Did Six Million Really Die?

Excerpted testimony by David Irving in the 1988 Zündel Trial in Canada

[David Irving testified as the twenty-third and final witness in the Zündel trial on Friday, April 22, Monday, April 25 and Tuesday, April 26, 1988.]

David Irving, the British historian and author, was permitted to testify as an expert in the area of the history of the Second World War. (33-9346)

Irving had worked as a professional historian since 1963 and was the author of between twenty and thirty books. These included Hess: The Missing Years, 1941 - 1945, The Service: The Memoirs of General Gehlen, Accident: The Death of General Sikorski, The Destruction of Dresden, The Secret Diaries of Hitler's Doctor, The Trail of the Fox, The War Between the Generals: Inside the Allied High Command, The German Atomic Bomb, Convoy: The Destruction of Convoy PQ 17, The Mare's Nest, The War Path, Hitler's War, The Morgenthau Plan, Breach of Security, Uprising, and Churchill's War.

As a historian, he was interested in contemporary history; that of the twentieth century. Irving himself came from an English service family. His father was a Royal Navy service officer. For twenty-five years, Irving had researched in archives around the world, including Canada, the United States, France, East and West Germany and other countries. He had also had the co- operation of the archives in Israel and the Soviet Union. (33-9312 to 9325)

He was "very familiar with the records of the German High Command and the other German wartime government agencies." He had acquired this knowledge and expertise initially at Alexandria in Virginia, where the archives were originally stored after they were seized by the American army. The documents had been subsequently sent back to West Germany. They were still available in Washington partly in original form and partly on microfilm. A number of records were also held by the British government. (33-9325)

Irving had also done in-depth research into the life of Adolf Hitler: "For ten years I researched Hitler's life based entirely on primary records. I don't believe in buying other people's books or reading them on Adolf Hitler. We can readily surmise there must be many tens or hundreds of tons of books. I think it's easier to go to the archives and look at the documents. That way you avoid soaking up other people's prejudices...Dealing with Adolf Hitler, I would look for the private papers of his personal staff, people who were directly associated with him from secretarial or adjutant level, up to Field-Marshal. I would try and amass a great body of documentary evidence which passes certain criteria. And these were the criteria which the great English historian, Hugh Trevor-Roper, laid down in particular; three criteria for a document to be acceptable to a historian. The first criterion is quite obviously, is the document you are looking at genuine? The second criterion is, was the person who wrote the document in a position to know what he is writing about? A street sweeper in Berlin may have been in Berlin in the last days of the war, but he doesn't know what's going on in Hitler's mind. The third criterion you ask yourself, why does this document exist? Why has it come into existence? You may look at a document that is apparently honest but you find out later on from other sources that the general wrote the document to protect himself. So you ask yourself, how did this document meet these three criteria and in the ten years that I worked on the Hitler project, I built up a shelf of about seventy feet of original documents that probably no other historian had ever seen. I persuaded Hitler's staff to trust me with their private papers that they had not shown to anyone else. I also built up a card index of ten or fifteen thousand filing cards on a day-by-day basis so you knew exactly what Hitler was doing, rather like a diary. You could say exactly what he was doing which meant that you had a useful tool to check any document. Any document that was shown to you had to fit with that card index. If it didn't, then there was something phony about the document." (33-9326, 9327)

Irving was very familiar with German documents, "...with the way they look, the way they smell - they have a certain physical smell - with the way they are phrased and with the archives they come from and the language they use, of course. I'm very fluent in the German language." (33-9328)

He had also conducted scientific tests as part of his research: "In the twenty-five years I have done research, on occasion documents have been offered to me that I had reason to suspect. On one occasion I was offered the private diaries of the German Vice Admiral Wilhelm Canaris...who is the chief of the German Secret Service. We knew that these diaries existed. We have been looking for them. They haven't been found to this day. In the end I persuaded the man who had offered these diaries to me and the English publishers, Collins, to come to London bringing one page of those diaries. In return, we paid 50,000 pounds into his bank but we didn't release it into his account until we carried out laboratory tests on the paper. This was in about 1970. And the laboratory tests carried out on the paper and the ink and the typewriter showed that the paper was wartime paper. It didn't have the whiteness that modern paper has; it didn't have melamine formaldehyde added that modern paper has. The paper had been cut to the German size with scissors, as microscopic examination showed. Also the signature had been written in a ball point pen. The chemical tests showed that quite clearly. Tests were carried out on the ink of the signature normally to show how old the signature is. This laboratory in London which I use, Hehner & Cox, carried out a test normally on the iron content [of the] ink. Normally, if you write a signature with ink, the iron oxidizes, so I am told, and you can tell the degree of oxidization, and tell how long a signature has been there. This document was signed in a ball- point pen and was clearly a forgery. I had the man prosecuted for criminal fraud and he avoided the consequences by dying, or by purporting to have died. At any rate, he submitted a death certificate which I was prepared to accept as genuine. And of course, I was involved in the very famous discovery of the Hitler diaries forgery. I had had the Hitler diaries submitted to me six months, I recall, earlier along with ancillary documents. I had had the Hitler's diaries submitted to me in 1982, November, along with other ancillary documents. And I detected that the letterhead on a Hermann Goering notepaper was actually misspelled. They misspelled the rank of the Field-Marshal, of the Reichsmarschall as he was, which was completely improbable, and when the Hitler diaries were presented to the world in April, 1983, I attended the press conference and exploded that press conference as you may have seen on "Good Morning America" and the other television programmes. The diaries were a fake and I had the forensic evidence they were fake...there had been occasions, sir, when I have used laboratories to determine forgeries. "(33-9328 to 9330)

Irving's Hitler research failed to uncover any evidence that Hitler was aware of the alleged "final solution" of the Jews: "At the end of writing the Adolf Hitler biography in draft, I was aware of the fact that having written it from primary, original Hitler sources, I, as the author, didn't know about the Holocaust. I had found no documents showing any involvement between Adolf Hitler and the Holocaust which was very disturbing for me. So I re-investigated. I sent a researcher back into the archives where, with a specific job, the researcher, who was a trained historical scientist at the Institute of Contemporary History in Munich, I said to her, 'Go back to the archives in Freiburg, Munich and Berlin, and see if I have missed anything'. I couldn't believe what I was seeing, the fact there were no documents whatsoever showing that a Holocaust had ever happened. I'm using the word 'Holocaust' in the modern sense that the newspapers tell us to use it. And certainly there was no evidence that Hitler had ever known such a thing was going on, whatever it was. This was very disturbing for me and it was even more disturbing for my literary agent who warned me of the consequences of producing the Hitler book in this fashion." (33-9330, 9331)

This completed defence attorney Doug Christie's examination of Irving for the purpose of qualifying him as an expert witness. Crown Attorney John Pearson then rose to cross-examine Irving on his qualifications as an expert in history. (33-9332)

In response to Pearson's questions, Irving testified that his book Churchill's War, was published in West Australia by Veritas Publishing Company. David Thompson, the firm's East Australian sales manager, introduced Irving at a speech Irving gave at the University of Sydney. (33-9332, 9333)

And do you remember, asked Pearson, saying that you had no qualifications whatsoever and you were proud of the fact that you had no qualifications whatsoever?

"I think my precise words would be to say that the only examination I...failed at school is O-level history which is the most elementary level of history you can fail," said Irving. (33-9333)

You were proud to say you flunked history?, asked Pearson.

"I have started off from such humble beginnings...I have no academic qualifications whatsoever." (33-9333)

Right, said Pearson, you make your living writing and publishing controversial books about history.

"I make my living publishing books about history, yes...Many of them are controversial. I don't create the controversy, the media do...I'm a controversial historian." Irving agreed that his books had been the object of contempt and scorn and that he had been hounded and attacked. He disagreed, however, that controversy was good for book sales: "Quite the contrary, sir. I rather hinted when I mentioned my literary agent, in the matter of Hitler's War, my literary agent warned me of the severe consequences of the controversy that would develop from omitting Hitler's role in the Holocaust. He told me we would lose the Sunday Times deal, the Reader's Digest deal, the Book of the Month Club deal, and we would not sell the book as a paperback in the United States. We lost about one million dollars. Controversy is not necessarily good." (33-9334, 9335)

Well, are you familiar with the book called Spy Catcher?, asked Pearson. Irving replied that he knew of the book and that it had been banned when he left Britain five weeks before. And wouldn't you agree with me it was good for sales?, asked Pearson. Irving agreed this had been true for sales of Spy Catcher in Australia, but said: "Being banned ipso facto is not good for sales. You have to be banned in a certain way...There are useful controversies and there are controversies which don't promote your purposes as a historian." (33-9335, 9336)

Well, said Pearson, if there's controversies that create media attention, that's good for sales because thereby people learn about a book that they'd otherwise not even know about. Isn't that right? Said Irving: "This is true. And I emphasize as a professional historian I have to sell my books. I can't afford to lose my credibility." (33-9336)

When you say you're a professional historian, asked Pearson, what you mean by that is you write books on history and sell them?

"I write books on history as a profession. That's what professional historian means." Irving agreed that he was in a fight for media attention: "I think that is correct. In England 58,000 new books are published every year and only 1,000 will ever get reviewed...So, it's a bit of a struggle of life." (33-9336)

Would you agree with me that you hold academic historians in contempt?, asked Pearson.

"I hold them in contempt for specific reasons," said Irving. "Not all academic historians but the broad majority of them." (33-9337)

Would you agree with me, asked Pearson, that the academic historians, for instance, Martin Broszat, consider your thesis in your Hitler book as embarrassing? Irving disagreed: "On the contrary. Martin Broszat went to great lengths in a 54-page review of my Hitler book to say on one central issue he considered that I was correct, that there was no general order for the extermination of the Jews...I don't think he ever used the word embarrassing. I'm not familiar with all his writings." (33-9337)

Pearson produced a copy of an article by Broszat published in Yad Vashem Studies. Irving indicated he was familiar only with the German edition: "...I haven't read this particular one. I don't subscribe to Yad Vashem Studies. If he said it was embarrassing, I will accept your word for it, but it would be embarrassing for the body of academic historians because I have shown them up for not doing the research which did I." Irving examined the article and confirmed that it was an English translation of the original German paper which appeared in Vierteljahrshefte für Zeitgeschichte with which he was familiar. (33-9338, 9339)

And it doesn't matter that it's published in Yad Vashem, does it?, asked Pearson.

"I...think I did emphasize I have co-operation from the Israeli archives so that does mean it's a two-way co-operation." (33-9339)

Pearson repeated the question.

"I can't see what point you're driving at," said Irving, "I just said...I'm not familiar with the Yad Vashem version of it." (33-9339, 9340)

The title of the article by Broszat was "Hitler and the Genesis of the 'Final Solution': An Assessment of David Irving's Theses."1 At Pearson's request, Irving read the first paragraph:

THE ENGLISH EDITION of David Irving's Hitler book, published in the spring of 1977, two years after the expurgated German edition, has created a furore both in England and elsewhere. The British author, who gained a reputation as an enfant terrible with earlier publications on contemporary history, has propounded a thesis which is embarrassing even to some of his friends and admirers.

Pearson indicated that Broszat went on to say that Irving was a very good writer. Pearson then continued reading from page 76 of the article:

The discovery and utilization of contemporary primary sources has long been a sort of adventuresome passion of Irving the historian. However, the unprejudiced historian and researcher is obstructed by the passionately partisan author whose insistence on primary sources lacks the control and discipline essential in the selective interpretation and evaluation of material.

He is too eager to accept authenticity for objectivity, is overly hasty in interpreting superficial diagnoses and often seems insufficiently interested in complex historical interconnections and in structural problems that transcend the mere recording of historical facts but are essential for their evaluation. Spurred by the ambition of matching himself against professional historians in his precise knowledge of documents, he adopts the role of the terrible simplificateur as he intends to wrest fresh interpretations from historical facts and events and spring these on the public in sensational new books.

Said Irving: "I think every historian is entitled to his opinion...What he is saying is I haven't learned to read between the lines the way that the academic historians have." (33-9341, 9342)

Pearson asked whether Irving's thesis in Hitler's War was that Hitler was a bad administrator who liked ideas and not details, and that it was Heydrich, Himmler, Frank and others who were engaged in perpetrating the Holocaust. Said Irving: "In the introduction I make plain that I regard Germany, by the end of the Second World War, as a Führer state without a Führer. He had lost control of whatever was going on and I'm not going to be so simple as to say it was quite simply what is now called the 'Holocaust.' Whatever it was that was going on, there is no evidence that Hitler knew it. There's not enough evidence to satisfy an English magistrate's court and it certainly shouldn't satisfy an academic historian or a professional one." (33 9342, 9343)

Are you repudiating what you wrote in Hitler's War about the activities of Himmler, Heydrich and Frank?, asked Pearson.

"I didn't use the word 'Holocaust' to the best of my knowledge. This is a relatively modern invention. I think we have to be much less simple than using a word like that. We have to try to examine what was going on, see if there was a pattern or was it just a haphazard series of ad hoc tragedies generated by all sorts of different criminals who were running amok." Irving indicated that he did not think he repudiated anything he wrote in Hitler's War, but indicated that he "would need to know exactly which passage I am being asked to...repudiate." (33-9343, 9344)

Pearson asked if Irving's thesis in his book Churchill's War was that Churchill wanted a war because he knew he wouldn't get elected in peacetime and he conducted a lot of his activities during the war in a drunken haze?

"This is not a thesis," said Irving. "That is, in fact, a statement of fact." (33-9344)

David Irving was accepted as an expert witness qualified to give testimony in the area of the history of the Second World War. Defence attorney Douglas Christie commenced his examination-in-chief of Irving. (33-9346)

In your opinion as a historian of the Second World War, asked Christie, what is the 'Holocaust' as it is currently presented?

"The Holocaust as it is currently presented," said Irving, "I can do no better than quote the words used by the chief rabbi of England, Lord...[Immanuel] Jakobovits, who has recently said that in his view, it has become big business...Which he deplores." (33-9347)

Irving had read Did Six Million Really Die?: "...I have seen this book before over several years. I have never read it until two days ago when a copy was sent to me by courier in Florida with a request that I should read it for the purposes of this trial. And I read it with great interest and I must say that I was surprised by the quality of the arguments that it represented. It has obvious flaws. It uses sources that I would not personally use. In fact, the entire body of sources is different. This is based entirely on secondary literature, books by other people, including some experts, whereas I use no books. I use just the archives. But independently, the author of this came to conclusions and asked questions of a logical nature which I had arrived at by an entirely different route, so-to-speak. I give one example. On one page, which I can't remember, he asks the obvious logical question, if you are going to exterminate millions of people, why did you go to all the trouble of shipping them thousands of miles across Europe first? This is the kind of logical question which the academic historian[s] have ducked until now. And if I was to ask what is the value of a brochure like this, I think it is that it provokes people to ask questions, rather as my book on Hitler's War provoked the historians. I think I am told that this court has heard about the historians' dispute that has opened up in Germany. That was entirely as a result of my controversial book on Hitler. Until 1977, the German historians had never asked the obvious questions. This is the kind of value which I found this brochure to have. It was asking proper questions on the basis of an entirely different set of sources. But I do emphasize that it contains flaws and it contains also some opinions with which I personally wouldn't agree." (33-9347, 9348)

If the 'Holocaust' is represented as the allegation of the extermination of 6 million Jews during the Second World War as a direct result of official German policy of extermination, what would you say to that thesis?, asked Christie.

"There are several elements of that sentence I would dispute," said Irving. "Firstly, the allegation that it was official German policy. We are not familiar, neither the academic nor the professional historians are familiar with the slightest documentary evidence that there was any such German policy. And I should be familiar with it having spent ten years wading around in the archives of the German High Command and speaking with Hitler's private staff. It isn't there. I am not familiar with any documentary evidence of any such figure as 6 million and I think I know how the figure originated because I am familiar with the private papers of the American Chief Justice at Nuremberg, the Justice Robert H. Jackson and I saw the actual interview on which that figure was...arrived at...Many years ago, I wrote a very detailed analysis of the Nuremberg trial and the procedures and the sequence of events at the Nuremberg trial. In the course of which I obtained privileged access to all the private and official records of the American chief prosecutor, Justice Robert H. Jackson, in the course of which I changed my opinion about him. I set off with a bad opinion of him and in the light of what I read in his diaries, I came to realize he was a profound and honest American lawyer." (33-9349, 9350)

Do you have any opinion as a result of your research as to the number of Jews who died in concentration camps during the Second World War?, asked Christie. Said Irving: "I am not sure that an opinion here would be of use. I have opinions. I have opinions, however, in the kind of statistical orders of magnitude, where you can see there's a minimum number and a maximum number, and I can only set these two limits and say that to my mind, it must have been of the order of 100,000 or more, but to my mind it was certainly less than the figure which is quoted nowadays of 6 million. Because on the evidence of comparison with other similar tragedies which happened in the Second World War, it is unlikely that the Jewish community would have suffered any worse than these communities. You can weigh the figures in certain ways and look at air raid damage and look at other communities like the gypsies and so on and say, this is the balance of probabilities. But it shouldn't be necessary to talk about probabilities. All Hitler's other crimes are documented in statistical details in the archives. This is supposed to have been the biggest crime of all and yet the documents just aren't there so why do we have to speculate? Why do we have to have opinions about figures?" Irving pointed out that there was documentary evidence to support the German policy of deporting the Jews: "Oh, yes. Quite definitely. In the course of my Hitler research I came across acceptable German archival evidence which met the criteria which Hugh Trevor-Roper had taught me, being authentic documents written by people in a position to know. I came across documents showing that Hitler had given the orders for the deportation of the Jews to the east. This deportation was in full swing by the middle of 1942 and you find, for example, Heinrich Himmler writing to Gauleiters that the Führer, Adolf Hitler, has given me the order to make Europe free of the Jews, clean of the Jews from west to east, stage-by- stage, and it's quite clearly referred to as Hitler's order, the deportation." (33-9351, 9352)

There were, however, no orders for the extermination of Jews: "None whatsoever. I have not found in any archives of the world, including I mentioned the Israeli archives which have been co-operating with me; I also underline the fact even in the British archives, where we were reading the signals, the code signals of the SS units operating on the eastern front, with our code- breaking machinery, not even in the British archives are there any deciphered Hitler orders for the killing of Jews...There are no explicit orders and this is where the academic historians start asking us to read between the lines and find fancy translations for certain words and I wouldn't go along with those methods. I want in a crime as big as this to find explicit evidence." (33-9352, 9353)

Was there a Madagascar plan?, asked Christie.

"The original 'final solution' of the Jewish problem as envisaged by the German High Command," said Irving, "was to deport the Jews to different territories. Various different territories were called into account for this. On one occasion, the Jews were going to be shipped to western Australia. On another occasion they were going to be shipped to Palestine and Adolf Eichmann was actually sent to...Palestine in 1939 to negotiate with the Zionists in Palestine. The principal plan was the so-called Madagascar plan. Madagascar is an island off the coast of Africa about the size of Germany. A temperate island, the kind you have in Canada or in Britain, and the idea was to ship all the world's Jews to Madagascar. In 1940 after the German defeat of France, the intention was to incorporate the Madagascar plan in the final peace treaty obliging France to make Madagascar, which was a French colony, available for the purpose of Jewish resettlement. And there are traces, by which I mean there are extensive files, on the Madagascar plan in the archives of the German admiralty, because they would be involved in the transportation, and the archives [of] the German Foreign Ministry and in various other German government bodies. This plan was abandoned when the war continued because it was impossible to have an overseas shipment of Jews at a time of war. And finally, in 1942, there is a document in the records of the German Foreign Ministry which says the Madagascar plan is being abandoned because we now have new territories available in the east, the occupied Russian territories, to which all the Jews will be transported instead." (33-9353, 9354)

Is there any one document in the archives, asked Christie, of the various ministries which say, as late as March 1942, that there was a plan to exterminate the Jews?

"This is typical of the documents which I have found and which the academic historians, until I had published it, would not publish it," replied Irving. "In the archives of the German Ministry of Justice, I found a document which was concealed at Nuremberg...which resurfaced in the archives in Koblenz, dated in the spring of 1942. It is a note of a telephone conversation of the Secretary of State of the German Ministry of Justice with the Reich Chancellor...That would be rather like a Prime Minister, a Prime Minister in a dictatorship, second man down from Hitler...[who was] Hans Lammers. Lammers had telephoned the ministry in the spring of 1942 and the minister writes a note on the conversation, and I can quote the memorandum from memory. It says: 'Lammers has said that the Führer, Adolf Hitler, has repeatedly ordained that he wants the 'final solution' - that he wants the solution of the Jewish problem postponed until after the war is over.' And this document, of course, takes some explaining and this is the kind of document which embarrasses the historians, if I can use the word that Mr. Pearson has reminded me of. They are embarrassed because they haven't found that document themselves." (33-9354, 9355)

Irving testified that he was familiar with the Einsatzgruppen reports: "Here we have to look at the third of the Trevor-Roper criteria. If you remember, the question a historian should ask is, 'Why does this document exist?'. A man is out in the field behind the Russian front doing his job for the SS and he is being asked how well he is doing and he's going to submit a report containing figures and he's going to show he's doing a jolly good job and that's the kind of category I... put these Einsatzgruppen reports into. I don't trust the statistics they contain. Soldiers who are out in the field doing a job or murderers who are out in the field doing a job, they don't have time to count. I don't think Lieutenant Calley stopped to find out how many people [he] killed. Statistics like this are meaningless. Documents like this I am very, very worried about as a historical source." (33-9355, 9356)

Christie produced Exhibit 118, a document referring to Galicia, which he showed to Irving. Said Irving: "May I say that I am very wary about any Nuremberg document that has the document number L...This is L-18...Historians are familiar with quite a number of L documents from the Nuremberg series and a lot of them turn out to be forgeries. A lot of them turn out to be produced or manufactured for the Nuremberg trials to the best of my knowledge. So, this is the first thing that would worry me about that." (33-9357)

Crown Attorney Pearson objected to this testimony, alleging that this was a serious accusation to make. Irving replied: "If I may answer that point, sir, I investigated the Nuremberg trials in some detail and I was familiar with the fact that at Nuremberg, they did have a collection of the necessary rubber stamps, the security classification stamps in order to manufacture documents and they did do it. There are several instances where this subsequently turned out...I have published a book on that sir. It's Nuremberg - The Last Battle...The prefixes on the Nuremberg documents give some index of the providence of the document. There's a PS series which was found by Colonel Storey [in] Paris, the Paris/Storey collection. Many PS series are thoroughly authentic. The L series were a small collection of documents used at Nuremberg and contain documents produced by journalists and handed over by a very eclectic series of sources. The NOK documents, the German for the [High] Command trial, the private files give us a first sniff, if I might put it like that." (33 9358, 9359)

Irving testified that he was not familiar with this particular document: "...I am not familiar with the document. I am not, I emphasize, a Holocaust historian." (33-9360) With respect to the authenticity of the document, Irving testified that he would "accept these documents as attached are probably genuine on the basis of the photocopies but that's just the first impression you get in looking at an archives - I recognize the numbers at the bottom. I can tell you which microfilms they come from. They are authentic reproductions from Nuremberg microfilm. . . Prima facie it appears to be genuine." (33-9362, 9363)

Have you yourself ever seen any evidence in any of the archives to establish the existence of homicidal gas chambers?, asked Christie.

"No, sir. None whatsoever. And certainly one would have expected to have found it in the number of archives that I've been in." (33-9363)

Yesterday, said Christie, the Crown produced a letter from someone in Auschwitz pertaining to the building of the crematories and the word used there was Vergasungskellers. Are you familiar with that document?, he asked.

"I am very familiar with the German language and I am quite familiar with that document also," said Irving. "No German would have referred to a gas chamber, which of course is quite a common concept because the Americans use[d] gas chambers at that time for legal executions. No German would have translated the word 'gas chamber' as vergasungskeller. They have a perfectly good German word for that... a gaskammer." (33-9363, 9364)

Christie noted that the Crown had quoted a man named Martin Broszat during his cross- examination of Irving. What was Broszat's job?

"He is now the director of the Institute of Contemporary History in Munich, which is a very good historical institute partly funded by German federal funds and partly by provincial funds...My dealing with the Institute of History began in late 1963 before he became director of the institute. The institute has acquired my entire research collections of documents which are now housed in that building as the David Irving Collection and I have suspended further deliveries of documents until Broszat resigns or retires." Irving testified that there were personal animosities between himself and Broszat which "began in the 1970s over a certain young lady who is now living with him...further animosity was caused by the fact that I revealed that documents that the Broszat institute published were forgeries. The diary of...Engel turned out to have been written on post-war paper and yet the Institute went ahead and published this diary knowing that it would pollute the writing of history for many decades afterwards...It is now recognized as a forgery and yet the institute of Dr. Broszat still publishes it." (33-9366, 9367)

Christie turned to the subject of the Posen speech of Heinrich Himmler. Said Irving: "In October, 1943, Heinrich Himmler, the chief of the SS, delivered two speeches, one to the SS generals and one to the Gauleiters - the Nazi party district chiefs, the governors of the districts." Irving had examined the transcripts of the speech and other archival materials: "I looked at Heinrich Himmler's handwritten notes on the basis of which he delivered those speeches, I looked at the typescript of the transcript made from the recording of the speeches, I looked at the final copy made that have typescript in the special large typewriter face that was used for Adolf Hitler to read, so the speeches exist in several copies and I understand that in the National Archives, there is also a sound recording of the two speeches." (33-9368)

Did he have any reason to question the accuracies of the Posen speech?, asked Christie.

"[In] both speeches which I referred to," said Irving, "Heinrich Himmler made startling admissions to his very select audience which amounted to the fact that he was - he had given orders personally not only for the killing of certain Jewish men, but also for the killing of certain Jewish women and children and he tried to justify what he was doing, using, if I may say so, rather the same kind of language as [Israeli Prime Minister] Mr. Shamir now uses in the West Bank, saying that we have to carry out this task in order to be able to live in security in future. This was the language that Himmler used and I arrived at the very strange discovery when I looked at the transcript of both those speeches that those two pages had been retyped at some other date. I can't say whether it was retyped before or after the bulk of the speech, but they had been typed by a different secretary on a different typewriter using different carbon paper. Obviously you only discover this if you look at the original documents which the average historian is not patient enough to do. They had been retyped and they had been repaginated in pencil at that point and I have to say to preempt your question, I have no explanation why. It just raises the fact that a document - if a document has been retyped at a key point, then I hold that document to be suspect." (33-9368, 9369)

Do historians generally have any criterion for accepting documents as being both authentic, genuine and true or do they simply take them at their face value?, asked Christie.

"It depends very much on the historian," replied Irving. "The green historian who is fresh out of university and not inquisitive, will be happy to accept the printed volumes of documents particularly if they have pictures in them and an index at the end. Later on, you learn not to trust printed volumes of documents. If I can give one example from my Churchill research, there is a report by the American Assistant Secretary of State, Sumner Welles, on a visit to Churchill in March 1940, describing how he found Churchill in a state of complete intoxication in the admiralty. The printed version of this document and the American government volumes omits those sentences describing Churchill's drunkenness, but the original report by the Secretary of State in the Roosevelt library contains those sentences. So, I can only say that a historian must be very careful about using printed or even photocopied documents."(33-9369, 9370)

Irving had also studied the Goebbels diaries: "I am very familiar with the Goebbels diaries insofar as they have been publicly available and in the course of the next twelve months I shall begin reading the entire microfiche of the Goebbels diaries that have now become available to western historians," said Irving. "They appeared in a very mysterious way from the custody of the East German government, where they have been held since the end of the Second World War unknown to us; we didn't know those diaries were there and then they suddenly turned up. I have to say from what I have seen so far, I consider the diaries to be genuine, but we have to apply once again the third criteria of Trevor-Roper which is, 'Why did they come into existence'? Why did Goebbels write them?" The diaries were partly written and partly transcribed: "Many early years are written in his very difficult, indecipherable handwriting. The later years when he was Minister of Propaganda in Nazi Germany, he dictated them onto a recording machine and his secretary transcribed them each day, sometimes at very great length. Sometimes 139 pages on one day in 1943." (33-9370, 9371)

He was also familiar with the Wannsee Conference documents: "In January 1942, there was a conference at a house in Berlin, Wannsee, an inter-agency or inter ministerial conference between state secretaries. The state secretaries were like the deputy minister in a ministry and they were discussing the technicalities of the final solution of the Jewish problem, and to understand the Wannsee protocol, it is not enough just to look at that document. You have to look at the entire file containing that document. And you then realize what the document is about. Even then it is written in very obscure civil service language and several of the participants in the Wannsee Conference subsequently testified in later criminal proceedings that they emerged from that conversation no wiser than when they went in. Certainly none of them had - certainly none of them had any idea that at that conference there had been a discussion of liquidation of Jews." (33-9371, 9372)

Had he investigated the trials of these individuals?, asked Christie.

"I read the records of the Wilhelmstrasse trial," said Irving, "which is the second trial to be held in the post-Nuremberg proceedings series after the plain Nuremberg trial. There were twelve subsequent proceedings. The Wilhelmstrasse trial was the second one. None of them testified that there had been any discussion of liquidation of the Jews at the Wannsee Conference." (33-9372, 9373)

Christie referred to the letter from Goering to Heydrich of July 1941 which had figured prominently in both Hilberg's and Browning's testimony and asked if Irving was familiar with it. Irving replied that he was: "On July the 31st, 1941, as is said from Hermann Goering's private diary, which I suppose I'm one of the very few people to have used it in the original, on the afternoon of that day, Reinhard Heydrich, the chief of the Gestapo, visited Goering who was passing very rapidly through Berlin and put a pile of documents on the desk for Goering to sign, one of which was a piece of what I would describe as legal bumph, where Heydrich is just saying to Goering, 'In 1939, you gave me orders to carry out certain measures connected with the Jewish solution, will you now extend the authority given by those orders to the new territories in Russia which we've captured'. That is what the document says. I wouldn't attempt to repeat the document from memory. I'm sure it's in the court files. July the 31st, 1941, Goering signs the document for Heydrich without ever even bothering to read it. It's a piece of legal bumph which again says nothing about killing Jews. It is talking about the overall solution of the Jewish problem which, as I testified earlier today, was at that time regarded to be the geographical resettlement of Jews, relocating them from where they were at that time." (33-9373, 9374)

Did those sources - the Posen speech, the Goebbels diary, the Wannsee Conference and the letter of July 31, 1941 - indicate any plan to exterminate European Jews?, asked Christie.

"No," said Irving. "There is no explicit reference either implicit in these documents or legible in these documents to liquidation of Jews. They are all equally applicable to any other solution. Of course, relocation of the Jews in the middle of a war was a radical solution but it is not what is described as the 'Holocaust.'" (33-9374)

Does the existence of these documents indicate to you that there is any other material that would corroborate an extermination programme?, asked Christie.

"I think it highly unlikely. It is very difficult to prove a negative to say that documents don't exist. But I will say is, if the documents did exist, I would have found them by now and if I hadn't found them, then certainly the Holocaust historians would have found them by now, explicit documents, and as you may know I have offered repeatedly around the world a thousand pounds for any wartime contemporary document showing that Adolf Hitler even knew what was going on, whatever it was, whatever is now described as the 'Holocaust' and they haven't been able to find that let alone explicit orders or documentary evidence about gas chambers or the similar kind of documentary material." (33-9374, 9375)

In your research as a historian, asked Christie, do you consider it likely that an enterprise of the magnitude of the extermination of the Jews of Europe could be accomplished by the people [Germans] knowing the way they conducted their business from their documents without the existence of explicit orders and plans?

"Not only without existence of orders," said Irving, "but also without the existence of any written reference to it. I have to say that the German wartime civil servant was basically a - a cowardly animal and he would not do something that he considered to be criminal without getting a document clearing himself. He would get his superior to write a letter saying, 'On the Führer's orders, we are doing the following', which is why there are letters showing Himmler saying, 'On the Führer's orders, we are deporting the Jews.' Which was the extent of the Führer's orders and which was the extent, to my mind, of the final solution. So the documents don't exist where you would expect to find them. Hitler's other crimes, the documents are there: the euthanasia order, the order to kill British commandos, the orders to lynch American airmen, the orders for the killing of the male population of Stalingrad if ever they occupied it. Hitler's other crimes, simple crimes, the documents are there where you expect to find them. And yet this biggest crime of all, there is no document...I think there would definitely have had to be orders and these orders would have been referred to in countless files of different ministerial bodies. So, it would have been impossible for these documents to have been destroyed at the end of the war. There would always be carbon copies somewhere." (33-9375, 9376)

The term ausrotten, said Christie, has been represented to mean 'extermination' in the literal sense. Have you examined that word in its context in the various speeches of Adolf Hitler?

"I am very fluent in the German language, having lived in that country for a long time and having read, of course, millions of words in the German language in context," said Irving. "There is no doubt that in modern Germany the word ausrotten now means murder. But we have to look at the meaning of the word ausrotten in the 1930s and the 1940s, as used by those who wrote or spoke these documents. In the mouth of Adolf Hitler, the word ausrotten is never once used to mean murder, and I've made a study of that particular semantic problem. You can find document after document which Hitler himself spoke or wrote where the word ausrotten cannot possibly mean murder. I can give one or two examples briefly. In August 1936, Hitler dictated the famous memorandum on the four year plan which contains the phrase 'if the Bolsheviks succeed in entering Germany, it will lead to the ausrotten of the German people'. Now, clearly, he doesn't mean that if the Bolsheviks invade Germany it will lead to the murder of 50 million Germans. He is saying it will lead to the end of Germany as a national state, as a power, as a factor, an end of the German people. He says the same to the Czechoslovakian President Emil Hácha, on March the 15th, 1939. Hácha has just signed away Czechoslovakia's independence in a midnight session with Hitler and Hitler says to him afterwards, 'It is a good thing that you signed because otherwise it would have meant the ausrotten of the Czechoslovakian people'. Hitler didn't mean, 'If you hadn't signed, I would have had to kill 8 million Czechs.' What he is saying [is], 'If you hadn't signed, I would have ended Czechoslovakia's existence as a separate country.' There are various other examples of that and I defy anybody to find the meaning of the word differently used by Adolf Hitler to mean the word 'murder'. This is the kind of analysis which unfortunately the academic historians have not bothered to conduct." (33-9377, 9378)

Could you give us your opinion of the value of Did Six Million Really Die?, asked Christie.

"It has a - a value I would suggest in technical terms of a catalyst. It has existed rather like the grain of sand inside an oyster. It has provoked and irritated people [in] rather the same way but on a different level that my book Hitler's War did. It has forced people to prove what they have been maintaining - to put their money where their mouth is in common terms - and they haven't been able to do it and because they haven't been able to prove what they've been maintaining for thirty or forty years, they resort to extramural methods. In Germany, it is declared a criminal offence now to question certain historical facts. In other countries, I think judicial notice is taken of them." (33-9378, 9379) Irving estimated "over 90 percent of the brochure Did Six Million Really Die? to be factually accurate on the basis of the facts which I arrived at by an entirely different approach, namely, the documentary basis." (33-9388)

Irving testified that he was familiar with the subject of Kurt Gerstein: "I have examined the Kurt Gerstein report and its various adaptations and having read the very interesting doctoral dissertation by the Frenchman Henri Roques, which was produced a year-and-a-half ago, I came to the conclusion on the basis of the documents that Roques found in the French police files, on the basis of my own family experience with a handicapped member of my family, that Gerstein himself was probably unstable when he wrote his various reports." Irving did not examine the documents in their original form: "I examined facsimiles. Had I been a Holocaust historian, of course, I would have gone into much greater detail and demanded to see the originals." Irving had also examined facsimiles of Gerstein's writings of a personal nature, which were found among his effects after his suicide. (33-9379, 9381)

In the course of his research, Irving was required to make assessments of the credibility of the people who had produced the documents: "Indeed I do, and one can do so on the internal evidence of the document itself or of associated events and documents. In this case, the suicide or apparent suicide of the person who wrote the document is a clear sign of mental instability...The documents themselves are unstable. The most graphic description of that are the words, that the facts and dates contained by the documents vary dramatically," said Irving. As a historian, he had made these types of assessments in regard to other documents as well: "Yes, over the years I have repeatedly had to do so. One has to weigh documents." (33-9380)

Irving testified that Professor Hans Mommsen of the University of Bochum now shared his thesis pertaining to the absence of a plan or order. That had not been the case in 1970. Said Irving: "...At the end of the Second World War, the - the professorial bodies at the institutes of higher learning in Germany were extensively re-staffed. New textbooks were introduced; the professors were retaught. The university system produced, in its turn, new professors. There was a broadly held body of opinion as to what had happened and it has not been without - not to be wondered at, as fresh documents became available, then this opinion is changed. Fresh hypotheses are raised by authorized or unauthorized writers and even the academics then have to change their minds." Irving himself had changed his mind over the years. In a book he published many years before on the Vietnam War, he had referred "to the 6 million who were killed at Auschwitz and if I was to be asked now why did I write that, then I would have to quote the words of William Casey and I - 'I believe[d]', but since then, since having spent ten years writing the Hitler biography and since having worked in the world's archives, I've come to question that belief which was an oversimple belief." (33-9381, 9382)

In your opinion as a historian, asked Christie, from what you have seen of the information about the subject, has the Holocaust been sufficiently investigated to determine accurately its extent and meaning?

"I think there has been virtually no investigation of the Holocaust," replied Irving. "When we realize that Mr. Zündel, the defendant in this case, is the first person who has gone to the trouble to get the aerial photographs of the German concentration camps, the kind of concrete evidence that anybody is entitled to demand when you're carrying out an investigation, this shows us how we can - all the other historians on that field, including myself - have been. And the same kind of forensic examination which has now been made of the site, an idea which hadn't occurred to me one could conduct - really getting down to the basics of what happened. This has not been done by historians of the Holocaust." (33-9382, 9383)

Are there factual errors in major history books?, asked Christie.

"Oh, yes. I think it would be a foolish historian who denies he makes errors on Adolf Hitler. The standard works like Alan Bullock, his book Hitler: A Study in Tyranny, is riddled with errors and yet that book goes into reprint after reprint. William Shirer's book The Rise and Fall of the Third Reich, is a very good book in its way, written at a very early stage. It is based entirely on the prosecution documents at Nuremberg and, as such, is out of balance and also contains misstatements of fact. These are gradually reshaped and corrected as the years pass. One never really establishes total truth. One only approximates to it." (33-9383)

Christie turned to Did Six Million Really Die? and some of the specific allegations made in it. Did Irving know of any indication that Ohlendorf, for example, was tortured?

"Oh, yes," said Irving. "The SS General Ohlendorf and the SS General Pohl were both very severely maltreated at Nuremberg and in the internment camps where they were held by the Allies after the Second World War and prior to their testimony. They subsequently testified to that to their fellow prisoners like Field Marshal Milch, who kept a diary which I have and also in the subsequent trials...Field-Marshal Milch was the second person in the German air force. He was threatened with severe punishment unless he testified against Goering. On November the 5th, 1945, an American, who is a Major Ernst Engländer, who is a Wall Street financier, who presented himself to Milch as Major Evans, instructed him that he would be subjected to a war crimes trial unless he agreed to perjure himself against Goering. Milch refused to perjure himself and although there was an animosity between himself and Goering, he went into the witness stand and spoke in defence of Goering and on the next day, Milch was thrown into the punishment bunker at Dachau concentration camp, a bunker which had been designed by the SS to hold one recalcitrant prisoner, but which the Americans were using rather more economically in as much as they put six prisoners in this one-man bunker, all of them Field-Marshals as a punishment. Milch was then subjected to a war crimes trial and sentenced to life imprisonment. Admiral Eberhard Godt, the Chief of Staff, was threatened with hanging unless he...testified that Dönitz had given illegal orders and so on. There's a whole string of examples of the coercion of prisoners at Nuremberg." (33-9384, 9385)

Irving testified that "[t]he principal trial was the trial of the major war criminals at Nuremberg from October 1945 to October 1946. There was then a series of twelve subsequent proceedings against Milch, who was the first trial, and then the Wilhelmstrasse trial defendants...The legal records, the whole of the legal system at Nuremberg was unlike any other legal system. No appeal was permitted. The procedure for hearing witnesses was remarkable. The affidavits were submitted [e]ven [if] their witnesses were present in person and could have testified personally...many, many hundreds of thousands of affidavits were submitted with no chance for the defence to cross-examine the person who had submitted the affidavit as to the conditions under which he had given the affidavit, sworn the affidavit." (33-9385, 9386)

Irving was familiar with the book on the Manstein war crimes trial written by Paget. Said Irving: "R.T. Paget was a labour member of Parliament who was a King's Counsel, defence counsel of Field-Marshal Manstein, one of the most illustrious German soldiers. He was put on...trial by the British in Hamburg. I read that book when I was twenty-two with great fascination and increasing indignation to read of the methods that had been used to obtain testimony from prisoners, including the very severe maltreatment, brutalization of a number of witnesses." As a result, Irving made inquiries of certain documents from the National Archives in Washington: "In the very early 1960s, I obtained from them a complete photocopy of the Simpson Commission of Inquiries which the American Justice Department, to its credit, sent to Europe to investigate the allegations that American officers were torturing German defence witnesses." After reading the document, said Irving, "I formed the opinion that in future, one would have to be very, very cautious before accepting without verification the evidence sworn by defence or prosecution witnesses in the Nuremberg trials." (33-9387)

In the course of your research, asked Christie, have you discovered new documents as you went along or documents now being made available that were not available in the past?

"It's a continuous process. For example, I have contacts with the Russians who provided me copies of the German documents that the Russians captured at the end of the war. I am constantly generating new sources of documents which I make available to international historians all over the world." (33-9388)

Irving testified that he was familiar with Sefton Delmer: "Sefton Delmer was a former German citizen who emigrated to Britain fairly early on and worked for the British propaganda agency, the psychological warfare executive, as a clandestine broadcaster, broadcasting what is called black propaganda; in other words, disinformation and lies to the enemy over clandestine radio transmitters. A very good journalist but not a man that one would turn to establish the truth." Irving did not know whether Delmer had been involved in activities in Germany after the war or not: "He may have been but I'm not familiar with that." (33-9388, 9389)

Christie turned to the subject of the Hans Frank diaries and whether Irving was familiar with them. Said Irving: "Very familiar with the Hans Frank diaries which is - the original Hans Frank diaries are in very many volumes, seventeen or twenty volumes of typescript and handwriting containing not just what we describe as diaries but also the verbatim transcripts of very many records of conferences which he attended...I read them from the angle of somebody...writing a biography of Adolf Hitler, so I was specifically interested in any reference to Adolf Hitler's doings and wrongdoings and the doings and wrongdoings of the Third Reich under Hitler's rule." In Irving's opinion the diaries did not verify the existence of any plan for or any extermination of the Jews of Europe: "There is no reference in the Hans Frank diaries," said Irving, "and one would expect them, because Hans Frank was the Governor General of Poland, or the Governor General of the area of...Poland where the extermination camps are now supposed to have existed. There is no explicit reference in the Hans Frank diaries from start to finish to gas chambers or to a mass extermination of the Jews as government policy whatsoever. And this is a unique source because it is so homogenous the whole way through. The most remarkable passage I found was in February or March, 1944, and I have quoted it in Hitler's War, where he has a long conference with Hitler as the Russians are invading Poland, his own territory, and Frank wants to know what to do and there's a passage there where Hans Frank writes in his diary saying, 'the Führer said to me how glad we are...solving the problem by deporting the Jews to all the different territories.' Words to that effect. When you see something like that, you have to say [to] yourself, are we all writing the same language? Did either of them know what is supposed to have been going on?" (33-9389, 9390)

Irving referred to Adolf Hitler's reaction when Auschwitz was captured by the Soviets in 1945: "On January the 26th or January the 27th, 1945, the Russian troops overran Auschwitz and on this day, the stenographers, who took down in Hitler's headquarters every word he spoke, recorded a passage which has survived. We have the fragment of what he said. General Guderian reported to the Führer, 'Yesterday the Russians overran Auschwitz', and Hitler just replied, 'Oh, yes.' Now, if Hitler had known what was going on, if Hitler had known what was supposed to have been going on, he would surely have said something like, 'Well, let's hope they manage to get rid of it' or 'They're not going to find anything.' All he said was 'Oh, yes' and move on to the next business. This is the kind of clue that one has. Straws in the wind. Altogether it makes a very different picture." (33-9390, 9391)

Are you familiar with someone by the name of Robert Kempner?, asked Christie.

"Robert M. W. Kempner, an attorney now in Frankfurt, was [with] Goering's Ministry of the Interior in Prussia in 1933. He emigrated to America because of the Nazi anti-semitism. There he became a successful attorney. He returned to Nuremberg after the war and he became a leading member of the American prosecution staff in the rebuttal division...Robert Kempner used methods of coercion to prevent witnesses from testifying in certain ways. Friedrich Gaus...a legal member of the German Foreign Ministry, testified to this in a subsequent trial and affidavit that he had been threatened by Kempner with being handed over to the Russians unless he withdrew certain incriminating testimony. By incriminating, I mean testimony that was going to incriminate the Russians." (33-9391, 9392)

Irving testified that at Nuremberg, the "prosecution witnesses, the witnesses who appeared on behalf of the prosecution were cosseted. They were flown in by special plane; they were housed in the few remaining luxury hotels in Nuremberg. They were lavishly fed. They were well paid and they were promised jobs in the American zone of Germany." On the other hand, he testified: "The defence witnesses were universally badly treated. They were housed in the criminal wings in the Nuremberg Palace of Justice. They were housed in cells with no windows; in winter in unheated cells. They were very poorly fed. They were subjected to coercion and physical maltreatment." Said Irving: "I think that not only I but I think reputable lawyers around the world are rather ashamed about the Nuremberg proceedings. Certainly Justice Robert H. Jackson, the American chief prosecutor, was ashamed about them as is quite evident from his private diary...I've examined it. I've had privileged access to that diary in the Library of Congress...I have made a copy of it which I could make available if necessary...Shortly after Robert H. Jackson was given the job by President Truman of conducting the American prosecution at Nuremberg, he learned of the American plans to drop the atomic bombs and from that moment on, he became very uneasy with what he, himself, was doing. Prosecuting for one nation, crimes it had committed, being fully aware that the United States was about to commit and indeed committing a crime of an even greater magnitude." (33-9392 to 9394)

The unfairness of the Nuremberg proceedings extended to the manner in which documentary evidence was handled. "The procedure with documents [at] Nuremberg was rather rare," said Irving. "The prosecution obtained all the documents for its own purposes and the defence was then allowed to build up its case entirely on the basis of the prosecution collection of documents. No collection of documents by the defence was made possible by the authorities in Nuremberg. They were allowed very limited access to the documents collected exclusively for the purposes of the prosecution." (33-9394)

In Irving's opinion, many of the witnesses at Nuremberg and other war crimes trials were unreliable. An example was Karl Wolff: "Major General Karl Wolff was the liaison officer between Hitler and Himmler, an SS general, a character I would describe as being a rather suave character who ended up, by reason of his personal favouritism with Himmler, in charge of the police units in northern Italy at the end of the war and as the military commander in that region, and largely in order to create an alibi, he then began negotiating with the American secret service in order to speed the surrender of the German troops in northern Italy...Wolff testified on many occasions over the years up to his death, frequently varying his testimony according to...which way he was being required to testify. He was always acutely aware of the fact that he had done a deal with the Americans whereby the Americans...promised him immunity and the subsequent West German government also promised him immunity from prosecution if he behaved in a certain way." (33 9394, 9395)

Another example was Dieter Wisliceny: "Dieter Wisliceny was a high SS official who was held by the Communist authorities at the end of the war, and among the private papers which Hugh Trevor-Roper, the British historian, made available to me, was a long, handwritten account by Wisliceny which greatly amplifies the version which is more familiar and known to historians...I read the Wisliceny report with great interest and entertainment, but one has to say that the internal evidence suggested that it was not a document that could be taken seriously in the absence of collateral evidence." Irving continued: "He explained things for which there was not a trace in the archives. He described episodes and matters - well, for example, he describes a conversation with Adolf Eichmann and Adolf Eichmann showing to him a Führer document, a Führer order. Well, there is no such order. It has not been seen and we then have to understand in human terms why Wisliceny is writing this down...It was written in Bratislava (or Pressburg) in Czechoslovakia... He was being held in rather inhumane conditions in captivity at the end of the war...by the Communist authorities." (33-9396, 9397)

The Allied authorities also ensured that certain witnesses were "not available" for the defence, such as Karl Koller: "General Karl Koller...[w]as the Chief of Staff of the German air force at the end of the war. I have his private diaries and papers...his presence was required by the defence at Nuremberg but the Americans pretended that they didn't know where to find him. They had, in fact, locked him away in a prison camp and were interrogating him at that time. This was one typical example of the Americans obstructing the defence at Nuremberg. Karl Wolff was locked up in a lunatic asylum and the Americans pretended they didn't know where he was either and he didn't surface again until 1947." (33-9395, 9396)

Christie turned to the subject of the Eichmann trial and asked Irving if he considered the information there to be of value to historians.

"I think the Eichmann trial is already getting very late in the day as far as recollected testimony is concerned. I personally hesitate to question a witness thirty or forty years after an event as to what happened. You can no longer separate in his mind, no matter how willing the witness is, what really happened and what he has in the meantime read has happened...I recollect from the parts of his testimony that I have read - and I can't purport to have read all the Eichmann testimony for the reason I just said - I recollect at one stage where Eichmann interrupts himself to say 'one moment, I want to point out what I just said I can no longer recollect whether I actually saw this or whether I'm recollecting what you told me I saw.' And this, I think, is a very honest statement by Eichmann where he is questioning his own powers of recollection. In human terms you have to say it's not unlikely in 1963 or 1964, when that trial was held, much had happened." (33-9397, 9398)

Irving had been involved in the publication of the book Ich, Adolf Eichmann: "Adolf Eichmann's son, who is an engineer in Germany, approached me and revealed he had all the tape recordings that his father had made several years before his kidnapping. And the son wanted to know what to do with these tape recorded memoirs of his father. I suggested he should transcribe them and have them published by the world's publishers as a historical source. Again of questionable value, depending on when the [tape] recordings were made, but certainly of great historical interest to historians to see how versions of events had changed over the years. And subsequently, those were published, I think, in the English language, the German language and Spanish." (33-9398, 9399)

Had Irving himself undertaken any investigation of the Anne Frank diaries?, asked Christie.

"The Anne Frank diaries have had a long and checkered history," said Irving, "which is best described by the present state of play, as a result of a court decision in a libel action. The father of Anne Frank, with whom I corresponded over many years, finally relented and allowed the diaries to be submitted to the kind of laboratory examination that I always insist [upon] where a document is in question. As a result of this laboratory examination carried out by the West German criminal police laboratory, in Wiesbaden, it was determined that the Anne Frank diaries were partly written in ball-point pen. It's a long story. I'm not going to bore you with the details. My own conclusion on the Anne Frank diaries is for the greater part they are authentic writings of a pubescent teenage Jewish girl who was locked up and hidden, that they were then taken by her father, Otto Frank, after the girl's tragic death of typhus in a concentration camp, and her father or other persons unknown amended the diaries into a saleable form as a result of which he and the Anne Frank Foundation became rich, but as a historical document they are completely worthless by virtue of having been tampered with." (33-9399, 9400)

Irving continued: "Anne Frank's father, Otto Frank, fought a number of legal actions to defend the authenticity of the diaries and the first legal action which I believe was fought in Lübeck, he introduced handwriting evidence of a graphologist and an affidavit swearing that the diaries were written throughout in the same handwriting. Subsequently, I stated in the introduction of the German edition of my Hitler biography, that a number of forged documents existed which were unquestionably accepted and I've mentioned them in court today, the Canaris diary, the Engel diaries, and I mentioned the Anne Frank diary, which was one of dubious authenticity. Anne Frank's father threatened my German publishers with libel proceedings. The German publishers paid him a cash settlement to shut up without consulting me. I would have told them they were on very safe ground. Subsequently, he has litigated against other people, but in the meantime this litigation has now been - is being spun out, because the only remaining trial I believe is in northern Germany and they are playing it for time. They're waiting for the defendant to die." (33-9400, 9401)

Christie noted that one of the publications tendered as an exhibit in the court was the book The Hitler We Loved and Why. Was Hitler loved in Germany?

"I think I'm right in saying in April 1938, 48 million Germans loved Adolf Hitler and about 200,000 didn't. That was as a result of a perfectly genuine plebiscite that was held shortly after the annexation of Austria by the Germans. I think there's not the slightest evidence that this plebiscite was faked in any way. I don't see how you can fake a referendum on that scale, and yet 48 million adult Germans voted for Adolf Hitler. I would like to add I personally found the title rather tasteless," said Irving. (33-9401, 9402)

Did Churchill have anything good to say about Adolf Hitler?, asked Christie.

"In the 1930[s], when Churchill was not in Parliament and he lived from journalism and writing in the Evening Standard in September 1937, he had words of high praise for Adolf Hitler...Words to the effect that, 'If Britain...should ever come into the position that Germany was in, I would hope that one day we would find a national leader of the stature of Adolf Hitler'." (33- 9402)

Christie asked Irving if there was a document called Table-Talk by Heinrich Heim and whether there was a reference in that to the position of Jews after the war.

"Indeed," said Irving. "Heinrich Heim was the adjutant of Martin Bormann who wrote down on a day by day basis a detailed semi-verbatim record of Adolf Hitler's lunch-time and dinner-time conversation...Hitler repeatedly referred to his post war plans with the Jews. He refers in the Table-Talk in July 1942, I believe I'm right in saying, to his plans for the deportation or relocation of the Jews elsewhere and Heinrich Heim was a very reputable German civil servant who is alive, in fact. I have no doubt that is an accurate rendering of Hitler's words." Irving testified that he had met Heinrich Heim: "I have also made use of the original paper of the Table- Talk. I'm one of the few privileged historians to have used that material. It's in private hands in Switzerland." (33-9402, 9403)

Christie referred back to Did Six Million Really Die? and asked Irving for his opinion on its conclusions regarding the number of Jews who survived. Said Irving: "Let me say at this point I think this conclusion...they are aiming at here is justified. I am delighted that so many Jews survived what they now describe as the 'Holocaust' and I am puzzled at the apparent lack of logic: that the Nazis are supposed to have had a government policy for the deliberate, ruthless, systematic extermination of the Jews in Auschwitz and other places of murder and yet tens if not hundreds of thousands of Jews passed through these camps and are, I am glad to say, alive and well amongst us now to testify to their survival. So either the Nazis had no such programme or they were an exceedingly sloppy race, which isn't the image that we have of them today. It's another of the logical questions which is being asked in this history which the historians hitherto have not asked." (33-9403, 9404)

Do you consider it possible to be accurate in terms of statistical analysis?, asked Christie. Irving did not: "No, I shy away from statistics. I am very, very nervous. I had a one year's training in statistics at university. I know how risky it is to operate with statistics, different tables or different fields or different sources. It's like subtracting apples from potatoes - you can't say there were so many Jews here at the beginning of the war and so many Jews there at the end of the war and subtract one total from the other and say this is the difference. I say this whether it helps or hinders the defence or prosecution. I am very nervous about mass statistics." (33 9404)

Was the conclusion of Did Six Million Really Die?, that the number of Jews who died in concentration camps could only be measured in thousands, legitimate and arguable?, asked Christie.

"Well, I refer to my previous answer," said Irving, "and say that I'm very nervous giving opinions about statistics. Do we mean died or killed?" (33-9405)

Christie indicated roughly 6 million were allegedly killed by either gassing or by the Einsatzgruppen. In your research, asked Christie, has there been any indication of hard evidence for numbers at all?

"Certain numbers for certain specific tragedies. One episode outside Dvinsk, being on the road to Dvinsk being in November 1941, certainly there was an episode there ...a mass grave had been dug and a mass execution...of unidentified civilians was being carried out by unidentified people. It was witnessed by one German Major General Walter Bruns. There is another episode which was witnessed by Hitler's photographer, Walter Frentz, who described it to me...from his own memory what he had seen when he accompanied Heinrich Himmler. Again one isolated episode behind the front, nothing to do with Auschwitz or Treblinka or the so-called extermination camps. So, we're looking there at several hundred if not several thousand people being killed in specific, isolated episodes which are repeatedly served up again and again as being examples of what was going on. I can only look at them as isolated episodes of what was going on." (33-9405, 9406)

Is there any hard evidence to support the estimates of millions of Jews gassed, for example, 4 million in Auschwitz-Birkenau?, asked Christie.

"No documentary, contemporaneous evidence of the kind that would satisfy me," said Irving, "but I think that other historians may perhaps be less pernickety...I think Winston Churchill once defined the job of a historian [is] to find out what happened and why and those are the major areas of historical fact that a historian should try to investigate. What happened and why and the Holocaust historians haven't really established either fact, in the case of the Holocaust, what really happened and why it happened." (33-9406)

In Irving's opinion it was the reader who decided what constituted a historical fact: "The reader. The reader on the balance of probabilities having weighed up not just one source but several sources. He can buy my book on Winston Churchill, he can buy Martin Gilbert's book on Winston Churchill and he can decide where on the two scales...the truth about Winston Churchill lies, but he has to have the alternate sources to look at. He can't have one book presented to him and be told this is the truth, take it or lump it. Take it or go to prison. That would be a very unacceptable form of society." (33-9406, 9407)

Irving pointed out that history was "constantly being revised. I mentioned the episode of the British code-breaking operations. Until 1974, the British official historians, the government historians, were not allowed to be told and not allowed to reveal that we British had been reading the German, the Japanese, the Spanish, the American, the Italian codes by computer. This is a so- called Ultra secret. Knowledge of that is, of course, crucial to the knowledge of how we won the war and yet our entire multi-volume official history of the Second World War until 1974 makes no mention of this. They are going to have to be rewritten. All history books are going to have to be rewritten since 1974 since that one fact became known and so it is in many other fields. It would be a sad day if there was no work for the historian to do. I say that with profound conviction as a professional historian." (33-9407, 9408)

And does a historian, asked Christie, when he's confronted with a document, have to take time to test and evaluate that source to determine its accuracies?

"Certainly with some documents," replied Irving. "Usually a historian will very rapidly get the feeling for where he can be easy with a document and comfortable, and where suddenly his ears prick up and say to himself, wait a minute, I didn't know this. This is so egregious, this fact, so unusual, can I trust it? There's one or two documents in the Holocaust mythology which make me very suspicious for no other reason than that they stand out too much. They are statistic oddities. It looks nice, it looks neat, it looks as though suddenly there's proof, there's 100,000 Jews been killed as partisans and Hitler's told this. And yet we have to say to ourselves, why suddenly this one document which looks like none of the other documents in that series? This is where you have to act a bit like a magistrate and say well, it's nice, I will take notice of that but I want to see more, please. The historian should be constantly weighing and evaluating and not necessarily accepting without question." (33-9408)

Does the fact that documents are located in archives satisfy those tests?, asked Christie.

"I shall disappoint you, I think, by saying on balance, usually yes," replied Irving. "I have rarely if ever come across an archive document which is fake. It is very difficult to get a fake document into an archive. Having said that, I would add it's not impossible and one would then want to look at the file of documents and say does this document, which is controversial, look different in any way? Is the paper newer? Is the ink of the signature fresher? Are the holes in a different position? Questions like that. I mean, the way the document looks; it's not impossible to put fake documents into archives. Certainly they get stolen out of them. But all the fakes that have been put to me - I emphasize all the fakes that have been put to me - come from private hands and not archival sources." (33-9409)

Did you investigate the effects of the breaking of the German codes upon the whole question of the Holocaust in relation to transportation of millions of people without orders?, asked Christie.

"Well, it is unlikely that the Germans could have been issuing criminal orders for the liquidation of millions of people or even hundreds of thousands of people to their SS or police units on the eastern front without us British knowing of it at the time from our code-breaking operations. And of course the Germans, at the end of the war, could not have required us to destroy those records." (33-9409, 9410)

There were, however, references during the war to allegations of mass gassings of Jews in some Allied documents: "I am familiar with the...British archives, the public records office, of attempts to start a black propaganda campaign alleging that the Germans were employing gas chambers and at one stage the head of the British secret service is being cautioned not to go too far with this propaganda because it will make the whole - it will undermine the credibility of the propaganda effort if we go too far with these allegations...This would have been in 1944," said Irving. The fact that these allegations were now made so freely was due, said Irving, to what the chief rabbi of Britain, Lord Jakobovits, said had "unfortunately ...become big business with whose teams of script writers and screen writers and journalists and newspaper writers, making great money out of it. I think it's a great tragedy." (33 9410, 9411)

As a writer yourself, you've been involved in publishing, said Christie. Do you have any knowledge of what would happen if you were writing about the subject of the Holocaust in your own books in a more favourable way than you have?

"After I wrote Hitler's War, my front door was smashed down by a gentleman with a sledgehammer," replied Irving. "I was raided by people disguised [as] telephone engineers who turned out to be from a Jewish organization in Britain. The people who printed this in Britain...had their printing works burned to the ground by one of these fake engineers. They all went to prison. I am an ordinary writer with a family who is frightened for - I don't like to be subjected to this kind of terror. If I was to write the other kind of book, if I was to follow the general line of the present Holocaust mythology, the easy acceptance of it all, 'Adolf Hitler ordered the killing of 6 million Jews in Auschwitz', I would do a very good job of it because I'm a good writer and I would be rich beyond the dreams of avarice, but I couldn't live with my own conscience." (33-9411)

[The testimony which follows was given by Irving in the absence of the jury in support of an application by defence attorney Douglas Christie for leave to introduce the Leuchter Report into evidence and to allow Irving to give his expert opinion on its value as a historical document.]

Irving testified that the previous day he had read the Leuchter Report in its entirety. Said Irving: "If a future historian was to be writing the history of the Holocaust controversy, then undoubtedly they can no longer ignore a document of this validity." (33-9413) He continued: "It is clearly an authentic document. It's clearly a document written by somebody in the position to know what he is writing about and it's a document written for a valid purpose. It's not a spurious document written in order to camouflage something, in my view...It is very much the kind of document that I, as a historian, would hope to find if I was investigating the Holocaust controversy. I'm very impressed, in fact, by the presentation, by the scientific manner of presentation, by the expertise that's been shown by it and by the very novel conclusion that he's arrived at and I must say that as a historian I'm rather ashamed it never occurred to me to make this kind of investigation on this particular controversy." (33-9414)

To your knowledge, asked Christie, has any physical examination of Auschwitz, Birkenau or Majdanek previously been published to determine if these places could have been used in the manner alleged in the Holocaust literature as homicidal gas chambers?

"There has been...to the best of my knowledge, no forensic examination of the sites conducted whatsoever. Either in situ by an expert in execution technology, or in absentia by taking samples for laboratory analysis elsewhere," Irving testified. (33 9414, 9415)

Crown Attorney Pearson rose to cross-examine Irving and began by asking him if the Leuchter Report was a document he would look to as a historian researching the Holocaust controversy.

Irving replied: "If I was a future historian researching the Holocaust controversy, this is certainly the kind of evidence that I should want to make use of." (33-9415)

Are you saying, asked Pearson, that if you were a historian in the year 2015 and you were doing research with respect to what happened in Birkenau on August 25, 1944, you would use this document as a foundation for a conclusion?

"This would give me a foundation for a conclusion about what did not happen in the concentration camps which were investigated by the expert in [the report]," replied Irving. (33- 9415)

What do you mean by saying the report is 'authentic', asked Pearson.

"By that I mean this clearly isn't a fake report. It isn't a report which purports to be what it is but in fact isn't, in the sense of what a fake document is. In other words, this isn't something that has not been written by the purported author. It is quite clearly an authentic investigation by the man who purports to be the author." (33 9416)

Irving agreed that the document was described as an "engineering report" and testified that he "would expect to find it written by a man who has some engineering qualifications." He defined 'engineering qualifications' to mean "[s]aid qualifications for the job that he was purporting to report on...In other words, if he is reporting on execution technology, then I would expect him to be an expert on the subject of the engineering of execution chambers." (33-9416)

If he was reporting on the residue of hydrogen cyanide, would you want him to have a background in chemistry?, asked Pearson.

"No," said Irving, "but I would want him to produce...evidence that - that would satisfy me that he had obtained the samples in a scientific manner and...had sub contracted the quantitative analysis of those samples to a qualified person to make those determinations. It would be too much to expect an engineer to be qualified in the quantitative or qualitative analysis."

An engineer, someone with a degree in engineering?, asked Pearson.

"Yes."

All right, said Pearson, issued by a recognized university?

"Is that a question?"

Yes, said Pearson. What I want to get at is you said authentic and you just said an engineer, someone with a degree in engineering?

"What I actually said was I expect to find him qualified in the engineering field on which he is purporting to report, in this case, execution technology," replied Irving. (33-9417)

So, would you mean somebody who's been recognized by a professional engineering body as being a competent person?, asked Pearson.

"This undoubtedly would be ideal, but obviously we're looking here at the - at what is practicable rather than what is ideal. In this case this is the best engineering report available to this date on the execution technology alleged to have been present at Auschwitz and the other camps." Irving testified that he did not know Leuchter's qualifications personally: "I don't know the author of this report personally at all. All I know from having read the report with the eye of a historian is that he purports to be an expert, a qualified expert in execution technology and...is recognized as such by those states of the United States of America which carry out executions by gas chamber."

If you found out that he only had a Bachelor of Arts and he didn't have an engineering degree, wouldn't that cause you some concern about his engineering report?, asked Pearson.

"It would cause me some concern but it obviously hasn't concerned the states of the United States of America which carry out the very grizzly business of forwarding people from life to death inside gas chambers. They have accepted his expertise." (33-9418, 9419)

Did the states of the Unites States have this man go over to Poland to produce an engineering report about what happened in Poland in 1944?, asked Pearson.

"No, this was, as I understand it, entirely an undertaking organized and financed at the expense of the defendant in the current proceedings," said Irving.

And what was the third criteria that Hugh Trevor-Roper mentioned?, asked Pearson.

"That is...the reason why the document has come into existence. I mentioned earlier this morning that sometimes German generals would write a document for a specific reason, namely to cover themselves for an operation. They would fake something to clear themselves in future. Now, the reason why this document has come into existence is quite clearly as a defence document in this case, and if I would elaborate on that, I would say that therefore the author of that report would be aware of the fact that the document would be subjected to the most expert scrutiny by the likes of yourself and therefore he would employ an enhanced accuracy in presenting his findings." (33-9419)

Irving testified that he would take into account the fact that the report was commissioned by the defence. Asked Pearson, And don't you think that might have some bearing on how much value a historian attaches to it? Irving replied: "Um, this is true, but one wouldn't expect the author of the report to perjure himself and one certainly wouldn't expect the highly qualified analytical laboratories which carried out the chemical analysis on the compounds which were procured from the gas chambers so-called and the delousing chambers so-called in the concentration camps, to have falsified their findings in any way. And certainly, my eye could detect no sign of any kind of falsification in these analytical reports."

Do you purport to have any expertise to draw conclusions from those analytical reports, sir?, asked Pearson.

"Not on the basis of any more than the quantitative chemistry analysis one has learned in the course of a university career," said Irving. "Certainly on the basis of a historian, I can detect fudging. I can detect where something is being omitted. When I exposed the Hitler diaries as being a fake, it was on the basis of the fact that the magazine purported to carry out tests on the ink but didn't, in fact, submit those tests to us at the press conference. They fudged around their findings." (33-9420, 9421)

Pearson indicated that the tests themselves did not say anything; it was the conclusions drawn from them that were important.

"I think that if historians are inclined to accept the eyewitness or hearsay testimony of people who were present on a site, forty years later, the testimony of the bricks and stones which can be collected from the site and subjected to objective chemical analysis should very certainly be relevant to a historian." (33-9421)

You're a historian, said Pearson. You agree with me that you do not have the expertise to draw a conclusion from the absence of a chemical compound on the wall of an installation? Irving disagreed: "Well, I'm afraid there's only one conclusion possible. If, forty years later, this chemical compound is absent from that wall and we are instructed by the scientific expertise it should have been present if it ever was present, then it never was present." (33-9422)

And whose scientific expertise are you talking about?, asked Pearson.

"Going by the expertise of the analytical chemists who were commissioned to make this report...It was either stated in the analysis reports or in the findings of the specialist who has prepared this report on the basis of the evidence presented by DEGESCH, the manufacturers of the cyanide, or on the basis of Dupont, who are the American manufacturers of an equivalent chemical compound. But this chemical compound should still have been present after that length of time." (33 9422, 9423)

Pearson suggested that the only person who had drawn that conclusion was Leuchter, in his report.

"Very well, sir," said Irving. "This is if you were to ask me, and I am sure you eventually will, if I find any flaws in this report, this is the kind of flaw which I would have found in this report and which I think could have been obviated if more money and time had been spent on it...I'm not saying that the report is perfect. What I am saying is, it is important. In fact, I think it is shattering in the significance of its discovery." (33-9423)

If someone is going to draw a conclusion about the absence of a compound on a wall, wouldn't you agree, asked Pearson, they should really know what they're talking about?

"Or consult people who knew what they were talking about," said Irving. "Yes, I would agree with you. But if I were to amplify my opinion as to the - the expertise of this particular witness, I can think of a no more suitable expert to go and examine the sites of purported gas chambers in Poland than one of the few American experts on the construction of gas chambers. And I think it's a stroke of genius on the part of the defence that they should have thought of this and gone to the expense of sending this particular expert with his team out to Poland to collect the samples and bring them back and I think it portrays a certain weakness of the supporters of the Holocaust historiography that they have not undertaken this kind of analysis in the past." (33- 9424)

Irving testified that from his understanding from reading the report, Leuchter was under contract and constructed gas chambers and been consulted by the various American states on their construction. He continued that he could be open to correction on this, and that Leuchter might merely have been consulted as an expert by the various American states concerned. Said Irving: "My conclusion as a historian is that on the basis of what is in front of me, Mr. Leuchter was in a position to know what he was talking about when he was investigating Auschwitz with the eye of a man familiar with the design of gas chambers." (33-9424 to 9427)

Judge Ron Thomas interjected: "Well, I think I can shorten this. You needn't ask any further questions. Do you have any submissions?," he asked Christie. (33-9427)

Christie said: "Yes, I would submit that it would be a remarkable double standard if the Crown can introduce documents without authors for them, without any proof of who wrote them in this case because they happen to be filed in the National Archives...I would submit to you that this witness has said that this evidence is important for historians, it's a valuable piece of historical evidence. It meets the test of historical evidence. The author of the report has been called and cross-examined in front of the jury, unlike any of the other pieces of evidence that have been tendered by the Crown through Mr. Browning, who didn't have any first-hand knowledge of any of them, and for that reason it's my submission that the witness should be allowed to tender that evidence and give his opinion of the value of it in a historical context. I would also like to ask the witness whether, to his knowledge, any physical examination of Auschwitz- Birkenau or Majdanek have previously been published to determine if these places have been used in the manner alleged [as] homicidal gas chambers." (33-9427, 9428)

Judge Ron Thomas ruled: "You will be permitted to ask that question. There will be no comment on the Leuchter Report. Send for the jury, please. You can refer to the fact, and advise this witness, that Mr. Leuchter testified here and that he had conducted this analysation (sic) and then find out from this historian if anything like this had been done to his knowledge before in the history of researching the Second World War." (33-9428)

Christie asked: "Can I ask him whether he considers such evidence valuable?" (33 9429)

Thomas replied: "No." (33-9429)

[This ended the voir dire to determine the admissibility of the Leuchter Report through the expert historian, David Irving. Thomas gave no reasons for disallowing the admission of the Leuchter Report, which had met all tests of valid historical evidence. The evidence which follows was given in the presence of the jury.]

Mr. Irving, said Christie, we have had in this trial the testimony of a Mr. Leuchter, indicating investigations of the physical sites and he was a person who has certain expertise in execution technology using hydrogen cyanide gas and certain chemical analysis was done pertaining to that report in regard to the content of hydrogen cyanide in the walls of the alleged gas chamber. To your knowledge, asked Christie, has any physical examination of Auschwitz, Birkenau, Majdanek, Treblinka, Belzec, Sobibor or any of the alleged extermination camps been previously published to determine if these places could have been used in the manner alleged in the Holocaust literature as homicidal gas chambers?

Irving replied: "No, sir. To the best of my knowledge, there has been no kind of examination prior to this trial and to the evidence introduced or the evidence mentioned in this trial of the so-called murder camps, the extermination camps. No kind of teams of analytical chemists were sent there to investigate the soil or the bricks of the chambers, no kind of a determination was made as to the suitability of the doors or the levers or the flanges or whether the walls had any kind of special sealing compound applied to them to protect the passersby on the street outside. There had been no kind of special determination made as to whether these buildings could ever have effectively been used as homicidal gas chambers and it wasn't until this trial that an attempt was made to carry out such an investigation."

This ended the examination-in-chief of Irving by defence attorney Douglas Christie. Crown Attorney John Pearson rose to commence his cross-examination. (33-9430, 9431)

Pearson referred first to the July 31, 1941 document from Goering to Heydrich and Irving's testimony that Goering could never have read the document. Said Irving: "He couldn't have had time to read it. It's quite evident that Heydrich was only with him for a matter of minutes. Heydrich, in fact, had the document prepared on a letterhead which Heydrich himself had typed. It wasn't even typed on Hermann Goering's notepaper. It was typed on Heydrich's notepaper. It was slipped in for Goering to sign and slipped out again." Irving knew this "From the evidence contained in Goering's diary showing how briefly Heydrich was with Goering." Heydrich was with Goering "ten minutes." Irving pointed out that it was not the only document signed that day. (33-9431, 9432)

How do you know it's not the only one he didn't read?, asked Pearson.

"Because Hermann Goering himself so testified under oath," replied Irving. "Goering testified that he was unfamiliar with this document. I have the entire series of Hermann Goering interrogations, when he was interrogated before the trial began, the pretrial interrogations."

Are you telling us, asked Pearson, that Goering testified that he never read that document?

"It was a surprise to him...To the best of my memory, he was shown the document under pretrial interrogation and this was the first time he recalled seeing it. The document itself is very harmless. It just talks about giving - giving Heydrich, extending his powers for the overall solution of the Jewish problem to the newly occupied-territories." Irving testified that Goering did not deny signing it: "No, in fact, I have the copy as signed by Hermann Goering with his signature." He agreed with Pearson that Goering must have seen it when he signed it but he continued: "Do you have any idea how many documents Hermann Goering would have signed every day normally?...It made no impression on him at all...let me say once again the document was shown to him in the course of a ten minute interview between the chief of the Gestapo, Heydrich, and himself on a rainy afternoon when Hermann Goering was hurrying to the station to pick up his wife whom he hadn't seen for three months." Irving pointed out there were certainly three documents signed by Hermann Goering that day for Heydrich in the ten minute period. He agreed with Pearson that Goering therefore had about three minutes per document. (33-9433 to 9435)

Wouldn't you agree, asked Pearson, that you are speculating when you say he never read it?

"We have to try to interpret how much a man can do in ten minutes when it's such an unimportant document as that." Irving pointed out that the document in question was two paragraphs long.

How long do you think it takes to read?, asked Pearson.

"Two paragraphs, a piece of bureaucratic bumph, I'm afraid you're not familiar with Hermann Goering's lifestyle," said Irving. "...he had a very opulent kind of lifestyle. He wasn't really interested in the minutiae of the bureaucratic life. He wasn't really interested in Reinhard Heydrich, he wasn't really interested in the Jewish question. In July 1942, he still is saying in a verbatim conference that the Führer has made exceptions all the way down the bureaucratic level. He can't understand why all this persecution of the Jews is going on...[t]he same with the Nuremberg race laws. He couldn't understand how they had come into being." (33-9436)

If the academic historians are right, suggested Pearson, that was indeed a significant memo, wasn't it?

"Indeed. They clutch at straws."

What was Heydrich's position?, asked Pearson.

"Heydrich was the chief of the Reichssicherheitshauptamt, which put him in overall charge of the Gestapo and various other important SS police executive agencies." Irving agreed that he held a senior position in the Nazi hierarchy and that "Hitler at one time was considering him as a successor." (33-9436, 9437)

Wasn't it right, asked Pearson, that Heydrich, being a senior person in the hierarchy, was looking to Goering for approval to do something?

"For the reason that Hermann Goering was chief of the four year plan. The head of the four year plan had very, very substantial economic influence in Germany, responsibilities also which had been assigned to him under the overall umbrella of the four year plan office. One of those responsibilities which Hitler had given to Goering at the time of the Reichskristallnacht, the night of broken glass in November 1938, was to oversee the final solution of the Jewish problem. Hermann Goering in January 1939 put Reinhard Heydrich in charge of the geographical resettlement of all Germany's Jews and Austria's Jews and Reinhard Heydrich set up at that time a central office for the relocation of the Jews and so it became Heydrich's penchant, drawing on Hermann Goering's authorities which is why he then had to go back to Hermann Goering in July 1941 to say, 'Look Hermann, we've now taken over all these territories in the east and I need you to expand that authority to me so I can carry on the job in the eastern territories', and that's what Hermann understood was the meat of the document he was signing. In other words, a piece of bureaucratic bumph, drawing the line a little bit further to the east." (33-9438, 9439)

Said Pearson, I don't know, sounds pretty important to me. Bureaucratic bumph?

"You're clutching at straws, the same as historians, if I may be so rude," replied Irving.

You are the one, said Pearson, who told us that this was a significant four year plan and the mandate of the senior official is being extended by the second most powerful man in Nazi Germany?

Said Irving: "The four year plan was very important until March 1942 and it virtually vanished...Heydrich took it as a useful convenience that he could put on his headed notepaper the fact that he was acting on behalf of the head of the four year plan [in] carrying out these jobs. It was a...short-circuiting [of] any kind of opposition that would come along that Heydrich could [use] and indeed did. For example, when Heydrich called the Wannsee Conference, he referred specifically to Hermann Goering's July 1941 document which says that the Reichsmarschall and head of the four year plan has instructed me to carry out an investigation of how we're going to carry out the final solution. I am therefore calling a meeting, which was the famous Wannsee Conference. Heydrich would point to the Goering document and [say] 'This is my authority, so don't start smart-talking me.'" (33-9439, 9440)

Irving agreed that the document was very important to Heydrich and that he used it. Pearson pointed out that Irving had nevertheless described it as 'bureaucratic bumph'. Said Irving: "Yes. When...you ask me why Hermann Goering himself would have paid little attention to what he was signing, he would have viewed it as a piece of bureaucratic bumph...he himself never again referred to it throughout the war years...We have seventy volumes of verbatim records of Hermann Goering's wartime conferences so we're pretty well informed about the way his mind was working. If people take the trouble to read them. But they are in that strange language and people don't take the time." (33-9440, 9441)

Pearson asked Irving whether he disputed the authenticity of the Wannsee Conference protocols. Irving testified that he did not: "I have read the entire file...incorporating the Wannsee Conference protocol and the other versions of the protocol. There are two or three records of the same meeting in various files." (33 9441)

You would agree, suggested Pearson, that at his trial in Jerusalem, Eichmann indicated that that was an important stage in the final steps of the creation of the 'final solution.' Irving interjected to point out that the trial was "twenty years later" and then continued: "I think we can agree that Adolf Eichmann at Jerusalem, when he was on trial, wasn't exactly attending a historical seminar. He was under considerable physical and mental coercion. Some of the things he said would have been true; others of the things that he said would have been false; and I am not in a position to determine which was which."

Are you now saying that the important thing is he was being coerced?, asked Pearson.

"Yes...I am saying that given the wealth of other documentation that we have, we should be able to dispense with looking at twenty year old trials to try and find still further clues as to what happened."

Pearson pointed out that Irving looked at the testimony of other participants at the conference as being significant.

"At the Nuremberg trials. This is true," said Irving. "The trials held in 1945, 1946 and 1947, they were particularly...in '46 and '47, the pretrial of Kritzinger and Lammers and the other...people who had attended, ...Wilhelm Stuckart, who attended the Wannsee Conference, were interrogated in great detail as to what they recollected." Irving agreed he viewed their testimony as significant: "One year or less after the end of the war, yes. I would consider that to be more acceptable than what Eichmann would be saying twenty years after the war." (33-9442. 9443)

So, asked Pearson, the significance now isn't the coercion, it's the passage of time, is it?

"There's an element," replied Irving. "There's an element of passage of time; an element of coercion. If a man, despite coercion, is saying things in a certain way, then it's more likely to be true than if a man because of coercion twenty years later is saying things in a certain way." (33- 9443)

Pearson asked if Irving agreed that if Eichmann attended and prepared the minutes of a meeting which was integral to the plan to exterminate the Jews of Europe, that the passage of twenty years was not going to make him forget that? Irving pointed out that this was Pearson's interpretation of the meeting. He continued: "I think that you have to realize the Wannsee Conference is one of very many interministerial conferences that were held during the war years on all sorts of different topics, stocks, shipping, barges, economy, the fat supply, nitrogen, this kind of conference. And to single out one conference and expect a man years later to recollect what went on there when it's a matter which was as boring to most of them as the solution of the Jewish problem - who is a Jew, who is a half-Jew, what is a quarter-Jew, what do we do with people who have one Jewish grandparent - this kind of thing, a lot of them will have had their minds elsewhere. A lot of them did have their minds elsewhere."

Is it your position, asked Pearson, as a professional historian, that the Wannsee Conference was not a conference to discuss the extermination of the Jews of Europe?

"There is no explicit reference to extermination of the Jews of Europe in the Wannsee Conference and more important, not in any of the other documents in that file. We cannot take documents out of context...In my opinion, it has been inflated to that importance by irresponsible historians who probably haven't read the document," said Irving.

Pearson pointed out there was also the testimony of Eichmann.

"Twenty years later...I think we talked this morning a bit about Eichmann's powers of recollection and the fact he himself got confused about what he really recalled and what he had in the meantime been told. And this is a human failing which unfortunately afflicts all of us, that our memories get bad as we get older."

Forget about the minutes of the meeting and forget about the testimony, said Pearson. Is it your opinion that the Wannsee Conference itself was not a conference to discuss the extermination of Jews?

"That is my opinion." (33-9444 to 9446)

So, suggested Pearson, Eichmann made it up?

"I'm saying that Eichmann was wrong in giving contrary testimony," replied Irving, "but you would have to tell me precisely what Eichmann said. I'm not prepared to take your word for what Eichmann said. I think I have to know his precise words. I don't mean that offensively at all. Even in paraphrasing we may oversimplify what somebody...had said."

Have you read the transcript of Eichmann's testimony?, asked Pearson.

"No, I haven't. I've read a few snatches of it like I mentioned this morning."

Pearson suggested that this hindered Irving's ability to reach the conclusion he had reached. Irving disagreed: "No. I think that when one has a given life span, one can decide how one spends that life. You can spend your life in a library reading all the books [on] Adolf Eichmann...and write the X plus one book or spend your life in the archives and try to write a truer book. If you do that, you don't have to read and why should you bother with the trial records because where you are sitting is right where the truth is, in the archives, and you haven't got the Israeli Ministry of Justice putting itself between you and Adolf Eichmann." (33-9447)

Said Irving: "I don't consider that the testimony of Adolf Eichmann at Jerusalem would have advanced...my knowledge of what happened at the Wannsee Conference. It is twenty years after the war, which is five years after the Wannsee Conference, four years after the Wannsee Conference, and it would have polluted my knowledge rather than improved it." Irving agreed that Eichmann was present at the Wannsee Conference but would not swear that it was he who drafted the protocol: "To the best of my knowledge there is no signature on it." (33-9448)

It's your opinion, suggested Pearson, it's of no value to read the words of a participant in a conference to determine what the conference was about?

"Having read the fragments of Adolf Eichmann's testimony where he says his memory is so shaken that he can no longer distinguish between fiction and fact, he can no longer distinguish between what he really recollects and what he is told he recollects, from that point on all the Adolf Eichmann testimony becomes polluted, dangerous to read for a historian. It would be really like watching a made-for-TV movie about Auschwitz. That would not advance my knowledge," said Irving.

Pearson suggested again that Irving relied on the testimony of the other participants at the conference when they were on trial and had a clear interest in denying that it had anything to do with extermination.

"I accept that, yes...I accept your inference too, that they had a reason to simulate, they had a reason to deceive...I read it with interest. That doesn't mean to say I rely on it. You take note of it."

But you don't take note of Eichmann?, asked Pearson.

"No," said Irving. "Not in that account because of the particular circumstances where Adolf Eichmann was being [heard]. Had Adolf Eichmann been questioned in 1945 at very great length by American or British interrogators, that would have been of substantially greater evidentiary value for a historian than given the circumstances where he is being interrogated under the certain knowledge that he's about to be executed." (33-9449, 9450)

April 25, 1988

Irving agreed that he had written about thirty books and researched for more than ten years before writing Hitler's War and ten years before writing Churchill's War. Hitler's War was first published in Germany in 1975. Said Irving: "The German publishers, without so informing me, willfully excluded and changed parts of the text. I then obliged them to withdraw the book from publication overnight on publication day." Among other things, the publishers had changed parts relating to Hitler's knowledge of the extermination of the Jews. (34-9455, 9456)

Is it your evidence, asked Pearson, that they published that first run without letting you see the final version they were going to publish?

"Most unusual," said Irving. "They did not let me see the typescript of the German translation which I normally like to check myself. They did not honour their promise to let me see the proofs. They did not supply me with an advance copy of the book. I had to buy a copy of the book myself in a book shop in Munich and I immediately sent a telegram forbidding them to print any further editions or to sell any more copies." The English language version of the book appeared in 1977. (34 9456)

Irving agreed that he commenced Hitler's War by saying that the ten years that he had chosen to research Hitler were the best ten years to do so because the archives opened up to researchers and the people who had been involved with Hitler, especially his closest personnel, were still available. (34-9457)

Irving wrote in his introduction to Hitler's War that "the most important documents were provided by Professor Hugh Trevor-Roper..." Irving testified that "Professor Hugh Trevor-Roper is a very well-known and eminent professor of history, modern history. He was the regius professor of Oxford in history...he is now the master of an important college at Cambridge University...He is an academic historian who started initially as a non-academic historian in British intelligence." Irving agreed that he had "[not] the slightest" contempt for Trevor-Roper and in fact had written that the historian's work The Last Days of Hitler was a brilliant exception to most weak biographies of Hitler. Said Irving: "This is why I singled him out for special commendation." He owed Trevor-Roper a "very considerable debt." (34-9457 to 9459)

Irving also agreed that in his introduction to Hitler's War he had acknowledged the debt he owed to Professor Raul Hilberg. Said Irving: "Indeed, oh, yes. I corresponded with Professor Hilberg who I understand has given evidence in a previous hearing." Irving testified he had "[not] the slightest" contempt for Hilberg: "Again, he's one of the few academic historians who has done his homework, if I can put it in that shorthand form." (34-9459)

Would you agree, asked Pearson, that Hugh Trevor-Roper is probably the foremost expert on the Nazi regime in Germany of any English historian?

"Except in one respect," said Irving. "He has very little knowledge of the German language which is a substantial impediment. But otherwise I agree with your statement." (34- 9459)

After Hitler's War, Irving moved on to Churchill, but kept his Hitler dossiers open "as a matter of professional interest." His research into Churchill relied more on archival documents than testimonials as many of Churchill's associates had already died. (34-9460)

Pearson turned to the subject of the assassination of General Sikorski, the Polish Prime Minister-in-exile during the war who died in a plane crash in Gibraltar. Irving gave qualified agreement that his book on Sikorski claimed that Churchill was responsible for his assassination. "I will go along with that description. In fact, it was left more open than that but the reader was invited to draw that conclusion," said Irving.

Did the law courts consider the proposition that Sikorski was assassinated by Churchill?, asked Pearson.

"They did indeed...The lower courts, on the basis of a play written by a completely different person, considered a libel action brought by the sole survivor of the plane, a Czechoslovakian national. The libel action was rather uniquely fought in as much as the defendant was a German living in Switzerland who made no attempt to appear and on the basis of that kind of court case, the court found, of course, for the plaintiff...to be perfectly specific, of course, my book was not on trial. The pilot, the Czech, Prchal, issued a libel writ against me as the author of the book, Accident: The Death of General Sikorski, and he chose not to, which implies in my view, he accepted that what I had written was not open to challenge in the English lower courts. We would certainly have defended it had he issued a writ." (34-9461, 9462)

Pearson produced a review of Hitler's War written by Hugh Trevor-Roper which appeared on June 12, 1977 in the Sunday Times Weekly Review, with which Irving was familiar:

It is well known that Mr. Irving, some years ago, convinced himself that General Sikorski, who died in an air-crash at Gibraltar, had been "assassinated" by Winston Churchill, to whom in fact his death was a political calamity. Not a shred of evidence or probability has ever been produced for this theory, and when it was tested in the courts, Mr. Irving's only "evidence" (which was very indirect at best) was shown to be a clumsy misreading of a manuscript diary. (I have myself seen the diary and feel justified in using the word "clumsy"). And yet here is this stale and exploded libel trotted out again, as if it were an accepted truth, in order to support a questionable generalisation.

Did Hugh Trevor-Roper say that in his article, sir?, asked Pearson.

"He did indeed," agreed Irving, "but he is wrong in suggesting that my theory was ever tested in the lower courts and you can have a look at my book if you wish, Accident: The Death of General Sikorski, and you will find no reference whatsoever in it to the diary which he mentions...The newspaper then refused to publish a letter from me in reply. I pointed out he was entitled to his opinions and he could put them to music and have them played by the Mainstream Guards, but I deal in facts."

Didn't Sir Frank Roberts say that Churchill wept when he heard the news?, asked Pearson.

"I have read that statement recently. It's a very recent statement by the head of the Central Department of the Foreign Office in 1943. He made that statement in the 1980s, forty years later to Winston Churchill's authorized biographer and we can each of us attach whatever weight we choose to that statement."

You choose not to accept it?, asked Pearson.

"Churchill wept freely and readily," said Irving. (34-9464, 9465)

Pearson turned to Hitler's War and read from the introduction:

The negative is traditionally always difficult to prove; but it seemed well worth attempting to discredit accepted dogmas if only to expose the "unseaworthiness" of many current legends about Hitler. The most durable of these concerns the Führer's involvement in the extermination of the Jews. My analysis of this controversial issue serves to highlight two broad conclusions: that in wartime, dictatorships are fundamentally weak - the dictator himself, however alert, is unable to oversee all the functions of his executives acting within the confines of his far-flung empire; and that in this particular case, the burden of guilt for the bloody and mindless massacre of the Jews rests on a large number of Germans, many of them alive today, and not just on one "mad dictator," whose order had to be obeyed without question.

"I think that today, eleven years later, I still stand by what I published on that date," said Irving. "...There were very large numbers of massacres which can only be described as bloody and mindless of Jews and other ethnic minorities in occupied Europe during the Second World War."

I suggest, said Pearson, that the way you have written it - 'the Jews', not 'some Jews' - that you're talking about race genocide.

"I think that readers who are picking up my book and looking at it are very familiar with the fact there has long been an allegation about a massacre or extermination of the Jews in the Second World War. The same as we talk about the extermination or massacre of the Armenians. I think it would - I really hope you have better material than this with which to challenge me frankly. I've come a very long way. I don't really want to spend a great deal of time debat[ing] one word, 'the'." (34-9466, 9467)

Pearson continued reading:

I had approached the massacre of the Jews from the traditional viewpoint prevailing in the mid- 1960s. "Supposing Hitler was a capable statesman and a gifted commander," the argument ran, "how does one explain his murder of six million Jews?" If this book were simply a history of the rise and fall of Hitler's Reich, it would be legitimate to conclude: "Hitler killed the Jews." He after all created the atmosphere of hatred with his anti-Semitic speeches in the 1930s; he and Himmler created the SS; he built the concentration camps; his speeches, though never explicit, left the clear impression that "liquidate" was what he meant. For a full length war biography of Hitler, I felt that a more analytical approach to the key questions of initiative, complicity, and execution would be necessary.

Pearson suggested that in that passage Irving was saying that if one was looking at Hitler's Reich and not just at Hitler, it would be legitimate to conclude that Hitler killed the Jews. Irving replied that Hitler "had a constitutional responsibility as head of state." (34-9467, 9468)

What was the significance of the statement that Hitler and Himmler created the SS?, asked Pearson.

"Back in the 1930s, back in the 1920s in fact," said Irving, "the SS was created as an elite bodyguard for Hitler and out of which emerged the various branches of the SS, including the Waffen SS, which was the biggest branch of all, and the sentence means what it says. They both jointly created the SS." (34-9468)

Pearson suggested that in effect, Irving was saying Hitler was responsible for creating the organ that massacred the Jews. Irving disagreed: "I don't think I say that the SS is the organ that massacred the Jews. I'm just saying what, in fact, I printed there. I chose those words very carefully in writing the introduction." (34-9468)

Pearson continued reading:

For a full-length war biography of Hitler, I felt that a more analytical approach to the key questions of initiative, complicity, and execution would be necessary. Remarkably, I found that Hitler's own role in the "Final Solution of the Jewish Problem" has never been examined.

What did you mean by the "final solution of the Jewish problem"?, asked Pearson.

"Well, earlier in that paragraph, I have talked about the argument, the public perception of what had happened and I have clearly put that sentence in quotation marks; what the public calls the 'final solution of the Jewish problem'...We are going to examine in the book what the 'final solution' was, but I am already advancing here, I am alerting the reader to the fact that in this book he's going to find data on this controversy."

Wasn't the "final solution" the term generally accepted as being the term used for the racial genocide of the Jews?, asked Pearson.

"On Friday I quoted you from memory a spring 1942 document in which Hitler is quoted by the chief of his Reich Chancellery as saying 'the Führer wants the solution of the Jewish problem postponed until after the war is over'. Now, you can't have it both ways. That document is a genuine document." (34-9469)

Pearson suggested that in his introduction, Irving was telling the reader that he was going to prove that Hitler did not have