Ирвинг против Липштадт
Holocaust Denial on Trial, Trial Judgment: Electronic Edition, by Charles GrayTable of Contents
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Himmler minute of 22 September 1942 (paragraphs 5.187-198 above)
13.39 I consider that the interpretation of Himmler's terse note is problematic. I recognise that there are pointers (including for example the reference to Globocnik) which might be said to render this an incriminating document. But there is force in Irving's argument that the internal evidence consisting in the language used in the note (auswanderung or emigration) is consistent with the discussion between Himmler and Hitler having been about resettlement and not extermination.
13.40 That said, I accept the validity of the criticism that there was no warrant for the claim made by Irving that at that meeting Himmler pulled the wool over Hitler's eyes. In my judgment, that claim ignores the circumstantial evidence as to the state of Hitler's knowledge by September 1942 of the use of gas chambers to kill Jews. It also runs counter to the evidence of the nature of the relationship between Hitler and Himmler, who does not appear to have been a man likely to have practised a deception of this kind on his Fuhrer. I therefore accept the contention of the Defendants that Irving's treatment of this minute is unjustifiably favourable to Hitler.