The Nizkor Project: Remembering the Holocaust (Shoah)

Shofar FTP Archive File: people/i/irving.david/libel.suit//transcripts//day011.06


Archive/File: people/i/irving.david/libel.suit/transcripts/day011.06
Last-Modified: 2000/07/20

   Q.   Are you saying that the slide was permanently removed and
        there was never any slide left there?
   A.   There is a problem because Tauber at certain moments
        mentions a slide in his testimony.  The big problem with
         -- the question is, and this is a problematic point in
        Tauber's testimony because we know that the sonderkommando
        of No. (ii) and No. (iii) were able to basically make use
        of those buildings, that when there were no gassings
        taking place, that these two compounds were in connection
        because some of the facilities used by the sonderkommando
        No. (ii) were in No. (iii) and in No. (iii) that slide is
        still there.  The slide was actually constructed.
                  To what extent actually he was in his testimony,
        I mean, the assumption in his testimony in German is that
        he talks about two, but if he introduces that, if he
        describes the subterranean level, if he actually describes
        something he saw in No. (iii) which is identical except
        for the fact that left and right are reversed, and it is
        particularly detail of the slide, it is very difficult to,
        you know, actually get a real handle on that.  One of the

.          P-46

        buildings has a slide, the other buildings does not have a slide.
   Q.   Just to be perfectly plain, the entrance which is moved to
        the street side of the building did not have a slide, did it?
   A.   No.  The entrance which is -- this other entrance does not
        have a slide.
   Q.   Would it not be a reasonable inference that the architects
        had decided that, being good architects, they ought to
        design a building where people had ways of getting in
        there where they might not have to mingle with corpses going in?
   A.   Can you repeat that?
   Q.   They decided that they need, for matters of taste and
        decency, to have a clean side of the building where people
        could go in without having to jostle with corpses that
        might be infected going down the steps and they decided,
        therefore, for pure hygiene reasons to move the staircase?
   A.   That would be perfectly -- that would be perfectly fine.
        The problem is how do you get then the corpses into the
        building, because this corpse access seemed to have been
        removed.  So what we have here is that there is no way any
        more to get corpses into this building, according to this
        drawing, and that the only way to get corpses into the
        build is that a staircase which has been narrowed to such
        an extent that it is certainly very difficult to carry a

.          P-47

        stretcher inside.
                  I also want to point out to you that in the
        original design -- sorry again -- there was enough space
        either when you slide the corpse downstairs or when two
        men are carrying the stretcher, there is not enough space
        for you to turn around.  However, here, this turn around,
        I mean, first of all, it is much narrower, as you see.  We
        are talking here about one metre width of, I think one
        meter 60, one metre 80, there is much less space actually
        for two people actually carrying a stretcher, there is no
        slide at all.  Then we get the problem actually of turning
        here.  It gets very, very tight.
   MR JUSTICE GRAY:  So do you deduce from that that it is live
        people who are going to go down to that morgue?
   A.   Yes.
   MR IRVING:  But is there not also an elevator or a hoist being
        installed which, we are told, is capable of carrying large
        numbers of bodies from the basement up to the furnaces?
        Could that elevator not also have been used to carry them
        down in the first place?
   A.   Ah, yes, but the problem is how do you get them in that
        space?  I mean, I am happy to go back to the original
        ground plan which we -- my Lord, do you want me to go back
        to the original ground plan?
   Q.   The elevator is just next to your shoulder on that design
        and there appears to be a lot of space in front of it.

.          P-48

   A.   Sorry.
   Q.   The elevator is just next to your shoulder, is it not?
   A.   Yes, but if you bring down the corpses by the elevator,
        and I will go down because again it is an important issue
        you raise and an important alternative explanation.
   Q.   A plausible alternative, and you have not established ----
   A.   The problem of the plausible alternative in this case is
        that the elevator is here.  Now, the only entrance we have
        now, the only way to get to the elevator, is to go through
        the entrance here, right next to the dissection room.  Go
        through the foreground, go now into the washing room for
        the corpses and then turn around into the elevator.
                  This elevator was meant to give direct access to
        the washing room.  When a corpse comes up, it can be
        washed and dissected.  But I would say that this is an
        extremely, and especially these doors here -- I mean, how
        do you actually -- these doors are not wide enough, these
        are not double doors which you get in the original design
        right here.  This is a double door.  So again, stretcher,
        two people carrying it, four people carrying it, there is
        enough width here for them all to go down.
                  But this is a very, very awkward way to get
        corpses actually in and then down in the elevator.  The
        alternative is that you have to go, there is no direct
        entrance into the incineration room.  The alternative is
        to go through this door, through this door, walk over the

.          P-49

        coke supply between the incinerators and go to that
        elevator.  Or the third possibility is to -- no, that is
        actually it.  That is it.
   Q.   Your evidence for saying that there was no corpse slide in
        the building as built is?
   A.   It is not in the drawing.  In this drawing and it does not
        seem to be there.  So, I mean, I can see it, well, I can
        still see it in crematorium (iii).
   MR JUSTICE GRAY:  What would it have been made of?  Metal?
   A.   The corpse slide?
   MR IRVING:  No, a concrete slide.
   A.   Concrete.
   MR JUSTICE GRAY:  Just a concrete slide?
   A.   Yes.
   MR IRVING:  So there is no evidence there was something in the
        building now and it was never there -- Mr Rampton, I am
        asking the questions here.
   A.   We have a blueprint.  We have the remains of the building.
   Q.   Will you answer my question?  There is no evidence that
        there is something in the building now and it was never there?
   A.   No, and I have not seen any evidence.  The only evidence
        there is -- let me be more precise.  There is evidence in
        Tauber.  Tauber says there is a corpse slide.  But I have
        addressed this problem already as a problem in the
        testimony, that I think he refers back to the corpse slide

.          P-50

        in crematorium No. (iii) which was installed.
   Q.   But is there not a lot of evidence that Tauber was being
        questioned on the basis of drawings put to him by Jan
        Sehn, the prosecutor?  When you read his interrogation, he
        is actually being interrogated on the basis of ----
   A.   If we would have seen the drawing which was this drawing
        and was available also to Dawidowski and so to Jan Sehn,
        then I presume that he would not have invented the corpse
        slide when it is not in the drawings.  See here, the
        corpse slide is still in this one, in the design.
   MR JUSTICE GRAY:  I suppose Jan Sehn may have used the drawings
        for crematorium No. (iii) when he was taking Tauber
        through it, if that is what happened?
   A.   No, there is not a special set for crematorium No.  (iii).
   Q.   There is not?
   A.   Crematorium (iii), they use the same drawings as No.  (ii),
        but they just reverse the building.
   Q.   Yes.
   MR IRVING:  The same as in the days of the British Empire when
        we built our buildings in India with blueprints that had
        been designed for England -- just reversed them, in fact?
   A.   Yes.  I do know exactly what you did there, but they did
        make a new set of blueprints.
                  So the first problem is the way the doors are hung.
                  The second issue, of course, is why is there a

.          P-51

        convenient way of accessing corpses in the morgues
        removed, and why at least they are bringing in corpses a
        very inconvenient and awkward way is replaced, but a
        staircase which seemed to be optimally useful to bring in
        human beings who are alive.
   Q.   Can I ask you, were the corpses that resulted from the
        great epidemic of 1942, where were they cremated?
   A.   The corpses from the great ----
   Q.   The typhus epidemic, the 8 or 9,000 that we know about?
   A.   In August 1942, there were two ways to get rid of corpses
        and then the question is where these people died?  In
        Auschwitz 1, the crematorium was functioning at the rate,
        an official rate, of 340 corpses per day.  So, certainly,
        the people who died in Auschwitz 1 -- at that moment
        Auschwitz 1 was still somewhere in the main camp.
        Birkenhau had not grown so much here.  It was still under
        construction.  So the crematorium in Auschwitz 1, No.  (i),
        dealt with the corpses of people who died there.  In
        Birkenhau, the major way of getting rid of corpses at that
        time was to bury them.
   Q.   And the epidemic of 1943, January 1943, in Birkenhau,
        where were those corpses cremated?
   A.   They had incinerators that open, these things which had
        been adopted by the Zentrale Bauleitung in the camp after
        the trip to Chelmo in mid September 1942 when they went to
        see Goebbels' ovens.

.          P-52

   Q.   The fire grate?
   A.   So they then created something like that in Birkenhau, and
        that is how they got rid both of the corpses which had
        been buried earlier ----
   Q.   But are you telling the court then that no external deaths
        were brought into this crematorium?
   A.   No, I do not want to say -- I am talking about the design.
        I am talking about their intentions.  This crematorium,
        obviously, undergoes a modification in which it is much
        more difficult, I do not want to say impossible because
        everything is possible, much more difficult, where a
        convenient system of bringing people who have died outside
        the building has been removed, and a new convenient system
        has been installed in order to bring people down who had
        not yet died.
   Q.   But if you answer my question?  Large numbers of people
        died outside this building, we know that, in the camp in
        Birkenhau?
   A.   When?
   Q.   In 1943, from various causes, and how would they have been
        brought into this building?
   A.   This is the most likely reason why the slide remains in
        crematorium No. (iii).
   Q.   So, no natural deaths were disposed off in this?
   A.   We do not know, but, I mean, when I said in the movie
        which is the clip we saw that, in my judgment, almost half

.          P-53

        of the people who died in Auschwitz, who were gassed in
        Auschwitz, died in crematorium No. (ii) ----
   Q.   In this very ruined gas chamber we are looking at here?
   A.   The gas chamber, it is based on a number of assumptions.
        It is not a calculation made on the back of an envelope.
        It is made on which building functioned when, during what
        operation, which building was solely dedicated to bring
        people in this way, and also at a certain moment, you
        know, which buildings broke down at what time?  There is,
        of course, a clear problem with crematoria (iv) and (v)
        where the ovens broke done constantly.
   Q.   So this building is one of the main factories of death in the camp?
   A.   Yes, but it is a building which, as we have seen now, it
        was case of adaptive reuse, and here we see exactly that
        piece of adaptive reuse.  I just want to -- I have various
        kinds of details of this drawing again to show the kind of
        texture of this particular one.  So, I think this is a
        very, very important drawing in the context of other
        drawings and in the context of testimony.

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