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Shofar FTP Archive File: people/i/irving.david/libel.suit/transcripts/day017.09

Archive/File: people/i/irving.david/libel.suit/transcripts/day017.09
Last-Modified: 2000/07/20

   MR JUSTICE GRAY:  I appreciate that, but you know what I mean.
        I have had rather less long.  So can you just help me who
        Greiser was?
   A.   Greiser is the head of----
   MR IRVING:  The Gauleiter of the Warthegau.
   A.   Gauleiter of the Warthegau.  Lodz and Chelmno are
        in the Warthegau.
   MR JUSTICE GRAY:  Thank you.
   MR IRVING:  The second document is the one -- you must help
        on this -- with the 97,000 figure in it?
   A.   I believe it is June 6th 1942.
   MR RAMPTON:  June 5th?
   A.   June 5th.
   MR IRVING:  1942, correct.
   MR RAMPTON:  Perhaps in this case we should maybe get the
   MR IRVING:  I agree.  There are two rather odd features
        the document I want to draw your Lordship's attention
   MR RAMPTON:  It is in the second volume.
   MR JUSTICE GRAY:  I hope it is in J or L.

.          P-75

   MR RAMPTON:  I think it is in the main bundle now.
   MR JUSTICE GRAY:  If Greiser's letter is there too, then
        I would quite like a reference to that at the same
   MR IRVING:  Do you have the actual document in front of
   MR JUSTICE GRAY:  Just a moment.  Let us catch up..
   A.   No, I do not.
   MR RAMPTON:  One starts at page 92 of the new Browning file
        which is Greiser's letter.
   MR JUSTICE GRAY:  You tell me about a new Browning file.  I
        feel I am the last to know about it.
   MR RAMPTON:  Tab 7, I am sorry.
   MR IRVING:  My Lord, meanwhile I can tell you what I am
        at here.
   MR JUSTICE GRAY:  Let us pause a little, Mr Irving.  You
        to be patient with us.
   MR RAMPTON:  Then the motor pool letter, the 97,000, is on
        following page, I hope, 93 to 97.
   MR JUSTICE GRAY:  I think I may have misunderstood.  Are we
        tab 7 of L1.
   MR RAMPTON:  Tab 7 of L1.
   MR JUSTICE GRAY:  Page 97.
   MR RAMPTON:  Starting at page 92, that is Greiser to
Himmler of
        1st May in a printed form.  We have not got a copy of
   MR JUSTICE GRAY:  Yes.  And the other one, Mr Rampton?
   MR RAMPTON:  Then the very next page, 93, is the 97,000

.          P-76

        of 5th June 1942.
   MR JUSTICE GRAY:  Thank you.
   MR IRVING:  I am just going to wave one little flag about
        document's oddities.  This is the document containing
        97,000 figure, correct?
   A.   Correct.
   Q.   Do you see at the top it says "Einzigste Ausfertigung"
   A.   Yes.
   Q.   Have you ever seen that designation on a document
        else in your entire archival experience?
   A.   I do not recall seeing it.
   Q.   Yes.  "Einzigste Ausfertigung" which means the
   A.   Yes, the motor pool sergeants were not terribly
   Q.   I take that point.  Can you see that the document
        with the sentence: Beispielsweise, for example?  The
        first sentence in the document.
   A.   Yes, it says, "seit December", yes.
   MR JUSTICE GRAY:  I am sorry, I have not got that.  Where
   MR IRVING:  In the very first sentence of the document, my
   MR JUSTICE GRAY:  "Seit December".
   MR IRVING:  The one with 97,000 figure in it.
   MR JUSTICE GRAY:  Since December.

.          P-77

   MR IRVING:  No.  The word I am looking at is
        It is a letter beginning with the phrase, for example,
        "Beispielsweise", it is just lifted out of the middle
        nowhere.  Have you ever received a letter from
        beginning with the word "Beispielsweise",
        Professor Browning?
   A.   No.
   Q.   Or "for example"?
   A.   But I think to have to realize Mr Schuss was not a
        graduate, that these are people who are working in the
        motor pool in Berlin, and that the tone, as I see it,
        someone who is trying to emulate what he thinks is
        bureaucratic German and he in fact is someone is not a
        bureaucrat, he is a mechanic.
   Q.   He was not stupid because, as you say, he was the only
        who was not punished in this entire horrible affair.
   A.   You have to remember that "Beispielweise" comes after
        subject, which is they are talking about technical
   Q.   Yes.
   A.   I presume that this is a result of a conversation
        have had, there has been a meeting.
   Q.   Yes.
   A.   And someone has said, write it up.
   Q.   OK.
   A.   We get a very ----

.          P-78

   Q.   Can you do a rough calculation of how many people were
        being killed per van per day?
   MR JUSTICE GRAY:  Just pause, Mr Irving.  If I may say so,
        must just let me absorb the points you are making.
   MR IRVING:  I am just planting suspicion.
   MR JUSTICE GRAY:  You are casting doubt on this, partly
        it has "Einsigste Ausfertigung" on the top and
        I understand that, but I am not sure I am really
        your point on "Beispielsweise".
   MR IRVING:  It is an unusual turn of phrase to start a
        with, my Lord.
   MR JUSTICE GRAY:  Why is it unusual?  He is picking three
        trucks, is he not, to give an example of the sort of
        numbers that are being processed if that is the right
        word, in the special trucks.
   MR IRVING:  I agree, my Lord, but you would normally expect
        that in the second paragraph of a letter.  In the
        paragraph he says, well, we are going to have troubles
        doing this, that and the other, troubles with the
        the exhaust hoses are getting corroded and all the
rest of
        it, for example, but in fact his letter begins with
        word "for example".  This is the oddity about it.  But
        can do no more than ----
   MR JUSTICE GRAY:  You rely on that as an indication that
        is not an authentic document?
   MR IRVING:  I am trying to plant a seed of suspicion in

.          P-79

        Lordship's mind, that is all.
   MR JUSTICE GRAY:  You are not succeeding at the moment
        I would have thought, if you are trying to create a
        document that is going to deceive anybody, you would
        do what you say is something obviously inappropriate,
        which is to refer to an example in the first
   MR IRVING:  It would be improper for me to do anything
        Mr Rampton will object if I do anything else because
        I have already stated that I fully accept that this
        document refers to the homicide of large numbers of
        beings in gas vans.
   MR JUSTICE GRAY: Where are we going?
   MR IRVING:  We are going to look at the number, my Lord,
   MR JUSTICE GRAY:  So you accept this is an authentic
   MR IRVING:  For the purposes of this morning, yes.
   MR RAMPTON:  I do have to know sooner or later, and so does
        your Lordship, whether Mr Irving accepts for the
        of this trial that this is an authentic document.  If
        is a forgery, we need to know why he says it is a
   MR JUSTICE GRAY:  You do not say it is a forgery?
   MR IRVING:  No.
   MR JUSTICE GRAY:  Then we can forget about Beispielsweise,
        we not?
   MR IRVING:  But it also helps to address the court's
        to the fact whether this witness had competently

.          P-80

        questioned the integrity of the documents we are
        confronted with.
   MR JUSTICE GRAY:  It is not a valid criticism of him if you
        not question it.
   MR IRVING:  I personally would question it but not for the
        purposes of this morning's hearing.  Shall we just
        to the number?
   MR JUSTICE GRAY:  Let us do the numbers.  97,000 -- what is
        wrong with that?
   MR IRVING:  I am sorry about that detour.  97,000 people
        in three vans in what space of time?
   A.   From December to June, this would be six months, by my
   Q.   Six months?
   A.   Yes.
   Q.   Are these regular German army diesel trucks, five ton
        trucks or something?
   A.   They refer to two and then a third, and I think they
        -- we do not know the capacity of two of them because
        they were not either the Opal or the Saurer trucks.
        were apparently converted Renault.  Then they brought
in a
        Saurer truck, which is the biggest model and could
        I think 50 to 80 people.  The Opal was 30 to 50.  We
        not know the capacity of the actual two trucks that
   Q.   From the descriptions we have, it did not actually do

.          P-81

        on the spot.  They were loaded aboard, the victims,
        they were driven off into the country side for a
couple of
        hours and then they were gassed on the way?
   A.   No.  As best we can tell they loaded them, gassed them
        there, or for a while ran the engines, and then drove
   Q.   Yes.
   A.   So it was not a long way from Chelmno to the forest.
        I think it is two kilometres or 3 kilometres.
   Q.   I have read 20 kilometres.
   A.   That is not correct at all.  I have driven it myself.
        is not far, and one would have to do a considerable
        of the time needed to kill the people, one would have
        remain in the courtyard unless you wanted to run the
        engines for a prolonged period after you arrived in
        forest camp.
   Q.   Have you ever calculated the quantities of gasoline or
        petrol that would be needed for these kind of trips?
   A.   Not knowing the fuel consumption of the various truck
        models, no, I have not made a calculation.
   Q.   Does it strike you as being a very economical way of
        killing people?
   A.   I think this camp was probably very inexpensive to run
        comparison to what they were taking in, property and
        getting in labour from the Jews in Lodz.  My guess is
        this was an infinitesimally small part of their

.          P-82

   Q.   If they had just the three trucks and this length of
        time to do it in, and they had the problem of
        the people to get into the truck, and loading them up,
        driving off, waiting for the gas to have its effect,
        unloading them at the other end and cleaning up the
        so that the next cargo did not have any suspicions,
        must have been quite a substantial turn around time?
   A.   The trucks made return trips each day.  In fact, we
        with just one truck at the Semlin camp, it took about
        months, with just one trip a day and occasionally two,
        gas the 7,000 people there.  So, with three trucks
        operating on a shorter run, they did not have to drive
        the way through Belgrade to the far side, which is
        happened in Semlin.  I did the calculations for
   Q.   You have done the calculations?
   A.   Yes. I have not done them for this.
   Q.   Does the 97,000 not strike you as being wrong by a
        of two or three?
   A.   Absolutely not.  It does not strike me as wrong at
   Q.   It depends strictly on what the capacity of the trucks
        would have been, what the turn around time was,
        they were really efficient, whether they worked 24
hours a
        day and whether the trucks had any down time.
   A.   From the witness reports the trucks made numerous
        each day, the drivers traded off so that they in fact
        operated continually during the day.

.          P-83

   Q.   Around the clock 24 hours a day?
   A.   Not 24 hours, through the day.
   Q.   Yes.
   MR JUSTICE GRAY:  It is pretty distasteful, but may I ask
        question?  How many people were there in a gas van
        they were being gassed?  How many people could be
   A.   We do not know for Chelmno because it is a different
        truck.  There is a Saurer truck, one Saurer truck was
        Chelmno.  That is the one that exploded.  Then they
        two converted Renault French military trucks that they
        turned into gas vans, so we do not have a knowledge
        there.  The small truck that they produced, the Opal
        Blitz, was the smallest.  The Saurer could carry 50 to 80
        people, the Opal Blitz was 30 to 50.  So, even if the
        Renault was smaller than the Opal, which probably as a
        military truck it was larger, would be in between the two.
   Q.   That is the order of magnitude?
   A.   Yes.

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