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Last-Modified: 2000/07/24

    Q.   So, in other words, it does have German documents as source?

    A.   Not cited as a basis for the their estimation of 50,000.

                                 .          189

          In fact, the figure they give is 42,600, whoever has
          reported that.  Again, there is no footnoted source for that.

     Q.   Yes.  Are you aware that ----

     A.   And their estimate of nearer 50,000 than 40,000 is very
          much a guess, as the footnote makes quite clear.

     Q.   In 1961, of course, there were still the 50 year rule in
          operation which prevented the official historians from
          giving sources, is that correct?

    MR JUSTICE GRAY:  Well, knowing what the sources said?

    A.   Well, they certainly cite sources here.

    MR IRVING:  My Lord, you can take it from me that the official
         historians in their volumes, the early volumes, unlike the
         later volumes, never gave sources.

    A.   But the 50-year rule did not apply to German documents,

         Mr Irving ----

    Q.   Have you ----

    A.   --- at all.  It applied ----

     Q.   Answer the question then.  As an historian ----

    A.   It applied to British documents.

    Q.   --- and as an expert witness before this court, no doubt
         you have read ----

    A.   What I am saying is that they did not use German documents.

    Q.   As an expert witness before this court, you have, no
         doubt, read large numbers of the official histories.  Do

                                 .          190

          any of the official histories every provide any sourced
          references up until the most recent official histories of
          the intelligence service, and so on, which has changed the pattern?

     A.   Yes, well, I mean, that is as may be.  The point I am
          trying to make is that since 1961, whatever they had
          available to them, and there have been numerous
          investigations which a responsible historian would make
          use of in arriving at an estimation of the numbers of dead
         in the Hamburg bombing raid in 1943, investigations
         carried out in Hamburg itself on the local Hamburg records.

    MR JUSTICE GRAY:  Do we need to spend very long on Hamburg
         because we are really in this case, I think, concerned
         with Dresden.

    MR IRVING:  It is difficult; each time when I think I have
         established a point to the court's satisfaction, we are
         dragged back down into the morass again, into the swamps.
          Strafing, page 500, I am at a loss here because there is
         no TV set, television, in the courtroom today and I was
         going to provide the court with ----

    MR JUSTICE GRAY:  You can do it at a later stage.

    MR IRVING:  At a later stage.  It is a five minute segment ----

    MR JUSTICE GRAY:  Am I wrong in thinking -- I am trying to
         remember -- have you cross-examined about Dresden before  ----

                                 .          191

     MR IRVING:  I have been cross-examined about Dresden.

     MR RAMPTON:  I cross-examined Mr Irving about the bombing figures.

     MR JUSTICE GRAY:  Yes.  I had an idea he cross-examined one of
          your witnesses about Dresden, but no?

     MR RAMPTON:  I do not think so, no.

     MR IRVING:  No.  I have been cross-examined, but I have done no

     MR RAMPTON:  On the bombing ----

    MR JUSTICE GRAY:  I am sorry, Mr Irving, I am wrong.

    MR RAMPTON:  It seemed the strafing to me was relatively insignificant.

    MR IRVING:  On the question of strafing, and you have quoted a
         book by Mr Gurtz Bergander quite frequently, have you not?

    A.   Yes.

    Q.   Are you aware that Gurtz Bergander is (or was at all
         material times) a reporter for the German Government radio
         station?  Did Bergander interview any of the aircrew
          members?  If you do not know just say so.  On page 500
         roughly.  If you do not know just say you do not know.

    A.   I cannot remember, to be honest.

    Q.   Have you read any of my notes on the interviews with the
         British and American aircrew members?

    A.   There is an awful lot of them, Mr Irving.  I have
         concentrated on what you published.

    Q.   But if you are trying to impugn the question whether the

                                 .          192

          British or the Americans opened fire with their machine
          guns during the raids, then this would be the kind of
          place to look for the source, would it not?

     A.   Well, yes.

     MR JUSTICE GRAY:  The British opened fire with machine guns, did they?

     MR IRVING:  At night, yes, my Lord.  It was just typical of the
          useless exuberance.  They would just poop off.

     MR JUSTICE GRAY:  The relevance of that is what?

    MR IRVING:  Strafing, the allegation of ground strafing.  It is
         levelled more directly against the Americans during the
         day-time raids.

    MR JUSTICE GRAY:  That is what I thought.

    MR IRVING:  Yes.  Page 503.

    A.   Sorry, I thought you said they did this during the day.

    MR IRVING:  Yes.  Page 500?

    A.   Not at night.

    Q.   Page 503.

     A.   Yes.

    Q.   Paragraph 2:  The witness here was a judge called Dr Wolf
         Rektenwault, that is correct?

    MR JUSTICE GRAY:  There is nothing about strafing by British aeroplanes.

    A.   It is Americans.

    MR JUSTICE GRAY:  It is the Americans.

    MR IRVING:  It is left open as to whether it is the British or

                                 .          193

          the Americans.

     MR JUSTICE GRAY:  It is not left open.  It is just not
          mentioned.  It is the Americans.

     MR IRVING:  I would not have included that if I had thought it
          was just limited to the Americans, my Lord.  But what
          I intend to do ----

     A.   It says American fighters.

     MR JUSTICE GRAY:  I am mystified why we were strafing at all.

     MR IRVING:  Because I am accused of inventing it or having
         adduced it without adequate evidence or the usual kind of
         story, and what I have here is an American television film
         on the Dresden raid in which that interviewed some of the
         people involved.

    MR JUSTICE GRAY:  The point is that you have interviewed
         American airmen who have said they did not strafe?

    MR IRVING:  I interviewed or corresponded with large numbers of
         the American airmen and I read their Unit histories.  It
         is not a major point.

     A.   Ah, yes, these are the members of the 20th Fighter Group.

    Q.   And other units.

    A.   Who, in fact, were strafing in Prague, not in Dresden,
         though you say it is Dresden.

    Q.   Well, as there is no television here, unfortunately
         I cannot show the film.  So I am going to move on.  Page 503.

    MR JUSTICE GRAY:  How would that help to say whether it was

                                 .          194

          Dresden or Prague?

     A.   Because it is a misrepresentation by Mr Irving.

     MR JUSTICE GRAY:  No.  How would a television film, Mr

          help show whether was Prague or Dresden?

     MR IRVING:  Survivors from the Dresden air raid describing to
          American television cameras how these American planes came
          up and down the meadows of the river, machine gunning the
          people on the banks.

     MR JUSTICE GRAY:  I see.  That has nothing to do with your
         interviews of airmen.

    MR IRVING:  I also have interviews with airmen, but it is not a
         point to which I attach much weight as, for example, the
         death roll in Dresden which I think the court is probably
         more interested in.

    MR JUSTICE GRAY:  I thought that was the real issue.

    MR IRVING:  Yes.  In that case we will go straight to page 508
         which takes us to the death roll in Dresden.  Now the
         allegation, if I may summarize it to the witness, is as
          follows.  I have given death figures ranging between
         35,000 as the low limit and 250,000 as the high limit and
         a probable figure of 135,000.  Is that correct?

    A.   Roughly speaking, yes.

    Q.   Yes,.   And you think that this was a perverse thing to
         do, on the basis of the evidence before me at the time the
         I wrote on each occasion?

    A.   Yes, that is right.  That is to say ti depends as much on

                                 .          195

          how you do it as on the fact that you do it.

     Q.   Would you first of all to document number 10 in the little bundle?

     A.   Page 10.

     Q.   Page 10, yes.  Is this a book issued or pages from a book
          issued by the Press and Information Office of the German
          Federal Republic, evidently in the 1950s?

     A.   Yes.

     Q.   And does it have an ----

    A.   The late to mid-50s.

    Q.   --- introduction by the Federal Chancellor Dr Conrad


    A.   It does.

    Q.   And page 11 shows his signature on the introduction?

    A.   Yes.

    Q.   If you now go to page 13, does footnote No. 2 say: The
         attack on the city on Dresden which was filled with
         refugees on 13th February 1945 alone cost about 250,000 dead?

    A.   No, I cannot find this.

    MR JUSTICE GRAY:  I have not got that.

    A.   That is page 12?

    MR IRVING:  It is page 12 or the paginated number is 154 and it
         is footnote No. 2.

    A.   Yes.

    Q.   So, prima facie, or on the face of it we have a German

                                 .          196

          government book with authority of the Chancellor himself
          alleging that the city of Dresden was filled with refugees
          and that there were 250,000 dead?

     A.   Yes.  This is Dr. Goebbels' figure of course which he put
          out in propaganda, knowing full well it was not true and
          was taken over.

     Q.   There is a distinction between Dr Ardenhau and
          Dr Goebbels, is there not?

     A.   Well, clearly whoever did this has taken that on trust.

    MR JUSTICE GRAY:  Is that what you relied on, Mr Irving?  Is
         that your case?  That is where the figure of 250,000 came from?

    MR IRVING:  My Lord, your Lordship surely does not accept that
         that is the only source I would have used.


    MR IRVING:  I am talking about the upper end of the scale.

    MR JUSTICE GRAY:  I am asking what your source for the figure
         you at one time were ----

     MR IRVING:  There were very many figures for 250,000.

    MR JUSTICE GRAY:  --- favouring as 250,000.  Are you saying
         that this was at least one of the sources or not?

    MR IRVING:  One of the sources.  I will now draw your
         Lordship's attention to a document that the Defendants
         have not been able to find, and it is in the
         interrogations of two doctors Fersage and Heard, page 41.

    A.   I think what I am saying about the Ardenhau figure, my

                                 .          197

          Lord, is that this is I think simply taken over from the
          Nazi propaganda ministry.  There does not seem to have
          been -- it is only in a footnote.

     MR JUSTICE GRAY:  How would ----

     A.   It does not seem to rest on any very elaborate investigation.

     MR JUSTICE GRAY:  No.  How would Mr Irving have known that it
          was just taken from Goebbels?

     A.   I did not know that he relied on this.

    Q.   No, well, he says he did.

    A.   It is fairly obvious that 250,000 is the figure that

         Dr Goebbels gave.

    Q.   Simply because he gave it?

    A.   Yes.  That is where it appears.  This is relatively
         shortly afterwards.

    MR IRVING:  Was not the figure that Dr Goebbels gave 102,040?

    A.   No, I do not think it was.  Well, he used the figure --
         2040 was the figure in Tages Befehl, daily order 47.
          I think Goebbels blew this to up 250,000.

    Q.   Would you now look at the document 41 in my little bundle,
         please.  This is the integration of the two doctors,
         Versage and Heard.  Dr Versage was formerlly a medical
         officer and Dr Heard was a woman physician.

    A.   Yes.

    Q.   Information on bombing casualties:  According to the
         informants the total number of casualties in Germany due

                                 .          198

          to bombing has been estimated between 3 and 4 million.
          That is an exaggeration, is it not?

     A.   It looks like it, yes.

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