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Last-Modified: 2000/07/29

   Q.   -- Rosenberg was perhaps, I do not know.  Is there
        anything you know of that prevents one from supposing
that
        Hitler might have telephoned as he apparently was able
to use the telephone on the train, was he not?

   A.   Himmler, you are talking about?

.          P-36



   Q.   Himmler I mean, telephoned the Wolf's Lair and said
"can
        I come and talk to you about something"?
   A.   No reason to suppose that at all, yes.
   Q.   So why you do use the word "summon"?
   A.   Because then Hitler would have said "all right, come
and
        see me".
   Q.   You see in the context, do you agree, the word
"summoned"?
   A.   Yes.
   Q.   Means that he is being summoned in order to discuss
the
        fate of the Berlin Jews?
   A.   In the context.
   Q.   Yes.  Amongst other things, perhaps?
   A.   No, I disagree with you Mr Rampton, on November 30th,
he,
        Himmler was summoned to the Wolf's Lair for a secret
        conference with Hitler at which the fate of Berlin's
Jews
        was clearly raised.
   Q.   By whom?
   A.   We do not know.
   Q.   Then you go on, at 1.30 p.m. Himmler was obliged to
        telephone from Hitler's bunker?
   A.   Yes.
   Q.   Who could have obliged, that is to say compel, Himmler
to
        do such a thing?
   A.   His own inner conscience.
   Q.   That is what it was, was it?
   A.   That is why I used word "obliged" otherwise I would
have

.          P-37



        said "ordered".
   MR JUSTICE GRAY:  The reality of the way, would you not
        accept, Mr Irving, of the way it is put in your book
is
        that the reader is going to infer that that was an
order
        from Hitler to him?
   A.   My Lord, I use my words with utmost care when I write
        passages like that. I will go backwards and forwards
over
        them looking for a word which I considered to be
justified
        by the evidence but not implying or imputing or
inferring
        too much.  If I used the word "obliged" then it was
        because I hesitated to use the word "order" but for
some
        reason he made the telephone conversation.  He did not
        wait until he got back to his own headquarters, he
        immediately phoned Heydrich from Hitler's bunker
without
        even getting over to the local phone box, he phoned
        Heydrich with these instructions saying "stop the
        killing".
   MR RAMPTON:  That is what you intended to convey in that
        passage of that page of Hitler's War 1977?
   A.   That is all that I felt it was safe to convey on the
basis
        of the very skimpy evidence I had at that time.  At
that
        time, of course, I did not even have the decodes, but
now
        the decodes confirm me.
   Q.   So you say.  Let us turn to page (xiv) of the
introduction
        to this book, may we?
   A.   Yes.

.          P-38



   Q.   Perhaps for completeness start at the bottom of page
        13: "Many people, particularly in Germany and Austria
had
        an interest in propagating the accepted version of the
        order of one mad man originated the entire massacre."
We
        are talking here about Holocaust in the old sense,
old, in
        the Irving history.
   MR JUSTICE GRAY:  I am so sorry, Mr Rampton, I am lost,
page
        13.
   MR RAMPTON:   (Xiii) of the introduction.
   MR JUSTICE GRAY:   Thank you.
   MR RAMPTON:  I will start again.  Last two lines bottom of
page
        13: "Many people, particularly in Germany and Austria
had
        an interest in propagating the accepted version that
the
        order of one mad man originated the entire massacre."
That
        is to say the massacre of the Jews, those are my
words, my
        Lord.  "Precisely when the order was given in what
form
        has admittedly never been established.  In 1939?  But
the
        secret extermination did not begin operating until
        December 1941.  At the January 1942 Bunzig conference?
        But the incontrovertible evidence is", note those
words,
        Mr Irving, in the light of your recent answers, "the
        incontrovertible evidence is that Hitler ordered on
        November 30th 1941 that there was to be 'no
liquidation'
        of the Jews (without much difficulty I found in
Himmler's
        private files his own handwritten note on this)." In
the
        light of that, Mr Irving, would you care to revise the

.          P-39



        answers you gave a moment ago?
   A.   No.
   Q.   Well, what do those words mean?  Do they speak for
        themselves or do they not, that I have just read?
   A.   I have done exactly what any normal editor would do,
you
        present the evidence and then you draw conclusions.
        I present the evidence in the body of the book.  I
even in
        this one case print a facsimile of the document which
is
        pivotal to this particular argument and then in the
        introduction (as a good author should) I put my
principal
        conclusions.  Here I am putting my principal
conclusion as
        the author, David Irving, that I draw the conclusion
from
        this episode that Hitler had intervened to stop -- and
        here is the error, the liquidation of the Jews.  What
        I should have written is "the liquidation of a
transport
        of Jews".  That was the state of my knowledge at the
time
        I wrote this version of this book. Subsequently of
course
        I amended it.
   Q.   I think you told me yesterday that the only evidence
you
        had for the order of Hitler was that Himmler was there
at
        the time?
   A.   The only evidence that I had for an order of Hitler?
   Q.   Yes, was that Himmler was at the Wolfsschanze at the
time?
   A.   I think we would have to see exactly what I testified
        before I would agree to that brief summary.
   MR JUSTICE GRAY:  I think it is right, but if you want to
be

.          P-40



        referred to it then no doubt you should be.
   MR RAMPTON:  A summary?
   A.   I hate to agree with vulgarised versions of what I
        testified.
   MR JUSTICE GRAY:  Let us have a look and see what you did
say.
   MR RAMPTON:  My Lord, one could start at line 20 on page
285
        perhaps?
   A.   285?
   Q.   285, line 20, I am trying not to take too much of it.
        I suppose it really begins at line five on page 285,
but
        I hope I summarized it fairly?
   A.   I do not think you did, but I will certainly stand by
what
        I stated on those two pages.
   MR JUSTICE GRAY:  Look at line 286, line 3 and onwards.
   MR RAMPTON:   Yes, please.
   A.   This is the question, of course, and not the answer.
   MR JUSTICE GRAY:   Yes, but there is an answer after the
        question.
   MR RAMPTON:  At line nine there is an answer.
   A.   Yes.
   Q.   My summary was a fair one.  There is no evidence
beyond
        the fact that Himmler was at the bunker that day and
had
        lunch with Hitler an hour later, is there?
   A.   Evidence for what?
   Q.   For an order from Hitler that Jews -- that the train
load
        of Jews, let us stick with that for the moment?

.          P-41



   A.   This is --
   Q.   Should be not liquidated?
   A.   -- I do not mean this offensively, but this is the
common
        sense interpretation of the evidence lying before us,
        rather the perverse interpretation.  We will always
has
        versions or two interpretations, one is the obvious
one,
        which is -- and the other is the perverse one.  The
        obvious one is if Himmler goes to Hitler's
headquarters
        and is handed a phone at some time on his way out and
he
        then has to make phone call to Heydrich saying, "stop
        killing the Berlin Jews", then there is some close
        connection between that and the fact he has seen
Hitler
        that day.
   Q.   That is a possible interpretation, we in this court,
and
        I do not know about the court of history, we in this
court
        when we say "evidence" we mean "evidence" not
"inference".
   A.   The issues that are being pleaded are mistranslation,
or
        distortion, deliberately mistranslation, distortion,
        manipulation and I do not think that the particular
avenue
        we are going down leads in the --
   Q.   I will put it bluntly to you and then I will leave it,
you
        can deny it, because you will deny it, I am sure; (a)
you
        deliberately mistranslated it, you inflated from one
train
        load into Jews generally, that is number one; and (b)
you
        inserted an order from Hitler for which there was no
        evidence?

.          P-42



   A.   -- I will take those two allegations seriatim; that
        I inflated it deliberately, there is not a shred of
        evidence for that.  The evidence is quite clear, that
as
        soon as Dr General Flemming brought to me the evidence
        there was one train load of Jews which was in trouble
that
        day, I immediately and in subsequent editions of the
book
        revised it to the narrow interpretation of the word
        "transport" rather than the wider interpretation.
   Q.   And you are sticking with the Hitler order answer?
   A.   As being the reasonable rather than perverse analysis
of
        the documents at that time before us.  I emphasise of
        course it has now been very amply confirmed by the
        intercepts I read out in my bundle this morning.
   Q.   Very well, then, we must look at another document.
This
        is one of your documents?
   MR JUSTICE GRAY:  Before you do can I ask one rather
mundane
        question.
   MR RAMPTON:  Yes, of course.
   MR JUSTICE GRAY:  But I think you will understand why I ask
it,
        Hitler's headquarters or the Wolf's Lair, how big a
        building or collection of buildings was that?
   A.   At that time it was not a big formidable complex which
        exists today, huge concrete bunkers. There were one or
two
        air raid shelters, but it was mostly in the form of
wooden
        barracks scattered around in a compound of a 2 or 3
        kilometres area with minefields and forests.

.          P-43



   Q.   How many people would work there?
   A.   Probably in the order of one thousand people including
all
        the escorts and security.  It had various inner areas
and
        so called "sperrkreise", which were the security zones
and
        he was in security zone A.  But if it is ausdembunker,
        from the bunker, then it is from Hitler's bunker.
   MR JUSTICE GRAY:  By which you mean an office or --
   A.   No, Hitler --
   Q.   -- a part of the compound where Hitler was himself
based?
   A.   -- in the security zone A there was the bunker in
which
        Hitler resided, lived and conducted his conferences.
        Later on it was massively reinforced after the Allied
air
        raids started.
   MR RAMPTON:  This is all on the same topic, Mr Irving, so
that
        the document you are will next need is to be found in
        bundle D8(iii), somebody will give it to you (same
        handed).
   A.   Very well.
   Q.   The page I want is 1042.
   A.   Yes.
   Q.   At the same time could I give you and his Lordship --
        I have composed a page of the reprinted Himmler logs
for
        Sunday 30th November 1941 and Monday 1st December
1941,
        I have taken from that Witte book.  I have taken out
the
        footnotes because I wanted the text. I wanted the text
to
        appear unvarnished.  First of all would like you to
look

.          P-44



        at the page in D8(iii) page in D8(iii), 1042.  This is
        taken from your website; do you recognize it?
   A.   Yes.
   Q.   You do, Mr Irving.  At the bottom of the page the last
        entry starts: Meanwhile another page from the Himmler
file
        in the Moscow archives obtained by David Irving on
Sunday
        May 17th 1998, reveals the Reischsfuhrer's
appointments
        for November 30th 1941, see above.  The day of the
        telephone call with Heydrich".
                  Turn over now to page 1043.
                  "This suggests that Mr Irving's original
theory
        that Himmler discussed the matter with Hitler before
        phoning Heydrich is wrong. Himmler saw SS
Sturmbannfuhrer
        Gunther d'Alquen, a journalist, from 12 to 1 p.m.
        (Reisebericht uber SS Pol Division [that is short for
        politzei] u. [that is an abbreviated U stop]
        Totenkopfdivision) then worked for an hour
        ('gearbeitet') during which he made the phone call,
        received General Dietl from 2 to 2.30 p.m." I will not
        bother to read the next bit.
                   "And only then, at 2.30 p.m., went for
lunch
        until 4 p.m. with Hitler ('Mittagessen b. Fuhrer')
that is
        short for bei, yes ?
   A.   Yes.
   Q.   That is your account, must postdate the 17th May 1998,
        must it not?  According to that entry anyway it does,
if

.          P-45



        you look at the first page?
   A.   Yes.  I did not understand the question, last
question, it
        was what?
   Q.   Well, if you say that you arrive at this conclusion in
        consequence of the discovery of a Himmler, a file page
on
        17th May 1998, this, what shall we say, "confession"
must
        postdate that, must it not?
   A.   Perhaps I should explain to his Lordship, if your
Lordship
        is wondering why it is written in the third person.
This
        is a page.
   MR JUSTICE GRAY:  I do not think that matters at all.


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