Irving v. Lipstadt
Holocaust Denial on Trial, Trial Transcripts, Day 15: Electronic Edition
Pages 51 - 55 of 93
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1 A. [Mr Peter Millar] That is correct.
2 Q. [Mr Rampton] Yes. I only want to ask you two questions about that
3paragraph that I read out. First of all, are its contents
5 A. [Mr Peter Millar] Yes.
6 Q. [Mr Rampton] You have to say "yes" because of the microphone.
7 A. [Mr Peter Millar] I am sorry, yes, they are true.
8 Q. [Mr Rampton] It is a recording microphone. Thank you. The only other
9question is this. What do you mean when you write,
10"These plates he had concealed in a James Bond-style
11fashion outside the Institute"?
12 A. [Mr Peter Millar] He had, to the best of my recollection, prepared two
13postcards which were slightly larger than the glass
14plates, or of cardboard material, one of which certainly
15had a postcard picture on it, had wrapped the plates in
16these and left them on a piece of waste ground about 100
17yards from the Institute.
18 Q. [Mr Rampton] So it was clear to you that he knew that he should not be
19taking the plates?
20 A. [Mr Peter Millar] Quite.
21 Q. [Mr Rampton] Then only one other thing: now will you please take the
22other file, the one you were first given, which is that
23one, and turn in it to I think it is page A37? It is in
24the front tab of the file. At A36 you see what the
25document is. It looks like a document from a memo from
26you and John Witheroe to the Editor of the Sunday Times.
1It is dated 2nd July '92. Do you have that?
2 A. [Mr Peter Millar] Yes.
3 Q. [Mr Rampton] If you turn over to the second page, which is A37, and
4look at paragraph 10: "We have also carried out our own
5handwriting and forensic tests on the glass plates and
6microfilm. These are not conclusive, but all indicate
7that the plates are not recently made and that the writing
8is that of Goebbels, although one of the tests seemed to
9indicate that they could have been copies. (We have not
10been able to do all tests because this would have meant
11destroying or severely damaging the plates. See below in
12case this becomes an issue).
13 "Asked how we got hold of two of the plates for
14tests, I suggest we fudge it by saying we have been
15supplied with two plates and that they are now safely back
16in the archives".
17 I am not criticising you for anything, Mr Millar
18-- apart from anything else, you are not a party to this
19action -- but what was it that suggested to you the need
21 A. [Mr Peter Millar] There was nothing that suggested that we need to fudge it.
22If you see, it was hypothetical. The question is if we
23are asked. The point was that the Times, as I repeat, the
24Sunday Times was very concerned about authenticity of
25these plates because of the Hitler's Diaries fiasco and,
26therefore, there was some concern that we should be seen
1to avoid any mistake again, and the question was whether
2and how we had got hold of these, we were obviously very
3concerned at this time nothing had been made known about
4the diaries. We did not want any other newspapers to get
5wind of what we were doing.
6 Q. [Mr Rampton] In particular, you did not want it to be known that these
7two plates which you brought back to this country via
8Munich to be tested for authenticity that they had been
9nicked -- I know they were returned -- if I may use a
11 A. [Mr Peter Millar] No, actually. I am going to disagree. As far as I know,
12the two plates that were nicked, as you put it, were those
13that were put on the piece of waste land overnight.
14 Q. [Mr Rampton] What about the next two?
15 A. [Mr Peter Millar] Those were nicked and returned, and that had nothing to do
16with these -- we are talking about two separate plates
17here and, as you will see from my witness statement, I was
18not present at the time the second two plates were taken
19back to the UK. I do not know the exact circumstances,
20I did assume that they were with permission.
21 Q. [Mr Rampton] You assumed they were with permission?
22 A. [Mr Peter Millar] Yes, I did.
23 Q. [Mr Rampton] Look back at your witness statement, will you, the second
24page? I will put it this way: do you know now,
25Mr Millar, that they were not taken with permission?
26 A. [Mr Peter Millar] Sorry, was that a question?
1 Q. [Mr Rampton] Yes, it was. I am sorry. It is difficult when I
2am asking you a question and somebody else answers it.
3Mr Millar, you do know now, do you not, that those two
4plates that were brought back to England were not taken
6 A. [Mr Peter Millar] No, I do not actually. I do not know that.
7 Q. [Mr Rampton] I am grateful to Miss Rogers. In the Moscow file,
8Mr Millar, could you look, in the light of that last
9answer, at page A28 in the front section of the file?
10There is a document whose format is not familiar to me,
11but I expect you will recognize it. What is it exactly?
12It is headed: "Catch gubby" -- is it some kind of
13computer print out?
14 A. [Mr Peter Millar] Sorry?
15 Q. [Mr Rampton] Is it some kind of computer print out?
16 A. [Mr Peter Millar] Yes, oh, it is. I recognize it. Yes, it is ----
17 Q. [Mr Rampton] You do recognize it?
18 A. [Mr Peter Millar] It is -- yes, I do recognize it. Indeed, it is an
19internal print out on the Old News International printer.
20 Q. [Mr Rampton] So it is a Sunday Times document?
21 A. [Mr Peter Millar] It is.
22 Q. [Mr Rampton] Yes, and do you know who wrote it?
23 A. [Mr Peter Millar] It tells me at the top. It was, without looking at in
24great detail, if you would like me to take a minute I can
25do that, but it appears to have been done on Susan
1 Q. [Mr Rampton] Yes. Maybe it was done on her computer, but where would
2show get her information from?
3 A. [Mr Peter Millar] Would you like me to spend a few minutes just reading the
5 MR JUSTICE GRAY: Yes of course, do.
6 MR RAMPTON: Well, look, just let us hurry up because I do not
7want to detain you longer than you need be here. Can you
8just read the third paragraph?
9 A. [Mr Peter Millar] Actually, I would like to read the whole thing if we are
10going to talk about it.
11 Q. [Mr Rampton] OK.
12 A. [Mr Peter Millar] Yes, I am not familiar with it and, in fact, it is a memo
13that was composed by myself and Susan Douglas jointly for
14submission to Andrew Neil.
15 Q. [Mr Rampton] So may I now read the third paragraph on page A28?
16 A. [Mr Peter Millar] Yes.
17 Q. [Mr Rampton] "Irving has taken liberties in our name in Moscow
18'borrowing' two plates and taking them out of the country
19and will shamelessly take more. I would be very wary, as
20I am sure would John and Matthew, of giving any impression
21over there that Irving represents us in any way except in
22this affair. He is not above trading on our reputation
23for his own profit". Now, are those your thoughts?
24 A. [Mr Peter Millar] They are the thoughts of Susan and myself combined, yes.
25 Q. [Mr Rampton] So you were -- I do not blame you for getting in a muddle
26-- then that the second two plates which were brought
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