Irving v. Lipstadt


Holocaust Denial on Trial, Trial Transcripts, Day 23: Electronic Edition

Pages 186 - 190 of 237

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    490, in paragraph 11, you cast doubt on the secretly
 2 A. [Professor Richard John Evans]     No.
 3 Q. [Mr Irving]     Paragraph 11 on page 490?
 4 A. [Professor Richard John Evans]     No. Where do I cast doubt on that?
 5 Q. [Mr Irving]     490?
 6 A. [Professor Richard John Evans]     Right, I have it, paragraph 11.
 7 Q. [Mr Irving]     "Irving claims he had a fund of collateral documentary
 9 A. [Professor Richard John Evans]     Yes.
10 Q. [Mr Irving]     And you then lament the fact that there is this secretly
11recorded transcript which does not seem to have been
12included in my list of documents, and so on?
13 A. [Professor Richard John Evans]     Yes. I am very cautious there -- conscious I might have
14overlooked it, but it does not seem to be there.
15 Q. [Mr Irving]     You are not familiar with the XP series of transcripts
16which are in my files -- you accept that it is possible it
17was in the documents?
18 A. [Professor Richard John Evans]     Well, that is why I have phrased it cautiously there.
19 Q. [Mr Irving]     Page 491, paragraph 14, does that paragraph, far from
20being contradictory, not actually confirm that Ribbentrop
21asked Hitler and Hitler denied all knowledge and that was
22the end of it? This is the Maidonek episode.
23 A. [Professor Richard John Evans]     Well, no, he is just saying he did not know anything about
24it until the Maidonek affair. That is all it says.
25 Q. [Mr Irving]     493, paragraph 5.1.1. I just draw his Lordship's
26attention to the fact the witness appears to be pleading

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 1innuendos of words there which is not part of his remit.
 2 MR JUSTICE GRAY:     No, I will not pay any attention to that.
 3 MR IRVING:     Page 495, paragraph 5.1.5, if I can find it?
 4 MR JUSTICE GRAY:     Well, that simply says that he is going to
 5deal with the statistics and the numbers killed in the
 6raids on Dresden.
 7 MR IRVING:     Yes. You say that my number of deaths in Hamburg
 8of what I put at 48 -- did I say 48,000, 50,000?
 9 A. [Professor Richard John Evans]     48, 50,000, yes.
10 Q. [Mr Irving]     And you consider this number to be totally exaggerated and
11perverse and another example of my manipulation and
13 A. [Professor Richard John Evans]     It is not a very strong argument, but you do go for the
14highest number available.
15 Q. [Mr Irving]     Is the reason ----
16 A. [Professor Richard John Evans]     Which does not seem to have any basis and certainly is not
18 Q. [Mr Irving]     Have you not ----
19 A. [Professor Richard John Evans]     It certainly is not borne out by the local investigations.
20 Q. [Mr Irving]     Have you not repeatedly referred to the fact that I have
21gone for these 50,000 figure in Hamburg and the high
22figure in Dresden and Fortzheime and elsewhere as an
23example of the distortions and false statistics that
24I introduced?
25 A. [Professor Richard John Evans]     I think this is the only other mention of Hamburg, apart
26from the brief discussion of your use of the exaggerated

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 1figure in the caption to an illustration in one of your
 3 Q. [Mr Irving]     Are you now back peddling on that because ----
 4 A. [Professor Richard John Evans]     It is not repeated.
 5 Q. [Mr Irving]     Are you now back peddling on that because you have seen
 6the page from the strategic air offensive against Germany,
 7the official history which I have introduced in that
 8little bundle? My Lord, it is page 9 of the little
 9bundle, pages 8 and 9. Does footnote 1 say in regard to
10the Hamburg air raid: "In addition, there were 2,000
11missing. The total number of deaths was probably nearer
1250,000 than 40,000"?
13 A. [Professor Richard John Evans]     Sorry.
14 MR JUSTICE GRAY:     Sorry, page?
15 MR IRVING:     It is page 9 of the little bundle this morning, my
17 A. [Professor Richard John Evans]     It does not say which raid this was.
18 Q. [Mr Irving]     That is going to be your answer, is it?
19 A. [Professor Richard John Evans]     No, I mean, I take it that is 43, yes. Well, what I
20would say is that a responsible historian should in
21reaching an estimation of the number of people killed in
22bombing raid should look at all the available
23investigations there have been.
24 Q. [Mr Irving]     Would you consider ----
25 A. [Professor Richard John Evans]     And this is from 1961 which is relatively early after the
26event and does not actually give any source, any German

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 1source, at all.
 2 Q. [Mr Irving]     Would you consider ----
 3 A. [Professor Richard John Evans]     The German investigations in Hamburg of the bombing deaths
 4came to a much lower figure.
 5 Q. [Mr Irving]     Would you consider that Sir Charles Webster and Nobel
 6Franklin, the official historians who had the complete
 7captured German and British records at their disposal in
 8writing this multi-volume work, are reasonable historians
 9for another historian to use as a source?
10 A. [Professor Richard John Evans]     Well, let me -- two points -- yes, but this is 1961. I
11mean, there have been plenty of German investigations of
12the Hamburg bombing raids since then which a responsible
13historian would use. This is relatively early after the
14event and it does not cite any German material here at
16 MR JUSTICE GRAY:     We are talking about Hamburg here, are we?
17 MR IRVING:     Yes, we are talking about the 1943 raid on hamburg.
18Are you aware that volume 4 of this work contains the
19entire police president's report on the Hamburg air raid
20as an appendix?
21 A. [Professor Richard John Evans]     It is not cited here in arriving at the numbers killed.
22 Q. [Mr Irving]     Can you answer my question?
23 A. [Professor Richard John Evans]     Yes.
24 Q. [Mr Irving]     So, in other words, it does have German documents as
26 A. [Professor Richard John Evans]     Not cited as a basis for the their estimation of 50,000.

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 1In fact, the figure they give is 42,600, whoever has
 2reported that. Again, there is no footnoted source for
 4 Q. [Mr Irving]     Yes. Are you aware that ----
 5 A. [Professor Richard John Evans]     And their estimate of nearer 50,000 than 40,000 is very
 6much a guess, as the footnote makes quite clear.
 7 Q. [Mr Irving]     In 1961, of course, there were still the 50 year rule in
 8operation which prevented the official historians from
 9giving sources, is that correct?
10 MR JUSTICE GRAY:     Well, knowing what the sources said?
11 A. [Professor Richard John Evans]     Well, they certainly cite sources here.
12 MR IRVING:     My Lord, you can take it from me that the official
13historians in their volumes, the early volumes, unlike the
14later volumes, never gave sources.
15 A. [Professor Richard John Evans]     But the 50-year rule did not apply to German documents,
16Mr Irving ----
17 Q. [Mr Irving]     Have you ----
18 A. [Professor Richard John Evans]     --- at all. It applied ----
19 Q. [Mr Irving]     Answer the question then. As an historian ----
20 A. [Professor Richard John Evans]     It applied to British documents.
21 Q. [Mr Irving]     --- and as an expert witness before this court, no doubt
22you have read ----
23 A. [Professor Richard John Evans]     What I am saying is that they did not use German
25 Q. [Mr Irving]     As an expert witness before this court, you have, no
26doubt, read large numbers of the official histories. Do

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