Irving v. Lipstadt


Holocaust Denial on Trial, Trial Transcripts, Day 19: Electronic Edition

Pages 136 - 140 of 217

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    My point here is that you are in paragraph 3, page 107, is
 1that you are suggesting without any evidence whatsoever
 2that the numbers of Jews killed listed in the
 3Einsatzgruppen reports were exaggerated by the task force
 4leaders. "Statistics like this are meaningless", I quote
 5you as saying. "It is possible that sometimes an
 6overzealous SS officer decided to put in a fictitious
 8     All this is -- I mean, elsewhere you are
 9extremely concerned to have authentic, authenticated
10documentary evidence for what you are saying or for, let
11us say, Hitler's involvement in the extermination of the
12Jews, but here you are indulging in what I think is wild
13speculation unsupported by any documentary evidence at
14all. That is the point I am making in this paragraph.
15 Q. [Mr Irving]     So when you see a figure referred to in a decode or in a
16telegram or in a report, you accept that this figure is
17necessarily accurate and there is no need to analyse it
18and investigate the feasibility of such a figure?
19 A. [Professor Richard John Evans]     No, I did not say that. I mean, I think obviously one
20looks for documentary evidence which will corroborate it
21or falsify it, but I think that is rather different from
22speculating simply that the officers might have written in
23phoney figures. There is no evidence for it.
24 Q. [Mr Irving]     Was one of the German Army officers who were put on trial
25after the War by the British for his part in these
26atrocities Field Marshal Von Manstein?

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 1 A. [Professor Richard John Evans]     Yes.
 2 Q. [Mr Irving]     Have you read the account of his case by Paget QC who was
 3his Defence counsel?
 4 A. [Professor Richard John Evans]     I have to say I have not, no.
 5 MR JUSTICE GRAY:     That does not stop you asking the next
 6question if you want to, although I am not necessarily
 7encouraging you.
 8 MR IRVING:     I cannot lead evidence. We have had this same
 9problem before. I should really bring along the pages and
10put the pages to the witness. That is the only way to do
11it, my Lord, I think.
12 MR JUSTICE GRAY:     I do not think anyone would mind if you put
13the next question and just see if you can get an answer
14from Professor Evans.
15 MR IRVING:     Very well. If Manstein's Defence counsel in this
16British Army court in Hamburg put it to the prosecutors
17that the Einsatzgruppen did not have the logistical means,
18in terms of manpower and truck space, to carry out the
19killings they claimed to have carried out, would that not
20be justification for casting doubt on the integrity of
21some of the figures?
22 A. [Professor Richard John Evans]     No, not of itself. I mean, I think one would have to look
23at the evidence which was presented of the logistical
24means and weigh it against the evidence for the numbers
26 Q. [Mr Irving]     To your knowledge, had any of the historians on the

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 1Einsatzgruppen carried out this kind of exercise, carried
 2out feasibility studies on the numbers?
 3 A. [Professor Richard John Evans]     I cannot answer that in reference to what the Defence said
 4in the Manstein trial, but certainly there is a great deal
 5of writing about the Einsatzgruppen which goes into
 6enormous detail about what they did.
 7 Q. [Mr Irving]     There is. Do you accept that SS officers would have had a
 8motive to try to inflate their achievements in order to
 9compare their prowess as opposed to the neighbouring
10Einsatzgruppen, if I can put it like that?
11 A. [Professor Richard John Evans]     I do not really know of any evidence for that.
12 Q. [Mr Irving]     Was there a similar phenomenon in the Vietnam War that you
13are familiar with?
14 A. [Professor Richard John Evans]     I really do not know.
15 Q. [Mr Irving]     Moving on to the famous December 1942 document, the report
16to Hitler with the 300,000 figure in it, are you roughly
17familiar, in vague terms, with that document?
18 A. [Professor Richard John Evans]     Yes.
19 Q. [Mr Irving]     I do not think there is any need to look at it. You
20comment on the fact that I said that I was unhappy about
21it because it is an unusual, isolated document. We are
22now at the top of page 108, my Lord.
23 A. [Professor Richard John Evans]     Yes, I have that.
24 Q. [Mr Irving]     Is a responsible historian not entitled to be unhappy
25about a document if it appears to stick out slightly from
26the rest of the body of documentation?

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 1 A. [Professor Richard John Evans]     Well, I think what you -- firstly, this is a habit that
 2you have, Mr Irving, of labelling documents that you do
 3not like as being orphan documents. In the course of this
 4trial in your work you have accumulated enough orphan
 5documents to fill half an orphanage. There are many of
 6these documents -- I have counted at least half a dozen --
 7and the problem is ----
 8 Q. [Mr Irving]     I do accept the document is genuine.
 9 A. [Professor Richard John Evans]     --- when you encounter, when an historian encounters a
10document that runs counter to the thesis that he or she is
11trying to put forward, then you have to take it
12seriously. You do not try to find every possible means
13you can of discrediting it and doing away with it. You
14have to look at it and try to deal with it. That may be
15it that it means you have to revise the views that you
16came to the document with.
17 Q. [Mr Irving]     Are there not certain questions that a responsible
18historian should put when he is facing a document like
19that look which is egregious, that he should say to
20himself (a) is the document genuine -- well, we have
21decided that it is -- but (b) what about the content of
22the document? Is it serving a particular purpose which is
23not what might at first appear. Should he not ask himself
24questions like that?
25 A. [Professor Richard John Evans]     I think you ask all the questions on all documents. You
26ask the question, who wrote it? What for? Who was it

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 1addressed to? Is it authentic? And so on.
 2 Q. [Mr Irving]     And the more remarkable the document, the more unhappy you
 3should be, if I can put it like that?
 4 A. [Professor Richard John Evans]     I think you look at all documents -- one should look at
 5all documents in roughly the same way.
 6 Q. [Mr Irving]     Yes. You comment on the fact that my books do not publish
 7photographs of concentration camp victims. I am now on
 8paragraph 5, 109.
 9 A. [Professor Richard John Evans]     Yes.
10 Q. [Mr Irving]     Page 109, paragraph 5: "By contrast", you write, "there
11re no pictures of concentration camp or extermination camp
12inmates or victims". Is this a serious criticism of my
14 A. [Professor Richard John Evans]     Yes, I think you have an illustration section in the 1991
15edition of Hitler's War where you include three
16photographs, but over two entire pages, of the victims of
17allied bombings of German towns, but you have no pictures
18of concentration or extermination camps' inmates or
19victims nor of any of the shootings, and so I add. So
20that does seem to be me to be evidence of imbalance.
21 Q. [Mr Irving]     Yes. Are you suggesting that I should have included the
22drawings by David Olaire which have been figured in this
23case, for example?
24 A. [Professor Richard John Evans]     I do not want to go into any particular ones, particular
26 Q. [Mr Irving]     Would you accept ----

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