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Last-Modified: 2000/07/24

   Q.   Do you accept that without the existence of such a body
        there would have been such major concessions in the
        Holocaust story that have occurred since the end of World
        War II?
   A.   No, to the question and no to the premise.
   Q.   Have there been major concessions in the story since the
        end of World War II?
   A.   You would have to tell me exactly what they were and
        demonstrate that they were based on the work of the
        Institute of Historical Review before I accepted that.
   Q.   Is it true that the Israeli authority at Yad Vashim now
        officially agree that the Nazis never manufactured soap
        from bodies?
   A.   I think that has long been the case.  Indeed ----
   Q.   Can you put a date on it?
   A.   No, I cannot, no.
   Q.   Was it about 1989?
   A.   I would have to see documentation of that.
   Q.   Do you agree that the figure of Auschwitz has been brought
        down from 4 million to 1.5 million?
   A.   We have already been through that.
   MR JUSTICE GRAY:  We had this, I think, last Thursday.
   MR IRVING:  I am just trying to look at the concessions
that
        have been made largely as a result of revisionist

.          P-169



        agitation, if I can put it like that?
   A.   I do not think, Mr Irving, that that was the result of
the
        work of the Institute of Historical Review which was
not
        founded at the time that that number was changed.
   MR IRVING:  Have you read the work of Michael Berenbaum --
I am
        sorry, of Aberhard Jackeln who states that it was not
        until 1977 that the whole of this Holocaust research
        industry began, that the historians started doing
their
        job?
   A.   I think we have already been through that, I think,
when
        you cross-examined Professor Browning, that certainly
        I would need to see a copy of that statement by
Professor
        Jackeln, but if he does say that, then he is certainly
not
        correct.
   Q.   You would not agree, therefore, that the revisionists,
        having created the Aunt Sally which the genuine
historians
        needed, the scholars needed, you do not agree with the
        premise that the scholar would not have done the job
as
        rigorously as they have had to?
   A.   No, not at all, no.  I have to say, on the whole, I do
not
        serious scholars pay any attention to the work of the
        Institute of Historical Review at all.
   MR JUSTICE GRAY:  Mr Irving, I wonder whether the time has
not
        come to move on to what is important which is page
205,
        what you have written about Hitler.
   MR IRVING:  Well, I, in fact, leapt on to page 207, my
Lord.

.          P-170



   MR JUSTICE GRAY:  Good.
   MR IRVING:  Would you look at that quotation at the top of
page
        208?
   A.   208?  Yes.
   Q.   Yes.  Have you left anything out of that quotation, do
you
        think?
   A.   Not that I can see.
   Q.   It is about the euthanasia programme, is it not?
   A.   Yes.
   Q.   If I start reading about where it says:  "About a
quarter
        of a million hospital beds", I am going to read it
from
        the book which is the actual source, which is the 1977
        edition at page 20?
   A.   Could I have a copy, please?  Page 20?
   Q.   Yes.  "About a quarter of a million hospital beds were
        required" -- this is the actual text -- "for Germany's
        mental institutions for Germany's disproportionately
large
        insane population, a result of centuries of lax and
        indiscriminate marriage laws:  of some 7 or 800,000
people
        all told, about 10 per cent were permanently
        institutionalized.  Others were in and out of
hospitals.
        They occupied bed space and the attention of skilled
        medical personnel which Hitler now urgently needed for
the
        treatment of the casualties of his coming campaigns".
You
        missed passages out without indicating it, have you
not?
   A.   Let me just have a look at this.

.          P-171



   Q.   Three passages have vanished?
   A.   Well, let me try to sort this out.  Certainly, those
two
        passages, the passage you read and this passage, would
        seem to indicate that.  Now, here I refer to, it is
        actually pages 227 to 8 of the 1991 edition that I am
        citing, as you can see from the bottom of the previous
        page.  Could I have the 1991 edition, please?  We have
227
        to 8.  No, it is the wrong one.  227 to 8.
   MR JUSTICE GRAY:  About a third of the way down.
   A.   Right, let me read this from page 227 of the 1991
        edition:  "About a quarter of a million hospital beds
were
        required for Germany's disproportionate large insane
        population:  of some 7 or 800,000 victims of insanity
all
        told, about 10 per cent were permanently
        institutionalized.  They occupied bed space and the
        attention of skilled medical personnel which Hitler
now
        urgently needed for the treatment of the casualties of
his
        coming campaigns".
                  So I have quoted absolutely correctly from
the
        source that I give without any omissions at all.
   Q.   But you have not actually realized that, in fact, the
        original quotation was fuller and you preferred the
        abbreviated version to base your ----
   MR JUSTICE GRAY:  Mr Irving, really!  What sort of a point
is
        that?
   MR IRVING:  Page 209.

.          P-172



   A.   May I just say, Mr Irving, I think you are entirely
right
        to condense that quotation because the reference to
lax
        marriage laws in 1977 is entirely wrong.  German
marriage
        laws up to the middle of the 19th century, in most of
        south Germany, at least, were extremely strict.  As
you
        say yourself, you are condensing all the way along.
There
        is no fault in that.
   Q.   Page 209, paragraph 4.1.8 please.  This is the Night
of
        the Long Knives?
   A.   Sorry, could you remind me?
   Q.   4.1.8, 209?
   A.   209?  Yes.
   Q.   209, you say in the final sentence of that paragraph
        4.1.8:  "Irving defended the Night of the Long Knives
in
        June 1934".  This is rather like saying I applauded
the
        Holocaust, is it not?
   A.   No, I think it is somewhat different.
   Q.   I  "defended the Night of the Long Knives"?
   A.   I go on in the next paragraph to outline your views.
You
        say that "the SA was planning to" was underlined --
         "overthrow Hitler's government".  "In an act of rare
        magnanimity Hitler ordered state pensions provided for
the
        next of kin of the people murdered in the Knight of
the
        Long Knives.  Even so he began to suffer nightmares
and
        could not sleep" although, in fact, as I point out,
Hitler
        personally marked crosses against the names of

.          P-173



        considerable numbers of people that he ordered to be
        murdered.
   Q.   I am going to come to that in a minute.  The idea of
        defending the Night of the Long Knives suggests that I
        defended the murder of people when they were planning
a
        revolution?
   A.   Well, the nub of it, of course, is were they planning
a
        revolution or not.
   Q.   Well ----
   A.   And in any case, and also, of course, the murder, that
was
        done wholly outside the judicial process.
   Q.   If I establish in a biography of Hitler that, in fact,
        these SA leaders were plotting something, this is not
the
        same as defending their murder, do you agree with
that?
   A.   I think it is -- I am prepared to jettison the word
         "defending" and say "excusing".  We have been down
this
        road before.
   Q.   "Excusing" is almost as bad as "defending".  But can
we
        now move to the next paragraph where you are saying
that
        the charges were trumped up.  Do you not accept that
the
        brown shirt movement were, in fact, planning the
overthrow
        of the Nazi government of Germany?
   A.   I think the evidence is very thin.
   Q.   Have you read various works on the subject, for
example,
        by Heinz Werner?
   A.   I have read some.

.          P-174



   Q.   So you have read some works, but just on the basis of
        having read some works, you are prepared to say that I
am
        wrong and that these other authors are wrong?
   A.   Well, let me see what I say.  You see:  "Most authors
have
        seen the Night of the Long Knives as a shocking
violation
        of moral and legal norms" ----
   Q.   Yes.
   A.   ---- "in which Hitler not only brought retrospectively
        trumped-up charges against the SA leaders of plotting
a
        coup, but also used the opportunity to bump off
        politicians, such as Kurt von Schleicher and Gustav
von
        Kahr, who he felt knew too much about his past, or
whom he
        simply strongly disliked, and against whom no
conceivable
        political suspicions could be directed in 1934".
   Q.   On the basis of your limited knowledge of the Night of
the
        Long Knives, what evidence do you have that Hitler
ordered
        the murder of Schleicher which was an appalling act --
        there is no question -- that Hitler was personally
        involved in that?  Do you have any evidence?
   A.   I do not present it here, no.  I would have to do some
        research on that.
   Q.   And what evidence do you have for saying that Hitler
        personally ----
   A.   Let me respond to that by saying can you present
evidence
        that he did not?  Maybe that is the way to go.
   Q.   Are you familiar with the excellent paper on the
murder of

.          P-175



        General Schleicher that was published by the Institute
of
        History about 35 years ago, giving the entire
background
        of the case?
   A.   I thought you did not read work by other historians,
        Mr Irving.
   Q.   For some historians I make exceptions?
   A.   Ah, so you do read work by other historians?
   Q.   This was a documentation.  You appreciate the
difference
        between a documentation and a book?  Two lines from
the
        bottom you say:  "Hitler personally marked crosses
against
        the names of scores of people on the night in
question".
        What evidence do you have for that?
   A.   That is what I understand from my reading.  I agree,
        I cite in footnote 11 the sources which I have used
for my
        extremely brief account of this.
   Q.   So this is one of those cases where the historian has
sat
        in his book lined cave and taken four books off a
shelf
        and written a fifth, effectively?
   A.   No.
   Q.   He has not really added to our knowledge?
   A.   I do not think -- oh, you mean me?
   Q.   Yes.
   A.   Well, if you can show that they are wrong or somebody
can
        show that they are wrong, then I would be quite happy
to
        accept that.
   Q.   If you can take it from me that Field Marshal Milch

.          P-176



        described to me personally, sitting at the Execution
        Council, together with Himmler and the other leading
        members of that gang, watching as Himmler read out a
list
        of names and they personally approved and wrote little
        ticks against the names of those to be liquidated
which
        were handed out through the door to the flunkers who
        ordered it carried out, that this was the way the
        Execution Council took place, and that Hitler was
nowhere
        near, would you accept that version?  It is contained
in
        one of the books you have read, the rise and fall of
the
        Luftwaffe?
   A.   No, Mr Irving.  That is a recollection a long time
after
        the event.  It is not a contemporary document.  You
        yourself would be the first to impugn the reliability
of
        that source if that source if it said something you
did
        not like.
   Q.   Would you accept that Milsche kept diaries throughout
that
        episode and also that Milsche would hardly relate
        something to me which under circumstances could be
taken
        as counting against himself if he was a participant in
or
        an eyewitness of this Execution Council?
   A.   Well, this is getting rather hypothetical.  If you
present
        to me documents that demonstrate that what I say here
is
        wrong, I will be quite happy to accept it.
   Q.   That is not the way it works, Professor.
   A.   I thought it was the way it worked.

.          P-177



   Q.   You are saying here in an expert report which you now
        concede is written on rather flimsy evidence that Hitler
        personally ----
   A.   I do not think I did that at all, Mr Irving.
   Q.    --- marked crosses against the names of scores of people?
   MR JUSTICE GRAY:  I think if you are wanting to say that there
        is documentary support for what you write, Mr Irving, and
        for what Professor Evans criticises, you really ought to
        be equipped to show Professor Evans what you rely on.  For
        example, I mean, did you record what General Milsche was
        telling you about the absence of Hitler, and so on?

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