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Last-Modified: 2000/07/25

Q.  Can I just take you back, and I am sure my Lord will
  understand why, to page 53, paragraph 1.2, the third
  line.  There is a sentence there: "750 Jews were killed in
  gas vans."  Do you see that?  The beginning of the
  sentence says: "In an action lasting several days at the
  end of November 700 Jews were killed in gas vans".  So, if
  it took several days to kill 700 Jews in gas vans, can you
  estimate how long it would take to kill 97,000?
A.  They were just experimenting at this time.  They improved
  their technique.  This statement does not say that they
  were trying to kill as many Jews as possible.  It just
  says they killed 700 Jews in a couple of days.  It does
  not make any sense to draw conclusions from that to their
  capacity, to their ability to kill Jews in gas vans.
Q.  So this was just experimental at this stage, was it?
A.  If you like to call the killing of 700 people as
  experimental, yes, then I have to agree, in comparison to
  what happened after that 97,000.

. P-161

Q.  Dr Longerich, you yourself used the phrase, and I quote
  verbatim, they were just experimenting at this stage.  I
  did not use the word.  You did.
A.  I tried to put it to you, I have to admit, in a kind of
  cynical way, to say, well, they were improving, wait a
  little bit, wait a couple of months and they were able to
  kill 97,000 people within six months.
Q.  With the same numbers of gas vans?  Three gas vans could
  kill 97,000?
A.  I think in the meantime they changed the models.  They
  worked on the models, as the report from June 1942 shows
  us.  They tried their best to extend the capacity of the
  gas vans.  Of course the use of Chelmno was a kind of
  improvement because they were able to deceive people, to
  say to them: Well, actually only entering a shower room,
  the shower room was in fact the gas, so this whole thing
  was much more effective a couple of months later than this
  one here.
Q.  Do you sometimes get the impression, Dr Longerich, that
  some of these figures that are put in letters and
  documents, or even eyewitness statements, are just fantasy
  figures?  They have very little relation to fact?
A.  That is not my general view.
Q.  Can I take you to page 56 please, line 8.  There is a
  sentence there on line 8 which says:  "On 12th October
  1941, 10,000 to 12,000 Jews were murdered in one town".

. P-162

  Is that right?
A.  Yes.
Q.  Would you likes to comment on the logistics of an
  operation of that scale?  How many men would be involved?
  How many shooters?  How many trucks?  How many pits?
A.  I went through the history of mass executions for quite a
  time.  I studied this for the book I wrote extensively.
  I looked at dozens of German court proceedings and I have
  a kind of idea how it was feasible to do that.  You
  actually needed to kill thousands of people, even 10,000
  people, you needed actually ----
Q.  In one day?
A.  Yes, on one day.
Q.  It just says on one day.
A.  Yes, it was possible.  You only needed a quite limited
  number of people who would shoot these people on the pits.
Q.  1,000 tons of bodies?
MR JUSTICE GRAY:  Mr Irving, when I asked you -- I am sorry to
  interrupt -- about 20 minutes ago, when we were on this
  paragraph before, whether you disputed the indiscriminate
  shootings in Galicia, you said no.  You are now putting to
  him that in some way it would have been impossible to
  dispose of the corpses and you are now challenging the killings.
MR IRVING:  Your Lordship may not have heard the introductory
  question which is does this witness have the impression

. P-163

  sometimes that these figures are fantasy figures.
MR JUSTICE GRAY:  So you are challenging the figures?
MR IRVING:  I am challenging globally these kinds of statistics
  which are in the history books and in the reports on the
  basis of what is practicable, and what is, on the basis of
  common sense, likely.
A.  I do not know as far as one can speak about common sense
  when it comes to mass killings, but this is called the
  bloody Sunday of Stanislaw.  So it is a tragedy which is
  well-known.  It is well-researched.
MR IRVING:  How many men were involved in the actual killing operation?
A.  I think, as far as I am aware, several hundred at least.
  Is it really necessary that I --
MR IRVING:  No, I have left that point now.
MR RAMPTON:  Without deigning to wait for the witness's full
  answer, I have to say.
MR JUSTICE GRAY:  Actually, what you would not have seen is
  that I rather suggested to Dr Longerich that we might move
  on from Galicia.
MR IRVING:  I did not see that either but I had already decided
  to move on.
MR JUSTICE GRAY:  We are all agreed.  Let us move on.
MR IRVING:  If your Lordship thinks that was not a valid point
  to make, then I will avoid making points like that in

. P-164

MR JUSTICE GRAY:  I think the killings in Galicia are a bit of
  a side issue, I am afraid.
MR IRVING:  It is the figures, the statistics, my Lord.
MR JUSTICE GRAY:  Even that.
MR IRVING:  If somebody is accused of Holocaust denial because
  he says the figures are too high.
MR JUSTICE GRAY:  We are talking about that particular
  obviously ghastly incident in Galicia, and I do not really
  think that that is what this case is centrally about.
MR IRVING:  Page 59, paragraph 3, please.  Two days later
  Rosenberg spoke at a press conference about the
  eradication of the Jews of Europe.  Was this supposed to
  be secret or not, this operation?
A.  The operation was secret.
Q.  He orders a press conference and talks about it.
A.  This was quoted yesterday.  I quoted this yesterday
  again.  This was under the heading "secret".  The
  journalists were not allowed to write about it.  There was
  a section of the press conference where it actually was
  said: This is now confidential, a confidential
  information, you are not allowed to write about this issue.
Q.  I do not want to labour the point, but what kind of top
  secret issue is it?  I do not remember General Leslie
  Groves holding top secret background briefings to the
  press about the Manhattan project, for example.  Either

. P-165

  something is top state secret or it is not.  You do not
  hold even background briefings with the press about it.
A.  I think you have to read the statement very carefully.
  "There are still about 6 million Jews in the east, and
  this question can only be solved through a biological
  eradication of all of Jewry in Europe.  The Jewish
  question will only be solved for Germany when the last Jew
  has left German territory and for Europe when there is no
  longer a Jew left standing on the European Continent".  He
  is not literally saying well, actually, we are killing at
  the moment people, women, men and children in gas
  chambers.  He is talking about this in very general
  phrases.  It is like Hitler spoke about ausrottung and
  vernichtung and I quote in the report No. 1.  I quote a
  number of other examples.  In every system where you have
  a principle of secrecy, of course, things are going wrong
  and people are talking too much to the press, and giving a
  kind of insight into the process.  These things happen.
Q.  Do you agree that, when Rosenberg specifically names the
  option as being to push them over the Urals as one way of
  eradicating them, then such expulsion over the Urals does
  not necessarily mean to kill them?
A.  I am not sure now about your question, whether it is
  actually a pronouncement to kill them or not to kill them.
Q.  Would you agree that the Rosenberg reference to

. P-166

  eradication therefore does not necessarily mean
physical extermination or killing?
A.  I look at the German text.  I am sorry.  Well, he says in
  the German:  "Und dazu ist es notig, sie uber den Ural zu
  drangen oder sonst irgendwie zur Ausmerzung zu bringen."
  For this it is necessary to push them over the Urals or
  otherwise eradicate them.  I think this is quite clear:
  Otherwise eradicate them.  So I think the phrase to push
  them over the Urals is a clear expression, a metaphor for killing.
Q.  Dr Longerich, I am looking at my little dictionary from
  yesterday, the 1935 one, and it says for Ausmerzung -- I
  did not know this but here we are, we take a plunge -- to
  expunge or to eliminate, to expunge them.
A.  To eliminate, I think, would be the right expression here.
Q.  Primary one to expunge?
A.  In this case I think, if somebody speaks about millions of
  people, Jews, who actually ----
Q.  You are going to boot them out or expunge them?
A.  Yes, but you have to look at the context.  I think, if you
  speak end of 1941, after half a million of Soviet Jews had
  been killed, at least, if a leading Nazi speaks about
  Ausmerzung, I think the second meaning would here be the
  better translation.
Q.  You are extrapolating backwards from your knowledge of
  what happened to assign a meaning to the word which is

. P-167

  different from the primary meaning given by the dictionaries.
A.  What happened at the time, and Rosenberg was of course
  quite aware about the----
MR RAMPTON:  Extrapolating backwards is unfair.  Putting two
  contemporary events side by side and drawing an inference
  would be more like it.
MR IRVING:  This press conference was in November 1941,
  I believe, is that right?
A.  Yes.
Q.  Mr Rampton has rightly said that events happened side by
  side.  At this time, 18th November, had the physical
  extermination of the Jews of Germany begun?
A.  No, but of the Soviet Jews.  I think the phrase to push
  them over the Urals is a very clear hint.
Q.  We now come to the Wannsee conference.  A general
  question: Are you able to identify any documentary
  evidence that proves that by the time of the Wannsee
  conference, which is January 20th 1942, the general plan
  for deportation had changed into one for mass murder?
A.  I think the Wannsee conference gives us a clear insight
  that they are about to change their plan.  I think we have
  to go into the detail to make this point more clear.
Q.  They had not yet changed but they are about to?
A.  They are about to change, yes.
Q.  In your opinion?

. P-168

A.  Yes.
Q.  So at the time that these gentlemen meet around their
  table in Berlin Wannsee, the change has not taken place,
  but sometime sooner or later after that the change will
  take place?
A.  Sooner, yes.
Q.  Is page 61 now, please, paragraph 2.  The passage that you
  identify as central concerning the general aims of the
  future Jewish policy is as follows, Dr Longerich: "A
  further possible solution instead of emigration has come
  up.  After appropriate approval by the Fuhrer, the
  evacuation of the Jews to the East has stepped into its
  place".  Let us have a look at that.  By "evacuation of
  the Jews", do you mean evacuation or killing?
A.  I think we have to look at the text of the Wannsee.
MR JUSTICE GRAY:  I am trying to find it.  For some reason it
  is not in N1.
MR RAMPTON:  We do not have it.
MR JUSTICE GRAY:  I thought I had looked at it.
MR RAMPTON:  It is nobody's fault.  I have asked.  There is a
  version printed in Nokes & Pridham, but I have not even
  got that.
MR JUSTICE GRAY:  I thought we had looked at it at some stage.
MR RAMPTON:  It is an extraordinary state of affairs, but
  nobody on either side of the court seems to have a text of
  the Wannsee conference.

. P-169

MR IRVING:  I do not mind very much because it is not a very
  important document.
MR RAMPTON:  I am not concerned with whether Mr Irving minds
  about that or anything else, to be quite honest.  I am
  concerned that it is not there when your Lordship wants to
  see it.
MR JUSTICE GRAY:  Is it obtainable?
MR RAMPTON:  It is printed in a well-known three volume history
  of Nazi Germany by two people from Exeter University
  called Nokes & Pridham.  It is referenced under that
  heading in a number of the reports, particularly Evans,
  but it is not in the documents.
MR IRVING:  My Lord, I can provide immediately an English
  translation on Monday.
MR JUSTICE GRAY:  I think it probably is a good idea to have it.
MR RAMPTON: I agree.
MR IRVING:  It is on my website.
MR JUSTICE GRAY: It is a document that one is going to have to
  look at quite carefully.
A.  I have the English text here in this documentation.
A.  Yes, I have it here.
MR JUSTICE GRAY:  Let us try and deal with the questions now.
MR IRVING:  The question was, in your central passage the
  evacuation of the Jews to the East has stepped into its

. P-170

  place.  Can we accept that evacuation has its real meaning
  there or is there an innuendo?
A.  This is not the central passage.  He is referring here to
  two different things.  First of all, he is actually
  telling the history of how the Nazis tried to solve the
  Jewish question.  He is saying here: "A further possible
  solution to emigration has come up.  After appropriate
  approval by the Fuhrer the evacuation of the Jews to the
  East has stepped into its place".  "Into its place" is in
  the place of emigration.  Then it goes on and says: "These
  actions however must be regarded only as an alternative
  solution.  But already the practical experience is being
  gathered which is of great importance to the coming Final
  Solution of the Jewish question".  Now in the next
  paragraph he is explaining what the coming Final Solution
  of the Jewish question is.  So he is referring to
  emigration, then to deportation, and then he is saying the
  next step, we are entering now the Final Solution, the
  coming Final Solution, and the central passage where he
  explains (Heydrich) what the coming Final Solution is, is
  quoted in my report on page 61 in the last paragraph.
  This is the central passage, I think.
A.  This is past tense.  This is history, the deportation.  We
  are now approaching the coming Final Solution.  That is
  what the Wannsee conference is about.

. P-171

MR JUSTICE GRAY:  What you say is that it is what he does not
  say rather than what he does say in relation to those who
  are unfit to work which is significant?  Have I understood
  you correctly?
A.  Yes, he is now explaining what the coming Final Solution
  is.  These are these famous sentences:  "Under the
  appropriate direction, the Jews shall now be put to work
  in the course of the Final Solution.  Organized into large
  work gangs and segregated according to sex, those Jews fit
  for work will be led into these areas as road builders,
  whereby, no doubt, a large part will fall out by natural
  elimination.  The remainder who will survive -- and they
  will certainly be those who have the greatest power of
  endurance -- will have to be dealt with accordingly.  For,
  if released, they would, according to the natural
  selection of the fittest, form the seed of a new Jewish
  regeneration".  I think the key word in German here is
  "entsprechend behandelt werden mussen", to be dealt with accordingly.
MR IRVING:  Treated accordingly, yes.
A.  This is the central passage of the Wannsee conference and
  this is where Heydrich explains what the coming Final Solution is.
Q.  Of course it depends how you translate it, does it not?
A.  The German text for me is pretty clear.
Q.  What about that phrase "bei Freilassung" which originally

. P-172

  you actually left out in your book?  You left those words
  out entirely, did you not, because it is difficult to get
  past those words "bei Freilassung"?
A.  No.  I am not sure about the book ----
Q.  I am sure because you left the words out of that quotation.
A.  I am quite happy that you read my book but we are talking
  about this text here.  If there is a mistake I will
  correct it.
Q.  You translate it as:  For the Jews, if released, would,
  according to natural selection of the fittest, form the
  seed of a new Jewish regeneration.
A.  Yes.
Q.  The word is not "if released".  It is not conditional.  It
  is "bei Freilassung", which means upon release, does it not?
A.  No.  In the case of release, bei Freilassung.
Q.  Upon release?
A.  No.
Q.  It is not conditional at all.  There is no if and but
  about it.  It says "bei Freilassung".
A.  Yes, "bei Freilassung".  This is meant in the context as
MR JUSTICE GRAY:  I think this is probably the key part, in a
  way, of your report, Dr Longerich.  The question, if
  I have understood it right, is that what Heydrich is

. P-173

  really proposing is that one would, by a process of
  natural selection, have the fittest Jews forming the seed
  of what he is intending should be a new Jewish
  regeneration.  Is that the suggestion, Mr Irving?
MR IRVING:  That is the danger which they foresee, and so they
  are going to have to be kept, for example, physically
  outside the Reich territories.  They must be prevented
  from returning.
MR JUSTICE GRAY:  Yes, but the idea that you are putting that
  Heydrich has is that there should be a new Jewish
  regeneration born of the fittest Jews who survive the
  labour camps.
MR IRVING:  He fears that they may be.  He is not saying they
  should be.  He says that if, upon release----

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