Archive/File: people/i/irving.david/libel.suit/transcripts/day024.02
Last-Modified: 2000/07/24

   Q.   A spectacular task.  So that gives you a very good
        overview over the whole of the domestic life of Nazi Germany?
   A.   I think it gave me a good insight into the day to day
        operation of the bureaucracy in the Nazi State.
   Q.   And into the kind of language they used?
   A.   Yes, of course.
   Q.   And into the hierarchy and the various rivalries and
        disputes?
   A.   Exactly.
   Q.   Was friction between the top Nazis a major element of the
        Third Reich?
   A.   Absolutely.
   Q.   [German] -- in other words ----
   A.   Yes.
   Q.   --- jealousies between the different ministries and
        agencies?
   A.   In-fighting and these things, yes.
   Q.   Would you, from your knowledge of other governments, think
        it was more or less than other governments around that

.          P-10

        time, British government or the American government, or
        was it something extraordinary, the degree of ----
   A.   I made point in the book I wrote on the Party Chancellery
        that I think this exceeded the normal of in-fighting you
        find in all governments.  It is a special case here.
   Q.   Yes.  When you worked in the Institute of History, who was
        the director at that time?  Was it still Martin Broszat?
   A.   At this time it was Martin Broszat until his death in 1989.
   Q.   He had a very great reputation, did he not, and he is
        still greatly admired by German historians?
   A.   Yes, I think so.
   Q.   Were you familiar with all the collections of documents in
        the Institute files?  Did you work in the archives at all?
   A.   Not all the files.  I mean, the Institute has an enormous
        collection of files, but I know some of them.
   Q.   Yes.  Was Dr Hoff still there, Anton Hoff, the archivist?
   A.   No, I think he died in 1883.
   Q.   1983?
   A.   1983, sorry.
   Q.   Just before you came?
   A.   Yes.
   Q.   It is a very friendly atmosphere there at the archives, at
        the institute?
   A.   I think they were friendly to me.  I do not know ----
   Q.   They are very co-operative, are they not?  They do not

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        hold things back very much apart from own private collections?
   A.   I cannot make such a general statement.
   Q.   In fact, you probably had quite a lowly position there,
        did you not?  You were a newcomer and you were working in
        the Institute?
   A.   I have no difficulties in actually getting access to the
        collection but I cannot make a general statement on that.
   Q.   Did you ever take the opportunity to look at what is now
        ED 100, the collection of my documents which is in the Institute?
   A.   I think I have seen some of the ED 100 files, but I cannot
        say that I have a complete overview.
   Q.   Yes.
   A.   I have seen some of them yes, but at the moment I cannot
        recall every document I have seen in the Institute.
   Q.   I am just going to give you a list of names of collections
        of diaries.  I am sorry, you have a copy of this already.
        I ought to give a copy to his Lordship, perhaps.  (Same
        handed) just on the back of that there is a blue column
        called Hitler's People.  Do you have that if you turn it
        over?  There is a list of names of diaries that I used
        when I wrote my book Hitler's War, which are now in the
        archives.  I have added to those since then but I just
        pick out a few names.  Canaris:  Would that be a valuable source?

.          P-12

   A.   At the moment I cannot recall the Canaris diaries.  I am
        not able to comment on every item, but I think some of
        them are of course important.
   Q.   Some are more important and some are less important?
   A.   Yes.
   Q.   Dr Longerich, I am not trying to trick you.  I am just at
        this stage trying establish -- I will give a little
        warning if I am going to try and trick you.
   MR JUSTICE GRAY:  Mr Irving, do I get anything more from than
        that -- is this the new edition that is coming out shortly.
   MR IRVING:  No, this is the second edition, my Lord, but I just
        wanted to comment on the fact I wondered whether he had
        taken the trouble to look at these very important
        collections of diaries that are in my collection, either
        for his own work or in the expert report.
   MR JUSTICE GRAY:  Can you put it as a single question rather
        than the whole lot?
   MR IRVING:  Yes.  Did you use the diary of Walter Havel?
   A.   I looked at the transcripts.  I think it is in England, is
        it not, the original?  I looked at the transcripts at one
        stage but not for the Party Chancellery.  I think I looked
        at the Bormann, it is more a calendar.
   Q.   The calendar?
   A.   Yes.
   Q.   Which I have now provided to the Defendants.  The Walter

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        Havel diary does contain one of these episodes July 1941,
        does it not, where Hitler describes the Jews as a bacillus?
   A.   I cannot recall this particular passage, I am afraid.
   Q.   When you drew up this glossary of meanings of words,
        which, I must say, I find very useful indeed, and this
        goes purely to the conduct of the case, when did you start
        writing that approximately?
   A.   I think it was in December last year.
   Q.   In December last year?
   A.   Yes, I tried to use the Christmas holiday to do it.
   Q.   When did you complete it?
   A.   I think it was actually in January think.
   Q.   You completed it in January?
   A.   Yes, January I think.
   Q.   Yes.  When were you asked to do it by the instructing
        solicitors in this case?
   A.   I think they wrote me an e-mail.  I think it was in
        November, but I could not start immediately to work on it
        because I had other obligations.  So I am sure I started
        to work on it at the end of the Christmas holidays.
   Q.   You got a letter of instruction?
   A.   I think, as far as I recall this, I got an e-mail.
   Q.   Yes.  So you got an e-mail sometime in November, you began
        writing in December and you completed it in January?
   A.   Yes, that is right.

.          P-14



   Q.   Any idea when in January you completed it?
   A.   I think it was more through the end of January, probably
        on the first days of February, I cannot recall.
   MR RAMPTON:  I can help, I think, because now it comes out of
        Dr Longerich's hands, as it were.  It came in its first
        version in German, which, since I was the person who
        requested it, I think in November is right, maybe even
        October, and was useless to me.  So it had to be
        translated.  It came back and the translation was, to say
        the least, unsatisfactory.  Then it had it go back again,
        and what we now have emerged in the course of the last few days.
   MR IRVING:  Yes.
   MR JUSTICE GRAY:  Mr Irving I am not unsympathetic to the fact
        that you are having to deal with this at pretty short
        notice because it came to you very, very late in the day.
   MR IRVING:  Of course I accept Mr Rampton's explanation but it
        was delivered to me on Friday evening and, if it turns out
        he completed it in January, I would have wanted to know
        what the reason for the delay was.
   MR JUSTICE GRAY:  If you want to say you want Dr Longerich to
        come back at some later stage because you want to ask some
        further questions, you would be pushing at an open door.
   MR IRVING:  I fully accept Mr Rampton's explanation about
        translation difficulties.
                  During your professional career, Dr Longerich,

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        as you say in your curriculum vitae on page 3 of your
        report, you have received research grants from the German
        Historical Institute in London, and from the Deutsche
        Forschungsgemeinschaft and also from Yad Vashem?
   A.   Yes, that is true.
   Q.   Are you still in debt to Yad Vashem in any way?
   A.   I started to work on the project.  The project has not yet
        been completed.  The relationship, there is no contract
        between us and in this sense, it is not a book contract or
        something like that, but I still have to complete this
        project we started a couple of years ago.
   Q.   I do not want to know any figures or quantum.  Does this
        mean to say they paid you in advance for something and you
        are still working on it?
   A.   No.  They paid me for ten months actually.  It enabled me
        to live in Israel for ten months.
   Q.   As you say in this ----
   MR JUSTICE GRAY:  What will you be doing for them?  What will
        you be researching?
   A.   We started to work on a project, a documentation about the
        deportation of the Jews from Germany to Minsk and Riga and
        I had a partner there.  We started to collect the
        documents, but unfortunately the work has not been
        completed yet.  It is actually a major project and has not
        been completed yet.
   MR IRVING:  The Eastern European archives have turned out to be

.          P-16



        particularly fruitful, is that right?
   A.   Absolutely, yes.
   Q.   Is it to be regarded as a great tragedy they have only
        recently in the last ten or 15 years become available to
        historians?  Is that right?
   A.   I cannot comment whether it is a tragedy.  It is a fact
        that it has become available in the last years.
   Q.   They were not available at the time I wrote my first
        edition of the Hitler biography in the 1960s?
   A.   With some exceptions.  It was always possible to get some
        of the documents out of the archives.  For instance, there
        is a large collection of documents in the German Central
        Agency for the Prosecution of Nazi Crimes.  They actually
        managed to get a large collection from this material in
        the 1960s.  There is also a large collection in the
        Bundesarchives archive and individual researchers had the
        chance to see not the whole archives but some of the documents.
   Q.   If I can just dwell briefly on the files in the
        Zentralestelle, which is presumably the ZST source?
   A.   Absolutely, yes.
   Q.   You did not identify that in your report, did you?
   A.   I think there is a list of abbreviations and it should be there.
   Q.   The documents provided by the Eastern European archives to
        the German Zentralestelle, which is a prosecuting archive

.          P-17



        -- could I put it like that?
   A.   It is the house archive of this agency.  They have their
        own library and their own archival collection.
   Q.   At Ludwigsburg?
   A.   Yes.
   Q.   Is it specifically collected for the purpose of carrying
        out prosecutions of German and other citizens for war crimes?
   A.   That is the main purpose of the whole institution and of
        course mainly some historical background.
   Q.   They have very valuable collections of documents there, do they not?
   A.   They have a very good collection, yes.
   Q.   That is where Dr Goldhart worked, for example?
   MR JUSTICE GRAY:  Mr Irving, do you think we should move on
        from the archives?
   MR IRVING:  I just want to ask one question which makes the
        point clear, my Lord.  Is it apparent to you that, if an
        archive has been collected for the purposes of
        prosecution, it is less likely to include defence
        material, if I can put it like that?
   A.   Well, you can use this material in different ways.  I do
        not say that they had a complete set of documents from the
        Russian archives.  It is certainly a selection.  I did not
        select it.  I do not know who selected it and who made the
        decision about this, so I should be very careful to make a

.          P-18



        comment on that.
   Q.   You would always bear in mind using such archives that you
        are only seeing one side of the picture and not
        necessarily the other side?
   A.   I think it is difficult to say because they were
        interested.  They did a lot of work in this Zentralestelle
        during the 1950s and 60s, and they actually had historical
        expertise there because they actually worked on the
        historical background.  I would not say that they were
        only interested in this aspect of prosecution.  I think
        they had to collect the historical expertise which was not
        available at this time and could not be provided by
        historians.  So I would be cautious to make such a
        statement about this collection.
   Q.   I see on page 5 of your report that you are an expert, or
        you have written about the Wannsee conference?
   A.   Yes, I gave the annual lecture in 1998 at the Haus of the
        Wannsee conference and this published as a booklet.

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