Archive/File: people/i/irving.david/libel.suit/transcripts/day021.02 Last-Modified: 2000/07/24 Q. Did you look in the equivalent collections which are in the Federal archives in Koblenz? A. I believe we did, yes. Q. Did you also look not just at the collections of documents which were in Munich but also at the collections of correspondence that I had donated to the Institute of History in Munich between myself and, for example, Adolf Hitler's private staff? A. I think we did, yes. We looked at as much as we could find in the time available. Q. The time available was 18 months, is that right? A. To write the whole report, yes, of which this is only one chapter. Q. You had a large number of people, or relatively large number of people, working on your staff? A. Two. Q. It was probably several man years. A. Two. I had two people, Mr Irving. Q. Again, it was several man years in the compilation of these particular aspects? A. Well, not really, no, because everybody of course had other things to do at the same time. None of us was working full time on this. Q. Yes. Do you think that any documents in my collection would have eluded your attention, or your researchers' . P-10 attention? A. I hope not, but it is always possible. Q. It is always possible. So, although it is possible that some of my documents on which I base my book may have eluded your attention, you quite boldly used these very repugnant words about my writing, about having distorted, manipulated and had no possible evidence, and this kind of thing? A. If you can show me that there are important documents in your collections which run against what I have said, then obviously I will accept it. I said I hoped that important documents did not elude our attention, and I have based what I say here and what I write here on the most thorough possible research in the time available. Q. On balance, you disapprove of my method of relying to any great degree on the statements made either to me or to postwar investigators and historians and interrogators by the members of Adolf Hitler's private staff, is that correct? A. We have been over this ground, Mr Irving. Q. Well, let us go through it again. A. This is later testimony, sometimes given many years after the event, and therefore has to be treated with caution on those grounds alone. Other things being equal, as it were, one gives somewhat greater weight to contemporary evidence such as the Goebbels diaries. And, in addition . P-11 of course, we have already discussed this, members of Hitler's entourage had good reason not to tell the whole truth. Q. You say that you attach great importance to Goebbels' diaries. Would you look at footnote 2 on page 233 of your report, please? You list there a number of these books that are on your shelves in your book lined cave where you do your writing, if I can put like that. Do any those books show any sign of having used the Goebbels diaries? A. I do not think that is a very fair question, Mr Irving. The point here is simply that I am introducing the section on the Reichskristallnacht. I say in sentence to which that is a footnote: "The episode is well-known to historians. There have been many important and scholarly studies based on a painstaking examination of the original archival documentation. These include two accounts by staff members of the Institut fur Zeitgeschichte in Munich and other detailed studies", and so on. This is simply an indication to the court of the fact that this is a well-known episode about which historians are writing. Q. Do you accept that every single item you refer to on that page, including all the books and all the well-known studies, and the work of historians at the institute, all emerged before I brought back the Goebbels diaries from Moscow relating to precisely this episode? Therefore they are, to that degree, superseded, they are old hat? . P-12 A. I would not describe them as old hat, Mr Irving, and in any case the point I am making there is that this has been the subject of many studies over many years. This is not something that has suddenly emerged into our knowledge with the Goebbels diaries. Q. Now, you have relied in your footnote 1 on Hermann Graml (who I know personally). He wrote that book in 1956, did he not? A. Indeed, yes, that is right. Q. Are you aware of the fact that I submitted my entire chapter on this Reichskristallnacht to Hermann Graml for his, not clearance, but for his edification and for him to comment on at the time I wrote the book? A. No, I am not, no. Q. But would you have expected to find that in the correspondence put before you in the discovery process? A. I did not, no. If it is there, it is there. You can show it to me. Q. Again the second source in footnote 1 is 1957 which is, what, 33 years old? A. Indeed. I am trying to establish here, Mr Irving, the fact that this is a well-known episode in history which has been studied over many years by many historians. I am not saying that all these books are absolutely right or that they are the last word or that they are up-to-date. I am saying they are works by scholars which in their day, . P-13 if you like, were advances of knowledge. Q. And these scholars have nothing to learn from us revisionists then? A. It depends what you mean by "revisionists". Q. If somebody brought back from Moscow the Goebbels' diaries, would that not be a contribution to the historical debate? A. That is something different. You do not have to be a revisionist to bring back the Goebbels diaries from Moscow. MR JUSTICE GRAY: Mr Irving, I expect you will come shortly, will you not, to what it is in Goebbels diaries that you say casts important light on the events of Reichskristallnacht? MR IRVING: I am laying the groundwork for the cross-examination, my Lord. I am establishing what this expert's credentials are for this particular matter. Professor Evans, you have worked for five years in Germany? A. On and off over a period of about 30 years, yes, if you totted up all the times I had been there, I have not done it, but it would come to, I do not know, five, six years. It is difficult to say. Q. But do you think that your knowledge of German is sufficient to understand all the vernacular and all the slang phrases and all the nuances? . P-14 A. Mostly, yes. I would not say it was absolutely perfect. It is impossible for any foreigner to enter totally 100 per cent into the inside of a language. Q. Would you say that I having worked in Germany for 39 years on and off would have possibly a better knowledge of German than yourself? A. It is possible and I do not dispute the fact you have a very good knowledge indeed of German, Mr Irving. Q. Is it right that the sources that you have relied upon by way of preference are largely war criminals who were properly convicted at Nuremberg and elsewhere for their activities, whereas not one of Adolf Hitler's personal private staff was ever convicted as a war criminal? A. No, I do not think that is true. Q. Which part is not true, that not one of Adolf Hitler's staff ---- A. No, no. The fact that I have relied on these sources and in any case that -- I mean, relied, for example, on the Goebbels' diaries. Q. Was Karl Wolff a war criminal? A. He was sentenced in 1964. Q. Was Max Jutner a war criminal? A. Now, I am not sure, but in any case the point here --- - Q. I am just commenting on the odd feature that you rely on Nazi war criminals and ---- A. You will have to point out to me, Mr Irving, where I rely . P-15 on the testimony of Max Jutner, and so on. MR JUSTICE GRAY: I think, if I may say so, that is an entirely fair observation. I quite understand the criticism. You are saying he has relied on convicted criminals for -- -- MR IRVING: In preference to people who have not got a criminal record. MR JUSTICE GRAY: --- his contentions. But let us get to the nitty-gritty of it. I think that is what the witness is saying and I think it is a fair point, if I may say so, Mr Irving. Where does he rely on Wolff? MR IRVING: It is a comment on the quality of sources, my Lord, and the quality of sources is very important, particularly in a matter like this. MR JUSTICE GRAY: I quite agree, but this point only has any impact if you show me where he relies on Wolff or whoever ---- MR IRVING: It is where I rely on rather than where he relies on, my Lord, which we are now going to come to. Would you look at the little bundle of documents which was handed to you this morning which begins with the word "Deckblatt", "Sammlung Irving Deckblatt", do you find that? A. Yes. Q. If you would just briefly scan it you, would you agree that this appears to be the covering sheet of a file of documents relating to one Wilhelm Bruckner? A. That is right. . P-16 Q. Do you know who Wilhelm Bruckner was? A. He was the head of Hitler's, a sort of personal or adjutantur in the 1930s. Q. He was dismissed in ---- A. '40. Q. --- humiliating circumstances in December 1940, is that correct? A. Yes. He was also a senior officer of the SA, the brown shirts, and he was an old Nazi -- he seems to have been already active before 1923. Q. Yes. So that he was Hitler's chief person adjutant at the material time, namely the Reichskristallnacht? A. That is right. Q. In November 1938? A. Yes. Q. From this covering sheet, it is evidence that I collected a number of papers and manuscripts and affidavits and letters from him? A. That is right. Q. In fact, this collection was obtained by me from his son, Manfred, in March 1971 and, as was my way, I denoted all these documents to the Institute of History in Munich? A. Yes. Q. Did you find this file of documents? A. Now, what we found was a summary of a statement by, I mean, you are referring here to page 252 of my report, . P-17 is that correct? Q. I am asking you just about this one document in front of you at present about the Irving collection? A. Well, yes, but Bruckner is dealt with on page 252 of my report, and I think we should really look at that to get the context. Q. No, I am asking you to answer my questions first please which is ---- A. I am trying to point out the context here. Q. --- have you bothered to find the Bruckner papers on which I relied in writing this passage? A. Well, now, we tried to chase up a reference of yours which was very difficult to find in the Institute for Contemporary History, and the only thing that we could find, because you did not point very carefully to it, was a summary statement of what Bruckner said. Q. So the answer to my question is, no, you did not find the file of Wilhelm Bruchner papers of which this was the covering sheet? A. This "Deckblatt" here. Q. Yes, but this covering sheet was actually brought to your attention, was it not? It was part of my discovery along with 500 other such covering sheets? A. It is just a covering sheet, Mr Irving. Q. Yes, but in the discovery there were 500 such covering sheets, there were 500 collections of documents that . P-18 I gave to the Institute of History, and this was one of them, and it was copied by the instructing solicitors so you were aware that this file on Wilhelm Bruckner existed in the Institute and yet you did not find it or use it? A. Well, what does it say? Let us have a look at the description under No. 1: "Brief description" -- I am translating here [German- documents not provided]. "Documents from the"... Q. "Wilhelm Bruchner papers"? A. "Papers of Wilhelm Bruchner, herein [German] ---- Q. In other words ---- A. "Declaration on oath 3749 on [German] SA on Adolf Hitler. Notice notes on the [German] Putsch 1934. General religious considerations and" ---- Q. "Clemency" ---- A. --- "clemency" ----
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