Irving v. Lipstadt


Holocaust Denial on Trial, Trial Transcripts, Day 29: Electronic Edition

Pages 96 - 100 of 186

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    --- on our pages 16 to 17 of the typescript. Since the
 1capital to 18,000 in 1934 compared with 31,000 in 1933,
 2the damage caused still amounts to over 112.5 million
 3Reichsmarks", am I doing all right so far?
 4 A. [Mr Irving]     Yes.
 5 Q. [Mr Rampton]     And here we come to the conclusion after further
 6investigation that "a considerable or significant part, if
 7not the largest, of these fraudulent manipulations are
 8still committed by Jews."
 9 A. [Mr Irving]     Yes.
10 Q. [Mr Rampton]     Right, where did you get your figure of no fewer than
1131,000 cases of fraud committed by Jews?
12 A. [Mr Irving]     I am just now looking for the original quotation. What
13page was the original quotation? 43?
14 Q. [Mr Rampton]     It is 47. You have the year wrong, but I am not going to
15criticise you for that. You put 1932 instead of 1933, but
16leave that on one side.
17 A. [Mr Irving]     Have you checked the two books that I give as sources
19 Q. [Mr Rampton]     No. I have not checked the two books, Mr Irving. This is
20your primary source. The books have been checked, yes,
21and so I am not on false ground.
22 A. [Mr Irving]     Yes -- well, I will give you a conditional response which
23probably will not satisfy you, and say that if the books
24which are also given in the footnote, there are four
25sources given in the footnote, do not support the year
26which is different from the year contained in the document

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 1you gave me, or do not support the figure of 31,000, then,
 2clearly, the same kind of error has occurred here as
 3happened with the 1.20 a.m. telegram that in the course of
 4writing six separate drafts one after the other this kind
 5of error goes ----
 6 Q. [Mr Rampton]     You have ----
 7 A. [Mr Irving]     --- but it is a conditional response.
 8 Q. [Mr Rampton]     You have effectively doubled, or more than doubled, the
 9number of fraud cases attributed by this rabid Nazi
10Daluege to the Jews in Berlin in that year, have you not?
11At the very most, even if the Jews are 50 per cent, it is
12only 15,500 cases attributable, according to Daluege, to
13Jewish perpetrators?
14 A. [Mr Irving]     Yes. If you are right, then that is correct, but, I
15mean, I have to say that is a conditional answer not
16seeing all the sources.
17 Q. [Mr Rampton]     Right.
18 A. [Mr Irving]     And I would not be able to reconstruct that now because
19I no longer have access to the sources that I had at the
20time for the reasons you know.
21 Q. [Mr Rampton]     Why do you say that these are Interpol statistics in your
23 A. [Mr Irving]     Presumably from one of the sources.
24 Q. [Mr Rampton]     No. Interpol was not actually established as Interpol
25until after the war.
26 A. [Mr Irving]     I am very sorry, but, of course, the Haus an Wannsee, the

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 1famous Wannsee House, where the Wannsee conference took
 2place, was the headquarters of Interpol. Interpol was
 3actually founded by Reinhardt Heydrich.
 4 Q. [Mr Rampton]     Yes, but, no, it was not called Interpol, was it?
 5 A. [Mr Irving]     It was presumably written out in full.
 6 Q. [Mr Rampton]     Even assuming (which I do not) that this was an innocent
 7mistake on your part to double the number of offences
 8attributable to Jews, do you think it right when your
 9source is this man Daluege uncritically simply to take his
10figure as being right? You state it as a fact, you see.
11In probability, he had already doubled the figures at
12least, do you not think?
13 A. [Mr Irving]     You are faced with a problem, of course, when you are
14writing a history of the 1930s, you look at as
15many sources as you can of what sources are available.
16These are the sources from the German Federal archives
17which contain all Daluege's papers. It is very easy to
18say, "Well, why do you take those figures because I do not
19like those figures, why do you not take these figures?"
20You have to take some kind of figures from somewhere, and
21if you are writing the Battle of Britain and you are going
22for a long time to believe Winston Churchill's figures of
23how many Nazi bombers were shot down, and we no know that
24those are wrong. But there we have the benefit of
25complete access to records and you can correct the

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 1 Q. [Mr Rampton]     May I suggest, Mr Irving, that if a reputable historian
 2were writing about this, he would say, "According to the
 3Nazi propagandist, Kurt Daluege, whose figures are very
 4probably not reliable" ----
 5 A. [Mr Irving]     Yes.
 6 Q. [Mr Rampton]     --- perhaps as many as 15,500 frauds were attributable to
 7Jews", but to assert that that is what Goebbels would find
 8in 1932 is just the most appalling distortion of the
 9truth, is it not?
10 A. [Mr Irving]     I do not agree. I have made it quite plain what the
11source of this evidence is. You found it, your
12researchers found it. Everybody knows who Kurt Daluege
13was. He was not a Nazi propagandist. He was the head of
14the German police system. He was in a position to know.
15He is giving facts to a learned audience. They would be,
16no doubt, in a position to check and expose these facts if
17they were wrong. I certainly would not have said it was
18an Interpol function if I did not have the evidence for
19it, and I am not going to waste the court's time looking
20in these pages of Gothic script for the actual evidence
21for it, why would I have invented that? And, of course,
22if you look at the rest of the page ----
23 Q. [Mr Rampton]     I can think of a simple answer, Mr Irving ----
24 A. [Mr Irving]     If you had looked at the rest of the page that you did not
25read out, I have relied on the figures from the German
26Federal Statistical Office on the percentages and so on.

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 1I built up a very careful picture from all the regular
 2sources and, admittedly, we are -- I beg your pardon.
 3 Q. [Mr Rampton]     We are going to look at some of those in a moment,
 4Mr Irving?
 5 A. [Mr Irving]     And, admittedly, in this particular matter we have to rely
 6on a dodgy source which is what you are trying to suggest.
 7 Q. [Mr Rampton]     We do not have to, Mr Irving.
 8 A. [Mr Irving]     But then, of course, the Goebbels diaries are dodgy
 9sources too. They are diaries written about the arch Nazi
10liar, and you have to pick and choose and that is the
11problem you have when you are writing history about the
12Nazis and it is a problem when you write about history
13about anything.
14 Q. [Mr Rampton]     Oh, Mr Irving. Where in that Daluege, which is your
15primary source, that Daluege document, do you have find
16any reference to insurance swindles?
17 A. [Mr Irving]     What basis do you have for saying it is the primary source
18when it is a scource of four.
19 Q. [Mr Rampton]     It is the first source you cite?
20 A. [Mr Irving]     The reason for lumping several sources under one number is
21because otherwise the book is going to look like a rash of
22measles, every single word is going to have a note number
23attached to it. So it is the standard practice that you
24will lump three or four sources relating to the previous
25two or three statements, even if they are gathered up in
26one sentence, into one note number. This does not mean to

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