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Last-Modified: 2000/07/20

   Q.   No.  This is not a trap.  We are trying to educate the
        court.  I have to admit that I have learned a lot out of

.          P-169

        Neufert as I went along as well.  But I think I have made
        the point that the provision of heating in a mortuary is a
        requirement, at least by the guidelines which were
        standard in all German architects' offices at that time,
        and no special significance can be read into the fact that
        they were trying to it in a cost effective way by using
        heat from the incinerators.
   A.   If that were to be the case, the heating installation
        would have been included in the original design of the
        crematorium.  It is not.  What actually it says here is
        why, why do you want to be able to keep the temperature of
        the morgue in that range of 2 to 12 degrees?  It is
        because the corpses still have to be viewed by the people
        who are basically the family members.  If we look at the
        diagram, I am very sorry, my Lord.  I have a diagram and
        you do not, but there is actually a diagram which shows
        that there is a Leichenshauraum, which means a room to
        show or to look at the corpse.  So this is a very usual
        thing in a crematorium.  The body is stored.  It happened
        to us very recently in my family.  You go and before the
        final cremation you still have an opportunity to look at
        the corpse.  You do not want to look at the corpse where
        ultimately frost has destroyed the corpse.  This is the
        purpose for that particular thing.  It has nothing to do
        with the mechanics or the physics of incineration.  It has
        to do with a certain sense of decorum.

.          P-170

   Q.   The fact remains, does it not, that the guidelines say
        mortuaries have to be warmed and they are going to
        the local building inspector from Kattowitz or Cracow
        coming round and he is going to say, ' Oy, you have
        got heating in here, cannot switch on until you have
        heating fixed"?
   A.   The fact of the matter, my Lord, is that these are
        guidelines.  If the guidelines in Neufert had been
        followed by the Auschwitz central building office,
        would have included the heating for the heating system
        also probably the cooling system for the morgue from
        beginning in the design.  This has not been done.  For
        year and a half this design has been developed without
        ability whatsoever to bring any heat in that morgue so
        is absolutely, I think, nonsense to suggest that, with
        this Neufert in mind, the Auschwitz architects were
        designing their morgues.
   MR JUSTICE GRAY:  By March 1943 how far advanced was the
        construction of crematoria (ii) and (iii)?
   A.   The building was finished and the design started in
        October 1941.
   MR IRVING:  They could not switch it on because they had
        made provision for the heating at this point.
   A.   They had forgotten it, but the inspector in Kattowitz
        obviously had also overlooked this one issue.
   Q.   But the burden of the letter of course says this is a

.          P-171

        cost effective way of doing the heating.  It is not
        you have forgotten the heating, it is saying let's do
        by this way because that is going to save the Reich
        or fuel or whatever.
   A.   Please, Mr Irving, show me any other letter.  I have
        seen one.  I am under oath, I understand, here.  I
        never seen any other letter talking about bringing any
        heating, any hot air, or any other means of heating
        the morgue.
   Q.   But fact remains that mortuaries have to be warmed, so
        common sense for once is wrong.  The audience is wrong
        this particular question.  The book gets it right.
        book says it has to be kept in a range of temperatures
        between 2 degrees and 12 degrees, either by heating or
   MR JUSTICE GRAY:  What about crematoria 4 and 5?  Was there
        heating provided for that?
   A.   There were stoves in crematoria 4 and 5.
   Q.   That was how they heated them?
   A.   Yes, no cooling installation.
   MR IRVING:  Would you now turn to page 255, please?  We
        now left the heating element.
   A.   Sorry, my Lord, I would like to come back to this
        because I have made a mistake.  The "them" you refer
        were probably morgues.  I refer to the gas chambers of
        crematoria 4 and 5.

.          P-172

   MR JUSTICE GRAY:  I was referring to the morgues or the
        mortuaries, yes. Did they have any heating?
   A.   There was a mortuary in crematoria 4 and 5 and they
        not have any heating.
   MR IRVING:  Will you now turn to page 255 of the architects
   A.   Yes.
   Q.   This shows halfway down on the right things that are
        needed for air raid shelters.  Does this show a door
        opening outwards?  Can you see the metal gas tight
        with the typical heavy handles?
   A.   Can you refer me to the particular passage?
   Q.   Page 255, on the page called Luftshutz air raid
        ARP, and it has various sketched layouts of air raid
        shelters and various air raid protection
        I am sorry, my Lord, I should have provided you with a
   MR JUSTICE GRAY:  I am following.
   MR IRVING:  Do you agree that that shows a steel door or a
        of some heavy substance designed to open outwards with
        handles on the outside?
   A.   I do not see any steel door.  That is the problem.  Oh
        there is a door.
   Q.   Yes.  Two of them?
   A.   Yes.  That is one.
   Q.   (German spoken - document not provided) 4104.  They

.          P-173

        actually had a German standard, the equivalent of
        standard, what a standard gas tight door looked like.
        will make an enlargement of this and provide it to
        Lordship because it is exactly like the doors that
        I believe the other side will produce pictures of.
   A.   OK.  It is unclear to see what is in and out in this
        drawing.  To be very honest, if this door is hung on
        inside -- again it is a very technical matter and I am
        uncomfortable discussing this without you actually
        the picture.
   MR RAMPTON:  I am also a bit uncomfortable trying to follow
        cross-examination when I do not have the document.
   MR JUSTICE GRAY:  I know, but let us try and do the best we
   A.   Shall I draw what actually the picture shows and then
        think we have a very quick answer.
   MR JUSTICE GRAY:  You are saying that the drawing is
        about whether it opens inwards or outwards?
   A.   No.  It shows that this door actually turns towards
        inside and there is a very easy way to substantiate
   MR IRVING:  Do you wish to explain why.
   MR JUSTICE GRAY:  Yes.  If you want to, yes, do.
   A.   The door is on the inside of the wall, so there is a
        and the question is where would the door be hung.  I
        trying to think this through.
   MR JUSTICE GRAY:  I cannot see that that would affect which

.          P-174

        it opened, but maybe I am missing something.
   A.   May I draw it?
   MR JUSTICE GRAY:  Yes, of course.
   A.   I have in my bag a lot of air raid shelter designs in
        Auschwitz.  So there is a wall right here.  There is a
        wall right there, and then the door is hung sitting
        here, and the door is like that.  The implication of
        course is that the door opens like that.
   MR IRVING:  It is not going to open any other way.
   A.   No.
   Q.   It is going to come up against----
   A.   I just want to say that I am talking here, just trying
        think out loud.  I do not have anything more right now
        about it.
   MR JUSTICE GRAY:  I think I know what you are going to say
   A.   I have not seen this door and I have not inspected
        particular shelter, but if indeed the door is fastened
        right here and right there, it would make sense to me
        think that, if the hinges are right there, the hinges
        would be on the inside, not on the outside because, if
        they are on the outside, it would be easy to blast
        off.  That is all I can say right now if you want to
        determine what is inside and outside.  I do not want
        make any more specific statements on this.  But we can
        look at documentation on doors and air raid shelter

.          P-175

        in Auschwitz and I am happy to do that to the court.
   MR IRVING:  That is the actual copy.  I have marked it with
        arrow, my Lord.  You will see the door rests on rims
        the outside of the wall.
   MR JUSTICE GRAY:  Yes, I see.
   MR IRVING:  I did alert the defence to the fact that I was
        going to take an interest in Neufert and I enquired
        whether Professor van Pelt had a copy of Neufert.  I
        sorry, I did not alert them to the specific matters
        I was going to raise.  Finally, is there anything
        you wish to say on the subject?
   A.   No.  I think it is very difficult to come to any
        conclusion right now on the basis of that drawing.
   Q.   But common sense suggests that, if you have 4,000
        bombs blasting outside a building, you do not want a
        that is going to come flying open into your face?
   A.   I do not know.  It is common sense that you do not
        if a building collapses and collapses over the air
        shelter, you do not want all the brick and rubble to
        right in front of the door so you can never open the
        door.  So you are inside there without able to leave.
   Q.   Can I now in general ask you by what means the corpses
        were taken out of the gas chamber upstairs to the
        where the furnaces were?
   A.   In crematorium (ii)?
   Q.   In crematorium (ii) I am only interested in

.          P-176

   A.   I just have to redirect my mind.
   Q.   I am only interested in crematorium (ii) because that
        where you said this was where the 500,000 people were
        killed.  You called this the centre of the atrocity.
   A.   They were brought up by elevator.
   Q.   They were carried up by elevator.  It is difficult to
        where it was, I suppose, is it not?
   A.   No it is actually quite easy.  The elevator is right
        here.  Actually the pit is still there.
   Q.   The pit is still there?  Do you know anything about
        dimensions of the elevator shaft?
   A.   It would be a little over, I would say, 2 metres 30,
        side, maybe 1 metre 40, 50 in the other.
   Q.   In our language how many feet is that?  Six or seven
   A.   Yes, eight feet by five feet, something like that.
   Q.   Yes.  Well 2 metres 30 is six feet, about seven feet.
   A.   We can check it on the blueprints, so why do we not do
   Q.   This is quite an important point, my Lord.  This is
        bottleneck.  We are looking at the bottleneck now.
   A.   We have actually the dimensions 2 metres 70 by 1 metre
        so 2 metres 70.  In the blueprints this is document
        tab 1, of the documents, it says in the enlargement to
        right.  So 143 would be 4 feet, 4 feet 10 inches and 2
        metres 70 would be ----

.          P-177

   Q.   Eight feet?
   A.   No, it would be 9 feet, 30 centimetres per foot.
   Q.   So, what, it is about as big as one of these table
        is it, the shaft?
   A.   No, 9 feet is longer than this table, and certainly it
        much wider.  This is less than a metre.
   Q.   I am just trying to get an idea.  Of course, that is
        the area of the floor space in elevator itself, is it?
   A.   The elevator, we can go back to the blueprint.
   Q.   Yes.
   A.   It says -- the dimension is taken, the width is taken
        the basis of the actual width of the platform.  In the
        length I have to admit, at least in the design, the
        platform would have been slightly less than 2 metres
   Q.   Because of course you have got to have room for the
        counter weight to go up and down?
   A.   No, the counter weight, there is a space for the
        weight right -- it is spared out to the side towards
        morgue No. 1.
   Q.   Although it is not in any of these designs, in the
        designs the counter weight comes down inside the
   A.   Are we referring to the plans of the crematorium or to
   Q.   You are saying there was an extra shaft to the counter
   A.   There is quite a substantial space, I would say

.          P-178

        one foot and a half, at the side of the platforms
        which the counter weight could go.
   Q.   Very well.  So what was put into this?  It was like a
        hospital lift, was it, in which bodies put or how
would it
        normally be designed if this operating as a mortuary,
        kind of insulation?  Would a gurney or stretcher be
        wheeled in there carrying the bodies if it was a
   A.   I have no idea how lifts in normal mortuaries are.
        information says "auf Zug", I presume that in this
        this was designed for this building.  This building
        obviously deals with mass mortality one way or
        So I think it is very unlikely that a gurney would
        been wheeled into this thing, because I would not know
        you would bring out a gurney into this morgue, and
        load it on a gurney, put the gurney in the elevator
        then immediately burn the body upstairs in a mass
        incineration facility.
   Q.   First of all, we will start with the normal mortuary
        design because this was presumably a standard mortuary
        design which has been adapted for special conditions?
   A.   No, Mr Irving, this is standard mortuary design.  This
        a rather unique mortuary design, probably unique in
        world, in the history, no, it is not a standard.
   Q.   But it was designed as a mortuary?
   A.   Sorry, I stated it wrongly.  You said "mortuary"

.          P-179

        I meant ----
   Q.   The entire building was ----
   A.   --- crematorium.

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