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Last-Modified: 2000/07/25

Q.  Yes, but I think somewhere else in your report you admit
  that we know virtually nothing.  We still do not find any

. P-148

  orders about extermination -- I do not want to turn up the
  actual page, but I could, I suppose, find it, I
  have flagged it -- and it struck me as odd that here we
  are, 55 years down the road, and we are still floundering
  in some respects.  That is page 46, paragraph 16.  Let us
  go briefly back to there where you admit that we do not
  know the answers.  So do we know much more than we did in 1960?
A.  Well, we have a lot more evidence.
Q.  The state of contemporary research does not give
  sufficient evidence, you say, and here we are at the
  beginning of the 21st century?
MR JUSTICE GRAY:  No, no, I think that is taking, if I may say
  so, that particular little section right out of context.
A.  Yes.  I am referring here to the question whether the
  deportation of Jews to the East was at this time already a
  matter for the plan.  What I am saying, I do not know.
  The research does not allow us to make such a statement.
MR IRVING:  So there are lots of areas where we still, even
  after 60 years, cannot make a firm statement.
A.  That is due to the fact that many of these decisions, you
  know, were done obviously orally between, you know, Hitler
  and Himmler.  The Nazis systematically tried to destroy
  the files concerning this question.  As far as the files
  are survived, they are scattered around Europe.  We
  actually have only access to Eastern European archives

. P-149

  since a couple of years, so it is...
Q.  Is that not a bit of a cop out, if I can use a phrase, to
  say that the files have been destroyed and it was done
  verbally between Hitler and Himmler?  Is it not a bit of
  an ausflugt?
A.  No.  Himmler said it himself in the speech.  This is
  history which has not been written and will never be
  written.  So they tried systematically to destroy the
  evidence and to mislead the following generations
  about  ----
Q.  Having said that, he then had the speech printed in
  numerable copies and shown to every member of the SS
  General Staff?
A.  I replied this yesterday.  It was not, it was a secret
  speech.  It was not planned to publish it.  It was just to
  have a copy available for internal use.
Q.  Page 53, paragraph 1.3, please?  We looked at this
  document once or twice already.  Do you agree that the
  approval for the mass killing came from Heydrich and
  Himmler, and that there is no evidence that Hitler himself
  approved of this operation or, indeed, was even informed
  of it?
A.  I have only can refer to this document and if you read the
  document, it is only a reference to Himmler.
Q.  Yes.
A.  And to Heydrich, of course.

. P-150

Q.  And that if there had been these verbal discussions
  between Himmler and Hitler that you refer to, this is the
  kind of place you would have expected to find reference to
  it between ----
A.  Not necessarily.
Q.  But if there had been general knowledge, and one can
  assume that Gauleiter Greisler who has carried out this
  special treatment of 100,000 Jews must have been wondering
  at the back of his mind, "Is it OK what I am doing?" that
  Himmler passed on to him the word, "Well, I have cleared
  it with the boss"?
A.  Well, Greisler obviously no difficulties to carry out this
  task.  He did not ask for this kind of approval and you
  know that there were very rules about secrecy, and it was
  not every -- it was not always necessary to mention the
  name of Hitler in this or to call upon the authority of
  Hitler in this ----
Q.  Well, you say so, Dr Longerich, but, of course, Gauleiter
  Greisler, as a Gauleiter, formally came under Hitler, did
  he not, so where was Hitler in this equation?  Here is
  Greiser dealing direct with Himmler, saying, "I have done
  what you and Heydrich have authorized", and there is no
  mention of Hitler in the document?
A.  No.  There is no mentioning because Greiser was quite
  prepared to carry out this, to carry out this task and he
  assumed that Himmler had the authority to ask him to do

. P-151

Q.  Do you agree that Hitler did not order this operation
  then, that the operation was ordered by Himmler and
  Heydrich, as the document says?
A.  I have no written evidence that Hitler ordered this
  particular operation to kill these, to kill 100,000 in the
  Warthegau area.
Q.  If somebody says precisely the words you have just used,
  would that make them a Holocaust denier?
A.  Not this one sentence, no, of course not.
Q.  The next page, please, paragraph 2.3, are you able to
  identify any document in support of your assertion that
  two districts were to take the lead in the implementation
  of the Final Solution?
A.  Well, this is mainly, if you look at the, if you look at
  the history of the two extermination camps, at the two
  extermination camps, Belzec, if you look at the history of
  the extermination camp, Belzec, and if you look then, if
  you go a little bit further, if you do not stop here, and
  if you go a little bit further and look into spring 1942
  and look at the deportation, what happened, then it is
  quite clear that Belzec was particularly built for the
  killing of the Jews who are labelled non-fit for work in
  the district of Belzec and to a certain extent in the
  district of Galicia.
Q.  So once again you are extrapolating backwards from what

. P-152

  happened to presume an order ----
A.  Yes, but that is something that if you do not have a
  complete, if you do not have a complete documentation,
  this is what historians sometimes have to do.  They have
  to draw conclusion what, you know, actually from the
  following sequence or they have to go back a little bit.
Q.  That is what I have been saying for some weeks, in fact,
  and obviously we share the same kind of methods ----
A.  I am not sure about that.
Q.  --- we do not always come up with the same conclusions.
  Paragraph 2.4, the only sources that you quote for your
  assertions about the events in East Galicia are the
  testimony rendered in the 1968 trial and a secondary work
  Ostgalizien by Pohl?
A.  This is a dissertation published three years ago by a
  colleague I know very much and I know very closely and,
  I mean, I follow ----
Q.  Just like Gerlach, the same kind of thing?
A.  And this is a first case study about the killing of the
  Jews of Eastern Galicia.  There is a second book written
  at the same time which came to the same conclusion written
  by Zan Kuhlack, and I think I do not have to go to the
  local archives in Galicia to prove that the Nazis killed
  the Jews of Galicia.  It is quite evident.  These books
  have been reviewed.  These people have to confront
  colleagues' criticism and conferences.  I attended those

. P-153

  conferences and I am of no doubt about their academic
  qualifications, and I do not have to present, I think,
  always first-hand evidence or documentary evidence for
  something which is commonly acknowledged among historians
  and is not disputed.
MR JUSTICE GRAY:  Do you dispute this, Mr Irving?  Do you say
  that this all made up by somebody?
MR IRVING:  Well, the question I was going to ask is precisely
  what he just answered.  Is he able to identify any
  documentary evidence in support of his allegations or is
  it all second-hand?
MR JUSTICE GRAY:  No, but would you answer my question?  Are
  you disputing that these indiscriminate killings in
  Galicia took place?
MR IRVING:  Not in so many words.
MR JUSTICE GRAY:  Well, then let us move on.
MR IRVING:  The purpose of asking these questions, of course,
  is to establish, my Lord, the sometimes rather threadbare
  evidence that this report is based on.
MR JUSTICE GRAY:  But there is no point in saying evidence for
  a proposition is threadbare if you accept the proposition.
MR IRVING:  Well, I am accustomed to working with original
  documents rather than with secondary and tertiary sources.
MR JUSTICE GRAY:  It would not make any difference if you had
  the original documents because you accept what they show.
MR IRVING:  2.6, Dr Longerich, once again are you able to

. P-154

  identify any document that records what Himmler and
  Globocnik discussed at their meeting on October 13th,
  other than, presumably, the Dienstkalender?
A.  Yes, it is in the Dienst calendar, you have it in front of
  you probably.
Q.  They were just talking about the einfluss der Juden,
  I suppose, or something like that?
A.  Yes, and then there is the BBC file of Globocnik and there
  is a very interesting exchange of letters, and you can
  come to this conclusion if you read through that.
Q.  And on the basis of those two sources, you then say: "It
  is presumably at this meeting that Globocnik received the
  assignment to build the Belzec extermination camp"?
A.  Just one second, well, we know that they met and we know
  that Globocnik from the internal correspondence of his
  office in Lublin, we know that he was looking for more
  radical solutions for the Jewish question.  Then he met
  Himmler and after that they started to build the
  extermination camp of Auschwitz.
This is a typical, I mean, in this field we have
  to rely, what we are trying to do, we are trying to
  reconstruct the history of the decision-making process.
  This means that because the evidence is sometimes or is
  sometimes fragmented, we have to put together pieces and
  have to draw conclusions from that.
Q.  Yes.

. P-155

A.  So it is not so easy, you do not have the daily or the
  weekly records of the conversations between Himmler and
  Hitler about the Holocaust.  We have to use these bits and
  pieces and put it together and to come to our
Q.  Very interesting.
A.  Of course, I made here, of course, these kind of
  reservations when I am not absolutely sure that they
  decided this day, it is an assumption based on documentary
  evidence that they probably at this day as I think made
  the decision to build an extermination camp for the
  district of Lublin which then existed, and there were
  people killed in this extermination camp which I think is
  also part of the evidence.
Q.  Now just a minor diversion here.  Am I right in saying it
  is a perfectly reasonable process as historian or writer
  you get fragmentary documents, sometimes only half a line,
  sometimes a scrap of handwriting.  You add your own
  knowledge, you add your experience, the 30 years you have
  worked in the archives, your general body of information,
  and on the basis of that you try to represent, in as
  accurate and genuine a form as possible, what, on the
  balance of probabilities, those fragments of information mean.
A.  And you have to include, of course, every piece you find.
  You cannot neglect anything.

. P-156

Q.  Yes, but here you had very little that you could have
  neglected, because your result said it is very
  fragmentary, is it not?
A.  Sometimes these things are very fragmentary.
Q.  What I just described is the normal process of writing
  history on the basis of very scant records?
A.  If the record is fragmented, yes.
Q.  Are you familiar with the writings of Jan Karski?  I will
  ask you about one particular one, page 56, paragraph 2.7.
  Are you aware of the first report that a Polish emissary
  called Jan Karski wrote?  He gave it to the Polish
  government in exile early 1940, in which he described a
  visit in December 1939 to a transit camp for Jews at Belzec?
A.  Yes.  A camp existed at Belzec before this.  There was a
  large slave labour camp in Belzec before this time.
  Belzec was just on the demarcation line between the Soviet
  and the German sphere of influence in Poland.  They
  employed Jewish slave labour in 1939 and 1940 to build
  what they called the Buchgraben, the fortification at the
  river Buch.  So there was a camp there and the living
  conditions in the camp were quite horrid.
Q.  Jan Karski describes this ----
MR JUSTICE GRAY:  Mr Irving, before you go on about Mr Karski,
  I had thought you accepted that at Belzec there were many
  thousands, tens if not hundreds of thousands, of Jews

. P-157

  killed by gassing.  What is the point of putting that
  Mr Karski took the view it was a transit camp?
MR IRVING:  I am looking at the quality of the sources.
  I appreciate this point.  We will just concentrate on the
  figures then.  Is your primary source on Belzec Michael
  Tregenza article published in the Wiener Library bulletin?
A.  No, my primary source is the Belzec verdict in German the
  court.  Of course I am familiar with the article.
Q.  It is in your footnote 259.
A.  Yes, it refers to it but it refers first of all to
  evidence from German court material.
Q.  So you accepted in your footnote 259 that Tregenza is reliable?
A.  No, I just quoted him here.  The footnote is about an
  attempt to reconstruct the history of the setting up of
  Belzec.  So I quoted here different statements from
  actually people who participated, worked, who actually
  built this up, and then I said in the footnote Tregenza as
  well confirmed the statement.  He accepted the statement
  as a kind of additional source, but I am primarily relying
  on the Polish workers who built there, and who gave us
  evidence about the history of the camp itself.
Q.  Have you disregarded anything that Tregenza wrote in his report?
A.  I only referred, I think, to his article here.  This does
  not mean I accepted every line that he has written about

. P-158

  the camp.
Q.  So, if he had written a number of totally absurd
  statements that would have implied to you that he had
  never been anywhere near the place?
MR JUSTICE GRAY:  There is no doubt that Belzec was
  constructed, is there?
MR IRVING:  Unfortunately, he is the source for one million
  being killed apparently?
A.  No, not in my report.
Q.  Do you endorse Tregenza's claim that more than a million
  Jews were killed at Belzec?
A.  We do not know the exact number.  I think best estimations
  were given in the German Belzec trial.  They said between
  500 and 600,000 people.  So I would assume that the number
  one million could be seen as exaggerated.  I am only
  quoting this article one time and, if he made an absurd
  statement there, I would not quote the article of course.
Q.  If he made a dozen absurd statements, would you have quoted it?
A.  Please criticise me if I quote him.  I think I only quoted
  him one once and I only quoted that he actually confirms
  these statements of documents which I found elsewhere.
MR JUSTICE GRAY:  I am sorry to keep interrupting but, if I do
  not understand, I may as well say so.  You quote whatever
  he is called, Tregenza, simply for the date when the
  construction of Belzec started.  You do not rely on him,

. P-159

  as I understand it, am I right, Dr Longerich, for the
  number killed there?
A.  No, exactly.
Q.  You rely on the German court documents for that and they
  give a different figure.  So why are we spending a long
  time on whether he is a reliable witness?
MR IRVING:  We are going to spend a short time.  I could have
  spent much longer describing all the absurd statements
  which make it quite plain that Tregenza was never anywhere
  near the place and that any reasonable historian, reading
  Tregenza's report, would have disqualified that source
  completely.  Paragraph 2.8, page 57, your only source for
  the claim that Globocnik had an assignment to kill the
  Jews of the Lublin and Galicia districts is a secondary
  work again, Pohl's Lublin?
A.  I am stating here that Globocnik had not yet received the
  order to prepare for the killing of all Jews in the
  Generalgouvernement, so this is the key sentence here.
  I came to the conclusion actually by looking at the
  history of Belzec because Belzec was obviously too small,
  put it this way, to kill all the Jews of the
  Generalgouvernement.  So I think in my attempt to
  reconstruct events, Belzec was first of all designed to
  kill the Jews non-fit for work in the district of Lublin,
  and in the district of Galicia, but not the killing centre
  for the whole Generalgouvernement.  I came to this

. P-160

  conclusion by looking actually at the size of this installation.
Q.  In Belzec?
A.  Belzec.
Q.  So we do not have very much information on the size
  anyway, do we?  We are very ill informed about it.
A.  Because these camps were destroyed systematically by the
  Nazis at the end of the war.

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