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</A> -Cui Bono?-

from;
http://www.nizkor.org/hweb/people/l/lipstadt-deborah/response-to-irving.html
Click Here: <A
HREF="http://www.nizkor.org/hweb/people/l/lipstadt-deborah/response-to-irving.
html">Dr. Deborah Lipstadt response to Irving lawsuit</A>
-----
For our archives.  Thanks, Michael.
Om
K
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Defense:
Dr. Lipstadt responds to David Irving

(Part 1 of 2)


------------------------------------------------------------------------
[UseNet headers trimmed]
1996.--I.--N.
In the High Court of Justice

QUEEN'S BENCH DIVISION
Between
DAVID JOHN CAWDELL IRVING
Plaintiff
and
PENGUIN BOOKS LIMITED
First Defendants
DEBORAH E. LIPSTADT
Second Defendant
DAVID CRANK
Third Defendant
ALISTAIR BABB
Fourth Defendant
STANLEY BROMLEY
Fifth Defendant
COLIN ORR
Sixth Defendant
DEFENCE OF THE SECOND DEFENDANT
1. It is admitted that the Plaintiff is a well-known writer, and the author
of a biography " Goebbels, Mastermind of the Third Reich" (hereinafter
referred to as "the Goebbels book"). It is denied that the Plaintiff is an
historian. Save as aforesaid, paragraph 1 of the Statement of Claim is not
admitted.
2. Paragraph 2 of the Statement of Claim is admitted.
3. It is admitted that the Second Defendant is the author of a book entitled D
ENYING THE HOLOCAUST, sub-titled The Growing Assault on Truth and Memory (the
Work), which the First Defendants published within the jurisdiction of this
Honourable Court in about July 1994. The Second Defendant occupies the Dorot
Chair in Modern Jewish and Holocaust Studies at Emory University in Atlanta,
Georgia, USA. Save as aforesaid, the Second Defendant declines to plead to
paragraphs 3 to 7 inclusive of the Statement of Claim, and those parts
thereafter of the Statement of Claim which concern the other Defendants to
this action.
4. It is admitted that in the Work, the First Defendants published the words
(as footnoted but with different numbering) set out in paragraph 8 of the
Statement of Claim. The said words formed but part of the Work, to the whole
of which the Second Defendant will refer to put the said words into their
proper context. It is denied the said words referred to the Plaintiffs save
where he was expressly referred to by name. Save as aforesaid, paragraph 8 of
the Statement of Claim is denied.
5. It is denied that the said words, whether in their natural and ordinary
meaning, or by way of innuendo bore or were understood to bear the meanings
pleaded in paragraph 9 of the Statement of Claim.
6. Further, or in the alternative, the said words are true in substance and
in fact. The meanings the Second Defendant will justify are :

that the Plaintiff has on numerous occasions (in the manner hereinafter
particularised) denied the Holocaust, the deliberate planned extermination of
Europe's Jewish population by the Nazis, and denied that gas chambers were
used by the Nazis as a means of carrying out that extermination;
7. that the Plaintiff holds extremist views, and has allied himself with
others who do so, including individuals such as Dr. Robert Faurisson, and Erns
t Zundel;
8. that the Plaintiff, driven by his obsession with Hitler, distorts,
manipulates and falsifies history in order to put Hitler in a more favourable
light, thereby demonstrating a lack of the detachment, rationality and
judgment necessary for an historian;
9. that there are grounds to suspect that the Plaintiff had removed certain
microfiches of Goebbels' diaries contained in the Moscow archives, from the
said archives without permission; and that the Plaintiff lied and/or
exaggerated the position with regard to the unpublished diaries on microfiche
of Goebbels contained in the Moscow archives, and used by him in the Goebbels
book;
10. that in all the premises, the Plaintiff is discredited as an historian
and user of source material, and there was an increased risk that the
Plaintiff would for his own purposes, distort, and manipulate the contents of
the said microfiches in pursuance of his said obsession.
P A R T I C U L A R S
Meaning (i) - (iii)(v): The Holocaust and the Gas Chambers
11. The Plaintiff has publicly claimed as follows :
12. "There were no gas chambers at Auschwitz.... by logical deduction that
were no gas chambers anywhere in Germany... But this is not an important
issue. I am not a Holocaust Historian. About 100,000 people died in Auschwitz
in three years. If we must assume generously that a quarter of them were
murdered then we must remember that the British killed 50,000 Germans in one
night when they raided Hamburg...."
13. "Auschwitz was not an extermination camp and the Holocaust was a
propaganda hoax by the British... That question [the Holocaust] is still wide
open. I still maintain Auschwitz was not an extermination camp. There were no
gas chambers there, I think they were a figment of British wartime
propaganda..."
14. "I also predict that one year from now [1992], the Holocaust will be
discredited. That prediction is lethal because of the vested interests
involved in the Holocaust industry. As I said to the Jewish Chronicle, if a
year from now the gas chamber legend collapses, what will that mean for
Israel? Israel is drawing millions of dollars each year from the German
taxpayer, provided by the German government as reparation for the gas
chambers. It is also drawing millions a year from American taxpayers who put
up with it because of the way the Israelis or Jews have suffered. No one is
going to like it when they find out that for 50 years they have been
believing a legend based on baloney".
15. "I do not think there were any gas chambers or any Master Plan. It's just
a myth and at last that myth is being exploded."
16. "Why dignify something (the Holocaust) with even a footnote that has not
happened" (when dealing with the new edition of "Hitler's War", written by
the Plaintiff and published by the Plaintiff's own imprint, Focal Point in
November 1991);
17. "The gas chambers were erected in Poland for the tourists".
18. The said claims were variously false and/or misleading in that:
19. The Nazis established Concentration Camps proper (camps in which persons
were imprisoned without regard to the accepted norms of arrest and
detention), throughout the Third Reich and the Nazi Occupied Territories: for
example, Dachau, Buchenwald, Ravensbruck and Bergen-Belsen;
20. The systematic mass murder of the Jews began in about June 1941, when the
Germans invaded the Soviet Union. In the first place, carried out primarily
by the SS Einsatzgruppen, hundreds of thousands of Jews were shot to death;
21. After an experiment on Soviet prisoners of war in the main camp of
Auschwitz on 3 September 1941 in which 600 of them were murdered using Zyklon
B gas, extermination camps in Poland at Chelmo, Belzec, Sobibor, Treblinka,
Auschwitz-Birkenau and Majdanek were used and/or established with (save for
the latter two, which were also labour camps) the sole purpose of murdering
every person brought to them, irrespective of age or sex;
22. Chelmo was put into use in December 1941. The victims were killed using
gas vans. About 320,000 persons were murdered there;
23. Auschwitz-Birkenau began operating as an extermination camp in March
1942. At its height, it had 4 gas chambers in use, using Zyklon B. Over 1
million Jews were murdered there, as were tens of thousands of gypsies and
Soviet prisoners of war, until it was closed in November 1944;
24. Belzec, Sobibor and Treblinka were established as part of Aktion Reinhard
(headed by Globocnik), the murder operation principally aimed at the Jews of
the General Government in Poland, and used carbon monoxide gas generated by a
diesel or gas engine. About 600,000 Jews were murdered at Belzec, whilst it
operated between March and December 1942; between about 250,000 and 500,000
Jews were murdered at Sobibor during its operation between April 1942 and
October 1943; and between about 870,000 and 1.1 million Jews were murdered at
Treblinka between July 1942 and August 1943.
25. The Holocaust, the deliberate planned extermination of Europe's Jewish
population by the Nazis, resulted in the murder of millions of Jews in
extermination camps as set out above. About a further 2 million Jews were
killed in Russia, elsewhere in Poland and in other European countries.
26. On 5 May 1992, the Plaintiff was found guilty by the District Court of
Munich of defamation in conjunction with the offence of denigrating the
memory of deceased persons. The facts upon which the said conviction was
based were as follows. On 21 April 1990, at a meeting attended by about 800
people of the Deutsches Jugendbildungeswerk at the restaurant Lowenbraukeller
on Stiglmaierplatz in Munich, the Plaintiff said (inter alia):

"We now know, and I need mention this here only by way of footnote, that
there were never any gas chambers at Auschwitz.... We now believe that, just
as the gas chambers which the Americans built here in Dachau in the days
following the end of the war, were a sham, the gas chambers which can now be
seen by tourists in Auschwitz were built by the authorities in Poland
following the Second World War...For this the German tax payers have had to
pay about 16 billion Deutschmarks as a penalty for Auschwitz... For a sham".
27. On 14 January 1994, the 25th Criminal Chamber of the Regional Court of
Munich upheld the said conviction of the Plaintiff, and increased his fine
(to 200.00 DM for 150 days). During the course of his appeal the Plaintiff
claimed that his researches had revealed no evidence of the gassing of the
Jews in Auschwitz and scientific opinions had proved the impracticability of
gassing. During the course of its judgment upholding the Plaintiff's
conviction as aforesaid, the Regional Court further found that (as was the
fact):

"Anyone denying the gassing and murdering of Jews in the `Third Reich'
defames every Jews and slanders the memory of all Jews gassed in Auschwitz.
By calling the mass gassing of Jews in Auschwitz an invention, the Accused
[the Plaintiff] denies the Jews the inhumane fate to which they were
subjected in the `Third Reich' purely on account of their origins...He knew
that the so-called Auschwitz lie would be assessed as defamation and
prosecuted...The Accused is seeking only superficially to paint a picture at
variance with established research and in truth is clearly seeking to deny
the mass murder of the Jewish people in the Third Reich...The Accused can
only reach his conviction by failing to heed the historical fact of the
gassing of the Jews in Auschwitz...and by relying on a few revisionist
outsiders and pseudo natural history propaganda magazines apologetic to the
National-Socialist cause. Had the Accused applied his endeavours in an
unprejudiced manner, not marked by any ideology of the Right, he would always
have been in a position to assess accurately the numerous historical sources
and witnesses...To the extent that the Accused is relying on his belief, the
Criminal Chamber has not taken this into account to reduce the fine...since
the gassing of the Jews in Auschwitz is such a publicly known historical fact
that only people - like the Accused - who refuse to acknowledge this dreadful
truth are able to arrive at such a belief.
To the detriment of the Accused it has to be said that a denial of the fate
of the Jews in Auschwitz represents a massive insult to Jewish people and a
grave defamation of those who died. The Criminal Chamber has also appraised
as aggravating the fact that the Accused from his own testimony disseminated
the so-called Auschwitz lie even subsequent to the events at issue here....
there is a risk of the generation which did not experience as direct
contemporary witness the situation prevailing during the National Socialist
period and the persecution of the Jews accepting this line of thinking
without questioning it... It also had to be taken into account that the
Accused as a writer and historian is also in a position to give the
impression that his thoughts are backed up by scientific evidence. There is
the risk that by giving voice in this way he will be used by revisionists of
the neo Nazi movement as a historical-scientific signboard and thereby
introduce above all uncritical young people not versed in history to his
ideas...."
28. The Institute of Historical Review ("the IHR") is an ultra-right wing,
pseudo academic organisation which is the centre of revisionist activities
and publications, and which attracts neo Nazis, anti-semites and racists. The
IHR is part of a network that includes the Liberty Lobby which publishes
Spotlight, a journal devoted to the Jewish conspiracy theory, and the Committe
e for Open Debate on the Holocaust. The IHR holds an annual revisionist
conference, devoted to the promulgation of the view inter alia that there was
no Holocaust. On its editorial board was Ditlieb Felderer, an Austrian
resident of Sweden, publisher of the vitriolic anti-semitic publication
"Jewish Information Bulletin", who in 1983 was sentenced to 10 months in
prison for distributing hate material (he had sent leaders of the European
Jewish community pieces of fat and locks of hair with a letter asking them if
they could identify the contents as Hungarian Jews gassed at Auschwitz).
29. In September 1983, the Plaintiff (described by the IHR as "noted British
revisionist historian"), lectured to the Fifth said conference. Amongst his
fellow speakers was Dr Robert Faurisson, author of numerous revisionist
works, and sued (according to IHR literature advertising the conference) for
defamation for speaking "independently on the Six Million/Gas Chambers
thesis". Dr Faurisson was in fact convicted by the French courts for the
libel of denying the Holocaust. Dr Faurisson has claimed the "so-called
gassing" of the Jews was a "gigantic politico-financial swindle whose
beneficiaries are the state of Israel and international Zionism" and whose
chief victims were the German people and the Palestinians. He has further
claimed that the Nazi decree making it mandatory for Jews to wear a yellow
star was a measure to ensure the safety of German soldiers because Jews
engaged in espionage, terrorism, black market operations and arms
trafficking; and that Jewish children were required to wear the yellow star
from the age of 6, because they too were engaged in illicit or resistance
activities against the Germans;
30. In February 1989, the Plaintiff lectured to the Ninth said conference.
Amongst his fellow speakers were Fred Leuchter, a self-styled engineer, who
published a report purporting to prove that the gas chambers at Auschwitz and
Majdenek were never used to gas people, speaking on "The `Gas Chambers' at
Auschwitz...", and Carlo Mattogno, speaking on "The First Auschwitz Gassings:
Genesis of a Myth". At the said conference the Plaintiff said:

"They [the Exterminationists] have realised that they are way out of line
with the Auschwitz story, and they are frantically engaged in damage control
at present. They're pulling their entire army of liars back from the main
battlefront, into the second line, because all the artillery that's coming
down on the front line now is making it too dangerous for them".
31. In October 1990, the Plaintiff lectured to the Tenth said conference.
Amongst his fellow speakers was Dr Robert Faurisson. The Plaintiff's lecture
was introduced by Mark Weber. Mr Weber described how at the trial of Ernst
Zundel (see (7) below), the Plaintiff had explained in detail why he now
accepted the Revisionist view of the extermination story. Mr Weber called the
Plaintiff "a kind of one-man IHR", and set out the conclusion of the
Plaintiff's address in Dresden on the anniversary of the fire-bombing of that
city in which he said:

"Ladies and gentlemen, survivors and descendants of the holocaust of Dresden,
the holocaust of Germans in Dresden really happened. That of the Jews in the
gas chambers of Auschwitz is an invention. I am ashamed to be an Englishman".
32. In the course of his said lecture to the IHR in 1990 (to the whole of
which the First Defendants will refer) the Plaintiff said (inter alia):

"Just picture me seven years ago, in 1983. I'm at the press conference of the
West German Magazine Der Stern, in Hamburg. I'd been smuggled in disguised as
a reporter for Bild-Zeitung, which is the opposition newspaper group in
Germany. I was very familiar with the Hitler case: I'd spent twenty years of
my life studying the story of Adolf Hitler. I'd built up a personal card
index on his life - about 30,000 index cards - and when they told me that
they were about to publish the Hitler diaries, I knew it was phony! So
Bild-Zeitung said: "Will you come along disguised as our press correspondence
and attend this damned press conference and blow it up for them"? So I went
along. I was the first one at the microphone, and I was the first one to have
the chance to ask the people at Der Stern certain questions. I said right
out: "The diaries are fake - the Adolf Hitler diaries are fake!" They'd spent
nine million deutschmarks on them! And all the German historians had said
they were genuine. Eberhard Jäckel had said they were genuine, so they must
be genuine - but they weren't.
I got the same kind of feeling about the Holocaust. (I'm going to come to
Rommel further on). But it's the same story, because when we come to look at
the story of Field Marshall Rommel, and the legend that he was a member of
the anti-Hitler resistance movement, that he was a hero of the twentieth of
July, 1944, a story that has come down for forty years, since World War Two -
we find that nobody has bothered to go back and look at the actual records.
They all believed what everybody else had written about him. And it isn't
until you go back and look at the records that you realise that the truth is
somewhere else".
This how it was when I was in Toronto a couple of years ago. I was called as
an expert witness as a historian to give evidence at the Ernst Zundel case,
where Zundel's researchers showed me the Leuchter Report, the laboratory
tests on the crematoria and the gas chambers. As a person who, at University
in London, studied chemistry and physics and the exact sciences, I knew that
this was an exact result. There was no way around it. And suddenly all that
I'd read in the archives clicked into place. You have to accept that, if
there is no evidence anywhere in the archives that there were any gassings
going on; that if there's not one sing German document that refers to the
gassings of human beings - not one wartime German document; and if there is
no reference anywhere in the German archives to anybody giving orders for the
gassings of people, and if, on the other hand, the forensic tests of the
laboratories, of the crematoria, and the gas chambers and Auschwitz and so
on, show that there is no trace, no significant residue whatsoever of a
cyanide compound, then this can all only mean one thing.
So how do we explain the fact that for forty-five years since the end of
World War Two, we have all, internationally, globally, been beset by a common
guilt: the idea that the human race was responsible for liquidating six
million human beings in gas chambers? Well, the answer is: we have been
subjected to the biggest propaganda offensive that the human race has ever
known. It's been conducted with such finesse, with such refinement, with such
financial clout, that we have not been able to recognize it as a propaganda
offensive - from start to finish. And yet there are these weapons cruising
past us on the horizon - in all their ugliness - and the biggest weapon, of
course, of all in this propaganda campaign against the truth since 1945 has
been the great battleship Auschwitz! And we have now, at last, the historical
profession - above all, the Revisionist historical profession - have found as
our own task, the major task: "Sink the Auschwitz!"
I warned you that I was going to show no respect for tests in the first part
of this talk. Sink the Auschwitz! But we haven't had to sink the Auschwitz,
because the crew of the Auschwitz, Beate Klarsfeld, the Wiesenthals, Elie
Wiesel and the rest of them, have been struggling on the bridge and battling
with each other - boxing and engaging in fisticuffs - and the Auschwitz has
been steering itself amongst the icebergs, and finally it has begun to
scuttle itself. They have begun to haul down the flat of the battleship
Auschwitz. They've taken down the placard, they've taken down the memorial to
the four million, and they've replaced it with a rather smaller memorial to
one million.
Of course that's not the end of the story. I'm convinced that it's just the
"interim memorial". I think it's on cardboard, if you have a close look,
because why waste money on an expensive memorial when you're only going to
have to change it again in a few months time! They're going to have to change
it because it's quite obvious. I'm not going to say only a million - I'm not
going to say only any figure died in Auschwitz. We don't know the exact
figures of how many people died in Auschwitz...
That's what's happening in Germany now. They're still sticking to the six
million figure. And they're still being told that they were gassed. Although
all the evidence runs the other way. To me, Auschwitz is unimportant - I'm
happy that the ship is scuttling itself. It's vanishing. It's going to be
left like the battleship Arizona at Pearl - if you ever go to Hawaii and have
a look at it - with just its mast sticking out of the water to mark where
once a great legend stood. And when people go there a hundred years from now
and say: "Down there is the most incredible legend that people believed for
fifty years: it's the great battleship Auschwitz, it was scuttled by its
crew!"
Why don't we have to believe it? Well, you know about the Leuchter Report".
The First Defendants will further rely on a comparison between the use made
by the Plaintiff in his lecture of what was said by Professor Arno Mayer in
his book " Why Did the Heavens Not Darken?", and what was actually said in
the book in context, as an example of manipulation of source material (see
(16) and following below);
33. In October 1992 the Plaintiff lectured to the 11th said conference.
Amongst his fellow speakers were Arthur Butz, author of "The Hoax of the
Twentieth Century", which purports to prove that there was never a Holocaust,
Fred Leuchter, Ahmed Rami described by the IHR as a gallant Moroccan who has
become a radio apostle for Revisionism in Sweden and who tells of his jail
sentence for "lack of respect" for Jews in Sweden, and (by videotape, since
he was refused permission to enter the USA) Ernst Zundel, a Canadian
neo-Nazi.
34. Ernst Zundel, is the author of "The Hitler We Loved and Why", published
by "White Power Publications" which concluded with the proclamation that
Hitler's spirit "soars beyond the shores of the White Man's home in Europe.
Where we are, he is with us. WE LOVE YOU, ADOLF HITLER!"; and also of the
book, "UFOs: Nazi Secret Weapons?" which argued that UFOs were Hitler's
secret weapons and are still in use at bases in the Antarctic beneath the
earth's surface. Zundel advocates fascism, denies that the Holocaust occurred
and created Samisdat Publications to reprint and distribute material which
was racist, anti-semitic and which denied the Holocaust.
35. In 1988, Zundel was prosecuted by the Canadian Government (for the second
time) for stimulating anti-semitism through the publication and distribution
of material he knew to be false. (Zundel was convicted on that charge at the
first trial, but the conviction was overturned on appeal). The Plaintiff gave
evidence at that second trial on Zundel's behalf, purportedly as an expert
witness. The Plaintiff was shown by Zundel's researchers, the so-called "Leuch
ter Report", ("the Report"). which purported to be an expert report based on
a visit by Fred Leuchter and Dr Robert Faurisson to Auschwitz - Birkenau and
Majdanek, and which proved (so its author claimed) that there had never been
any homicidal gassing at Auschwitz, Birkenau and Majdanek. The Plaintiff
adopted the said report enthusiastically. As he said at the IHR meeting
referred to at (5)(iv) above:

"As a person who, at University in London, studied chemistry and physics and
the exact sciences, I knew this was an exact result. There was no way round
it. And suddenly all that I'd read in the archives clicked into place. You
have to accept that, if there is no evidence anywhere in the archives that
there were any gassings going on; that if there's not one single German
document that refers to the gassing of human beings...and if, on the other
hand, the forensic tests of the laboratories, of the crematoria, and the gas
chambers and Auschwitz and so on, show that there is no trace, no significant
residue whatsoever of a cyanide compound, then this can all only mean one
thing..." [no gassings of human beings (at Auschwitz-Birkenau) in gas
chambers]
36. In fact, Fred Leuchter had no expertise in the matters upon which he
purported to give an expert view in the Report, and his evidence as a
self-styled expert was (rightly) rejected (save to a very limited extent) by
the Canadian Court, for that reason. Moreover, the scientific validity and
methodology of the Report were fundamentally flawed. Though Leuchter claimed
an expertise in engineering, he had none. Indeed in June 1991, 2 weeks before
Leuchter was due to go on trial in Massachussets for practising or offering
to practice engineering without a licence, Leuchter signed a consent
agreement admitting that he was not and never had been a professional
engineer, and had fraudulently presented himself to various states as an
engineer with the ability to consult on matters concerning execution
technology. Leuchter further acknowledged that though he was not an engineer
and had never taken an engineering licensing test, he had produced reports,
including the Report containing his engineering opinions. Henceforth,
Leuchter agreed to cease and desist, presenting himself as an engineer and
issuing any reports, including the Report.
37. By then the Plaintiff had published under his Focal Point imprint, the
English edition of the Report entitled "Auschwitz: The End of the Line: The
Leuchter Report - The First Forensic Examination of Auschwitz", with a
foreword written by the Plaintiff. In that foreword, the Plaintiff said:

"UNLIKE THE WRITING OF HISTORY, chemistry is an exact science. Old fashioned
historians have always conducted endless learned debates about meanings and
interpretations, and the more indolent among them have developed a subsidiary
Black Art of "reading between the lines", as a substitute for wading into the
archives of World War II documents which are now available in embarrassing
abundance.
Recently, however, the more daring modern historians have begun using the
tools of forensic science - carbon-dating, gas chromatography, and simple
ink-aging tests - to examine, and not infrequently dispel, some of the more
tenaciously held myths of the twentieth century
Sometimes the public is receptive to the results, sometimes not. The negative
results of the laboratory analysis of the ancient Shroud of Turin is one
example: it is not a deliberate fake, perhaps, but nor was it nearly as old
as the priests would have had centuries of gullible tourists believe.
It is unlikely that the world's public will be as receptive, yet, to the
results of the professional and dispassionate chemical examination of the
remains of the wartime Auschwitz concentration camp which is at the centre of
this report.
Nobody likes to be swindled, still less where considerable sums of money are
involved. (Since 1949 the State of Israel has received over 90 billion
Deutschmarks in voluntary reparations from West Germany, essentially in
atonement for the "gas chambers of Auschwitz"). And this myth will not die
easily: Too many hundreds of millions of honest, intelligent people have been
duped by the well-financed and brilliantly successful post-war publicity
campaign which followed on from the original ingenious plan of the British
Psychological Warfare Executive (PWE) in 1942 to spread to the world the
propaganda story that the Germans were using "gas chambers" to kill millions
of Jews and other "undesirables".
As late as August 1943 the head of the PWE minuted the Cabinet secretly that
despite the stories they were putting out, there was not the slightest
evidence that such contraptions existed, and he continued with a warning that
stories from Jewish sources in this connection were particularly suspect.
As a historian, I have, on occasion, had recourse to fraud laboratories to
test controversial documents for their authenticity. In the late 1960s I
discarded certain diaries of Vice Admiral Wilhelm Canaris, offered to myself
and the publishers William Collins Ltd, since Messrs. Hehner & Cox Ltd of the
City of London advised me that the ink used for one signature did not exist
during the war years. It was I who exposed the "Hitler Diaries" as fakes at
Der Stern's famous International Press Conference in Hamburg in April 1983.
And yet I have to admit that it would never have occurred to me to subject
the actual fabric of the Auschwitz concentration camp and its "gas chambers"
- the holiest shrines of this new Twentieth Century religion - to chemical
tests to see if there was any trace of cyanide compounds in the walls.
The truly astounding results are as set out in this report: while significant
quantities of cyanide compounds were found in the small de-lousing facilities
of the camp where the proprietary (and lethal) Zyklon B compound was used, as
all are agreed, to disinfect the plague-ridden clothing of all persons
entering these brutal slave-labour camps, no significant trace whatsoever was
found in the buildings which international opinion - for it is not more than
that - has always labelled as the camp's infamous gas chambers. Nor, as the
report's gruesomely expert author makes plain, could the design and
construction of those buildings have made their use as mass gas-chambers
feasible under any circumstances.
For myself, shown this evidence for the first time when called as an expert
witness at the Zundel trial in Toronto in April 1988, the laboratory reports
were shattering. There could be no doubt as to their integrity. I myself
would, admittedly, have preferred to see more rigorous methods used in
identifying and certifying the samples taken for analysis, but I accept
without reservation the difficulties that the examining team faced on
location in what is now Poland; chiselling out the samples from the hallowed
site under the very noses of the new camp guards. The video tapes made
simultaneously by the team - which I have studied - provide compelling visual
evidence of the scrupulous methods that they used.
Until the end of this tragic century there will always be incorrigible
historians, statesmen and publicists who are content to believe, or have no
economically viable alternative but to believe, that the Nazis used "gas
chambers" at Auschwitz to kill human beings. But it is now up to them to
explain to me as an intelligent and critical student of modern history why
there is no significant trace of any cyanide compound in the building which
they have always identified as the former gas chambers.
Forensic chemistry is, I repeat, an exact science.
The ball is in their court.
David Irving London, W1 May 1989"
38. In an Early Day Motion, in the 1988/9 session of Parliament, 92 Members
of Parliament condemned the Plaintiff and the Report as follows:-

"That this House, on the occasion of the reunion in London of 1000 refugees
from the Holocaust, most of whose families were killed in gas chambers, or
otherwise by Nazi murderers, is appalled by the allegation by Nazi
propagandist and long-time Hitler apologist David Irving that the infamous
gas chambers of Auschwitz, Treblinka and Majdenak did not exist, ever, except
perhaps as the brain-child of Britain's brilliant wartime Psychological
Warfare Executive; draws attention to a new fascist publication, the Leuchter
report, in which this evil column appears; and condemns without qualification
such pernicious works of Hitler's heirs."
39. In an Early Day Motion, in the 1991/2 session of Parliament, 43 Members
of Parliament condemned the Plaintiff and his aforesaid views and the
Plaintiff's activity in smuggling Leuchter, the subject of an exclusion order
by the Home Secretary into the United Kingdom. The Plaintiff had done so in
order that Leuchter could speak at a meeting organised by the Plaintiff which
coincided with the publication by the Plaintiff of the revised version of
Hitler's War, held at Chelsea Town Hall in November 1991. The meeting was
addressed by the Plaintiff and was attended by prominent members of the
National Front and the BNP (which organisations were described by the
Plaintiff after the meeting as NCOs and foot soldiers).
40. Whilst publicly denying the Holocaust (for example see (1)(v) and (5)(iv)
above) in the new edition of "Hitler's War" in 1991, the Plaintiff wrote
extensively about the shooting of hundreds of thousands of Jews, including
women and children, by the Einsatzgruppen in the East, mentioned the 152,000
Jews killed at Chelmo on 8 December 1941 only to propose that an official
exchange of letters, six months later proved Hitler had nothing to do with
them, and referred to the "thousands [of Jews] evidently being murdered",
between March 1942 and July 1942, without explaining how they were killed,
again emphasising that Hitler knew nothing.
41. The Plaintiff holds extremist views (see above). He described himself as
"a mild fascist" (or took no objection to being so described until recently),
and said he had visited Hitler's eyrie at Berchtesgarten and regarded it as a
shrine. The Plaintiff has also said, "I am more sympathetic to Hitler than
others have been ... I may well exchange pleasantries with Andries Tremact
but he lacks Adolf Hitler's charisma ...". The Plaintiff has a small
self-portrait of Hitler in a glass case in his study, and other Nazi
memorabilia. The Plaintiff believes in the benevolent repatriation of
immigrants.
42. Moreover, the Plaintiff has strong links with Ewald Althans, the leading
neo-Nazi in Munich, who is anti-semitic, and racist (and proud of it).
Althans booked the Plaintiff's hotel in Munich for him under a pseudonym in
May 1992, and sells and distributes the Plaintiff's books, videos and
cassettes.
43. As a result of the Plaintiff's aforesaid views and activities, the
Plaintiff has been deported from Austria (inter alia, for his extremist views
and his connections with the German extremist group, the DVU); and banned
from entering Australia, Canada and Germany. The Plaintiff has also been
banned from the German State Archives.
Meaning (i)-(iii)(v): "Hitler's War" (unattributed page references are to
"Hitler's War")
44. In 1977, the English edition of the Plaintiff's book, " Hitler's War" was
published. The purpose of Hitler's War, informing its massive documentary
presentation, was to present a revised picture of Hitler by transferring both
the political and military errors and the crimes ascribed to him to others:
the errors to his generals, the crimes to his political associates.
45. As in the case of the death of Sikorski (see (49) below), the Plaintiff
had one vital document, which he declared (p.xiv) was "incontrovertible
evidence" that Hitler was not responsible for the extermination of the Jews -
indeed knew nothing about it (until October 1943) it was carried out behind
his back by Himmler. This "incontrovertible evidence" is an entry in
Himmler's telephone log-book recording a call on 20 November 1941 made by
Himmler, then at the Führer's Headquarters in East Prussia, to his deputy,
Reinhard Heydrich, head of the Reich Security Main Office, then in Prague.
46. The Plaintiff claimed (at p.xiv):

"Many people, particularly in Germany and Austria, had an interest in
propagating the accepted version that the order of one madman [Hitler]
originated the entire massacre [of the Jews]. Precisely when the order was
given and in what form has, admittedly, never been established. In 1939? -
but the secret extermination camps did not begin operating until December
1941. At the January 1942 "Wannsee Conference"? - but the incontrovertible
evidence is that Hitler ordered on November 30, 1941, that there was to be
"no liquidation" of the Jews (without much difficulty I found in Himmler's
private files his own handwritten note on this)."
47. This claimed the Plaintiff, (e.g at pp.332, 393 and 504) proved that
Hitler positively forbade the murder of the Jews (of which somewhat
inconsistently, he was declared by the Plaintiff to be unaware). Thus, the
Plaintiff could conclude, the Final Solution, and extermination of Jews in
the Gas Chambers were the unauthorised policy of Himmler alone.
48. In fact, the said note proved no such thing. The Himmler note actually
read (in translation):

"Transport of Jews from Berlin. No liquidation".
It is quite clear that the order (even if it was Hitler's) applied (as the
Plaintiff must have been aware, since he read it) to a particular transport
(i.e. train load) of Jews only: it was an exception. A particular liquidation
would not have been forbidden unless it would otherwise have happened.
49. Further, the said document, like any document, has to be seen in its
context, from which the Plaintiff detached it. Although the full diary page
entry was reproduced in facsimile in a plate in the book, the plate was not
transcribed apart from the two sentences set out in (20) above. The lay
reader would not have been able to understand Himmler's handwriting (in
German) from the plate or the significance of the rest of the diary entry.
Additionally, the transportation of Jews from Berlin and their semi-public
murder in Riga was causing unrest both in Berlin and among the occupying
troops in Riga; and so the order was given that this train-load was not to be
liquidated (although in fact it was liquidated since the particular exception
arrived too late). [Continued]
--[cont]--
Aloha, He'Ping,
Om, Shalom, Salaam.
Em Hotep, Peace Be,
All My Relations.
Omnia Bona Bonis,
Adieu, Adios, Aloha.
Amen.
Roads End

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