughly an accurate translation of that
22paragraph?
23 A. [Mr Irving]     Just two minor beefs, as I would call them. I would say
24in connection with, where he says "in connection with the
25measures to be discussed from the Reich", I would say "in
26the context of" is probably a more apposite description.

.   P-183



 1When he talks about "the institutions", "is a matter for
 2the institutions", "instansun(?)" would be more accurately
 3translated as "departments" in the sense of government
 4departments.
 5 Q. [Mr Rampton]     Yes. I am happy to wear that correction for the moment.
 6I do not know whether the translator is. I will find that
 7out later. Does that not, Mr Irving, completely demolish
 8the idea that in Berlin it was Frank who was telling the
 9people in Berlin "liquidate the Jews yourselves"? Is he
10not here expanding on the instruction from Berlin,
11"liquidate them yourselves"?
12 A. [Mr Irving]     May I first of all make plain that I had not seen this
13passage at the time I wrote the book. So this is not
14something that lay before me when I wrote my books. Can
15I make that quite plain on oath?
16 Q. [Mr Rampton]     Yes.
17 A. [Mr Irving]     You will find this when I produce the materials that I had
18that were given to me by the Institute from the Hans Frank
19diaries. Secondly, it confirms what I said about them
20already having more Jews in the Government General than
21they could handle. They could not feed and house the ones
22they did have and they were very indignant at any more
23being dumped on them given the problems they had of
24feeding the mouths they already had.
25 Q. [Mr Rampton]     He is saying: "We have got two and a half, maybe three
26and a half million Jews in this part of the Reich occupied

.   P-184



 1territories, we cannot shoot them all, we cannot poison
 2them."
 3 A. [Mr Irving]     He says "we can't shoot them". He does not say "all".
 4There is a subtle difference there.
 5 Q. [Mr Rampton]     Is it?
 6 A. [Mr Irving]     Yes.
 7 Q. [Mr Rampton]     Oh.
 8 A. [Mr Irving]     Yes, otherwise it implies they can shoot some. If I am
 9saying I cannot shoot all the people in this room, that
10implies half the people in this room have a rather bleak
11lookout.
12 MR JUSTICE GRAY:     Yes, but making the place phrase "Judenfrage"
13is pretty unambiguous.
14 A. [Mr Irving]     No, the actual phrase that has been translated here, he
15says: "These 3.5 million, we can't shoot them. We can't
16poison them", and Mr Rampton just slid in the word "all".
17 MR RAMPTON:     Oh, no. I am paraphrasing. Be kind to me,
18Mr Irving.
19 A. [Mr Irving]     You put in the word "all". We all heard you say it.
20 Q. [Mr Rampton]     Of course it does, but that is what it means?
21 A. [Mr Irving]     No. What it means is quite plain. "We can't shoot them".
22 Q. [Mr Rampton]     How do you make the General Government "Judenfrage" if you
23do not get rid of all the Jews, if you do not achieve a
24vernichtung serfolg?
25 A. [Mr Irving]     I do not want to labour the point. If you say that we
26cannot shoot them all, that implies we can shoot some of

.   P-185



 1them. If he says we cannot shoot the Jews that implies we
 2cannot shoot any of them.
 3 Q. [Mr Rampton]     That will do. We cannot poison them. We cannot shoot 3.5
 4million. We cannot poison 3.5 million?
 5 A. [Mr Irving]     But we will be able to do something, he goes on to say,
 6which will lead to wiping them out, getting rid of them,
 7vernichtung.
 8 Q. [Mr Rampton]     Getting rid of?
 9 A. [Mr Irving]     Vernichtung.
10 Q. [Mr Rampton]     Vernichtung is to get rid of?
11 A. [Mr Irving]     I am just saying the sense of this sentence is, "we can't
12kill them, we can do something that will get rid of them."
13 Q. [Mr Rampton]     It is not.
14 A. [Mr Irving]     He just said, "We can't poison, we can't shoot them".
15Whatever ways would you suggest?
16 Q. [Mr Rampton]     Gas, Mr Irving, gas?
17 A. [Mr Irving]     Vergeltung? It sounds like poisoning to me, poison gas.
18 Q. [Mr Rampton]     "Gift gas" is poison gas. Vergeltung is poison?
19 A. [Mr Irving]     That is right, he says "we can't do it".
20 Q. [Mr Rampton]     Yes. He does not say anything about gassing. This is an
21evolutionary document.
22 A. [Mr Irving]     No point using gas if it is not poison gas.
23 MR JUSTICE GRAY:     Mr Irving, I am not sure I got your answer to
24the initial question which was, does this or does it not
25show that the instructions were from Berlin to the General
26Government as to what was to be done in the General

.   P-186



 1Government?
 2 A. [Mr Irving]     I am sorry, my Lord, if I did not make myself plain. I
 3thought that this in fact supported my version that Hans
 4Frank was saying that they already had all the Jews they
 5could handle. They could not even feed the ones they had
 6got: "So please don't send us any more, get rid of them
 7yourself".
 8 MR RAMPTON:     So the word "vernichtung serfolg" is not talking
 9about a liquidation?
10 A. [Mr Irving]     If you want to wipe out Christianity you do not have to
11liquidate the Christians.
12 Q. [Mr Rampton]     I do not see anything about Judaism in this passage. It
13is all about Jews, numbers of Jews, 3.5 million?
14 A. [Mr Irving]     He says here explicitly, "We can't kill", he says, I will
15translate it for you and it is exactly the same as your
16translation there. "These 3.5 million Jews, we can't
17shoot them, we can't poison them, but we will be able to
18do something which will one way or another lead to a
19successful wipe out, destruction".
20 Q. [Mr Rampton]     Annihilation?
21 A. [Mr Irving]     "We will get rid of them". We are back on that word
22vernichtung again, which Germans who like using these
23words in the knowledge they are going to be providing
24endless humour for lawyers 50 years down the road.
25 Q. [Mr Rampton]     I do not think it is very humorous, Mr Irving, I am bound
26to say, not humorous at all.

.   P-187



 1 A. [Mr Irving]     That is why I prefer to sit on documents where it is
 2absolutely unambiguous where we do not have to waste time
 3about the meanings of words.
 4 Q. [Mr Rampton]     You mentioned I think, whether it was this morning or
 5yesterday I am afraid I cannot remember, somebody called
 6Wisliceny?
 7 A. [Mr Irving]     Wisliceny, W-I-S-L-I-C-E-N-Y.
 8 Q. [Mr Rampton]     Yes. He was I think on Eichmann's staff, was he not?
 9 A. [Mr Irving]     A member of Eichmann's staff who was responsible for the
10Final Solution in Slovakia and other countries.
11 Q. [Mr Rampton]     He made some statements after the war, did he not?
12 A. [Mr Irving]     Under duress, yes.
13 Q. [Mr Rampton]     What do you mean by duress?
14 A. [Mr Irving]     In Allied captivity, inside the gallows, which is about as
15much duress as you can imagine.
16 Q. [Mr Rampton]     You are not saying he was tortured?
17 A. [Mr Irving]     Good Lord no.
18 Q. [Mr Rampton]     You say that Rudolf Hess was tortured, do you not?
19 A. [Mr Irving]     I say that he was maltreated. He had a torch rammed into
20his mouth.
21 MR JUSTICE GRAY:     Let us stick with Wisliceny for the moment
22otherwise we are going to get confused.
23 MR RAMPTON:     That is my fault, my Lord.
24 A. [Mr Irving]     He richly deserved it, people like that.
25 Q. [Mr Rampton]     No, I do not agree with that as it happens, Mr Irving.
26Can you see if you still have Professor Evans' report

.   P-188



 1there? It was handed to you in error earlier.
 2 A. [Mr Irving]     Yes.
 3 Q. [Mr Rampton]     I am sorry. Let us turn to page 344, will you?
 4 A. [Mr Irving]     Yes.
 5 Q. [Mr Rampton]     Evans' report. It is at letter G and Professor Evans
 6writes this, Mr Irving. I will not read the heading
 7except to say it says "Testimony of Dieter Wisliceny".
 8 A. [Mr Irving]     It also says: "Manipulation and Suppression of Evidence".
 9 Q. [Mr Rampton]     I was going to save your blushes. Yes, it does, does it
10not?
11 A. [Mr Irving]     Yes.
12 Q. [Mr Rampton]     "As described above, Irving claims that Dieter Wisliceny,
13one of Eichmann's top officials, described Goebbels'
14article in Das Reich as a watershed in the Final Solution
15of the Jewish problem. Once more Irving makes it very
16difficult to verify claims. According to his footnotes,
17Wisliceny's postwar report of 18th November 1946 can be
18found in the IFZ file F71/8. However, this file does not
19exist and Wisliceny's report has to be located elsewhere."
20     It is a minor point, Mr Irving. Do you accept
21that you gave a wrong reference?
22 A. [Mr Irving]     No. I saw this file probably 30 years ago, probably
23before Professor Longerich was born.
24 Q. [Mr Rampton]     This is not Professor Longerich. This is Professor
25Evans.
26 A. [Mr Irving]     Well, even more to the point. That being so, it is

.   P-189



 1extremely likely that they changed the reference number
 2since the archives are constantly changing reference
 3numbers.
 4 Q. [Mr Rampton]     It is a small point. "In his report Wisliceny states that
 5after the invasion of the USSR in June 1941 Nazi policy
 6against the Jews was transformed dramatically in a
 7step-by-step process, completed in the Spring of 1942.
 8One these radicalisng steps was taken in late 1941. As
 9Wisliceny reported: 'The second wave of radicalization
10began after the USA entered the war. This could clearly
11be felt in the internal German propaganda too. Externally
12it was expressed in the introduction of the yellow star as
13a mark of the Jews. Reference in this connection also to
14the Goebbels' article that 'Jews are guilty' in an edition
15of the magazine Das Reich'.
16     "In this period of time, after the beginning of
17the war with the USA, I am convinced must fall the
18decision of Hitler which ordered the biological
19annihilation of European Jewry" -- biologische vernichtung
20des europaischen Judentums befahl.
21 A. [Mr Irving]     Yes.
22 Q. [Mr Rampton]     You are well aware of that passage?
23 A. [Mr Irving]     Yes, and I draw attention to the fact that in order to
24emphasis that the word "vernichtung" here means killing he
25adds the adjective "biologische", biological, because
26without that it does not mean it with sufficient emphasis.

.   P-190



 1 MR JUSTICE GRAY:     Do not let us go back on that.
 2 MR RAMPTON:     You can argue about it. Eventually, you see,
 3Mr Irving, whatever you may think and whatever I may put
 4to you, his Lordship will make a decision about what the
 5natural meaning of the word is in these various contexts.
 6 A. [Mr Irving]     But without input from me he will only hear input from
 7you.
 8 Q. [Mr Rampton]     Of course you must say what you think it means. Whether I
 9or anybody else accepts what you say is quite another
10matter.
11 A. [Mr Irving]     But I think it is quite useful to say it here in view of
12the fact that this man obviously thought that
13"vernichtung" does not mean killing unless he adds the
14word "biologische" in front of it.
15 MR JUSTICE GRAY:     I do not think that is right actually, but
16I have the point. It is obvious what it means if it has
17"biological" attached to it. If it has not, you say it
18does not mean extermination. Mr Rampton says it does.
19I think we really have thrashed that one.
20 MR RAMPTON:     I am afraid I am going to take up, argumentative
21person that I am, one little point on this. You notice,
22do you not, that although you stress the use of the word
23"biologische" to qualify "vernichtung", what is it that
24is being biologically annihilated?
25 A. [Mr Irving]     Judentums.
26 Q. [Mr Rampton]     Judentums?

.   P-191



 1 A. [Mr Irving]     Yes.
 2 Q. [Mr Rampton]     European Judentums?
 3 A. [Mr Irving]     Yes.
 4 Q. [Mr Rampton]     What is "Judentums"?
 5 A. [Mr Irving]     In this case quite clearly he is talking about the Jews
 6because he has added the word "biological in advance" and
 7you cannot have biological in reference to provision.
 8 Q. [Mr Rampton]     There is no rule of German which says that the word must
 9mean Judaism. It can easily mean Jewish people or Jewry
10as a collective, can it not?
11 A. [Mr Irving]     I do not want to labour the point, but this is why
12dictionaries give orders of priority for the meanings of
13words, the first meaning, second meaning and third meaning
14and so on.
15 Q. [Mr Rampton]     Wisliceny thinks or says that he things, is reported as
16saying that he thinks, that the order for the biological
17annihilation of the European Jews came from Hitler. He is
18saying that, is he not?
19 A. [Mr Irving]     He could set that conviction of his to music and play it
20to the mass bands of the Cold Stream Guards, but it does
21not make it proof.
22 Q. [Mr Rampton]     He says it again and again. Is it right that you have
23consistently ignored what he said?
24 A. [Mr Irving]     What is the date of this report, Mr Rampton?
25 Q. [Mr Rampton]     It is 1946, 18th November 1946.
26 A. [Mr Irving]     Just two or three weeks after the unfortunate Nazi

.   P-192



 1gangsters have been hanged at Nuremberg. Where is he
 2writing this report?
 3 Q. [Mr Rampton]     Is the answer to my question, yes? Give the explanation
 4afterwards, please, Mr Irving. The answer to my question
 5is, yes, you have ignored it. Now the reason ----
 6 A. [Mr Irving]     No. The answer to the question is that I have discounted
 7that kind of evidence as being the fact that he does not
 8say he saw an order. He is saying it is his opinion. He
 9thinks that, yes, there must surely have been some such
10kind of order. What kind of evidence is that given by a
11man sitting in the face of the gallows just after the Nazi
12leaders have been hanged at Nuremberg, and he is sitting
13in Czech Slovac prison knowing that he is going to be
14hanged as well, and he is sitting down there writing the
15first thing that comes into his head, and he says: "Well,
16surely Hitler must have given an order." What kind of
17evidence is that? What kind of historian would I be who
18in the absence of any kind of documentation whatsoever of
19any concrete diamond value of the war archives then
20decides to pollute his work with relying on this kind of
21documentation? Material that Wisliceny himself is an
22expert on -- I remind you of the Trevor Roper criteria,
23something that he himself has experienced, something that
24he is in a position to know. That I would accept, but for
25him to speculate, as he clearly is here, that is neither
26here nor there. It is information of janitorial level.

.   P-193



 1 Q. [Mr Rampton]     Yes. Janitorial, this is to anticipate something we are
 2going to come to perhaps next week or the week after, Mr
 3Irving, but "janitorial level" is a phrase you often use.
 4Is not "janitorial level" very often the place you expect
 5to find the diamonds?
 6 A. [Mr Irving]     Janitorial level is not the kind of place that
 7I frequently inhabit, Mr Rampton.
 8 Q. [Mr Rampton]     That is very patrician of you, Mr Irving. If you are an
 9historian you must look even in the basement, the sewer,
10if you want to find the gems, must you not sometimes?
11 A. [Mr Irving]     If one fails to find the gems, my opponents and my jealous
12rivals they have gone down among the sewers looking for
13things, but I found the gems because I have done the work.
14 Q. [Mr Rampton]     You saw some of them, did you not, in Professor van Pelt's
15report, "janitorial gems"?
16 A. [Mr Irving]     We shall have great enjoyment discussing this with van
17Pelt when the time comes.
18 MR JUSTICE GRAY:     Can I just understand why Wisliceny is being
19put into the janitorial category at all? He is one of
20Eichmann's top officials.
21 A. [Mr Irving]     He is one of Eichmann's top officials.
22 Q. [Mr Justice Gray]     And Eichmann was one of the senior officials within the
23Reich carrying out the extermination programme.
24 A. [Mr Irving]     Mr Wisliceny is a man who is in deep trouble. First of
25all he is facing ----
26 Q. [Mr Justice Gray]     That is a different point, if I may say so. He is not a

.   P-194



 1janitor.
 2 A. [Mr Irving]     He is also a man of very dubious character. He is a man
 3who has been not an officer in the SS, but he has been
 4involved in corrupt schemes, in stealing and robbing and
 5disposing of stolen Jewish property and all sorts of
 6things that got him in trouble even with the SS. He is a
 7man whose character I would not give a fig for. He is
 8sitting in a prison cell in a Slovac prison knowing that
 9he is going to be put on trial for his life.
10 Q. [Mr Justice Gray]     That is a different point.
11 A. [Mr Irving]     I am sorry, let me cut to the bottom line and say what he
12is actually saying here, I have lost it, he is not saying
13"I know this for a fact"; he is just saying, "I speculate
14that probably this happened." I have lost it totally, the
15actual reference.
16 Q. [Mr Justice Gray]     "I am convinced it must fall the decision of Hitler".
17 A. [Mr Irving]     Yes, but his conviction that something must fall within, I
18mean, that is not evidence of any kind at all, my Lord,
19and I am sure no court would accept that kind of evidence
20in a matter of great seriousness, somebody's conviction
21that something must surely have happened, not in the total
22absence of any kind of qualifying documents.
23 MR RAMPTON:     I am sorry, Mr Irving. Sometimes my questions
24involve quite a lot of paper chasing. You are quite
25content to use Dieter Wisliceny when it suits your
26purposes, are you not?

.   P-195



 1 A. [Mr Irving]     If it fits the criteria which I mentioned earlier.
 2 Q. [Mr Rampton]     If it fits the bill, I would suggest, Mr Irving.
 3 A. [Mr Irving]     That is not what I said. I said if it fits the criteriA.
 4 Q. [Mr Rampton]     Have you got your Goebbels' book there?
 5 A. [Mr Irving]     Yes.
 6 Q. [Mr Rampton]     You say on page 379 -- has your Lordship got one?
 7 MR JUSTICE GRAY:     Yes, I have. 379, you say?
 8 MR RAMPTON:     Yes.
 9 A. [Mr Irving]     Yes, I have that.
10 Q. [Mr Rampton]     We are talking here about an article written by, or
11probably written by, Dr Goebbels?
12 A. [Mr Irving]     It is one of the two most important articles he wrote.
13 Q. [Mr Rampton]     You say that; it was written and published, I think, on
1416th December?
15 A. [Mr Irving]     November.
16 Q. [Mr Rampton]     I am sorry, November?
17 A. [Mr Irving]     1941.
18 Q. [Mr Rampton]     1941, as virulently anti-Semitic as anything that Hitler
19ever said?
20 A. [Mr Irving]     Far more so.
21 Q. [Mr Rampton]     You say that, do you?
22 A. [Mr Irving]     Far more so.
23 Q. [Mr Rampton]     You say here on page 379 in the last paragraph, the
24complete paragraph, on the page: "Dieter Wisliceny, one
25of Eichmann's closest associates, would describe the
26Goebbels' article in Das Reiche", that is the one I

.   P-196



 1have just mentioned, as a watershed in the Final Solution
 2of the Jewish problem". Then footnote 40 is a reference
 3to the Wisliceny Report, date November 18th 1946. That is
 4to be found on page 645. You go on in the text ----
 5 A. [Mr Irving]     I also reference his interrogations I see.
 6 Q. [Mr Rampton]     You did.
 7 A. [Mr Irving]     Yes.
 8 Q. [Mr Rampton]     "The SS took it as a sign from above Adolf Eichmann would
 9admit in his unpublished memoirs it is quite possible that
10I got orders to direct this or that railroad to Riga", and
11I don't know where we go from there quite. Yes, I will
12read the whole paragraph. "On the last day of November,
13on the orders of the local SS Commander, Friedrich
14Jeckelm, 4,000 of Riga's unwanted Jews were trucked five
15miles down" -- the Germans called that Dinoberg, I think,
16did they not?
17 A. [Mr Irving]     Dunoberg, yes.
18 Q. [Mr Rampton]     -- "a highway to Skiaturbe plundered and machine-gunned
19into two or three pits. According to one army colonel",
20this is Bruns, is it not----
22 Q. [Mr Rampton]     --- who witnessed it, a trainload of Jews from Berlin,
23those expelled three days before, arrived in the midst
24of this aktion. Its passengers were taken straight out to
25the pits and shot. This happened", and here we go again,
26even has Hitler's hundreds of miles away, "Hitler", I

.   P-197



 1emphasise, hundreds of miles away in the Wolf's Lair, "was
 2instructing Himmler that these Berlin Jews were not to be
 3liquidated. I am not going back to that hoary old
 4chestnut, you will be glad to hear, but I do want to take
 5you back to the beginning of this paragraph.
 6 A. [Mr Irving]     It is a remarkable paragraph for a Holocaust denier to
 7write, is it not?
 8 Q. [Mr Rampton]     I have no idea, Mr Irving, and anyway I am not going to
 9answer your question. "Dieter Wisliceny, one
10of Eichmann's closest associates, would describe the
11Goebbels' article in Das Reich as a watershed in the Final
12Solution of the Jewish problem"?
13 A. [Mr Irving]     Yes.
14 Q. [Mr Rampton]     Where did he give that description?
15 A. [Mr Irving]     What, whether he actually used the word watershed?
16 Q. [Mr Rampton]     Yes.
17 A. [Mr Irving]     You see that I reference his manuscript written in
18Bratislava or Presburg and I also reference the
19interrogations in the associated footnote.
20 Q. [Mr Rampton]     But if you read what we find here in Professor Evans'
21report which is an English translation of some part of the
22Wisliceny report, what you immediately realize, you do not
23learn it from Mr Irving's books, you learn it
24from Professor Evans' report, what you immediately realize
25is that Dieter Wisliceny did not see the Reich article as
26a watershed. He saw the watershed as being an order from

.   P-198



 1Adolf Hitler?
 2 A. [Mr Irving]     Can we have a look at the passage you are relying on,
 3please?
 4 Q. [Mr Rampton]     The which?
 5 A. [Mr Irving]     The passage of the Wisliceny report you are relying upon
 6in the Evans...
 7 Q. [Mr Rampton]     One would have to go back now to ----
 8 A. [Mr Irving]     I no longer trust your paraphrases, you see, Mr Rampton.
 9 Q. [Mr Rampton]     --- where I was.
10 MR JUSTICE GRAY:     It is page 340, I think.
11 MR RAMPTON:     Yes. 345, sorry, my Lord. The passage -- I am
12not going to read it again, I have read it once already.
13Read what is said there. The German is at the bottom of
14the page, so if you are going to criticise Professor
15Evans' translation, say so now.
16 A. [Mr Irving]     The English is a slightly vague translation. I am looking
17at the paragraph at the top of page 345, where he says
18this is just simply "reference in this connection also to
19the Goebbels-article" ----
20 Q. [Mr Rampton]     Yes?
21 A. [Mr Irving]     --- "'The Jews are guilty'".
22 Q. [Mr Rampton]     What does the German say?
23 A. [Mr Irving]     The German says: "In this connection, I draw attention
24also to the Goebbels-article 'The Jews are to blame' in an
25edition of the newspaper Das Reich" which is possibly a
26slightly more coherent way of translating it.

.   P-199



 1 Q. [Mr Rampton]     But he is talking about German propaganda, that is to say,
 2domestic propaganda, is he not?
 3 A. [Mr Irving]     Yes.
 4 Q. [Mr Rampton]     After 11th December when Hitler, perhaps rather stupidly,
 5declared war on the United States?
 6 A. [Mr Irving]     Yes.
 7 Q. [Mr Rampton]     He is talking about the Yellow Star and he is talking
 8about the article in Das Reich as examples. He then
 9said: "In this period of time, after the beginning of the
10war with the USA, I am convinced must fall the decision of
11Hitler which ordered the biological annihilation of
12European Jews". So how is it, if that is the piece you
13were referring to, that that gets converted into Dieter
14Wisliceny saying that the article by Goebbels in Das Reich
15was a watershed?
16 A. [Mr Irving]     I beg to differ with you. I think that even this source
17bears me out. He said the words you omitted in your
18summary, he says: "The second wave of radicalization
19began" and the instance of this he gives is the
20publication of the article. This is what triggered off
21the off the second wave of radicalization. But you have
22also overlooked, and I am sorry I tripped you up on this
23when you referred to the Goebbels' Diaries, would you like
24to read out the reference for the passage that I gave
25you? You implied that it relies only on the Wisliceny
26report.

.   P-200



 1 Q. [Mr Rampton]     No, you refer to something else, but so what? Sorry, I am
 2not following you.
 3 A. [Mr Irving]     If you look in the source reference, it clearly says:
 4"Wisliceny report and interrogations of Wisliceny in the
 5national archives" which Professor Evans has obviously not
 6bothered to look at.
 7 Q. [Mr Rampton]     I am quite open-minded, Mr Irving. If you tell me that in
 8the interrogations, as opposed to the report, there is a
 9positive statement by Wisliceny to the effect that
10Goebbels' article was the watershed or a watershed, then
11I will accept it, if you tell me to find it?
12 A. [Mr Irving]     Mr Rampton, I am under oath and I am not going to make a
13statement from memory for something that I cannot back up
14without going home and checking the files. All that I do
15say is that Professor Evans has made no reference to the
16fact that I used other sources to justify that one
17sentence and that he, apparently, has not bothered to go
18and have a look at those interrogations of Wisliceny
19because they are so many thousands of miles away.
20 Q. [Mr Rampton]     We may just have time to go over to the other side of this
21page in Evans' Report, 346 at paragraph 4. This is a
22further extract, says Professor Evans -- of course, you
23may prove that he is wrong about it -- this is an extract
24from the same document, apparently, where Wisliceny says
25this:
26     "According to Eichmann's own report, which he

.   P-201



 1made to me, Globocnig (sic) was the first to use gas
 2chambers for the mass extermination of humans. Globocnig
 3had set up big labour camps for Jews in his area of
 4command, and he got rid of those who were unable to work
 5in the manner described. As Eichmann explained,
 6this 'procedure' was 'less conspicuous' than the mass
 7shootings". The German is "Massenerschiessungen". Do you
 8remember those words? Do they ring a bell?
 9 A. [Mr Irving]     Yes, indeed.
10 Q. [Mr Rampton]     Something to do with General Bruns? Does that ring a
11bell?
12 A. [Mr Irving]     Well, there were mass shootings occurring all over the
13Eastern Front. It is not specifically a reference just to
14that one. There were mass shootings at Riga, there were
15mass shootings at Minsk, mass shootings elsewhere in the
16Ukraine. So it would be specious just to say this is a
17reference to the Bruns Report.
18 Q. [Mr Rampton]     My point is a slightly different one. Indeed, it is not a
19reference to the Bruns Report.
20 A. [Mr Irving]     Well, you mentioned the Bruns.
21 Q. [Mr Rampton]     Exactly, and I will tell you why. What Bruns said he was
22told by Altemeyer was to precisely the same effect, "These
23mass shootings, or mass shootings of this kind, mass
24shootings, must stop. That must be done more discreetly"?
25 A. [Mr Irving]     Yes.
26 Q. [Mr Rampton]     It is almost a mirror image of what Wisliceny reports

.   P-202



 1Eichmann having said, this procedure, gassing, was less
 2conspicuous, "unauffalliger" ----
 3 A. [Mr Irving]     Yes.
 4 Q. [Mr Rampton]     --- than the "Massenerschiessungen"?
 5 A. [Mr Irving]     This was the tendency in the SS; they did not like
 6shooting people. Shooting took it out of them.
 7 Q. [Mr Rampton]     Sure.
 8 A. [Mr Irving]     Yes.
 9 Q. [Mr Rampton]     And that is why they took to gassing people, is it not?
10 MR JUSTICE GRAY:     But you accept, do you, Mr Irving, that ----
11 A. [Mr Irving]     Gassing did occur, yes.
12 Q. [Mr Justice Gray]     --- the Bruns Report corresponds with what is, apparently,
13recorded in Eichmann's report?
14 MR RAMPTON:     In Wisliceny's report, my Lord.
15 MR JUSTICE GRAY:     Sorry, in Wisliceny's report.
16 MR RAMPTON:     It is double hearsay, if you like, but so what if
17you are an historian.
18 A. [Mr Irving]     It is indeed and the word "report", of course, is slightly
19sharpening it up. He is actually just saying, "According
20to what Eichmann said", he is saying.
21 MR RAMPTON:     Do they not echo one another?
22 A. [Mr Irving]     Yes.
23 Q. [Mr Rampton]     Bruns is talking about shootings in the Osland in Latvia?
24 A. [Mr Irving]     Yes.
25 Q. [Mr Rampton]     Here Wisliceny is talking much more generally, is he not?
26 A. [Mr Irving]     Indeed, yes, and we do not know about what period he is

.   P-203



 1talking about, we do not know about what region he is
 2talking about.
 3 Q. [Mr Rampton]     Do you not detect in the convergence of those two
 4completely otherwise unrelated pieces of evidence ----
 5 A. [Mr Irving]     Yes.
 6 Q. [Mr Rampton]     --- even a hint of a suggestion that the reality was that
 7mass shootings were embarrassing because they could get
 8out because it upset the soldiers too much, because it was
 9expensive in bullets, a shift in policy from shooting to a
10more discreet means of disposal, that is to say, gassing?
11 A. [Mr Irving]     I am afraid that was such a long question that I had lost
12you halfway through again.
13 MR JUSTICE GRAY:     Well, I think it is the end of a longish day
14for Mr Irving and I think we will...
15 MR RAMPTON:     I will repeat the question first thing on Monday
16morning.
17 MR JUSTICE GRAY:     Will you?
18 MR RAMPTON:     It will be on the transcript.
19 A. [Mr Irving]     Can you put it in two halves so that ----
20 MR JUSTICE GRAY:     It was a long question. Anyway, we are
21adjourning now.
22 A. [Mr Irving]     --- a bear of limited brain can follow it, but I lost it.
23 MR JUSTICE GRAY:     So it is 10.30 on Monday in court 73.
24 (The court adjourned until 10.30 p.m. on Monday, 17th
25January 2000)
26

.   P-204



  

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