Archive/File: people/i/irving.david/libel.suit/transcripts/day011.09
Last-Modified: 2000/07/20

   MR JUSTICE GRAY:  That is what I thought.
   A.   I think in my report I quote Dragon on that, for example.
   MR IRVING:  You quote who?
   A.   Dragon.  Now we go out.  I just want to ----
   Q.   Am I right in saying that Dragon is one of the principal

.          P-72

        witnesses for the Soviets when they produced their
        commission report?
   A.   I think Dragon came in in April.  Dragon was not in the
        original Soviet report, I think.  The Soviets produced a
        report in February or March and Dragon only appears in April.
   Q.   I am referring to USSR 008, the exhibit.
   A.   Yes.  I do not think Dragon was mentioned there, also that
        he testified for them when that report came out, in that
        report.  I could be wrong on that but I do not remember
        Dragon in that context.
                  Now we are back in the vestibule.  Go into the
        next room, again, and look at the incineration room.  In
        this case we have back-to-back incinerators with the
        firing pit between them, instead of in crematorium 2 the
        firing pits are behind the incinerators.
                  Now I would like to go back to the blueprint.
        In your bundle you have a great magnifications of this one
        showing, for example, the 30 by 40 size of these openings,
        which is very important.  There is a problem that 12 of
        these things were ordered, 12 of these gas tight shutters
        were ordered of 30 by 40 centimetres, in early 1943.
        Which were the 12?  If you start counting, we have one,
        two, three, four, five, six, seven, eight, which means by
        implication that, according to the design, there should
        have been 16 ordered.  So how do we explain the difference

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        between 16 and 12?  It is very obvious that this room, it
        was a modification, that is what I call the vestibule,
        that this was not going to be to be used as gas chamber.
        It is also actually described that only two of these rooms
        in the eyewitness reports were actually used as gas
        chambers and is not.  So then we enter with one, two,
        three, four, five, six and the same arrangement in
        crematorium 5, which then ends up as 12 gas tight 30 by 40
        centimetre shutters.  That is very important.
                  The second important thing, and Mr Irving has
        already pointed at that, are the drains.  This particular
        blueprint is one which exactly shows the drains.  That is
        why it was created.  So we see that on the existing copy
        we have here a drain, we have a drain there, and these
        drains are connected right there.  There is a drain right
        there, and they are connected to a pipe.
   Q.   Can you tell the court what they are connected to on the
        outside?  To the main sewage?
   A.   They are connected.  This continues.  This is not a main
        sewage system there.  But this obviously connects back to
        something.
   Q.   It does not just go into a hole in the ground, though,
        does it?  They do something with it at the other end?
   A.   No.  This probably goes on right there all the way, yes.
   Q.   What would environmentalists have to say about kilograms
        of cyanide being dumped in the sewage system, do you

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        think?
   A.   I think that virtually all the cyanide would have been
        cleared out of the building.
   MR JUSTICE GRAY:  I think we had this debate before.
   MR IRVING:  It is very useful, my Lord, actually to see the
        drainage system.  We only have Professor van Pelt's word
        for it that all the cyanide would have gone out of the
        building, none of it would have been washed off down into
        the sewage system, which is clearly wrong.  Neither of us
        is an architect.  We agree on that point.  But the
        evidence of our eyes on that plan is that they had the
        drainage going into the public sewage system, and 8
        kilograms or however many of cyanide being pumped into
        those rooms to kill people on a lethal scale, and the
        bodies being washed down, the room being washed down
        afterwards, and you are telling us that none of that
        cyanide would have gone into the environment?
   A.   I certainly think that you are a little over estimated on
        the eight kilograms, to start with.  The gas thing in this
        building could have been very well done in these rooms
        with 200 gramme tins, maybe two 500 grammes, maybe a kilo
        was used, a kilo of cyanide and most of it would have
        evaporated into the air.
   MR JUSTICE GRAY:  I am sorry, Professor I am going to interrupt
        you.  We must stick to the drawings.  We are going down a
        side track.  Of course you can come back to it, Mr Irving,

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        but I think it really is going to be confusing if we go
        into that argument now.
   MR IRVING:  While we had the drainage map in front of us my
        Lord, I wanted to----
   MR JUSTICE GRAY:  That is established.  It is linked up,
        apparently or possibly, probably I think, to the main
        sewage system of the camp.
   MR IRVING:  It goes to the water purification plant.
   MR JUSTICE GRAY:  No, not that, I think.
   A.   So the major point here is that the evidence of the
        blueprint of these spaces, with these little windows right
        on top there, converges with the document which talks
        about the gas tight shutters of 30 by 40 centimetres,
        converges with eyewitness testimony which talks about SS
        men getting up a little stool or step ladder there and
        opening the gas tight shutters and throwing in the
        contents of a Zyklon-B canister, and it converges also
        with a detail right here that in fact it is difficult to
        see in this one that they are actually sealing, sitting
        right in here.  The roof is not open to the rafters but
        there is no sealant in there.  So why actually this very
        low bit here?  It is around 2 metres high.  You also start
        to put a sealing when you do not put the sealing in
        anywhere else.  So this is as much as I want to say right
        now about crematorium 4.
   MR IRVING:  Did these eyewitness you talk about see what was on

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        the other side of the wall through which this stuff was
        being tossed?
   A.   No, they were on the outside.
   Q.   Yes.
   A.   This is crematorium No. 1.  I think we can leave it.  This
        is at the moment the case I would like to make for
        crematoria No. 2, and crematorium No. 4, and by
        implications 3 and 5.
   MR JUSTICE GRAY:  I was going ask you that.
   MR IRVING:  While we have that map up, can I ask  you which is
        the fuel supply, which is the room for storing the coke?
   A.   This is it right there.
   Q.   The whole of that room.  Can you estimate approximately
        how much coke that would hold, how many tonnes or
        kilograms?
   A.   I cannot, I am sorry.
   MR JUSTICE GRAY:  Does that conclude our looking at the
        blueprints?
   A.   Yes.
   MR JUSTICE GRAY:  So we can turn the lights on?
   A.   Yes, unless you want to see more of the same.
   MR JUSTICE GRAY:  No.  I think I understand what you tell us
        about them.  Thank you very much.
   A.   Just for your understanding, in the last discussion quite
        important are No. 9A and No. 9B in your bundle.
   MR JUSTICE GRAY:  In tab 2?

.          P-77

   A.   In tab 1.  The important point is the 30 by 40, which is
        seen there in the size of these little windows.
   MR JUSTICE GRAY:  Yes, Mr Irving.
   MR RAMPTON:  Before this cross-examination continues, I need to
        draw your Lordship's attention to something.
   MR JUSTICE GRAY:  Yes.
   MR RAMPTON:  On Wednesday evening we received a document, which
        we have never seen before, which I do not believe
        Professor van Pelt has seen, which Mr Irving has because
        we sent it to him on Thursday once we had had it
        translated, and which has a bearing, or your Lordship may
        think it has a bearing, on this repeated question why are
        not these documents marked "secret".  I do believe that,
        in fairness to the witness who I believe, I do not know,
        is not familiar with this document, he and your Lordship
        should be allowed to read it before the cross-examination
        continues.
   MR JUSTICE GRAY:  Is this not re-examination?
   MR RAMPTON:  No.  I could bring it into re-examination but, if
        your Lordship would read it first, that perhaps is the
        best thing.  It will save time in cross-examination
        because the witness will then be familiar with the
        document.
   MR IRVING:  Are you also offering a translation of this
        document?
   MR RAMPTON:  Yes.  Have you not got that?

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   MR IRVING:  I have not.  I have only the actual document but
        not translated.  (Same handed).
   MR JUSTICE GRAY:  What is the second document, Mr Rampton?
   MR RAMPTON:  There is another document.  The document which is
        clipped to it is the translation.
   MR JUSTICE GRAY:  I have just been handed something headed
        "Heinrich Himmler".
   MR RAMPTON:  I do not think that arises now.  That will arise
        in re-examination.
   MR JUSTICE GRAY:  Where I shall I put this?
   MR RAMPTON:  It is the document of 5th May 1943. It can go in
        at the end of section 4 of K2, just before page 49 if your
        Lordship wants to put them in date order.  That means a
        different page number.  I do not know whether the witness
        has it?  I do not know what he is looking at.
   MR JUSTICE GRAY:  I think he is looking at the right thing.
        5th May 1943?
   MR RAMPTON:  Yes, 5th May 1943.
   MR JUSTICE GRAY:  Professor van Pelt, is that what you are
        looking at?
   A.   I know this one, yes.
   Q.   You know that one?
   A.   I mean I have seen it.  In my files there is a copy of
        that.  I had forgotten about it.
   MR RAMPTON:  I did not know that.
   MR JUSTICE GRAY:  Anyway, you have it now.  Yes, Mr Irving.  I

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        am sorry about that interruption.
   MR IRVING:  Your Lordship will anticipate the first thing I
        will say, which is that this is not the way to do things.
        This was supplied to me yesterday afternoon at 1 p.m.  It
        is a document of great importance, I appreciate that.  It
        is the document which I would have wished to have seen
        many months ago.  We have just heard the witness say that
        he has had it in his files for some considerable time.  If
        it was of importance, no doubt he would have advanced it
        already.  He may well have reached the same conclusions as
        I did that there are perfectly plausible explanations for
        this document which have a bearing only on one room in the
        crematorium concerned, or the building concerned, and have
        no relevance for the Final Solution, apart from that very
        limited aspect.
   MR JUSTICE GRAY:  I do not think it is sensible to have an
        inquest as to why it has been produced late.  That has
        been happening on both sides. The fact is we have it.  In
        the end I am not going to ignore it.
   MR IRVING:  If your Lordship is going to allow it to be
        produced in this manner, then there must be some manner
        for me to respond to the document.  I seek your Lordship's
        guidance as to the appropriate means of doing this.  By
        putting questions to the witness on this matter?
   MR JUSTICE GRAY:  Of course you can.  Indeed, why not do it
        now?

.          P-80

   MR RAMPTON:  That is why I produced it.
   MR IRVING:  Yes, indeed.
   MR JUSTICE GRAY:  Yes.
   MR RAMPTON:  Professor van Pelt, how long has this document
        been in your possession, in rough terms?
   A.   I saw this document in 1990 for the first time.  I made a
        copy of it, and I have forgotten since then.  My Auschwitz
        archive is something like that wall there, and I have
        forgotten about it since.
   Q.   So you attached little importance to it at the time you
        first saw it?
   A.   No, but it was in accordance with other things I had heard
        in the Ertl Dejaco trial about the way the design office
        operated and already in the Dejaco Ertl trial they had
        made a lot about indeed the fact that there was a great
        limitation to the number of people who could actually be
        entrusted with these drawings.  In some way I did not
        write in the end a book on the procedures of the
        Zentralbaleitung.  I know that Mr Montonia has done so.
        So in the end I forgot about it and it has been sitting in
        my files unseen and unthought of now for the past nine
        years, I assume.
   Q.   Would you accept from me that, had I seen a document like
        this I would certainly have turned it over in my hands for
        many weeks, pondering the significance of it and wondering
        whether it was to be mentioned in my major work or at

.          P-81

        least disregarded on a footnote, and not suppressed, shall
        we say?
   A.   Mr Irving, I forgot.  In the end, I did not write a book
        on the work of the Zentralbauleitung.  I forgot about this
        document because I addressed other issues.

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