Holocaust Denial on Trial, Trial Transcripts, Day 16: Electronic Edition

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1996 I. No. 113
 2Royal Courts of Justice
 3Strand, London
 4 Monday, 7th February 2000
10Claimant -and-
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
21(Transcribed from the stenographic notes of Harry Counsell
&Company, Clifford's Inn, Fetter Lane, London EC4
22Telephone: 020-7242-9346)
23(This transcript is not to be reproduced without the written permission of Harry Counsell &Company)

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 1 Day 16 Monday, 7th February 2000.
 2 (10.30 a.m.)
 3 MR JUSTICE GRAY:     Mr Irving and Mr Rampton, I have received a
 4letter from I think it is a German lawyer called Gunter
 5Murmann, the significance of which is not immediately
 6obvious to me, but I thought I had better hand it down to
 7you to make what you will of it. I know you have been
 8receiving a lot of similar documents. Have a look at it
 9when you have a convenient moment. Yes, Mr Irving?
10 MR IRVING:     May it please the court. I have here this morning
11a witness on summons, Sir John Keegan. I also have a
12number of points that I wish to submit to your Lordship.
13I think, out of fairness to Sir John Keegan, we ought to
14hear his evidence first, and then I will put to your
15Lordship the various procedural points which I wish to.
16 MR JUSTICE GRAY:     That sounds perfectly sensible. Let us have
17him straightaway.
18 MR IRVING:     I call Sir John Keegan.
19 < SIR JOHN KEEGAN, sworn.
20< Examined by MR IRVING.
21 Q. [Mr Irving]     My Lord, Sir John's evidence will go entirely to
22reputation and no other matter in this court. Sir John,
23first of all, to make it perfectly plain to the court, you
24are here pursuant to a witness summons, in other words,
25what used to be called a subpoena. Is that correct?
26 A. [Sir John Keegan]     I was subpoenaed by you. I would also like to say that

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 1until this moment I have never met you, never spoken to
 2you and never corresponded with you.
 3 Q. [Mr Irving]     That is precisely what I was going to ask next. In other
 4words, I have not rehearsed with you in any way what
 5I might or might not ask you by way of questions?
 6 A. [Sir John Keegan]     I would not have agreed to that in any case.
 7 Q. [Mr Irving]     Yes, of course.
 8 A. [Sir John Keegan]     Sir John, you are now Defence Correspondent for Telegraph
 9Newspapers Limited?
10 A. [Sir John Keegan]     Defence Editor.
11 Q. [Mr Irving]     Defence Editor of Telegraph Newspapers Limited. How long
12have you held that post, please?
13 A. [Sir John Keegan]     I was Defence Correspondent to begin with in 1986 and
14became Defence Editor about 1990.
15 Q. [Mr Irving]     You have, it is fair to say, a very high reputation in
16England as what I might call an establishment historian?
17 A. [Sir John Keegan]     Well, I was knighted for services to military history
18 Q. [Mr Irving]     My congratulations and the congratulations of the court go
19to you for that very recent honour. It was in the New
20Year's Honours list?
21 A. [Sir John Keegan]     Yes.
22 Q. [Mr Irving]     I do not wish to detain you at all long, Sir John, here
23this morning. I am grateful to you for coming in spite of
24your disability. I just want to take you through a number
25of papers which I have handed to you a few minutes ago
26going back to 1980. I believe your Lordship also has that

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 1small clip of them?
 2 MR JUSTICE GRAY:     Yes, I do. Thank you very much.
 3 MR IRVING:     Do you remember writing an article for The Times
 4Literary Supplement in about April 1980?
 5 A. [Sir John Keegan]     Yes, I do not, because I review a great deal, but I am
 6quite sure that I did write what is quoted here.
 7 Q. [Mr Irving]     Is it right that in that review you wrote -- this is a
 8review of another book, not a book by myself?
 9 MR JUSTICE GRAY:     Well, both, is it not?.
10 A. [Sir John Keegan]     I am sorry, I did not understand the question.
11 MR IRVING:     This was not reviewing a book by me, was it? It
12was reviewing some other book.
13 A. [Sir John Keegan]     If you say so.
14 Q. [Mr Irving]     Is it right that you wrote the following words: "Two
15books in English stand out from the vast literature of the
16Second World War, Chester Wilmott, 'Struggle for Europe'
17published in 1952 and David Irving's 'Hitler's War' which
18appeared three years ago"?
19 A. [Sir John Keegan]     Yes, and that is my general opinion. I think that, taken
20together, they are -- if I were to recommend to a starter
21two books which would explain the Second World War from
22Hitler's side and from the Allies' side, those are the two
23books I would choose.
24 Q. [Mr Irving]     This does not, of course, mean that you endorse or accept
25all the views that I might be held to propagate in them or
26not, or otherwise?

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 1 A. [Sir John Keegan]     Indeed not, because later on in the papers you have given
 2me I reprove you for your lack of a moral point of view in
 3your discussion of Hitler and of his status relative to
 4Churchill and Roosevelt.
 5 Q. [Mr Irving]     Is it right to say that this opinion which you expressed
 6in that review was not only publicly held but also
 7privately held by yourself?
 8 A. [Sir John Keegan]     Yes. I often say you have to read Hitler's War.
 9 Q. [Mr Irving]     Can I draw your attention to letter No. 2 in the bundle?
10This is a letter from a man called Mr Alan Williams?
11 A. [Sir John Keegan]     Yes, he used to be my editor at the Viking Press, my
12American publishers.
13 Q. [Mr Irving]     Yes. The late Alan Williams was also my editor, of
14course, so he knew us both. Is it true that sometime
15early in 1980 you had a conversation with our mutual
16friend, Alan Williams, in which you commented on the same
17book 'Hitler's War'? Will you read, please, the middle
18sentences of the second paragraph? Does he state ----
19 A. [Sir John Keegan]     "John Keegan is, as you may know, writing a book for us on
20the D-day invasion. While we were talking about it, he
21said that there were two general survey books that really
22stood head and shoulders above all the rest, one of them
23the Chester Wilmott and the other 'Hitler's War'".
24 Q. [Mr Irving]     He did not know ----
25 A. [Sir John Keegan]     "He did not know I had any involvement with the latter
26volume when he said this".

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