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MR JUSTICE GRAY:  No.  Are you suggesting that the true meaning
  of this passage is that Heydrich is proposing that there
  should be -- all right, outside the Nazi empire -- the
  seed of a new Jewish regeneration?  Is that what you are putting?
MR IRVING:  It is, because on February 4th 1942, which is only
  a week or two later, Heydrich, speaking in Prague,
  actually spoke again of the white sea option.  He said
  nothing about the mass annihilation of the Jews.  Are you
  familiar with the book by Gotz Aly?
A.  Yes.
Q.  Final Solution, Nazi population policy, and the murder
of

. P-174



  the European Jews.  He prints extracts from this speech by
  Heydrich in Prague, does he not, February 4th 1942?
A.  Yes, but Aly is of course----
Q.  He says nothing about mass annihilation of the Jews.  He
  reiterates the white sea option, which involves sending
  the Jews to form a Russian concentration camp and says
  that this area will form an ideal homeland for the
  European Jews.  Are you familiar with that passage from
  Gotz Aly?
A.  Yes.
Q.  You have not mentioned it, have you?
A.  No, but Gotz Aly is among those who actually suggest in
  the book that the decision to carry out the Final Solution
  was taken in October 1941.  You quote him completely
  against his own intentions.
Q.  I am allowed to, am I not?  Historians are allowed to take
  pieces out of other people's books that do not necessarily
  fit in with the----
A.  Yes, but you have also to read his interpretation of this
  sentence which does not go along with your interpretation.
MR JUSTICE GRAY:  Dr Longerich, can you just go back to what
  I believe is the suggestion as to what Heydrich was
  proposing at Wannsee.  Leave aside what happened later.
  Would you comment on Mr Irving's proposition?
A.  Yes.  I think this passage makes it quite clear what
  Heydrich's intentions are.  He says that the Jews will be

. P-175



  led into the East in large labour gangs, segregated
  according to sex.  Thus Jews fit for work will be let into
  those areas, whereby, no doubt, a large part will fall out
  by natural elimination.  So they will die by hard labour,
  diseases and so on.  The remainder who will survive, and
  they will certainly be those who have the greatest power
  of endurance, so they are fit to survive, will have to be
  dealt with accordingly.  Again the German phrase here is
  "entsprechend behandelt werden mussen".  This is a
  typical phrase used by the SS, they have to be
  liquidated.  Then, because, if they were released, in
  contrast to Heydrich's intention, there would be a
  selection of the finest and could form the seed of a new
  Jewish regeneration.  This is exactly what Heydrich of
  course wanted to prevent.  He did not want to see after
  this ordeal a new generation of Jews in his empire.  In
  the Wannsee protocol there are also other references,
  I think, and other passages which make it quite clear what
  the intention was.
MR IRVING:  At the end of that passages does he also have a
  passage in brackets which you left out, "see the lessons
  of history"?
A.  Sorry?  Here in the text I left something out?
Q.  "als Keimzelle eines neuen judischen Aufbaues anzusprechen
  ist".  Then there is another passage in brackets which you
  left out, is it not, in that paragraph, "see the lessons

. P-176



  of history"?
A.  The lessons of history are we do not want to see actually
  Jews regenerate from such a catastrophe any more, we want
  to kill them all.  By the way, the logic of this sentence,
  this idea to lead large labour gangs into the East and to
  have them diminished by natural selection, and then to
  deal with the survivors, what about the people who are not
  fit for work?  He does not say that.  What about the
  children and the mothers?  What is he going to offer for
  them in the context of this speech?
Q.  You say that what Heydrich was saying in Prague on
  February 4th 1942, just a few days later, has no bearing
  on this, that he makes no mention of mass annihilation,
  and he is talking about the white sea option and using the
  Russian concentration camps, which are now emptied of
  course, to house the Jewish emigres.  What is this, just
  window dressing?
A.  They are speaking here about the coming Final Solution, so
  it has not started yet.  It will start in May 1942.
MR JUSTICE GRAY:  Who was Heydrich speaking to in February
  1942, Dr Longerich, do you know?  Do you know, Mr Irving?
  May I enquire of you?
MR IRVING:  I am just checking on the source, Gotz Aly.
MR JUSTICE GRAY:  Sorry, do not worry.
MR IRVING:  A secret address by Heydrich on February 4th 1942
  in Prague, page 174 of Gotz Aly, the Final Solution.  That

. P-177



  is the only reference that I have for that.
A.  Again, one should see the whole document.  Secret address
  to whom?  I would like to see the full text before I could
  comment on that.
Q.  He was not speaking to the Boy Scouts and the Brownies,
  was he? He was obviously speaking to people who----
MR JUSTICE GRAY:  I do not think I have seen any transcript or
  note of what he said on February 4th.
MR IRVING:  I will obtain it, my Lord.  That is all I can say.
  The whole passage.
MR JUSTICE GRAY:  Would you mind?  Thank you.
MR IRVING:  It does seem important because of the value one
  learns from it to place on the Wannsee conference.  Can
  I just ask, or re-ask, one or two questions about the
  Wannsee conference?  There is no specific mention of
  killing.  You have once again to interpret, you have to
  read between the lines?
A.  Yes.  Again, I tried to show you this here.  If you go to
  the end of the minutes, it is, I think, quite clear.  If
  you look at the remarks of the Secretary of State of the
  Generalgouvernement, I quoted this in my report, it is
  page 64, the last paragraph:  "In the concluding
  discussion different possible solutions were talked
  about.  Gauleiter Dr Meyer (the representative of the
  Ministry for the occupied Eastern territories) as well as
  Staatssekretar Dr Buhler, Secretary of State of the

. P-178



  Generalgouvernement, represented the position that certain
  preparatory measures in the course of the Final Solution
  should be carried out in the relevant areas themselves,
  whereby, however, the disquieting of the population must
  be avoided."
Then the Wannsee protocol makes clears that they
  were talking about the different solutions they were
  suggesting here.  So what they are doing is they are
  saying, well, we cannot wait until the Final Solution is
  coming, we want to start with it now.  So they are trying
  to exempt the killing operations against the Polish Jews
  and the Soviet Jews from this coming Final Solution.
Q.  These preparations that might have upset or caused unrest,
  would it be things like drawing up lists of people to be
  deported?  Would that have caused unrest?
A.  No, the preparatory measures are the building of killing
  installations.
Q.  How do you know that?
A.  This is my interpretation.
Q.  Your interpretation?
A.  From the text and from what happened.  They started to
  build a couple of weeks later Sobibor, they started to
  build Treblinka and they built gas chambers in Auschwitz.
  As I said, well, they prefer to use a camouflage
  language.  We also have the statements by Eichmann in his
  trial when he said at the Wannsee conference they spoke

. P-179



  quite openly about killing and different ways of killing.
  I think this is here the passage he is referring to.
Q.  You are saying that making the preparatory measures in the
  relevant areas might disquiet the population.  Why would
  creating killing installations in Poland, or wherever the
  killing is going to be done, upset the population who are
  going to be rounded up and shipped off to them?
A.  I think the fact that they were going to establish
  extermination camps would upset the local population.
  They would not like it.
Q.  Is it not far more likely that the preparatory measures
  that they are talking about are things as I mentioned,
  like rounding up or listing or drawing up black lists of
  people to be deported, making all the necessary transport
  preparations, word of which would get out and what would
  happen then would be the same as happened in Rome, where
  they start off with 8,000 and only manage to get their
  hands on 1,000?
A.  I think we have to go back to the text here.
Q.  Well, can I take you now to paragraph 3 of that page, 61?
  I am going to suggest to you, Dr Longerich, they are
  talking about the Final Solution as is going to be
  implemented after the victory, is that right?
A.  No, definitely not.  It is saying here in the -- it says
  in the -- really, it is a pity that we do not have the
  full text here ----

. P-180



Q.  Let me draw your attention to the last sentence.
MR JUSTICE GRAY:  Let him finish the answer.
A.  We have a clear indication in the text that they are
  expecting the beginning of the coming Final Solution in a
  couple of months, because it is said here in the text:
"The timing for the start of the individual large scale
  evacuation actions will be largely dependent on military
  development".  So they ----
MR IRVING:  "And could only be fully realized after a German victory"?
A.  Is it in the text?
Q.  Yes, your paragraph 3.
A.  Well, I am sorry but ----
Q.  That is the question I asked you ----
A.  Well, just a moment ----
Q.  At the end of paragraph 3.
MR JUSTICE GRAY:  You are talking over each over.
A.  Just a moment.  I am not quoting from the minutes of the
  Wannsee Conference where it clearly said that this
  deportation could start after the military developments
  would allow that.  This is in a couple of -- from their
  perspective, is a couple of months.  The whole operation
  could, of course, only be, could only be carried out, the
  whole operation, they talking here about the killing of 11
  million Jews, including British Jews, Turkish Jews, Swiss
  Jews, and so on.  So the whole operation could, of course,

. P-181



  only -- it is a question of logic -- only be dealt to a
  full extent after the war because the precondition of that
  is, of course, that they had to win the war.
MR IRVING:  Precisely.
A.  But the text gives us a clear indication that they are
  bound to start this.  They are just waiting.  They say:
"As soon as the military, as soon as the military
  situation improves, we will start that" and in the end it
  becomes clear from the comments of Buhler and Meiyer that
  they cannot wait.  They want to start preparatory measures
  on the spot and ----
Q.  So the answer to my question is, yes, this comprehensive
  plan was only going to be implemented after final victory?
A.  To a full extent, but they were quite prepared and were
  quite keen to start it as soon as possible, as soon as the
  military situation would allow it to start it.
Q.  Because if you look further up that paragraph, it says
  they are going to get their hands on those, the Jews,
  outside Germany, in Great Britain, Ireland, Portugal,
  Sweden, Switzerland, Spain and Turkey.  Now, how are they
  going to do that, except by some kind of peace treaty?
A.  I think I have made my point quite clear.
MR JUSTICE GRAY:  I think you have, but can I just ask you this
  and see whether I am taking a bad point.  The bit of
  Heydrich that you quote at the foot of your page 61, says:
"Under the appropriate direction, the Jews shall now be

. P-182



  put to work in the course of the Final Solution", and so
  on.  The word in the German text is "nun"?
A.  Yes.
Q.  Is he contemplating there that the work gangs of those fit
  enough to work will be got together straightaway?
A.  Yes.
Q.  And that does not wait until the end of the war or
  anything of that kind?
A.  Exactly.  The "now" is another confirmation that it will
  start very, very soon -- as soon as the military situation
  allows that.
MR IRVING:  The entry was, as you say, on paragraph 4:
"Initially, the Jews were going to be brought to
  'transit-ghettos in order to be transported from there
  further to the East'."
A.  Yes, before they could start the coming Final Solution.
Q.  But they could not do the whole job though until the war
  was over and they could sign the peace treaties with
  Britain and the rest of the countries?
A.  Well, I make my point quite clear, I think.  I disagree
  with that and now I give you one, I give you one quotation
  and there is another quotation, the word "nun" indicates
  that it would start very, very soon -- now actually.
Q.  Part of it starts now, but the final Final Solution is
  going to be after the war?
A.  No.  I do not want to repeat myself.

. P-183



Q.  Well, my Lord, there is an important corollary, it now follows?
A.  I do not want to repeat that.  I made it very clear that
  I quoted now again and again this quotation here ----
Q.  Yes, but can I now put the ----
A.  --- that "The timing for the start of the individual large
  evacuations action will be largely dependent on military
  developments".  So as soon as the military situation will
  improve, they will start it and they actually started it
  in a couple of month.
Q.  Can I now put the final question in this particular
  context which is this.  If peace broke out and all the
  Jews of Europe started rolling eastwards into these camps,
  these transit camps, set up by the Germans, what could the
  Germans do with them in peace time?  They could not run
  the gas chambers, could they?  They could not have these
  huge extermination operations in peace time, could they,
  because that kind of thing people get attention of in
  peace time.  You can do things in war time that you cannot
  do in peace, is that right?
A.  You are talking here, you are assuming here, a total
  victory of Nazi Germany in World War II, and I can imagine
  that in this case they would be able to carry out whatever
  they want to do in Europe.
Q.  They are obviously assuming a total victory; they are
  going to get their hands on Britain's Jews and even the

. P-184



  Irish ----
A.  Yes, of course.
Q.  --- not to mention Portugal, the Swiss, all of them?
A.  Yes.
Q.  So they are anticipating total victory, and yet when peace
  time comes, somehow they are going to keep these gas
  chambers and the whole paraphernalia of death clanking
  with nobody noticing?
A.  Well, they are under full, if they really had won the war,
  they were under full control.  There was nobody who could
  interfere.  Who could actually come and interfere and do
  anything about that?
Q.  It rather destroys the homicidal nature of the Wannsee
  Conference, does it not, the idea that it is all going to
  be put off until peace time, the final part of the Solution?
A.  I made it quite clear that i do not follow this, and what
  is said here that this operation to a full extent could
  only be carried out after the war.  So they would assume
  that they, if they had won the war they would starting to
  kill the British Jews, according to the minutes of the
  Wannsee Conference.  I think it is quite clear here.
Q.  Paragraph 5, line 4, you say that in the case that they
  should survive these trials and tribulations, they would
  be murdered.  That is just the spin you put on that "dealt
  with accordingly", right?

. P-185



A.  Yes.
Q.  Yes?
A.  That is true, yes.
Q.  Which might be a legitimate interpretation, but, of
  course, there might be other interpretations.  Do you accept that?
MR JUSTICE GRAY:  Such as?
A.  I think the text is quite clear.  They are talking here
  about killing.
MR JUSTICE GRAY:  What alternative explanation would you put forward?
MR IRVING:  Well, I did put this to the witness, my Lord.  Is
  it not possible that these ultrafit, able-bodied
  survivalist Jews had survived the whole of this appalling
  experience and emerged at the end of it, that, as Heydrich
  said, "We are going to have to deal with them separately.
  We are going to have to make sure they do not come back"?
A.  Well, I think the context makes it clear that Heydrich
  wants to avoid that these people are the seed of a
  regeneration of European Jewry.  I think from the context
  it is quite clear he wants to kill them in order to avoid
  that.  He is not talking about building up a kind of
  recreation camp or something in the East where they can,
  you know, regenerate and become the core of a Jewish
  nation or something like that.  I think the context is clear.

. P-186



Q.  Apart from Eichmann, have you considered the testimony of
  any of the participants in the Wannsee Conference?
A.  I think I have seen most of them, yes.

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