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Last-Modified: 2000/07/25

Q.  Are they all unanimous in saying, "Yes, we all discussed killing"?
A.  No, of course not.  They were taken during the Nuremberg
  trial, the main trial, and during the so-called [German],
  that is the trial against the administration, and they
  were all evasive.I mean, for instance, the Secretary of
  State, Noimann, said he was not actually there, you know.
  You have this kind of quality.  They were
  self-exculpatory.  This is the largest killing, murderous
  operation in modern history and this is the key document
  we have.  Of course, everybody who was there, every
  Secretary of State, every Civil Servant, would, of course,
  do everything to distance themselves from these minutes.
  So they had all kinds of -----
Q.  Is there not evidence that Stuchart, in fact, sold at out
  Nuremberg to the Americans as a witness, and that if he
  had been there and he had known of what really happened,
  he would have been very willing to tell the Americans what happened?
A.  I do not see where, what is the evidence for that.
Q.  Well, are you aware that Stuchart was, when all the rest
  around him were being sentenced to 10 years, 20 years and
  the gallows, he was released, sentenced to time served?

. P-187



A.  What does it -- I cannot see the point.
MR JUSTICE GRAY:  So what?
A.  What does it?
MR IRVING:  Well, the point I am making, my Lord, is there were
  about 20 participants in the Wannsee Conference.  Any one
  of them would have had a severe temptation to go to the
  Americans and say, "If you guarantee that I am going to be
  released in the foreseeable future, I will tell you what
  you want to hear".
A.  Well, that is your speculation.  I cannot follow that.
Q.  And they all maintained a solid front and said, no, there
  was no such discussion?
A.  Well, they find -- there was nothing like a solid front.
  They had all, I mean, all kind of answers to this
  question, all kinds of evasion, all kinds of different
  tactics.  Most of them, most of them pretended that
  actually the only issue there was the Mischlinger question
  which formed the second part of the Wannsee Conference,
  and that they simply did not realize that Heydrich was
  talking about killing, and this was what most of the
  witnesses actually said.
MR JUSTICE GRAY:  What they said that the January part ----
A.  Yes.
Q.  --- of the Wannsee was all about Mischlinger?
A.  They were referring in their answers, referring to the
  second part of the Wannsee Conference, yes.

. P-188



Q.  Is there any reference to Mischlinger in the protocol of
  the January part of the Wannsee Conference?
A.  Yes.  The Wannsee conference, the minutes has two parts.
  First of all, it is Heydrich's speech, this general speech
  about the fate of the Jews, and the second part is
  about -- the Wannsee Conference is about how and who, how
  was the first part and who was the second part?
MR JUSTICE GRAY:  We do need to have a translation of the minutes.
MR IRVING:  I have a complete translation on my website site,
  so it is very easy to provide it.  (To the witness):
  Dr Longerich, the only other point on the Wannsee
  Conference is statistics, on population statistics that it
  contains.  Are they accurate, in your view?
A.  Not entirely.  There are some mistakes in it, I think.
Q.  There are some gross errors, are there not?
A.  Which one?
Q.  The French Jewish population is overestimated substantially?
A.  No, what they did, they made a mistake.  That have a figure of ----
Q.  700,000?
A.  Yes, and I think an additional figure for the occupied
  territory of 165 -- so this is a kind of confusion.  They
  actually double counted the people in the occupied territory.

. P-189



Q.  What about Buhler's reference to 2.5 million Jews in the
  Generalgouvernement?  Was that an accurate estimate or was it high?
A.  That is probably a little bit exaggerated.
Q.  You say that is exaggerated, but, of course, Dr Frank in
  his famous December 16th 1941 speech talks of 3.5 million Jews?
A.  No, he says at 2.5 and they are [German] -- the families,
  their relatives, or everybody, he is talking about, I
  think he is talking about the so-called mixed Mischlinger
  or mixed Jews.  He gives two figures.  I think one is 2.5
  and then he says, "Well, and their dependents and people
  that are related to them" and then he comes to 3.5.  The
  figure 3.5 is too high.
Q.  65.  Go to page 65, please, paragraph 4 -- page 66,
  paragraph 5, please.  You say:  "There is conclusive proof
  of 43 transports, which as a rule carried 1,000 people
  each", but the only source you gave on this is one of your own books?
A.  Yes.  There is more research about this in my book.  This
  is, sorry, from where is that from?
MR JUSTICE GRAY:  To Lublin, I think.
A.  Yes, to Lublin.  In the book I have a -- it is a list of
  the trains.  I list every train with arrival dates and so on.
Q.  Is that challenged, Mr Irving?  Do you say there were not?

. P-190



MR IRVING:  No.  I am just curious to know what his sources
  were.  Do you agree that the transports were for the
  purpose of deportation to ghettos and not for
  extermination?
A.  We are talking now about the spring of 1942, so we are
  still in this transitional phase, so they have not started
  what they call in the Wannsee Conference their coming
  Final Solution.  They are still deporting people into
  ghettos and not directly -- German Jews or Jews from
  Germany, not directly, not directly into extermination
  camps.  They will start this in May 1942.
Q.  67, paragraph 10.  What did Heydrich mean by the
  resettlement of altogether half a million Jews out of
  Europe to the East?  This is the second sentence from the
  end of paragraph 10.
A.  Well, I think this is in April.
Q.  1942?
A.  April 1942.  I think they are, they talked in the Wannsee
  Conference, they talked about this, the coming Final
  Solution, about this large programme to deport Jews to the
  East and to kill them there.  And I think this is -- they
  are not going to shift their plans from bringing people to
  ghettos, and they now shift these plans to the next stage
  where they are actually about to send Jews directly to
  extermination camps.
So you can see from this document that they are

. P-191



  in the [German] they are planning on a larger programme,
  and I think they are just about to make the decision
  actually that these new transports will go directly into
  extermination camps, but I have no ----
Q.  No proof?
A.  --- no final evidence for that.  This is a document which
  was unknown so far.  And we will find more and this will
  add to our knowledge.
Q.  It is quite unsatisfactory, is it not, that every time we
  want to deduce an extermination inference, we have to end
  up by saying, "Unfortunately, there is no proof, it is
  just one's own conclusion"?
A.  No, I do not think I say that.
MR JUSTICE GRAY:  Mr Irving, you accept that hundreds of
  thousands of Jews were exterminated.
MR IRVING:  Yes.
MR JUSTICE GRAY:  So why are you criticising the inference that
  Dr Longerich draws that that was what was proposed?
MR IRVING:  We are looking at the overall figures, my Lord, we
  have to if we are to avoid the allegation of Holocaust denial.
MR JUSTICE GRAY:  You are on the figure of half a million?
MR IRVING:  I beg your pardon?
MR JUSTICE GRAY:  You are tackling the figure of half a million?
MR IRVING:  Yes.  That is a substantial number going to the

. P-192



  East.  We needed to know what it is ----
A.  Yes, well, there is more evidence for that.  I made a
  calculation here.  He said in Bratislava this would
  comprise six countries, that is Germany, Belgium,
  Netherlands, France and the Protectorate and Slovakia, and
  if you look at the planning for the deportation at the
  first phase of deportations in spring 1942, we can see,
  you know, 55,000 people from Germany, about 70,000,
  I think, from Slovakia, you can actually look at the
  different countries, look at the figures and you come to
  the conclusion that 500,000 is actually what they were
  going to plan at this time.
MR JUSTICE GRAY:  This is planning?  It is not what happened?
A.  This is planning.  This is planning.
MR IRVING:  But, you see, the problem is in paragraph 11 now we
  come to the Dannecker Conference of June 11th 1942.
  Dannecker was Eichmann's man in Paris, is that right?
A.  Yes, that is right.
Q.  They are talking about shipping Jews from France to
  Auschwitz or to ----
A.  Yes.
Q.  The document here is quite specific.  We have the actual
  German wording, have we not?
A.  Yes.
Q.  [German - document not provided]  "We agree that from the
  Netherlands 15,000, from Belgium 10,000 and from France,

. P-193



  including the unoccupied territory, altogether 100,000
  Jews are to be deported".  The note states that "Himmler",
  as you say, on page 68, line 3,  "had given the order to
'provide larger quantities of Jews to the Auschwitz
  concentration camp, to increase the workforce'"?
A.  Yes.
Q.  The primary condition is they have got to be able- bodied,
  between 16 and 40 years old, but the transports are also
  allowed to include 10 per cent who are not fit for work.
  Have you any conclusion you want to draw on that?
A.  Yes, I think it shows you that they are not at this stage,
  not only using Jews as slave labour, but they also at this
  stage have started to include in the transport Jews who
  are not fit for work.  So the plan is, obviously, to kill
  them on arrival in Auschwitz.  So, the coming Final
  Solution actually started.  People are directly deported
  to extermination camps.
Q.  Is that the only conclusion you draw from that, that there
  is no other possible interpretation of the 10 per cent,
  that there may have been a desire there possibly to keep
  families together or to tell them they are going to be
  kept together or something like that?
A.  No.  I would not at this stage, if you look at the reality
  in transition camps and transports at camps, I would not,
  I cannot agree that they had this humanitarian considerations.

. P-194



Q.  Have you seen any documents relating to the building in
  West Germany of special camps for the French to be housed
  in?  They actually went to Auschwitz and came back from
  Auschwitz to these special camps.
A.  Well, there is a small number of Jews who were deported
  from France, a relatively small number, who were sent to
  war camps in Upper Silesia.  This is, you announce this a
  couple of, I think two or three weeks ago that you wanted
  to actually prove that the majority of the Jews who were
  deported from France were not sent to Auschwitz but were
  used in a kind of labour programme, but I have not
  received the documentation yet so I am ----
Q.  Have you seen the document that was used in the trial of
  Frans Novac, Eichmann's transportation officer?
A.  Yes, well, again if you have those documents, if they are
  available, I would like to look at them and to comment on them.
Q.  Perhaps I could just ask you to look at the two indented
  paragraphs in that letter, in that document.
A.  Yes, again I am asked here to comment on a text prepared
  by Mr Irving.  It is not an original document.
MR JUSTICE GRAY:  I have no idea what you are looking at.  Have
  you got copies for anybody else, Mr Irving?
MR IRVING:  If the witness is not prepared to answer a question
  on that document, then...
MR JUSTICE GRAY:  He has not said he is not; he has just said

. P-195



  he has not seen it before.
MR IRVING:  He is unhappy about it.
MR JUSTICE GRAY:  But, I mean, it is a bit unsatisfactory if
  there are not any copies for anybody else because
  Mr Rampton would like probably to follow it as well.
MR IRVING:  I am just hopelessly badly prepared, unfortunately.
MR JUSTICE GRAY:  No, you are normally extremely
  well-prepared.  I mean that.
MR IRVING:  Not having the facilities that the huge team on the
  other side have.
MR JUSTICE GRAY:  Let us try.  Yes, well, I know.
MR RAMPTON:  We do apologise for being huge!
MR JUSTICE GRAY:  Let us try to see whether we can manage
  without a copy.  What is the question, Mr Irving?  You
  probably do not have your own copy now.
MR IRVING:  No.  Could I have it back to ask you a question?
  I will read it out.  The document is a Schnell brief which
  is an express letter from Himmler to the Minister of
  Finance, dated August 17th 1942.  Your Lordship may
  remember we have had this document before, before the
  court, about four weeks ago.
MR RAMPTON:  I have not seen it.
MR JUSTICE GRAY:  I have to say I do not remember it.
MR IRVING:  And it is headed:  "Costs involved in the
  evacuation of the Jews from France".  Now, this letter is
  in the period when you claim that the comprehensive

. P-196



  extermination period has begun, is it not?
A.  Yes, yes.
Q.  The relevant sections reads, and it is in German, but I
  will translate it:  "In the framework of the general
  solution of the Jewish problem and for the security of the
  occupation forces in the occupied French territories, Jews
  are continually being transported from France to the
  Reich.  At first the evacuated Jews are being housed in
  the concentration camp, Auschwitz, but a special reception
  camp is to be built in the western Reich territory for
  them.  The barracks necessary for this are already stored
  ready for shipment in the occupied French territory and
  they can be transported to the Reich immediately after
  payment of the purchase sum of 340,000 Reichsmarks.  It is
  intended every month to send 13 railway trains with Jews
  into the Reich territory.  By 10th August 1942", that is a
  week before the date of this letter, "18 trains from
  France have gone to the camp in Auschwitz which have
  involved the following transportation costs, 76,000
  Reichsmarks as far as the Reich frontier, 439,000
  Reichsmarks from the Reich frontier and to the camp" - ---
A.  So this letter -- sorry.
Q.  "The costs involved in B can be dramatically reduced or
  substantially reduced in the future by erection of a
  reception camp on Reich territory".
A.  Well, this is a letter from -- sorry, from ----

. P-197



Q.  From Himmler to Sherin Krosik, the Minister of Finance.
A.  Yes, so the Finance Ministry, so the Finance Ministry was
  not -- the Finance Ministry, he could not write to the
  Finance Ministry, "Actually, we are sending Jews to
  Auschwitz and kill them there" because the Finance
  Ministry was not officially involved in this operation.
  So this is purely deception.  The second comment I would
  like to make, show me where is the camp?  Where is this
  besonderes Aufanlage, this reception camp, where is it?
Q.  So you are saying that Sherin Krosik, a Reich Cabinet
  Minister, is having the wool pulled over his eyes by
  Heinrich Himmler?
A.  Yes.  He was simply lying to him, he was deceiving him and
  I do not know where is this camp, this camp for the French use?
MR JUSTICE GRAY:  Did you suggest, Mr Irving -- I may have
  misunderstood you -- that these French Jews were going to
  be sent back from Auschwitz to this ----
MR IRVING:  We had exactly this conversation already four weeks
  ago, my Lord, and the answer is this is what the document
  says.  They were going to be sent ----
MR JUSTICE GRAY:  I must say, hearing it read out, it did not
  seem to me it was saying anything of the kind, but I may
  be wrong.  I thought it was saying, "It is very expensive
  and a security risk sending French Jews right across
  Germany, therefore, we will build a camp on the Western

. P-198



  edge of the Reich and they can go there".
MR IRVING:  And the purpose of the letter is to the Minister of
  Finance:  "Please provide the funds because we can save a
  lot of money by doing it like this".
MR JUSTICE GRAY:  Anyway, your evidence is this is not really
  worth the paper it is written on?
A.  We know that about 79,000, I think, Jews were deported to
  the East and we have 2,570 survivors, I think, who managed
  to survive in work labour camps.  This camp never exists, existed.
MR IRVING:  Are you familiar with the note made by the member
  of the Judenreferat in Paris, a man called Ahnert --
  A-H-N-E-R-T -- on a conference at the Reisigerhuptsam on
  Jewish questions on September 1st 1942 at about this time?
A.  Well, I do not have the document in front of me so -- do
  you want me to comment on that?
Q.  Now then ----
MR RAMPTON:  We have the translation of some of these documents
  provided some time ago, but really, with this witness in
  particular, it is essential he sees the original German
  and the whole of the original German.
MR IRVING:  I agree, my Lord.
MR JUSTICE GRAY:  Are you talking now about the document about
  the French Jews?
MR RAMPTON:  No.  We have the translation, as I said, done by
  Mr Irving.  It looks to me to be a partial translation --

. P-199



  I mean in the sense it is not a whole translation.  With
  this witness, it simply is not good enough.

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