Irving v. Lipstadt
Holocaust Denial on Trial, Trial Transcripts, Day 22: Electronic Edition
Pages 36 - 40 of 207
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1 Q. [Mr Irving] Would you accept that I am expert in digging pits, having
2worked in my early years as a student as a navvi for many
3years in order to finance my way through university?
4 MR JUSTICE GRAY: Mr Irving, come on. You can dig a pit as
5deep as you have got the energy to dig it.
6 MR IRVING: My Lord, that is a very hazardous operation if you
7are standing at the bottom of the pit and you dig it
8without any kind of shoring. I would now draw your
9Lordship's attention to one such pit which is photographed
10in the little bundle I gave you. It is the last item in
11the bundle. It provides a useful check point for the
12depth that these pits go when they are only three metres
14 A. [Professor Richard John Evans] And you are saying, are you, Mr Irving, that this is one
15of the pits in Riga? This is an authenticated photograph
16of one of them?
17 Q. [Mr Irving] This is, well, as you can tell by the British soldier
18standing around with machine guns, this is probably
19Bergen-Belsen or Buchenwald, where the victims of Nazi
20atrocities are being buried by some of the perpetrators.
21 A. [Professor Richard John Evans] And what does that tell us about the pits in Riga,
23 Q. [Mr Irving] I am sorry, my Lord. You do not have the photograph?
24 MR JUSTICE GRAY: I think maybe I am missing a few pages off
25the back of this little clip.
26 MR IRVING: This is the photograph from my collection of
1original photographs that I have assembled over the years
2of Nazi atrocities.
3 MR JUSTICE GRAY: What is the question?
4 MR IRVING: Yes. Do you have the photograph in front of you?
5 A. [Professor Richard John Evans] Yes. I will take it out again.
6 Q. [Mr Irving] Can you give a rough estimate as to how wide and probably
7how long that pit or, at any rate, how wide the pit is?
8 A. [Professor Richard John Evans] Mr Irving, I am not -- this is not one of the pits at
9Riga. This is no relevance whatsoever to the matter we
10are dealing with.
11 Q. [Mr Irving] It is relevant to the matter of how deep you can dig a pit
12in circumstances like this ----
13 A. [Professor Richard John Evans] You can dig pit any depth you like, Mr Irving.
14 Q. [Mr Irving] Is that your expert evidence as a pit digger or can we
15apply some common sense?
16 A. [Professor Richard John Evans] As it happens, I have been having my house reconstructed,
17Mr Irving, recently ----
18 MR JUSTICE GRAY: That is as may be.
19 A. [Professor Richard John Evans] --- and people have been digging pits and I have watched
20them, so I do know something about digging pits.
21 MR IRVING: Can I ask my Lord, did your Lordship consider that
22it is possible now using that photograph to make some
23basic assumptions about the kind of pits and graves that
24were dug and whether they had layers of soil on top of
26 MR JUSTICE GRAY: Put your case briefly for saying that the
1pits could have contained -- well, put your case briefly.
2 MR IRVING: Would you agree, as General Bruns describes, the
3ditch was 24 yards long and 3 metres wide, and if it was 2
4metres deep, that would be 144 cubic metres?
5 A. [Professor Richard John Evans] 25 metres long and 3 metres wide? No, I do not, no. They
6could have dug it any depth they wanted to.
7 Q. [Mr Irving] We will ignore that remark for the moment and continue
8with this calculation, please. Will you agree that if the
9pit is 25 by 3 by 2 metres deep, for an example, it would
10be 150 cubic metres?
11 A. [Professor Richard John Evans] I am not going to challenge your mathematics, Mr Irving,
12but it really is not a very relevant question. I do not
13know how deep these pits.
14 MR JUSTICE GRAY: Let him continue. I see which way he is
15going. That is on the assumption it is 2 metres deep, the
16arithmetic is right.
17 MR IRVING: Yes. Would you agree that the bodies were not left
18exposed, that there was a certain amount of back fill done
20 A. [Professor Richard John Evans] Yes, if you wish.
21 Q. [Mr Irving] So, in other words, 2 metres of this hypothetical pit
22would not be used. But let us assume that it was used and
23let us assume that the walls went straight down, they did
24not slope inwards, as you can see in the photograph which
25is before you, so there we would have 150 cubic metres,
26and you can get about 10 bodies to a cubic metre if you do
1a calculation with which I will not bother you. So how
2many bodies would be in that pit, just on that rough order
4 A. [Professor Richard John Evans] You say this all in your footnote, "It would have held 1
5or 2,000 victims each", that is what you say, but it is
6entirely hypothetical. There is a number of "ifs" in that
8 Q. [Mr Irving] Just one "if"?
9 A. [Professor Richard John Evans] --- if that is the question you were asking. It is
10entirely hypothetical. We do not know how deep this pit
12 Q. [Mr Irving] So if it was 2 metres deep and if it had straight sides
13and if there was no back fill ----
14 A. [Professor Richard John Evans] That is three "ifs", Mr Irving.
15 Q. [Mr Irving] --- would you stop interrupting -- you would get 1,500
16bodies into that pit, is that right?
17 A. [Professor Richard John Evans] Yes.
18 Q. [Mr Irving] So if it was another metre deep, you would get another 750
19in, so you can do an order of magnitude calculation, can
21 A. [Professor Richard John Evans] On the basis of those four "ifs", yes, you can do any
22calculation you like.
23 Q. [Mr Irving] So you can do a ball park calculation of two or three pits
24of that kind of size and magnitude would hold of the order
25of, say, three to 7,000 bodies?
26 A. [Professor Richard John Evans] Yes, on the basis of those four hypotheticals, yes.
1 Q. [Mr Irving] Did you bother to do such a check sum before you
3 A. [Professor Richard John Evans] I did not know how deep the pits were, Mr Irving. My
4criticism is that there is no evidence of the depth of the
5pits. You do not provide any. You simply make all these
6if, if, if assumptions and then somehow treat them as
8 Q. [Mr Irving] Do you accept that when you are writing history and you
9cannot get all these documents on hand, occasionally you
10have to make common sense calculations and deductions?
11 A. [Professor Richard John Evans] This is not common sense, Mr Irving. This is a systematic
12attempt to undermine the figure given of 27,800 Jews,
13suggesting that this is too large. This is typical of
14your minimisation of the statistics of the numbers of Jews
15killed in any number of instances.
16 MR JUSTICE GRAY: Right. On to the next point, Mr Irving. I
17think we have exhausted that.
18 MR IRVING: My Lord, I just say, you do accept that I had a
19document which stated the figure of 5,000, and that it is
20within the order of magnitude that the pits would allow?
21 A. [Professor Richard John Evans] No.
22 Q. [Mr Irving] When you write books, Professor, just as an after thought,
23do you ever bother to look at photographic evidence like
25 A. [Professor Richard John Evans] I look at photographic evidence, yes.
26 Q. [Mr Irving]
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