Excerpted testimony by David Irving in the 1988 Zündel Trial in Canada

[David Irving testified as the twenty-third and final witness in the Zündel trial on Friday, April 22, Monday, April 25 and Tuesday, April 26, 1988.]


David Irving, the British historian and author, was permitted to testify as an expert in the area of the history of the Second World War. (33-9346)

Irving had worked as a professional historian since 1963 and was the author of between twenty and thirty books. These included Hess: The Missing Years, 1941 - 1945, The Service: The Memoirs of General Gehlen, Accident: The Death of General Sikorski, The Destruction of Dresden, The Secret Diaries of Hitler's Doctor, The Trail of the Fox, The War Between the Generals: Inside the Allied High Command, The German Atomic Bomb, Convoy: The Destruction of Convoy PQ 17, The Mare's Nest, The War Path, Hitler's War, The Morgenthau Plan, Breach of Security, Uprising, and Churchill's War.

As a historian, he was interested in contemporary history; that of the twentieth century. Irving himself came from an English service family. His father was a Royal Navy service officer. For twenty-five years, Irving had researched in archives around the world, including Canada, the United States, France, East and West Germany and other countries. He had also had the co-operation of the archives in Israel and the Soviet Union. (33-9312 to 9325)

He was "very familiar with the records of the German High Command and the other German wartime government agencies." He had acquired this knowledge and expertise initially at Alexandria in Virginia, where the archives were originally stored after they were seized by the American army. The documents had been subsequently sent back to West Germany. They were still available in Washington partly in original form and partly on microfilm. A number of records were also held by the British government. (33-9325)

Irving had also done in-depth research into the life of Adolf Hitler: "For ten years I researched Hitler's life based entirely on primary records. I don't believe in buying other people's books or reading them on Adolf Hitler. We can readily surmise there must be many tens or hundreds of tons of books. I think it's easier to go to the archives and look at the documents. That way you avoid soaking up other people's prejudices...Dealing with Adolf Hitler, I would look for the private papers of his personal staff, people who were directly associated with him from secretarial or adjutant level, up to Field-Marshal. I would try and amass a great body of documentary evidence which passes certain criteria. And these were the criteria which the great English historian, Hugh Trevor-Roper, laid down in particular; three criteria for a document to be acceptable to a historian. The first criterion is quite obviously, is the document you are looking at genuine? The second criterion is, was the person who wrote the document in a position to know what he is writing about? A street sweeper in Berlin may have been in Berlin in the last days of the war, but he doesn't know what's going on in Hitler's mind. The third criterion you ask yourself, why does this document exist? Why has it come into existence? You may look at a document that is apparently honest but you find out later on from other sources that the general wrote the document to protect himself. So you ask yourself, how did this document meet these three criteria and in the ten years that I worked on the Hitler project, I built up a shelf of about seventy feet of original documents that probably no other historian had ever seen. I persuaded Hitler's staff to trust me with their private papers that they had not shown to anyone else. I also built up a card index of ten or fifteen thousand filing cards on a day-by-day basis so you knew exactly what Hitler was doing, rather like a diary. You could say exactly what he was doing which meant that you had a useful tool to check any document. Any document that was shown to you had to fit with that card index. If it didn't, then there was something phony about the document." (33-9326, 9327)

Irving was very familiar with German documents, "...with the way they look, the way they smell - they have a certain physical smell - with the way they are phrased and with the archives they come from and the language they use, of course. I'm very fluent in the German language." (33-9328)

He had also conducted scientific tests as part of his research: "In the twenty-five years I have done research, on occasion documents have been offered to me that I had reason to suspect. On one occasion I was offered the private diaries of the German Vice Admiral Wilhelm Canaris...who is the chief of the German Secret Service. We knew that these diaries existed. We have been looking for them. They haven't been found to this day. In the end I persuaded the man who had offered these diaries to me and the English publishers, Collins, to come to London bringing one page of those diaries. In return, we paid 50,000 pounds into his bank but we didn't release it into his account until we carried out laboratory tests on the paper. This was in about 1970. And the laboratory tests carried out on the paper and the ink and the typewriter showed that the paper was wartime paper. It didn't have the whiteness that modern paper has; it didn't have melamine formaldehyde added that modern paper has. The paper had been cut to the German size with scissors, as microscopic examination showed. Also the signature had been written in a ball-point pen. The chemical tests showed that quite clearly. Tests were carried out on the ink of the signature normally to show how old the signature is. This laboratory in London which I use, Hehner & Cox, carried out a test normally on the iron content [of the] ink. Normally, if you write a signature with ink, the iron oxidizes, so I am told, and you can tell the degree of oxidization, and tell how long a signature has been there. This document was signed in a ball-point pen and was clearly a forgery. I had the man prosecuted for criminal fraud and he avoided the consequences by dying, or by purporting to have died. At any rate, he submitted a death certificate which I was prepared to accept as genuine. And of course, I was involved in the very famous discovery of the Hitler diaries forgery. I had had the Hitler diaries submitted to me six months, I recall, earlier along with ancillary documents. I had had the Hitler's diaries submitted to me in 1982, November, along with other ancillary documents. And I detected that the letterhead on a Hermann Goering notepaper was actually misspelled. They misspelled the rank of the Field-Marshal, of the Reichsmarschall as he was, which was completely improbable, and when the Hitler diaries were presented to the world in April, 1983, I attended the press conference and exploded that press conference as you may have seen on "Good Morning America" and the other television programmes. The diaries were a fake and I had the forensic evidence they were fake...there had been occasions, sir, when I have used laboratories to determine forgeries. "(33-9328 to 9330)

Irving's Hitler research failed to uncover any evidence that Hitler was aware of the alleged "final solution" of the Jews: "At the end of writing the Adolf Hitler biography in draft, I was aware of the fact that having written it from primary, original Hitler sources, I, as the author, didn't know about the Holocaust. I had found no documents showing any involvement between Adolf Hitler and the Holocaust which was very disturbing for me. So I re-investigated. I sent a researcher back into the archives where, with a specific job, the researcher, who was a trained historical scientist at the Institute of Contemporary History in Munich, I said to her, 'Go back to the archives in Freiburg, Munich and Berlin, and see if I have missed anything'. I couldn't believe what I was seeing, the fact there were no documents whatsoever showing that a Holocaust had ever happened. I'm using the word 'Holocaust' in the modern sense that the newspapers tell us to use it. And certainly there was no evidence that Hitler had ever known such a thing was going on, whatever it was. This was very disturbing for me and it was even more disturbing for my literary agent who warned me of the consequences of producing the Hitler book in this fashion." (33-9330, 9331)

This completed defence attorney Doug Christie's examination of Irving for the purpose of qualifying him as an expert witness. Crown Attorney John Pearson then rose to cross-examine Irving on his qualifications as an expert in history. (33-9332)

In response to Pearson's questions, Irving testified that his book Churchill's War, was published in West Australia by Veritas Publishing Company. David Thompson, the firm's East Australian sales manager, introduced Irving at a speech Irving gave at the University of Sydney. (33-9332, 9333)

And do you remember, asked Pearson, saying that you had no qualifications whatsoever and you were proud of the fact that you had no qualifications whatsoever?

"I think my precise words would be to say that the only examination I...failed at school is O-level history which is the most elementary level of history you can fail," said Irving. (33-9333)

You were proud to say you flunked history?, asked Pearson.

"I have started off from such humble beginnings...I have no academic qualifications whatsoever." (33-9333)

Right, said Pearson, you make your living writing and publishing controversial books about history.

"I make my living publishing books about history, yes...Many of them are controversial. I don't create the controversy, the media do...I'm a controversial historian." Irving agreed that his books had been the object of contempt and scorn and that he had been hounded and attacked. He disagreed, however, that controversy was good for book sales: "Quite the contrary, sir. I rather hinted when I mentioned my literary agent, in the matter of Hitler's War, my literary agent warned me of the severe consequences of the controversy that would develop from omitting Hitler's role in the Holocaust. He told me we would lose the Sunday Times deal, the Reader's Digest deal, the Book of the Month Club deal, and we would not sell the book as a paperback in the United States. We lost about one million dollars. Controversy is not necessarily good." (33-9334, 9335)

Well, are you familiar with the book called Spy Catcher?, asked Pearson. Irving replied that he knew of the book and that it had been banned when he left Britain five weeks before. And wouldn't you agree with me it was good for sales?, asked Pearson. Irving agreed this had been true for sales of Spy Catcher in Australia, but said: "Being banned ipso facto is not good for sales. You have to be banned in a certain way...There are useful controversies and there are controversies which don't promote your purposes as a historian." (33-9335, 9336)

Well, said Pearson, if there's controversies that create media attention, that's good for sales because thereby people learn about a book that they'd otherwise not even know about. Isn't that right? Said Irving: "This is true. And I emphasize as a professional historian I have to sell my books. I can't afford to lose my credibility." (33-9336)

When you say you're a professional historian, asked Pearson, what you mean by that is you write books on history and sell them?

"I write books on history as a profession. That's what professional historian means." Irving agreed that he was in a fight for media attention: "I think that is correct. In England 58,000 new books are published every year and only 1,000 will ever get reviewed...So, it's a bit of a struggle of life." (33-9336)

Would you agree with me that you hold academic historians in contempt?, asked Pearson.

"I hold them in contempt for specific reasons," said Irving. "Not all academic historians but the broad majority of them." (33-9337)

Would you agree with me, asked Pearson, that the academic historians, for instance, Martin Broszat, consider your thesis in your Hitler book as embarrassing? Irving disagreed: "On the contrary. Martin Broszat went to great lengths in a 54-page review of my Hitler book to say on one central issue he considered that I was correct, that there was no general order for the extermination of the Jews...I don't think he ever used the word embarrassing. I'm not familiar with all his writings." (33-9337)

Pearson produced a copy of an article by Broszat published in Yad Vashem Studies. Irving indicated he was familiar only with the German edition: "...I haven't read this particular one. I don't subscribe to Yad Vashem Studies. If he said it was embarrassing, I will accept your word for it, but it would be embarrassing for the body of academic historians because I have shown them up for not doing the research which did I." Irving examined the article and confirmed that it was an English translation of the original German paper which appeared in Vierteljahrshefte für Zeitgeschichte with which he was familiar. (33-9338, 9339)

And it doesn't matter that it's published in Yad Vashem, does it?, asked Pearson.

"I...think I did emphasize I have co-operation from the Israeli archives so that does mean it's a two-way co-operation." (33-9339)

Pearson repeated the question.

"I can't see what point you're driving at," said Irving, "I just said...I'm not familiar with the Yad Vashem version of it." (33-9339, 9340)

The title of the article by Broszat was "Hitler and the Genesis of the 'Final Solution': An Assessment of David Irving's Theses."1 At Pearson's request, Irving read the first paragraph:

THE ENGLISH EDITION of David Irving's Hitler book, published in the spring of 1977, two years after the expurgated German edition, has created a furore both in England and elsewhere. The British author, who gained a reputation as an enfant terrible with earlier publications on contemporary history, has propounded a thesis which is embarrassing even to some of his friends and admirers.

Pearson indicated that Broszat went on to say that Irving was a very good writer. Pearson then continued reading from page 76 of the article:

The discovery and utilization of contemporary primary sources has long been a sort of adventuresome passion of Irving the historian. However, the unprejudiced historian and researcher is obstructed by the passionately partisan author whose insistence on primary sources lacks the control and discipline essential in the selective interpretation and evaluation of material.

He is too eager to accept authenticity for objectivity, is overly hasty in interpreting superficial diagnoses and often seems insufficiently interested in complex historical interconnections and in structural problems that transcend the mere recording of historical facts but are essential for their evaluation. Spurred by the ambition of matching himself against professional historians in his precise knowledge of documents, he adopts the role of the terrible simplificateur as he intends to wrest fresh interpretations from historical facts and events and spring these on the public in sensational new books.

Said Irving: "I think every historian is entitled to his opinion...What he is saying is I haven't learned to read between the lines the way that the academic historians have." (33-9341, 9342)

Pearson asked whether Irving's thesis in Hitler's War was that Hitler was a bad administrator who liked ideas and not details, and that it was Heydrich, Himmler, Frank and others who were engaged in perpetrating the Holocaust. Said Irving: "In the introduction I make plain that I regard Germany, by the end of the Second World War, as a Führer state without a Führer. He had lost control of whatever was going on and I'm not going to be so simple as to say it was quite simply what is now called the 'Holocaust.' Whatever it was that was going on, there is no evidence that Hitler knew it. There's not enough evidence to satisfy an English magistrate's court and it certainly shouldn't satisfy an academic historian or a professional one." (33-9342, 9343)

Are you repudiating what you wrote in Hitler's War about the activities of Himmler, Heydrich and Frank?, asked Pearson.

"I didn't use the word 'Holocaust' to the best of my knowledge. This is a relatively modern invention. I think we have to be much less simple than using a word like that. We have to try to examine what was going on, see if there was a pattern or was it just a haphazard series of ad hoc tragedies generated by all sorts of different criminals who were running amok." Irving indicated that he did not think he repudiated anything he wrote in Hitler's War, but indicated that he "would need to know exactly which passage I am being asked to...repudiate." (33-9343, 9344)

Pearson asked if Irving's thesis in his book Churchill's War was that Churchill wanted a war because he knew he wouldn't get elected in peacetime and he conducted a lot of his activities during the war in a drunken haze?

"This is not a thesis," said Irving. "That is, in fact, a statement of fact." (33-9344)

David Irving was accepted as an expert witness qualified to give testimony in the area of the history of the Second World War. Defence attorney Douglas Christie commenced his examination-in-chief of Irving. (33-9346)

In your opinion as a historian of the Second World War, asked Christie, what is the 'Holocaust' as it is currently presented?

"The Holocaust as it is currently presented," said Irving, "I can do no better than quote the words used by the chief rabbi of England, Lord...[Immanuel] Jakobovits, who has recently said that in his view, it has become big business...Which he deplores." (33-9347)

Irving had read Did Six Million Really Die?: "...I have seen this book before over several years. I have never read it until two days ago when a copy was sent to me by courier in Florida with a request that I should read it for the purposes of this trial. And I read it with great interest and I must say that I was surprised by the quality of the arguments that it represented. It has obvious flaws. It uses sources that I would not personally use. In fact, the entire body of sources is different. This is based entirely on secondary literature, books by other people, including some experts, whereas I use no books. I use just the archives. But independently, the author of this came to conclusions and asked questions of a logical nature which I had arrived at by an entirely different route, so-to-speak. I give one example. On one page, which I can't remember, he asks the obvious logical question, if you are going to exterminate millions of people, why did you go to all the trouble of shipping them thousands of miles across Europe first? This is the kind of logical question which the academic historian[s] have ducked until now. And if I was to ask what is the value of a brochure like this, I think it is that it provokes people to ask questions, rather as my book on Hitler's War provoked the historians. I think I am told that this court has heard about the historians' dispute that has opened up in Germany. That was entirely as a result of my controversial book on Hitler. Until 1977, the German historians had never asked the obvious questions. This is the kind of value which I found this brochure to have. It was asking proper questions on the basis of an entirely different set of sources. But I do emphasize that it contains flaws and it contains also some opinions with which I personally wouldn't agree." (33-9347, 9348)

If the 'Holocaust' is represented as the allegation of the extermination of 6 million Jews during the Second World War as a direct result of official German policy of extermination, what would you say to that thesis?, asked Christie.

"There are several elements of that sentence I would dispute," said Irving. "Firstly, the allegation that it was official German policy. We are not familiar, neither the academic nor the professional historians are familiar with the slightest documentary evidence that there was any such German policy. And I should be familiar with it having spent ten years wading around in the archives of the German High Command and speaking with Hitler's private staff. It isn't there. I am not familiar with any documentary evidence of any such figure as 6 million and I think I know how the figure originated because I am familiar with the private papers of the American Chief Justice at Nuremberg, the Justice Robert H. Jackson and I saw the actual interview on which that figure was...arrived at...Many years ago, I wrote a very detailed analysis of the Nuremberg trial and the procedures and the sequence of events at the Nuremberg trial. In the course of which I obtained privileged access to all the private and official records of the American chief prosecutor, Justice Robert H. Jackson, in the course of which I changed my opinion about him. I set off with a bad opinion of him and in the light of what I read in his diaries, I came to realize he was a profound and honest American lawyer." (33-9349, 9350)

Do you have any opinion as a result of your research as to the number of Jews who died in concentration camps during the Second World War?, asked Christie. Said Irving: "I am not sure that an opinion here would be of use. I have opinions. I have opinions, however, in the kind of statistical orders of magnitude, where you can see there's a minimum number and a maximum number, and I can only set these two limits and say that to my mind, it must have been of the order of 100,000 or more, but to my mind it was certainly less than the figure which is quoted nowadays of 6 million. Because on the evidence of comparison with other similar tragedies which happened in the Second World War, it is unlikely that the Jewish community would have suffered any worse than these communities. You can weigh the figures in certain ways and look at air raid damage and look at other communities like the gypsies and so on and say, this is the balance of probabilities. But it shouldn't be necessary to talk about probabilities. All Hitler's other crimes are documented in statistical details in the archives. This is supposed to have been the biggest crime of all and yet the documents just aren't there so why do we have to speculate? Why do we have to have opinions about figures?" Irving pointed out that there was documentary evidence to support the German policy of deporting the Jews: "Oh, yes. Quite definitely. In the course of my Hitler research I came across acceptable German archival evidence which met the criteria which Hugh Trevor-Roper had taught me, being authentic documents written by people in a position to know. I came across documents showing that Hitler had given the orders for the deportation of the Jews to the east. This deportation was in full swing by the middle of 1942 and you find, for example, Heinrich Himmler writing to Gauleiters that the Führer, Adolf Hitler, has given me the order to make Europe free of the Jews, clean of the Jews from west to east, stage-by-stage, and it's quite clearly referred to as Hitler's order, the deportation." (33-9351, 9352)

There were, however, no orders for the extermination of Jews: "None whatsoever. I have not found in any archives of the world, including I mentioned the Israeli archives which have been co-operating with me; I also underline the fact even in the British archives, where we were reading the signals, the code signals of the SS units operating on the eastern front, with our code-breaking machinery, not even in the British archives are there any deciphered Hitler orders for the killing of Jews...There are no explicit orders and this is where the academic historians start asking us to read between the lines and find fancy translations for certain words and I wouldn't go along with those methods. I want in a crime as big as this to find explicit evidence." (33-9352, 9353)

Was there a Madagascar plan?, asked Christie.

"The original 'final solution' of the Jewish problem as envisaged by the German High Command," said Irving, "was to deport the Jews to different territories. Various different territories were called into account for this. On one occasion, the Jews were going to be shipped to western Australia. On another occasion they were going to be shipped to Palestine and Adolf Eichmann was actually sent to...Palestine in 1939 to negotiate with the Zionists in Palestine. The principal plan was the so-called Madagascar plan. Madagascar is an island off the coast of Africa about the size of Germany. A temperate island, the kind you have in Canada or in Britain, and the idea was to ship all the world's Jews to Madagascar. In 1940 after the German defeat of France, the intention was to incorporate the Madagascar plan in the final peace treaty obliging France to make Madagascar, which was a French colony, available for the purpose of Jewish resettlement. And there are traces, by which I mean there are extensive files, on the Madagascar plan in the archives of the German admiralty, because they would be involved in the transportation, and the archives [of] the German Foreign Ministry and in various other German government bodies. This plan was abandoned when the war continued because it was impossible to have an overseas shipment of Jews at a time of war. And finally, in 1942, there is a document in the records of the German Foreign Ministry which says the Madagascar plan is being abandoned because we now have new territories available in the east, the occupied Russian territories, to which all the Jews will be transported instead." (33-9353, 9354)

Is there any one document in the archives, asked Christie, of the various ministries which say, as late as March 1942, that there was a plan to exterminate the Jews?

"This is typical of the documents which I have found and which the academic historians, until I had published it, would not publish it," replied Irving. "In the archives of the German Ministry of Justice, I found a document which was concealed at Nuremberg...which resurfaced in the archives in Koblenz, dated in the spring of 1942. It is a note of a telephone conversation of the Secretary of State of the German Ministry of Justice with the Reich Chancellor...That would be rather like a Prime Minister, a Prime Minister in a dictatorship, second man down from Hitler...[who was] Hans Lammers. Lammers had telephoned the ministry in the spring of 1942 and the minister writes a note on the conversation, and I can quote the memorandum from memory. It says: 'Lammers has said that the Führer, Adolf Hitler, has repeatedly ordained that he wants the 'final solution' - that he wants the solution of the Jewish problem postponed until after the war is over.' And this document, of course, takes some explaining and this is the kind of document which embarrasses the historians, if I can use the word that Mr. Pearson has reminded me of. They are embarrassed because they haven't found that document themselves." (33-9354, 9355)

Irving testified that he was familiar with the Einsatzgruppen reports: "Here we have to look at the third of the Trevor-Roper criteria. If you remember, the question a historian should ask is, 'Why does this document exist?'. A man is out in the field behind the Russian front doing his job for the SS and he is being asked how well he is doing and he's going to submit a report containing figures and he's going to show he's doing a jolly good job and that's the kind of category I... put these Einsatzgruppen reports into. I don't trust the statistics they contain. Soldiers who are out in the field doing a job or murderers who are out in the field doing a job, they don't have time to count. I don't think Lieutenant Calley stopped to find out how many people [he] killed. Statistics like this are meaningless. Documents like this I am very, very worried about as a historical source." (33-9355, 9356)

Christie produced Exhibit 118, a document referring to Galicia, which he showed to Irving. Said Irving: "May I say that I am very wary about any Nuremberg document that has the document number L...This is L-18...Historians are familiar with quite a number of L documents from the Nuremberg series and a lot of them turn out to be forgeries. A lot of them turn out to be produced or manufactured for the Nuremberg trials to the best of my knowledge. So, this is the first thing that would worry me about that." (33-9357)

Crown Attorney Pearson objected to this testimony, alleging that this was a serious accusation to make. Irving replied: "If I may answer that point, sir, I investigated the Nuremberg trials in some detail and I was familiar with the fact that at Nuremberg, they did have a collection of the necessary rubber stamps, the security classification stamps in order to manufacture documents and they did do it. There are several instances where this subsequently turned out...I have published a book on that sir. It's Nuremberg - The Last Battle...The prefixes on the Nuremberg documents give some index of the providence of the document. There's a PS series which was found by Colonel Storey [in] Paris, the Paris/Storey collection. Many PS series are thoroughly authentic. The L series were a small collection of documents used at Nuremberg and contain documents produced by journalists and handed over by a very eclectic series of sources. The NOK documents, the German for the [High] Command trial, the private files give us a first sniff, if I might put it like that." (33-9358, 9359)

Irving testified that he was not familiar with this particular document: "...I am not familiar with the document. I am not, I emphasize, a Holocaust historian." (33-9360) With respect to the authenticity of the document, Irving testified that he would "accept these documents as attached are probably genuine on the basis of the photocopies but that's just the first impression you get in looking at an archives - I recognize the numbers at the bottom. I can tell you which microfilms they come from. They are authentic reproductions from Nuremberg microfilm. . . Prima facie it appears to be genuine." (33-9362, 9363)

Have you yourself ever seen any evidence in any of the archives to establish the existence of homicidal gas chambers?, asked Christie.

"No, sir. None whatsoever. And certainly one would have expected to have found it in the number of archives that I've been in." (33-9363)

Yesterday, said Christie, the Crown produced a letter from someone in Auschwitz pertaining to the building of the crematories and the word used there was Vergasungskellers. Are you familiar with that document?, he asked.

"I am very familiar with the German language and I am quite familiar with that document also," said Irving. "No German would have referred to a gas chamber, which of course is quite a common concept because the Americans use[d] gas chambers at that time for legal executions. No German would have translated the word 'gas chamber' as vergasungskeller. They have a perfectly good German word for that... a gaskammer." (33-9363, 9364)

Christie noted that the Crown had quoted a man named Martin Broszat during his cross-examination of Irving. What was Broszat's job?

"He is now the director of the Institute of Contemporary History in Munich, which is a very good historical institute partly funded by German federal funds and partly by provincial funds...My dealing with the Institute of History began in late 1963 before he became director of the institute. The institute has acquired my entire research collections of documents which are now housed in that building as the David Irving Collection and I have suspended further deliveries of documents until Broszat resigns or retires." Irving testified that there were personal animosities between himself and Broszat which "began in the 1970s over a certain young lady who is now living with him...further animosity was caused by the fact that I revealed that documents that the Broszat institute published were forgeries. The diary of...Engel turned out to have been written on post-war paper and yet the Institute went ahead and published this diary knowing that it would pollute the writing of history for many decades afterwards...It is now recognized as a forgery and yet the institute of Dr. Broszat still publishes it." (33-9366, 9367)

Christie turned to the subject of the Posen speech of Heinrich Himmler. Said Irving: "In October, 1943, Heinrich Himmler, the chief of the SS, delivered two speeches, one to the SS generals and one to the Gauleiters - the Nazi party district chiefs, the governors of the districts." Irving had examined the transcripts of the speech and other archival materials: "I looked at Heinrich Himmler's handwritten notes on the basis of which he delivered those speeches, I looked at the typescript of the transcript made from the recording of the speeches, I looked at the final copy made that have typescript in the special large typewriter face that was used for Adolf Hitler to read, so the speeches exist in several copies and I understand that in the National Archives, there is also a sound recording of the two speeches." (33-9368)

Did he have any reason to question the accuracies of the Posen speech?, asked Christie.

"[In] both speeches which I referred to," said Irving, "Heinrich Himmler made startling admissions to his very select audience which amounted to the fact that he was - he had given orders personally not only for the killing of certain Jewish men, but also for the killing of certain Jewish women and children and he tried to justify what he was doing, using, if I may say so, rather the same kind of language as [Israeli Prime Minister] Mr. Shamir now uses in the West Bank, saying that we have to carry out this task in order to be able to live in security in future. This was the language that Himmler used and I arrived at the very strange discovery when I looked at the transcript of both those speeches that those two pages had been retyped at some other date. I can't say whether it was retyped before or after the bulk of the speech, but they had been typed by a different secretary on a different typewriter using different carbon paper. Obviously you only discover this if you look at the original documents which the average historian is not patient enough to do. They had been retyped and they had been repaginated in pencil at that point and I have to say to preempt your question, I have no explanation why. It just raises the fact that a document - if a document has been retyped at a key point, then I hold that document to be suspect." (33-9368, 9369)

Do historians generally have any criterion for accepting documents as being both authentic, genuine and true or do they simply take them at their face value?, asked Christie.

"It depends very much on the historian," replied Irving. "The green historian who is fresh out of university and not inquisitive, will be happy to accept the printed volumes of documents particularly if they have pictures in them and an index at the end. Later on, you learn not to trust printed volumes of documents. If I can give one example from my Churchill research, there is a report by the American Assistant Secretary of State, Sumner Welles, on a visit to Churchill in March 1940, describing how he found Churchill in a state of complete intoxication in the admiralty. The printed version of this document and the American government volumes omits those sentences describing Churchill's drunkenness, but the original report by the Secretary of State in the Roosevelt library contains those sentences. So, I can only say that a historian must be very careful about using printed or even photocopied documents."(33-9369, 9370)

Irving had also studied the Goebbels diaries: "I am very familiar with the Goebbels diaries insofar as they have been publicly available and in the course of the next twelve months I shall begin reading the entire microfiche of the Goebbels diaries that have now become available to western historians," said Irving. "They appeared in a very mysterious way from the custody of the East German government, where they have been held since the end of the Second World War unknown to us; we didn't know those diaries were there and then they suddenly turned up. I have to say from what I have seen so far, I consider the diaries to be genuine, but we have to apply once again the third criteria of Trevor-Roper which is, 'Why did they come into existence'? Why did Goebbels write them?" The diaries were partly written and partly transcribed: "Many early years are written in his very difficult, indecipherable handwriting. The later years when he was Minister of Propaganda in Nazi Germany, he dictated them onto a recording machine and his secretary transcribed them each day, sometimes at very great length. Sometimes 139 pages on one day in 1943." (33-9370, 9371)

He was also familiar with the Wannsee Conference documents: "In January 1942, there was a conference at a house in Berlin, Wannsee, an inter-agency or inter ministerial conference between state secretaries. The state secretaries were like the deputy minister in a ministry and they were discussing the technicalities of the final solution of the Jewish problem, and to understand the Wannsee protocol, it is not enough just to look at that document. You have to look at the entire file containing that document. And you then realize what the document is about. Even then it is written in very obscure civil service language and several of the participants in the Wannsee Conference subsequently testified in later criminal proceedings that they emerged from that conversation no wiser than when they went in. Certainly none of them had - certainly none of them had any idea that at that conference there had been a discussion of liquidation of Jews." (33-9371, 9372)

Had he investigated the trials of these individuals?, asked Christie.

"I read the records of the Wilhelmstrasse trial," said Irving, "which is the second trial to be held in the post-Nuremberg proceedings series after the plain Nuremberg trial. There were twelve subsequent proceedings. The Wilhelmstrasse trial was the second one. None of them testified that there had been any discussion of liquidation of the Jews at the Wannsee Conference." (33-9372, 9373)

Christie referred to the letter from Goering to Heydrich of July 1941 which had figured prominently in both Hilberg's and Browning's testimony and asked if Irving was familiar with it. Irving replied that he was: "On July the 31st, 1941, as is said from Hermann Goering's private diary, which I suppose I'm one of the very few people to have used it in the original, on the afternoon of that day, Reinhard Heydrich, the chief of the Gestapo, visited Goering who was passing very rapidly through Berlin and put a pile of documents on the desk for Goering to sign, one of which was a piece of what I would describe as legal bumph, where Heydrich is just saying to Goering, 'In 1939, you gave me orders to carry out certain measures connected with the Jewish solution, will you now extend the authority given by those orders to the new territories in Russia which we've captured'. That is what the document says. I wouldn't attempt to repeat the document from memory. I'm sure it's in the court files. July the 31st, 1941, Goering signs the document for Heydrich without ever even bothering to read it. It's a piece of legal bumph which again says nothing about killing Jews. It is talking about the overall solution of the Jewish problem which, as I testified earlier today, was at that time regarded to be the geographical resettlement of Jews, relocating them from where they were at that time." (33-9373, 9374)

Did those sources - the Posen speech, the Goebbels diary, the Wannsee Conference and the letter of July 31, 1941 - indicate any plan to exterminate European Jews?, asked Christie.

"No," said Irving. "There is no explicit reference either implicit in these documents or legible in these documents to liquidation of Jews. They are all equally applicable to any other solution. Of course, relocation of the Jews in the middle of a war was a radical solution but it is not what is described as the 'Holocaust.'" (33-9374)

Does the existence of these documents indicate to you that there is any other material that would corroborate an extermination programme?, asked Christie.

"I think it highly unlikely. It is very difficult to prove a negative to say that documents don't exist. But I will say is, if the documents did exist, I would have found them by now and if I hadn't found them, then certainly the Holocaust historians would have found them by now, explicit documents, and as you may know I have offered repeatedly around the world a thousand pounds for any wartime contemporary document showing that Adolf Hitler even knew what was going on, whatever it was, whatever is now described as the 'Holocaust' and they haven't been able to find that let alone explicit orders or documentary evidence about gas chambers or the similar kind of documentary material." (33-9374, 9375)

In your research as a historian, asked Christie, do you consider it likely that an enterprise of the magnitude of the extermination of the Jews of Europe could be accomplished by the people [Germans] knowing the way they conducted their business from their documents without the existence of explicit orders and plans?

"Not only without existence of orders," said Irving, "but also without the existence of any written reference to it. I have to say that the German wartime civil servant was basically a - a cowardly animal and he would not do something that he considered to be criminal without getting a document clearing himself. He would get his superior to write a letter saying, 'On the Führer's orders, we are doing the following', which is why there are letters showing Himmler saying, 'On the Führer's orders, we are deporting the Jews.' Which was the extent of the Führer's orders and which was the extent, to my mind, of the final solution. So the documents don't exist where you would expect to find them. Hitler's other crimes, the documents are there: the euthanasia order, the order to kill British commandos, the orders to lynch American airmen, the orders for the killing of the male population of Stalingrad if ever they occupied it. Hitler's other crimes, simple crimes, the documents are there where you expect to find them. And yet this biggest crime of all, there is no document...I think there would definitely have had to be orders and these orders would have been referred to in countless files of different ministerial bodies. So, it would have been impossible for these documents to have been destroyed at the end of the war. There would always be carbon copies somewhere." (33-9375, 9376)

The term ausrotten, said Christie, has been represented to mean 'extermination' in the literal sense. Have you examined that word in its context in the various speeches of Adolf Hitler?

"I am very fluent in the German language, having lived in that country for a long time and having read, of course, millions of words in the German language in context," said Irving. "There is no doubt that in modern Germany the word ausrotten now means murder. But we have to look at the meaning of the word ausrotten in the 1930s and the 1940s, as used by those who wrote or spoke these documents. In the mouth of Adolf Hitler, the word ausrotten is never once used to mean murder, and I've made a study of that particular semantic problem. You can find document after document which Hitler himself spoke or wrote where the word ausrotten cannot possibly mean murder. I can give one or two examples briefly. In August 1936, Hitler dictated the famous memorandum on the four year plan which contains the phrase 'if the Bolsheviks succeed in entering Germany, it will lead to the ausrotten of the German people'. Now, clearly, he doesn't mean that if the Bolsheviks invade Germany it will lead to the murder of 50 million Germans. He is saying it will lead to the end of Germany as a national state, as a power, as a factor, an end of the German people. He says the same to the Czechoslovakian President Emil Hácha, on March the 15th, 1939. Hácha has just signed away Czechoslovakia's independence in a midnight session with Hitler and Hitler says to him afterwards, 'It is a good thing that you signed because otherwise it would have meant the ausrotten of the Czechoslovakian people'. Hitler didn't mean, 'If you hadn't signed, I would have had to kill 8 million Czechs.' What he is saying [is], 'If you hadn't signed, I would have ended Czechoslovakia's existence as a separate country.' There are various other examples of that and I defy anybody to find the meaning of the word differently used by Adolf Hitler to mean the word 'murder'. This is the kind of analysis which unfortunately the academic historians have not bothered to conduct." (33-9377, 9378)

Could you give us your opinion of the value of Did Six Million Really Die?, asked Christie.

"It has a - a value I would suggest in technical terms of a catalyst. It has existed rather like the grain of sand inside an oyster. It has provoked and irritated people [in] rather the same way but on a different level that my book Hitler's War did. It has forced people to prove what they have been maintaining - to put their money where their mouth is in common terms - and they haven't been able to do it and because they haven't been able to prove what they've been maintaining for thirty or forty years, they resort to extramural methods. In Germany, it is declared a criminal offence now to question certain historical facts. In other countries, I think judicial notice is taken of them." (33-9378, 9379) Irving estimated "over 90 percent of the brochure Did Six Million Really Die? to be factually accurate on the basis of the facts which I arrived at by an entirely different approach, namely, the documentary basis." (33-9388)

Irving testified that he was familiar with the subject of Kurt Gerstein: "I have examined the Kurt Gerstein report and its various adaptations and having read the very interesting doctoral dissertation by the Frenchman Henri Roques, which was produced a year-and-a-half ago, I came to the conclusion on the basis of the documents that Roques found in the French police files, on the basis of my own family experience with a handicapped member of my family, that Gerstein himself was probably unstable when he wrote his various reports." Irving did not examine the documents in their original form: "I examined facsimiles. Had I been a Holocaust historian, of course, I would have gone into much greater detail and demanded to see the originals." Irving had also examined facsimiles of Gerstein's writings of a personal nature, which were found among his effects after his suicide. (33-9379, 9381)

In the course of his research, Irving was required to make assessments of the credibility of the people who had produced the documents: "Indeed I do, and one can do so on the internal evidence of the document itself or of associated events and documents. In this case, the suicide or apparent suicide of the person who wrote the document is a clear sign of mental instability...The documents themselves are unstable. The most graphic description of that are the words, that the facts and dates contained by the documents vary dramatically," said Irving. As a historian, he had made these types of assessments in regard to other documents as well: "Yes, over the years I have repeatedly had to do so. One has to weigh documents." (33-9380)

Irving testified that Professor Hans Mommsen of the University of Bochum now shared his thesis pertaining to the absence of a plan or order. That had not been the case in 1970. Said Irving: "...At the end of the Second World War, the - the professorial bodies at the institutes of higher learning in Germany were extensively re-staffed. New textbooks were introduced; the professors were retaught. The university system produced, in its turn, new professors. There was a broadly held body of opinion as to what had happened and it has not been without - not to be wondered at, as fresh documents became available, then this opinion is changed. Fresh hypotheses are raised by authorized or unauthorized writers and even the academics then have to change their minds." Irving himself had changed his mind over the years. In a book he published many years before on the Vietnam War, he had referred "to the 6 million who were killed at Auschwitz and if I was to be asked now why did I write that, then I would have to quote the words of William Casey and I - 'I believe[d]', but since then, since having spent ten years writing the Hitler biography and since having worked in the world's archives, I've come to question that belief which was an oversimple belief." (33-9381, 9382)

In your opinion as a historian, asked Christie, from what you have seen of the information about the subject, has the Holocaust been sufficiently investigated to determine accurately its extent and meaning?

"I think there has been virtually no investigation of the Holocaust," replied Irving. "When we realize that Mr. Zündel, the defendant in this case, is the first person who has gone to the trouble to get the aerial photographs of the German concentration camps, the kind of concrete evidence that anybody is entitled to demand when you're carrying out an investigation, this shows us how we can - all the other historians on that field, including myself - have been. And the same kind of forensic examination which has now been made of the site, an idea which hadn't occurred to me one could conduct - really getting down to the basics of what happened. This has not been done by historians of the Holocaust." (33-9382, 9383)

Are there factual errors in major history books?, asked Christie.

"Oh, yes. I think it would be a foolish historian who denies he makes errors on Adolf Hitler. The standard works like Alan Bullock, his book Hitler: A Study in Tyranny, is riddled with errors and yet that book goes into reprint after reprint. William Shirer's book The Rise and Fall of the Third Reich, is a very good book in its way, written at a very early stage. It is based entirely on the prosecution documents at Nuremberg and, as such, is out of balance and also contains misstatements of fact. These are gradually reshaped and corrected as the years pass. One never really establishes total truth. One only approximates to it." (33-9383)

Christie turned to Did Six Million Really Die? and some of the specific allegations made in it. Did Irving know of any indication that Ohlendorf, for example, was tortured?

"Oh, yes," said Irving. "The SS General Ohlendorf and the SS General Pohl were both very severely maltreated at Nuremberg and in the internment camps where they were held by the Allies after the Second World War and prior to their testimony. They subsequently testified to that to their fellow prisoners like Field Marshal Milch, who kept a diary which I have and also in the subsequent trials...Field-Marshal Milch was the second person in the German air force. He was threatened with severe punishment unless he testified against Goering. On November the 5th, 1945, an American, who is a Major Ernst Engländer, who is a Wall Street financier, who presented himself to Milch as Major Evans, instructed him that he would be subjected to a war crimes trial unless he agreed to perjure himself against Goering. Milch refused to perjure himself and although there was an animosity between himself and Goering, he went into the witness stand and spoke in defence of Goering and on the next day, Milch was thrown into the punishment bunker at Dachau concentration camp, a bunker which had been designed by the SS to hold one recalcitrant prisoner, but which the Americans were using rather more economically in as much as they put six prisoners in this one-man bunker, all of them Field-Marshals as a punishment. Milch was then subjected to a war crimes trial and sentenced to life imprisonment. Admiral Eberhard Godt, the Chief of Staff, was threatened with hanging unless he...testified that Dönitz had given illegal orders and so on. There's a whole string of examples of the coercion of prisoners at Nuremberg." (33-9384, 9385)

Irving testified that "[t]he principal trial was the trial of the major war criminals at Nuremberg from October 1945 to October 1946. There was then a series of twelve subsequent proceedings against Milch, who was the first trial, and then the Wilhelmstrasse trial defendants...The legal records, the whole of the legal system at Nuremberg was unlike any other legal system. No appeal was permitted. The procedure for hearing witnesses was remarkable. The affidavits were submitted [e]ven [if] their witnesses were present in person and could have testified personally...many, many hundreds of thousands of affidavits were submitted with no chance for the defence to cross-examine the person who had submitted the affidavit as to the conditions under which he had given the affidavit, sworn the affidavit." (33-9385, 9386)

Irving was familiar with the book on the Manstein war crimes trial written by Paget. Said Irving: "R.T. Paget was a labour member of Parliament who was a King's Counsel, defence counsel of Field-Marshal Manstein, one of the most illustrious German soldiers. He was put on...trial by the British in Hamburg. I read that book when I was twenty-two with great fascination and increasing indignation to read of the methods that had been used to obtain testimony from prisoners, including the very severe maltreatment, brutalization of a number of witnesses." As a result, Irving made inquiries of certain documents from the National Archives in Washington: "In the very early 1960s, I obtained from them a complete photocopy of the Simpson Commission of Inquiries which the American Justice Department, to its credit, sent to Europe to investigate the allegations that American officers were torturing German defence witnesses." After reading the document, said Irving, "I formed the opinion that in future, one would have to be very, very cautious before accepting without verification the evidence sworn by defence or prosecution witnesses in the Nuremberg trials." (33-9387)

In the course of your research, asked Christie, have you discovered new documents as you went along or documents now being made available that were not available in the past?

"It's a continuous process. For example, I have contacts with the Russians who provided me copies of the German documents that the Russians captured at the end of the war. I am constantly generating new sources of documents which I make available to international historians all over the world." (33-9388)

Irving testified that he was familiar with Sefton Delmer: "Sefton Delmer was a former German citizen who emigrated to Britain fairly early on and worked for the British propaganda agency, the psychological warfare executive, as a clandestine broadcaster, broadcasting what is called black propaganda; in other words, disinformation and lies to the enemy over clandestine radio transmitters. A very good journalist but not a man that one would turn to establish the truth." Irving did not know whether Delmer had been involved in activities in Germany after the war or not: "He may have been but I'm not familiar with that." (33-9388, 9389)

Christie turned to the subject of the Hans Frank diaries and whether Irving was familiar with them. Said Irving: "Very familiar with the Hans Frank diaries which is - the original Hans Frank diaries are in very many volumes, seventeen or twenty volumes of typescript and handwriting containing not just what we describe as diaries but also the verbatim transcripts of very many records of conferences which he attended...I read them from the angle of somebody...writing a biography of Adolf Hitler, so I was specifically interested in any reference to Adolf Hitler's doings and wrongdoings and the doings and wrongdoings of the Third Reich under Hitler's rule." In Irving's opinion the diaries did not verify the existence of any plan for or any extermination of the Jews of Europe: "There is no reference in the Hans Frank diaries," said Irving, "and one would expect them, because Hans Frank was the Governor General of Poland, or the Governor General of the area of...Poland where the extermination camps are now supposed to have existed. There is no explicit reference in the Hans Frank diaries from start to finish to gas chambers or to a mass extermination of the Jews as government policy whatsoever. And this is a unique source because it is so homogenous the whole way through. The most remarkable passage I found was in February or March, 1944, and I have quoted it in Hitler's War, where he has a long conference with Hitler as the Russians are invading Poland, his own territory, and Frank wants to know what to do and there's a passage there where Hans Frank writes in his diary saying, 'the Führer said to me how glad we are...solving the problem by deporting the Jews to all the different territories.' Words to that effect. When you see something like that, you have to say [to] yourself, are we all writing the same language? Did either of them know what is supposed to have been going on?" (33-9389, 9390)

Irving referred to Adolf Hitler's reaction when Auschwitz was captured by the Soviets in 1945: "On January the 26th or January the 27th, 1945, the Russian troops overran Auschwitz and on this day, the stenographers, who took down in Hitler's headquarters every word he spoke, recorded a passage which has survived. We have the fragment of what he said. General Guderian reported to the Führer, 'Yesterday the Russians overran Auschwitz', and Hitler just replied, 'Oh, yes.' Now, if Hitler had known what was going on, if Hitler had known what was supposed to have been going on, he would surely have said something like, 'Well, let's hope they manage to get rid of it' or 'They're not going to find anything.' All he said was 'Oh, yes' and move on to the next business. This is the kind of clue that one has. Straws in the wind. Altogether it makes a very different picture." (33-9390, 9391)

Are you familiar with someone by the name of Robert Kempner?, asked Christie.

"Robert M. W. Kempner, an attorney now in Frankfurt, was [with] Goering's Ministry of the Interior in Prussia in 1933. He emigrated to America because of the Nazi anti-semitism. There he became a successful attorney. He returned to Nuremberg after the war and he became a leading member of the American prosecution staff in the rebuttal division...Robert Kempner used methods of coercion to prevent witnesses from testifying in certain ways. Friedrich Gaus...a legal member of the German Foreign Ministry, testified to this in a subsequent trial and affidavit that he had been threatened by Kempner with being handed over to the Russians unless he withdrew certain incriminating testimony. By incriminating, I mean testimony that was going to incriminate the Russians." (33-9391, 9392)

Irving testified that at Nuremberg, the "prosecution witnesses, the witnesses who appeared on behalf of the prosecution were cosseted. They were flown in by special plane; they were housed in the few remaining luxury hotels in Nuremberg. They were lavishly fed. They were well paid and they were promised jobs in the American zone of Germany." On the other hand, he testified: "The defence witnesses were universally badly treated. They were housed in the criminal wings in the Nuremberg Palace of Justice. They were housed in cells with no windows; in winter in unheated cells. They were very poorly fed. They were subjected to coercion and physical maltreatment." Said Irving: "I think that not only I but I think reputable lawyers around the world are rather ashamed about the Nuremberg proceedings. Certainly Justice Robert H. Jackson, the American chief prosecutor, was ashamed about them as is quite evident from his private diary...I've examined it. I've had privileged access to that diary in the Library of Congress...I have made a copy of it which I could make available if necessary...Shortly after Robert H. Jackson was given the job by President Truman of conducting the American prosecution at Nuremberg, he learned of the American plans to drop the atomic bombs and from that moment on, he became very uneasy with what he, himself, was doing. Prosecuting for one nation, crimes it had committed, being fully aware that the United States was about to commit and indeed committing a crime of an even greater magnitude." (33-9392 to 9394)

The unfairness of the Nuremberg proceedings extended to the manner in which documentary evidence was handled. "The procedure with documents [at] Nuremberg was rather rare," said Irving. "The prosecution obtained all the documents for its own purposes and the defence was then allowed to build up its case entirely on the basis of the prosecution collection of documents. No collection of documents by the defence was made possible by the authorities in Nuremberg. They were allowed very limited access to the documents collected exclusively for the purposes of the prosecution." (33-9394)

In Irving's opinion, many of the witnesses at Nuremberg and other war crimes trials were unreliable. An example was Karl Wolff: "Major General Karl Wolff was the liaison officer between Hitler and Himmler, an SS general, a character I would describe as being a rather suave character who ended up, by reason of his personal favouritism with Himmler, in charge of the police units in northern Italy at the end of the war and as the military commander in that region, and largely in order to create an alibi, he then began negotiating with the American secret service in order to speed the surrender of the German troops in northern Italy...Wolff testified on many occasions over the years up to his death, frequently varying his testimony according to...which way he was being required to testify. He was always acutely aware of the fact that he had done a deal with the Americans whereby the Americans...promised him immunity and the subsequent West German government also promised him immunity from prosecution if he behaved in a certain way." (33-9394, 9395)

Another example was Dieter Wisliceny: "Dieter Wisliceny was a high SS official who was held by the Communist authorities at the end of the war, and among the private papers which Hugh Trevor-Roper, the British historian, made available to me, was a long, handwritten account by Wisliceny which greatly amplifies the version which is more familiar and known to historians...I read the Wisliceny report with great interest and entertainment, but one has to say that the internal evidence suggested that it was not a document that could be taken seriously in the absence of collateral evidence." Irving continued: "He explained things for which there was not a trace in the archives. He described episodes and matters - well, for example, he describes a conversation with Adolf Eichmann and Adolf Eichmann showing to him a Führer document, a Führer order. Well, there is no such order. It has not been seen and we then have to understand in human terms why Wisliceny is writing this down...It was written in Bratislava (or Pressburg) in Czechoslovakia... He was being held in rather inhumane conditions in captivity at the end of the war...by the Communist authorities." (33-9396, 9397)

The Allied authorities also ensured that certain witnesses were "not available" for the defence, such as Karl Koller: "General Karl Koller...[w]as the Chief of Staff of the German air force at the end of the war. I have his private diaries and papers...his presence was required by the defence at Nuremberg but the Americans pretended that they didn't know where to find him. They had, in fact, locked him away in a prison camp and were interrogating him at that time. This was one typical example of the Americans obstructing the defence at Nuremberg. Karl Wolff was locked up in a lunatic asylum and the Americans pretended they didn't know where he was either and he didn't surface again until 1947." (33-9395, 9396)

Christie turned to the subject of the Eichmann trial and asked Irving if he considered the information there to be of value to historians.

"I think the Eichmann trial is already getting very late in the day as far as recollected testimony is concerned. I personally hesitate to question a witness thirty or forty years after an event as to what happened. You can no longer separate in his mind, no matter how willing the witness is, what really happened and what he has in the meantime read has happened...I recollect from the parts of his testimony that I have read - and I can't purport to have read all the Eichmann testimony for the reason I just said - I recollect at one stage where Eichmann interrupts himself to say 'one moment, I want to point out what I just said I can no longer recollect whether I actually saw this or whether I'm recollecting what you told me I saw.' And this, I think, is a very honest statement by Eichmann where he is questioning his own powers of recollection. In human terms you have to say it's not unlikely in 1963 or 1964, when that trial was held, much had happened." (33-9397, 9398)

Irving had been involved in the publication of the book Ich, Adolf Eichmann: "Adolf Eichmann's son, who is an engineer in Germany, approached me and revealed he had all the tape recordings that his father had made several years before his kidnapping. And the son wanted to know what to do with these tape recorded memoirs of his father. I suggested he should transcribe them and have them published by the world's publishers as a historical source. Again of questionable value, depending on when the [tape] recordings were made, but certainly of great historical interest to historians to see how versions of events had changed over the years. And subsequently, those were published, I think, in the English language, the German language and Spanish." (33-9398, 9399)

Had Irving himself undertaken any investigation of the Anne Frank diaries?, asked Christie.

"The Anne Frank diaries have had a long and checkered history," said Irving, "which is best described by the present state of play, as a result of a court decision in a libel action. The father of Anne Frank, with whom I corresponded over many years, finally relented and allowed the diaries to be submitted to the kind of laboratory examination that I always insist [upon] where a document is in question. As a result of this laboratory examination carried out by the West German criminal police laboratory, in Wiesbaden, it was determined that the Anne Frank diaries were partly written in ball-point pen. It's a long story. I'm not going to bore you with the details. My own conclusion on the Anne Frank diaries is for the greater part they are authentic writings of a pubescent teenage Jewish girl who was locked up and hidden, that they were then taken by her father, Otto Frank, after the girl's tragic death of typhus in a concentration camp, and her father or other persons unknown amended the diaries into a saleable form as a result of which he and the Anne Frank Foundation became rich, but as a historical document they are completely worthless by virtue of having been tampered with." (33-9399, 9400)

Irving continued: "Anne Frank's father, Otto Frank, fought a number of legal actions to defend the authenticity of the diaries and the first legal action which I believe was fought in Lübeck, he introduced handwriting evidence of a graphologist and an affidavit swearing that the diaries were written throughout in the same handwriting. Subsequently, I stated in the introduction of the German edition of my Hitler biography, that a number of forged documents existed which were unquestionably accepted and I've mentioned them in court today, the Canaris diary, the Engel diaries, and I mentioned the Anne Frank diary, which was one of dubious authenticity. Anne Frank's father threatened my German publishers with libel proceedings. The German publishers paid him a cash settlement to shut up without consulting me. I would have told them they were on very safe ground. Subsequently, he has litigated against other people, but in the meantime this litigation has now been - is being spun out, because the only remaining trial I believe is in northern Germany and they are playing it for time. They're waiting for the defendant to die." (33-9400, 9401)

Christie noted that one of the publications tendered as an exhibit in the court was the book The Hitler We Loved and Why. Was Hitler loved in Germany?

"I think I'm right in saying in April 1938, 48 million Germans loved Adolf Hitler and about 200,000 didn't. That was as a result of a perfectly genuine plebiscite that was held shortly after the annexation of Austria by the Germans. I think there's not the slightest evidence that this plebiscite was faked in any way. I don't see how you can fake a referendum on that scale, and yet 48 million adult Germans voted for Adolf Hitler. I would like to add I personally found the title rather tasteless," said Irving. (33-9401, 9402)

Did Churchill have anything good to say about Adolf Hitler?, asked Christie.

"In the 1930[s], when Churchill was not in Parliament and he lived from journalism and writing in the Evening Standard in September 1937, he had words of high praise for Adolf Hitler...Words to the effect that, 'If Britain...should ever come into the position that Germany was in, I would hope that one day we would find a national leader of the stature of Adolf Hitler'." (33-9402)

Christie asked Irving if there was a document called Table-Talk by Heinrich Heim and whether there was a reference in that to the position of Jews after the war.

"Indeed," said Irving. "Heinrich Heim was the adjutant of Martin Bormann who wrote down on a day by day basis a detailed semi-verbatim record of Adolf Hitler's lunch-time and dinner-time conversation...Hitler repeatedly referred to his post war plans with the Jews. He refers in the Table-Talk in July 1942, I believe I'm right in saying, to his plans for the deportation or relocation of the Jews elsewhere and Heinrich Heim was a very reputable German civil servant who is alive, in fact. I have no doubt that is an accurate rendering of Hitler's words." Irving testified that he had met Heinrich Heim: "I have also made use of the original paper of the Table-Talk. I'm one of the few privileged historians to have used that material. It's in private hands in Switzerland." (33-9402, 9403)

Christie referred back to Did Six Million Really Die? and asked Irving for his opinion on its conclusions regarding the number of Jews who survived. Said Irving: "Let me say at this point I think this conclusion...they are aiming at here is justified. I am delighted that so many Jews survived what they now describe as the 'Holocaust' and I am puzzled at the apparent lack of logic: that the Nazis are supposed to have had a government policy for the deliberate, ruthless, systematic extermination of the Jews in Auschwitz and other places of murder and yet tens if not hundreds of thousands of Jews passed through these camps and are, I am glad to say, alive and well amongst us now to testify to their survival. So either the Nazis had no such programme or they were an exceedingly sloppy race, which isn't the image that we have of them today. It's another of the logical questions which is being asked in this history which the historians hitherto have not asked." (33-9403, 9404)

Do you consider it possible to be accurate in terms of statistical analysis?, asked Christie. Irving did not: "No, I shy away from statistics. I am very, very nervous. I had a one year's training in statistics at university. I know how risky it is to operate with statistics, different tables or different fields or different sources. It's like subtracting apples from potatoes - you can't say there were so many Jews here at the beginning of the war and so many Jews there at the end of the war and subtract one total from the other and say this is the difference. I say this whether it helps or hinders the defence or prosecution. I am very nervous about mass statistics." (33-9404)

Was the conclusion of Did Six Million Really Die?, that the number of Jews who died in concentration camps could only be measured in thousands, legitimate and arguable?, asked Christie.

"Well, I refer to my previous answer," said Irving, "and say that I'm very nervous giving opinions about statistics. Do we mean died or killed?" (33-9405)

Christie indicated roughly 6 million were allegedly killed by either gassing or by the Einsatzgruppen. In your research, asked Christie, has there been any indication of hard evidence for numbers at all?

"Certain numbers for certain specific tragedies. One episode outside Dvinsk, being on the road to Dvinsk being in November 1941, certainly there was an episode there ...a mass grave had been dug and a mass execution...of unidentified civilians was being carried out by unidentified people. It was witnessed by one German Major General Walter Bruns. There is another episode which was witnessed by Hitler's photographer, Walter Frentz, who described it to me...from his own memory what he had seen when he accompanied Heinrich Himmler. Again one isolated episode behind the front, nothing to do with Auschwitz or Treblinka or the so-called extermination camps. So, we're looking there at several hundred if not several thousand people being killed in specific, isolated episodes which are repeatedly served up again and again as being examples of what was going on. I can only look at them as isolated episodes of what was going on." (33-9405, 9406)

Is there any hard evidence to support the estimates of millions of Jews gassed, for example, 4 million in Auschwitz-Birkenau?, asked Christie.

"No documentary, contemporaneous evidence of the kind that would satisfy me," said Irving, "but I think that other historians may perhaps be less pernickety...I think Winston Churchill once defined the job of a historian [is] to find out what happened and why and those are the major areas of historical fact that a historian should try to investigate. What happened and why and the Holocaust historians haven't really established either fact, in the case of the Holocaust, what really happened and why it happened." (33-9406)

In Irving's opinion it was the reader who decided what constituted a historical fact: "The reader. The reader on the balance of probabilities having weighed up not just one source but several sources. He can buy my book on Winston Churchill, he can buy Martin Gilbert's book on Winston Churchill and he can decide where on the two scales...the truth about Winston Churchill lies, but he has to have the alternate sources to look at. He can't have one book presented to him and be told this is the truth, take it or lump it. Take it or go to prison. That would be a very unacceptable form of society." (33-9406, 9407)

Irving pointed out that history was "constantly being revised. I mentioned the episode of the British code-breaking operations. Until 1974, the British official historians, the government historians, were not allowed to be told and not allowed to reveal that we British had been reading the German, the Japanese, the Spanish, the American, the Italian codes by computer. This is a so-called Ultra secret. Knowledge of that is, of course, crucial to the knowledge of how we won the war and yet our entire multi-volume official history of the Second World War until 1974 makes no mention of this. They are going to have to be rewritten. All history books are going to have to be rewritten since 1974 since that one fact became known and so it is in many other fields. It would be a sad day if there was no work for the historian to do. I say that with profound conviction as a professional historian." (33-9407, 9408)

And does a historian, asked Christie, when he's confronted with a document, have to take time to test and evaluate that source to determine its accuracies?

"Certainly with some documents," replied Irving. "Usually a historian will very rapidly get the feeling for where he can be easy with a document and comfortable, and where suddenly his ears prick up and say to himself, wait a minute, I didn't know this. This is so egregious, this fact, so unusual, can I trust it? There's one or two documents in the Holocaust mythology which make me very suspicious for no other reason than that they stand out too much. They are statistic oddities. It looks nice, it looks neat, it looks as though suddenly there's proof, there's 100,000 Jews been killed as partisans and Hitler's told this. And yet we have to say to ourselves, why suddenly this one document which looks like none of the other documents in that series? This is where you have to act a bit like a magistrate and say well, it's nice, I will take notice of that but I want to see more, please. The historian should be constantly weighing and evaluating and not necessarily accepting without question." (33-9408)

Does the fact that documents are located in archives satisfy those tests?, asked Christie.

"I shall disappoint you, I think, by saying on balance, usually yes," replied Irving. "I have rarely if ever come across an archive document which is fake. It is very difficult to get a fake document into an archive. Having said that, I would add it's not impossible and one would then want to look at the file of documents and say does this document, which is controversial, look different in any way? Is the paper newer? Is the ink of the signature fresher? Are the holes in a different position? Questions like that. I mean, the way the document looks; it's not impossible to put fake documents into archives. Certainly they get stolen out of them. But all the fakes that have been put to me - I emphasize all the fakes that have been put to me - come from private hands and not archival sources." (33-9409)

Did you investigate the effects of the breaking of the German codes upon the whole question of the Holocaust in relation to transportation of millions of people without orders?, asked Christie.

"Well, it is unlikely that the Germans could have been issuing criminal orders for the liquidation of millions of people or even hundreds of thousands of people to their SS or police units on the eastern front without us British knowing of it at the time from our code-breaking operations. And of course the Germans, at the end of the war, could not have required us to destroy those records." (33-9409, 9410)

There were, however, references during the war to allegations of mass gassings of Jews in some Allied documents: "I am familiar with the...British archives, the public records office, of attempts to start a black propaganda campaign alleging that the Germans were employing gas chambers and at one stage the head of the British secret service is being cautioned not to go too far with this propaganda because it will make the whole - it will undermine the credibility of the propaganda effort if we go too far with these allegations...This would have been in 1944," said Irving. The fact that these allegations were now made so freely was due, said Irving, to what the chief rabbi of Britain, Lord Jakobovits, said had "unfortunately ...become big business with whose teams of script writers and screen writers and journalists and newspaper writers, making great money out of it. I think it's a great tragedy." (33-9410, 9411)

As a writer yourself, you've been involved in publishing, said Christie. Do you have any knowledge of what would happen if you were writing about the subject of the Holocaust in your own books in a more favourable way than you have?

"After I wrote Hitler's War, my front door was smashed down by a gentleman with a sledgehammer," replied Irving. "I was raided by people disguised [as] telephone engineers who turned out to be from a Jewish organization in Britain. The people who printed this in Britain...had their printing works burned to the ground by one of these fake engineers. They all went to prison. I am an ordinary writer with a family who is frightened for - I don't like to be subjected to this kind of terror. If I was to write the other kind of book, if I was to follow the general line of the present Holocaust mythology, the easy acceptance of it all, 'Adolf Hitler ordered the killing of 6 million Jews in Auschwitz', I would do a very good job of it because I'm a good writer and I would be rich beyond the dreams of avarice, but I couldn't live with my own conscience." (33-9411)

[The testimony which follows was given by Irving in the absence of the jury in support of an application by defence attorney Douglas Christie for leave to introduce the Leuchter Report into evidence and to allow Irving to give his expert opinion on its value as a historical document.]

Irving testified that the previous day he had read the Leuchter Report in its entirety. Said Irving: "If a future historian was to be writing the history of the Holocaust controversy, then undoubtedly they can no longer ignore a document of this validity." (33-9413) He continued: "It is clearly an authentic document. It's clearly a document written by somebody in the position to know what he is writing about and it's a document written for a valid purpose. It's not a spurious document written in order to camouflage something, in my view...It is very much the kind of document that I, as a historian, would hope to find if I was investigating the Holocaust controversy. I'm very impressed, in fact, by the presentation, by the scientific manner of presentation, by the expertise that's been shown by it and by the very novel conclusion that he's arrived at and I must say that as a historian I'm rather ashamed it never occurred to me to make this kind of investigation on this particular controversy." (33-9414)

To your knowledge, asked Christie, has any physical examination of Auschwitz, Birkenau or Majdanek previously been published to determine if these places could have been used in the manner alleged in the Holocaust literature as homicidal gas chambers?

"There has been...to the best of my knowledge, no forensic examination of the sites conducted whatsoever. Either in situ by an expert in execution technology, or in absentia by taking samples for laboratory analysis elsewhere," Irving testified. (33-9414, 9415)

Crown Attorney Pearson rose to cross-examine Irving and began by asking him if the Leuchter Report was a document he would look to as a historian researching the Holocaust controversy.

Irving replied: "If I was a future historian researching the Holocaust controversy, this is certainly the kind of evidence that I should want to make use of." (33-9415)

Are you saying, asked Pearson, that if you were a historian in the year 2015 and you were doing research with respect to what happened in Birkenau on August 25, 1944, you would use this document as a foundation for a conclusion?

"This would give me a foundation for a conclusion about what did not happen in the concentration camps which were investigated by the expert in [the report]," replied Irving. (33-9415)

What do you mean by saying the report is 'authentic', asked Pearson.

"By that I mean this clearly isn't a fake report. It isn't a report which purports to be what it is but in fact isn't, in the sense of what a fake document is. In other words, this isn't something that has not been written by the purported author. It is quite clearly an authentic investigation by the man who purports to be the author." (33-9416)

Irving agreed that the document was described as an "engineering report" and testified that he "would expect to find it written by a man who has some engineering qualifications." He defined 'engineering qualifications' to mean "[s]aid qualifications for the job that he was purporting to report on...In other words, if he is reporting on execution technology, then I would expect him to be an expert on the subject of the engineering of execution chambers." (33-9416)

If he was reporting on the residue of hydrogen cyanide, would you want him to have a background in chemistry?, asked Pearson.

"No," said Irving, "but I would want him to produce...evidence that - that would satisfy me that he had obtained the samples in a scientific manner and...had sub contracted the quantitative analysis of those samples to a qualified person to make those determinations. It would be too much to expect an engineer to be qualified in the quantitative or qualitative analysis."

An engineer, someone with a degree in engineering?, asked Pearson.

"Yes."

All right, said Pearson, issued by a recognized university?

"Is that a question?"

Yes, said Pearson. What I want to get at is you said authentic and you just said an engineer, someone with a degree in engineering?

"What I actually said was I expect to find him qualified in the engineering field on which he is purporting to report, in this case, execution technology," replied Irving. (33-9417)

So, would you mean somebody who's been recognized by a professional engineering body as being a competent person?, asked Pearson.

"This undoubtedly would be ideal, but obviously we're looking here at the - at what is practicable rather than what is ideal. In this case this is the best engineering report available to this date on the execution technology alleged to have been present at Auschwitz and the other camps." Irving testified that he did not know Leuchter's qualifications personally: "I don't know the author of this report personally at all. All I know from having read the report with the eye of a historian is that he purports to be an expert, a qualified expert in execution technology and...is recognized as such by those states of the United States of America which carry out executions by gas chamber."

If you found out that he only had a Bachelor of Arts and he didn't have an engineering degree, wouldn't that cause you some concern about his engineering report?, asked Pearson.

"It would cause me some concern but it obviously hasn't concerned the states of the United States of America which carry out the very grizzly business of forwarding people from life to death inside gas chambers. They have accepted his expertise." (33-9418, 9419)

Did the states of the Unites States have this man go over to Poland to produce an engineering report about what happened in Poland in 1944?, asked Pearson.

"No, this was, as I understand it, entirely an undertaking organized and financed at the expense of the defendant in the current proceedings," said Irving.

And what was the third criteria that Hugh Trevor-Roper mentioned?, asked Pearson.

"That is...the reason why the document has come into existence. I mentioned earlier this morning that sometimes German generals would write a document for a specific reason, namely to cover themselves for an operation. They would fake something to clear themselves in future. Now, the reason why this document has come into existence is quite clearly as a defence document in this case, and if I would elaborate on that, I would say that therefore the author of that report would be aware of the fact that the document would be subjected to the most expert scrutiny by the likes of yourself and therefore he would employ an enhanced accuracy in presenting his findings." (33-9419)

Irving testified that he would take into account the fact that the report was commissioned by the defence. Asked Pearson, And don't you think that might have some bearing on how much value a historian attaches to it? Irving replied: "Um, this is true, but one wouldn't expect the author of the report to perjure himself and one certainly wouldn't expect the highly qualified analytical laboratories which carried out the chemical analysis on the compounds which were procured from the gas chambers so-called and the delousing chambers so-called in the concentration camps, to have falsified their findings in any way. And certainly, my eye could detect no sign of any kind of falsification in these analytical reports."

Do you purport to have any expertise to draw conclusions from those analytical reports, sir?, asked Pearson.

"Not on the basis of any more than the quantitative chemistry analysis one has learned in the course of a university career," said Irving. "Certainly on the basis of a historian, I can detect fudging. I can detect where something is being omitted. When I exposed the Hitler diaries as being a fake, it was on the basis of the fact that the magazine purported to carry out tests on the ink but didn't, in fact, submit those tests to us at the press conference. They fudged around their findings." (33-9420, 9421)

Pearson indicated that the tests themselves did not say anything; it was the conclusions drawn from them that were important.

"I think that if historians are inclined to accept the eyewitness or hearsay testimony of people who were present on a site, forty years later, the testimony of the bricks and stones which can be collected from the site and subjected to objective chemical analysis should very certainly be relevant to a historian." (33-9421)

You're a historian, said Pearson. You agree with me that you do not have the expertise to draw a conclusion from the absence of a chemical compound on the wall of an installation? Irving disagreed: "Well, I'm afraid there's only one conclusion possible. If, forty years later, this chemical compound is absent from that wall and we are instructed by the scientific expertise it should have been present if it ever was present, then it never was present." (33-9422)

And whose scientific expertise are you talking about?, asked Pearson.

"Going by the expertise of the analytical chemists who were commissioned to make this report...It was either stated in the analysis reports or in the findings of the specialist who has prepared this report on the basis of the evidence presented by DEGESCH, the manufacturers of the cyanide, or on the basis of Dupont, who are the American manufacturers of an equivalent chemical compound. But this chemical compound should still have been present after that length of time." (33-9422, 9423)

Pearson suggested that the only person who had drawn that conclusion was Leuchter, in his report.

"Very well, sir," said Irving. "This is if you were to ask me, and I am sure you eventually will, if I find any flaws in this report, this is the kind of flaw which I would have found in this report and which I think could have been obviated if more money and time had been spent on it...I'm not saying that the report is perfect. What I am saying is, it is important. In fact, I think it is shattering in the significance of its discovery." (33-9423)

If someone is going to draw a conclusion about the absence of a compound on a wall, wouldn't you agree, asked Pearson, they should really know what they're talking about?

"Or consult people who knew what they were talking about," said Irving. "Yes, I would agree with you. But if I were to amplify my opinion as to the - the expertise of this particular witness, I can think of a no more suitable expert to go and examine the sites of purported gas chambers in Poland than one of the few American experts on the construction of gas chambers. And I think it's a stroke of genius on the part of the defence that they should have thought of this and gone to the expense of sending this particular expert with his team out to Poland to collect the samples and bring them back and I think it portrays a certain weakness of the supporters of the Holocaust historiography that they have not undertaken this kind of analysis in the past." (33-9424)

Irving testified that from his understanding from reading the report, Leuchter was under contract and constructed gas chambers and been consulted by the various American states on their construction. He continued that he could be open to correction on this, and that Leuchter might merely have been consulted as an expert by the various American states concerned. Said Irving: "My conclusion as a historian is that on the basis of what is in front of me, Mr. Leuchter was in a position to know what he was talking about when he was investigating Auschwitz with the eye of a man familiar with the design of gas chambers." (33-9424 to 9427)

Judge Ron Thomas interjected: "Well, I think I can shorten this. You needn't ask any further questions. Do you have any submissions?," he asked Christie. (33-9427)

Christie said: "Yes, I would submit that it would be a remarkable double standard if the Crown can introduce documents without authors for them, without any proof of who wrote them in this case because they happen to be filed in the National Archives...I would submit to you that this witness has said that this evidence is important for historians, it's a valuable piece of historical evidence. It meets the test of historical evidence. The author of the report has been called and cross-examined in front of the jury, unlike any of the other pieces of evidence that have been tendered by the Crown through Mr. Browning, who didn't have any first-hand knowledge of any of them, and for that reason it's my submission that the witness should be allowed to tender that evidence and give his opinion of the value of it in a historical context. I would also like to ask the witness whether, to his knowledge, any physical examination of Auschwitz-Birkenau or Majdanek have previously been published to determine if these places have been used in the manner alleged [as] homicidal gas chambers." (33-9427, 9428)

Judge Ron Thomas ruled: "You will be permitted to ask that question. There will be no comment on the Leuchter Report. Send for the jury, please. You can refer to the fact, and advise this witness, that Mr. Leuchter testified here and that he had conducted this analysation (sic) and then find out from this historian if anything like this had been done to his knowledge before in the history of researching the Second World War." (33-9428)

Christie asked: "Can I ask him whether he considers such evidence valuable?" (33-9429)

Thomas replied: "No." (33-9429)

[This ended the voir dire to determine the admissibility of the Leuchter Report through the expert historian, David Irving. Thomas gave no reasons for disallowing the admission of the Leuchter Report, which had met all tests of valid historical evidence. The evidence which follows was given in the presence of the jury.]

Mr. Irving, said Christie, we have had in this trial the testimony of a Mr. Leuchter, indicating investigations of the physical sites and he was a person who has certain expertise in execution technology using hydrogen cyanide gas and certain chemical analysis was done pertaining to that report in regard to the content of hydrogen cyanide in the walls of the alleged gas chamber. To your knowledge, asked Christie, has any physical examination of Auschwitz, Birkenau, Majdanek, Treblinka, Belzec, Sobibor or any of the alleged extermination camps been previously published to determine if these places could have been used in the manner alleged in the Holocaust literature as homicidal gas chambers?

Irving replied: "No, sir. To the best of my knowledge, there has been no kind of examination prior to this trial and to the evidence introduced or the evidence mentioned in this trial of the so-called murder camps, the extermination camps. No kind of teams of analytical chemists were sent there to investigate the soil or the bricks of the chambers, no kind of a determination was made as to the suitability of the doors or the levers or the flanges or whether the walls had any kind of special sealing compound applied to them to protect the passersby on the street outside. There had been no kind of special determination made as to whether these buildings could ever have effectively been used as homicidal gas chambers and it wasn't until this trial that an attempt was made to carry out such an investigation."

This ended the examination-in-chief of Irving by defence attorney Douglas Christie. Crown Attorney John Pearson rose to commence his cross-examination. (33-9430, 9431)

Pearson referred first to the July 31, 1941 document from Goering to Heydrich and Irving's testimony that Goering could never have read the document. Said Irving: "He couldn't have had time to read it. It's quite evident that Heydrich was only with him for a matter of minutes. Heydrich, in fact, had the document prepared on a letterhead which Heydrich himself had typed. It wasn't even typed on Hermann Goering's notepaper. It was typed on Heydrich's notepaper. It was slipped in for Goering to sign and slipped out again." Irving knew this "From the evidence contained in Goering's diary showing how briefly Heydrich was with Goering." Heydrich was with Goering "ten minutes." Irving pointed out that it was not the only document signed that day. (33-9431, 9432)

How do you know it's not the only one he didn't read?, asked Pearson.

"Because Hermann Goering himself so testified under oath," replied Irving. "Goering testified that he was unfamiliar with this document. I have the entire series of Hermann Goering interrogations, when he was interrogated before the trial began, the pretrial interrogations."

Are you telling us, asked Pearson, that Goering testified that he never read that document?

"It was a surprise to him...To the best of my memory, he was shown the document under pretrial interrogation and this was the first time he recalled seeing it. The document itself is very harmless. It just talks about giving - giving Heydrich, extending his powers for the overall solution of the Jewish problem to the newly occupied-territories." Irving testified that Goering did not deny signing it: "No, in fact, I have the copy as signed by Hermann Goering with his signature." He agreed with Pearson that Goering must have seen it when he signed it but he continued: "Do you have any idea how many documents Hermann Goering would have signed every day normally?...It made no impression on him at all...let me say once again the document was shown to him in the course of a ten minute interview between the chief of the Gestapo, Heydrich, and himself on a rainy afternoon when Hermann Goering was hurrying to the station to pick up his wife whom he hadn't seen for three months." Irving pointed out there were certainly three documents signed by Hermann Goering that day for Heydrich in the ten minute period. He agreed with Pearson that Goering therefore had about three minutes per document. (33-9433 to 9435)

Wouldn't you agree, asked Pearson, that you are speculating when you say he never read it?

"We have to try to interpret how much a man can do in ten minutes when it's such an unimportant document as that." Irving pointed out that the document in question was two paragraphs long.

How long do you think it takes to read?, asked Pearson.

"Two paragraphs, a piece of bureaucratic bumph, I'm afraid you're not familiar with Hermann Goering's lifestyle," said Irving. "...he had a very opulent kind of lifestyle. He wasn't really interested in the minutiae of the bureaucratic life. He wasn't really interested in Reinhard Heydrich, he wasn't really interested in the Jewish question. In July 1942, he still is saying in a verbatim conference that the Führer has made exceptions all the way down the bureaucratic level. He can't understand why all this persecution of the Jews is going on...[t]he same with the Nuremberg race laws. He couldn't understand how they had come into being." (33-9436)

If the academic historians are right, suggested Pearson, that was indeed a significant memo, wasn't it?

"Indeed. They clutch at straws."

What was Heydrich's position?, asked Pearson.

"Heydrich was the chief of the Reichssicherheitshauptamt, which put him in overall charge of the Gestapo and various other important SS police executive agencies." Irving agreed that he held a senior position in the Nazi hierarchy and that "Hitler at one time was considering him as a successor." (33-9436, 9437)

Wasn't it right, asked Pearson, that Heydrich, being a senior person in the hierarchy, was looking to Goering for approval to do something?

"For the reason that Hermann Goering was chief of the four year plan. The head of the four year plan had very, very substantial economic influence in Germany, responsibilities also which had been assigned to him under the overall umbrella of the four year plan office. One of those responsibilities which Hitler had given to Goering at the time of the Reichskristallnacht, the night of broken glass in November 1938, was to oversee the final solution of the Jewish problem. Hermann Goering in January 1939 put Reinhard Heydrich in charge of the geographical resettlement of all Germany's Jews and Austria's Jews and Reinhard Heydrich set up at that time a central office for the relocation of the Jews and so it became Heydrich's penchant, drawing on Hermann Goering's authorities which is why he then had to go back to Hermann Goering in July 1941 to say, 'Look Hermann, we've now taken over all these territories in the east and I need you to expand that authority to me so I can carry on the job in the eastern territories', and that's what Hermann understood was the meat of the document he was signing. In other words, a piece of bureaucratic bumph, drawing the line a little bit further to the east." (33-9438, 9439)

Said Pearson, I don't know, sounds pretty important to me. Bureaucratic bumph?

"You're clutching at straws, the same as historians, if I may be so rude," replied Irving.

You are the one, said Pearson, who told us that this was a significant four year plan and the mandate of the senior official is being extended by the second most powerful man in Nazi Germany?

Said Irving: "The four year plan was very important until March 1942 and it virtually vanished...Heydrich took it as a useful convenience that he could put on his headed notepaper the fact that he was acting on behalf of the head of the four year plan [in] carrying out these jobs. It was a...short-circuiting [of] any kind of opposition that would come along that Heydrich could [use] and indeed did. For example, when Heydrich called the Wannsee Conference, he referred specifically to Hermann Goering's July 1941 document which says that the Reichsmarschall and head of the four year plan has instructed me to carry out an investigation of how we're going to carry out the final solution. I am therefore calling a meeting, which was the famous Wannsee Conference. Heydrich would point to the Goering document and [say] 'This is my authority, so don't start smart-talking me.'" (33-9439, 9440)

Irving agreed that the document was very important to Heydrich and that he used it. Pearson pointed out that Irving had nevertheless described it as 'bureaucratic bumph'. Said Irving: "Yes. When...you ask me why Hermann Goering himself would have paid little attention to what he was signing, he would have viewed it as a piece of bureaucratic bumph...he himself never again referred to it throughout the war years...We have seventy volumes of verbatim records of Hermann Goering's wartime conferences so we're pretty well informed about the way his mind was working. If people take the trouble to read them. But they are in that strange language and people don't take the time." (33-9440, 9441)

Pearson asked Irving whether he disputed the authenticity of the Wannsee Conference protocols. Irving testified that he did not: "I have read the entire file...incorporating the Wannsee Conference protocol and the other versions of the protocol. There are two or three records of the same meeting in various files." (33-9441)

You would agree, suggested Pearson, that at his trial in Jerusalem, Eichmann indicated that that was an important stage in the final steps of the creation of the 'final solution.' Irving interjected to point out that the trial was "twenty years later" and then continued: "I think we can agree that Adolf Eichmann at Jerusalem, when he was on trial, wasn't exactly attending a historical seminar. He was under considerable physical and mental coercion. Some of the things he said would have been true; others of the things that he said would have been false; and I am not in a position to determine which was which."

Are you now saying that the important thing is he was being coerced?, asked Pearson.

"Yes...I am saying that given the wealth of other documentation that we have, we should be able to dispense with looking at twenty year old trials to try and find still further clues as to what happened."

Pearson pointed out that Irving looked at the testimony of other participants at the conference as being significant.

"At the Nuremberg trials. This is true," said Irving. "The trials held in 1945, 1946 and 1947, they were particularly...in '46 and '47, the pretrial of Kritzinger and Lammers and the other...people who had attended, ...Wilhelm Stuckart, who attended the Wannsee Conference, were interrogated in great detail as to what they recollected." Irving agreed he viewed their testimony as significant: "One year or less after the end of the war, yes. I would consider that to be more acceptable than what Eichmann would be saying twenty years after the war." (33-9442. 9443)

So, asked Pearson, the significance now isn't the coercion, it's the passage of time, is it?

"There's an element," replied Irving. "There's an element of passage of time; an element of coercion. If a man, despite coercion, is saying things in a certain way, then it's more likely to be true than if a man because of coercion twenty years later is saying things in a certain way." (33-9443)

Pearson asked if Irving agreed that if Eichmann attended and prepared the minutes of a meeting which was integral to the plan to exterminate the Jews of Europe, that the passage of twenty years was not going to make him forget that? Irving pointed out that this was Pearson's interpretation of the meeting. He continued: "I think that you have to realize the Wannsee Conference is one of very many interministerial conferences that were held during the war years on all sorts of different topics, stocks, shipping, barges, economy, the fat supply, nitrogen, this kind of conference. And to single out one conference and expect a man years later to recollect what went on there when it's a matter which was as boring to most of them as the solution of the Jewish problem - who is a Jew, who is a half-Jew, what is a quarter-Jew, what do we do with people who have one Jewish grandparent - this kind of thing, a lot of them will have had their minds elsewhere. A lot of them did have their minds elsewhere."

Is it your position, asked Pearson, as a professional historian, that the Wannsee Conference was not a conference to discuss the extermination of the Jews of Europe?

"There is no explicit reference to extermination of the Jews of Europe in the Wannsee Conference and more important, not in any of the other documents in that file. We cannot take documents out of context...In my opinion, it has been inflated to that importance by irresponsible historians who probably haven't read the document," said Irving.

Pearson pointed out there was also the testimony of Eichmann.

"Twenty years later...I think we talked this morning a bit about Eichmann's powers of recollection and the fact he himself got confused about what he really recalled and what he had in the meantime been told. And this is a human failing which unfortunately afflicts all of us, that our memories get bad as we get older."

Forget about the minutes of the meeting and forget about the testimony, said Pearson. Is it your opinion that the Wannsee Conference itself was not a conference to discuss the extermination of Jews?

"That is my opinion." (33-9444 to 9446)

So, suggested Pearson, Eichmann made it up?

"I'm saying that Eichmann was wrong in giving contrary testimony," replied Irving, "but you would have to tell me precisely what Eichmann said. I'm not prepared to take your word for what Eichmann said. I think I have to know his precise words. I don't mean that offensively at all. Even in paraphrasing we may oversimplify what somebody...had said."

Have you read the transcript of Eichmann's testimony?, asked Pearson.

"No, I haven't. I've read a few snatches of it like I mentioned this morning."

Pearson suggested that this hindered Irving's ability to reach the conclusion he had reached. Irving disagreed: "No. I think that when one has a given life span, one can decide how one spends that life. You can spend your life in a library reading all the books [on] Adolf Eichmann...and write the X plus one book or spend your life in the archives and try to write a truer book. If you do that, you don't have to read and why should you bother with the trial records because where you are sitting is right where the truth is, in the archives, and you haven't got the Israeli Ministry of Justice putting itself between you and Adolf Eichmann." (33-9447)

Said Irving: "I don't consider that the testimony of Adolf Eichmann at Jerusalem would have advanced...my knowledge of what happened at the Wannsee Conference. It is twenty years after the war, which is five years after the Wannsee Conference, four years after the Wannsee Conference, and it would have polluted my knowledge rather than improved it." Irving agreed that Eichmann was present at the Wannsee Conference but would not swear that it was he who drafted the protocol: "To the best of my knowledge there is no signature on it." (33-9448)

It's your opinion, suggested Pearson, it's of no value to read the words of a participant in a conference to determine what the conference was about?

"Having read the fragments of Adolf Eichmann's testimony where he says his memory is so shaken that he can no longer distinguish between fiction and fact, he can no longer distinguish between what he really recollects and what he is told he recollects, from that point on all the Adolf Eichmann testimony becomes polluted, dangerous to read for a historian. It would be really like watching a made-for-TV movie about Auschwitz. That would not advance my knowledge," said Irving.

Pearson suggested again that Irving relied on the testimony of the other participants at the conference when they were on trial and had a clear interest in denying that it had anything to do with extermination.

"I accept that, yes...I accept your inference too, that they had a reason to simulate, they had a reason to deceive...I read it with interest. That doesn't mean to say I rely on it. You take note of it."

But you don't take note of Eichmann?, asked Pearson.

"No," said Irving. "Not in that account because of the particular circumstances where Adolf Eichmann was being [heard]. Had Adolf Eichmann been questioned in 1945 at very great length by American or British interrogators, that would have been of substantially greater evidentiary value for a historian than given the circumstances where he is being interrogated under the certain knowledge that he's about to be executed." (33-9449, 9450)

April 25, 1988

Irving agreed that he had written about thirty books and researched for more than ten years before writing Hitler's War and ten years before writing Churchill's War. Hitler's War was first published in Germany in 1975. Said Irving: "The German publishers, without so informing me, willfully excluded and changed parts of the text. I then obliged them to withdraw the book from publication overnight on publication day." Among other things, the publishers had changed parts relating to Hitler's knowledge of the extermination of the Jews. (34-9455, 9456)

Is it your evidence, asked Pearson, that they published that first run without letting you see the final version they were going to publish?

"Most unusual," said Irving. "They did not let me see the typescript of the German translation which I normally like to check myself. They did not honour their promise to let me see the proofs. They did not supply me with an advance copy of the book. I had to buy a copy of the book myself in a book shop in Munich and I immediately sent a telegram forbidding them to print any further editions or to sell any more copies." The English language version of the book appeared in 1977. (34-9456)

Irving agreed that he commenced Hitler's War by saying that the ten years that he had chosen to research Hitler were the best ten years to do so because the archives opened up to researchers and the people who had been involved with Hitler, especially his closest personnel, were still available. (34-9457)

Irving wrote in his introduction to Hitler's War that "the most important documents were provided by Professor Hugh Trevor-Roper..." Irving testified that "Professor Hugh Trevor-Roper is a very well-known and eminent professor of history, modern history. He was the regius professor of Oxford in history...he is now the master of an important college at Cambridge University...He is an academic historian who started initially as a non-academic historian in British intelligence." Irving agreed that he had "[not] the slightest" contempt for Trevor-Roper and in fact had written that the historian's work The Last Days of Hitler was a brilliant exception to most weak biographies of Hitler. Said Irving: "This is why I singled him out for special commendation." He owed Trevor-Roper a "very considerable debt." (34-9457 to 9459)

Irving also agreed that in his introduction to Hitler's War he had acknowledged the debt he owed to Professor Raul Hilberg. Said Irving: "Indeed, oh, yes. I corresponded with Professor Hilberg who I understand has given evidence in a previous hearing." Irving testified he had "[not] the slightest" contempt for Hilberg: "Again, he's one of the few academic historians who has done his homework, if I can put it in that shorthand form." (34-9459)

Would you agree, asked Pearson, that Hugh Trevor-Roper is probably the foremost expert on the Nazi regime in Germany of any English historian?

"Except in one respect," said Irving. "He has very little knowledge of the German language which is a substantial impediment. But otherwise I agree with your statement." (34-9459)

After Hitler's War, Irving moved on to Churchill, but kept his Hitler dossiers open "as a matter of professional interest." His research into Churchill relied more on archival documents than testimonials as many of Churchill's associates had already died. (34-9460)

Pearson turned to the subject of the assassination of General Sikorski, the Polish Prime Minister-in-exile during the war who died in a plane crash in Gibraltar. Irving gave qualified agreement that his book on Sikorski claimed that Churchill was responsible for his assassination. "I will go along with that description. In fact, it was left more open than that but the reader was invited to draw that conclusion," said Irving.

Did the law courts consider the proposition that Sikorski was assassinated by Churchill?, asked Pearson.

"They did indeed...The lower courts, on the basis of a play written by a completely different person, considered a libel action brought by the sole survivor of the plane, a Czechoslovakian national. The libel action was rather uniquely fought in as much as the defendant was a German living in Switzerland who made no attempt to appear and on the basis of that kind of court case, the court found, of course, for the plaintiff...to be perfectly specific, of course, my book was not on trial. The pilot, the Czech, Prchal, issued a libel writ against me as the author of the book, Accident: The Death of General Sikorski, and he chose not to, which implies in my view, he accepted that what I had written was not open to challenge in the English lower courts. We would certainly have defended it had he issued a writ." (34-9461, 9462)

Pearson produced a review of Hitler's War written by Hugh Trevor-Roper which appeared on June 12, 1977 in the Sunday Times Weekly Review, with which Irving was familiar:

It is well known that Mr. Irving, some years ago, convinced himself that General Sikorski, who died in an air-crash at Gibraltar, had been "assassinated" by Winston Churchill, to whom in fact his death was a political calamity. Not a shred of evidence or probability has ever been produced for this theory, and when it was tested in the courts, Mr. Irving's only "evidence" (which was very indirect at best) was shown to be a clumsy misreading of a manuscript diary. (I have myself seen the diary and feel justified in using the word "clumsy"). And yet here is this stale and exploded libel trotted out again, as if it were an accepted truth, in order to support a questionable generalisation.

Did Hugh Trevor-Roper say that in his article, sir?, asked Pearson.

"He did indeed," agreed Irving, "but he is wrong in suggesting that my theory was ever tested in the lower courts and you can have a look at my book if you wish, Accident: The Death of General Sikorski, and you will find no reference whatsoever in it to the diary which he mentions...The newspaper then refused to publish a letter from me in reply. I pointed out he was entitled to his opinions and he could put them to music and have them played by the Mainstream Guards, but I deal in facts."

Didn't Sir Frank Roberts say that Churchill wept when he heard the news?, asked Pearson.

"I have read that statement recently. It's a very recent statement by the head of the Central Department of the Foreign Office in 1943. He made that statement in the 1980s, forty years later to Winston Churchill's authorized biographer and we can each of us attach whatever weight we choose to that statement."

You choose not to accept it?, asked Pearson.

"Churchill wept freely and readily," said Irving. (34-9464, 9465)

Pearson turned to Hitler's War and read from the introduction:

The negative is traditionally always difficult to prove; but it seemed well worth attempting to discredit accepted dogmas if only to expose the "unseaworthiness" of many current legends about Hitler. The most durable of these concerns the Führer's involvement in the extermination of the Jews. My analysis of this controversial issue serves to highlight two broad conclusions: that in wartime, dictatorships are fundamentally weak - the dictator himself, however alert, is unable to oversee all the functions of his executives acting within the confines of his far-flung empire; and that in this particular case, the burden of guilt for the bloody and mindless massacre of the Jews rests on a large number of Germans, many of them alive today, and not just on one "mad dictator," whose order had to be obeyed without question.

"I think that today, eleven years later, I still stand by what I published on that date," said Irving. "...There were very large numbers of massacres which can only be described as bloody and mindless of Jews and other ethnic minorities in occupied Europe during the Second World War."

I suggest, said Pearson, that the way you have written it - 'the Jews', not 'some Jews' - that you're talking about race genocide.

"I think that readers who are picking up my book and looking at it are very familiar with the fact there has long been an allegation about a massacre or extermination of the Jews in the Second World War. The same as we talk about the extermination or massacre of the Armenians. I think it would - I really hope you have better material than this with which to challenge me frankly. I've come a very long way. I don't really want to spend a great deal of time debat[ing] one word, 'the'." (34-9466, 9467)

Pearson continued reading:

I had approached the massacre of the Jews from the traditional viewpoint prevailing in the mid-1960s. "Supposing Hitler was a capable statesman and a gifted commander," the argument ran, "how does one explain his murder of six million Jews?" If this book were simply a history of the rise and fall of Hitler's Reich, it would be legitimate to conclude: "Hitler killed the Jews." He after all created the atmosphere of hatred with his anti-Semitic speeches in the 1930s; he and Himmler created the SS; he built the concentration camps; his speeches, though never explicit, left the clear impression that "liquidate" was what he meant. For a full length war biography of Hitler, I felt that a more analytical approach to the key questions of initiative, complicity, and execution would be necessary.

Pearson suggested that in that passage Irving was saying that if one was looking at Hitler's Reich and not just at Hitler, it would be legitimate to conclude that Hitler killed the Jews. Irving replied that Hitler "had a constitutional responsibility as head of state." (34-9467, 9468)

What was the significance of the statement that Hitler and Himmler created the SS?, asked Pearson.

"Back in the 1930s, back in the 1920s in fact," said Irving, "the SS was created as an elite bodyguard for Hitler and out of which emerged the various branches of the SS, including the Waffen SS, which was the biggest branch of all, and the sentence means what it says. They both jointly created the SS." (34-9468)

Pearson suggested that in effect, Irving was saying Hitler was responsible for creating the organ that massacred the Jews. Irving disagreed: "I don't think I say that the SS is the organ that massacred the Jews. I'm just saying what, in fact, I printed there. I chose those words very carefully in writing the introduction." (34-9468)

Pearson continued reading:

For a full-length war biography of Hitler, I felt that a more analytical approach to the key questions of initiative, complicity, and execution would be necessary. Remarkably, I found that Hitler's own role in the "Final Solution of the Jewish Problem" has never been examined.

What did you mean by the "final solution of the Jewish problem"?, asked Pearson.

"Well, earlier in that paragraph, I have talked about the argument, the public perception of what had happened and I have clearly put that sentence in quotation marks; what the public calls the 'final solution of the Jewish problem'...We are going to examine in the book what the 'final solution' was, but I am already advancing here, I am alerting the reader to the fact that in this book he's going to find data on this controversy."

Wasn't the "final solution" the term generally accepted as being the term used for the racial genocide of the Jews?, asked Pearson.

"On Friday I quoted you from memory a spring 1942 document in which Hitler is quoted by the chief of his Reich Chancellery as saying 'the Führer wants the solution of the Jewish problem postponed until after the war is over'. Now, you can't have it both ways. That document is a genuine document." (34-9469)

Pearson suggested that in his introduction, Irving was telling the reader that he was going to prove that Hitler did not have personal knowledge of the extermination of the Jews. Irving agreed: "I am." He continued: "What I am more specifically saying in there is what I actually write, that Hitler, his role and whatever the 'final solution of the Jewish problem' was, whatever that was, is going to be analysed in this book."

Where are the words 'whatever that was', asked Pearson.

"It's not necessary," replied Irving. "What I am saying is that if I was writing a history of the Third Reich I would analyse it, but I'm not. I'm writing a biography of Hitler. It's already a thousand pages long. If I'm going to write an analysis of the Holocaust, the book would be 2,000 pages long."

Are you saying, asked Pearson, that you wrote a book to prove that Hitler wasn't responsible for something that never happened? Irving replied that he did not set out to write a book to prove anything: "I set out to write a biography of Hitler based on the documents as accurately as I could find them...having written the book, I wrote the introduction and not the other way around." (34-9470)

And the conclusion, suggested Pearson, was that Hitler was not responsible for something that never happened?

Said Irving: "I don't say that Hitler wasn't responsible. I am very clear there that he had a constitutional responsibility. But certainly it is questionable whether he ever knew that the 'final solution' was going on, whatever the 'final solution' was." (34-9471)

Pearson continued reading:

For thirty years, our knowledge of Hitler's part in the atrocity has rested on inter historian incest.

What atrocity are you talking about?, asked Pearson.

"There is no other way to describe what happened," said Irving. "Thousands of civilians being lined up on the side of pits and being machine-gunned to the pits after being robbed of their personal possessions. This kind of thing can only be described as an atrocity whether it happens in Germany, Yugoslavia or Vietnam." (34-9472)

Pearson continued reading:

Many people, particularly in Germany and Austria, had an interest in propagating the accepted version that the order of one madman originated the entire massacre. Precisely when the order was given and in what form has, admittedly, never been established. In 1939? - but the secret extermination camps did not begin operating until December 1941.

Order for the what?, asked Pearson.

"The order for the atrocities. We are talking about the order that these people imagine exist so there was one central order." (34-9472)

Aren't you suggesting there, asked Pearson, that secret extermination camps did not begin operating until December 1941?

"I think I have to say here that this sentence falls into the category of sentences that I would not repeat in 1988," said Irving. "At the time I wrote that in the 1960s, 1974 thereabouts when I wrote...that introduction, I believed. I believed everything I had heard about the extermination camps. I wasn't investigating the extermination camps. I was investigating Hitler." (34-9472, 9473)

But you told us you did ten years of extensive research on the National Socialist regime, said Pearson, and you had no problem making that statement, did you?

"Because I believed," said Irving. He continued: "I believed what I had read up [to] that point. I hadn't gone to the sites of Auschwitz and Treblinka and Majdanek and brought back samples and carried out an analysis. I hadn't done any research into what is called the 'Holocaust'. I researched Hitler and his staff." Irving testified that he had not done such research in the meantime: "I have carried out no investigation...in equivalent depth of the Holocaust." (34-9473)

But your mind changed?, asked Pearson, You no longer believe it?

"My mind has now changed," said Irving. "I have now begun to challenge that. I understand it is now a subject open to debate...My belief has now changed because I understand that the whole of the Holocaust mythology is, after all, open to doubt and certainly in the course of what I have read in the last few days, in fact, in this trial, I am now becoming more and more hardened in this view." (34-9474)

Said Irving: "One sees the sentence, the line of that page, 'the secret extermination camps did not begin operating until...'. Then I wrote that on the basis of what all the other eminent academic historians had been saying, that there were such extermination camps. I believed." (34-9474)

Pearson returned to Hitler's War and continued reading:

...but the incontrovertible evidence is that Hitler ordered on November 30, 1941, that there was to be "no liquidation" of the Jews (without much difficulty, I found in Himmler's private files his own handwritten note on this).

Would you agree, asked Pearson, that this November 30, 1941 order is the lynch-pin of your whole argument in Hitler's War?

"No, sir. I am aware of the newspapers hav[ing] tried to make out that was the lynch pin. In fact, that is one minor item in a series of about ten documents beginning in 1923, 1924 and going right through until 1944. The only documents specifically linking Hitler with what was happening to the Jews, and in each Hitler is putting out his hand to stop it happening. This is just one of those items and I have to say there preemptively that the word 'the' in front of Jews is wrong. It is one specific transport of Jews from Berlin going to the eastern front going to Riga, who were, in fact, at that time, November the 30th, 1941, already dead by some hours. This was one of the specific atrocities." (34-9475, 9476)

Pearson suggested that the academic historians had indicated that Irving had tried to extrapolate from a single order, relating to one shipment of Jews, a profound conclusion with respect to Hitler's role.

"They couldn't - they can't establish that. What they have overlooked is that is just one document that is referred to in a book of a thousand pages containing very many similar documents. Obviously, I particularly enjoyed drawing their attention to that document because it gave me the chance of pointing out that all these world famous academic historians had not even bothered to transcribe Himmler's own handwritten notes of his telephone conversations. This is [why] I referred to it in the introduction."

Don't they suggest that they didn't consider it that significant?, asked Pearson.

"I wouldn't think any of them have had the cheek or the gall or effrontery to suggest that Himmler's own handwritten notes on a matter like this would not be significant," replied Irving. He continued: "It is very significant. It is one of a series of documents showing Hitler intervening to try and stop mindless subordinates carrying out atrocities. There was another identical handwritten note by Himmler on April the 20th, 1942, reading in English: 'no annihilation of the gypsies'. Himmler has just been to see Hitler on that day, it was Hitler's birthday, and Himmler came out and had to telephone Heydrich, the chief of the Reich Security Office, with the instruction that there was to be no annihilation of the gypsies. But you don't see this kind of thing referred to...in the history books because they can't make it fit. They pretend that these documents don't exist." (34-9476, 9477)

Why would Hitler have to give those orders, asked Pearson, if there was no annihilation of the gypsies and, as you now claim, no liquidation of the Jews?

"I haven't said there was no annihilation of the Jews," said Irving. "I specifically said this morning and on Friday that there were a number of massacres and atrocities. I refer to them here as being 'mindless' in the introduction. I am not denying that there were these ghastly episodes and I think that what happened on this occasion, if I am allowed to have an opinion, Himmler went to see Hitler on November the 30th, 1941, in fact his handwritten notes begin with the words 'from the train'. He makes a number of telephone calls from his train. Then the next telephone call is from the bunker at the Wolf's Lair, Hitler's headquarters, 1:30 p.m., November the 30th, 1941. Himmler comes out of the bunker and telephones Heydrich and he says, 'Transport of Jews from Berlin. No liquidation.' I think Himmler has gone to see Hitler and said 'Mein Führer, why don't we just get rid of them?' and Hitler says, Kommt nicht in Frage - out of the question." (34-9477, 9478)

He continued: "There were approximately, to the best of my knowledge, between five and 10,000 Jews from the Berlin area who had been loaded onto a train and shipped out to Riga and at the time of that telephone conversation, they had already been killed three or four hours earlier...I can repeat from memory most of what is in the note. The first item is the arrest of Dr. Jekelius; the next item after appeared is apparently son of Molotov; then there's another period and then it says transport of Jews from Berlin; and then there's another period and then it says no liquidation and then there's another period." Irving testified that to the best of his knowledge both Himmler, who was chief of the SS, and Heydrich had knowledge of this massacre. (34-9478, 9479)

Would you agree, asked Pearson, that Himmler had the authority to engage the machinery of the state vis-a-vis the SS?

"I discussed this with Himmler's brother...Gebhard Himmler, many years ago, and he said to me 'I cannot believe that Heini would have done this without Hitler's authority'. Himmler certainly had the authority to set the wheels in motion himself and in the famous speeches at Posen in October 1943, he actually uses the words, 'I therefore took the decision that the women and children were to be killed as well'. So this strongly implies that he had the authority."

Pearson suggested that, with respect to the bloody and mindless massacre of the Jews, Himmler was implementing policy. Irving disagreed: "I think that it is such an important matter that it's very difficult to try and bridge that gap without some evidentiary basis...When you're trying to suggest there was a policy which is what I would contest, I don't think there was any overall Reich policy to kill the Jews. If there was, they would have been killed and there would not be now so many millions of survivors. And believe me, I am glad for every survivor that there was."

Do you know how many survivors there are?, asked Pearson.

"I don't dabble in statistics," replied Irving. (34-9479, 9480)

Pearson continued reading from Hitler's War:

My own hypothesis, to which I point in the various chapters in which I deal in chronological sequence with the unfolding persecution and liquidation of the European Jews, is this: the killing was partly of an ad hoc nature, what the Germans called a Verlegenheitslösung - the way out of an awkward dilemma, chosen by the middle-level authorities in the eastern territories overrun by the Nazis - and partly a cynical extrapolation by the central SS authorities of Hitler's anti-Semitic decrees. Hitler had unquestionably decreed that Europe's Jews were to be "swept back" to the east; I describe the various phase-lines established by this doctrine. But the SS authorities, Gauleiters, and regional commissars and governors in "the east" proved wholly unequal to the problems caused by this mass uprooting in midwar. The Jews were brought by the trainload to ghettos already overcrowded and underprovisioned. Partly in collusion with each other, partly independently, the Nazi agencies there simply liquidated the deportees as their trains arrived, on a scale increasingly more methodical and more regimented as the months passed.

Do you repudiate those statements, sir?, asked Pearson.

"I think [in] the first part of the paragraph there is not a line I would change," said Irving. "The last lines of the paragraph I think I would rubber stamp over the top of that 'at that time I believed'. At that time I believed there had been an increasingly more methodical liquidation. This is something which I am now increasingly inclined to challenge because over the intervening ten years, I still haven't seen any evidence that there was."

Have you engaged in any research on that question?, asked Pearson.

"I have engaged in a lot of research in the German archives not on that question. When you go through the German archives trolling for subjects about what you are writing about, you are going to notice if you come across blueprints or things referring to gas chambers or the methodical and systematic liquidation. Believe me, I wouldn't have concealed it if I had...I have continued writing books since then. I've worked consistently in the German archives. My relations with the world's historians are still of the very best. I have offered substantial cash rewards for documents that would prove me wrong because I have no vested interest. I have no axe to grind. If somebody came forward with a document proving that I am wrong on this, then I would accept that I am wrong and I would regard it as a battle lost and it's not the way - it's not the result, it's the way you play the game, even in writing history, and I would have said to myself I've had a good run for my money but they've found the document." (34-9481, 9482)

Have you offered a reward for anybody who can produce to you a document signed, for instance, by Himmler?, asked Pearson.

"No. What I have offered is far simpler. I have said I will pay a thousand pounds in cash to any historian or private person, anybody, who can find one single wartime document showing that Adolf Hitler knew what was going on - the 'Holocaust', whatever it was. They can't even do that."

Pearson accused Irving of being an apologist for Hitler by saying Hitler was not the one that was responsible.

"You want to call me an apologist for Hitler so the newspapers will use this tomorrow, no doubt."

What is meant by an apologist, sir?, asked Pearson.

"An apologist? I think the word is quite frank. It's a person that goes around making apologies for himself like the German people at present...If you have read the rest of the introduction - I am quite prepared to do so; I have the time - I will draw your attention to every single one of Hitler's crimes which I have set out in the introduction and drawn the reader's attention to the pages of this book where they will find Hitler's other crimes set out in more detail than in any other Hitler biography." (34-9483, 9484)

Irving agreed with Pearson that he said in his introduction that the greatest crime alleged against Hitler was the extermination of the Jews. He did not agree that he concluded Hitler wasn't responsible for it: "I deny that I say he wasn't responsible. I think I said earlier today that he had a constitutional responsibility as head of state but as his biographer, it is not without interest to me if he knew about it or not, whatever it was that was happening. It then draws the conclusion he must have been a very weak Führer of Germany if he didn't know everything that was going on on this scale." (34-9484, 9485)

Pearson continued reading from page xiv of the introduction to Hitler's War:

A subsidiary motive in the atrocity was the animal desire of the murderers to loot and plunder the Jewish victims and conceal their traces. (This hypothesis does not include the methodical liquidation of Russian Jews during the "Barbarossa" invasion of 1941, which came under a different Nazi heading - preemptive guerrilla warfare; and there is no indication that Hitler expressed any compunctions about it.)

Irving agreed that this passage was a reference to the activities of the Einsatzgruppen in Russia: "This is true...it makes me a strange apologist for Hitler when I put in a sentence like that. I think he would like for a better apologist for himself in future. I have drawn attention to the fact that in the post-invasion operations of Russia, he had specifically provided for police executive [SS] units to sweep in behind, mopping up anybody - I think one document says anybody who looked crookedly over his shoulder at us. He rounded up everybody who was likely to be partisan material and in this category the Jews figured very strongly...these Jews were not sent to Auschwitz or Majdanek or Treblinka; they were liquidated in the battlefield so-to-speak, by these SS and police units. It's an entirely different kettle of fish from what we now commonly regard as the 'Holocaust'." (34-9485, 9486)

You don't really mean in the battlefield, do you?, asked Pearson.

"In the rear battlefield areas," said Irving. "They weren't taken by train across Europe fifteen hundred miles to camps like Auschwitz and Majdanek and Treblinka and subjected to what we now have been told the Holocaust was. This is why I put that in a different paragraph. This is police units going along behind the lines, rounding up people, deporting them and liquidating them if they fell within the suspect persons categories and I - this is why I used the word 'atrocities.' It was an atrocity." (34-9486)

You don't deny that women and children were liquidated by the Einsatzgruppen, do you?, asked Pearson.

"On Friday I gave two specific instances where people whom I interviewed myself had seen this with their own eyes...This is referred to by Heinrich Himmler in the Posen speech. He said we weren't able to leave the women and children to survive. It was an atrocity. No other way of describing it."

And it had nothing to do with suspect categories, did it, asked Pearson, it was racial genocide once again?

"I can't say what was going on in the mind of those who pulled the triggers. They may very well have been motivated by racial motives."

Weren't they responding to orders they received?, asked Pearson.

"Undoubtedly, the people who were taking part in the execution squads had received orders to take part in them...I think that indirectly they [the orders] led up to Himmler," said Irving. (34-9487)

Didn't they actually go to Hitler?, asked Pearson.

"Once again if you can find that piece of paper, then you're going to be a rich man," said Irving. "You would then collect the reward, but everyone's been trying for twenty or thirty years. They haven't succeeded to find that kind of evidence."

In your book, asked Pearson, you cite a memo from Himmler to Hitler in which 300,000 Jews are referred to as being exterminated?

"I'm familiar with this," said Irving. "It's the report number 53 or 54 in October 1942. It is a very remarkable report." He continued: "It's a document that raises my eyebrows. It's a document I am unhappy about because it - it is so - it's a rare document. It pokes out above the clouds of the other archives like Mount Kilimanjaro. You wonder what it's doing there. If you work in the archives, you're familiar with documents and you're familiar with statistics and tables and suddenly you come across this document which is the only one of its kind containing this kind of statistics. It's a monthly report or a weekly report. The other weekly reports don't have that category or that kind of figure in it. I am not challenging its authenticity; I'm just saying [it's] the kind of document I am unhappy about. I am unhappy about it because it is such an unusual, isolated document." (34-9488, 9489)

Irving testified that he referred to the document in his book: "I would be dishonest if I didn't refer to it." He agreed that he did not question its authenticity in the book, but added: "If you look in the footnote to which I refer to this document, I do a very kind of mild glance at the document in which I draw the reader's attention to the colossal number of Jews who apparently have been killed on that week, 300,000, and the very small number of hand guns and other items that have been picked up in the same operations. This [is the] kind of thing which makes me suspect that perhaps - perhaps - we shouldn't believe this one document is all that it purports to be. I would be dishonest if I had ignored the document; it would be equally dishonest to try and build an entire federal case on it. I'm sure you're not trying to do that." (34-9489)

The overall heading in the document was 'people killed as partisans': "They are not killed as Jews. There is a category of partisans who have been liquidated in that period allegedly and one of the sub-headings is suddenly this colossal figure of Jews."

And you don't accept that document as evidence of Hitler being informed that the Jews are being centred out for extermination?

"I think that you're looking at the wrong paragraph of this book," said Irving. "We're talking in this paragraph about the Russian Jews being rounded up and liquidated as partisans and counter-partisan warfare. We're not looking at - at what we generally understand as the 'Holocaust'; that is, Jews being rounded up, put in trains in Amsterdam and Paris and put in trains and shipped to Auschwitz where they're gassed. This is two completely different operations we're looking at." (34-9490, 9491)

Do you deny that Hilberg sees the Einsatzgruppen as a prelude of what he calls the 'Holocaust'?, asked Pearson.

"On Friday, I said I consider every historian is entitled to his opinion. It would be a sad day if they weren't," said Irving. In his opinion, the activities of the Einsatzgruppen were not "part of an overall German state policy of exterminating Jews...because there is no documentary evidence to support the...contention." He pointed out to Pearson that the title of the document indicated it was a report on partisan warfare. (34-9492)

Pearson continued reading from Irving's introduction to Hitler's War at page xiv:

We shall see how in October 1943, even as Himmler was disclosing to audiences of SS generals and Gauleiters that Europe's Jews had virtually been exterminated, Hitler was still forbidding liquidations...

Irving agreed that the statement "Europe's Jews had virtually been exterminated" was based on something he had read: "That's correct. That comes under the category of 'at that time I believed'."

But isn't that your interpretation of what Himmler said?, asked Pearson.

"It's my interpretation based on what the perception of the world's historians up to 1977 was of the 'Holocaust'."

Irving had read Himmler's speeches in great detail. "Now, when we read them again we see that Himmler is admitting quite frankly that the German SS troops had been liquidating Jewish men and also Jewish women and children, which he then tries to justify in the eyes of his generals and in the eyes of the party Gauleiters. But this of course falls far short of what I say in that sentence that 'Europe's Jews had been virtually exterminated'." Since writing that sentence, he had studied Himmler's speeches again. "I have repeatedly because I have repeatedly been involved in historians asking to see my file of material on the High Command level decisions and the Holocaust."

So, after reading them in detail, said Pearson, preparing to write your book, you reach this conclusion but now you've changed your mind. Is that what you're saying?

"That is correct," said Irving. "I certainly wouldn't write that again." (34-9493, 9494)

Judge Ron Thomas interjected and asked when Irving had changed his mind.

"As I became aware that the whole of the Holocaust was coming under scrutiny and that the historians of the world were not able to put up a defence," replied Irving. This occurred between 1977 and the present day.

Was it at the 1983 convention of the Institute for Historical Review?, asked Pearson.

"I have made many speeches since then. I have attended many conventions. I can't be specific about where I formed any particular opinions. Obviously, this particular change of mind, and historians do change their minds over the years as they acquire better and further particulars, occurred gradually over the intervening ten years." (34-9495)

Pearson continued reading:

Wholly in keeping with his character, when Hitler was confronted with the facts - either then or, as Kaltenbrunner later claimed, in October 1944 - he took no action to rebuke the guilty. His failure or inability to act in effect kept the extermination machinery going until the end of the war.

What facts was Hitler confronted with?, asked Pearson.

"There was an investigation of specific atrocities in SS and other concentration camps in 1944," replied Irving. "The investigation was carried out by Konrad Morgen with whom I corresponded. My attention was drawn to this investigation by what Kaltenbrunner, the chief of the Gestapo, said under interrogation. Kaltenbrunner claimed that when Morgen made these reports to him about atrocities that he had found in concentration camps, he, Kaltenbrunner, had gone to see Hitler who ordered that these atrocities had to stop." Morgen was referring to Auschwitz and Treblinka. (34-9496, 9497)

Did Irving now repudiate the last sentence?, asked Pearson.

"Of course, again it makes me look a very odd apologist for Hitler that I write things like that. His 'failure or inability to act' on several occasions - he failed to act after the Reichskristallnacht in November, 1938. He took no steps to punish those who were guilty of those atrocities against the Jews. The 'extermination machinery' - I don't now believe there was anything that you could describe as 'extermination machinery' other than the very disorganized ad hoc efforts of the criminals and murderers among the SS who were carrying out the liquidations that we described earlier...I would say now 'his failure or inability...in effect, kept the atrocities possible until the end of the war'."

Pearson suggested that Irving would not even blame Hitler for failing his constitutional duty with respect to official policy. Irving disagreed: "I didn't say that. I think it was very culpable on his part. He was so busy fighting the war, defending Europe against the Soviet invasion, that he paid very little attention to what the gangsters, Himmler, Bormann, were carrying on inside occupied Europe at that time." (34-9497, 9498)

Irving agreed that Himmler and Bormann, in the hierarchy of the Nazi regime, were "right outside Hitler's door." He agreed that in his book he stated that Hitler often gave his orders to them in non-written form. He also agreed that both men were very interested in seeing to it that Hitler's wishes were realized. Irving continued: "That is where they [the orders] became paper. Himmler and Bormann wrote 'On the basis of the Führer's order, this is what we have done', and that is what is lacking in this case." (34-9499)

Pearson continued reading from Hitler's War, page 12 in the first chapter, dealing with a speech by Hitler:

...[Hitler] reminded his Party faithfuls of that unique 1939 "prophesy", adding with ominous ambiguity: "As a prophet they always laughed at me. But of those who laughed loudest then, countless laugh no longer today. Nor are those who are still laughing even now likely to laugh when the time comes...".

While Hitler's overall anti-Jewish policy was clearly and repeatedly enunciated, it is harder to establish a documentary link between him and the murderous activities of the SS "task forces" (Einsatzgruppen) and their extermination camps in the east.

You repudiate that statement, sir?, asked Pearson.

"I would not use the words 'their extermination camps'," said Irving. "I think probably there was one camp that could be described as an extermination camp at that time, 1939, 1940, and that was at Chelmno...This was operating on a very small scale and the people responsible, I believe, were subsequently penalized for it." (34-9500)

Pearson continued reading from page 12 and 53:

For the pogroms that now began, Himmler and Heydrich provided the initiative and drive themselves, using arguments of Reich security. Hitler's only order to the Reichsführer SS Himmler in this context was one for the general consolidation of the German racial position; there is no evidence that Hitler gave him any more specific instructions than this, nor did Himmler ever claim so. When army generals became restless about deeds being enacted by the SS in Poland, Himmler reassured them in a secret speech at Koblenz in March 1940, of which his handwritten notes survive - though they are infuriatingly cryptic in parts...

In the east, meanwhile, the "devil's work" was well in hand. Gruesome reports of massacre and persecution began to filter up through army channels. Not all of them reached Hitler, since Brauchitsch had in September tacitly agreed that Heydrich should have free rein for his special tasks...

What do you mean by "devil's work"?, asked Pearson.

Irving replied: "Um, the SS units under the command of General von Woyrsch...had begun rounding up opposition elements including Jews, the clergy and Polish intellectuals and they were being ruthlessly massacred." This was also the meaning of "special tasks."(34-9501, 9502)

Pearson continued reading:

...for Brauchitsch to have protested now would have been hypocritical, and besides, his row with Hitler on November 5 had made him reluctant to set foot in the Chancellery again. But consciences had to be salved and the reports were dutifully shuttled about between the adjutants. Thus, soon after the Munich plot, Captain Engel received from Brauchitsch's adjutant a grisly set of eye-witness accounts of executions by the SS at Schwetz. An outspoken medical officer addressed to Hitler in person a report summarizing the eye-witness evidence of three of his men:

Together with about 150 fellow soldiers they witnessed the summary execution of about 20 or 30 Poles at the Jewish cemetery at Schwetz at about 9:30 A.M. on Sunday, October 8. The execution was carried out by a detachment consisting of an SS man, two men in old blue police uniforms, and a man in plain clothes. An SS major was in command. Among those executed were also 5 or 6 children aged from two to eight years old.

Whether Engel showed this document and its attached eye-witness accounts to Hitler is uncertain.

Would you agree, asked Pearson, that an SS Major here is reported to have conducted a massacre that was against non-combatants?

"Oh, indeed," said Irving, "and I would like to draw attention to the quality of the documentary evidence which does exist relating to smaller crimes. Dealing here with twenty or thirty Poles who are being massacred, a small atrocity. Why do we not have documents on the huge crimes of equivalent evidentiary value?" (34-9503)

Pearson continued reading:

If Hitler still regretted having kindled this holocaust, it was not because of the horrors that were beginning to spread like a medieval plague across eastern Europe: they were inevitable byproducts of his program, and he was more concerned to justify them inwardly than to prevent them. What unsettled him was the unscheduled delay the war would inflict on his grand plans for the reconstruction of Germany.

What "holocaust" are you talking about?, asked Pearson.

"It's quite remarkable that long before the word 'Holocaust' became trademarked in the way it now has - with a capital H - I use that word there. This is because I was using it in the medieval sense of the word holocaust, the original Greek origins of the word. It's nothing to do with what is now referred to as the capital H trademark." (34-9503)

Pearson suggested that Irving was not referring to isolated incidences in the passage, but to something that was spreading like a medieval plague.

Said Irving: "I think war produces barbarism and as the barbarisation of the war progresses, then the violence and atrocities conducted by both sides increase in scale."

Pearson turned to the subject of the Madagascar project and asked Irving whether the plan did not go ahead because of French refusal to go along with it.

"From my reading of the documents at Hitler's level, the reason that the plan could not go ahead was because the conditions of war made it impossible to ship large numbers of any kind of population across the dangerous high seas...I think it was a question of unnecessary movements of civilian populations across seas that were infested by U-boats of either side." (34-9504)

It had nothing to do with the position of the French?, asked Pearson.

"This is a novelty, I have to admit," said Irving. "I had never heard before that Hitler had paid very much respect to the wishes of the French government in 1940."

Pearson continued reading from page 270 of Hitler's War:

But for the duration of the war the Madagascar plan was out. Hans Frank's Generalgouvernement of Poland would have to accommodate Europe's displaced Jews for the time being. On October 2, 1940, Hitler had discussed this with Frank and Baldur von Schirach, Gauleiter of Vienna. Schirach pointed out that his fifty thousand Viennese Jews were the first due for deportation. Frank reported that Warsaw and other Polish cities had concentrated their Jews in restricted areas - "ghettos" - and complained that he had no accommodation available for a fresh influx of Jews. But Hitler had dreamed of ridding Europe of the "Jewish plague" since 1921, if not earlier, and he had strong popular support for his program in the Reich.

You don't contest that huge numbers of Jews were displaced?, asked Pearson.

"At this time," said Irving, "we're talking about relatively small numbers because at this time all that Hitler had physically occupied was Poland, part of Czechoslovakia, France, the low countries and Norway. We're not looking at the very large populations of Jews in eastern Europe. But he has certainly by this time begun to issue the orders for the deportation, the relocation, the resettlement of Europe's Jews in the east instead of in Madagascar." (34-9505)

Would you agree, asked Pearson, that Hitler's blueprint for the Jews is evident as early as Mein Kampf? Irving disagreed: "I think you have to be very careful before using Mein Kampf as a source of Hitler's thinking. It was written in 1924 in prison in Landsberg partly by him, partly by Rudolf Hess. It's very difficult to disentangle which man wrote what. [Of] far more value is what is known to historians as Hitler's [Secret] Book which was never published until after his death, and that really was Hitler's original thinking." (34-9506)

You wouldn't deny that Hitler was virulently anti-Semitic?, asked Pearson.

"A strange character," Irving replied. "He was virulently anti-Semitic; he was seen from the documents I referred to earlier the only person in real authority who repeatedly put out his hand to protect ugly things happening to them in specific instances."

Pearson continued reading from Hitler's War:

Thus Hitler overrode Hans Frank's practical objections to using the Generalgouvernement as a dumping ground. The problem with the Madagascar plan in wartime was, he told Martin Bormann, how to transport the Jews that far. "I would dearly like to devote my entire fleet of...ocean liners to it, but in wartime that's not so easy. I don't want my German crews being sunk by enemy torpedoes." In private - to Keitel, Bormann and Speer - Hitler described it as his eventual ambition to eliminate all Jewish influence throughout the Axis domains.

Irving testified that he agreed with this passage: "I'm not sure it does your case any good because this is clear proof that Hitler had no intention, if he did have, of liquidating the Jews. He wants to ship them overseas which is a very poor way of liquidating them." (34-9507)

Irving agreed that Hitler wasn't able to ship them overseas: "The war was continuing unexpectedly...Mr. Churchill's war was continuing from June 1940 onwards and so another solution had to be found. They were shipped to the east instead." (34-9508)

Pearson continued reading:

As "Operation Barbarossa" approached, it occurred to Hitler that the new eastern empire would enable him to humour Hans Frank's loud objections to the dumping of Jews on his Generalgouvernement territory and Himmler's growing influence there. Three days after the Wehrmacht attacked Russia, Hitler announced this explicitly to Frank; and the latter accordingly briefed his staff that no fresh ghettoes were to be established, "since the Führer expressly stated to me on June 19 that in due course the Jews will be removed from the Generalgouvernement - and that the Generalgouvernement is to be, so to speak, only a transit camp". Seven months later, the Madagascar plan died a natural death. A foreign ministry official would then write: "The war against the Soviet Union has meanwhile made it possible to provide other territories for the final solution. Accordingly, the Führer has decided that the Jews are not to be deported to Madagascar, but to the east".

What exactly did Hitler mean by "east" of the Generalgouvernement? On the twentieth, Rosenberg had revealed to Canaris, Heydrich, and a host of other Party and Wehrmacht leaders that White Ruthenia - the area around Minsk - was to be set aside for "undesirables" and antisocial elements from Germany's dominions. Was this to be the new Israel, or did Hitler now use "east" just as a vague generic term, whose more precise definition would be: perdition, oblivion, extermination? The documents at our disposal do not help us.

Irving interjected, stating: "A small tingle of pride overcomes me when I read those words because I got it so right, I think, on the basis of the documents then available." (34-9509)

Pearson continued reading from page 330:

Hitherto, Adolf Eichmann, one of Himmler's leading experts on Jewish affairs, had continued holding regular conferences with his regional officials on the various problems associated with the "Madagascar plan"...But on October 18, Himmler scribbled on his telephone pad the message he had just dictated to Heydrich: "No emigration by Jews to overseas." Instead, on October 15, 1941, the big exodus from Europe to the east began - the Jews being herded initially into camps in Poland and the Lodz ghetto. "In daily transports of a thousand people, 20,000 Jews and 5,000 gypsies are being sent to the Lodz ghetto between October 15 and November 8," Heydrich informed Himmler on October 19. For the time being Himmler reluctantly kept the able-bodied Jews alive for the work they could perform; but farther east the Gauleiters had no intention of preserving the unemployable Jews: a letter dated October 25 in SS files states that Adolf Eichmann had now approved Gauleiter Lohse's proposal that those arriving at Riga should be killed by mobile gas-trucks.

Irving testified that he stood by what he wrote concerning Eichmann: "That is what that letter stated...Without having another look at the letter now ten years later in the light of our present information, I would stand by what I wrote there." (34-9510 to 9511)

Pearson continued reading:

This initially ad hoc operation gathered momentum. Soon the Jews from the Lodz ghetto and Greiser's territories were being deported farther east - to the extermination camp at Chelmno. There were 152,000 Jews involved in all, and Chelmno began liquidating them on December 8.

At this stage of the Jewish massacre it is possible to be more specific about the instigators, because on May 1, 1942, Greiser himself mentioned in a letter to Himmler that the current "special treatment" program of the hundred thousand Jews in his own Gau had been authorized by Himmler "with the agreement of" Heydrich.

With respect to the first two sentences of this passage, Irving testified: "I think I mentioned Chelmno earlier about fifteen minutes ago as one of the camps which I am prepared to accept was probably involved in this kind of operation. I think it has to be pointed out we're not talking about 152,000 Jews being exterminated. I'm just saying this is one figure which is contained in the document and that Chelmno was certainly involved in killing Jews. I don't think it's proper to read anymore into that sentence than that." (34-9511)

With respect to the last part of the passage Irving testified: "I think that in that document as used by those writers and recipients, the phrase 'special treatment' was probably a code word for liquidation." (34-9512)

Himmler had the authority to engage in a special treatment programme of hundreds of thousands of Jews, right?, asked Pearson.

"I think he arrogated to himself that authority," said Irving. "But we have to be very cautious with the word 'special treatment' because it belongs in a category of words which means different things in different mouths and in different documents." Irving agreed that particular document "left very little room for doubt" concerning its meaning. He added, however, that: "The only room for doubt would come under the heading, is this document genuine or has it been fabricated by the Polish government after the war...That would be the only kind of room for doubt. The document appeared to be authentic. One would have to carry out far more detailed forensic tests on a document like that if I was to answer it specifically." Irving testified that he published the document in his 1977 book "[o]n the basis of the beliefs current in 1977." (34-9513)

Have you asked your publisher to stop publishing Hitler's War?, asked Pearson.

"Hitler's War is out of print in this country," said Irving.

Have you asked your publisher in any other country to stop publishing it?

"Remember I said earlier I told the German publisher to stop on the very first day at a very substantial loss to myself because he tampered with the text."

What I want to know, asked Pearson, is since you changed heart and decided that many of the statements that you put in Hitler's War are no longer accurate, have you asked your publisher to withdraw it from publication?

"I think that question portrays an ignorance about the way that publishers operate. They would not reprint a book if they had to change lines in the middle of the text. The reprinting is done on a strictly photographic basis. But in the subsequent volume of this which was called The War Path, which is in fact the pre-war years of Hitler's life, I included a very detailed introduction to The War Path in which I dealt specifically with the Holocaust controversy which had blown-up as a result of this book being published...That was published in about 1978 or 1979." (34-9514, 9515)

And did you deny that the Holocaust had happened in that?, asked Pearson.

"I took exactly the same stand as I adopted in this book here," said Irving. "Very similar to the stand which I am adopting now, which was to say that the historians have not proven me wrong."

Well, sir, said Pearson, I want to know if you at any point published a disclaimer with respect to those parts of Hitler's War in which you clearly indicated that there was an extermination programme going on which you now deny?

"There's a limit of how many disclaimers an author can publish. I have disassociated myself from three or four books that have been published by me. Accident was published - the Sikorski book - was published and I put in the Times on the publication date I disassociated it from myself because changes were made...The way one disassociates oneself from something mistakenly written in an earlier volume is to lecture, is...to write articles, it is to correct the record in subsequent volumes of the book. I have occasionally done this. My very first book on the air raid at Dresden, I discovered documents existed which cast light - which cast doubt, rather, on my own figures, and I wrote a letter to the Times drawing the attention of the public to the fact that I might be wrong on the air raid casualties in Dresden." (34-9515, 9516)

In Churchill's War, do you say that the Holocaust never happened?, asked Pearson.

"In volume two of Churchill's War, we come to some very interesting documents in the British archives which show the British intelligence service suggesting a propaganda campaign against Germany on the basis of invented allegations of gas chambers and the subsequent belief that it would be wrong to press this kind of absurd story too far in order not to make the whole of British propaganda implausible," said Irving.

And would you agree with me that Did Six Million Really Die? is wrong when it suggests that the Holocaust was invented post-war? Irving replied that he needed to see the exact passage in the booklet referred to, but added: "I think the simple answer is that the author of this brochure did not have access at that time to the government records, the wartime records that I have now seen."

Was the Joint Allied Declaration something that was kept secret during the war?, asked Pearson.

"It was published in the newspapers in December 1942 along with a large number of other such propaganda declarations and probably attracted very little attention," said Irving. (34-9516, 9517)

Pearson continued reading from Hitler's War, page 330:

At Kovno and Riga the Jews were invariably shot soon after. At Minsk the Jews did not survive much longer: Richard Kube, Rosenberg's general commissioner of White Ruthenia, recorded on July 31, 1942, that 10,000 had been liquidated since the twenty-eighth, "of which 6,500 were Russian Jews, old folk, women and children, with the rest unemployable Jews largely sent to Minsk from Vienna, Brünn, Bremen, and Berlin in November last year on the Führer's orders". It is not without evidentiary value that Himmler's handwritten telephone notes include one on a call to Heydrich on November 17, 1941, on the "situation in the Generalgouvernement" and "getting rid of the Jews"; two days later Heydrich circulated invitations to an interministerial conference on the Final Solution of the Jewish Problem - delayed until January 1942, it became notorious as the Wannsee Conference.

Pearson suggested it was clear from the context that "the Final Solution" dealt with by the Wannsee Conference was about the extermination of the Jews.

"I stand by what I wrote on this page and on the previous page," said Irving, "but I don't think you are entitled to extrapolate from what I wrote there the conclusion that the reference to the Wannsee Conference in that paragraph means that I accept that it was a conference about the extermination of Jews...perhaps I can tell you by reminding you on Friday I stated that Heydrich had been given the job in January 1939 by Goering of arranging the resettlement and deportation of Jews out of what was then Germany and Austria, and that in 1941, in July, July 1941, Goering had signed an order to Heydrich expanding that authority to include the new occupied territories in the east, again as Goering understood, for the geographical resettlement of the Jews to other territories and that here, this paragraph states quite simply that Himmler and Heydrich are talking on November the 17th about the situation in the Generalgouvernement of Poland and getting rid of the Jews which was the best translation I could find that would give the flavour of the original words in German, Beseitigung, which literally means putting the Jews aside, getting rid of them." (34-9519 to 9521)

So when you wrote those words, asked Pearson, you were of the view that the Wannsee Conference was a conference about emigration and not about extermination?

"No more and no less than what that paragraph states," said Irving, "which is on November the 17th, there was that telephone conversation and that two days later, Heydrich issues invitations for an interministerial conference on the final solution of the Jewish problem. And I don't think it's proper to try and read any more into that paragraph than what I, myself, wrote." He continued: "When I wrote that, my intention as a historian was to be of assistance to other historians who hadn't bothered to read the handwriting and who hadn't bothered to look at the Wannsee Conference record, setting things out in chronological sequence so that they could form their own opinions." (34-9521)

Pearson pointed out Irving had called the Wannsee Conference "notorious". Wouldn't it have been more helpful to historians, he asked, to have said wait a minute, it shouldn't have been notorious because all they were talking about was emigration?

"I have tried not to be too polemical in this book," said Irving. "I was in trouble with the book as it was. As I said on Friday, my literary agent warned me we were going to lose a million dollars in subsidiary contracts because of the very new stand I was taking even in this kind of dry, dry as dust treatment of a very emotional subject. If I had tried to be more polemical and said it was notorious because historians have got it all wrong, if I had kept on saying that, then I think an editor would very rightly have said 'Mr. Irving, let's leave it as dry and as sober as possible'."

Are you saying, asked Pearson, that back in 1977 you knew that the historians had got it wrong? Irving agreed: "Yes, they hadn't bothered to read Himmler's handwritten notes. For example, I was the first person to produce this. This is why I was, with a rather smug grin on my face - 'it is not without evidentiary value' - this is my gentle way of poking historians in the ribs and say[ing], 'Ha, ha, 1977, twenty years after the end of the war - thirty years after the end of the war, none of you has bothered to read Himmler's own handwriting'...They had not done their homework, that they had been making claims without having exhaustively raked over all the old ashes...I think I was striking a deliberately sober tone in this and in this I was greatly aided by the fact that my editor in New York, a Jew, Stan Hochman, a very fine editor and he repeatedly caught me, held my arm and said, 'David, what do you mean by writing this? Can you be more specific?'." (34-9523)

Pearson returned to Hitler's War and continued reading at page 332:

In most circumstances Hitler was a pragmatist. It would have been unlike him to sanction the use of scarce transport space to move millions of Jews east for no other purpose than liquidating them there; nor would he willingly destroy manpower, for which his industry was crying out.

That sentence, said Pearson, was very similar to a sentence that Colin Cross had in his book about Adolf Hitler. Did Irving remember reading that sentence in Cross's book?

"I haven't read Colin Cross's work. I believe from my reading of the brochure Did Six Million Really Die? that Colin Cross's book was published in 1972...By that time I had long ago written these pages, of course. This book was being written from 1964 onwards, but it is not without interest that the brochure raises precisely the same logical questions as I have in this book, about why do you transport people if you were going to liquidate them," said Irving. He continued: "I am not prepared to have the opinions of Colin Cross quoted against my own. Colin Cross can't read German to the best of my knowledge. He hasn't read the documents that I used in this paragraph, Himmler's telephone notes. He hasn't interviewed Heinrich Heim, Martin Bormann's adjutant. He didn't do the work I did in formulating my opinion." (34-9524, 9525)

Pearson continued reading from Hitler's War at page 332:

It was Heydrich and the fanatical Gauleiters in the east who were interpreting with brutal thoroughness Hitler's decree that the Jews must "finally disappear" from Europe; Himmler's personal role is ambivalent. On November 30, 1941, he was summoned to the Wolf's Lair for a secret conference with Hitler, at which the fate of Berlin's Jews was clearly raised. At 1:30 P.M. Himmler was obliged to telephone from Hitler's bunker to Heydrich the explicit order that Jews were not to be liquidated; and the next day Himmler telephoned SS General Oswald Pohl, overall chief of the concentration camp system, with the order: "Jews are to stay where they are."

Once again, asked Pearson, why was Hitler giving orders that Jews were not to be liquidated if they weren't being liquidated?

"We discussed this in the earlier session today. This was, in fact, a reference to one trainload of Jews as becomes evident in the facsimile of that page of Himmler's handwritten notes which I published in the book so that readers could see it for themselves. It's a reference where a transport of Jews from Berlin and the next sentence is in Himmler's handwriting, Keine Vernichtung - not to be liquidated."

Pearson suggested that the only reason why someone would issue this order is they assumed that in the normal course if they didn't issue the order, the Jews were going to be liquidated. Said Irving: "It is correct to say, and I will go along with you to this extent, that the territories behind the advancing German armies in Russia were not a very healthy place for the Jews to be sent to because Hitler's commissar order existed at that time and Hitler's other orders for the ruthless combatting of partisans, which had, as we have seen, resulted in the tragic execution of very large numbers of Jews and women and children." (34-9527, 9528)

So you will agree, asked Pearson, that the person who issued the order knew that if the order didn't issue, those Jews were going to be liquidated?

"Not quite the same," said Irving. "I think what I said just now was that it wasn't a healthy place to be sent to because Jews were free game, so-to-speak, in the area behind the advancing Russian - behind the German armies in Russia." (34-9528)

Pearson continued reading at page 332:

Yet the blood purge continued. The extermination program had gained a momentum of its own. Hans Frank, announcing to his Lublin cabinet on December 16, 1941, that Heydrich was calling a big conference in January on the expulsion of Europe's Jews to the east, irritably exclaimed: "Do you imagine they're going to be housed in neat estates in the Baltic provinces! In Berlin" - and with Hitler in East Prussia this can only be taken as a reference to Heydrich's agencies - "they tell us: why the caviling? We've got no use for them either...Liquidate them yourselves!"

Said Irving: "Magnificent piece of evidence. A first-rate piece of evidence. A shorthand record taken by a stenographer in Hans Frank's government in December 1941 in Poland, a cardinal piece of evidence showing how the tragedy happened. Somebody on-the-spot taking a decision for himself. Saying Berlin has got [no] idea of the problems we've got here, we say why put them - why dump them on us? We can't use them either. Liquidate them yourselves. This bears out what I said in my introduction that the whole of the ghastly tragedy was an ad hoc measure taken, a decision taken by local people on-the-spot who just found that the Jews were a bother. They were being dumped on them and they didn't want them. Just like we in Britain didn't want them, like the Americans didn't want them either."

Irving testified that Hans Frank was the governor of Nazi-occupied Poland and its highest authority. He continued: "Remarkable thing is that this is, I think, the only explicit reference in Hans Frank's entire diaries which occupy many feet of shelf space to the tragedy that was occurring." (34-9529, 9530)

So what did Hans Frank mean at Nuremberg when he said his own diary convicted him?, asked Pearson.

"I think he is referring to probably all the Nazi atrocities that occurred," said Irving, "not just this kind of specific episode. He's referring to the whole of the Nazi occupation regime. Hans Frank at Nuremberg was a changed man. He wasn't a very morally upstanding man. He was a lawyer. He was - I don't mean that offensively. He wasn't a soldier; he wasn't an SS general. He was just a man who did what he was told or what he was paid to do. Perhaps I better say no more." (34-9530)

Who was the only person who could tell Hans Frank what to do?, asked Pearson.

"I think it depends which hat he was wearing. Certainly he came under Adolf Hitler's overall regime and in other respects he would come under Himmler's regime as the Reich Commissioner for the consolidation of Germandom."

So, when you say the extermination programme gained a momentum of its own, asked Pearson, you now repudiate the terms "the extermination programme"?

"I think I would go along with the terms there. I think it's sufficiently vague and we've described in the earlier paragraphs what I am referring to so I would let them stand there. I wouldn't want to change them." Irving testified he was referring in the sentence "to Hans Frank and the local governors, the police chiefs, meeting him and in Lublin at that conference...I think probably he was addressing the dictates of his own conscience there rather than any dictates from Hitler's headquarters." (34-9531)

Irving continued: "When he went to see Hitler in 1944, and there was a seventeen page record of their conversation, it's quite obvious that Hitler is still under the misapprehension that the Jews have been transferred further east out of Poland."

And what in fact, asked Pearson, had happened to them?

"Well, we are now taught to believe, and I stress the word believe, that they have all been exterminated," said Irving.

What did Hitler misapprehend then?, asked Pearson.

"Well, Hitler had been led to believe by his commanders they were being sent further east," said Irving. "We are now looking at it from a 1988 knowledge. I am looking at it from your side of the bench. From your point of view it could be a misapprehension...Because the present Holocaust belief is that all the Jews who were sent to Auschwitz and Treblinka and Majdanek and the other camps in Hans Frank's government generally were sent there for the purpose of liquidation. And this, of course, is now what is now open to dispute." (34-9532)

Pearson returned to Hitler's War and read from a chapter note on page 851:

In view of Himmler's note of November 30, 1941, I cannot accept the view of Dr. Kubovy, of the Jewish Document Centre, Tel Aviv, expressed in La Terre Retrouvé on December 15, 1960, that "there exists no document signed by Hitler, Himmler or Heydrich speaking of the extermination of the Jews". Of equal evidentiary interest is Himmler's telephone call to Heydrich on April 20, 1942 - after a day with Hitler - on which the Reichsführer noted: "No annihilation of gypsies". Yet the gypsies were also deported en masse to the death camps by the SS.

Pearson turned to Did Six Million Really Die? and quoted from page 29:

Finally, Professor Rassinier draws attention to an important admission by Dr. Kubovy, director of the World Centre of Contemporary Jewish Documentation at Tel-Aviv, made in La Terre Retrouvée, December 15th, 1960. Dr. Kubovy recognised that not a single order for extermination exists from Hitler, Himmler, Heydrich or Goering.

Would you agree, asked Pearson, that the pamphlet inaccurately describes Dr. Kubovy's organization? Irving did not: "It would undoubtedly be translated from the Hebrew and [the] two translations are equally valid." (34-9534)

You do agree with Dr. Kubovy?, asked Pearson.

"Well, I take exception to the - to his statement there that he says there is no document signed by Himmler speaking of the extermination of the Jews, because I have given a facsimile in the book of this telephone conversation in Himmler's handwriting speaking of 'no liquidation of the Jews'...The statement is really 'no document'. That is the operative thing there. It's quite clearly evidentiary material written in Himmler's own handwriting relating [to] liquidation of the Jews using those precise words vernichtung juden....All that I am really doing - this is another poke from me in the ribs of the historians when I am saying you haven't found this document because you didn't bother to read Himmler's own handwriting." (34-9534, 9535)

Pearson suggested Did Six Million Really Die? was wrong.

"I think the difference is that my quotation is a direct quotation in quotation marks and the author of this brochure has paraphrased it into a different form...What he really said is what I have in quotation marks and it has apparently been paraphrased by the author of this pamphlet...'That not a single order for extermination exists from Hitler...' - well, clearly, if no document exists signed by Hitler, Himmler, [Heydrich] or Goering, equally it follows logically there could not have been an order signed by them speaking of the extermination of the Jews...He has drawn a conclusion in his paraphrase. He is saying if there's no document then there's also no order...it follows if there's no single document then there's no order either. The one embraces the other." (34-9536, 9537)

You don't agree with the conclusion?, asked Pearson.

"With his conclusion? I do agree with that and I equally agree with this except that they haven't seen that Himmler did sign documents speaking of the extermination of the Jews because Himmler's telephone note uses the words 'no liquidation of the Jews'...it speaks of it in a negative sense," said Irving. (34-9537)

What were the 'death camps of the SS'?, asked Pearson, referring back to Hitler's War.

Said Irving: "I thought you weren't going to ask. 'Yet the gypsies were also deported en masse to the death camps by the SS'. The present belief is that gypsies were liquidated to some degree by the SS in Germany and I therefore assumed that they had gone to the death camps for that purpose. That was my state of belief in 1977 when this book was published. This was clearly against the orders of Hitler who had told Himmler on the 20th of April, 1942, there was to be no annihilation of gypsies." (34-9539)

Pearson suggested that a major thesis of Hitler's War was that Hitler didn't know about the mass extermination of Jews. Irving disagreed: "Not quite right. The other way around. There is no evidence that he did know what was going on, whatever it was." (34-9539)

Now your position, asked Pearson, is it's all irrelevant because there wasn't anything going on?

"Well, I would semantically say it is now all irrelevant because the mythologists have failed to produce any evidence that it was going on."

Have you read Professor Hilberg's three volume work?, asked Pearson.

"No," replied Irving. "But Professor Hilberg was kind enough to correspond with me to say that he was inclined to share my conclusions on Hitler's responsibility."

Pearson requested that Irving not shift ground. Would he agree, asked Pearson, that Hilberg had chronicled the mass extermination of the Jews in his three volume work?

"I think that Professor Hilberg will eventually also come to change his beliefs," said Irving. He had not read Hilberg's three volumes: "I don't read people's books if I can avoid it...It's easier...to go into the archives and read the original documents." (34-9540)

Pearson turned to page 390 of Hitler's War:

"It would have been a scandal if these cities' priceless treasures had suffered from air bombardment," he [Hitler] told a neutral diplomat. But now the boot was on the other foot: quite without their wanting it, the peoples of Europe were breathing a new climate of brutality.

Said Irving: "...I'm talking about the fact...that we have started sending one thousand heavy bombers to bomb the interior of German cities...It's quite plain from that paragraph I am talking about the brutality of sending bombers to drop bombs, not like the bombing of Tripoli a day or two ago, but sometimes ten thousand tons of bombs on a civilian city in one night." (34-9541, 9542)

Pearson continued reading from page 390:

Germany's contribution to this new climate, the elimination of the Jews from central Europe, was now gathering momentum. Hitler's radical followers saw the eleven million Jews as "Europe's misfortune" - as an eastern plague threatening friend and foe alike. Hitler felt that in time all Europe would understand his hatred. "Somehow we must get rid of them, if they are not to get rid of us", reasoned Josef Goebbels. It seemed no coincidence that the Jews were at the bottom of the spreading partisan movement everywhere.

The precise mode of "elimination" met with varying interpretations. Hitler's was unquestionably the authority behind the expulsion operations; on whose initiative the grim procedures at the terminal stations of this miserable exodus were adopted, is arguable.

What were these "grim procedures" at the "terminal stations"? asked Pearson.

"I think in 1977 we had all seen the movie films of Auschwitz and the other so-called death camps. This was the image I had in my eyes when I was writing that paragraph." (34-9543)

Pearson continued reading at page 391:

In January 1942, Reinhard Heydrich, chief of the Gestapo, had briefed the leading government officials in Berlin thus: the Führer had sanctioned the evacuation of all Jews to the eastern territories, substituting this for the overseas deportation originally planned. In the east they would build roads, until they dropped. At a further Heydrich conference early in March the awkward problem posed by half- and quarter-Jews was examined. One solution would be to sterilize them, but it would take ten days' hospital treatment to sterilize each of the seventy thousand people involved, so this procedure would have to wait until the war was over; a "top level" opinion - i.e., Hitler's - was quoted to the effect that a sharp distinction must be made between Jews and non-Jews, as it would not be acceptable for a mini race of semi-Jews to be perpetrated in law.

Irving testified that in this paragraph he was referring to the Wannsee Conference. He said: "I think that this document shows quite clearly that one thing...the Wannsee Conference didn't discuss was the extermination of every Jew in Europe which is now what we are led to believe. We're talking here about subsequent conferences, looking at what to do with the residual problems caused by the deportation and all the other problems of it." (34-9544)

Pearson continued reading:

In a paper circulated early in March 1942, Heydrich's office advised the ministries that Europe's eleven million Jews were to be concentrated "in the east" for the time being; after the war they might be allocated a remote territory like Madagascar as a national home. Thus the official version.

Irving testified that the figure of 11 million Jews was given in the paper itself, which Irving felt was the approximately correct figure. The "official version" he referred to was that "given by the archives. I am accepting there that it's possible, if we remember Trevor-Roper's three criteria - we ask why does a document exist, for what purpose was it written? I am accepting that it's possible these documents might have been written by Nazi criminals to cover their tracks. I think it would have been irresponsible, I believe, for me not to accept that possibility." (34-9545, 9546)

Pearson continued reading:

The actual operation proceeded differently. Starting in March and April the European Jews were rounded up in occupied France, Holland and Belgium, and in the eager Nazi satellite Slovakia; for political reasons Hungary - which had nearly a million Jews - and Romania were not approached yet but were told that their Jewish "problems" would be left unresolved until the war was over. From Hans Frank's Generalgouvernement of Poland too - beginning with the ghettos of Lublin - the Jews set out eastward under the direction of one of the cruelest SS leaders, Brigadier Odilo Globocnik, the Trieste-born former Gauleiter of Vienna. Upon arrival at Auschwitz and Treblinka, four in every ten were pronounced fit for work; the rest were exterminated with a maximum of concealment.

Where did you get the figure four in every ten?, asked Pearson.

"I believe that at that time I had been shown a document in the Berlin Document Centre of the U.S. Mission in Berlin which was one unsigned purported eyewitness account. And at that time I had no reason to challenge its reliability." Irving testified that in talking about the "official version" he was not talking about public propaganda: "I'm not talking about public propaganda. I'm talking about the official version contained in the official documents in the archives." He agreed that he went on to say in the passage that that was not what was really happening: "On the basis of my 1977 knowledge, yes." (34-9547, 9548)

Pearson put to Irving that he had written this passage after ten years of research that he had not duplicated since. Irving disagreed: "I have repeatedly been through the archives of the Nazi agency since I have written the memoirs of Field-Marshal Milch, Field-Marshal Rommel, Reichsmarschall Goering, and I have written all of these biographies which required me to go over the same ground again and expand the basis of the archival research." (34-9548)

So do you now repudiate what you've written in your book?, asked Pearson.

"I am now uncertain," said Irving, "because I now understand that the whole of the story of what happened in Auschwitz and the other camps is controversial and with that knowledge of the controversy at the back of my mind, I have kept my eyes that much more open and going through the archives again in the hope of finding a document that would resolve the controversy."

But you haven't read Professor Hilberg's three volume work?, asked Pearson.

"Professor Hilberg's three volume work isn't a document. It's the product of another historian's mind. Certainly he would make no claim that he has found evidence definitely that there was such an extermination programme directed by Hitler, because in a private letter to me he conceded that I was probably correct," replied Irving.

You made it clear in 1977, suggested Pearson, that there was an extermination programme going on, didn't you? Irving disagreed: "I made it clear that I have believed what was at that time the accepted version of events...Even in this book, I was challenging about how that tragedy...happened." (34-9549)

And yet you haven't read Professor Hilberg's three volume work where he sets out his findings for how it happened?, reiterated Pearson.

"I am sure when the time comes you will put his documentation to me and ask me my opinion on it," replied Irving.

What did you mean when you wrote "the rest were exterminated with a maximum of concealment"?, asked Pearson.

"By virtue of the fact that apart from this one document that I saw in the archives of the American government in Berlin, there was no similar kind of evidentiary proof of the existence of such an extermination programme," said Irving. (34-9550)

Pearson continued reading from Hitler's War at page 391:

Two documents shed some oblique rays of light on the level of responsibility for this. At a cabinet meeting in Cracow on April 9, Hans Frank disclaimed responsibility for the disruption in the work process caused by the order to turn over all Jews for liquidation. "The directive for the liquidation of the Jews comes from higher up."

Irving testified that he had no reason to doubt the authenticity of the report but pointed out that in a footnote he indicated that the German phrase for "higher up" referred to an intermediary level, not the highest level: "It doesn't come from Hitler." (34-9550)

Irving indicated that "at that time there was quite definitely a liquidation of Jews going on. I haven't challenged that. I've made it quite plain. I accept that there were a large number of atrocities being conducted during the war." In Irving's opinion, however, Frank was "trying to shift responsibility away from himself. He doesn't care where." (34-9551)

Pearson returned to Hitler's War and continued reading:

In a letter of June 26 it became clear that Himmler was anxious to conceal the massacre, for Globocnik was quoted as being eager to get it over with as quickly as possible in case one day force majeure should prevent them completing it: "You yourself, Reichsführer, once mentioned that you felt the job should be done as quickly as possible if only for reasons of concealment". The concealment was almost perfect, and Himmler's own papers reveal how he pulled the wool over Hitler's eyes. On September 17, while the murder machinery was operating at peak capacity, the Reichsführer still calmly jotted down in his notes for that day's Führer conference: "Jewish emigration - how should we proceed?" And in March 1943 he was to order a too-explicit statistical report rewritten to remove a stray reference to the massacre of Europe's Jews before it was submitted to the Führer!

The ghastly secrets of Auschwitz and Treblinka were well kept. Goebbels wrote a frank summary of them in his diary on March 27, 1942, but evidently held his tongue when he met Hitler two days later, for he quotes only Hitler's remark: "The Jews must get out of Europe. If need be, we must resort to the most brutal methods."

Would you agree, asked Pearson, that what you wrote in 1977 was that the Goebbels diary entry for March 17, 1942 was a "frank summary of the ghastly secrets of Auschwitz and Treblinka"? Irving did not: "No, sir, he doesn't refer specifically to Auschwitz and Treblinka, he just refers to the grizzly fate that is befalling the Jews on their arrival in the east from what he has read in a report submitted to him by the SD, the German Gestapo." (34-9552, 9553)

Irving agreed that, grammatically, the "ghastly secrets of Auschwitz and Treblinka" were joined with "Goebbels wrote a frank summary of them in his diary." He continued: "But I repeat that Auschwitz and Treblinka are not referred to in that Goebbels diary entry. He is referring to a report he claims to have read and I must add that nowhere in the German archives is this report itself contained...It's very difficult what reason Goebbels would have had to write this entry in his diary...It is Goebbels diary which was held in American custody after the war. It's...one of the volumes published by Louis Lochner." Irving testified that he was not in a position to say whether the diary was authentic or not: "I haven't examined its authenticity to this date." (34-9554)

Irving agreed that if the diary was authentic, it indicated that Goebbels knew what was going on: "I agree. Goebbels was one of the most vicious anti-semitists in the Nazi regime...We have a large number of Nazi potentates knowing about atrocities against the Jews." (34-9554)

Pearson continued reading at page 392:

In reality, Himmler was simultaneously throwing the murder machinery into top gear, while he was careful not to place responsibility for the massacre itself on Hitler in writing. (Thus on July 28 he wrote to SS General Gottlob Berger: "The occupied eastern territories" - meaning Poland - "are to be liberated of Jews. The Führer has entrusted me with the execution of this arduous order. Nobody can deprive me of this responsibility.") On July 19, three days after seeing Hitler, Himmler ordered the "resettlement" of the entire Jewish population of the Generalgouvernement to be completed by the last day of 1942. Each day after July 22, a trainload of five thousand Jews left Warsaw for the extermination centre at Treblinka; each week two trains left Przemysl for the centre at Belsec. Moreover, in August the first informal approach was made to the Hungarians to begin deporting their one million Jews to the east immediately.

Would you agree, asked Pearson, that this is talking about the systematic emptying of countries for the purpose of sending the Jews to extermination centres?

Irving replied: "Well, I do note, and I think I am entitled to refer to it - you put it on the screen -2 you specifically avoided reading this paragraph here. The middle paragraph which makes quite plain that Hitler was of the belief as late as July the 24th, he was still referring to his plan to transport the Jews to Madagascar...by now already in British hands - or to some other Jewish national home after the war was over. This is a verbatim record written by Heinrich Heim which was in my possession and I am sure your omission was inadvertent, but it does tend to throw doubt on what is happening in the next paragraph for which I have religiously reported on the basis of the documents and belief that was current in the mid 1970s." (34-9556)

Judge Ron Thomas interjected: "Well, let's just be accurate here. Unless I'm mistaken, isn't the thrust of this passage in the book at this time clearly that Hitler was being duped by more than one person?" (34-9556)

"This is the thrust of the book which I wrote at that time, sir," said Irving. He continued: "But obviously, ten years later now, I would be inclined to question what I wrote in the last line there. We know that each day after July the 22nd, a trainload of five thousand Jews left Warsaw because there is a document specifically saying that and it continues with the words 'for Treblinka' because the document adds those words, but it doesn't use the word 'for the extermination centre' which I put in intending to help my readers but now unfortunately I would have to say on the basis of my 1988 beliefs, I wouldn't use those words." (34-9556, 9557)

Irving testified that he did not deny that murders took place on a colossal scale, but he had seen no credible evidence that Treblinka was an extermination centre as alleged.

Have you talked to anybody who was at Treblinka?, asked Pearson.

"I'm afraid I have to say I wouldn't consider what a survivor of Treblinka could tell me in 1988 to be credible evidence," said Irving. He continued: "I would prefer the evidence of photographic aerial reconnaissance. I would prefer the evidence of somebody who goes to the site with expert knowledge now, and carries out concrete examinations, to the very human and fallible human memories after a tragic wartime experience forty years after the event." (34-9558)

What would Irving have a person go and see at Treblinka today?, asked Pearson.

Said Irving: "I would want them to, if they had been there at the time, I would then want them to identify where they had been on an aerial photograph and see if I could see what they have purported to have seen. I would want experts to go and examine the site and inform me with their own expert knowledge whether the site could have been used as some kind of extermination camp."

If they went to Treblinka today, what would they find?, asked Pearson.

"I think they would have to go to the real Treblinka," said Irving. "They would have to locate Treblinka first, the actual site. They would have to locate it on the basis of existing SS or German Reich government maps. They would have to look at aerial photographs to see what buildings were there [at] that time in 1944 on that site. It's very [easy] to be misled." (34-9559)

Have you seen documentation that orders Treblinka to be razed and a farm placed over it?, asked Pearson.

"Mr. Pearson, I said on Friday I am not a Holocaust historian and I have not dealt in-depth as an investigator on the Holocaust. My expertise is largely on the command level decisions which included the final solution."

Just so I get this straight, said Pearson, back in 1977 after ten years of work on National Socialist records to produce the biography of Adolf Hitler, you state conclusions about Treblinka, you now no longer accept your own conclusions, you haven't read Professor Hilberg's work, you wouldn't know what was at Treblinka if you went there and yet you no longer are prepared to accept - .

Irving interjected: "Mr. Pearson, I was in trouble as it was by suggesting in a Hitler biography what I did suggest. I was in deep trouble. If I had gone on to suggest Auschwitz, Treblinka, Majdanek, perhaps even they weren't what they were supposed to be, I think I could have packed up my writing gear forever and gone back to being a steel worker. We have to look at realities, I'm afraid." (34-9559, 9560)

So, you're saying, said Pearson, that you misled your readers so your book would sell?

"I saw no reason in 1977 not to believe the then existing version that Treblinka, Majdanek and Auschwitz had been death camps," replied Irving. (34-9560)

Pearson returned to page 393 of Hitler's War:

By August 1942 the massacre machinery was gathering momentum - of such refinement and devilish ingenuity that from Himmler down to the ex-lawyers who ran the extermination camps perhaps only seventy men were aware of the truth.

Where did you get the August 1942, the massacre machinery was gathering momentum?, asked Pearson.

Said Irving: "...this is from a date that I picked out of the post-war confidential writings of General Karl Wolff, who was Himmler's personal adjutant and liaison officer to Hitler. And he describes very shortly in this paragraph a conference with Himmler and this is why I dated this paragraph August 1942...At that time, Wolff himself had no knowledge of the massacre machinery being in operation...All you see Himmler telling Wolff is for the sake of Germany, he's having to do something which nobody can find out about and Wolff himself then speculated years later that this must be what Himmler must have been talking about." (34-9560)

Irving testified that he considered Wolff "to be a rather unstable witness inasmuch as he tended to flop and flip." He did not rely on Wolff in his book for "important matters, for substance. For this rather neat conference with Himmler, I put it in because I thought it would be irresponsible, I believe, not to mention this because we don't have very many verbatim descriptions of Himmler's own references to what he was doing." (34-9561)

Irving did not believe that Wolff was lying when he said Himmler said these things: "No, it's possible that Wolff may have misinterpreted it. Wolff may have assumed after the war that Himmler was talking about this, what is now called the 'Holocaust'. It may be that Himmler was talking about something completely different, the problems of growing artificial rubber perhaps or something like that." (34-9562)

But in 1977, asked Pearson, you had no such doubts in your mind, did you? Irving agreed: "No, you're quite right. It's very difficult to cast our minds back to 1977 before the first serious doubts about the Holocaust mythology began to arise." (34-9562)

Who are the people who brought those doubts forward?, asked Pearson.

"Partly myself," said Irving, "because I first began to question, from looking out from behind Hitler's desk, Hitler himself has no knowledge of what is going on but I assumed that something had been going on because the whole world was saying it. Now we find that other people are independently asking whether these systematic extermination programmes had been progressing." Irving testified that "[a] whole host of people have begun questioning it," including Robert Faurisson. (34-9563)

Who else denies the Holocaust happened like you seem to be doing now?, asked Pearson.

"Wait a minute," said Irving. "What I am saying is that I am not denying that the Holocaust happened in some degree. I am saying that there were a large series of unrelated atrocities. But the idea of the Holocaust mythology, 'Adolf Hitler ordered the killing of 6 million Jews in Auschwitz,' in simple terms, that, I think, is now very suspect." (34-9563)

Asked Pearson, if we define the Holocaust as, in essence, the mass murder and extermination of Jews in Europe by the Nazi regime during the Second World War, would you deny that the Holocaust happened?

"If you limit it to that definition, I wouldn't deny that that happened, that there was a mass murder of Jews by the Nazis during the Second World War," said Irving. His thesis in 1977 was that "Himmler and other senior associates of Adolf Hitler were aware that mass murders of Jews and others were taking place." (34-9580)

Pearson suggested that if Himmler and other senior officers were aware that it was taking place, it had to be considered official policy because they were the policy makers of the Nazi regime. Irving disagreed: "I think that statement derives from a lack of knowledge of the Führer principle which exists in a Führer state like Nazi Germany. Policy is only that which is laid down by the Führer himself if it is going to be considered to be state policy. And if it is surmised that something was happening, of which the Führer was unaware, then it could not be considered to be state policy for that reason." He continued: "State policy in a Führer state would be a policy which the Führer himself had ordered." (34-9581)

Pearson pointed out that Did Six Million Really Die? did not talk about state policy; it spoke of official German policy of extermination. Was it Irving's position, asked Pearson, that unless Hitler knew about it, it could not be called an official German policy of extermination?

"I think it would be quibbling over words to try to draw a distinction between official German policy and the policy of German officials," replied Irving. "Certainly, certain German officials were aware that Jews were being massacred, but to try to derive from this a broad statement that this makes an official German policy, is, I think, quibbling with words and would not be justified." (34-9582)

Irving agreed with a statement by Pearson that Hitler was consumed and preoccupied with military objectives "at the operative time..."; that beneath Hitler was an hierarchy competing for his favour and that the name of the game was basically to anticipate the Führer's will. Pearson put to Irving that Hitler had delegated to Himmler policy-making with respect to security matters. Said Irving: "In addition to security matters, the consolidation of Germandom, which was the racial kind of policy which was entrusted to Himmler." (34-9583)

Isn't it your conclusion in 1977, asked Pearson, that Himmler decided to use that delegated power which he derived from the Führer to exterminate Jews?

"I would alter the word 'used' to 'abused', and then I would accept your statement. Himmler abused the authority to exterminate large numbers of Jews and other enemies of the state at a time when it was clear from Hitler's statements that Hitler was intent on a geographical solution instead...Himmler repeatedly said that Hitler had given him the job of making Europe free of Jews. Hitler was envisaging this as a geographical resettlement, a relocation. Himmler, it is quite plain from the documents, was carrying out the task in a different way." (34-9581)

Pearson suggested that if one were looking for the official policy of the Nazi regime in security matters, one would look to what Himmler did. Irving disagreed: "Himmler was not the highest authority in the Reich. Himmler was only [an] intermediary authority. The highest authority in the Führer state was Hitler himself." He continued: "Hitler had given authorities and powers to Himmler, but he had not, so far as I'm aware from the documents that I have seen, at any time, either orally or in writing, given to Himmler the job of carrying out a mass extermination of Jews on any scale whatever." (34-9584)

Pearson put to Irving that in his book he claimed that later in the war, Hitler did find out what Himmler was doing.

"There [are] one or two documents of a post-war nature - I emphasize post-war - which indicate that this possibly happened," agreed Irving. He continued: "I repeat what these documents said; the version of events as given by these documents. I felt it was too important not to mention." Irving pointed out that in Hitler's last will and testament of April 29, 1945 "...Himmler was thrown out and demoted from all his positions of power and responsibility." (34-9585, 9586)

When did you place Hitler with knowledge of what Himmler was up to?, asked Pearson.

"In my book, I'm very specific in the way I put it. I say after October 1943, Hitler had no real excuse for not knowing. This is as far as I was prepared to go."

Irving testified that from October 9, 1943 to April 29, 1945, Hitler left Himmler in command, an action which was "[v]ery much in character with Hitler..." (34-9587)

After he found out what Himmler was up to?, asked Pearson.

"After it would - after, we must assume, Hitler had had every chance to find out," said Irving. "I based that statement on the fact that in October 1943, as we have seen, Himmler made a speech to the German Gauleiters and on the following day the German Gauleiters all trooped into Hitler's headquarters and, as I say, it would be human to assume that they had discussed this matter with Hitler, but there is no evidence one way or the other." (34-9587)

Pearson returned to Hitler's War and continued reading at page 393:

Early in August, Himmler made to Wolff the melancholy confession that for the sake of the German nation and its Führer he had shouldered a burden of which nobody could ever learn, in order that the "Messiah of the coming two millennia" might remain personally uncontaminated. At the time, Wolff was unable to elicit from Himmler precisely what that burden was.

Irving testified: "It is - Wolff related this in 1952 in a confidential memorandum for the Institute of History in Munich that he had had this conversation with Himmler and after the war he only assumed that this must have been a reference to what we now call the 'Holocaust'." (34-9589)

Didn't Wolff go on and say how many people he thought were aware of what Himmler was up to?, asked Pearson.

"He reconstructed his own knowledge of the SS hierarchy, what was the number of people who would therefore have had to be in the know if this had in fact happened...'Probably only some 70 men' were the [words] that Wolff used. In other words, it would have been a very, very small chain of command, a very small number of people in the know." Irving agreed that Wolff was an SS General; he did not agree that this put Wolff in a position to know who knew: "It's a very difficult thing to speculate on, somebody being in a position to know about something that one doesn't know about oneself...He never admitted that he had ever known about this during the war. I note that there are some documents which implied strongly that he did know about it during the war from roundabout this period. I'm referring to Karl Wolff, but certainly in his testimony, he never admitted that he had known about the mass extermination of Jews, nor ever proven to the contrary, because he was not ever punished for it." Irving nevertheless believed that Wolff was "in a very good position to have known." (34-9590, 9591)

By the post-war period, Wolff had been told there was a liquidation programme of the Jews and he believed in it. This post-war testimony was the basis for Irving's note with respect to page 392 of Hitler's War, where he had written:

Hitler still referred to the "Madagascar plan" in Table Talk, July 24, 1942. SS General Karl Wolff estimated - in a confidential postwar manuscript - that altogether probably only some seventy men, from Himmler down to Hoess, were involved in the liquidation program. The only evidence of a "Führer Order" behind the program came from postwar testimony of SS Major Dieter Wisliceny, Eichmann's thirty-one-year-old adviser on Jewish problems attached to the Slovak government (e.g., in pretrial interrogations at Nuremberg on November 11 and 24, 1945, and a written narrative dated Bratislava, November 18, 1946). He claimed the Slovaks had sent him to Berlin in July or August 1942 to check up on the fate of 33,000 next-of-kin of the 17,000 able-bodied Jews supplied for the German arms industry. Eichmann admitted to him that the 33,000 had been liquidated, and - said Wisliceny - pulled from his safe a red-bordered Immediate Letter, stamped "Top State Secret," with Himmler's signature and addressed to Heydrich and Pohl. It read (from memory): "The Führer has decided that the Final Solution of the Jewish Question is to begin at once. I herewith designate [Heydrich and Pohl] responsible for the execution of this order." However, there is a marked difference between Wisliceny's 1945 and 1946 recollections of this text; and when years later Eichmann was cross examined about this in his trial on April 10, 1961, he testified that he had neither received any such written order nor shown one to Wisliceny (who had long since been executed himself). He had only told Wisliceny verbally, "Heydrich sent for me and informed me that the Führer has ordered the physical annihilation of the Jews."

Irving agreed that in this passage he cited Eichmann's cross-examination at his trial: "I have compared the testimony of one man mentioned in Wisliceny's evidence, with Wisliceny's evidence in order to assess the validity of quite an important historical document and, as I say in the paragraph of that footnote that you didn't quote: 'This kind of evidence, of course, would not suffice in an English magistrate's court to convict a vagabond of bicycle stealing, let alone assign the responsibility for the mass murder of 6 million Jews, given the powerful written evidence that Hitler again and again ordered the 'Jewish Problem' set aside until the war was won.'" (34-9593)

While you were reading what Eichmann said about this, asked Pearson, didn't you think that you must as well read what he said about Wannsee?

"No," said Irving. "Probably a researcher who I had employed for this specific task of investigating if I had missed any evidence, came to me with the appropriate pages of the Eichmann trial testimony and said, 'Mr. Irving, Eichmann has addressed the problem of Wisliceny's statement as follows...in his trial in 1961', and I then merely compared those pages with Wisliceny's statement." (34-9594)

Is that the researcher who disassociated herself from your conclusions?, asked Pearson.

"She subsequently disassociated herself from the printed disassociation; [there] has been quite a lot of monkey business in this controversy. The newspaper announced she [had] disassociated herself from my research and that she [had] never worked for me, and she then wrote a letter to the Sunday Times saying she had very definitely worked for me and that this disassociation previously mentioned was nothing to do with her...she certainly couldn't disassociate herself from the research because I had all the receipts and invoices for the work she had done for me." (34-9595)

Did she disassociate herself from the conclusions?, asked Pearson.

"She is presently the wife or common-law wife of Professor Martin Broszat, previously mentioned in this case," said Irving.

Irving did not agree with a suggestion that there was a personal reason for Broszat being critical of his book. "I think probably it is unfair to impute that. I can't read his mind. I don't know why he does certain things. It will be wrong for me to speculate." (34-9596)

Irving agreed with Pearson that there was evidence from two separate sources, Wisliceny and Eichmann, that the Führer had ordered the physical annihilation of the Jews, but, he continued, it was: "Mutually contradictory evidence. It is hearsay evidence and referring to a document alleged to exist which has, however, never been found. And which, of course, both men had every reason to indicate had once existed because they were both facing the gallows." (34-9596)

Did Irving say that from the outset Eichmann knew he was condemned to be hanged?, asked Pearson.

"If my name was Adolf Eichmann," said Irving, "and I've been kidnapped at great expense from Argentina, and taken to Israel and put on trial, then I think that no insurance company would have offered me life insurance." (34-9597)

Pearson put to Irving that if Eichmann knew he was going to be hanged no matter what he said, why would he admit to killing millions of Jews if he had not done it.

Said Irving: "He apparently made this kind of statement on several occasions. I'm not going to put myself in the position of a psychiatrist and suggest why he did things because you would protest that I don't have these qualifications, and I think it would be wrong for me to speculate on why Eichmann made certain statements."

Irving testified that it was not correct to say that he had access to the tapes that were used to make the book Ich, Adolf Eichmann: "Eichmann's son approached me with the information that he had the tapes and he asked advice on what should be done with them, with the transcript, and I said they are a historical document which should, of course, be published." Irving never listened to the tapes and made no assessment whatever of them. (34-9597, 9598)

Pearson continued reading from Hitler's War, on page 858:

On the "resettlement" of the Jews from Poland, see Himmler's letter of July 19, 1942, to SS General Friedrich Krüger, the SS and police chief at Cracow:... and the report by the Reich transport ministry's state secretary, Theodor Ganzenmüller, nine days later to Himmler's adjutant Karl Wolff that since July 22 one train per day with five thousand Jews was leaving Warsaw for Treblinka, and that twice a week a train was leaving Przemysl with five thousand Jews for Belzek. Wolff replied on August 13 that it gave him "special pleasure" to learn this - that "daily trainloads of five thousand members of the Chosen People are going to Treblinka and that we are thus being enabled to accelerate this migration". He assured Ganzenmüller he would do all he could to smooth their way. Wolff - as ignorant as Ganzenmüller of the true functions of Treblinka extermination camp - was tried in 1964 by a Munich court and sentenced to fifteen years in prison. In the Wolff trial, the notorious SS General von dem Bach-Zelewski testified on July 24, 1964, that in his view "Hitler knew nothing of the mass destruction of the Jews" and that "the entire thing began with Himmler."

In Irving's opinion, Himmler was aware of the fact that large numbers of Jews were being killed. Karl Wolff was Himmler's adjutant. In 1977 Irving believed Treblinka's true function was extermination; thus he had described it that way in this passage. (34-9599, 9600)

Pearson asked Irving if he could agree that this passage dealt with the mass destruction of the Jews.

"Well, that is again hearsay evidence or quoting the evidence of an SS General, Bach-Zelewski, who was tried by a German court...in '64. He is repeating perceived opinions, received opinions, that in 1964, the overwhelming opinion was that there had been a mass destruction of Jews, what you call the Holocaust." Irving agreed it was possible that the document was written for the purposes of camouflage, but believed it would be unusual. (34-9602)

Pearson continued reading from Hitler's War at page 436:

In private Hitler regretted the Italians' kid-glove treatment of the Serbs. Only brute force bereft of inhibitions would work - just as only brute force would work in the war against the partisans in Russia. "On principle, when combatting illegals, anything that works is right - and I want that hammered into everybody", he laid down. "This gives everybody the freedom of action they need...If the illegals use women and children as shields, then our officer or NCO must be able to open fire on them without hesitation. What matters is that he gets through and wipes out the illegals". Hitler wanted no "pedantic" disciplinary action against the officer afterward. Himmler took the hint. In August, September, October and November his security forces counted 1,337 dead Russian partisans and executed a further 8,564 taken prisoner. His report to Hitler for the same period listed 16,553 "partisan accomplices and suspects" captured, of which 14,257 were executed; an additional 363,211 Russian Jews were claimed to have been executed under the same heading.

Pearson produced and showed to Irving Exhibit 62B (Einsatzgruppen report no. 51). Irving testified that this was the document he was referring to in the passage from the book, and that he had no reason whatever to doubt its authenticity. It set out the results of the combatting of partisans from 1 September 1942 to 1 December 1942 and listed the Jews executed under the heading "accomplices of bands and persons suspected of helping the bands." A note written on the top of the copy used by Irving indicated that the note was shown to the Führer. (34-9604, 9605)

Pearson put to Irving that the number for Jews executed was far in excess of the numbers for the other groups executed. Irving agreed: "This is precisely what I referred to this morning as being - or what makes it such an extraordinary document." He continued: "But I can only repeat what I said previously, that this was such an extraordinary document, that the figure was so unusual that it is the kind of thing which makes one raise one's eyebrows and question further. If I may just expand in two sentences, one would then look for a reference to this document in perhaps the war diary of the German High Command or in some other collateral source where you would find the same figures turning up quoted. It would be sufficient to make me mistrustful of the document because it is such an extraordinary figure, and to have that item, 'c) Jews executed', inserted there almost as an afterthought, a figure that is twenty or thirty times as large as any other figure on the page, it would make me want to find collateral evidence in another archive or in another document... I'm suggesting it is possible that at the time some overzealous SS officer decided to put in a fictitious figure in order to do Heinrich Himmler a favour. Who knows what the - once you begin speculating, you're in the wrong field for a historian." (34-9606)

Pearson accused Irving of already speculating about the Einsatzgruppen reports when he testified that the figures were inflated by people in the field.

Irving replied: "I haven't said that. Again you asked me to suggest the reason why a figure might have been tampered with. I offered the same reason that the people on the spot have a duty to show productivity. Just like in the Vietnam War, the American officers had to have a body count...This would be the same possible motivation why that figure is suddenly so startlingly high." (34-9607)

So you're prepared to reject the Einsatzgruppen reports on the basis of this speculation?, asked Pearson.

"I'm not prepared to accept them without being an expert on them, but as a historian, what I would want then is to find collateral documentation in another Ministry perhaps where you see the same kind of figures bearing out these figures as being authentic. You would find the German High Command and...their war diary. Occasionally it would summarize or report that it has been received about partisan warfare on the Russian front and it would give figures, and then you would hope to find a figure like that repeated in this completely different archival source, and then I would, without the slightest hesitation, say this document is genuine because it is in another document of the Nazi archives. This document...unfortunately is unique." (34-9608)

Who else is going to be around to report on those things?, asked Pearson.

"Well, let me give you three examples," said Irving. "The report like this would have gone quite possibly by code from the German SS police unit at the Russian front back to Berlin headquarters, and we British would have intercepted it because we were reading the German SS code at that time, and then we would find in British files those figures, terms. That is one example...Just one example of the kind of collateral evidence we historians would expect, now, forty years after the event."

That could be a false message sent out to fool the Brits, couldn't it?, asked Pearson.

"Yes, but this document is very much an orphan," said Irving. "It is all by itself, without parents, and I'm very sorry for it. It's rather pathetic and it arouses my mistrust. I emphasize that I'm very sorry to see a single figure under the heading 'Jews executed'. I'm very sorry to see that. But as a historian, I have to say why suddenly this colossal figure was inserted there in this report when all the other reports of that series contained no such figure. I want to know. It raises questions in my head and I'm uncomfortable with it." (34-9609) He continued: "This report was going to Heinrich Himmler, and he took it along with him, apparently typed on the special Führer-type typewriter to show to Hitler...[p]ossibly because he wanted subsequently to push it under Hitler's desk, so to speak, and get cover for what he was doing. Again, we're in the field of speculation. Himmler's diary is unfortunately in the hands of the Israelis. It is a point worth mentioning that the Israeli government would not allow any historians to make use of Heinrich Himmler's private diary. If Heinrich Himmler's private diary contained evidence that there had been a Holocaust, such as defined by you, or your interpretation of these documents is correct, then I'm sure the Israelis would have been the first to release the diary and make it available, but they don't." (34-9611)

Isn't that a bit of speculation, sir?, asked Pearson. Irving disagreed: "No, I think it is a very reasonable assumption, when archives or universities offer documents of a quality like that, they are very keen to make it available unless it contained something they don't want to make available."

Irving agreed with Pearson that he did not suggest in Hitler's War that the figure might have been inflated or that it might have been added. Said Irving: "This is true. You will have seen that I was leafing through the book just now. I was trying to find a footnote which I had originally included and which I thought was included, doing a few internal statistical checks on the document, the number of handguns that had been captured and so on, and comparing that with apparent number of partisans that have been captured, but I couldn't find it. But again this book is written in 1977, at a time when a lot of people believed that there had been a Holocaust as you defined it." (34-9612)

Irving agreed that on page 462 of his book, he made reference to Hitler authorizing Himmler to remove six or seven hundred thousand Jews from France. Said Irving: "Yes, that is based on, again, a handwritten note by Heinrich Himmler which...I was the first historian to find and transcribe...Himmler's notes contained the heading about the removal of the six or seven hundred thousand Jews from France, and written next to that, in Himmler's handwriting, was Hitler's decision - abtransportiert - transport them away. Again, Hitler took the decision to transport them." (34-9613)

Pearson asked Irving to look at the chapter note on page 867:

Himmler's own handwritten agenda for discussion with Hitler on December 10 survives...against Item 3, "Jews in France", Himmler put a tick and the word abschaffen...

Irving testified that abschaffen meant "dispose of." He continued: "The word abtransportiert occurred in a subsequent memo from Himmler to the Gestapo chief Müller. He used the milder words verhaftet und abtransportiert - arrested and transported away." (34-9614)

Pearson returned to page 867 of Hitler's War:

There are other illuminating references to the "Jewish problem" in Himmler's files at this time. On October 2, 1942, he wrote to Pohl, Krüger, Globocnik and Wolff about his determination to extract the Jews from their protected status within important arms factories in Poland too. "It will then be our aim to replace these Jewish workers by Poles and to merge most of these Jewish concentration-camp workshops into a very few big Jewish concentration-camp factories, as far as practicable in the east of the Generalgouvernement. But there too the Jews must one day, in accordance with the Führer's wish, disappear [verschwinden]."

Irving testified that Pohl was an SS general who was the chief of the Economic Office of the SS and had overall responsibility for concentration camps. He interpolated between Himmler and the concentration camps. General Krüger was one of the police commanders in the eastern territories. Globocnik, whom Irving described as "one of the mass murderers, one of the real Nazi criminals," was one of the SS police commanders in the occupied Polish area. (34-9614, 9615) Irving believed the document "is perfectly authentic...But it highlights, of course, one particular problem. You had to be very careful, how you translate. He is being very precious about the word he's used...he says 'to disappear', and he is not being specific what he means by the word 'disappear'. That's why I used the German word in brackets next to it." (34-9616)

Isn't it clear, asked Pearson, that when he says "there too the Jews must one day disappear" he was talking about a solution that was taking place on the site? Irving disagreed: "Mr. Pearson, in an earlier document in 1942, Himmler talks about, and I quoted it in the book, about Hitler having given that order that Europe is to become free of the Jews, that Hitler has ordered that Europe is to be ridden of the Jews...stage by stage, from west to east, and what he's talking about here is one part of Poland further to the east, but there too they must disappear and go even further to the east." (34-9616, 9617)

Irving testified that he put the document in the book "because I wanted to help the historians who weren't doing their jobs, and I was provid[ing] documents for them which they hadn't seen before. I was translating the words that were the precious delicate words, that they had a chance to make up their own mind how they are going to interpret these words, and I very much tried to avoid drawing conclusions myself." (34-9617)

Irving himself continued to read from the next passage in Hitler's War:

On November 30, Himmler sent to Gestapo Chief Müller a very "interesting [press] announcement about a memorandum written by Dr. [Stephen F.] Wise [President of the American Jewish Congress] in September 1942," and commented: "Given the scale of the Jewish migration, I'm not surprised that such rumors crop up somewhere in the world. We both know there's a high death rate among the Jews who are put to work. But you are to guarantee to me that at each location the cadavers of these deceased Jews are either burned or buried, and that nothing else can happen with the cadavers wherever they are. You are to investigate at once in all quarters to find out whether there have been any such abuses as the - no doubt mendacious - rumors disseminated around the world claim. All such abuses are to be reported to me on the SS oath of honour"...This letter was the purest humbug, and Himmler's suave reaction to two specific Allied press reports on the extermination of the European Jews proves it. On November 24, 1942, The Times (London) published a dispatch from the Jewish Agency in Jerusalem on the holocaust, partly fanciful but with an unmistakable hard core of truth. Himmler's office obtained it from Sweden and forwarded it with a noncommittal letter to the SS Reich Main Security Office in Berlin "for your attention". On February 14, 1943, the same newspaper published a report received by the British Section of the World Jewish Congress from Central Europe, claiming that the extermination of Jews was being accelerated: Bohemia-Moravia was to be "judenrein" by March 31, deportations from Germany were continuing, and the mass exterminations in Poland were proceeding, in one place at the rate of six thousand daily. "Before being massacred, the Jews are ordered to strip and their clothes are sent to Germany." Rudolf Brandt, Himmler's adjutant, sent the news report to Kaltenbrunner's office. "On the instructions of the Reichsführer SS I am transmitting herewith to you a press dispatch on the accelerated extermination [Ausrottung] of the Jews in Occupied Europe."

Irving testified: "When I write here there is an 'unmistakable hard core of truth', I'm comparing the Times report of November 1942 with what our state of knowledge was in 1977 when that was published, and I'm saying, 'Look, it appears to be the same. They're talking about gas chambers, about people being forced to strip and having their property robbed and all the rest of it. The reason I printed this very long footnote at the back of the book, because I [found] these documents in Himmler's files in the private papers of the chief of the SS, and I thought they were such unusual documents that they deserved to be mentioned. It would be irresponsible not to quote them at length but they do sometimes have the feel of the kind of document that Trevor-Roper was warning about when he said why has this document come into existence? What is the purpose of this document? The real purport? Is somebody trying to pull the wool over somebody's eyes? And you very much get the feeling of that when you read some of these documents, and that's why I put that in. I get the feeling there that Himmler is writing a letter and passing it on to Müller and winking and nodding at the same time, and now saying 'Put this [in] your file, Müller. You may need it.' Who knows? We're speculating again, but it is important to speculate on the basis of responsible information from the archives, which is what I considered my job to be." (34-9620, 9621)

Irving pointed out that the words "I am transmitting herewith to you a press dispatch on the accelerated extermination of the Jews in Occupied Europe," was Brandt's translation of what the Times was writing in the news report "and the Times in 1943 was very much into the business of publishing British propaganda." Irving agreed that Brandt did not point out that it was propaganda and that logically, he should have put "the alleged accelerated extermination." (34-9622)

Pearson returned to Hitler's War at page 503, where Irving had dealt with a two-hour meeting between Himmler and Hitler on March 30, 1943:

Nor did Himmler evidently raise with Hitler the progress made on the "Jewish problem" during their two hour mountain stroll on March 30 - Hitler wearing a soft peaked cap to shade his eyes against the Alpine glare. Earlier in 1943 Himmler had submitted to him a statistical report on a similar topic - the population migrations he had sponsored since Hitler's written order of October 1939; the report was typed on the special large-face typewriter and clearly went to the Führer. But did Hitler ever see the statistical report the Reichsführer had commissioned at the same time on the "Final Solution of the Jewish Problem in Europe"? In dry tones, Himmler's chief statistician, Dr. Richard Korherr, had analyzed the fate of the world's estimated 17,000,000 Jews: Europe's 10,000,000 had dwindled by 45 percent since 1937, owing to emigration, the high natural mortality rate, and the enforced "evacuation" that had begun with the prohibition of emigration late in 1941. To Himmler's annoyance, on reading the sixteen-page document on March 23 he found that it stated expressis verbis on page 9 that of the 1,449,692 Jews deported from the eastern provinces 1,274,166 had been subjected to "special treatment" at camps in the Generalgouvernement and a further 145,301 similarly dealt with in the Warthegau.

Irving agreed that Dr. Richard Korherr had been instructed to make his report to show Himmler how things were going with the extermination of the Jews. "It's a very, very questionable document, but I accept the figures it contains. It's a report that does a somersault after it comes from existence, because Himmler demanded that the report should be rewritten in a form suitable for showing to Hitler." Irving termed the document "questionable" because "of the extraordinary manner in which Himmler protested about the document and asked it be rewritten in a more suitable form. It was only introduced in part in Nuremberg at the Nuremberg trial. The evidence, these covering letters, showing that it had been tampered with by Himmler or by other people, subsequently was omitted from the Nuremberg exhibits." Irving did not believe the document was tampered with after the war, but tampered with during the war by Himmler. The suggestion he made in his book was that Himmler tampered with it to "pull the wool" over Hitler's eyes. (34-9625, 9626)

Pearson put to Irving that in the Korherr report, the words "special treatment" meant liquidation.

"This is one possible interpretation on this document, but Korherr himself is still alive and has challenged it," said Irving. "He said he did not mean that when he wrote it...He wrote a very long letter, as I understand it, to the German news magazine, Der Spiegel, a very irritated letter saying he's fed up with his report always being adduced as evidence that there was a mass murder of the Jews. The report that he wrote was quite a straightforward statistical report and at no stage in his report had he referred to the mass killing of large numbers of Jews...I have to be honest and say that I haven't seen Korherr's letter to Der Spiegel. I'm just repeating what I understand the letter to have said, that he protested against the imputation that his document was an explicit proof of the liquidation of Jews, large numbers of Jews." (34-9627)

Irving agreed that in 1977 when he wrote his book, he believed that the words "special treatment" in the Korherr report meant liquidation: "...I agree it is difficult to conceive what else 'special treatment' can have been at one point, 3 million Jews being subjected to it at camps in the Warthegau...it can't have been a haircut. But I just have to add the rider that the author of the report himself says this is an improper imputation to place on his own report." (34-9628)

Irving agreed that the document was strong proof that 1.2 million Jews died in the camps in the General Government: "Indeed, and this is why when you asked what my estimate would be, I said the upper limit at that kind of figure, making the mental reservation in my mind if this document is accurate and 'special treatment' was meaning that, and if Korherr was lying after the war when he said it didn't mean that, then it would be proper to put that figure as the upper level." (34-9629)

Pearson questioned whether this would have been the upper limit since there were two more years to go in the war. Irving explained: "It was prepared and submitted to Himmler on March the 23rd, 1943...At that time, there were no more territories under German control from which they could have extracted more Jews. It wasn't until they marched into Hungary that they then had a further reservation for their problems. Statistics then changed. This was basically a ten-year report." (34-9629)

Irving pointed out that Himmler himself objected to the use of the words "special treatment" in the report; Himmler indicated that the Jews hadn't been submitted to "special treatment" but had been channeled through the camps to the east. (34-9630)

But I thought you said that the reason for that was because Himmler wanted to "pull the wool" over Hitler's eyes?, asked Pearson.

Said Irving: "This is one possible interpretation. I don't know. He doesn't say, 'The reason I'm asking for this different report is in order to pull the wool over the Führer's eyes.'" (34-9630)

Pearson returned to Hitler's War and continued reading at page 504:

Himmler knew too well that the Führer had in November 1941 ordered that the Jews were not to be liquidated. On April 1 he had the report edited "for submission to the Führer"; and a few days later - lest he had not made himself plain - instructed that in the version for the Führer he "did not want there to be any mention of 'special treatment of Jews' whatever". According to the new text, the Jews would have been "channeled through" the camps...As he wrote on April 9, the report would serve magnificently for "camouflage purposes" in later years.

"I don't know what he's camouflaging," said Irving. "I have not the faintest idea what he's camouflaging, but it does show that documents get created for different reasons than they apparently seem to portray. If on...Friday, you may have thought I was being a bit precious saying there was three criteria: is the document authentic; written by somebody in a position of authority who knows; for what purpose was the document written? This is a typical example of a very suspicious document which has been written for a reason quite clearly other than what it appears to portray." (34-9631)

Pearson put to Irving that Himmler was concerned with camouflaging what was going on, not keeping anything from Hitler who would have known what was going on. Irving disagreed: "You are entitled to your opinion. I have felt I have done my duty in representing that report. It is noteworthy that this particular page about the camouflage was removed by the Nuremberg authorities. It wasn't included in their exhibit because it was embarrassing, but my job as a historian is to try and present the total truth as I see it, and the total truth is never, never completely clear. It is always confusing at the edges."

Pearson read the note on page 871 in Hitler's War with respect to the Korherr report:

Himmler had ordered Korherr to make a statistical analysis of the Final Solution, by letter of January 18, 1943...explaining that Kaltenbrunner's office "lacked the necessary expert precision." The draft and shortened final reports, and Himmler's related correspondence, are on microfilm...As the ribbon copy of the shorter version is still in Himmler's files, it may not even have gone to Hitler. Nor did several letters which at about this time reached Dr. Hans Lammers alleging that Jews were being methodically exterminated in Poland...At the Nuremberg war crimes trials, Lammers stated that he followed up these reports by asking Himmler. "Himmler denied that there was any authorized killing going on and told me" - making reference to the Führer's orders - "I have to evacuate the Jews and in such evacuations there are...obviously fatalities. Apart from those, the people are being housed in camps in the East." And he fetched a mass of pictures and albums and showed me how the Jews were being put to work in the camps on war production, in shoe factories, tailors' shops, and the like. Then he told me: "This job comes from the Führer. If you think you must put a stop to it, then go and tell the Führer."

Irving testified that Kaltenbrunner was the successor of Heydrich as chief of the Reich Main Security Office. He did not agree with Pearson's suggestion that Himmler was lying to Lammers: "Himmler denied that there was any authorized killing going on. It's a bit vague. What does he mean about that? Does he mean there is no official policy to kill? I think that does mean just what it says." (34-9633)

Pearson returned to Hitler's War at page 575:

Early in October [1943] the remaining Jews were deported from Denmark. Himmler also considered the eight thousand Jews in Rome a potential threat to public order; Ribbentrop brought to Hitler an urgent telegram from his consul in Rome reporting that the SS had ordered from Berlin that "the eight thousand Jews resident in Rome are to be rounded up and brought to Upper Italy, where they are to be liquidated." Again Hitler took a marginally more "moderate" line. On the ninth Ribbentrop informed Rome that the Führer had directed that the eight thousand Jews were to be transported to Mauthausen concentration camp in Austria instead, where they were to be held "as hostages." It was, Ribbentrop defined, purely a matter for the SS. (The SS liquidated them anyway, regardless of Hitler's order.)

Irving testified that he did not repudiate that paragraph: "No, sir, I stand by that paragraph. The German document referred to the eight thousand Jews resident in Rome are to be rounded up and brought to Upper Italy where they are to be liquidated...You can't dispute that at all, and this belongs to that category of document I mentioned earlier showing whenever Hitler is personally involved in this process he always puts out his hand to stop something ugly happening to the Jews. In this case, he intervened to stop them being liquidated and ordered them transported to Mauthausen instead, and I understand that nevertheless they were still killed, and I understand that the Jews of Rome suffered that fate." Irving did not know where the Jews were liquidated: "I've only heard that the Jews of Rome did suffer that fate." (34-9635, 9636)

Ribbentrop was the Reich Foreign Minister. Said Irving: "I think on this occasion, he very clearly acted to prevent it happening. As soon as he received information from his diplomats in Rome that the SS had a plan to liquidate the Jews in Rome, Ribbentrop immediately took that telegram around to Hitler in Hitler's headquarters and showed it to Hitler and obtained an order that that was not to happen."

Wasn't there another occasion when Ribbentrop counseled the leader of Hungary, Horthy, to liquidate the Jews of Hungary?, asked Pearson.

"I'm sure you will remind us of the episode in precise wording rather than your summary," said Irving. (34-9637)

You tell us how you summarize it then, said Pearson. Wasn't there a conversation involving Hitler, Horthy and Ribbentrop in April, 1943?

"Hitler, Admiral Horthy and Ribbentrop had a discussion of the future fate of the Jewish population of Hungary," replied Irving, "which is very large, to the order of one or two million Jews in Hungary, and the Nazi leaders [urged] the Hungarians to be more radical, to agree to them being rounded up and put away, locked away, in security because they were a security threat. And I am speaking from memory here. I've dealt with this previously in the book and we can probably look it up, if you had it on one of your photocopies. The German record of their conversation makes no specific reference from which you could deduce that the Jews were to be killed. In fact, on the second day of their discussion, Hitler actually said to Admiral Horthy, 'You can't really expect of us that they should be killed', or words to that effect. And of greater interest is the Hungarian record of the conversation which I looked at in the Hungary archives, which makes it quite plain that there was never any discussion about recommending that the Hungarians should kill the Jewish population." (34-9637)

Irving located where he had discussed this in Hitler's War on page 509 and read the passage to the court:

Poland should have been an object lesson to Horthy, Hitler argued. He related how Jews who refused to work there were shot; those who could not work just wasted away. Jews must be treated like tuberculosis bacilli, he said, using his favorite analogy. Was that so cruel when one considered that even innocent creatures like hares and deer had to be put down to prevent their doing damage? Why preserve a bestial species whose ambition was to inflict bolshevism on us all? Horthy apologetically noted that he had done all he decently could against the Jews: "But they can hardly be murdered or otherwise eliminated", he protested. Hitler reassured him: "There is no need for that."

In a footnote, Irving had written:

According to Schmidt's notes, Ribbentrop went even further than Hitler in one outburst to Horthy, exclaiming "that the Jews must either be destroyed or put in concentration camps - there is no other way."

Irving testified that he believed this was said in a separate discussion between Ribbentrop and Horthy. He continued: "And then, in a letter in the Hungarian archives, there is a letter from Horthy to Adolf Hitler, on May the 7th. Horthy says in his draft letter, there is a sentence which he later deleted: 'Your Excellency' - meaning Hitler - 'further reproached me that my government does not proceed with stamping out Jewry with the same radicalism as is practised in Germany.'" (34-9640)

Pearson suggested to Irving that it was clear to Horthy that what was happening in areas where the Nazis were in control was racial genocide. Irving disagreed: "No, I think it is quite plain, from page 509, which you haven't photocopied for the jury, that Hitler told Admiral Horthy that nobody is talking of murdering the Jews. There is no need for that. I'm sorry, here we are: 'Hitler reassured him there is no need for that.'" (34-9640)

I suggest, said Pearson, that what Hitler was telling him is that Admiral Horthy didn't have to do that to the Hungarian Jews, that he didn't have to go as far as Hitler's own regime was going.

"I don't think that interpretation is borne out either by the German document when read in full or by the Hungarian version of the same conversation." (34-9641)

Pearson returned to Hitler's War, page 575:

Coincidentally, it was at this time that Himmler first revealed to two audiences - of SS Gruppenführer (generals) on October 4, and Gauleiters on October 6 - an awful secret which he forbade them to discuss in public; by the end of 1943 the last Jews in occupied Europe would have been physically exterminated. That Himmler's intention was to make all his SS generals and the Gauleiters, regardless of their guilt, accessories after the fact to the massacre is strongly suggested by one curious document in his files: a name-by-name list of those who had not attended his speech!

Irving testified that "Himmler is saying that he's talking about the liquidation of Jews to his men . . . He is explaining it to them. We discussed this on Friday. He is also justifying why they are killing the Jewish women and children in these operations because he said it would be wrong to leave them, to come back when they grow up . . ." (34-9642)

Did he say, asked Pearson, that "by the end of 1943 the last Jews in occupied Europe would have been physically exterminated"?

"I think that this was the burden of those two speeches, as I understood it when I read them at the time." (34-9642)

Pearson asked Irving to go to page 11 of Did Six Million Really Die?:

•  ...the files of Himmler's headquarters and Hitler's own war directives there is not a single order for the extermination of Jews or anyone else. It will be seen later that this has, in fact, been admitted by the World Centre of Contemporary Jewish Documentation at Tel-Aviv. Attempts to find "veiled allusions" to genocide in speeches like that of Himmler's to his SS Obergruppenführers at Posen in 1943 are likewise quite hopeless.

Irving agreed that he didn't have any trouble finding an allusion to racial genocide in the Posen speech, the precise words of which he had put in a footnote, where he had quoted Himmler saying: "The hard decision had to be taken to make this race disappear from earth." (34-9643, 9644) Irving continued: "... but I think I discussed on Friday, the reasons why I'm unhappy about the integrity of those two documents because of the remarkable fact that precisely at this point the typescript changes, a page appears to have been inserted by a different typist, the numeration of the pages changes from a typewritten page number at the top to a pencilled page number at the top, and there are various other indications about that speech that make me queasy. I don't accept that the text ..."

Pearson interjected: Are you now telling us that this is not a speech that Himmler delivered?

"I'm saying," replied Irving, "that the text of the speech, using the words that I just quoted as the text of the speech, is contained in the original archives...But examination of this text - examination of this script reveals the odd fact that precisely at that point the text has been tampered with." Irving could not speculate on when or by whom the text was tampered with. He had not listened to the sound recording of the speech which he understood was in the National Archives in Washington. Said Irving: "...I made the discovery at the time when I was writing my book on Field-Marshal Milch that some sound recording[s] of the Nuremberg trials, for example, were also not of integrity. They had been tampered with." Irving believed, however, that it would be improper for him to suggest that the sound recording of the Posen speech of Himmler had been tampered with without first listening to the speech. (34-9645)

Why did you raise the topic of some other speech at Nuremberg if you thought it was improper for you?, asked Pearson.

"You raised the topic of the sound recording at the National Archives and I said that I haven't heard it, but that I'm familiar with the fact that certain other recordings in the same archives are not of 100 percent integrity." Irving agreed it would be a good idea to listen to the sound recording, "but it would also be a good idea for the Holocaust historian to look at the original script and not just the printed text..." He continued: "I think that in connection with this brochure, this brochure was wrong to suggest that that speech, as it is known to us historians, contains no allusion to genocide...I'm also saying that the speech as known to historians has quite clearly been tampered with at that point, and I know of no reasonable explanation for why." (34-9646, 9647) Irving pointed out that what was contained in these pages "changes very much the essence of the speech, depending on whether it is an authentic transcript of the speech or whether that has been tampered with for some reason...I don't think we need to know the motives of people tampering with speeches. It is sufficient for historians to look at a document and say 'This document has been tampered with'; for him then to say, 'In that case, I must set it aside.'" (34-9647)

Doesn't he have to have some evidence before he does that?, asked Pearson.

"I think the evidence is what I mentioned," said Irving, "the fact that at that point in the script, the page relating that very damaging and incriminating sentence has quite clearly been retyped by a different typist on a different typewriter using different carbon paper, and that page has been numbered by pencil and inserted at that point." (34-9648)

Irving pointed out that the speech was about 70 or 80 pages of typed script: "You know this is a different page that has been inserted in an otherwise homogeneous script. One only notes it if one looks at the actual script in the archives or on microfilm, not from the printed text of course."

What are you suggesting by all this, sir?, asked Pearson.

"I'm suggesting that this is sufficient to make a reasonable mind hesitate to use this document rather in the same way as that partisan combatting report. You hesitate over that because, once again, there is a reason to suspect - "

Pearson interjected: It didn't stop you from using it in 1977, did it?

"I wasn't trying to prove a case," replied Irving. "I was writing a book about Adolf Hitler." The speech was quoted at length in his book because "It would be very, very irresponsible not to." (34-9649) Irving continued: "I'm suggesting I would hesitate before hanging a federal case on this particular page...I didn't 'hang it on a big bell' as the Germans said. To me, it was just one more [part] in the story." (34-9650)

Would you agree, asked Pearson, that if somebody like Professor Hilberg went and listened to the sound recording, they'd be in a better position than you to reach a conclusion with respect to the validity of the speech and the document?

"I would say that if he had taken the trouble to look at the original typed script, he would also be in a better position, but I'm the only person to have taken that trouble. As I said on Friday, I not only looked at the typed script, I looked at Heinrich Himmler's original handwritten note on the basis of which he delivered the speeches. I looked at the original typed script, the transcript, the final version of the typed script." (34-9651)

Do you have any reason to suggest that Professor Hilberg has not looked at the original typed speech?, asked Pearson.

"What if he has? He hasn't spotted this very obvious and glaring fact," said Irving. (34-9652)

Perhaps he doesn't think it's significant because perhaps he has checked with the sound recording and seen there is no difference. Those are possibilities, aren't they, sir?, asked Pearson.

Said Irving: "Everything is possible, but do you want to base your -"

Judge Ron Thomas interjected, stating that this was speculation since Irving hadn't read the book. Defence attorney Christie asked if the Crown was suggesting that this was in the book somewhere. Thomas replied: "Not that I heard." Christie again objected on the grounds that it was improper for the Crown to make submissions in their questions that they were not prepared to prove. Thomas said. "Thank you." Christie asked for a ruling on his objection. Thomas replied: "I have ruled on it." (34-9652)

Pearson returned to Hitler's War at page 575:

Against the fifty-one names were checks marking whether or not they had since read his speech or otherwise "taken cognizance of it". The shorthand record and magnetic recordings show that he did not yet claim to be acting on Hitler's orders. Himmler clearly considered his standing with the Führer impregnable, to admit so openly that he had disregarded Hitler's veto on liquidating the Jews all along. The same Gauleiters were Hitler's guests at the Wolf's Lair on October 7; from this point on, he could no longer logically plead ignorance of what his "faithful Heinrich" had done.

Irving testified that he had examined the shorthand record of transcripts of the magnetic recordings, but repeated that he had not listened to the recording itself. Irving pointed out that the suspect sentence, "The hard decision had to be taken to make this race disappear from earth," appeared on the suspect page, the one where the typing suddenly changed. (34-9653 to 9655)

"There must be a logical explanation why a page has been taken out of a script and retyped by somebody else at this point of all points," said Irving. "Nowhere else in the script, and...nowhere else in all of Himmler's other speeches - and he made a whole series of speeches week after week, month after month, always repeating the same old gramophone record of what he is doing and why, does this passage appear. It is unique." Irving testified that "from the way that the transcript at this point appears to have obtained an enhanced quality by virtue of the fact that it's been retyped and renumbered and inserted at this point, one begins to suspect that all this may have been said for a special reason. In other words, it may be another of these famous German 'camouflage' documents or statements that we were looking at an hour ago." (34-9657)

He continued: "I don't challenge that he may well have used these horrendous words, 'The hard decision had to be taken to make this race disappear from earth'...But for some reason, they were being spoken for a special reason because that page has, for some reason, been taken out and put in and retyped, that page of all pages, and he doesn't make this statement anywhere else when he's delivering almost identical speeches to...similar audiences." (34-9658)

Doesn't he start out his remarks on the Jews, asked Pearson, by saying that he was going to deal with a subject that must not be spoken of in public?

"He says this...kind of cautionary statement in very many speeches. I think there is something like ten or fifteen speeches that he delivered between 1942 and June 1944 to the same kind of high-level audience where very frequently he raises the same kind of matter, of what he is up to, with his famous task of consolidating Germandom in the east. But this is the only occasion where he makes this kind of statement, and it's the only occasion where this transcript has been tampered with." (34-9658, 9659)

Why would he be admitting to the extermination of Jews for camouflage purposes?, asked Pearson.

"We're now speculating," said Irving. "It may be that because he is talking to a party, political audience, that he is lighting a bonfire [under] them and saying: 'At least we're doing it. We're really carrying it out.' Who knows what his reasons for appearing to say something were?" Another possible interpretation was that he had done it: "He has carried out the job. He thinks the mission is complete and now is the time to broaden the responsibility among other generals. This is another possibility." (34-9659, 9660)

So he has carried out racial genocide, asked Pearson, and you admit that that's what he is talking about?

"This is a possibility that I contemplated in 1977 at the time that I believed and at the time that I wrote that book," said Irving.

Has that belief changed now?, asked Pearson.

"My belief has not changed that this particular page is a very suspect page. This particular remark by Himmler is a very suspect remark...can his statement be taken at face value? Because that is the only time he says it. This is the only time that this particular page in his speech has been tampered with. This is the kind of very detailed forensic examination that has to be applied to important speeches like this." (34-9660)

Pearson returned to Hitler's War on page 576:

To the SS generals on October 4, 1943, Himmler praised the toughness of those who had had to carry out the massacre: "This is a page of glory in our history which has never been written and is never to be written." To the Gauleiters two days later he referred to "the Jewish problem" as the most difficult he had handled. "The Jews must be exterminated," was easier said than done. Even where women and children were concerned he, Himmler, had opted for a clear solution. "I did not consider myself justified in exterminating the menfolk - that is to kill them or have them killed - while leaving their children to grow up and take vengeance on our sons and grandsons. The hard decision had to be taken to make this race disappear from earth." He could not have been more explicit as to his own responsibility.

Irving testified: "'The hard decision had to be taken to make this race disappear from earth', and yet he hasn't taken the decision, because at this very time millions upon millions of Jews are within the Nazi clutches and yet they are surviving; they are not being sent to extermination, firing squads or whatever. They are working in the factories or working in the fields. They are working in the labour camps. Millions and millions of them have survived the Second World War, and I'm glad for every single one. So here, he's apparently saying, 'I took the hard decision to make this race disappear from earth', and yet he didn't do it." (34-9662)

Irving repeated that he was unhappy because of the tampering which had occurred with this page of the transcript of the speech. He continued: "...this isn't just any page...I suppose it is probably the most important page of the most important speech in the whole of the Holocaust history, and this page, of all pages, when we look at it, turned out to have been tampered with." (34-9663)

Pearson read a note to page 575 found on page 879:

At one stage in his speech of October 6, 1943 - according to the wire-recording archived in Washington (NA, 242-299) - Himmler directly addressed himself to "You, Herr Reichsminister," which indicates that Speer was a listener. Few generals later admitted that they had known; perhaps they did not realize the enormity of what they were being told in such dry sentences. Field-Marshal Weichs frankly told interrogators of the U.S. Seventh Army on May 30, 1945, that Himmler had once visited him in the Balkans and confirmed that the rumors were true - that the (unspecified) victims were loaded into railroad trucks without knowing that a sudden, painless death awaited them. "They are just criminals of whom we must get rid ourselves," was Himmler's explanation.

Irving testified that he never heard the wire-recording, but had had a correspondence with Albert Speer regarding it: "...he told me that he had a transcript of the wire-recording which used those words. He sent me a number of affidavits relating to it." (34-9664)

With respect to the interrogation of Field-Marshal Weichs, Irving testified: "I think we have to look very carefully at that source and say this is a record written by an American NCO or sergeant of what an interpreter has told him that a Field-Marshal has told him that Himmler has told him. It is at sixth or seventh removed, so we can't really attach...too much weight to precise words here in a statement made after the war is over." (34-9665) He continued: "Mr. Pearson, I can help you by saying I can accept that that is an accurate report of what Himmler said. I don't think it is very important one way or the other." (34-9666)

Irving pointed out that the American government was also gassing criminals at this same time. Looking at the precise wording used, said Irving, "Weichs is saying that unspecified people, according to Himmler, were being sent to camps where they were being executed. This isn't what we're talking about in your specification of the Holocaust." Irving indicated that what Pearson had read was a footnote to a footnote, adding: "...I think that's about as much weight as can be assigned to it. Certainly, I gave it no more importance than that." (34-9667)

Pearson continued reading from Hitler's War at page 630:

The motives of Hitler and Himmler still diverged, though the Führer's attitude had noticeably hardened. Hitler was primarily concerned that this potential Fifth Column be removed from the Balkans...but Himmler - however much he protested that he was not just "bloodthirsty" - was eager to see what he called an "uncompromising," an irrevocable, and above all a Final Solution. When Hitler instructed him in April to provide two 100,000-strong contingents of Hungarian Jews to work on Saur's bombproof tank and fighter factories in the Protectorate and elsewhere, the Reichsführer SS expressed unconcealed displeasure at this "singular" arrangement.

Irving testified that Hungary had been invaded in March [1944], so that the Jews of Hungary were now within the German as opposed to the Hungarian government's clutches. Horthy did not proceed with the radicalism that the Germans expected from him, said Irving, in that he was not rounding the Jews up and locking them away. (34-9668)

Pearson suggested that Irving was saying that Himmler was interested in killing all the Jews of Hungary. Said Irving: "That is correct at the time I wrote that book." (34-9668)

Do you not now think that Himmler was interested in an "uncompromising, an irrevocable, and above all, a Final Solution"?, asked Pearson.

"Himmler, by 1944, had become a very different person. He was already negotiating with the Allied governments to ship Jews out of Hungary in...exchange for thousands of trucks, in exchange for cash, all sorts of scams that Himmler was operating...if he was purely concerned with the racial solution of liquidating every Jew from the face of the earth, he was allowing the bucket to leak in several places." (34-9669)

Pearson suggested that in the last sentence Irving was saying that Himmler was upset that he lost an opportunity to exterminate two 100,000-strong contingents of Jews.

"I think that here I put in a sentence speculating on what Himmler's feelings were. It's probably irresponsible speculation on the basis of evidence or beliefs in 1977." Irving continued: "I have to be frank and say that since I wrote this, which was in 1965 or 1966, I'm...no longer familiar now, twenty years later, with the documents that it's based on and I'm not in the position really to offer any constructive comment on that. I would have to look at the original documents again that I used." (34-9670)

Pearson continued reading at page 630:

In theory he might therefore have found the passage in Himmler's seventy-page speech of October 6, 1943, where he bluntly disclosed to Albert Speer and the Gauleiters that he, Himmler, had decided to murder Jewish women and children as well as adult males...On May 5, 1944, however, Himmler tried a new version - or adapted it to his audience of generals. After revealing in now stereotyped sentences that he had "uncompromisingly" solved the "Jewish problem" in Germany and the German-occupied countries, he added: "I am telling this to you as my comrades. We are all soldiers regardless of which uniform we wear. You can imagine how I felt executing this soldierly order issued to me, but I obediently complied and carried it out to the best of my convictions." Never before, and never after, did Himmler hint at a Führer Order; but there is reason to doubt he dared show this passage to his Führer.

Irving pointed out that there was a footnote to this passage which ought to be read, and he read it to the court:

Page 28 of the large-face typescript, containing this pregnant sentence - for only Hitler was empowered to issue a "soldierly order" to Himmler - was manifestly retyped and inserted in the transcript at a later date, as the different indenting shows.

"Another example of a document being tampered with," said Irving. "A reason which I speculate at here, that Himmler didn't want Hitler to see that he was actually putting the - passing the buck to Hitler. We keep on having to ask: How does a document come into existence, and why? That's a really good example." (34-9672)

Pearson continued reading from Hitler's War:

Consider too Himmler's speech of May 24, in which again speaking before generals he explained his stance somewhat differently. He recalled how in 1933 and 1934 he had thrown habitual criminals into concentration camps without trial, and boasted, "I must admit I have committed many such illegal acts in my time. But rest assured of this: I have resorted to these only when I felt that sound common-sense and the inner justice of a Germanic - and right-thinking - people were on my side." With this in mind Himmler had confronted the "Jewish problem" too: "It was solved uncompromisingly - on orders and at the dictate of sound common-sense."

Irving again pointed out that a further sentence and its footnote ought to be read:

One page later, Himmler's speech again hinted that Jewish women and children were also being liquidated.

The footnote read:

This page alone was also retyped and possibly inserted at a later date in the typescript.

Said Irving: "This is what I mean when I say that these transcripts of Himmler's speeches are very odd. Every time there is a real killing reference, in both senses of the word, that page has been retyped...my conclusion is that there is reason to suspect that this speech may have been, or the transcript may have been, put together for camouflage purposes." (34-9673, 9674)

Pearson continued reading from Hitler's War, page 631 - a speech by Hitler to his generals:

Of course, people can say, "Yes, but couldn't you have got out of it...more humanely?" My dear generals, we are fighting a battle of life and death. If our enemies are victorious in this struggle, the German people will be extirpated. The Bolsheviks will butcher millions upon millions of our intellectuals. Those who escape the bullet in the nape of the neck will be deported. The children of the upper classes will be taken away and got rid of. This entire bestiality has been organized by Jews. Today incendiary and other bombs are dropped on our cities although the enemy knows he is hitting just women and children. They are machine-gunning ordinary railroad trains, or farmers working in their fields. In one night in a city like Hamburg we lost over forty thousand women and children, burned to death. Expect nothing else from me, but that I do just what I think best suits the national interest and in the manner best serving the German nation.

(Prolonged loud applause).

Kindness here as indeed anywhere else would be just about the greatest cruelty to our own people. If the Jews are going to hate me, then at least I want to take advantage of that hatred.

(Murmurs of approval)

The advantage is this: now we have a cleanly organized nation, in which no outsider can interfere.

Look at the other countries...Hungary! The entire country subverted and rotten, Jews everywhere, Jews and still more Jews right up to the highest level, and the whole country covered by a continuous network of agents and spies waiting for the moment to strike, but fearing to do so in case a premature move on their part drew us in. Here too I intervened, and this problem is now going to be solved too. If I may say this: the Jews had as their program the extirpation [Ausrottung] of the German people. On September 1, 1939, I announced in the Reichstag, if any man believes he can extirpate the German nation in a world war, he is wrong; if Jewry really tries that, then the one that will be extirpated is Jewry itself.

(Spirited applause)

In Auschwitz, the defunct paraphernalia of death - idle since late 1943 - began to clank again as the first trainloads from Hungary arrived.

What "defunct paraphernalia of death" were you talking about?, asked Pearson.

"Well, my belief then was that Auschwitz had been a major extermination camp which ceased operation in late 1943 and resumed operation after the occupation of Hungary in the summer of 1944." (34-9676)

April 26, 1988

Pearson turned to page 883 of Hitler's War, where Irving had dealt with Himmler's views on Admiral Horthy's initial actions to stop the transports of the Jews out of Hungary:

Himmler's views are evident from his handwritten speech notes, e.g., for his speech to field commanders at Posen on January 26, 1944..."Jewish question. In the Generalgouvernement [Poland] huge calmdown since Jewish problem solved. - Racial struggle. - Total solution. - Don't let avengers arise to take revenge on our children."

Irving testified that he had looked at the actual handwritten notes made by Himmler and had transcribed them himself. The notes were the basis on which he delivered his speech. (34-9682, 9683)

Pearson suggested that the notes showed Himmler was talking about racial genocide.

"I am unhappy about your introduction recently of this word genocide...I think you really ought to be specific...if you use the word, I think you ought to define it. The word genocide doesn't occur in these notes. That's why I say that." Irving pointed out that the last sentence of the Himmler notes "is an echo of what he said in the earlier speech in Posen in October 1943, where he was explaining why they had had to kill women and children too." (34-9684)

Would you agree, asked Pearson, that he is going beyond talking about individual massacres, that he is talking about the solution to a racial struggle with respect to the Jews? Irving disagreed: "I am anxious not to try to read more into the notes than they actually portray. Trying to read between the lines and add things on has, I think, bedeviled the whole of the history of the Holocaust." (34-9684)

So, asked Pearson, unless Himmler had written 'we have subjected the Jews to racial genocide', you would not be prepared to admit that that is what he's talking about?

"Not in a matter as important as this," said Irving. "I believe I am right in saying that we don't actually have the text of the speech he made on that occasion and so I introduced just the handwritten notes for it. But I think, if I may repeat, that the whole of the history of the Holocaust, the writing of the history of the Holocaust has been bedeviled by eager historians trying to write things between the lines which aren't justified. I don't accuse Hilberg of that. I think Hilberg is very good. I've had a chance since yesterday to look at some of Hilberg's writing. If I may just say this, particularly on the case you introduced yesterday about the Roman Jews, and I've checked up on Hilberg's description of the expulsion of the Jews from Rome, the eight thousand that we were talking about yesterday, and Hilberg makes plain that in fact 1,007 Jews were finally expelled to Auschwitz. He doesn't say that they were killed there. He writes they were sent to the killing centre of Auschwitz and so in as much as Hilberg modifies what I said, I'm happy to accept his version of history...I am very impressed by the clinical precision of his language. He didn't say they were sent to Auschwitz and killed. He said they were sent to the killing centre at Auschwitz because Hilberg has also found no evidence that they were killed. He then writes two or three pages later of the total of seven thousand Jews deported from the whole of Italy, fewer than eight hundred returned to Italy. But he doesn't then look at the possibility that they may have been trans-shipped straight from the displaced persons camps to Palestine, for example. I think Hilberg is a very accurate and precise writer. He phrases his words very closely...I'm very impressed by the quality of his writing." (34-9684, 9685)

So when he says 5.1 million Jews were exterminated, that is the conclusion of a man who is conservative in his approach and precise?, asked Pearson. Irving replied that he "would like to know exactly what he said and how he phrased it." (34-9686)

Pearson turned next to the subject of the Wannsee Conference protocol and read an excerpt of Hilberg's translation from page 94 of his book Documents of Destruction:

In the course of the final solution, the Jews should be brought under appropriate direction in a suitable manner to the east for labor utilization. Separated by sex, the Jews capable of work will be led into these areas in large labor columns to build roads, whereby doubtless a large part will fall away through natural reduction.

The inevitable final remainder which doubtless constitutes the toughest element will have to be dealt with appropriately, since it represents a natural selection which upon liberation is to be regarded as a germ cell of a new Jewish development. (See the lesson of history.)

After Irving confirmed that this was an "acceptable translation," Pearson put to him that what this really said was what Himmler had said, that women and children would have to be killed to stop future avengers from taking revenge.

"It says nothing of the sort," said Irving. "There's no reference to women or children in that paragraph whatsoever. What they are saying there is that after those who have built roads until they drop, which is the phrase I use in the book and it's a very adequate description of the first paragraph, that they will build roads until they drop, the others, the ones who don't drop, the ones who are tough enough to survive - they're going to be a tough element and we're going to have to deal with them appropriately. There's not a hint as to what that appropriate dealing is...it could be locking away in a very secure prison camp somewhere. There's not a hint. You are beginning to read between the lines. I admire the skill with which you do it...What it does say is if we liberate them, they will be a germ cell so from that you can conclude that the alternative was going to be the choice chosen; they weren't going to be liberated...I am suggesting to you there are very many different ways of reading between the lines of that paragraph and I said I admire the ingenuity with which you try to read women and children into that paragraph and you try to read a massacre into that paragraph. It just isn't there. There are other alternatives." (34-9688, 9689)

Would you agree, asked Pearson, that it was ridiculous to suggest that the object of the Nazis would have been to create a new Jewish development of the toughest elements of the Jews?

"There is a strong Zionist element in the pre-war Nazi history," said Irving. "They sent Adolf Eichmann to Palestine to negotiate with the Zionist leaders about the Jewish immigration to Palestine. So there was certainly as at that time, there was an idea of sending the Jews out."

So are you suggesting, asked Pearson, that here they are talking about putting together through natural selection the germ cell of a new Jewish development?

"They are concerned a new germ cell will derive which, if liberated, will cause them, the Germans, problems." (34-9690)

If it's liberated by the Allies, for instance?, asked Pearson.

"If it's liberated by anybody...I can't see the words 'Allies' in there. I am reading clearly what the document said...The words here are 'which, upon liberation, is to be regarded as ... a germ cell of a new Jewish development'. But there is no explicit reference to solving that problem by liquidating this final remainder." (34-9690)

Would you agree that was Himmler's solution?, asked Pearson.

"I'm not certain who wrote this paragraph," said Irving. "I think we would have to know who is the author of this paragraph. I'm just putting it to you in my reply that there are other alternatives. I accept you can read the lines the way you do. Equally other people could read between the lines with alternative interpretations." Irving continued: "If I might just...mention that that effectively deals with the Wannsee protocol, this famous, notorious document upon [which] so much of the Holocaust history depends. There is nothing in it...it is a balloon which collapses." (34-9691, 9692)

Pearson returned to Hitler's War, page 645, regarding a speech by Himmler made in 1944 that may have been shown to Hitler. The speech:

...covered the familiar ground, though he no longer claimed to be murdering the Jews on Hitler's orders. He conceded that ("at most") fifty thousand Germans were now in concentration camps, including some fifteen thousand political prisoners. He asked for the generals' sympathy in having had to eliminate the Jews: Germany could not have withstood the bombing terror if the Jewish germ had remained, he argued, nor could the front line have been held east of Lemberg...if the big Jewish settlements had still existed in that city - or in Cracow, Lublin, and Warsaw. And using the familiar arguments he answered their unspoken question as to why the Jewish children had to be murdered too.

Irving testified that he did not dispute that Himmler said those things: "Very similar to his previous speeches. He's just going over the old familiar ground, answering their questions because of the questions that were on the minds of a lot of army generals at this time; they had seen the atrocities behind the lines; they wanted to know what the hell was going on." (34-9693)

And it's clear, suggested Pearson, that he was talking about eliminating the Jews as opposed to talking about ad hoc massacres.

"I would have to look again at the entire text of the speech if I was going to answer that question honestly. He certainly is talking about the elimination of the Jews which the German generals in his audience had been concerned about. There were a number of German generals at that time, like Field-Marshal von Weichs...who were concerned about what they had seen. So they had to have this kind of pep talk from the chief of the SS to explain the politics of it." (34-9693, 9694)

Pearson turned to page 660 of Hitler's War and asked Irving if at this page he was dealing with the Hungarian Jews and the fact that Hitler and Himmler were very interested in getting the Jews out of Hungary. Irving testified that it "was a security problem. They regarded Hungary as a major strategic security threat so long as it had a large Jewish element in the population." (34-9694)

Pearson read from page 660, where Irving explained why Horthy did not go along with it:

But now Himmler's ghastly secret was coming out, for two Slovak Jews had escaped from Auschwitz extermination camp, and their horrifying revelations were published in two reputable Swiss newspapers early in July. Horthy refused to deport the Jews from Budapest; instead, he announced that a general would bring Hitler a letter on July 21.

Do you repudiate what you wrote there?, asked Pearson.

"This is a very well-known report by two Slovak Jews who claimed to have been in Auschwitz camp...I have to use that wording...without being able to be too specific, because I haven't come prepared to answer questions on that Slovak report. I now understand that that report is open to some question...It is a very, very detailed report. A copy is in the Roosevelt Library. It came out to the United States and it has every appearance of being authentic." Irving testified that he had not talked to the two Slovak Jews in question. He stood by what he wrote about the report being published by two reputable Swiss newspapers. (34-9695)

And you'd agree, asked Pearson, that the Swiss were neutrals during the war?

"The Swiss were neutrals," replied Irving. "They had to accept whatever propaganda was fed to them by either side." (34-9696)

The report was one among other causes which had stopped Horthy from deporting the Jews. Said Irving: "Horthy certainly believed something was going on which he disapproved of...But having since written this book in 1977, I understand that that Slovak report is open to some question...over the last ten years I suppose I have heard on two or three occasions people say, oh, that report you must be careful of. We're not certain how it came into existence and what the motives were of the two Slovaks concerned." (34-9696)

Irving testified that during the war Hungary was a "very reluctant ally. They came and went. They came when there was something to pick up, like a piece of Czechoslovakia, and they went when there was any fighting to do. They came again then reluctantly in March 1944 when Hitler invaded them and his troops overran Hungary to reinforce and bolster...the sagging eastern front...It had its own government until October the 15th, 1944, when the Germans actually overthrew the Hungarian government and imposed their own regime." (34-9697)

Pearson suggested to Irving that the leader of Hungary was in a good position to know what was going on in Europe. Irving disagreed: "...as you know having read Hitler's War, my contention is even Adolf Hitler didn't know what was going on in Europe in every respect." (34-9697)

Pearson turned to Did Six Million Really Die?, page 24:

•  In the Federal Archives of Koblenz there is a directive of January 1943 from Himmler regarding such executions, stressing that "no brutality is to be allowed" (Manvell & Frankl, ibid, p. 312). Occasionally there was brutality, but such cases were immediately scrutinised by SS Judge Dr. Konrad Morgen of the Reich Criminal Police Office, whose job was to investigate irregularities at the various camps. Morgen himself prosecuted commander Koch of Buchenwald in 1943 for excesses at his camp, a trial to which the German public were invited. It is significant that Oswald Pohl, the administrator of the concentration camp system who was dealt with so harshly at Nuremberg, was in favour of the death penalty for Koch. In fact, the SS court did sentence Koch to death, but he was given the option of serving on the Russian front. Before he could do this, however, Prince Waldeck, the leader of the SS in the district, carried out his execution. This case is ample proof of the seriousness with which the SS regarded unnecessary brutality. Several SS court actions of this kind were conducted in the camps during the war to prevent excesses, and more than 800 cases were investigated before 1945. Morgen testified at Nuremberg that he discussed confidentially with hundreds of inmates the prevailing conditions in the camps. He found few that were undernourished except in the hospitals, and noted that the pace and achievement in compulsory labour by inmates was far lower than among German civilian workers.

Irving testified that he had not quoted the Himmler directive mentioned in the booklet; however, he was familiar with it: "It's a reference to ordinary, disciplinary executions inside institutions and concentration camps for whatever reason and Himmler had ordered there be no photographs and no brutality." (34-9699) Irving agreed that the directive had "nothing at all" to do with extermination, but later said: "I would modify my previous answer and say it was indirectly to do with the extermination controversy because it showed a certain squeamishness on Himmler's part. I think several historians have suggested that Himmler was personally squeamish." Irving added that he thought all brutality was unnecessary and that Harwood "obviously" didn't. (34-9700, 9702)

Would you agree, asked Pearson, that the passage in Did Six Million Really Die? was not an honest summary of Konrad Morgen's testimony?

"It is some fifteen years since I read Konrad Morgen's testimony and corresponded with him...But to the best of my recollection, it is a fair reflection of Morgen's testimony except in the detail. I am not sure that Koch was convicted of brutality. I have a feeling that the original indictment was in connection with fraud and embezzlement at the Buchenwald camp ... Certainly the impression I had from the Morgen testimony was that he found himself being drawn into a sink of iniquity, of SS inequity at camp level. He found that most extraordinary things were happening and that there was a lot of reluctance by higher-ups to allow him to investigate further and he ran into the usual kind of [obstruction]. He was obviously a very unusual and dedicated judicial inquirer. Having said that, I would once again say that this paragraph fairly reflects the essence of what the Konrad Morgen report was." (34-9702, 9703)

Pearson turned to page 718 of Hitler's War where Irving had dealt with Morgen's report:

In October 1944, Himmler ordered the extermination of the Jews to stop. What led to this order is uncertain. SS General Ernst Kaltenbrunner, chief of the Reich Main Security Office, stated in his closing speech to the Allied tribunal at Nuremberg two years later that he had received a stunning report from an investigating judge he had appointed in 1943 to prosecute corruption at top level in the concentration camp system: this lawyer, Dr. Konrad Morgen, had been drafted into the SS for the purpose, and his early inquires at Buchenwald convinced him that illegal murders of witnesses of the commandant's corrupt practices had occurred. Morgen had secured the execution of the commandant, Karl Koch, and eventually procured indictments in two hundred other cases. Late in 1943 he had realized that a systematic mass murder was proceeding at two camps - Auschwitz and Lublin. The commandant at Lublin, a former Stuttgart lawyer named Wirth, told him "they were destroying the Jews on the Führer's orders," and he was running altogether four extermination camps in the eastern Generalgouvernement of Poland, including Majdanek near Treblinka, in which five thousand Jews were themselves operating the machinery (before being systematically liquidated themselves). Shortly after telling him this, Morgen later reported, Wirth vanished from Lublin, having been instructed to raze his extermination camps to the ground. Late in 1943, he continued, while following up a major gold smuggling racket, he stumbled on the truth about Auschwitz, where one Rudolf Hoess was commandant. Believing at that time that Hitler himself had ordered all this, Morgen felt powerless to intervene. He began a merciless prosecution of the camp officials over the "lesser" murders, however - outside the general massacre program, hoping in this way to ventilate the whole issue. But an investigating judge sent to scrutinize the files of the Reich Main Security Office itself - under whose Departments IV and IVb the massacre had begun - found that no general order for the massacre had ever been received or issued. Morgen himself was the target of harassment; his staff's barracks were burned down one night, with all their files, but he fought on and eventually laid the dossier before Kaltenbrunner.

Kaltenbrunner stated (in August 1946) that he was "stunned by the report." He himself had been interested only in the Intelligence side of his office. He sent the document by special courier that October 1944 day to Hitler. Hitler sent for him in person the next day, and after a long discussion agreed to call Himmler and Oswald Pohl, chief of the concentration camps, to account for their actions. In Kaltenbrunner's presence - as he described at Nuremberg - the Führer ordered SS General Fegelein to ensure that Himmler reported to him immediately. (According to the manservant's register, Himmler came on October 17, and then again on November 7.) Hitler gave Kaltenbrunner his word, as they shook hands and parted, that he would put an immediate end to the massacre. (We have only Kaltenbrunner's account of all this; he himself was hanged at Nuremberg, and his widow possesses none of his personal papers which might have thrown light on the truth. Morgen, now a respected lawyer in Frankfurt, supports only part of the SS general's account, while motivated by an obvious and understandable antipathy toward him.)

The following scene, is, however, independently testified to. On October 27, 1944, news reports reached Hitler that the Russians claimed to have found a former concentration camp, Majdanek, near Lublin, at which 1,500,000 people had been liquidated; according to Heinz Lorenz, his press officer, Hitler angrily dismissed the reports as propaganda - just as German troops had been accused of "hacking off children's hands in Belgium" in 1914. When Ribbentrop pressed him for an answer, the Führer replied more revealingly, "That is Himmler's affair and his alone". He betrayed no flicker of emotion.

Is that what you wrote in 1977?, asked Pearson.

"Indeed. I don't think I would change a line of it. I think I built in all the necessary safeguards to point to the obvious inadequacies of the testimony." (34-9707)

Pearson asked Irving what he was referring to in the first sentence regarding the order by Himmler to stop the extermination of the Jews. Irving testified that he was referring "to the testimony of Kaltenbrunner at Nuremberg, where he in turn refers to the steps that he took after getting the reports from Konrad Morgen that these excesses were occurring in certain camps." (34-9704)

Was Kaltenbrunner lying?, asked Pearson.

"Since we took care of making sure he couldn't speak afterwards, it's difficult now to tell," said Irving. (34-9704) He continued: "I corresponded with Morgen, I visited the widow of Kaltenbrunner. I did everything I could to establish precisely what had happened...I was unhappy that the Allies had not made greater use of the man. Here's a man, Konrad Morgen, who investigated what you called the Holocaust. He investigated it. He was obviously a first- hand witness and yet the Allies made hardly any use of him whatsoever as a source." (34-9708)

Pearson put to Irving that Morgen's investigation led him to conclude that there were a number of extermination camps operating in Poland. Irving disagreed: "He didn't get to them. He got to some of the people who reported atrocities to him and from that he concluded that something extraordinary was going on. But when I corresponded with him, as I say in the book, he denied Kaltenbrunner's account of the story, but I thought again it was so important that the whole matter had to be ventilated in this book on Adolf Hitler...And Hitler himself dismissed it angrily and said this is just Allied propaganda." (34-9708)

Pearson pointed out that Irving had gone on to say in the book that the Führer had replied "more revealingly" to Ribbentrop.

"It is 'more revealingly' in connection with Adolf Hitler if we want to know what his own knowledge was of affairs, if he on repeated occasions brushed it away from himself and said all of this kind of thing is Himmler's pigeon. The buck stops with him. As we know, Himmler had been given the job for the consolidation of Germandom and he had been given the job of police security in rear areas and under that category fell the liquidation of Jews as partisan material. This was probably what was going through Hitler's mind when he said that." (34-9709)

Irving testified that he had a "very good" source for the exchange between Ribbentrop and Hitler and that his statement that "Hitler betrayed no flicker of emotion" probably came from the testimony given by Ribbentrop in the source that he had used.

What you are saying, suggested Pearson, is that Hitler was not surprised that 1.5 million people had been liquidated?

"If you read the paragraph closely, you'll see this is the Allied propaganda saying that 1.5 million people have been liquidated. This was among a number of very large similar claims put out by the British psychological warfare executive on the instructions of the British secret service. The gas chamber story originated in the British secret service. The psychological warfare executive and the files on that are now available in the British Public Records Office." (34-9710)

Irving agreed that Harwood should have mentioned that Morgen's investigations led him to conclude that there were extermination camps in Poland and that Harwood should then have examined the allegation. Irving believed Harwood should also have mentioned that the initial investigation was touched off by charges of corruption. (34-9711)

Pearson pointed out that Irving had described Morgen as a "respected" lawyer and asked whether Irving had any reason to doubt the honesty of what Morgen had told him.

Said Irving: "He is a lawyer. He is a very respected lawyer. He is obviously not eager to get caught up in this controversy. He is not anxious to have people recall that he was Heinrich Himmler's chief investigating judge. So, he would certainly temper his statements in the modern Federal Republic of Germany with an element of caution." (34-9711)

But his investigations, asked Pearson, had proceeded to the stage where he actually talked to the commandants?

"Yes," said Irving, "but here we must introduce an element of caution. What we are reading is a fourth or fifth-hand account. It is Kaltenbrunner relating what Morgen was told by Wirth about what he had heard...And Morgen in his correspondence with me was very cautious indeed. He was anxious not to confirm what Kaltenbrunner was saying...I very much regret that the Allies didn't interrogate Konrad Morgen in very much greater detail in 1945." (34-9712)

Pearson returned to Hitler's War, page 791:

As American troops advanced across Thuringia, Hitler was confronted with the problem of the concentration camps. Goering advised him to turn them over intact and under guard to the Western Allies, who would sort out the criminals from the foreign laborers and Russian prisoners, thus preventing hordes of embittered ex convicts from roaming the countryside and inflicting additional horrors on the law abiding. Hitler did not share Goering's trust in the enemy. Sitting casually on the edge of the map table after one war conference, he instructed Himmler's representative to ensure that all inmates were liquidated or evacuated before the camps were overrun.

"This was the testimony given to me by the SS Colonel Otto Günsche," said Irving, "...who was the colonel who subsequently had the task of burning the bodies of Hitler and Eva Braun. In my ten years working on Hitler, I went to very great lengths to persuade them to talk the truth to me and not just to tell me the attractive facets of his character, few though they were, but also all the ugly details. And when I asked each of Hitler's private staff in turn, and Günsche was his personal adjutant and bodyguard, what had been discussed at Hitler's headquarters about the killing of the Jews or concentration camp prisoners, instead of just saying, 'Mr. Irving, there was no such discussion', he said, 'Mr. Irving, I remember one episode only. Right at the end of the war, when Heinrich Himmler in Hitler's war conference said, 'Mein Führer, the American troops are advancing on Weimar. They are about to overrun a concentration camp' - I believe it must have been Buchenwald - 'What are your instructions about that camp? Should I evacuate the prisoners?' And Hitler said to Himmler, 'Herr Reichsführer, stay behind until the conference is over.' After the conference was over, according to Otto Günsche, who was the only eyewitness, Hitler said to Himmler, 'Make sure that all the prisoners are liquidated before the Americans overrun the camp, if they cannot be evacuated.' The second time I [had] Günsche tell the story to me, which was two or three years later as a check to see if his memory had changed, he added the sentence in Hitler's mouth, he said, 'Hitler said, Make sure that all the prisoners are liquidated if they cannot be evacuated. I don't want to think of these criminals being turned loose on the local German population.'" (34-9714)

Pearson turned to Did Six Million Really Die? at page 24:

•  The orderly situation prevailing in the German concentration camps slowly broke down in the last fearful months of 1945. The Red Cross Report of 1948 explains that the saturation bombing by the Allies paralysed the transport and communications system of the Reich, no food reached the camps and starvation claimed an increasing number of victims, both in prison camps and among the civilian population of Germany. This terrible situation was compounded in the camps both by great overcrowding and the consequent outbreak of typhus epidemics. Overcrowding occurred as a result of prisoners from the eastern camps such as Auschwitz being evacuated westward before the Russian advance; columns of such exhausted people arrived at several German camps such as Belsen and Buchenwald which had themselves reached a state of great hardship.

Wouldn't you agree, asked Pearson, that in talking about what was compounding a terrible situation, one would have to add Hitler's order that the prisoners be liquidated before the camps were overrun?

"I think it likely that Mr. Harwood was not aware of that particular order. But I think his description is a fair description except perhaps in detail. I am not aware of prisoners being evacuated westward from Auschwitz, but this may be my ignorance. Certainly concentration camps were evacuated where possible and the people who were brought back were often under conditions of great hardship because these columns of prisoners were ruthlessly attacked by Russian and British and American fighter planes, causing great casualties among the prisoners. And when they arrived in the camps like Bergen-Belsen and Buchenwald, which had been relatively well-organized until the closing weeks and months of the war, great chaos then did set in and the chaos was unfortunately compounded by our Operation Clarion which was the ruthless bombing of all the communications networks in January and February 1945, and by our saturation bombing of the German cities, including the pharmaceutical factories, so that by March, 1945, there had been a complete collapse of the provision of medications and the necessary medicines to prevent the outbreak of epidemics." (34-9716)

But, said Pearson, you testified that if they couldn't be evacuated, Hitler ordered that they be liquidated?

"As a security measure in this one camp, Buchenwald, which was not a Jewish concentration camp as such, it was a regular - I know we English call it an internment camp - containing all sorts of political prisoners, religious prisoners and enemies of the regime," said Irving. (34-9717)

Pearson asked if people who had things to sell with respect to memoirs, diaries of the Second World War often went to him.

"As an expert," said Irving, "the publishers come to me and ask me for value judgments on the material or the people possessing the material come to me and ask me for information on a good profitable market to sell it in." Irving testified that he himself "very seldom" purchased records: "I think I can recall only two episodes. I once bought a diary for twenty-five pounds of a naval officer and I paid five thousand pounds to rent Churchill's stolen desk diaries from the man who stole them, his bodyguard." (34-9721, 9722)

Pearson asked Irving to explain the manner in which he was approached with respect to the Eichmann tapes. Irving testified that he received a letter from the son of Adolf Eichmann, by the name of Klaus. This was the name printed on the letterhead and he introduced himself in the letter as being the son of Adolf Eichmann. Said Irving: "And he announced that he had the tapes which his father had already recorded in the years prior to his kidnapping by the Israelis and that these had never been published and that he was anxious to see they should be published and that there was a problem - I have to say quite fairly - inasmuch as the tapes might be held to damage the right-wing cause, if I can put it as simply as that...I would just say that if one was to hope that...the tapes by Adolf Eichmann would be a total denial, then these hopes would be disappointed." (34-9723)

Irving agreed that there were neo-Nazi groups who hoped for such material to surface. He continued: "So I then contacted one or two reputable publishers and I put this material to them as a project without being able to enclose the actual material, which I emphasize I have never handled. I just said that I had learned that Eichmann's unpublished memoirs did exist. Clearly they had an enormous evidentiary value depending on how honest Eichmann was. Having not looked at it, I couldn't judge, of course. And I left it at that. A number of publishers then came forward and took up direct contact with the son and I was interested to see that the American publishers made no effort to publish the book at all, so clearly it wasn't considered to be as helpful as they had hoped...The German publishers did publish it. I believe it is a right-wing publishing house. Yes, a right-wing publishing house published it in Germany and it was published in the Spanish language as well." (34-9724)

Pearson referred to Did Six Million Really Die? at page 20:

•  Strangely enough, the alleged "memoirs" of Adolf Eichmann suddenly appeared at the time of his abduction to Israel. They were uncritically published by the American Life magazine (November 28th, December 5th, 1960), and were supposed to have been given by Eichmann to a journalist in the Argentine shortly before his capture...

Said Irving: "I remember reading that and thinking to myself, I wonder if this was the same as the book but then I formed the impression that it probably wasn't because I am familiar with American newspaper methods of inventing interviews with people whom they've never seen." Irving testified that he had never heard of a live interview with Adolf Eichmann. (34-9725)

Pearson produced a copy of Adolf Hitler's last testament. Irving testified that he was familiar with the document: "There were seven versions of the political testament. Three were originally typed by his secretary, Traudl Junge, and four more copies were made by Martin Bormann on the following day." (34-9730) At Pearson's request, Irving translated two paragraphs of the testament:

Three days before the outbreak of the German-Polish war, I suggested to the British ambassador in Berlin a solution of the German-Polish problem, similar to the solution adopted in the case of the Saarland, putting it under international control. This offer cannot be denied either. It was only rejected because the authoritative circles of the British high policies wanted war partly because of the business deals they hoped to make out of it, and partly driven on by a propaganda campaign organized by international Jewry.

But nor did I leave anybody in any doubt that if the nations of Europe were once more...regarded just as a kind of bundle of stocks and shares in the hands of these international gold dealers and financial conspirators, then this race, this folk would also be called to account. The race which are the real culprits in this murderous struggle: the Jews or Jewry! Nor, moreover, did I leave any doubt that this time it would not be millions of children of Europeans of the Aryan races who would be starving, not only millions of adult men would be suffering death and not only hundreds of thousands of women and children would be...burned to death in the towns and cities without the real culprits having to pay the penalty, even if by far more humane means.

Irving testified that the culprits, the international Jews, were going to have to pay the penalty for having started this murderous struggle: "He says this was going to happen." (34-9732) Pearson began to move on to other subjects. Irving interjected: "I'm sorry, are you going to ask me to comment on the testament or just use me as a translator on those, because I would have wanted to comment on the fact that all he is saying is that the Jews are going to suffer but in a far more humane way than the millions of people who died in the air raids." Irving continued: "He actually says it. He says 'in a far more humane way.' Humane - you can't challenge the translation of that word. He is not explicit. He is not saying I have arranged that they would be killed. He is...just saying I'm going to make them pay." (34-9733)

There's no way he could have been saying that it's less painful to be gassed to death than to burn to death in bombing?, asked Pearson.

"I'm sorry you asked me that question because when I interviewed a marshal of the Royal Air Force, Sir Arthur Harris, many years ago in 1962, and he was the commander-in-chief of RAF Commander bombers, and I asked him why he hadn't bombed Auschwitz. His reply was, 'Mr. Irving, if I was a concentration camp prisoner, I would prefer to die from gas than to be burned alive by an incendiary bomb,' which was the fate of two million people in Europe in the 1940s." (34-9734)

So Air Marshal Harris may have been saying the same thing as Adolf Hitler?, asked Pearson.

"No," said Irving. "Hitler's actual words were he had predicted that he would make the Jews pay the penalty but in a far more humane way than the millions who had died in the air raids...Harris is talking about gassing and Hitler is not talking about gassing, he is talking about a humane way which can equally be deporting or a geographical location, throwing them out of [Germany] lock, stock and barrel. What happened to the Jews isn't humane...on any score." (34-9734)

Have you read the memoirs of the commandant of Auschwitz, Rudolf Hoess?, asked Pearson.

"I haven't because I understand that these memoirs are very suspect and I considered it unnecessary to the work I was...doing on Adolf Hitler," said Irving.

Before he radically changed his view of what went on in Auschwitz, didn't he think it would be of assistance to read the memoirs?, asked Pearson.

"If I had had a document I was satisfied was the genuine memoirs signed at the end in affidavit form by a man saying 'I have made this statement under no kind of coercion whatever,' then I think perhaps I would attach some importance to it but as I understand it, the memoirs of Rudolf Hoess were extracted in a rather more painful surgery." (34-9735) Irving testified that he had read "quite a bit how various prisoners were interrogated in the post-war years...It is quite easy to be psychologically coerced; you can have promises made to you, threats made to you." (34-9736)

What kind of psychological coercion was used against Rudolf Hoess?, asked Pearson.

"I'm not going to be specific about that because I would be taking from a memory that is twenty years old," replied Irving. "All I can say is I was unwilling to use the Hoess memoirs because I was satisfied that in doing so I was introducing a probable element of uncertainty." Irving had not read the Nuremberg trial testimony of Hoess: "My view was that when you only have one given life span and one doesn't have a vast team of researchers working, you have to use your reading and researching time at the most profitable and efficient level which in my case was looking at the original wartime documents in the archives and my feeling was that if you did enough work on those, then you would do without using the post-war testimony of people like Hoess which was bound to be suspect." (34-9737)

Pearson produced a document from the National Archives of the United States, Nuremberg Document NO-4473, being a letter from the chief of the Central Construction Management, Auschwitz to SS Major-General Kammler, WVHA, in Berlin, dated January 29, 1943. (34-9738; filed as Exh. 155 at 34-9747)

Irving testified that he was familiar with the document and had no reason to question its authenticity, although the providence of the document was not clear from the Nuremberg Staff Evidence Analysis Sheet attached to it. Irving explained that staff evidence analysis sheets were attached to exhibits at the Nuremberg trial. The purpose of the sheet was to inform where the document had been found. (34 9739)

Pearson read the document to the court:

The crematorium II has been completed (save for some minor constructional work) by the use of all the forces available, in spite of unspeakable difficulties and the severe cold, in 24 hours-shifts. The fires were started in the ovens in the presence of Oberingenieur Prüfer, the representative of the contractors, the firm of Topf & Söhne, Erfurt and they are working most satisfactorily. The planks from the concrete ceiling of the cellar used as a mortuary (Leichenkeller) could not yet be removed on account of the frost. It is, however, not very important, as the gazchamber (gassing cellar) can be used for that purpose.

The firm of Topf & Söhne was not able to start in time deliveries of the installation for aeration and ventilation as had been requested by the Central Building Management because of restrictions in the use of railroad-cars. As soon as the installation for aeration and ventilation arrives the installing will start so that the complete installation may be expected to be ready for use by 20 February, 1943.

We enclose a report of the testing engineers of the firm of Topf & Söhne, Erfurt.

Irving testified that the word vergasungskeller, which had been translated as "gas chamber" should have been translated to mean a carbonization process in some kind of oil fire heater. By translating the word as gas chamber, said Irving, "it is giving possibly a deliberately wrong translation of the word. It is a possible translation but it is an unlikely translation because if a German was going to write the word 'gas chamber', he would not write vergasungskeller. He would write [gaskammer]."3 (34-9741) Irving agreed that the translator had added the alternative translation of 'gassing-cellar' but pointed out that no Englishman would use the term 'gassing-cellar'. (34-9741) Said Irving: "We need to know more from the context of that document. We would need more from the documents of this file. I would like to see the blueprint of the Crematorium II to see what the vergasungskeller was and see what pipe work went between the vergasungskeller and the crematory because that would answer all my questions." (34-9741)

Irving pointed out that the translation had also incorrectly used the word 'fires.' The German word used was the plural of oven or furnaces. The correct translation was therefore 'the furnaces were fired up', not 'the fires were started in the ovens.' (34-9742)

Irving also pointed out that Pearson had failed to read the first line of the letter which Irving translated as:

Re: Krematorium No. II, construction status

Said Irving: "In other words, this entire document refers to Krematorium No. II, not to any other building or any other installation. Purely to the crematorium. I think that needs possibly to be underlined. I think this justifies me in suggesting that if we're looking for which of the alternative translations to look for...this key word underlined here, vergasungskeller, it is some piece of equipment to do with a crematorium process and not to do with any other process." (34-9744)

Pearson returned to a review of Hitler's War written by Hugh Trevor-Roper which appeared in the Sunday Times Weekly on June 12, 1977, and read excerpts to the court:

Mr. Irving's essential point is that it is "hard to establish a documentary link" between Hitler and the extermination programme. This is certainly true. That whole programme was veiled in secrecy and carried out at a safe distance. Himmler himself explicitly forbade all discussion of it, and, if it had to be mentioned, it was always disguised as "resettlement" or "transport to the east." Therefore we should not expect it to appear openly in formal documents. Indeed, it is because of this official silence that our new anti-semites brazenly declare that the Jews were not exterminated at all. For the same reason, Hitler's notorious "commissar order" (whose authenticity Mr. Irving does not dispute) does not survive in documentary form.

Irving testified that he had reflected on this criticism after reading the review: "It is an opinion. Different historians have different opinions. I would have pointed out to him that all Hitler's other very many crimes are dealt with in some detail in the archives and can be proved on the basis of archival documents and yet this is supposed to have been the biggest crime of all and there is a sudden lack of any...comparable documents." (34-9748)

Irving agreed that he did not dispute the commissar order but pointed out that Trevor-Roper was wrong in saying that the order did not survive. Said Irving: "The commissar order exists in the files of the German High Command as dictated by Hitler to Colonel General Alfred Jodl." This was the order which specified that all "the Soviet commissars who were principally, in my understanding, Jews, were to be liquidated on the field of battle." This was the order under which the Einsatzgruppen operated and was issued one month before the Soviet invasion, in May of 1941. (34-9748, 9749)

Pearson continued reading from the review:

However, a historian must not only read the official documents: he must also look behind them. I believe that, if we do this, Hitler's responsibility for the policy is clear.

Of course the extermination was carried out by Himmler's SS. But could Himmler have mounted so vast a programme without Hitler's authority?

Had Irving reflected on that point?, asked Pearson. Irving replied that Trevor-Roper was "asking a question and...is virtually doing in that article what you have spent three days in doing which is reading between the lines because there is no evidence. After forty years, we're entitled to expect evidence." (34-9750)

Pearson continued reading:

Did he not always insist that the SS was built on the basis of unquestioning obedience to the Führer? He explicitly claimed Hitler's authority for the action, and although, in documents written for Hitler, the references may have been muted or expunged, that is explicable by the public pretence.

Said Irving: "I would challenge his statement earlier in that sentence where he says he explicitly made reference to Hitler, to his authority from Hitler in carrying out the operation." Irving testified that the speeches of Himmler where he said 'This is why I have had to take this severe decision' was more evidence that Himmler was "very much acting on his own when he carries out these isolated atrocities." He continued: "...from...October 1943, when Himmler broke the secret to his generals of what he had been doing, from that moment on Hitler has no excuse not to have known because those same people trooped in to see him the next day. This again is a long way short of proving that he did know." Irving pointed out that Himmler used circumlocutions but was never specific: "...and this is the tragedy. The whole way through with the tens of thousands of tons of documents, there's no one specific line which would help us." (34-9751, 9752)

Pearson continued reading:

It is quite unnecessary to suppose that the whole policy was a "violation of Hitler's orders" and that Himmler used the conventional euphemisms of "re-settlement" and "transport to the East" in order "to pull the wool over Hitler's eyes." Hitler (as Mr. Irving often reminds us) had an extraordinary grasp of the details of his war, and since his anti-semitism was essential to his ideology, it is unlikely that he totally ignored that sector of it.

Would you agree, asked Pearson, that Hitler made public statements which reflected his anti-semitism?

"Indeed," said Irving, "and I have drawn attention to the strange paradox that he makes these public statements and yet every one of the dozen or so documents directly linking Hitler with again, what you call elements of the genocide, show him putting out his hand to stop something ugly happening to the Jews. The Roman case we were looking at yesterday. That specific other case of the transport of Jews from Berlin to Riga. He evidently tells Himmler they are not to be liquidated. Every specific document linking Hitler with the Jewish question is him intervening to say postpone it until the war is over, don't liquidate them, I don't want them liquidated in northern Italy, I want them kept alive as hostages." (34-9752)

Sir, is it your position Hitler was a friend of the Jews in the war?, asked Pearson.

"Mr. Pearson, you are again trying to give the newspapers quotes for tomorrow morning," said Irving. "I don't think this is what this court action is about. I would, to answer your question...say without the tragedy of the Third Reich, the state of Israel would probably not exist and in that respect he was doing the Jewish nation a favour." (34-9753)

Pearson continued reading:

Moreover, the extermination was not a private secret of the SS. It was well known, though not discussed, at Hitler's court. Goering, Goebbels, Keitel showed that they knew it.

Irving testified that he did not agree with this statement: "Goering showed no knowledge whatsoever of the genocide as you describe it. Goebbels showed limited knowledge of it in his diaries but now that his entire diaries have become available to us that weren't available in 1977...[w]e see his ignorance was as profound as that of the rest of us. Keitel appears to be largely in the dark. I know of no document showing that Keitel was aware of anything approaching what you describe as the genocide or the Holocaust." (34-9754)

So Hugh Trevor-Roper is misleading us here?, asked Pearson.

"He's misleading us on that," replied Irving. "I think he is writing off the top of his head and at that time, 1977, he was among the believers."

Pearson continued reading:

The euthanasia programme, which trained the personnel for it, had originated in the Führer's Chancellery.

Do you deny there was a euthanasia programme in Nazi Germany?, asked Pearson.

"I don't," replied Irving. "I don't deny that at all. The euthanasia programme went under the code name T-4...from which it operated...under the control of Philipp Bouhler...who was the head of the Führer's Chancellery, but that was a building, an office, an agency in Berlin and Hitler was operating from his field headquarters in East Prussia...I think it's specious to suggest the title is the Führer's Chancellery, therefore it was Hitler's programme." (34-9754, 9755)

How many people were killed by the euthanasia programme?, asked Pearson.

"About 50,000 people, as many as in one small British air raid," said Irving.

Pearson continued reading:

The breath of the courtiers may have been bated, but the whisper can still be heard. In his diary, on March 27, 1942 - that is soon after the famous Wannsee Conference which had launched the full programme of extermination - Goebbels gave what Mr. Irving calls a "frank summary" of "the ghastly secrets of Auschwitz and Treblinka." Mr. Irving explicitly refers to this entry in the course of his argument, but he forbears to cite Goebbels' words. I therefore supply his omission. "It is a pretty barbarous business," Goebbels wrote, "and it is best not to mention details," but the Jews had asked for it. Now the Führer's threat of "annihilation" was to be realised "in the most dreadful manner. We must not be sentimental in these matters...it is war to the death between the Aryan race and the Jewish bacillus...Here too the Führer is the inflexible champion of a radical solution."

Are you suggesting there is no reference to death in there?, asked Pearson.

"I am suggesting this is typical of Goebbels shooting off his mouth. It's a radical solution if I am a Jewish family living in Berlin [and] in the middle of the night somebody comes along and says, 'Out, there's a truck waiting downstairs,' you're going to be shipped off to the east, God knows what happens to you, you're going to work until you drop; that's a radical solution." (34-9756)

Isn't that reading between the lines, sir?, asked Pearson. Said Irving: "No, sir. I am entitled to draw that inference from that entry as you are to draw the inference that Goebbels is talking about the 'Holocaust', 'genocide', racial mass murder, the killing of 6 million people. We need something far more explicit than that and surely we are entitled to it after forty years, and tens of thousands of tons of documents. They're all available to us and you can't help us." (34-9757)

Pearson continued reading:

Against this explicit evidence what does Mr. Irving offer? At least four times he refers to a brief note of a telephone-call which Himmler made from Hitler's headquarters on November 30, 1941 - i.e. before the Wannsee Conference. Himmler then told his henchmen, Reinhard Heydrich, the "Protector" of Bohemia, that there was to be "no liquidation" of a transport of Jews from Berlin. Mr. Irving prints a photograph of this note, which he represents as a general veto on the liquidation of Jews. To me, it bears no such implications. Specifically, it refers only to a particular convoy, which is not to be liquidated - at least not yet. Generally speaking, one does not veto an action unless one thinks that it is otherwise likely to occur.

Would you agree, asked Pearson, that in your book you do suggest that that order from Hitler was a general order?

"Taken in conjunction with all the other documents that I referred to, yes. It's part of a chain of evidence and if I may just amplify on that, you've just quoted the Goebbels entry to us of March the 27th, 1942, which I described as Mr. Goebbels himself shooting off his mouth. At precisely the same time as that document, of much greater evidentiary value, there is a telephone call from the chief of the Reich Chancellery to the Minister of Justice saying, and I quote: 'The Führer has repeatedly said he wants the solution of the Jewish problem postponed until after the war is over.' How do you climb out of that one, Mr. Pearson." (34-9758)

Pearson continued reading:

Mr. Irving's argument about the Jews typifies his greatest weakness as a historian. Here, as in the Sikorski affair, he seizes on a small and dubious particle of "evidence"; builds upon it, by private interpretation, a large general conclusion; and then overlooks or re-interprets the more substantial evidence and probability against it. Since this defective method is invariably used to excuse Hitler or the Nazis and to damage their opponents, we may reasonably speak of a consistent bias, unconsciously distorting the evidence.

"I wouldn't accept the word distorting," said Irving. "I am quite prepared to be accused of bias. I think every historian has the arrogance to believe that his opinion is better than that of his rivals. And I believe that my opinion was better having done the research among Hitler's staff and among Hitler's documents that Hugh Trevor-Roper and Alan Bullock and the other Hitler historians had not done. Therefore I felt I was entitled to change opinions at that point." (34-9759)

Pearson pointed out that Irving had acknowledged Trevor-Roper in his book as exceptional. Irving agreed: "He's very good but we are referring there to his book called The Last Days of Adolf Hitler and I don't challenge his account of the last days of Adolf Hitler except in unimportant detail." (34-9760)

Do you agree, asked Pearson, that in your latest book, Churchill's War, you suggest that during his period out of power, Churchill fell under the influence of Jewish moneylenders?

"This is approximately one page in about 300 pages describing that period," said Irving. "We are looking at the very interesting question how a Member of Parliament, Winston Churchill, with no government office whatever and a 500 pound per annum salary is able to maintain himself in considerable luxury, support a very large household, private and secretarial staff, and do this with no visible means of support. And I then built up from various sources, including the Czechoslovakian government archives, the archives of Chaim Weizmann in Israel, the captured records of the French and other governments, I then built up a picture of where Mr. Churchill's money had come from, which I considered to be germane to a Winston Churchill biography." (34-9760, 9761)

And then you say that war starts and Hitler makes overtures for peace to Churchill which Churchill refuses, suggested Pearson.

"Not quite as simple as that. Hitler had made very many offers of peace, usually just after he secured a major military victory, and Winston Churchill secured increasingly from June 1940 onwards the refusal of these peace offers by one means or another. It was extremely urgent for him to do so because by that time, half the British people wanted peace - particularly the working classes - and if peace had broken out in the summer of 1940, Winston Churchill would have been finished as Prime Minister. So he used various techniques to prolong the war."

So, asked Pearson, it's your thesis that to avoid peace breaking out and him losing office he prolonged the war and part of the reason why he didn't agree to the overtures of peace was the influence that Jews exerted on him?

"No, sir," said Irving. "I haven't expressed that view in the book at all but in volume two which is...in the process of production, we do come to the extraordinary meeting between Chaim Weizmann, the leader of [the] world Zionist movement, and the first president of the state of Israel, and I remind you I have had private access, privileged access to Weizmann's papers, and there was a meeting between Weizmann and Mr. Churchill in September 1941, when Churchill was very keen to drag the United States into his war and Weizmann used to him the words which he records in his own handwriting: 'We managed to bring the United States into the First World War and if you tow our line over Palestine and the Jewish fighting force, then we can persuade the Jews of the United States to drag the United States into it again this time', which I find an extraordinary document, frankly, and I am very, very anxious about how to present this in a balanced historical review and it's typical of the problems which confront me as an honest biographer." (34-9762)

What do you say about Churchill's American roots?, asked Pearson.

"He was half-American...I refer to the fact that he was not a man of the British Empire at all. He put the British Empire second," said Irving. He pointed out that when Churchill first met President Roosevelt in August 1941, almost in Canadian waters off the coast of Newfoundland, he didn't tell Canadian Prime Minister Mackenzie King that he was coming. "The Canadian government found out by code-breaking that Churchill and Roosevelt were meeting in Canadian waters. This was the respect that Churchill had for the Great Dominion leaders who were helping him in his war." (34-9763)

And you state that Churchill conducted most of his war in a drunken state?, asked Pearson.

"I wouldn't go so far as to agree with you on that, Mr. Pearson," said Irving. "The diaries of some of Churchill's cabinet ministers, the diaries of some of his officers when he was First Lord of the Admiralty reveal that Churchill repeatedly attended Admiralty meetings or cabinet meetings in a state of intoxication. For example, on July the 6th, 1944, the diary of the Chief of Naval Staff, Admiral Cunningham, reveals that Churchill arrived at the cabinet meeting in a state of drunkenness. We know from the cabinet records that on this occasion, Churchill issued the criminal order for the launching of poison gas warfare on German cities." (34-9763)

And it's your position, asked Pearson, that if Churchill had acceded to the peace overtures of Adolf Hitler, the British Empire may have survived and that would have been the best thing for the British Empire?

Irving replied: "If the peace offers had been accepted in June 1940, we can speculate on how the world would have been different today. Two million people killed in bombing would have survived. The millions of people who were suffering in the various massacres of the Second World War would also not have died. However many people were killed because they were Jews...whether it was 100,000 or a million, whatever the figure we choose, they would also in all probability not have been killed. The great cities of Europe would not have been destroyed. Britain and her Empire would not have been bankrupted." (34-9764)

Pearson suggested to Irving that his thesis was the same as one Hitler had presented in one of his last conversations where he said, 'If fate had granted to an aging and enfeebled Britain a new Pitt instead of this Jew-ridden, half-American drunkard, the new Pitt would have at once recognized that Britain allied to a united Europe would still have retained the chance of being able to play the arbiter in world affairs, but I underestimated the power of Jewish domination over Churchill's England.' (34-9764) In response to Irving's query, Pearson revealed that he had obtained this quotation from an article in the Sydney Morning Herald of October 9, 1987 by John Foster, a historian at the University of Melbourne. (34-9765)

Said Irving: "He doesn't give the source? I can give you the source. It's from the so called bunker conversations of Adolf Hitler. I mentioned that because these bunker conversations of Adolf Hitler conducted in allegedly February 1945 and in April 1945 were, in fact, the product of the brain of a Swiss lawyer - I'm sorry to keep on dragging lawyers into this - but I won't mention his name, quite simply because he is still a very active Swiss lawyer. He himself concocted these documents in the 1950s. They have no historical value whatsoever." (34-9765)

So, you deny that that was Hitler's view of Churchill, that he was a drunkard?, asked Pearson.

"He regarded Churchill and repeatedly described him as a 'drunken poltroon'," said Irving. "Roosevelt also described Churchill as 'that drunken bum', so Hitler wasn't alone in describing Churchill in those words."

Irving agreed with Pearson that Hitler often said that Churchill or Britain were being dominated by the Jews. (34-9766) I suggest, said Pearson, that you have written a biography of Winston Churchill that Hitler would have written.

"Not from every respect. We find out from the Weizmann papers, although Churchill describes himself as a Zionist admirer, he gave the Jews a run-around. He didn't concede to all their claims and Weizmann was a very disappointed man at the end of the Second World War." He continued: "I am not surprised that both Hitler and I came across the same basic truths. Hitler himself said even a blind hen occasionally picks up a grain of corn." (34-9767)

Pearson produced a review of Hitler's War written by Professor Walter Laqueur of the Georgetown University Centre for Strategic and International Studies which appeared in the New York Times Book Review on April 3, 1977 and read excerpts to the court:

The reasons for this book's shortcomings lie deep. Mr. Irving may have out-grown the eccentric political views of his earlier years...when he criticised his native country for lining up with the Bolsheviks in a fight against the first great unifying force (meaning Nazi Germany) Europe had known in 600 years..."Hitler's War"... reads like the plea of an advocate who knows from the very beginning what he intends to prove and who marshals his evidence to this end relentlessly and with an enthusiasm worthy of a better cause. The result is a book of value to a few dozen military historians capable of separating new facts from old fiction, of differentiating between fresh, documentary material and unsupported claims, distortions and sheer fantasies.

Irving pointed out that Laqueur was better-known as the director of the Wiener Library, which was a wartime and post-war Jewish propaganda library: "...a very, very good library but I think we have to know what his colours are..." Irving testified that he had read the review and commented that Laqueur "will be sorry to hear that my book is required reading in universities around the world including West Point in the United States and the United States Military Academy at Carlyle." (34-9768)

Pearson next quoted from a 1959 edition of a satirical publication called Carnival Times from Imperial College. Irving, then a student at the collage and editor of the magazine, had written in an editorial:

The organs of the National Press owned by Jews are acting in the same way. The formation of a European Union is interpreted as an attempt at building a group of superior peoples and the Jews have always viewed with suspicion the emergence of any 'master race' (other than their own, of course)...Why, little Germany by herself under the direction of Herr Hitler nearly succeeded in subjugating the combined might of the Union of Soviet Socialist Republics. Perhaps if, at the same time, he was not being attacked by the whole of the rest of the world, he might have succeeded.4

Irving testified that the publication was "satirical...If I had known [you were] going to refer to it I would have brought it. You would have seen immediately what kind of satirical magazine it was. I don't think you would seriously quote sentences out of it to a learned court of law." (34-9769) He continued: "...the essence of satire is that in every sentence there is a lot of wicked truth and a lot of blatant, obvious untruth...I have just said to you the magazine was a satirical magazine. The next article after that was called 'Christopher Robin and the Facts'. I hope you're not going to read out of that one to us." (34-9770)

I'm going to stay on the one with respect to the European union, said Pearson. He asked Irving to explain the satire.

"Student satire written thirty years ago," said Irving. "If you have nothing more recent than thirty years ago with which to smear me, I think this in itself is a statement of the case...I think that what I am saying there and what I say now...if we had left the Soviet Union and Germany to fight it out between themselves, if Hitler and Stalin had been fighting it out between themselves, to this day it couldn't have happened to two nicer people...They were both gangsters." Irving agreed that Hitler and Stalin were on the same side at the beginning, "[t]hen we put one of the gangsters on our side which is what the satire in my article is about." (34-9773)

Pearson asked Irving to explain what his publication Focal Point was about. Irving testified that Focal Point was published around 1981 or 1982 and was a publication "produced by a small group around me called the Focus, and we were aiming to attract the support of particularly university students, people with an intelligent background." (34-9773)

Irving agreed that he was a "dissident historian...I don't like the term revisionist historian as put in the mouths of my enemies. They sullied the word revisionism as if history doesn't need to be revised. History needs to be revised; every historian needs to revise his own histories from time-to-time." (34-9774)

And in 1980, asked Pearson, when you formed this group called the Focus had you had a change of heart with respect to the Holocaust?

"I think it's difficult to be precise where between 1977, when my Hitler book was published, and the present date, the change of heart occurred. I think it is something like a...[gradual] change of colour as you realize that the expected overwhelming attack on the Hitler book still didn't produce any evidence that there had been this Holocaust, this genocide of which you are speaking, that you then begin to question your own beliefs and say - " (34-9774)

Pearson interjected: Your book didn't deny there was a Holocaust. Irving replied that he accepted that. Why then, asked Pearson, did you think someone was going to comment on your Hitler book proving that the Holocaust happened when you admitted and conceded in your book that it did happen?

"Because it acted like a spade whacked down in the whole of the historical body," replied Irving. "All the historians who had written about the Holocaust before began crawling around unearthing new documents, some of them very good historians - Professor Gerald Fleming went to work for the first time in the Polish and Russian archives to start work on the Holocaust and I expected every day that I was going to be proven wrong. They have brought back very, very good and useful research but in this particular and important aspect, their research was barren, not only with them failing to prove that Hitler had known about it, but they were failing to prove it, whatever it had been." (34-9775)

Irving agreed that Gerald Fleming's book Hitler and the Final Solution was directed to one aspect only of the thesis contained in Hitler's War, namely, that Hitler didn't know what was going on. He pointed out, however, that "you can't just carry out research on that one thesis. Inevitably you bring back barrow loads of documents relating to the whole broad area of attack." (34-9775)

Pearson suggested that Irving was bitter about the way the historical community reacted to Hitler's War.

"I think humanly disappointed is a better way to describe it," said Irving. "Because most of the historians...are men of substance and integrity, and I had hoped and expected that they would have valued the work that I had done and some of them privately could do, like Raul Hilberg, some of them do it publically and eventually I had to wait until the great split occurred in the body of historians for which I claim the entire credit. It wasn't until my book came out that they started re examining their own tenets." (34-9776)

Irving agreed with Pearson that he spoke to a convention of the Institute for Historical Review in the United States in 1983, where he gave a speech indicating that he thought that Hitler was probably the greatest friend the Jews had in the Third Reich. Said Irving: "For the reason that I just specified, that without Hitler's active campaign on the Jewish front, the state of Israel would probably not now exist and have attracted its overwhelming worldwide sympathy and I was specific about that in my speech." (34-9776)

Irving could not remember meeting Ernst Zündel at the convention. He had no precise recollection of when he first met Zündel: "I would say that over the last two or three years, when he became involved in the current litigation, he approached me as an expert who had written on this field and asked for assistance." (34-9777)

As a result of Irving's attendance in California, asked Pearson, did Gerald Fleming quote you?

"Yes," said Irving, "he published...an article in the Jewish Chronicle in London purporting to reproduce what I had said at Los Angeles and I wrote a letter to the Jewish Chronicle in London correcting on the basis of my memory what I had said in Los Angeles and then Gerald Fleming probably wrote another letter to the Jewish Chronicle." (34-9778)

Would you agree, asked Pearson, that at the IHR convention in 1983, you did not deny the Holocaust happened and it killed millions of Jews?

"Mr. Pearson, having flown from London to Los Angeles I was eight hours jet lagged. I made the speech to them with my mind in a fog and to try and recall from that fog precisely what I said in the course of one and a half hours talking - not just about the Jewish tragedy in the Second World War - but the whole field of historical research I had done including Hungary, German atomic research and the rest...", said Irving. He agreed that he wrote a letter in response to Fleming's article: "He had accused me of having said certain things at Los Angeles which I believed I hadn't said." (34-9779)

Pearson read from Irving's letter of December 23, 1983:

Dr. Fleming's malicious quotation from the proceedings in California is taken wildly out of context. I have a full recording of my talk which was about the Hungarian uprising of 1956. In the subsequent discussion about the Holocaust, I made it clear that the Nazis undoubtedly did murder many millions of Jews, a view which was unpopular to that audience, and continued by setting out my well known views of this tragedy.5

So in December of 1983, asked Pearson, you made it clear that the Nazis undoubtedly did murder many millions of Jews which was unpopular at the IHR convention?

"I remember the unpopularity," said Irving. "This is quite plain. This is half-way through the period between 1977, when I had the then view which I then believed, and the present date when I have changed my mind on whether there was the act of genocide you refer to. But I don't really want to dabble in statistics, whether I still believe it was millions killed by the Nazis or hundreds of thousands...You're very usefully trying to establish exactly when I changed my mind during the last ten years. And that advances it some way." Irving continued: "I obviously half-changed my mind there because I am not talking about the Holocaust, I am not talking about genocide, I am not talking about 6 million or any other precise figure. I am already talking in much vaguer terms there." (34-9780)

Pearson suggested that Irving was very specific when he said that the Nazis undoubtedly did murder many millions of Jews.

"I think I would delete the word 'millions.' I'm not in a position to say it was millions or hundreds of thousands and the more that I see the lack of evidence now, the more I am inclined to question the word 'millions'." (34-9781)

Pearson asked Irving whether he came to Canada on a speaking tour in 1986. Irving testified that he had; he was promoting a book on the Hungarian uprising of 1956. Pearson produced an eight-page brochure and asked if it was a brochure that advertised the speaking tour he was on. Irving testified that he was familiar with the original of it, a brochure called Torpedo Running. The sponsorship for the speaking tour was from an Australian publishing house, Veritas, which had various local groups sponsor the tour in different parts of the world - Australia, New Zealand, South Africa, Canada and Britain. Veritas, a publishing house in the Australian outback fifty miles outside Perth, had published his book Churchill's War. He was not aware of what else they had published other than a book on aboriginal land rights. (34-9781 to 9783)

On his speaking tour in Canada, Irving had been introduced by the Australian Eric Butler. Ron Gostick of the Canadian League of Rights had also spoken at the meetings. He was the organizer of the meetings in Toronto, Montreal and Ottawa. (34-9783, 9784)

Irving was introduced to Zündel in Vancouver on the 1986 speaking tour; he saw him at the back of the lecture hall on a speaking tour in 1987 in Toronto but did not speak to him then. (34-9784)

Pearson asked whether another book advertised in the eight-page brochure advertised a book called The Zionist Factor: A Study of the Jewish Presence in 20th Century History. Irving replied that he had never seen this page before: "For my worldwide tour, I produced this glossy brochure. Had two or three thousand copies printed worldwide and a number of copies were sent to Canada. And I can see from this that the Canadian organizer took that brochure and made a miniaturized photocopy of it in eight pages...in fact, I haven't seen this before except, of course, the pages like this one which come...from that brochure. So, some of these pages I am seeing now for the first time, including that advertisement for my Hungarian book and the page that you just wanted to show me." (34-9785)

Pearson returned to Did Six Million Really Die? at page 30:

•  Of great concern to Professor Rassinier is the way in which the extermination legend is deliberately exploited for political and financial advantage, and in this he finds Israel and the Soviet Union to be in concert.

Do you agree that the extermination legend is being deliberately exploited for political and financial advantage?, asked Pearson.

Said Irving: "I agree with the chief rabbi of Britain, as I said on the first day...It has become big business. Those are the words used by the chief rabbi, and I echo them." Irving agreed with what Harwood had written in this passage, with the exception that he would not have added the Soviet Union. (34-9802)

Pearson returned to Did Six Million Really Die? and read from page 30:

•  Who has the right to compound it with vast imaginary slaughter, marking with eternal shame a great European nation, as well as wringing fraudulent monetary compensation from them?

Did Irving agree, asked Pearson, that "fraudulent monetary compensation" was being wrung from Germany?

"If the compensation had been wrought from West Germany - I take it that's the nation referred to - on the basis that there was a state massacre of 6 million Jews for whom financial compensation has to be paid, and we then find out that that statement is a willful misrepresentation of the facts, if that is so, then that can only be represented as fraud." Irving continued: "I'm prepared to accept that the Jewish community as a whole believes in the Holocaust. If that is so, then it is not a willful fraud. It would be a - I don't know what legal term I would apply to describe it, but it wouldn't be a willful fraud in the terms of this paragraph." (34-9803)

Pearson read from the same page of the booklet:

•  ...on the one hand Germany pays to Israel sums which are calculated on six million dead...

Irving testified that he was "not aware of what actuarial basis the payments are made on. I'm aware only of the original conference between Dr. Adenauer, the German Chancellor, and Dr. Goldmann who was the Zionist representative...and Adenauer on his own initiative decided to pay, I believe, one billion dollars to the state of Israel as a compensation payment." Irving indicated that "not to my knowledge" was the money calculated on 6 million dead. (34-9804)

Pearson read from Did Six Million Really Die?, at page 9:

•  Gerstein's fantastic exaggerations have done little but discredit the whole notion of mass extermination. Indeed, Evangelical Bishop Wilhelm Dibelius of Berlin denounced his memoranda as "Untrustworthy."

Irving agreed that he was not suggesting that an author could be dishonest with his sources as long as the right conclusion was reached. Irving also agreed that if it was in fact Gerstein's sister-in-law that died of euthanasia, this would have "no bearing on his personal mental instability whatsoever." (34-9806)

Would you agree, asked Pearson, that this would be a dishonest technique of the author, to suggest that it was his sister instead of a sister-in-law?

"It may very well be that the author of this brochure is aware of a sister in addition to a sister-in-law, but this is a possibility which I can neither confirm nor deny." Irving agreed that it was also a possibility that Harwood was being deliberately dishonest. (34-9806)

Pearson read the description of Harwood which appeared at the end of the essay on page 30:

•  Richard Harwood is a writer and specialist in political and diplomatic aspects of the Second World War. At present he is with the University of London.

Do you know of any Richard Harwood at the University of London?, asked Pearson.

"No, sir," said Irving. "and I have to admit that when I read that description, I thought that the words 'At present he is with the University of London' were rather precious and arousing suspicion." Irving agreed that it appeared to be designed to suggest that the author was a professor at the University of London or held some kind of post. Irving did not know any Richard Harwood who was a writer and specialist in political and diplomatic aspects of the Second World War, other than the author of the booklet. He indicated that it was important to some readers to know who was writing something and that if the author was someone named Richard Verrall and that he was a member of a neo-Nazi group, that would be taken into consideration by the reader and weighed with other factors in determining the approach taken by the reader to the booklet. (34-9806 to 9808)

Pearson produced Six Million Did Die and read what Hugh Trevor-Roper had said about Did Six Million Really Die? at page 56:

My judgment of it is that, behind a simulated objectivity of expression, it is in fact an irresponsible and tendentious publication which avoids material evidence and presents selected half-truths and distortions for the sole purpose of serving anti-Semitic propaganda.

Did reading that opinion, asked Pearson, change Irving's own assessment of Did Six Million Really Die?

"I would say to this that I value Trevor-Roper's judgment, and like any other historian he is entitled to his own opinion. It doesn't change my assessment of this brochure because my assessment was, as I stated on Friday - that it serves a useful catalytic purpose in making people think and rethink and possibly even revise their accepted opinions," said Irving. He continued: "It doesn't change my opinion because it doesn't surprise me that the...establishment historians like Professor Hugh Trevor-Roper, who hold very important semi-political positions in the English university structure, find it more congenial to express that view on this brochure than to express the view which I have expressed, that it serves a useful catalytic purpose in making people think afresh, and when I say that, I am not saying that I endorse everything that the brochure contends, merely that it serves a useful purpose in promoting and stimulating discussion." (34-9811)

This ended the cross-examination of Irving by Crown Attorney Pearson. Defence attorney Douglas Christie rose to commence re-examination.

In regard to the Posen speech, asked Christie, would you think it useful as a historian to conduct a voice analysis using scientific methods of the tape itself to determine if it was actually spoken by the person who it was purported to be spoken by?

"Given a speech of this importance, of this historical importance," said Irving, "I would certainly hope that this kind of forensic test could be made on the speech...On this particular speech, I'm not aware of any such test having been made, but I'm certain that similar voice spectrograms had been made on tapes in criminal cases..."

Christie asked whether Irving was specifically investigating the alleged extermination while he was writing Hitler's War. This question was disallowed by Judge Ron Thomas. (34-9812, 9813)

Christie asked Irving to provide details of his correspondence with Raul Hilberg. Irving replied: "I wrote a letter to a number of Jewish authorities, authorities on the so-called Holocaust, when I was in a stage of some embarrassment with my Hitler biography, not having been able to find any evidence linking Hitler with what I at that time believed to have gone on, and I asked each of these Jewish authorities, which included the YIVO Institute in New York, the Wiener Library in London, and respected Jewish historians like Raul Hilberg, if they could provide me with evidence which I want[ed] to know about. And Hilberg, in the course of the correspondence, which perhaps encompassed two or three letters and replies, said that he had come to the same conclusion independently, as I had, that quite probably Adolf Hitler himself was not concerned in what had gone on...This correspondence would have been in the early 1970s, probably about 1970. Of course, I didn't continue to ask him what had gone on because at that time I still believed that there had been an organized massacre. The realization only dawned on me bit by bit that this was something that had to be tested on every front." (34-9813, 9814)

Since that time, asked Christie, what was the most significant piece of evidence that had affected your opinion on the matter?

"I think, probably, that document from the files, the German Ministry of Justice, in the spring of 1942, showing Adolf Hitler as demanding that the 'final solution' be postponed until after the war is over," said Irving. "That was the most significant piece of evidence on the Hitler level, but on the other front, as to whether a mass extermination occurred in Auschwitz itself, I must say that the most significant piece of evidence is what I've been shown since I arrived here in Toronto on Thursday, which is a document which I am not at liberty to talk about, I think." (34-9814, 9815)

[Judge Ron Thomas excused the jury, then told Christie to explain the purpose of the re-examination. Christie said: "It is in the course of the cross examination the Crown has implied that he had no reasons for the change of his opinion, and I want to explore the area of what the reasons were. I had not yet heard Your Honour to determine that he could not mention the name of the Leuchter Report. I had heard Your Honour to determine that he cannot introduce it but I'd like him to be able to at least mention it." (34-9816) After sarcastically belittling Christie for not knowing the purpose of re-examination, Thomas stated: "I made a ruling that he could mention the fact that he had seen the report, that he knew that it was done and that it had not been done before, but he isn't here in the position to give evidence on whether this report is valuable in the history of mankind." (34-9817)]

Upon resumption of the court in the presence of the jury, Christie asked Irving about who penalized the persons who committed atrocities at Chelmno. Irving indicated they were penalized by authorities or agencies of the German state. (34-9821)

Christie directed Irving to page 867 of Hitler's War, where it dealt with a note sent by Himmler to Gestapo Chief Müller on November 30, 1942 and which said: 'You are to investigate at once in all quarters to find out whether there have been any such abuses as the - no doubt mendacious - rumors disseminated around the world claim. All such abuses are to be reported to me on the SS oath of honor.' Irving had written in the book that this letter was the 'purest humbug'. Asked Christie, I'm wondering if in light of your current knowledge you would think it appropriate to reassess some of those statements?

Said Irving: "It is a letter from Himmler to the Gestapo Chief Müller, November 30, 1942, which gives the impression that Himmler knew nothing about what was going on. He had read press accounts in foreign newspapers and I, at that point, at that time, believed that the letter must be, as I say here, purest humbug because my belief at that time was that something had been going on of which Himmler must have been aware. In other words, he must have been aware that what was alleged in these foreign press accounts was true. So his denial was purest humbug. That was based on my belief in 1977 when I published the book. I wouldn't have used that phrase with such confidence if I was writing it now. I would have toned it down and I would have qualified it by saying if there was atrocities on the scale now alleged, then for Himmler to have written a letter in these terms would have been purest humbug. I would have qualified the statement." (34-9822)

This ended the testimony of David Irving.


* * * *


Notes

1. Martin Broszat. "Hitler and the Genesis of the 'Final Solution': An Assessment of David Irving's Theses." Yad Vashem Studies, 13 (1979): 73-125. Also published as "Hitler und die Genesis der 'Endlösung.' Aus Anlass der Thesen von David Irving." Vierteljahrshefte für Zeitgeschichte 25 (1977): 739-75.

2. Pages which Pearson read to the court were projected on a screen in the courtroom with the use of an overhead projector.

3. In the original transcript, this word was "gasungskeller." In correspondence with the editor, however, Irving stated that he never said this word and in fact said "gaskammer".

4. Not compared with original.

5. Not compared with original.

 

The concepts expressed in this document are protected by the basic human right to freedom of speech, as guaranteed by the First Amendment of the Constitution of the United States, reaffirmed by the U.S. Supreme Court as applying to the Internet content on June 26, 1997.

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