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Last-Modified: 2000/07/24

    Q.   --- I am sure that every effort was made the Defence in
         this action to produce the notes from her of this alleged
         interview and these alleged remarks by Christa Schroeder,

         I am afraid you and I must agree to differ on that.

    A.   I will believe it when you show the correspondence
         relating to the notes.

    MR JUSTICE GRAY:  Would you care to deal with it this way,
         Mr Irving?  Would you like to put to Professor Evans
         exactly what your case is?  Is it your case that there is
          not any record, whether tapes, notes or anything, of Gita
         Szereni's interview with Christa Schroeder and she is, in
         fact, making the whole thing up?

    MR IRVING:  Yes.

    MR JUSTICE GRAY:  Because I think that should be put clearly,
         because she is still alive and well.  Put your case, would you?

    MR IRVING:  Yes.  As stated in your report, your expert report,

                                 .          140

          this relies entirely on one published source by Gita
          Szereni.  Is that correct?

     A.   Yes.

     Q.   This passage on page 652.

     A.   Where there are lengthy previous quotations?

     Q.   Yes.

     A.   Quotations from Christa Schroeder.

     Q.   Did you or your researchers make any attempt to obtain
          from Gita Szereni, who lives in London, any original notes
         or tape recordings, or other memoranda drawn up
         contemporaneously on her interview with Christa Schroeder?

    A.   No, I do not see why we should have done so.  She says
         clearly that this is in her article.  This is what Christa
         Schroeder told her and we have no reason to disbelieve her.

    Q.   Are you aware that Christa Schroeder expressed herself to
         me in terms of the utmost contempt for this particular
         author and what she was trying to get her to say?

     A.   No, I am not.  You will have to show me evidence of that
         if I am to believe you.

    Q.   Have you had complete access to all my private diaries,
         papers and telephone logs?

    A.   Yes.

    Q.   Have you seen no reference to any conversations or letters
         from Christa Schroeder in that vein?

    MR JUSTICE GRAY:  If there are any, I would like to see them.

                                 .          141

     A.   Yes.  It would be very interesting to see them.  I mean,
          obviously, there is far too much there for us to read all
          the way through.  As I have said many days ago, we were
          particularly looking at the diaries and telephone logs and
          so on, with a view, with certain particular questions in
          mind, and we were not looking to them in order to verify
          what seems to be a perfectly straightforward statement by
          Miss Szereni in her article, that this is what Christa
          Schroeder said to her in her statement and which we had no
         reason to disbelieve, and I still have no reason to disbelieve.

    MR IRVING:  Are you aware of a book called "Hitler Privat"
         written by a Frenchman called Albert Zoller which,
         apparently, is conversations with Hitler's private
         secretary, Christa Schroeder?

    A.   This is discussed at length in my report.

    Q.   Would you draw us to the page, please?

    A.   Pages 647 to 651.

     Q.   Have you seen Christa Schroeder's original copy of that
         book with the crossings out and heavy lines in the margin
         and exclamation marks where she has dismissed most
         robustly the statements she is alleged to have made?

    A.   That is much too sweeping, Mr Irving.

    Q.   Well, the answer is no, is it?

    A.   No, I am trying to give you an answer, if you will let me.

    MR JUSTICE GRAY:  Yes, wait for it.

                                 .          142

     A.   So many of your questions do require a lengthy answer.  It
          is on page 649 that I describe the critical addition in
          1985, where Frau Schroeder tells the Editor, Anton
          Joachimstahler, the exact nature of the book produced by
          Zoller, which leads to conclusions about 160-70 pages
          originated by Frau Schroeder, although some of those are
          distorted or amended more, in a greater or lesser vein, by Zoller.

     Q.   Can you, in that circumstance, attach any value whatever
         to the Zoller book?

    A.   Yes, of course, yes.

    Q.   Can you show straightaway what was said by her and what
         has been said by Schroeder?

    A.   It is a complex -- well, because we know in her copy the
         pages she has crossed out were not by her, so at least we
         have got rid of those extra 70 odd pages which do not
         originate from Frau Schroeder.  Frau Schroeder was asked
         with reference to or in the course of the preparation of
          the 1985 edition about these amendments in the pages she
         did write, and she said that she did not doubt the truth
         of the statements in the least, only that they were
         polemically distorted in some details and not represented
         quite exactly.  That is rather a convoluted way of saying
         that they are basically her words, but slightly altered in
         some cases or given a slight spin.

    Q.   Was this book published after her death?

                                 .          143

     A.   Yes, seems to have been.  As you know, books are prepared
          a long time in advance of their publication.  She died in
          1984 and the book was published in 1985.  You have argued
          with reference to some of your books that you wrote them
          four or five or six years before they were published.

     Q.   If Christa Schroeder had any reason whatsoever to be
          disgruntled with what I wrote or to dispute what I wrote
          in my various biographies, why would she have continued an
          amicable correspondence with me until the very last weeks
         of her life?

    A.   Let me try to find it.

    Q.   Which has been in discovery throughout this action.  Every
         single letter she wrote me has been in discovery.

    A.   That is right, yes.  We have looked at some of them.

    MR JUSTICE GRAY:  Page 647.

    A.   Yes.  There she says, that she regretted this and once
         rashly put a part of my, I guess, letters at David
         Irving's disposal.  "I passed on (parroted) the judgments
          expressed therein from Hitler's conversations, for
         instance about the Russian mentality.  Today I am
         horrified about these views thoughtlessly taken from Hitler".

    MR IRVING:  It is true that she wrote these letters to a woman
         friend.  She had a woman friend living in Switzerland, and
         that she had written some pretty harsh judgments on other
         peoples in those letters, and that is what she regretted

                                 .          144

          I had access to.

     A.   In the later years of her life.  In other words, she seems
          to have changed her mind somewhat about many issues.

     Q.   As people frequently do when they give their most intimate
          papers to a writer and it is then used in a book.
          Sometimes they have second thoughts.

     A.   Yes, that is I think probably the explanation of why
          towards the end of her life she said to Gita Sereny, of
          course Hitler knew, not only knew, it was all his ideas,
         his orders, whereas she did not say that to you many years earlier.

    Q.   Have you any indication of the relationship that existed
         between Gita Sereny and Christa Schroeder, whether they
         were on an amicable basis or whether in fact there was the
         utmost hostility between them from the start to the finish?

    A.   I do not, no.  I do not see how that affects this at all.

    Q.   Yes.

     MR JUSTICE GRAY:  It affects it in this way, and I am not quite
         clear what Mr Irving's case is on this.  If the contention
         is that Gita Sereny invented effectively everything that
         Christa Schroeder said ----

    A.   It appears to be that.

    Q.  -- and, when asked for some note or tape recording, said,
         oh well, there is not any record at all of my interview,
         then I think that should be put.  Is that your case,

                                 .          145

          Mr Irving?

     MR IRVING:  That is, coupled with the fact that the book was
          published posthumously, the Christa Schroeder book, and
          the fact these statements by Gita Sereny have surfaced
          more recently still.  Can I ask this question?  Is it
          known to you that Gita Sereny had to withdraw statements
          that she made in her famous attack on my book in a letter
          pushed in the Sunday Times?

     A.   We could have a look at that.  I think it is in discovery
         and we can see which ones.  I do not think she withdrew this.

    Q.   Is it a fact ----

    A.   Of course I go back to the fact that the book was
         published very shortly, the edition of the memoirs was
         published very shortly after Christa Schroeder's death,
         and that the editor clearly had the collaboration of Frau
         Schroeder in preparing the edition, as he says in the
         preface.  I do not accept your view, because I think it is
          your view, that Gita Sereny made all this up.

    Q.   Can I get back to my question, which is this?  Given that
         Gita Sereny in an article in the Sunday Times also claimed
         to have interviewed Dr. Frohlich, and quoted Dr Frohlich
         in quotation remarks and saying various very disreputable
         things about me, and that two weeks later Gita Sereny had
         to publish a letter in the Sunday Times admitting that
         this was totally untrue, is she a reliable source, in your

                                 .          146


     A.   Could we have a look at the letter, please?

     Q.   It has been in discovery throughout.

     MR JUSTICE GRAY:  There is a problem, Mr Irving.  I am
          reluctant to press you to chase up every document for
          which Professor Evans asks, and frankly I think we can
          forget about the Frohlich one.  But, if you are saying
          that there are documents emanating from Christa Schroeder
          protesting about Gita Sereny, then I think those, at some
         stage I would like to see them.

    MR IRVING:  My Lord, I have a note of both Christa Schroeder's
         name and Sereny's name.

    MR JUSTICE GRAY:  I know it is difficult for you on the hoof
         but can you bear that in mind.

    MR IRVING:  It is important. I have one more question on this
         particular matter.  Christa Schroeder, through the Albert
         Soller book, apparently makes a statement incriminating
         Adolf Hitler in the Final Solution, upon which reliance
          has been placed by people like Gita Sereny.

    A.   Sorry, is that a question?

    Q.   Yes.

    A.   I am not quite sure what I am meant to ----

    Q.   Do you agree this is so?

    A.   I would have to see the documentation for that.

    Q.   Well, in that case, let us move on to another name?

    A.   Obviously, you are suggesting that it derived from the

                                 .          147

          bits of the book which were not written by Sereny but were
          based on the interrogations of Heinrich Hofmann, the
          photographer and Schaub, the side kick of Hitler.

     Q.   Then I will ask this further question.  Have you seen, as
          you say you have seen, all my memoranda on my interviews
          with Christa Schroeder, which are in the Institute's files?

     A.   Yes.

     Q.   Do you agree that I keep very clean records of all my
         interviews with these people, the times, the dates,
         exactly what they said, by numbered paragraphs and so on?

    A.   Yes.

    Q.   Have you not seen in one of these memoranda that Christa
         Schroeder specifically disavows that remark by Albert
         Soller and says that she never said it?

    A.   I would want to see that but I can quite accept that she
         might have said that, had it been derived from the other
         material used in the Soller book, certainly, yes.  I make
          that quite clear, that the Soller book is a kind of hybrid
         of interrogations of Hofmann, Schaub and the Schroeder
         stuff, which is the majority of it.

    Q.   Do you have another name?

    A.   Yes, the famous incident recounted on pages 653 to 4, by
         Sonnleithner and also by Lorenz.

    MR IRVING:  Sonnleithner replaced Walter Habel, did he not, for
         a time as the liaison officer of the foreign minister to

                                 .          148

          Adolf Hitler's staff?

     A.   Yes, Foreign Ministry official, that is right.  This is
          quite a celebrated incident, so that is the last one, my Lord.

     MR JUSTICE GRAY:  Thank you very much for doing that.

     MR IRVING:  Since we are on that Maidonek episode that
          Sonnleithner relates here, is it not true that Ribbentrop,
          when he also heard the reports about Maidonek, expressed
          disbelief in September 1944?

    A.   Yes.  He is quoted in fact on the next page, 655, as
         saying I did not know anything about the exterminations
         until the Maidonek affair came out in 44.

    Q.   Yes, and that he discussed it one morning with his son
         Roland, did he not?

    A.   That is right, yes.

    Q.   As Roland told me, he said his father had asked him and
         shown him a copy of the Daily Mail reporting the Maidonek episode.

     A.   Yes.  I am trying to find where I deal with this.  I think
         it is earlier on.

    Q.   Does this not rather indicate that Ribbentrop was somewhat
         in the dark until then?

    A.   This is dealt with.

    Q.   Either he did not know or he did not want to know what was
         going on?

    A.   On pages 478 to 496 of my report.

                                 .          149

     MR JUSTICE GRAY:  This is Ribbentrop on Hitler's knowledge, is
          that right, Professor?

     A.   That is right, my Lord.

     MR IRVING:  It is not really about this episode, is it?

     A.   I am not quite sure what are you trying to ask.

     MR IRVING:  I am asking whether you have not heard that
          Ribbentrop always maintained that the first he learned
          about the atrocities was when the reports came through the
          foreign press of Maidonek, the capture by the Russians of
         the Maidonek camp.

    A.   In 1944 he says -- on page 491 -- that is what he
         claimed, yes.  Whether he is to be believed or not is
         quite a different matter.

    Q.   Have you seen any evidence?

    A.   Yes, the conversation with Horthy that we were discussing
         this morning.

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