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   Q.   Very well.  The first page, page 1 -- I am looking at the
        big numbers at the bottom -- the ausrottung des Prostesten

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        tismus?
   A.   Your bundle, yes.
   Q.   It is my little bundle, yes.  This is 1900 ----
   A.   Yes.
   Q.   -- published by some church body, and it is about the
        ausrotten des Prostesten tismus in Salzburg?
   A.   Yes.
   Q.   Obviously, they are not talking about liquidating all the
        Protestants, are they?
   A.   I do not know, I mean, you know, in Germany in the 17th
        century, for instance, they had what they called religious
        wars and many people were actually ausgerot for religious
        reasons.  So if you give me a chance to find out whether
        this is about the 30 year war.
   MR JUSTICE GRAY:  It appears to be dated 1900.  I do not know
        whether the Gothic script means it is older than that.
   A.   It is written 1900, but is it not historical subject?
   MR JUSTICE GRAY:  Mr Irving, if I may say so, I do not think we
        will get very much help out of that.
   A.   I see.  It is about the church history of the 18th century.
   Q.   I am looking just at the use of the word, my Lord, and
        suggesting strongly that at this time they were not -- it
        is in close parallel to the phrase the ausrotten des Judentums?
   MR JUSTICE GRAY:  Yes.  I follow the point you are making, but

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        can one not put it this way?  Do you accept or not, I do
        not know, Dr Longerich, that you can use "ausrotten" to
        mean "rooting out".  It depends on the context?
   A.   I am not sure about "rooting out".  I think the meaning
        here of "ausrotten" is to wipe out, to get completely rid of.
   Q.   All right, wipe out?
   A.   This applies not to -- I do not know, I mean, I am not
        familiar with the -- I mean, if you give me the time
        I will try to do my best to get familiar with the history
        of the churches, of a church in Salzburg in the 19th
        century, I am not sure whether they kill anybody or so.
   MR JUSTICE GRAY:  Let us forget about ----
   A.   I think the term "ausrotten" applies to an organization
        which probably Protestentismus is here.  It does not
        necessarily mean that everybody who belongs to this
        organization is going to be killed.  You can also speak,
        I mean, today about "ausrotten" of criminality, for
        instance, if you mean, you know, that you get rid of this
        problem.  But I think what is more important is that, you
        know, it is more tricky when it comes actually to the
        ausrotten of human beings, then I think the meaning is
        quite clear, as far I see it.
   MR IRVING:  Can we now go to page 2 which is a 1935 Nazi
        reference to it, one which you have not adduced in your
        glossary.  This is a speech by Rudolf Hess on May 14th. My

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        Lord, the translation is the final paragraph on that page.
         "National socialist legislation", the actual phrase which
        I am going to look at is "National Sozialische Deutschland
        des Judentums etwa richtiglos ausgerottet wurde".
   A.   Where is that?
   Q.   So there is a specific reference here to ----
   MR JUSTICE GRAY:  Fourth line?
   A.   Yes.
   MR IRVING:  --- the fourth line of the German.  Here you
        have: "National Socialist legislation has now introduced
        corrective measures against this overalienisation.  I say
        'corrective' because the proof that the Jews are not
        being ruthlessly ausgerottet", which I say is rooted out,
         "in National Socialist Germany, is that in Prussian alone
        33,500 Jews were working in the manufacturing industry,
        89,800 are engaged...", and so on.  So he is talking
        clearly there about rooting out, is he not, not about
        liquidating because this is 1935, no one is killing Jews
        at that time, are they?
   A.   I take your word that this is the authentical texts.
        I have not seen this document myself.  I do not know the
        context.  He is saying that the Judentum, which is
        probably the Jewry in this context, is not ausgerottet in
        1935, which is perfectly true, I think.  It is a
        preHolocaust document, I cannot see ----
   Q.   It is a Nuremberg document, is it not, if you look ---
-

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   MR JUSTICE GRAY:  But the point that is being put,
        Dr Longerich, is that "ausrotten" is being used there in a
        context which has nothing to do with extermination.  That
        is the only point that is being put.
   MR IRVING:  By a Nazi, in connection with the Jews?
   A.   Yes, so it is not the Jews, it is the Judentum, the term
        "Judentum" means here, let us say ----
   MR IRVING:  The Jewish community?
   A.   --- the Jewish community, the alleged social position of
        the Jews in Germany, their property, their wealth and so
        on.  So I think that, and so far the term means not only
        human beings, a collective, but it also means more than
        that, and in this sense the Judentum was not ausgerottet,
        so that is....
   Q.   The next page, Dr Longerich, on page 3 is the English
        translation, but you can look at the German, if you wish,
        which is on page 5.  This is on item that you yourself
        have adduced.  This is Adolf Hitler's use of the word
        "ausrottung" in 1936.  He is not talking about Jews, but
        it is the same word.  He is talking about the need for an
        economic four-year plan.  On page 3 he puts in this
        sentence:  "A victory of Bolshevism over Germany would not
        lead to a Versaille Treaty, but to a final destruction,
        indeed the ausrottung of the German nation", "volk".  Is
        Hitler saying that if the Bolsheviks succeed in war
        against Germany, they are going to exterminate the German

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        nation?
   A.   I am sorry.  Normally, I have more time to interpret
        documents than this one or two minutes.
   Q.   This is one referred that you yourself have referred to
        though, is it not, in your glossary?
   A.   So I just have to look at it because I quoted it myself in
        my own document, he goes then on and says after you stop
        here, "And if the ausrottung", he tries to explain what
        "ausrotten" means.  In English, it says here that:
         "After a Bolshevik victory, the European states,
        including Germany, would experience the most terrible
        catastrophe for its people since humanity was affected by
        the extinguishing of the states of classical antiquity".
        So I think if you say, "Well, this will be worse than the
        end of the Roman Empire", this statement involves clearly
        that this will be done in a very, that this ausrottung
        will be done in very cruel manner, it will cost a lot of
        lives.  I think this is implicit here in Hitler's words.
   Q.   But "ausrottung" here cannot be equated to the word
        "extermination", can it?  He is not saying, "If the
        Bolsheviks win in a future war, it will lead to the
        extermination of the German people", he is saying, "It
        will lead to the emasculation of the German people or the
        end of them as an important power in Europe"?
   A.   I would not agree because when he makes this reference,
         "It is more terrible than the end of the Roman Empire,

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        the states", he says.
   Q.   Yes.
   A.   Then it is quite something.  I mean, this is not just, you
        the Versaille Treaty, as he said.  It is not just the
        collapse of the German Empire; it is much, much more.
   Q.   Hunger, starvation and pestilence.
   A.   In a way, I am trying not to speculate what Hitler thought
        in 1936 what is actually more terrible than the end of the
        Roman Empire.  I think it is quite reasonable to assume
        that this kind of "ausrottung" would, as the end of the
        Roman Empire did, involve the killing of many, many people.
   MR JUSTICE GRAY:  Can you just for my benefit translate
        quickly, if you would not mind, the immediately following
        words, where he talks about what a catastrophe that would be?
   MR IRVING:  "The extent of such a catastrophe cannot be really
        imagined".
   MR JUSTICE GRAY:  Next sentence?
   MR IRVING:  "How the densely populated west of Europe,
        including German, would survive after a Bolshevik
        collapse, it would experience probably the most awful
        national catastrophe since the extinction of the antique
        states -- since the" -- it is a complicated sentence.
   MR JUSTICE GRAY:  It is a complicated sentence, but,
        Dr Longerich, it is all pretty apocalyptic stuff, is it

.          P-34



        not, that he is ----
   A.   Yes.  Exactly, and I think I translate it a little bit
        more, I said, "The most terrible catastrophe",
        "grauenhaft", I think is the word "terror" in it, and so
        it is ----
   MR IRVING:  "Awesome"?
   A.   I think it is more than that.
   Q.   Can I just ask you briefly about this document.  This is,
        of course, a document dictated by Adolf Hitler to his
        private secretary, is it not?  It is not a speech.  He is
        choosing his words carefully.
   A.   Yes.  I do not know whether he dictated this to his
        private secretary.  It is a document he provided for
        Goring.  It is an instruction for Goring to carry on
        with  ----
   Q.   Well, I know because Christa Schroeder told me he dictated
        it to her.
   A.   I am trying to explain this to the court.  It is the
        document which actually says that Germany should be able
        within four years to fight the next war.  So it is an
        instruction for Goring.  But I think if we go -- no,
        I cannot read more than that in this document.
   MR JUSTICE GRAY:  We have your answer about that document anyway.
   MR IRVING:  Yes.  Page 6, again we are still in 1936, but
        collection of documents published obviously by anti-Nazis

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        now about the expropriation, the humiliation and the
        vernichtung of the Jews in Germany ----
   A.   Yes.
   Q.   --- since the government of Adolf Hitler.  This time it is
        the word "vernichtung".
   A.   Yes.
   Q.   1936, of course, the Jews as such had not been vernichtet,
        had they, and yet this is a history of the destruction of
        the Jews?
   A.   I have to make here a general observation.  I just have to
        trust that this is all, you know, this is original.
   Q.   I have the original documents here.
   A.   And I always prefer to look at documents in the
        appropriate context, but, of course, it is possible that
        somebody in '36, and I think these are the Jews who
        emigrated from Germany, would use the term "vernichtung"
        in a sense that, you know, "vernichtung" there, you would
        use it in the sense that he would not refer to the actual
        killing of the Jews because the actual killing, as we
        know, did happen later on.  So I do not think how this
        document can help us to interpret or to put the Nazi
        terminology into the historical context.
   Q.   Yes, I agree.  It is a low grade document.  It is outside
        Germany but there is the phrase "vernichtung der Juden" in 1936.
   A.   Yes, and who actually published it, do you know that?

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   MR JUSTICE GRAY:  Let us move on.  It is a low grade document.
   MR IRVING:  The next one is high grade.  It is page 7, Walter Hewel?
   A.   Yes.
   Q.   Walter Hewel was a diplomat on Hitler's staff.  He was the
        liaison officer, von Ribbentrop, was he not?
   A.   Yes.
   Q.   H-E-W-E-L?
   A.   Yes.
   Q.   And he wrote a memorandum on the conference between Hitler
        and this Czech State president Hacha -- H-A-C-H-A -- on
        March 15th 1939, which is in the official published
        volumes, is it not, ADAP?
   A.   Well, again I cannot recall the document.  I just trust
        that this is correct what you are saying.  I do not have
        the ADAP with me and I do not have ----
   Q.   Well, if this is a fig quotation, no doubt, I will be shot
        down in due course by the Defence.  The phrase in German
        is [German - document not provided] which I will translate
        as "If in the a autumn of the last year, 1938,
        Czechoslovakia had not given in, then the Czech volk would
        have been ausgerottet?
   A.   Yes.
   Q.   What is Hitler saying there?
   A.   Well...
   Q.   Is it important, do you think, this use of the word here?

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   MR RAMPTON:  Do let him answer.  One question at a time.

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