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Last-Modified: 2000/07/25

   MR RAMPTON:  Do you know of any evidence -- this is getting a
        little bit of ahead of myself but I may as well deal with
        this part of it first -- Dr Longerich, whether eyewitness
        testimony or contemporaneous documents, whether clear or
        needing interpretation, that speak of large scale
        transports or deportations of Jews from the occupied
        Eastern territories further East?
   A.   At this stage, no.
   Q.   As a matter of practical reality, is there any evidence
        that it happened?
   A.   No.
   Q.   Do you take this document to be an indication that Himmler
        found the -- I think I have asked this already -- the
        administrative task of, I do not know how many Jews that

.          P-85y


        there were left in the occupied Eastern territories by
        this date, do you?
   A.   Definitely several hundred thousand.
   Q.   Right, presumably, they have got to go -- how Far East had
        the German Army got by this date?
   A.   Well, this was in summer 1942, they were in their, I think
        just started their summer offensive so they were quite,
        I mean, advanced, so they had large parts of Ukrainia, for
        instance, under their control.
   Q.   And they were pushing out as far as Koursk and Stalingrad,
        were they not?
   A.   Yes.
   Q.   In due course?
   A.   Yes.
   Q.   So there would have been plenty of room behind them to
        which to transport all the remaining Jews of the occupied
        Eastern territories, would there not?
   A.   Yes.
   Q.   But you know of no evidence that it ever happened?
   A.   No.
   Q.   Can we compare for a moment what Himmler wrote in that
        letter about the very difficult order that the Fuhrer had
        laid on his shoulders with what Mr Irving relies on as
        evidence of the truth, the historical truth, which is what
        Karl Wolff told Dr , I cannot remember, was it Fiegler or
        Ziegler?

.          P-86

   A.   Ziegler.
   Q.   Ziegler?
   A.   Ziegler, sorry.
   Q.   Von Ziegler in 1952.  Have you still got that German of
        that document ----
   A.   I hope so.
   Q.   --- with you?  It is on page 5 of the German and, my Lord,
        it is the fifth page of the English under the square
        bracket 00032.  Do you mind if I use the English of Mr Irving?
   A.   No, I do not have the -- I could not find the...
   Q.   You do not have the document.  I am sorry.
   MR JUSTICE GRAY:  Where are we going to put this?
   MR RAMPTON:  Day 2, tab 11, my Lord.  14A the page number is.
   MR JUSTICE GRAY:  That will do.
   MR RAMPTON:  It is one of the documents that was passed up this
        morning, I think.  It is only short.  In your German
        version, Dr Longerich, it is the second paragraph on page
        5 with page numbers at the top.  It is the sentence which
        begins "es war im August 1942".  Do you have that?  Page 5
        at the top or 00032 at the bottom.
   A.   Sorry, the German sentence begins?
   Q.   The German sentence begins "es war im August 1942".
   A.   Yes, I have the German sentence.
   Q.   Have you got that?
   A.   Yes.

.          P-87

   Q.   Do you mind if I read out the English?
   A.   No.
   Q.   But do follow it in the German because you can check the
        translation at the same time if you want.  "Around August
        942 GW", that is?
   A.   General Wolff.
   Q.   General Wolff, yes, I thought his name was Karl, I must
        say, "... General Wolff undertook drive from the Fuhrer's
        headquarters to Berlin.  He found Himmler there in a state
        of deep depression.  To General Wolff's questions as to
        what was up, Hitler dropped dark and vague hints.  Wolff
        could have no idea what one had had to take upon oneself
        for the Messiah of the next 2000 years" -- we can say that
        is Hitler, can we not?
   A.   Yes.
   Q.   "... in order that this man remained personally free of
        sin.  He, the Reichsfuhrer, was beyond mortal help.  For
        the sake of the German people and its Fuhrer, he had had
        to burden things on to his own shoulders of which nobody
        must ever be allowed to learn".  If you have to choose
        between a postwar interrogation of Karl Wolff, which
        resulted in that account, and the letter which Heinreich
        Himmler wrote to Berger at the time in 1942, which source
        do you prefer?
   A.   I would prefer contemporary documents like this source.
   Q.   Then, finally, there is one other document in here that

.          P-88

        I would like you to look at.  It is the next document on
        from the Himmler to Berger in the main blue file?
   MR JUSTICE GRAY:  This is part of the same sequence,
        Mr Rampton, is it?
   MR RAMPTON:  It is, my Lord.
   MR JUSTICE GRAY:  Because I want to ask something after you
        have finished.
   MR RAMPTON:  Absolutely.  Then I am coming to the Furl letter
        in a moment.  Do you see that this is some kind of a copy
        of a letter written by somebody called Guntzen Muller to
        Karl Wolff on the same day, 28th July 1942, is it?
   A.   Yes, that it is in front of me.
   Q.   Does it recount that 5,000 Jews are going every day from
        Warsaw to Treblinka and twice a week 5,000 from a place
        whose name I cannot pronounce, it is something like
        "Schimmel" to Belzec?
   A.   Premisul(?) to Belzec, yes.
   Q.   To Belzec.  So that is a total of 45,000 a week, you can
        take it from me, at that time.  That has been going on,
        has it not, since 22nd July 1942?  Yes?
   A.   Yes, this is clear from this letter.
   Q.   Then does the last part of the letter tell us that in due
        time, I think in October, transports will go from Warsaw
        via Lublin to Sobibor?
   A.   Yes.
   Q.   Yes.  They do not tell us in what quantities, do they?

.          P-89

   A.   No, because they are just working on the track, on the
        railway track.
   Q.   On the track, yes.  The transports are held up from the
        track.  But assume for a moment that that little
        collection of documents is evidence of a massive
        extermination programme underway at the General Government
        and in the occupied Eastern territories, that Himmler is
        in charge of it, and we have seen the contacts between
        Himmler and Hitler during this time.  How credible does it
        seem to you that Hitler, Himmler's old chum, Hitler, did
        not know what was going on?
   A.   Well, I find this absolutely incredible that he should not
        have known that.
   MR JUSTICE GRAY:  Can I just ask you a question because I am a
        bit puzzled at the moment.  Your evidence is that the
        order that Hitler gave Himmler related to the Jews in the
        Ostgebiet?
   A.   Yes.
   Q.   And they accounted for, I think you said, about 600,000
        out of about two and a half million?
   A.   Yes.
   Q.   The thing that is slightly going through my mind at the
        moment is, well, that leaves a bit of  question mark over
        the remaining, whatever it is, 1.9 million.
   A.   Sorry, you are referring to?
   Q.   To the Jews who were in the General Government?

.          P-90

   A.   Yes.
   Q.   But not in the Eastern territories?
   A.   Yes.
   Q.   What was the position, as far as they were concerned?  Is
        there any evidence one way or the other?
   A.   I am sorry.  I am not sure whether I could follow the question.
   MR JUSTICE GRAY:  No, I think you have not followed the
        question.  Perhaps I did not put it very clear.
   MR RAMPTON:  My Lord, perhaps I could deal with it?
   MR JUSTICE GRAY:  Yes, all right, do.
   MR RAMPTON:  Undoubtedly I see the question that your Lordship
        has asked.  Himmler's letter to Berger deals with the Jews
        in the occupied Eastern territories, in other words, Russia?
   A.   Yes.
   Q.   And they have to be cleared by the end of the year?
   A.   Yes.
   Q.   These trains which we are talking about here in the letter
        from Guntz Muller to Wolff are not Russian Jews at all?
   A.   No, this is the Generalgouvernement, Poland.
   Q.   This is the General government?
   A.   Yes.
   Q.   And they are going variously in, one might think, rather
        large numbers from Warsaw, this place Premisul, and so on
        and so forth, to the three Reinhardt camps?

.          P-91

   A.   Yes.
   Q.   Treblinka, Belzec and Sobibor, are they not?
   A.   Yes.
   Q.   My question is where were they going?
   A.   Well, they would be deported to these camps, to the
        extermination camps, and would be killed there.
   Q.   Do you know of any evidence that any of those three camps
        was at any time a work camp?
   A.   No, this is particularly, these were particular
        extermination camps, very small camps, only one purpose,
        to kill as many people as possible in a very short time.
   MR JUSTICE GRAY:  That does not though actually quite meet the
        point that I was trying to put.  I will try again.
   MR RAMPTON:  I am sorry.
   MR JUSTICE GRAY:  Well, it does partially.  We are concerned in
        this aspect of the case really very much with what Hitler
        knew and authorized.  You have been taken through a series
        of documents which you have given evidence establishes to
        your satisfaction at least that Hitler did order Himmler
        to free the Ostgebiet of Jews by, as Mr Rampton says, the
        end of December 1942.
                  My question really related to the vastly greater
        number of Jews who were at that time in the area of the
        General Government, and what I was really seeking to ask
        you is do you have any knowledge of any documents or are
        there any inferences that one can draw as to what Hitler

.          P-92

        said, if anything, about what was to be the fate of the
        Jews in the General Government?
   A.   We do not have the same document for the General
        Government.  We have this document for the 28th July, but
        not a comparable document for the Jews of the Generalgouvernement.  So we are relying here on a
        construction, a reconstruction, of events and, as
        Mr Rampton has, I think, lead me through these documents,
        it is clear that we have a number of important meetings
        between Himmler and Hitler, and right after these meetings
        Hitler, sorry, Himmler gave the order to make the
        Generalgouvernement of Judenfrager until the end of the
        year.  So we do not have the same kind of documentation
        for the Generalgouvernement.
   MR IRVING:  My Lord, there is, of course, the 22nd September
        1942 handwritten document, "Judenfrage dies wie wir
        weiterfahren", how shall we continue, "Auswanderung", the
        Himmler and Hitler plan, 108.
   MR JUSTICE GRAY:  I appreciate you say they were going to be
        dealt with differently, but, I mean, can I ask the
        question that was in my mind anyway to ask, which is would
        you think that it is a legitimate inference or not from
        the fact that there was an expressed Hitler order in
        relation to the Jews in the Ostgebiet that may be the
        position was in some way different with regards to the
        Jews who were to the West of them?

.          P-93

   A.   No, we only have this, we have this reference by Himmler
        by chance because he wrote this letter to Berger.  We have
        not, we have not got the full correspondence of Himmler,
        so it is impossible to answer this question really.
   MR IRVING:  The note I referred to is page 274 of this blue bundle.
   MR JUSTICE GRAY:  Thank you.
   MR RAMPTON:  I do not want to be -- for once in my life, I will
        not be diverted if it is all right.
   MR JUSTICE GRAY:  It was not intended to be a diversion.
   MR RAMPTON:  No, no, no, by Mr Irving, I meant.  It was not
        intended as a diversion, of course not, but I will not go
        to that document at the moment.
   MR IRVING:  I was trying to be helpful.
   MR JUSTICE GRAY:  No, I meant that was not intended to be a
        diversion by me which you may or may not accept.

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