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Q.  --- of men and women?
A.  --- Auschwitz had two functions.  It was a slave labour
  camp and it was an extermination camp, and this clearly
  relates to the -- clearly relates to the slave labour camp.
Q.  What are they dying of?
A.  Well, as I am trying to say, in the slave labour camp they
  had a programme of extermination through work, and the
  life expectancy of a prisoner in the death, in the slave
  labour camp was a couple of weeks or probably a couple of
  months, and they died -- you can see actually see it from
  the document itself because the documents state, you know,
  what has to be improved.  The food has to be improved
  because the conditions, the food conditions, are
  completely unsufficient.  It says in the document, for
  instance, that prisoners are allowed to wear a coat
  outside during the winter.  So this gives, I think, a very
  clear answer that prisoners in the camp would die because
  they do not have the efficient, they do not have

. P-34

  sufficient clothing, and there are, of course, epidemics
  in the camp and, of course, there is a regular process of
  selection.  The people unfit for work, the sick and the
  weak prisoners would be selected and sent to the gas chambers.
I think, if you read the document with a
  reference to actually the conditions in the camp, the
  conditions in, let us say, August 1943, you have a very
  good idea of what the conditions were.  August '43, 1442
  people died, for instance, in the camp.
MR JUSTICE GRAY:  Can you explain what "durch mittel
  Belegstaff" is?
A.  This is the average number of prisoners.
MR IRVING:  Average camp strength.
A.  Yes.
MR JUSTICE GRAY:  Average prison population?
A.  Yes.
MR IRVING:  So the five columns, my Lord, average prison
  population of each of those camps.  The next column is the
  numbers of deaths which, in the case of Auschwitz and one
  or two of the other camps is being divided up as to men
  and women, separate figures.  The next column is the percentage ----
MR JUSTICE GRAY:  I think the rest is clear.
A.  Yes.  It is quite clear because the numbers here were
  separated because Auschwitz, the slave labour camps, was

. P-35

  divided into a women's camp and into a men's camp, so this
  gives you an indication that this relates clearly to the
  slave labour camp and nothing to do with the extermination
MR JUSTICE GRAY:  Which camp would be meant by "Lublin"?
A.  This is the -- this is Maidonek, complex of camps really.
MR IRVING:  If you go now to the next page after that
  statistical table, you have three pages showing a graph
  showing how over the three or four years, 1940 to 1943,
  the mortality has soared from various causes.  There are
  quite visible peak.  There is a big peak around about
  March 1943 which is on the second page.
MR JUSTICE GRAY:  Can you explain for our benefit what this
  covers?  Is it all concentration camps?
MR IRVING:  It is all the camps.  I draw the witness's
  attention first to the third of three pages.  It has a
  rubber stamp.  The senior doctor on Pohl's staff.  In
  other words, he is the head doctor or, I suppose, the
  surgeon general of the concentration camp system.  It has
  Himmler's initials on this document on the third page.
A.  Where is that?  Which page?
Q.  Do you have the graphs?
A.  Yes.
Q.  It will be the last page but one before the big yellow
  sheet.  Do you see, it has a rubber stamp saying that,
  effectively, it is the surgeon general of the

. P-36

  concentration camp system?
A.  Yes.
Q.  On the right it has Heinrich Himmler's own initials, so it
  has been submitted to Himmler?
A.  Yes, yes.
Q.  And it is a graph showing, the bottom two curves are the
  percentage figures, the middle curve is a percentage
  figure, the bottom curve appears to be numbers of death
  per month and the upper curve appears to be a cumulative
  figure.  But it is difficult to interpret, and I am not a
  statistician, all I am going to say is there are quite
  clear peaks.  They have gone through crises.  Would you
  accept that that is a fair statement?
A.  There were differences in the monthly death rate, yes,
  I can see that.
Q.  And the final page is the yellow page right at the end
  which is a contrast of the mortality rates in the
  concentration camps in the second half year of 1942
  compared with the second half year of 1943.  Again you can
  see in August and September 1942 and in August and
  September 1943 they have gone through a serious crisis of
  some kind.  There have been 11,000 deaths, 12,000 deaths,
  in the concentration camp system in corresponding August
  and September of both years.  So I am only going to ask
  one or two general questions now from what you have seen.
  In other words, there was a very high mortality rate in

. P-37

  these concentration camps?
A.  Yes, indeed.
Q.  How did they dispose of the bodies?
A.  Well, I am actually not prepared to -- I mean, I am not
  prepared here to comment on the concentration camps, but,
  as far as I know, they burnt the bodies in crematoria.
Q.  In crematoria, yes.  If these deaths had been caused
  through epidemics, would that be an appropriate way of
  disposing of the bodies?
A.  Yes, I think so.
Q.  Have you any indication as to what the major cause of
  deaths in Auschwitz was in 1942 or 1943?
A.  I do not think I should guess at what I think.  As far as
  I recall it, it was typhus, but I am not sure.  I am not
Q.  Have you even seen any references to this epidemic in the
  police decodes at the Public Record Office or in the
  United States?
A.  No.
Q.  Have you seen any references to the camp at Auschwitz
  being quarantined of what is called a lager spare?
A.  I cannot recall that.
Q.  My Lord, that is the only questions I have to put on the
  death statistics.
MR JUSTICE GRAY:  I am not sure that you are really putting
  what I suspect may be your case.  Are you suggesting (and

. P-38

  I am not sure this is the right witness anyway) that the
  crematoria were solely being used in order to burn the
  corpses of those who are shown on this graph to have died
  from typhus?
MR IRVING:  Let me put two or three more questions in that
  direction then, my Lord, to nail it down.
MR JUSTICE GRAY:  Yes, because if that is your case, you must
  put it fair and square and it may be Dr Longerich will
  say, "Well, I am not the right person to ask".
MR IRVING:  But he is not the right expert, yes.  Dr Longerich,
  from your knowledge of the concentration camp system or
  its workings, who would have the job of disposing of the
  bodies in the crematoria?  Would that be the
A.  I think so, yes.
Q.  And would they remove all the gold and valuables from
  these bodies first?
A.  Yes.
Q.  Would it be a very grisly and memorable task?
A.  I would suppose so, yes.
Q.  I do not think really, my Lord, I can ask any further
  questions on that.
A.  I am not sure, I am not really sure, I am also -- actually
  I am not prepared to go into details about the history of
  Auschwitz, and if this is a kind of, I do not know, I am
  not too sure about the sonderkommando here, and I should

. P-39

  probably -- we had expert in Auschwitz and I should
  probably simply say I am not sure here.
MR RAMPTON:  Can I make a suggestion?  If these documents be
  thought important, and if it be Mr Irving's case (which,
  by implication, I suppose it must be, forget all the other
  camps mentioned in these documents as they are nothing to
  do with this case) that the reference to Auschwitz is a
  reference to Auschwitz Birkenhau, then I think maybe the
  right thing to do, I do not know what your Lordship
  thinks, this gentleman is not an expert on Auschwitz, is
  to send these documents to Professor van Pelt and get him
  to put something in writing as a supplement to his report
  by of commentary on these documents.
MR IRVING:  Together with the appropriate part of the
MR RAMPTON:  Yes, certainly.
MR JUSTICE GRAY:  The first thing, though, is to get clear and,
  I mean, it is what I was trying to do, and I think
  Mr Rampton is also wishing for clarification, quite what
  you are making of these graphs.  They are new and I have
  no doubt there are good explanations why they were not put
  to Professor van Pelt.  But are you suggesting, just take
  Auschwitz because we have not gone into detail in the
  other camps, that the deaths that one infers were taking
  place at Auschwitz from these graphs were the reason why
  the crematoria were being employed in the way that various

. P-40

  witnesses have described they were being employed?
MR IRVING:  Let me put one more question then to the witness.
MR JUSTICE GRAY:  Well, I do not think the witness is really
  going to be very happy to answer.  I am really asking you
  to tell me and tell the Defendants.
MR IRVING:  In that case, if you look at the statistical table,
  my Lord, which is the third page, it would be page 18, I suppose.
MR JUSTICE GRAY:  What, the yellow one?
MR IRVING:  No, the table with columns.  You see that in one
  month, August, 1943, there were 2400 deaths in Auschwitz
  from whatever cause, and for the argument I would accept
  it is Auschwitz and not Birkenhau, then that is 2400
  bodies that have to be disposed of in that 31 days
  period.  It is 200 tonnes of bodies which is a memorable
  task for the sonderkommandos who had the wretched task of
  cremating them.  The suggestion I am making is that it is
  not beyond the bounds of probability that this is what
  they are recalling when they see -- one question which
  I think van Pelt would have to answer, if this question
  was to put to him, is did the Auschwitz camp, as opposed
  to Birkenhau, have the cremation capacity for disposing of
  bodies on that scale at this time or would the bodies have
  been sent to Birkenhau to be disposed of?
MR RAMPTON:  This is a terrible confusion in Mr Irving's mind,
  that the greater part of the workers, as opposed to what

. P-41

  I might call the murderees, who were put into the labour
  section after selection were housed at Birkenhau.
MR IRVING:  So this is Birkenhau then we are talking about?
MR RAMPTON:  No, no.  When one talks about the
  facility at Auschwitz, one is talking mainly but not
  exclusively of the two bunkers and the four crematoria
  where the people went immediately after they got off the
  train.  They never went into the work camp.
The work camp part housed the majority of the
  slave labour at Auschwitz Birkenhau.  That has been
  clearly described by Professor van Pelt.  We have seen the
  picture of the wire with the gate through it into the
  women's camp, and that is where the majority of those
  Auschwitz frauen would have been housed.  That evidence is
  already in court.
MR JUSTICE GRAY:  I think we have to be clear, you see, you did
  not really, I think, actually quite explain, Mr Irving,
  what it was that you were saying was not beyond the bounds
  of possibility.  I think we must really be absolutely
  clear about this.  Are you saying that it is not beyond
  the bounds of possibility that all the evidence that we
  have heard about bodies being burnt in the ----
MR IRVING:  The eyewitness evidence.
MR JUSTICE GRAY:  --- crematoria, whether at Birkenhau or at
  Auschwitz, was the burning of bodies of those who had died
  through disease?

. P-42

MR IRVING:  Of whom there are clearly a very large number.
MR JUSTICE GRAY:  Yes, but what is the answer to the question?
MR IRVING:  The answer is yes.
MR RAMPTON:  My Lord, again I think this is unsatisfactory for
  this witness, I really do, because ----
MR IRVING:  Except, of course, that I do accept that there were
  gassings on a small scale in Auschwitz as well.
MR RAMPTON:  This is most unsatisfactory because the evidence
  of Professor van Pelt is, whether it be right or wrong,
  which this witness may or may not know but he is not the
  right person to deal with it, the incineration capacity in
  crematoria 1, 2, 3, 4 and 5 at Auschwitz Birkenhau was by
  June 1943 something in the region 4,700 bodies a day, and
  this is a monthly figure.
MR JUSTICE GRAY:  I understand the point you are making, and
  that will be a point you will, no doubt, make later on,
  but I think we have got clear now from Mr Irving, because
  I am anxious that he states clearly what his case is and
  then it can be addressed by Professor van Pelt, but I
  think it is clear now that the suggestion is that, apart
  from a small number of gassings, which is something that
  has already been accepted by Mr Irving, he says that the
  crematoria were being used to -- everywhere were being
  used solely for the purpose of burning the bodies of those
  who died through disease or from overwork, I suppose.
MR RAMPTON:  Maybe, but on what appears to be, if we are right,

. P-43

  a relatively insignificant scale.
MR JUSTICE GRAY:  Well, that is obviously the point to be made,
  but I have not misrepresented your case, have I,
  Mr Irving?
MR IRVING:  No, that is correct, although I am not sure this
  was the way to have elicited it.  Let me ask two more
  related questions then.
MR IRVING:  Dr Longerich, you said that the prisoners who
  arrived at these camps they were selected and some were
  sent to work and others were exterminated without being
  registered, this is the common consensus, is it not, among
A.  Yes.
Q.  Why would the Germans have gone to such enormous trouble
  to list down to the last digit the numbers of those who
  were dying in the camps if just 100 yards down the road in
  the same camps they were killing them like flies without
  any kind of registry at all?
A.  Well, I think it is difficult to answer this question, you
  know, actually to reconstruct the rationality of this
  system.  I think what -- they had a kind of proper
  concentration camp system.  They wanted to know who was in
  the camp.  They wanted to control whether people actually
  were able to flee from the camp, for instance, and they
  did not keep statistics about the people they were going

. P-44

  to kill, as far as I am aware of.
Q.  This generates two further questions, Dr Longerich.  Have
  you heard of Dr Conrad Morgan, the chief Judge of the SS system?
A.  Yes, I have heard of him, yes.
Q.  And he was a lawyer in Frankfurt after the war, was he
  not?  He was not prosecuted for war crimes, just so we can
  establish his credentials.
A.  Yes.
Q.  He was an investigating judge who carried out
  investigations for the SS about atrocities in
  concentration camps, is that right?
A.  Yes.
Q.  And were any concentration camp kommandants hanged by the
  SS as a result of having committed what I would call wild atrocities?
A.  Yes, as far as I remember, Koch was, for instance, among them.
Q.  Buchenwald?  The kommandant of Buchenwald?
A.  Yes.
Q.  The husband of the notorious Elz Koch?
A.  Yes.
Q.  He was hanged in front of the prisoners of his own camp
  for having committed atrocities?
A.  I do not recall the circumstance, but I know that he was punished.

. P-45

Q.  And the kommandant of the infamous camp at Pleskau which
  figured in the film Schindler's List, was he also
  penalised, punished, by the SS for committing atrocities?
A.  I do not recall the details.
Q.  Did Conrad Morgan report back to Berlin that large numbers
  of illegal killings had been carried out by these Kommandants?
A.  Yes, I remember that.
Q.  Is this not an extraordinary business, in the light of the
  whole story of the Holocaust now, that the SS was
  conducting its own internal enquiries within its own
A.  Well, Himmler himself refers to this incident in his
  speech in Posnan.  He said actually, "We are proud that we
  carried out this operation in a proper way, except some
  exceptions", and he is clearly referring to these people.
  So they had an idea that one had to kill people properly,
  and what, you know, they did not hang Koch because he
  killed prisoners in the camp.  They were extreme, the
  conditions in the camp were extremely, for instance, the
  amount of looting and the amount of actually -- what is
  the expression in German?  [German]

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