Irving v. Lipstadt


Holocaust Denial on Trial, Trial Transcripts, Day 17: Electronic Edition

Pages 201 - 205 of 214

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    I do not know. I have not heard what he says
 1about this. I know that he does not ----
 2 MR JUSTICE GRAY:     Well, it is re-examination.
 3 MR RAMPTON:     No, this arose in the course of cross-examination,
 4this document.
 5 MR JUSTICE GRAY:     Yes, I know it did, but this point about
 6whether Jews are disjunctive as a category.
 7 MR RAMPTON:     Yes. Professor Browning said in his
 8cross-examination Jews are a separate category.
 9 MR JUSTICE GRAY:     Yes.
10 MR RAMPTON:     So I wanted to check with him against the German
11whether he thought that Longerich had translated it
13 MR JUSTICE GRAY:     Yes, I see.
14 MR RAMPTON:     He did not have it in front of him at the time
15when he said it, I think, actually.
16 A. [Professor Christopher Robert Browning]     Yes, I was doing that from memory and now I am looking at
17the document.
18 MR RAMPTON:     The second question is this. Again, this is said
19to be a document directed at the Vermacht, not at the SS
20or anybody else like that or the Gestapo. Who would have
21written it?
22 A. [Professor Christopher Robert Browning]     These would have been prepared in the General Staff,
23I think.
24 Q. [Mr Rampton]     Somebody underneath Jodl?
25 A. [Professor Christopher Robert Browning]     Yes, or even further down but in the Armed Forces, yes.
26 Q. [Mr Rampton]     Now, the numbers -- page 38 of your report, please,

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 1Professor, now -- this is the famous 97,000, I should say
 2"notorious". We do not need the German for this. I am
 3going to excuse the motor mechanic who is not good at
 4German grammar.
 5     Page 38: "Since December 1941, for example,
 697,000 were processed by three trucks in action, without
 7any defects in the vehicles being encountered".
 8     How many trucks did they use during this period,
 9December to June 1942?
10 A. [Professor Christopher Robert Browning]     They had two trucks that were there constantly. Another
11truck came and that is the one that had the accident that
12blew up. So most of time they had two trucks running,
13part of the time a third truck.
14 Q. [Mr Rampton]     I am going to use some arithmetic, then I will ask you
15further questions, if may? I do not know whether 1941 was
16a leap year or not, but there are from 1st December '41 to
171st June 1942, 172 or 173 days.
18 A. [Professor Christopher Robert Browning]     Yes.
19 Q. [Mr Rampton]     So let us assume it was not a leap year and it is 172. If
20you divide 97,000 by 172, that means they are processing
21564 people a day. If you divide that by three trucks --
22I know this is rough stuff and maybe the trucks did not
23have equal capacities -- that means roughly 188 people per
24truck per day. If they did, say, four trips a day, that
25would be 47 people per trip and that would mean -- when
26I say "a day" I mean on a 24-hour basis?

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 1 A. [Professor Christopher Robert Browning]     Yes.
 2 Q. [Mr Rampton]     That would mean there would be six hours, roughly
 3speaking, five and a bit, between each trip. Does that
 4seem feasible?
 5 A. [Professor Christopher Robert Browning]     We know the Saurer truck was much bigger than 40. We do
 6not know the size ----
 7 Q. [Mr Rampton]     What do you think its capacity was?
 8 A. [Professor Christopher Robert Browning]     The Saurer truck was, depending on, you know, women and
 9children or adults, would be between 50 and 80.
10 Q. [Mr Rampton]     Right.
11 A. [Professor Christopher Robert Browning]     But, in general, you know, I mean, I think as they show
12that the number per day is not beyond the capacity of the
13two and three trucks.
14 Q. [Mr Rampton]     Right. So four trips a day, that would actually cover the
15numbers involved, would it not?
16 A. [Professor Christopher Robert Browning]     Yes, we know in Semlin when they made -- they could do two
17trips a day and that would be all the way across Belgrade
18to a burial site that was much further away than the
19distance between the burial grounds and the Chelmno camp
21 Q. [Mr Rampton]     I mean, how long does it take to drive 20 kilometres in
22one of these trucks?
23 A. [Professor Christopher Robert Browning]     We are talking about driving about two or three kilometres
24from the camp.
25 Q. [Mr Rampton]     Two or three? That is a matter of minutes?
26 A. [Professor Christopher Robert Browning]     Yes. The longer period would be the period to gas. That

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 1is why the motors had to run inside the camp before they
 2left or the passengers would not be dead when they
 4 Q. [Mr Rampton]     From start to finish of the operation, what is your
 5estimate of how long it would have taken?
 6 A. [Professor Christopher Robert Browning]     Well, would you have to let the desired number of people
 7into the basement of the main building where they would be
 8undressed, force them up ramp into the truck, close the
 9truck doors, run the motor for probably 20 minutes, and
10then drive, given the issue of undressing and the driving,
11on the generous side, we would say an hour, and then you
12must empty the van and clean it out and drive back.
13 MR IRVING:     My Lord, this is purely speculative. He is not an
14expert on gassing operating ----
15 MR JUSTICE GRAY:     No, Mr irving, you must understand if you ask
16almost identical questions in cross-examination,
17Mr Rampton must be entitled to ask the same sort of
18questions in re-examination.
19 MR IRVING:     Well, I was objecting really to the question that
20was asked about how long would it take to gas them and...
21 MR JUSTICE GRAY:     But you went into the arithmetic, Mr Irving.
22That opens the issue for Mr Rampton. I am afraid you have
23to take that as being the rule.
24 MR IRVING:     Well, I asked a slightly vaguer question. He asked
25a specific expert question.
26 MR JUSTICE GRAY:     Again that is legitimate, I am afraid.

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 1 A. [Professor Christopher Robert Browning]     I would say this is not speculation in the sense that
 2I have read through virtually all the testimony of the
 3Chelmno trial and have seen a number of descriptions of
 4the operations, so to call what I have said speculation
 5would be unfair characterization.
 6 MR JUSTICE GRAY:     Well, it is speculation in the sense it is
 8 A. [Professor Christopher Robert Browning]     Correct.
 9 MR RAMPTON:     Yes, reconstruction. My real question is this.
10Those sorts of rates, whether it is two or three trucks in
11operation at any one time, whether it is 40 or 50 people
12in the truck at a time, whether there are three or four or
13five trips a day for each truck, does the figure of 97,000
14seem to you to be credible?
15 A. [Professor Christopher Robert Browning]     It is entirely credible.
16 Q. [Mr Rampton]     Can we please turn back to your L1 tab 7 documents and
17turn to page 74 where I think you were accused -- this is
18Hans Frank on 16th December accused by Mr Irving of
19deliberately suppressing significant parts of the German.
20It is the paragraph that begins "Die Juden"?
21 A. [Professor Christopher Robert Browning]     Yes.
22 Q. [Mr Rampton]     I only want you to look at the sentence, the next
23sentence, which begins: "[German - document not
24provided]". What would you say if you were going to say
25"gas" there?
26 A. [Professor Christopher Robert Browning]     "Vergasung".

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