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   MR IRVING:  We are making rapid progress.  For the remaining
        three minutes I will just have a quick look at page, 45
        please.  On May 25th 1940 Himmler did put this document to
        Hitler on the plans for the East?
   A.   Yes.
   Q.   Was this again Plan Ost or was that another document?
   A.   This was the future of the Frentfurgischer, as it was
        called in the text, the alien people.
   Q.   Does not Himmler in this document say words to the effect
        that we cannot do what the Russians do, we cannot just
        liquidate them?
   A.   Yes, the quote here is:  "The Bolshevist methods of
        physically extirpation (Ausrottung) of a people because of
        inner conviction, as un-German and impossible".  So he is
        distancing himself from ausrottung.  In the same text he

.          P-111

        says: "I hope to see that by means of the possibility of a
        large emigration of all Jews to Africa or to some other
        colony - that the concept of Jew will be fully
        extinguished".  So I think we have take these
        two sentences into account.  Distinguished but not ausrottung.
   Q.   I just wanted to look at the fact that the word ausrottung
        in that document does not by itself mean killing, because
        Himmler had to add the word "physical" in font of it, did
        he not, so going to physically ausrottung them?
   A.   Of course that is a possible interpretation, but sometimes
        in a document you make your position very clear by
        actually repeating the same meaning and adjective.
   Q.   That is added emphasis, is it?
   A.   Yes, you have to have a subject but you also add an
   Q.   To make it unmistakable?
   A.   Yes, exactly.
   Q.   Because otherwise it could be mistook.
   A.   Yes, and also probably you want to strengthen your point.
        People tend to repeat themselves.  That is quite a common
        experience.  If in the same document you make the same
        point twice or three times, it does not always, I think
        one cannot -- well, I stop here.  Sorry.
   Q.   Just like Adolf Hitler in that November 10th 1938 speech
        using the phrase "we do not need them"?  He says it twice

.          P-112

        in one sentence.
   A.   Yes.
   Q.   It does not add anything really?
   A.   Yes, for example.
   Q.   I see a smile from his Lordship.  That was not the point
        I was hoping to make there.  I would hate to go down just
        on that one sentence.  That is the reason.  Page 46 just
        for one minute.  The Madagascar plan was quite feasible, was it not?
   A.   In which sense feasible?
   Q.   It could have housed them.  The island is big enough.
   MR JUSTICE GRAY:  The relevant question is they thought it was
        feasible?  Whether they were right or not may not be here or there.
   MR IRVING:  I was going to ask the witness.  He is rather
        dismissive of the plan.
   A.   In which sense feasible?  You mean to provide a place
        where 4 million Jews could have a happy life?  In this
        sense feasible?
   Q.   Happier life.
   A.   Or feasible in the sense of an SS police state, so to say
        a big prison, with a high death rate?  In this sense
        I would say, yes, it was feasible.  We have contemporary
        examinations about this problem.  For instance, the Polish
        Jewish Commission which was sent to Madagascar in 37, they
        came back with a recommendation that, as one member put

.          P-113

        it, Madagascar would offer a place for about 50 to 75,000
        people.  The Jewish members of this Commission did not
        agree.  They said 2,000 probably.  So this is contemporary
        evidence we have.  I would say clearly that I doubt that 4
        million Jews would have the chance to survive this, if
        I may say, excursion to Madagascar in 1940.
   Q.   Dr Longerich, one final question before the adjournment.
        Are you aware that the population in Madagascar has
        increased from about 2 million to 13 million over the period?
   A.   I looked it up because this was always said.  4 million in
        30s to 30 million indeed in the 1990s, yes.
   Q.   So that kind of population could have been absorbed?
   A.   Yes, within 50 years, with an infrastructure and so on, of
        course.  Experience shows that.
   MR JUSTICE GRAY:  Two o'clock.

                         (Luncheon Adjournment)
   (2.00 p.m.)

   MR RAMPTON:  My Lord, can I hand in my little note on the
        inadmissibility of expert witness statements?
   MR JUSTICE GRAY:  Thank you very much -- yes, please.
   MR RAMPTON:  I say no more about it.  Yes.
   MR JUSTICE GRAY:  Yes, Mr Irving?
   MR IRVING:  Thank you.  (To the witness):  Dr Longerich, we had
        reached the middle of 1941 roughly and I think I am right
        in summarizing that there is no evidence up to 1941, the

.          P-114

        middle of 1941, of any directives by Hitler to exterminate
        Jews, no order for a systematic extermination of the Jews
        that you are aware of by the middle of 1941?
   A.   Well, if it comes to the preparation of Barbarossa,
        I would not agree.  Before that -- at the moment I cannot
         -- probably you are right, I cannot recall something like that.
   Q.   Yes, shall we have a look at the directives issued in May
        1941 now?
   A.   Yes.  Well, by the way, no, I have to correct myself,
        there is no -- we do not have a written, a written
        statement by Hitler signed by Hitler, you know, that the
        Jews have to be killed.  This is something we do not have.
   Q.   On page 55 of your report, 15.1, you begin by saying: "In
        the course of the preparations for the racist war of
        extermination against the Soviet Union", that is rather
        colourful language, is it not?
   A.   Well, this is actually a language which is commonly used
        by historians to describe the specific nature of this war.
   Q.   Yes.  It is not really material here except that it goes
        to your state of mind, I suppose, but are you not aware
        that there is a body of historical opinion on the other
        side now which says that to a certain extent,
        notwithstanding that Hitler had always wanted to fight the
        Soviet Union, by June 1941 it also had a preventive character?

.          P-115

   A.   No, I do not accept this thesis.  I think it does not
        convince me at all.  These historians have not produced,
        in my opinion, enough evidence to prove that Hitler was
        just, well, fighting a preventive war.
   Q.   Preventive war?
   A.   Yes.
   Q.   I did not say he was just fighting a preventive war
        because I said that there was certainly evidence that he
        had always wanted to fight the Soviet Union.  I chapter 14
        of Mein Kampf goes that way, does it not?  But Stalin's
        biographer, General Volkagonov, has presented documents
        from Stalin's own private archives indicating that the
        Russians were planning to attack Germany?
   A.   I do not think there is enough evidence now.  I mean,
        I know that research is going on, and one actually can
        find more material in Soviet archives, but at the moment
        I do not think that the case is made that Hitler was just
        fighting a preventive war against the Soviet Union and
        that Stalin had decided to attack Hitler somewhere in the
        summer 1941.
   Q.   Once again, I did not say he was just fighting a
        preventive war, but it had a preventive element?
   A.   I do not accept this.  I think, from the German side, if
        you follow the preparations, I mean, I am, of course, more
        an expert -- expert on the Germans, not on the Soviets.
        I am just following the discussion, but on the German

.          P-116

        side, it is quite clear in the preparations, from my point
        of view, that Hitler actually is planning this war since
        the summer of 1940, and in the documentation that there is
        actually, as far as I am aware, almost no reference to the
        policy of behaviour of the other side.  So I think it is
        the main reason for this was really, on the one hand, the
        ideological belief of Hitler that he has to destroy this
        so-called Bolshevik Empire and, on the other hand, he is
        trying to find a way out of the general, the war situation
        he found himself in in the summer of 1940 when Britain was
        not prepared to surrender.  So I do not share this view,
        that it was to some extent a preventive war.
   Q.   Or to any extent at all a preventive war?
   A.   No, I do not share this view.
   Q.   I do not want to labour the point, but I am just drawing
        attention to the fact that in that first line you do
        appear to throw around words like "extermination" rather loosely.
   A.   I do not think I throw around; I just say that, in my
        opinion, if you follow this documentation, I think it is
        fair to say that this was a racist war of extermination
        from, you know, as both, if you look at the preparation
        and planning and, on the other hand, if you then look at
        what happened after the 22nd June 1941.
   Q.   We are looking now at Hitler's instructions to the High
        Command Operations staff, March 3rd 1941.  These are the

.          P-117

        guidelines which I believe I gave your Lordship in
        complete translation a few days ago, the English
        translation of the document.
   MR JUSTICE GRAY:  Yes, I think you did.
   MR IRVING:  Is there any indication in that document, apart
        from that quoted paragraph, that there is an intention
        when the Russian campaign begins to liquidate the Jews as
        such rather than just the leadership?
   A.   I do not have the full document in front of me, so
        I cannot answer this, but you could probably help me.
   Q.   But you would have quoted it if it was in the document?
   A.   I think I looked through the document and if I did make a
        mistake, it is nothing, there is not such a phrase in document.
   Q.   I think we can take it that Hitler himself is the author
        of this document, can we?
   A.   Yes.
   Q.   When Hitler refers to the Jewish Bolshevik intelligentsia,
        der Judisch Bolschewikisch intelligentsia, he is referring
        to the people around Stalin and the leadership of the NKBD
        and the Commissarts, that kind of people?
   A.   Well, I think the top leadership but also the Party
        functioners, I think.
   Q.   Whether they were Jewish or not, he just put them all into
        one package?
   A.   The Jewish Bolshevik intelligence, yes, Jews and non- Jews

.          P-118

   Q.   This was part of the Nazi party jargon, was it not?  It
        was part and parcel -- it was a word they liked using a lot?
   A.   Yes, but it refers to the fact that they were convinced
        that Bolshevism or Marxism is a kind of sinister, you
        know, tool of the Jews, you know, in order to destroy the
        Aryan people.  This is, I think, the background.  It is
        just not, it is just not kind of jargon.  It has a thing,
        it has a background.
   Q.   The further quotations that you put on that page from the
        papers of General Thomas ----
   A.   Yes.
   Q.   --- who I incidentally learned was the father-in-law of my
        private secretary after 20 years she worked for me, oddly
        enough.  It is a small world.  These are just references
        to destroying the Soviet leadership?
   A.   Yes.
   Q.   Or murdering them or killing them?
   A.   Yes.
   Q.   Would that be a legitimate military aim to discuss with
        the German High Command?
   A.   Well, it gives you a kind of insight about the nature of
        this war because they are not planning only to annihilate
        or exterminate the Russian Army, but also they are trying
        to crush the whole system, including killing, obviously,

.          P-119

        the leadership.  So it is far more than a normal war when
        two armies fight against each other, and, yes, and --- -
   Q.   So it is just one step up the ladder, shall we say, of
   A.   Yes.
   Q.   So it is not the whole way, but it is an interesting rung
        in the ladder?
   A.   Yes.

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