The Nizkor Project: Remembering the Holocaust (Shoah)

Shofar FTP Archive File: people/i/irving.david/libel.suit/transcripts/day010.21

Archive/File: people/i/irving.david/libel.suit/transcripts/day010.21
Last-Modified: 2000/07/20

   Q.   --- was originally designed for the purpose of acting as a
        joint mortuary crematorium?
   A.   But this crematorium was of a size and a capacity which
        has absolutely no precedent at all, or for that matter has
        never been followed by a crematorium of this size ever.
        There is no civilian crematorium at all of this size.  The
        largest civilian crematorium so far as I know had three
        single muffle ovens and never had something like 15 muffle ovens.
   Q.   Was that in wartime or in peacetime?
   A.   In Germany people built in peacetime and destroy in
        wartime.  It is very unusual to build these kind of
        buildings in wartime.
   Q.   Yes.  You appreciate, do you not, that that lift shaft was
        the bottleneck through which all the victims of the
        Holocaust had to go, if we follow the standard version?
   A.   I think most of the victims in the Holocaust died outside
        Auschwitz.  So at least ----
   Q.   These 500,000 you talk about?
   A.   --- these people who went through that lift, that would
        have been a bottleneck between gassing and
   Q.   I appreciate your earlier point.  Of course far more
        people died than those 500,000 and I have never

.          P-180

        that point, let there be no doubt about that.  We are
        looking at this building where, as you yourself said,
        people died in this gas chamber than in any in other
        on earth?
   A.   But bottleneck, of course, the bottleneck of course --
        there is going to be a bottleneck, let us say this
door is
        going to be a bottleneck, a real serious bottleneck,
        somebody screams "fire" in this room and we all try to
        out as quickly as possible and some do not notice
there is
        another room, another exit which says "fire exit"
        but if people file out, as they do at the end of these
        sessions, in a relatively orderly fashion, this is not
   Q.   If everyone here is dead, then they have a problem,
        things slow down?
   A.   But the question is, the issue is, is it a bottleneck,
        also has to be considered in relationship to how long
        will take to incinerate those bodies.  So if at a
        moment it would take, let us say, 20 hours to
        the bodies of the people who have been gassed in the
        morgue, you have 20 hours to move the bodies upstairs.
        then question is over that time would there be a
        bottleneck, yes or no, because the incineration room
        upstairs cannot also take all the 1500 bodies,
        number of people were gassed downstairs.  So only if
        want to get all the bodies up simultaneously is this

.          P-181

        to be a serious bottleneck.
   Q.   So they used the mortuary, however the people died,
        the time being as a mortuary then?
   A.   I mean corpses were removed in small batches from the
        mortuary to the incineration room to feed the
   Q.   Yes.  Can we get some idea of the speed of the
        because your eyewitnesses differ, do they not, as to
        frequently this procedure was repeated?
   A.   Which procedure?
   Q.   The liquidation procedure, people being rammed into
        gas chamber 2,000 at a time.  We are looking at
        basically here.  We not concerned with the "if".  We
        looking at how many.
   A.   Again I am happy to discuss these testimonies when I
        them in front of me.  I thought we were talking about
        elevator right now.
   Q.   We are talking about the elevator.  If the people are
        being rammed in at one time into the gas chamber and
        are being liquidated and then they are being taken out
        through that one exit, up that relatively small lift
        shaft, this is the bottleneck which is going to be
        the bottleneck in an hour glass.  You cannot speed up
   A.   But the bottleneck in an hour glass is only a
        if you want all the sand to go down simultaneously.

.          P-182

        you want the sand to go down in an hour it is not a
   Q.   But it is a controlling factor on the speed of the
        liquidation programme, is it not?
   A.   But there are much more important factors like the
        of incineration in the ovens.
   Q.   You say it is more important, but let us look at the
        elevator.  To make it absolutely plain, there was no
        way of bringing the bodies from downstairs up to the
        furnace stage level?
   A.   There is another way.  You could take the stairs, but
        would have been very, very ----
   Q.   But that was not used?
   A.   --- it would be very inefficient and awkward.
   Q.   Yes.
   A.   My Lord, I presume that a question is coming.
   MR JUSTICE GRAY:  I am presuming.  I am waiting for it.
   MR IRVING:  Yes.  What do we know about the carrying
        of that elevator?
   A.   There is a document for that.  The elevator, this
        in March for that, I think it is March 1943, they
        the original one which was installed for 750 kilos.
   Q.   750 kilos.
   A.   They immediately asked to increase the carrying
        of that elevator by providing extra cables to 1500
   Q.   What do we know about the provision of the motors for

.          P-183

        those elevators?
   A.   Again I do not want to talk about that right now.  I
        not have the document.  But I do know, because I
        looked it up this morning, that they were adapting
        particular -- it was a temporary elevator -- to a
        to a carrying load of 1500 kilos.  So I presume if
they do
        that, that indeed there is a motor which will be able
        hoist 1500 kilos.
   Q.   This was made by Daemarg, I believe, the company?
   A.   Yes.
   Q.   The provisional one.  Why was there a provisional one
        installed, because the final ones were not ready?
   A.   Because the SS, despite whatever they were doing in
        Auschwitz, were unable to get an elevator in early
   Q.   They could not get the priority.
   MR JUSTICE GRAY:  Anyway, carrying a load of 1500 kilos,
        would be how many corpses?
   A.   An average one 60 kilos.  It seems a little high, by
        would be -- the theoretical carrying capacity would
        let us say, 20 corpses, so that would be 20, 25
   MR IRVING:  The same question of course is how many people
        can pack into a telephone box, but packing them in
        time.  It would be difficult to envisage having a
        lift system with people piled four or five or six or
        high, because quite simply the doors would not close?
   A.   There were no doors.

.          P-184

   Q.   There were no doors?
   A.   No.  It was simply a platform which went up and down.
   Q.   That would be even worse then.  The bodies would
        presumably get jammed against the side of the lift
        if they piled them too high.  I am just looking at
        practicalities here, that although technically the
        version of the lift, and I emphasise that, was going
        have the 1500 kilogram capacity, in theory, when was
        lift actually installed?
   A.   The 750 kilograms was installed by the time the
        was finished and immediately they asked to double the
        capacity the oven.
   Q.   And the 1500 one was not of course installed at this
   A.   It was not immediately, but they asked immediately for
        increase in the carrying capacity.  So obviously they
        wanted, whatever they were bringing up from the
        they probably wanted, they felt they needed more
        for this lift.
   Q.   Yes.  It was not in fact installed until the end of
        the bigger the one?
   A.   The final one, no.  This is only a modification to add
        extra cables.  This is not the final elevator which is
        in when finally the factory gets around to deliver
   Q.   Is it not odd that once again the question arises
        that here is one of the most important killing centres

.          P-185

        the Third Reich and they just cannot get the stuff,
        are not getting the priorities?
   MR JUSTICE GRAY:  Shall we stick to one point at a time?
        are on whether this was a bottleneck.
   MR IRVING:  Can we now look at how long it took to make one
        round trip and load up?  Have you any estimate of how
        minutes or seconds it would take?
   A.   To load up how many corpses?
   Q.   Well, this is the question.  You have told us that it
        would take a large number of corpses, but I find this
        to believe if they had no doors and walls on this
lift; it
        was just a platform going up and down?
   A.   I think there are too many variables right now to
        here in court.  I am happy to sit down and, like the
        Zyklon-B, spend a couple of days considering this
   Q.   I am not asking you to do that.  I am just asking you
        do a back-of-an-envelope calculation which will help
us to
        form some idea of how long it would take to raise
        bodies from this underground morgue to the furnace
        bring them in, stack them on, raise them up, unload
        at the top level, bring the thing down empty again and
        repeat the cycle?
   A.   I do not do a back-of-the-envelope and I would just
        to do it as I am thinking out loud and nothing more.
        us say that it would take three to four minutes to

.          P-186

        this platform, that it takes another minute ----
   Q.   With how many?  With how many bodies?
   A.   Let us 10 bodies, 15 bodies, three to four minutes.
        me just make a note of it as I am going on.  Then let
        say it takes one minute and that is a long time for
        platform to go up one storey.
   Q.   No, because if it is a freight elevator in fact it
        twice as long.  We know that from Neufert, do we not?
   A.   But we are talking one storey and we talk about a
        and a minute is a very long time.
   Q.   A freight elevator does go slower than a passenger
   A.   Yes, but we still talk about ----
   MR JUSTICE GRAY:  Come on much, not much turns on that,
        it? We must keep an eye on realities.
   A.   We talk about 2 metres 50.  We talk about 8 feet going
        up.  Let us say it is another three, and I am very,
        generous, you know, three, whatever, two, I mean less,
        minute to unload the thing.
   MR IRVING:  One minute to unload ten bodies?
   A.   Yes.  A minute is a long time.
   Q.   That is being very generous.  I would suggest that the
        round trip, loading and unloading, would take about
        minutes each time?
   A.   Ten minutes.  So?
   Q.   Then we have 2,000 bodies to process in this manner.

.          P-187

   A.   So in your calculation we have, and I am slightly
        disgusted right now by the thing I have to do, but ---
   Q.   These are very rough calculations, but I am suggesting
        that we have a serious bottleneck which indicates that
        figures that talk about have been inflated.  I am only
        looking here at the figures.  I am not looking at
        this happened or not.
   A.   It is going a little fast for me, my Lord, right now.
        I am happy to come back to this on Friday.
   MR JUSTICE GRAY:  If you prefer to, as it is a new point to
   A.   I am just trying to calculate in my head on the 10-
        basis, and, let us say we, what did we say, 10, 15
        on the thing, it would mean that in 10 minutes you
        get ----
   Q.   10 to 15.
   A.   It is one ----
   MR IRVING:  My Lord, I think it would be useful if he was to
        return to this after he has had time to do a calculation.
   MR JUSTICE GRAY:  If you prefer.
   A.   Yes, I would prefer to do that, because I think it seems
        to be a very important point.

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