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1. Introduction

1.1. Professional qualifications of the author

I am professor of politics and culture at the Political Science Institute [Otto-Suhr Institute] of the Free University of Berlin.

1.1.2. I was born in 1944 in Guhrau in Silesia. High school completed in 1964, I served my military service from 1964 to 1966. In 1971 I gained my diploma in political science at the free University, where I became a part-time teaching assistant at the Political Science Institute from 1971 to 1976. I gained my Ph. D. on the political sociology of work-conditions, with special reference to Frederic W. Taylor [summa cum laude]. From 1977 to 1983 I was awarded a research fellowship at the Science Centre, Berlin to undertake empirical research on industrial relations.

1.1.3. In 1984 I took the German postdoctoral thesis [`Habilitation'], with a lecture on the theory and history of German anti-Semitism.. From 1983 to 1986 I undertook fiuther research and held guest-professorships at the Technical University of Copenhagen [Tekniske HojskoleJ, the University of Linz in Austria, and the Darmstadt College [Fachhochschule]. From 1986 to 1988 I researched the conditions of Jewish emigration from Nazi-Germany. From 1988 to 1989 I held a guest-professorship [Vertretungsprofessur] of the Alexander Schwan chair of political philosophy, the Free University Berlin. From 1989 to 1992 I was the German Academic Exchange Service [Deutsche Akademische Austausch Dienst] professor of German Area Studies at University College Berkeley, California, specialising on modern history, German literature, and politics.

1.1.4. Since 1993 I have held my current chair as professor of political science (politics and culture) at Free University Berlin. My main fields of interest are right-wing extremism, ethno-centric nationalism, and social prejudice with case-studies of Bosnia and Kosovo, Southeast Europe.

1.1.5. I reconstructed and analysed the ideology of the right-wing oriented German political

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party the `Republicans', particularly in reference to its hatred of foreigners, its anti-Semitism, and its ultra-nationalism. I have also analysed the ideas and roots of ethnocentricity within German nationalism. Since 1993 I have been engaged in researching the sociological, ideological, and political dynamics of right-wing extremism following German unification. I have also examined the ideological roots of rightwing extremism, for instance the anti-democratic `conservative revolution' of the Weimar Republic. Since 1995 My research and published work has concentrated on the sociological and ideological aspects of violence within right-wing and left-wing extremist movements, especially amongst the younger generation in east-Germany. I have written on the neo-Nazi network, and the role played in them by radical revisionism and social prejudices, especially anti-Semitism and a hatred of foreigners. My most recent publication examines the Southeast European crisis and the ideology and the political causes of ultra-nationalism in that region.

1.1.6. I am author or co-author of

Hajo Funke, Die Republikaner. (Berlin, 1989).

Hajo Funke,"Jetzt sind wir dran" - Nationalismus im gecinten Deutschland Aspekte der Enigunspolitik and nationalistische Potentiale in Deutschland (Berlin, 1991).

Hajo Funke, Brandstifter (Göttingen, 1993).

Hajo Funke, Markus Kemper, and Harald Klier, "Ich kann mich nicht daran gewöhnen " - Fremdenfeindlichkeit in Oranienburg (Berlin, 1998).

Hajo Funke and Alexander Rhotert, Unter unseren Augen. Ethnische Reinheit: Die Politik des Milosevic-Regimes and die Rolle des Westens (Berlin, 1999).

1.1.7. I am the editor or contributor to the following:

Hajo Funke (ed.), Von der Gnade der geschenkten Nation. Über die politische Kultur (1988).

Hajo Funke, Die andere Erinnerung (Frankfurt, 1989).

Hajo Funke, `Rechtsextremismus - Zeitgeist, Politik and Gewalt. Eine Zwischenbilanz', in Richard Faber, Hajo Funke, and Gerhard Schönberner (eds.), Rechtsextremismus, Ideologie and Gewalt (Berlin, 1995).

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Hajo Funke, `Die Republikaner', in Jens Mecklenburg (ed.), Die braune Gefahr (Berlin, 1999).

1.1.8. I am likewise the author of various articles on nationalism, RWE, right-wing extremism including:

Hajo Funke and Elliot Neaman, `Germany - the Nationalist Backlash', dissent, winter 1993.

Hajo Funke and Lars Rensmann, "`Out of a German soul". Why Martin Walser can't understand Ignatz Bubis', Allgemeine Jüdische Wochenzeitung, 24 December 1998.

Hajo Funke, "`When memory comes". On solidarity with the unknown. On the debate of the Berlin-holocaust-Mahnmal,' Freitag, 27 February 1998.

1.2 Scope of the report

1.2.1 The following expert opinion is given in the suit David Irving has brought against Deborah Lipstadt, especially with reference to the `defence of the second defendant' (1996 I. NO. 1113). In particular it will be examined that,

I) that the plaintiff has on numerous occasions denied the holocaust;

ii) that the plaintiff holds extremist views, and has aligned himself with others who do so, including individuals such as Dr. Robert Faurisson and Ernst Zündel;

and that,

14) Moreover, the plaintiff has strong links with Ewald Althans, the leading Neo-Nazi in Munich, who is anti-Semitic and racist (and proud of it). Althans booked the plaintiffs hotel in Munich for him under a pseudonym in May 1992, and sells and distributes the plaintiffs books, videos and cassettes.

15) As a result of the plaintiffs aforesaid views and activities, the plaintiff has been deported from Austria (inter alia, for his extremist views and his connections with the German extremist group, the DVU), and banned from entering Australia, Canada and Germany. The plaintiff has also been banned from the German state archives.

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1.2.2. And to the plaintiff's `reply to the defence of second

defendant' that

6. (i) it is denied that the plaintiff has denied the holocaust; it is denied, that the plaintiff has denied that gas chambers were used by Nazis as the principle means of carrying out that extermination...

(ii) it is denied that the plaintiff holds extremist views. He has on occasion taken issue with both, Faurisson and Zündel and with their views, and they have taken issue with him...

1.2.3. And further

(15) (ii) it is admitted that the plaintiff is currently banned from entering Germany... it is denied that the plaintiff has extremist views, and also that he has connections with any extremist German group. The DVU (German People's Union) is a long standing democratic and lawfully constituted German political organization which has competed in the national and municipal elections.

1.2.4. The following text will address in particular the plaintiff's denial that he holds extremist views and that he has connections to extremists in Germany. To address these points, it is necessary, to refer to the definition and concept of right-wing extremism [henceforth RWE] within the German official institutions responsible for the defence of the constitution, in particular the office responsible for defending the constitution [Bundesamt fur Verfassungschutz, henceforth OPC, i.e. office for the protection of the constitution] and the definition within the social and political sciences.

1.2.5. We.will first describe and analyse the peculiarities of RWE in Germany after 1945, in keeping with the definition of right-wing extremism outlined. In the second part of the first chapter we will reconstruct the development of the organizations and persons with RWE views in Germany, in so far as it is of importance to understand with whom David Irving has connections and with whom he co-operates.

1:2.6. We will further address the ideas and the strategy of the German People's Union [Deutsche Volksunion - DVU] and of its leader Dr. Gerhard Frey, as one of the central representatives of RWE in the 1980s, and further the specifics of David Irving's

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connections with the DVU. We will also look at the DVU in the context of the development of RWE in this period and beyond.

1.2.7. In the third chapter we will describe the changes within, and the radicalisation of RWE in the 1980s and early 1990s. We will outline the connection between these groups and the role of radical revisionist ideology in mobilizing their supporters. In the second part of the third chapter we will reconstruct the connections David Irving has had with these radicalized extremists and especially with Germany's neo-National Socialists [henceforth neo-Nazis] in the early 1990s, such as the National -Offensive. [Nationale Offensive - NO], National List [Nationale Liste - NL], or Ewald Althans and the Althans Sales and Publicity Organisation / Office for People's Enlightenment and Publicity [Althans Vertriebswege and Offentlichkeitsarbeit / Amt für Volksaufklärung - AVÖ].

1.2.8. We will also illustrate how in the late 1980s David Irving decisively took on extremist views on Auschwitz and the Holocaust, and moved into the radical revisionist camp around Robert Faurisson, Ernst Zündel, and Fred Leuchter. Together they constituted the core international propagators of the so-called 'Auschwitz lie' [`die Auschwitz Lüge'<1>. It is also important to consider the structural confluence of interest that bound the denialist or revisionist upsurge of the 1990s with the resurgent neo-Nazi movement in Germany.

1.2.9. Finally the report will discuss how Irving knowingly and wilfully violated the current laws of the Federal Republic of Germany, not in his self-appointed capacity as an historian, but as a political agitator for the revisionist cause, RWE, and neo-Nazi groups. This will involve an analysis of why the German authorities fined David Irving, banned (partially or fully) his speeches, and finally asked him to leave Germany and banned him from re-entering in 1993 - measures that give empirical weight to the OPC's analysis of Irving's political activities in Germany.

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1.2.10. The main body of the report will concentrate on the years 1988/9-1993, as these are the years involved in most of the accusations concerning David Irving's political activities. There would be much to say about the overlaps between David Irving's political activities in Germany and those in Austria, but by necessity I have chosen to deal exclusively with Germany. Persons named in the body of the text can be referred to in the appendix.

1.2.11. In the conclusion we attempt to answer the question posed in the introduction, especially if David Irving has connections with extremists in Germany and to what degree he co-operated with them? Does David Irving hold extremist views and in what form has he presented them to the German public?

1.3. Sources.

1.3.1. The arguments and opinions set out below have relied on those set out by the Plaintiff and the Defendant as set out their respective pleadings. In the course of writing I have relied mainly on the documents and materials released in the Plaintiff's further discovery.<2>

13.2. It is important at this juncture to comment on two items in the further discovery. David Irving's diaries, although named such, are not what one would consider diaries in the normal sense. Only rarely does David Irving comment on political activities or political issues. Much more they constitute a listing of daily occurrences and business (political or domestic). References in the diaries indicate that Irving at times gave copies to friends or used them to substantiate legal issues. This would suggest that they have been `sanitised' for other readers, and thus do not constitute a private but rather a public diary. As will be set out below important passages in Irving's diaries have not been released to the defence, sometimes consisting of a few days, sometimes weeks or even months. David Irving has also released many hours of video and audio material. As will become apparent Irving and those he associated with were almost

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obsessive in their recordings of David Irving's speeches in Germany. The suspicion is that some crucial speeches have not been disclosed. Where this suspicion arises it is noted.

1.3.3. Part of the duties of the German office for the protection of the constitution [Bundesamt für Verfassungsschutz - OPC] is to monitor those activities within Germany seen as extra-constitutional and more importantly anti-constitutional (see below). Since the late 1960s the OPC has published their monitoring activities and their judgements on parties, groups, and individuals. These findings are published in Germany at both a national and state level in the form of annual constitutional reports [Verfassungsschutzberichte, henceforth VSB]. They constitute an invaluable and authoritative source on extremism in Germany and more importantly on what activities and individuals are officially considered extremist in Germany by the authorities. In this sense the VSBs can be viewed as an equivalent in politics to say yearly government economic reports. The reports are consequently cited frequently in my report.

1.3.4. A certain amount of secondary literature has been relied on, particularly in identifying some of the more obscure figures and organisations Irving came into contact with. Some of it is what David Irving would consider `anti-fascist', although it has mostly been written by experienced and conscientious academics and researchers. In my own experience I have found that the material contained in such reference books is reliable, and that any short-comings are inherent to the secretive and conspiratorial nature of individuals and groups concerned.

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