Archive/File: people/i/irving.david/libel.suit/transcripts/day004.05
Last-Modified: 2000/08/01

   Q.   What I am suggesting to you, Mr Irving, is very simple.
        It is simply this.  You cannot tell from looking at these
        two paragraphs which is Hitler and which is Goebbels?
   A.   I think that is a very fair comment, yes.
   Q.   Yes.  So if (and we are dealing in probabilities, as
        I remind you, not certainties) as seems likely, the second
        of those two paragraphs is, as you have just told us,
        Goebbels' version of what Hitler said to the Gauleiters on
        12th December, then so is it as likely that the first
        paragraph is in precisely the same case, is it not?

.          P-37

   A.   Mr Rampton, that is not what I said.  I said it is
        Goebbels' version of Hitler's intentions, not what he
        said.
   Q.   Where do you think that Goebbels derived his impression of
        Hitler's intention?
   A.   Over a long period of sitting with him and talking with
        him over many weeks and months.
   Q.   So this is nothing whatever to do with what Hitler is
        supposed to have said to the Gauleiters, is that your
        case?
   A.   When you are writing a diary this is what happens.  You
        put in information from what has just been told to you,
        but also your own external knowledge of what the person is
        thinking and saying.  You cannot encapsulate individual
        phrases like that.  If it was a shorthand record, it would
        be different.  I prefer using shorthand records or even
        the table talk which is written in the first person form.
   Q.   Well, I do not think I will push it any further,
        Mr Irving.  We have your answer.  I certainly do not
        accept it.  I put it to you that it is perfectly clear
        that this is Goebbels' version of what Hitler said on 12th
        December 1941.
   A.   I think it is possible that you and I and Dr Longerich
        have different criteria when we are evaluating documents.
   Q.   Mr Irving, does it not read very naturally as a direct
        speech account of the Fuhrer's thoughts as expressed on

.          P-38

        that occasion?
   A.   Which sentence are you referring to?
   Q.   Any one you like.
   A.   Well, I mean, if I give you a general statement of
        opinion, then you are going to apply it to one particular
        sentence and say, "Here you have agreed that this sentence
        is Hitler's statement on that day" and that is ----
   Q.   Well, look at the second paragraph.  Let us leave out the
        paragraph you do not like.
   A.   Yes.
   Q.   Let us look at the second paragraph at the top of page
        499.
   A.   Yes.
   Q.   "In the East, the Fuhrer sees above all" -- you correct me
        where I go wrong -- "our approaching India".
   A.   Yes.  "This is colonial territory that we are going to
        settle".
   Q.   Yes.  "This is colonial territory that we shall settle.
        Here great ----
   A.   "Farmsteads".
   Q.   "Homesteads" -- what?
   A.   Yes, "he already established great farmsteads for our
        peasant sons and the" ----
   Q.   Yes, and what are the "Kapitulanten"?
   A.   I do not know what that word means, I must confess.
   Q.   No. "unserer Wehrmacht gesch werden"?

.          P-39



   A.   "Created".
   Q.   "Created", exactly.  It is all part of the same thought
        process, is it not?
   A.   It may be but it may not be.  Nowhere does he say, "This
        afternoon the Fuhrer said".  This is just Goebbels writing
        down, waffling about what Hitler's views on the future
        are, and it is not ----
   Q.   I am sorry.  Finish your answer.  I do not mean to
        interrupt.
   A.   But may I also state and remind the court once more that
        was material which was not in front of me at the time
        I wrote the book, so I cannot really see, with respect,
        I would rise if I was now sitting and say, "What is the
        relevance of this material?"
   Q.   It may in the end turn out to be a small point, but, you
        see, Mr Irving, you are in the habit, are you not --
        I drew something to your attention on Thursday -- of
        asserting certainties where all that a cautious and
        responsible historian would do would be to say "It looks
        like it"?
   A.   I agree, this is absolutely right and in this particular
        case a responsible historian would say, "On this occasion
        Goebbels reported and it may well be that Hitler had told
        him on this occasion".
   Q.   But you told on Thursday that it was quite certain that
        this could not be Hitler, it must be Goebbels in the

.          P-40



        contentious paragraph because the tense changes from the
        past in the first sentence to direct speech in the second,
        well, from the ----
   A.   To be more specific, the part that Longerich alleged was
        Hitler being quoted was not in the subjunctive tense.  It
        was not in the subjunctive.
   MR JUSTICE GRAY:  We went through that in considerable detail
        on Thursday.
   A.   Yes, and also we are not referring to this paragraph, we
        are referring to one specific sentence.
   MR RAMPTON:  Now I want to go back, please, and you will see
        how it is going to develop as we go along.  I give you
        notice of what I am now going to do.
   A.   If I may just say, what alarms me is the fact that you had
        from my discovery the documents showing precisely how much
        of this diary was at my disposable when I wrote the book.
   MR JUSTICE GRAY:  We are moving on now, Mr Irving.  I take your
        point.
   A.   I appreciate that, but I think it is dishonest for them to
        have advanced this kind of argument.
   Q.   That is a comment you can make at the end of the case but
        let us get on now with the questions and answers.
   MR RAMPTON:  You will have that opportunity.  What I am going
        to do is I am going to start with your Kovno train which
        we dealt with on Thursday of 17th November 1941, and then
        I am going to use that as a way of opening the door to

.          P-41



        what I call system.  Do you understand?
   A.   Right.
   Q.   Can we, first of all, start with your Kovno train.  Have
        you that little bundle?
   A.   I do not, but I am quite familiar with the documents.
   MR JUSTICE GRAY:  Can you take me to it, Kovno train?  I am
        sorry, the significance of that is completely missing
to
        me.
   A.   The train from Bremen to Kovno.
   MR RAMPTON:  Could your Lordship first turn up page 13 of
the
        transcript for Thursday and the other documents, the
        little Irving documents I call them, are at tab 3 of
file
        J, my Lord, or should be.
   MR JUSTICE GRAY:  Yes.
   MR RAMPTON:  I would quite like Mr Irving to have both what
he
        said in court and the Cogno signal.
   A.   It is the intercept - correct?
   Q.   Has anybody got a spare transcript?  Page 5 is the
        translation, or the transcription, I know not which
and it
        does not matter.  Just have that open.  Is it possible
for
        him to have a transcript for Thursday?
   A.   I think I have the wrong bundle.  Are we talking about
        Cogno?
   MR JUSTICE GRAY:  That is what is going to happen when you
have
        all these little files knocking around.  We must put
them
        all in the same place.  I have them in J and I hoped

.          P-42



        everybody else was going to put it in J, tab 3.
   A.   I have J 1.
   MR JUSTICE GRAY:  To save time, could somebody pass up the
        bundle which has the index on the front of it?  It is
        called bundle C, Himmler.
   A.   This is bundle J 1 again.
   MR JUSTICE GRAY:  I do not think that is the right bundle.
You
        are talking about the clip that Mr Irving handed in?
   MR RAMPTON:  Yes, I am.
   MR JUSTICE GRAY:  Probably on Wednesday.
   MR RAMPTON:  Yes.
   MR JUSTICE GRAY:  He has called it Claimant bundle C
Himmler.
        I had hoped everyone was putting it in J but, wherever
it
        is, can somebody hand it up because every minute that
goes
        by is a waste of time.
   A.   I am very familiar with the document, if you wish to
        proceed.
   MR RAMPTON:  I think we can get most of it anyway, Mr
Irving,
        from what you said in the witness box.  We will not
spend
        any more time.
   A.   I read most of the document out, I believe.
   Q.   Yes.  Can I read from line 4 on page 13 of the
        transcript? "In this particular case what is
significant
        is that the man in Berlin is telling his recipient in
Riga
        on November 17th", in other words that same day at
6.25
        p.m., "transport train number blah has left Berlin for

.          P-43



        Cogno or Kaunat" -- in fact it is K A U N A S, is it
not,
        and sometimes Mr Irving, pausing there, sometimes in
        German K A U E N?
   A.   That is the problem.  A lot of these towns have three
or
        four different names.
   Q.   But it is all the same place, is it not?
   A.   Yes, Cogno and Kauen.
   Q.   Cogno is an old fortified, or fortress in the Latvian
        country side, or is it Lithuania?  It matters not
perhaps
        very much. "With 940 or more Jews on board, or 940
more".
        In fact it was 944, was it not?
   MR JUSTICE GRAY:  It obviously was.  I think that is
probably
        just a mistranscription.  Understandable.
   MR RAMPTON:  I think so too. "That was usually the rough
size
        of each train load of Jews, about 1,000 Jews.
Transport
        escorted by two Gestapo and 15 police officers.
Transport
        commander is criminal Ober SS Exner (?), and the man's
        name, who has two copies of the transport list with
him.
        Transport provided with ...".  We have not got the
German
        of this.  What is the German that you translate "as
        provided with"?
   A.   I would not like to hazard a guess.
   Q.   All right.  "With following provisions"?
   A.   Vorversehen (?)
   Q.   Provided?
   A.   Yes, literally.

.          P-44



   Q.   For seeing, as it were?
   A.   We must not mention the word Latin.
   Q.  "Provided with following provisions", and this is the
        interesting part, my Lord: "3,000 kilograms of bread,
3
        tons of bread for a two or three day journey, 2700 (it
        should read) kilograms of flour, nearly 3 tons of
flour,
        200 kilograms of peas, etc. 300 kilograms of
cornflakes,
        18 bottles of soup spices", -- then continuing in the
next
        message, 52 kilograms of soup powders, ten packets of
        something or other, we do not know, 50 kilograms of
salt,
        47,200 reichmarks in crates.  What do you suppose
those
        were for?
   A.   It was credits, credits.
   Q.   Yes, for whom?
   A.   I am sorry.
   MR JUSTICE GRAY:  What is the point of having them on the
        train?  That is really the question.
   A.   I imagine it was the same with bomber crews.  When
they
        flew to Germany, they carried money with them.  One
always
        needed money.  You cannot send a train load of people
        around Europe without money to pay for things.
   Q.   This money was for the 944 Jews, was it?
   A.   I do not think I applied that it was.
   Q.   I am asking you.
   A.   No, presumably not.  Presumably it was to cover
transport
        costs.

.          P-45



   Q.   All right.  Signed Gestapo Headquarters, Berlin, and
then
        this is Mr Irving speaking: "It is quite an
interesting
        document, my Lord.  It is the first kind of thing we
come
        across in my view to show that these trains were
actually
        well provisioned.  It is a bit of a dent, a tiny dent,
in
        the image we have, the perception as Mr Rampton calls
it,
        of the Holocaust today."  Why do you say that?
   A.   The image that we have from the literature is of coal
        trucks and cattle trucks being filled.  I am not
saying
        that this did not happen, but I am saying that the
image
        we have is that all that happened was that these
wretched
        victims were stuffed into trains, with no food and
water
        for three or four days, and shipped across Europe to
their
        deaths, when this and the subsequent telegram which we
        British intercepted, which I quote, indicates that
very
        substantial quantities of food were put on board these
        trains for the short journey, and that, in the next
        telegram, you will remember, it also added the fact
that
        they were carrying their appliances with them, food
and
        appliances.  So obviously people were sending them, at
        least the system that was sending them apprehended
that
        they were going to be doing something at the other end
        when they got there.
   Q.   What was German word for the appliances?
   A.   Gerat.
   Q.   And plural gerater?

.          P-46



   A.   No.  You would use it in the singular form.

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