Lying About Hitler:
The Irving-Lipstadt Trial

Can a Revisionist Really Get a Fair Trial?

by S. H.

A student essay from Dr. Elliot Neaman's History 210 class (historical methods - fall 2001)

© Elliot Neaman / PHDN
Reproduction interdite par quelque moyen que ce soit / no reproduction allowed

How It All Began

“Oh you think that’s tasteless. How about this. There are so many Auschwitz survivors going around, in fact the number increases as the years go past which is biologically very odd to say the least, because I am going to form an Association of Auschwitz Survivors, Survivors of the Holocaust and other Liars for the ‘A-S-S-H-O-L-S’”[1]. The man who said this to an audience in Calgary Alberto in September of 1991 is named David Irving. When in 1993 Deborah Lipstadt published a book listing him a “Holocaust denier” he turned around and sued her for defamation of character. The case, as one might guess, was high profile to say the least, which raises the question of whether or not, with the intense and special circumstances like Irving representing himself in court, he received a fair trial. To determine as much it is necessary it look at the case individually and from both sides.

The case really started with the publication of Deborah Lipstadt’s second book, Denying the Holocaust: The Growing Assault on Truth and Memory. Published first in the United States, by the publishing house Penguin Books Limited in 1993 and then in England by July of 1994. The book does make reference to Mr. Irving roughly seven times. Lipstadt discusses how Irving was always known for his controversial theories[2], and has been described as a “Hitler Partisan” and a “Nazi sympathizer”[3].  Acknowledging that he is best known for his thesis that Hitler did not know about the Final Solution, she links him to “neofasist and denial connections[4]. As one example for this she lists the Anti-Zionist conference that he had been scheduled to speak at in Sweden, during November of 1992[5]. Lipstadt reveals the common opinion among historians, authors and reviewers that Irving is a pseudo historian who will “…misstate, misquote, falsify statistics, and falsely attribute conclusions to reliable sources.”[6] Of course what came to be the heart of the trial was the definite referral to Mr. Irving as a “Holocaust Denier”, at first as an example of Holocaust denial on page 111, then as a self-proclaimed convert to the denial on page 179, quoting him as he discusses the Holocaust as a “myth” set up by the Allies[7]. Finally, she quite directly writes, “Irving is one of the most dangerous spokespersons for Holocaust denial. Familiar with historical evidence, he bends it until it conforms with his ideological learnings and political agenda”[8].  These and the few other quotes backing up this argument of Irving as a Holocaust denier were what Irving cited in 1995 when he wrote Penguin demanding the withdrawal of Lipstadt’s book from circulation alleging defamation and threatening to sue. Penguin refused to withdrawal the book, which in turn led to Irving issuing a defamation writ in September of 1996. In his Statement of Claim he described himself as a “reputable historian and publisher wholly or largely dependent since 1961 on his income from writing and marketing books and from lecturing at home and overseas on topics of modern history”[9].

Citing Penguin Books Limited as the first defendants and Deborah E. Lipstadt as the second defendant, he claimed that the non-fiction nature of the body of work this book is complied of has caused “damage of a lasting nature” to the Plaintiff’s career, and personal safety[10].  As the liability laws in England are set up, the defendants are placed in a position of having to prove their innocence in relation to the charges brought against them. Therefore, the defense had two choices, either prove that Lipstadt had not made such accusations of Irving in her book, or that the accusations were true and well known, proving she was not guilty of falsely slandering Irving. Given the straightforward nature of Lipstadt’s material the first choice was ruled out, leaving the Defense to prove the two main points, which were that Irving (A) knowingly falsified documents and misrepresented information and that (B) Irving fit the description of a Holocaust denier. Beginning in January of 2000, Penguin and Lipstadt were represented in front of the Royal High Court of Justice; Queen’s Bench Division presided over by Mr Justice Gray, by a team of lawyers including lead attorney Richard Rampton.  In contrast, Irving chose to represent himself, using only volunteers to help him with some of the research and legal documentation. As a bit of a departure from usual court proceedings, there was to be no jury deciding the outcome of this case. Instead it was to be solely decided by the judge. “Everyone agreed that the mass of documentation was too vast, the issues too intricate for a jury to cope with”[11].  The trial played out amongst media frenzy declaring that the Holocaust itself was on trial. The basic format of the trial when broken down first covered Irving’s reputation and reputability of work followed by the discussion of whether or not he fell into the category of being a Holocaust denial. This last point drew a great deal of press and attention because it focused on things like the existence of gas chambers at concentration camps like Auschwitz. The trial drew to a close in March of 2000.

As his Statement of Claim indicated, Irving’s case revolved around showing what he believed was the true meaning of a Holocaust denier. By doing so he would then be able to demonstrate not only that he was not someone who could be classified as such, but also how in being labeled in such a way his career had been derailed and his very safety compromised. “The Plaintiff will show at the hearing of this action that the true or legal innuendo of the words otherwise complained of hereinbefore as being published in “the Work” is that he is a person unfit to be allowed access to archival collections; and that he is a person who should properly be banned from foreign countries regardless of the effect this will have on the lawful exercise of his profession”[12].  Irving’s strategy involved representing himself, as was formerly mentioned. In doing so he had chosen “…not call any expert witnesses to testify on substantive issues, only two historians to comment, favorably as he hoped, on his reputation among professional historians, and one Kevin MacDonald, a Californian “evolutionary psychologist,” to defend him against the charge of anti-Semitism by supporting his view that Jews had always stuck together throughout history in pursuit of their own interests”[13].  It was surprising to many that Irving had not called on any of the self titled Revisionists like Ernst Zundel, to testify on his behalf. This was most surprising to the “Revisionists” themselves who felt they could have turned the case for him. “David Irving refused to present Germar Rudolf as an expert witness. Here is the price he has to pay for it: He lost his lawsuit, and has to pay $3.2 million (AP) or even $4.5 million”[14]. However, as was shown, this too was part of Irving’s plan to distance him from the image of Holocaust denial.

Harrowing and time consuming, as it was at the time, in retrospect the defense team had a fairly cut and dry case they needed to execute. They would first establish the fact that contrary to what Irving had claimed “…the Plaintiff is discredited as an historian and user of source material,” and that he “…holds extremist views and has allied himself with others who do so,”[15]. The use of expert witnesses was heavily depended on by the Defense in order to establish the two main points to their case. First, that Irving had falsified and willfully manipulated documentation to make it back his own personal, political and historical views and second, that he was in fact an example of a “Holocaust denier”. This had to be carefully done by first setting up the guidelines of what Holocaust denial is and then applying it to Irving. Robert Jan Van Pelt, Richard Evans, Christopher Browning, and Peter Longerich were all commissioned to write various reports dealing with these facets of the case. As Evans notes in his book, Lying About Hitler, the expert witness evidence was extremely important in this case. “Almost every aspect of the assessment of Irving’s work reached in the final judgement derived ultimately from the expert reports and the way Irving had dealt with them in court”[16].

Irving Tells His Tale

In reference to the figure of six million Jews killed in Auschwitz, Irving was quoted in a 1993 lecture as saying “I don’t like the word ‘deny’, the word ‘deny’ is only one step away from lying really.  I challenge it. I contest it”[17].  This is very representative of the way Irving works. He deals in words, which to him can at times be far more important and potent than issues. At the center of this suit is the meaning of the words Holocaust denier. Irving, as he relays in his Statement of Claim, sees the words “Holocaust denier” as a lethal innuendo.  “…the words “Holocaust denier” is that of any person described as such willfully perversely and with disregard to all existing historical evidence denied and continues to deny all and any occurrence of one of the worst crimes known to history namely the mass murder by whatever means by Hitler’s agents and their associates of the Jewish people and hence genocide and hence a crime against humanity”[18]. By setting up this definition Irving is in affect defining his case.  If the rest of the facts are going to rely on the matter of what these two words mean it is imperative for him to try and set his own definition. In this way the defense will not be able to apply their label to him and thus go on to try and justify their case based on such.  During his opening argument Irving once again places an extreme amount of attention on the words.  Here he breaks them down in order to debunk their nature. “As a phrase, it is of itself quite meaningless.  The word “Holocaust” is an artificial label commonly attached to one of the greatest and still most unexplained tragedies of this century. The word “denier” is particularly evil because no person in full command of his mental facilities…can deny that the tragedy happened…”.  He ends his comment saying, “It is a verbal Yellow Star”[19]. When finally questioned on day two of the trial as to what he understands the meaning to be he quips, “I think it is otiose to try and define the Holocaust just the way you wish to define it in order to snare somebody,” before giving the loose definition of, “…the Holocaust is the tragedy that befell—that undoubtedly befell the Jewish people during the Third Reich, not even just during WWII. The Holocaust in my submission is not the machinery which produced the result, it is the suffering and not the murderer, shall we say”[20]. Lastly on the subject he says, “To that extent I find it offensive to be called a Holocaust denier because there are aspects of the Holocaust as are currently portrayed that I find questionable, debatable and they need to be debated. But that is not Holocaust denial in my view, my Lord”[21]. With such a build up as to the nature of what a horrible label Irving had been given his logical next step was to show how such name calling had done real damage to his personal and professional life.  He stated, “My books have appeared between hard covers under the imprint of the finest publishing houses”[22], giving as an example, Viking Press, St. Martin’s Press as well as Penguin Books, to name but a few.  Coming next to the point that he believed that it was Lipstadt’s book that cased him to lose his publishing connections which make up his livelihood.  He said, “… I have since 1996 seen one fearful publisher after another falling away from me, declining to reprint my works, refusing to accept new commissions and turning their backs on me when I approach”[23]. Part of his reasoning for this was an article that was printed in the Australia/Israel Review published in Sydney, which concluded that Irving’s book, Goebbels. Mastermind of the Third Reich, had been dropped by St. Martin’s Press after being warned by Lipstadt and “others” about his approach to history.[24] Irving also contended that his personal safety had been compromised due to his being labeled a Holocaust Denier in the Lipstadt book. As an example he recalled how in Los Angeles while attending his publishing imprint, “a notorious member of the Jewish community… came up to the stand and screamed that he was going to come back and kill me, “You’re a Holocaust denier” he screamed as he was led away by the police, using the phrase coined by the Second Defendant”[25].

With his obvious objection stated, Irving began his argument by setting up his reputation as a historian and author. He submitted to the court countless articles and reviews that he felt looked favorably upon his work. This included reviews from Captain Stephen Roskill, Professor Norman Stone, and interestingly enough, Professor Hugh Trevor Roper, as a few examples[26].  Hugh Trevor Roper is the same person who, acting for the Times newspaper in London, declared the “Hitler Diaries” to be authentic after conducting a brief look at them in a Swiss bank vault. He later resigned on his position of their authenticity, but it is still interesting that he would be a person that Irving would name in the arena of establishing credibility[27].  Irving spoke of his commitment to what he calls “pure” or “true” history. By this he is referring to his strict policy of using only primary documents whenever possible.  He would for example rather use actual telegram messages or hand written notes form those he is studying than to read works by other historians on the same subject. He feels that other people’s books are “ill-written” and ironically says, “you are liable to imbibe the errors and prejudices with which those books are beset”[28]. This of course lets him expound upon the fact that he feels he is responsible for much of the new and groundbreaking material found in the subjects of Hitler and the Third Reich, etc. . “…I have provided historical documents both to the community of scholars and to the general public of which they were completely unaware before I discovered these documents, and published and translated them”[29].

Irving, when concerning his reputation, also needed to address his alleged misconduct in the case of the “Gobbels Diaries”.  Lipstadt had written that Irving had “violated” his agreement with the Russian archives, and taken them abroad and had them copied without permission. “There is serious concern in archival circles that he may have significantly damaged the plates when he did so, rendering them of limited use to subsequent researchers”[30].  In response to this Irving argues what he considers to be the two main objectives. “The moot point is that there is a dispute as to the nature of the Russian permission”[31]. This is because, as Irving states on several following occasions, Russian officials, mainly Professor Tarasov, gave the permission to him. He says that this occurred by way of a verbal agreement to work on translating the plates.  “Certainly the Russians committed nothing to paper about such an agreement”[32].  As to whether or not he had permission to take the plates he does admit, “…I have stipulated, in what I believe is known in legal terms as an admission, that I carried with me two of the glass plates from the Moscow archives to the Sunday Times in London, informally borrowing them in the same manner as previously…” [33]. His explanation? That he feared due to the “chaotic conditions” of the archives that immediate action was required to insure that the information would not be lost. He further justifies the act by saying, “The next day, Dr. Bondarev formally authorized the borrowing of two more such plates anyway. So it was clear to me that nobody would have been offended by my earlier action”[34]. Irving’s largest effort to establish credibility lay in his two key witnesses, both which had to be subpoenaed. Both Professor Cameron Watt and Sir John Keegan were called in order to provide credibility for the Plaintiff.  Professor Watt , who teaches International history at London school of economics, and is familiar with German documentation from the end of the war, was called on day seven. He seemed to be a little more open to Irving’s work, saying that he found it to lean in favor of Hitler but not to be immediately dismissed[35]. Sir John Keegan, who is the Defense correspondent for Telegraph Newspapers Limited, seemed to be quite weary of Mr. Irving.  Called on day 16, to help establish military knowledge and credibility, Sir John said, “Just because I admire ‘Hitler’s War’, which I do…it does not mean to say that I endorse your opinions beyond what you have to say, about what I am interested in, in ‘Hitler’s War’…As a military historian…I think you do it extremely well in ‘Hitler’s War’, that does not mean I go any farther in following you” [36].

One of the main arguments that Irving needed to deal with was the point of whether or not he had purposely changed or manipulated documents with knowledge and intent. As a sort of running theme throughout the trial, one of his tactics to combat this was his argument that he was not in fact an expert on the Holocaust. Rather he had dealt with it only on a superficial basis in relation to WWII as a whole and was therefore not responsible for deeper meanings of the comments he had made on the subject.  “I have never held myself out to be a Holocaust expert, nor have I written books about what is now called the Holocaust. If I am an expert at all, I may be so immodest to submit that it is in the role that Adolf Hitler played in the Propagation of WWII, and in the decisions which he made and the knowledge on which he based those decisions”[37]. As proof of this point and of his expertise Irving offers the fact that he was the first one to state that the before mentioned “Hitler Diaries” were in fact a fraud. This could not explain away all of the examples of his misquoting as the defense saw it. Irving, however had another simple way to explain this. They were on the whole mistakes. Translations that he had misread, information that had come out after he had published his work, or that he had been kept unaware of until long after his work had been produced, etc.  Of course these things could not be his fault. During testimony he acknowledges one such mistake in his text that had the affect of painting Hitler as having intervened on behalf of the Jews in relation to “no liquidation”. As well in the same text having misquoted a word that would have then made the text refer to all the Jews instead of one specific trainload.  “I appreciate quite readily that in the first chapter of my “Hitler’s War” book I wrongly put that in the plural.” “It is very difficult handwriting and I have to plead that as being my partial excuse for having misread (German spoken) and also on the following day for having misread the word “juden” as “haben”(?) or vice versa[38]. At one point Irving even showed the court a German newsreel from the 1940’s produced under allied authorities that stated the number killed at Auschwitz as “300,000 victims”. He then told the court “…if this was one of the documents before me at the time I wrote my book, my Lord, then I could hardly be accused of manipulation or distortion if I choose to rely on this document rather than on the evidence of someone like Rudolf Hess”[39].

Another serious matter that Irving needed to address was the fact that Lipstadt had referred to him as extreme right wing and an anti-Semitism, and his connections with such types of  organizations, not excluding neo-nazi groups. When testifying as to these points Irving once again fell back on his powers of rhetoric. His argument often consisted of contesting the meaning of what was meant by his comments. Questioned by defense council Mr. Rampton, as to the nature of the claims of, “What is said about you (in relation to Nazi anti-Semitism) is that you tried to blame what was done during the Third Reich against Jews upon the Jews themselves.” Irving responded, “That is a gross oversimplification. I have said on a number of occasions, for example, most recently to Daniel Goldhagen who wrote a book on Hitler and his executioners. If I were a Jew I would be far more concerned, not by the question of who pulled the trigger, but why; and I do not think that has ever been properly investigated.”   He defines Anti-Semitism as “malaise in society” a recurring “historical problem”, but as a failsafe once again he says, “…frankly, I do not have the qualifications to investigate it”[40].  In relation to his association with Neo Nazis and other right-wing extremists Irving had several tactics. First, he disputed the defining of the titles. “These people are extremists by definition of these expert witnesses. I do not think there is any satisfactory definition of “extremist”…this is a very subjective subject[41]. Second, he brought to the table the concept of guilt by association. His theory being that he could not be proven to be Anti-Semitic, right wing extremist or a Neo Nazi supporter merely because they might be some of the people who came to hear him speak. “I think it is a very loose kind of argument when people say, ”Look who he is in the same room with” or “Look who comes to hear him speak” which is what a lot of allegations appear to be”[42]. In relation to the Institute for Historical Review, Irving denied being associated with it as well as the fact that it is  “ultra right-wing, pseudo-academic, or attractive to Neo Nazis, Anti-Semites and racists.”  He did have to admit that he had lectured to IHR audiences on several occasions, but emphasized only “…about five times in fourteen years”[43]. When questioned about these associations by Mr. Rampton who asked, “So you would say that there is not anyone who you feel, in hindsight, you should not have associated with?”  Irving responded with “Oh, in retrospect, good lord, yes! In retrospect…you can say,  “I wish I never got to know him”, but we have all met people like that, my Lord. This should not be held against me. People change”[44]. Concerning then his connection with “revisionists” like Ernst Zundel, Irving felt the correct approach would be to emphasize that he had never wanted to associate with Zundel due to his reputation and only first met him by accident on a lecture tour. In relation to testifying at Zundel’s trial he said that he stood behind the evidence that he gave but would not do it again if he had the chance because of the associative company it put him in. He maintained that he does not agree with Zundel on a number of beliefs and felt he should not be automatically assumed to share those[45]. His last key witness, Kevin MacDonald was also part of Irving’s plan to show that he was not Anti-Semitic. MacDonald, who claims to be “a evolutionary psychologist”, was to give testimony on the theory that Jews had always stuck together throughout history in pursuit of their own interests. This was intended to show that Irving therefore could not be labeled anti-Semitic for simply restating this argument. When asked if he felt he had seen proof that Jewish communities around the world have strategies to protect themselves or to preserve their interests, Mac Donald answered, “Yes I think that anti-Semitism is a perennial problem, and Jewish organizations developed very sophisticated ways of dealing with it …anti-Semitism is fought very, very intensely. They take it very seriously and they do quite a job obviously of suppressing it”[46].

Here of course then lies some of the theories that Irving needed to expound upon which were thought to be examples of Holocaust denial. There was the subject of distorting the number of Jews said to have been killed. It had been indicated first of all that Irving had tried to compare the number of Jews killed to the number of Germans killed by Allied bombings. This was in order to diminish the number of Jews and to make it seem as if the Holocaust was just another atrocity that happened during a time of war. Irving  indicated that he felt the word “comparisons” was wrong, but that he had mentioned the facts in successive sentences. On the subject of the bombing of Dresden in 1945, his figures for the number dead were 135,000 dead based on what he gathered from a Trevor Roper who had been a schoolteacher in Hanover at the time and had been in charge of identifying the dead. This number was pointed out to have been reduced in his current version of his book Destruction of Dresden, but only to 60,000, which is still quite inflated from the official Grosse Report of around 35,000. His answer to this was that “… the Grosse Report had been deliberately issued by the Propaganda Ministry for propaganda purposes.”, ending with, “But 60,000, my Lord, 35,000, 135,000, you may disagree with me, but I see no difference between these figures”and, “If you are you are one of those dead it hurts just as much if you are one of the 35,000 or one of the 135,000”[47].

In response to the bigger subject of whether or not six million was the correct number for Jews killed in the Holocaust, Irving slightly adjusted his view but would only say that the margin was somewhere between one and four million. His final view on the subject however was that the majority was due to epidemics such as Typhus, and Allied bombing raids.[48]

As to the nature of the Nazis killing mass numbers of people by gassings Irving had always had quite a definite opinion on this subject. He has always maintained that he was in fact a “gas chamber denier” saying “I denied the gas chambers. I denied that the Germans killed millions in gas chambers”[49]. On the stand Irving did concede that some gassings had taken place on an experimental basis, but believed that those were mostly the experimental truck gassings and that they had proven too much trouble to be used in great degree by the Nazis[50]. When asked point blank about the numbers killed, in this case at Birkenhau, Irving said, “I am denying that any kind of multiple millions of people were killed at Birkenhau” proceeded by the comment, “A million people weigh 100,000 tons. We are talking a major logistics problem[51].   When confronted with evidence that at Birkenhau human female hair had been found to have the presence of hydrogen cyanide, Irving’s logical conclusion was that corpses had been routinely fumigated because of lice and typhus[52]. The subject was then brought up that if these rooms were indeed used for fumigation processes why did they have “peep windows” and gas tight doors? Irving’s ready answer was that they also had to be able to double as bomb shelters in case of an allied attack[53]. Irving also offered up what he believed were the reasons that Nazis running the camps after the war would admit to the false gas chambers. When asked by Justice Gray, “Can you tell me…what you say the motivation of the eye witnesses who painted a false picture of what had been going on in Auschwitz was?” he answered, “I would say it varies, my Lord. It would be partly the promise of alleviated punishment, partly torture, partly pecuniary. It depends on when we are talking about, whether it was done recently in connection with a Hollywood film or back in 1945 to assist the Polish authorities”[54]. The Leuchter report, which had been used at the Zundel Trial, raised even more questions. Irving had hailed the report at the time as proof that mass gassings were a myth. Fred Leuchter, a designer of gas chambers and lethal injection devices, had written it. He had allegedly illegally taken samples from a “gas chamber” at Auschwitz, and had tests done on them. He said the results showed that there could not have been gassings of humans done there because the amount of chemical residue left was too small.  The report, however, was not used in the trial because it was found to be inaccurate. Although Irving would say that the report is flawed he still contends that “…the chemical results contained in that report, which I still considered to be a valuable starting point for the whole controversy” [55].

Being a self proclaimed expert on the subject of Hitler it was obvious that Irving would have an opinion on Hitler’s position concerning the Holocaust. Irving’s usual argument when dealing with Hitler came up which is that he demands to see just one document showing proof that Hitler had ordered the “liquidation” of the Jews. Often attacked as his double standard, because he will go on very limited information and documentation when it comes to supporting his arguments, but in the case of Hitler he wants undeniable proof.  Even Justice Gray asked him about this  to which he answers that it is a valid but not a correct criticism. He gave as a example something he had said in relation to this to AGP Taylor,  “…after over 50 years we would be entitled by now to have found the document that proves me wrong, where as we are not entitled to expect to find records about General Sikorski, even now, because it would have been a Secret Service matter and the Secret Service files are closed for at least the next 100 years[56]. This leads right into Irving’s idea that Hitler was unaware for the most part that a mass movement to exterminate the Jews was taking place. His example of this, is when talking about a document which was addressed to Hitler, with “shown to the Fuhrer” written in German on top. The document actually talks about “Jews executed” at one point with the number of 363,211 given. Irving would except that the document was probably seen by Hitler but negated the point by saying, “I think in all probability he paid no attention to it . The reason being the date. This is the height of the Stalingrad crisis. …Heydrich Himmler has thought that this is an opportune moment to slip a document into the heap to be shown to the Fuhrer which he can use one way or the other as time may come later on, either to say, ‘look how well I did mein Fuhrer’, or on the other hand to say, ‘But I told you at the time we had done that.’” [57].

Such a path of thinking leads to his other argument that Hitler had no plan to exterminate the Jews of Europe. Irving keeps to his original belief that at the most there was only a lose plan to deport the Jews, noting that one possible place discussed was Madagasgar .  Mr. Rampton in an attempt to challenge this theory asks about several speeches that Hitler made where he refers to getting rid of the Jews. One  speech made in January of 1939, reports him as saying that as so far as the Jewish question is concerned, the Fuhrer is determined to make a clean sweep.  Irving replies that this is just an example of “…the old gramophone record that Hitler played again and again”[58]. In essence he is saying that Hitler never really meant these terms in exchange for talking of extermination, but rather that it was just lecture tactic that he had always employed.

To Irving the last end to wrap up would be the question of why the defendant would have singled him out in such a way.  In the opinion of Irving it is quite clear to see that he felt that there were definite forces much bigger than just the defense working against him. Time and again he referred to these unnamed groups that had plotted his downfall.  It was evident even in his opening speech to the court, saying that the Defendants did not act alone in their determination to destroy my career and to vandalize my legitimacy as an historian. They were part of an organized international endeavor at achieving precisely that”[59]. These are the issues and views that the defense was looking at when they were preparing to face Irving in court.

Defense’s Day In Court

As has been discussed, the defense team had the real burden of this case. In order to win they needed to prove how Irving fit without a doubt all the accusations made in Deborah Lipstadt’s book. Radiating out from the central hub of the defense were the three main spokes of how to prove Irving was a Holocaust denier.  First, would be to prove Irving had indeed knowingly falsified and manipulated history in his interpretations of it. Second, they needed to set up a reasonable definition of what a Holocaust denier was, first breaking it down into elements. It would then be their task to show evidence that Irving fit each of these elements in one way or another. Last, it would be important to prove how Irving was connected with what Lipstadt had named as extreme right-wing and Neo-Nazi groups in order to establish proof that what she had said about him manipulating history to serve his political views was true.

In order to prove that Irving had falsified history, the defense commissioned Professor Richard Evans to serve as an expert witness and write a report on the body of Irving's work. Evans and the other key witnesses, though engaged by the defense, would be paid by the hour, not by the results to help maintain the integrity of the reports.  In the case of Irving , the report should show after reviewing Irving’s written work, speeches and lectures whether or not he had accurately gathered and fully conveyed the contents of his sources. Evans, fluent in German and able to read obsolete German script, was chosen also because he is a specialist in modern German history. [60]

Unfamiliar with Irving’s work, Evans first began by looking up some of the reviews on Irving’s past books. He found that although some of the books like Hitler’s War, first published in 1977, received accolades for his military knowledge, it was noted that he often leaned toward painting Hitler in a positive light.  American historian John Lukacs commented that Hitler’s War was a “partial rehabilitation of Hitler”[61]. In fact, the same Hugh Trevor-Roper that Irving would submit as having written a favorable review of his work had also written in 1977 of Hitler’s War that he found a “consistent bias” in favor of Hitler and against his opponents[62].

When Evans then began his own investigation, as his book which chronicles the trial from the onset of his involvement shows, he found what he believes to be a great deal of evidence that Irving chose to manipulate and even falsify documentation.  He tells that time and again he found Irving leaving out key parts of information or hiding them in footnotes or endnotes if they did not support his thesis. In just one example he looks at the case of Daluege’s conference, which was a blatant propaganda exercise, designed to justify the brutal persecution of German Jews by the Nazis, Evans found that Irving had represented the propaganda as an “objective source” but he also had failed to cite Dualuege’s figures correctly[63].  Evans found that Irving could be what he considered especially deceptive when the direct subject was Hitler. Examples were abundant throughout his interpretation of the ‘Gobbels Diaries’. At one point, in reference to pages 273-74 of the diary where there is a mention among other things to a Town Hall meeting, Irving has altered the script in translation so that the mistranslation and omissions give the impression that Hitler merely “ordered the local police not to intervene against some unspecified anti-Jewish demonstrators in Munich.” However the truth of what Gobbels actually recorded was that Hitler had said that police forces should be withdrawn in case of demonstrations against Jews, so that the Jews would “feel the people’s fury” as expressed in the destruction of the Jewish property which had already occurred in Kassel and Dessau”[64]. Given the vast amount of like examples that Evans turned up, it was not inconceivable that the defense felt they could prove Lipstadt’s opinion that Irving had falsified history.

Next was the challenge of proving Irving fit the profile of a Holocaust denier. To do this they had to first define what a Holocaust denier typically believed.  Looking across the board at all the different views of deniers, there were four common denominators that seemed to be the same for virtually all of them. These were the four basic criteria that the defense then used to define the words Holocaust denier.  To begin with there was the question of the number of Jews killed in the war. Deniers refused to believed that the number was fewer than six million, typically agreeing on a few hundred thousand. Similar to or less than German civilians in Allied bombings.  Second, the denial that gas chambers were used at any time to kill large numbers of Jews.  Third, the idea that neither Hitler or Nazi leadership in general had a program of exterminating Europe’s Jews, they only had plans to deport them. Fourth, that what is known today as the Holocaust was a myth invented by the Allies in a propaganda campaign, which after the war was carried on by Jews who wished to gain political and financial support for Israel or for themselves. This of course meant that any evidence (i.e., gas chambers) was fabricated after the war[65].  With those criteria set, the job was then to match Irving to it.  To begin with they needed to look no farther than to the testimony he gave in 1988 at Zundel’s trial.  When asked about the thesis alleging the extermination of 6 million Jews during WWII being a direct result of an official German policy of extermination, he answered, “ I am not familiar with any documentary evidence of any such figure as 6 million… 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[66].  He was also quoted in 1993 on his “The Search for Truth in History” videotape as saying, “Probably 100,000 Jews died in Auschwitz, but not from gas chambers, they died from epidemics” [67].

The next evidence to gather would be his view on the gas chambers.  Indeed after the Zundel trial where Irving had been introduced to the Leuchter Report Irving did no longer try to downplay his feelings that the gas chambers were a myth. He often referred to its results in his lectures and speeches to back his claims that the “gas chambers” could not have been used for those purposes. Again on his “The Search for Truth in History” video he could be quoted as saying, “How can you gas millions of people with hydrogen cyanide gas and not leave the slightest trace of chemical residue in the walls of the gas chambers?” [68]. The Leuchter Report was a big clue into Irving’s denial of the gassings because the evidence of the report had long been discredited because of the improper way it had been conducted.  In its own way it had backed the thesis that the chambers in question were used for gassing. This is because the amount of cyanide used to kill humans would be some 22 times lower than to kill lice, therefore the low concentration should be suspicious to someone trying to prove that the chambers were in fact used for fumigating. Yet even with the debunking of the report Irving was fully into the theory that the gas chambers had not existed. In a speech given on March 5, 1990 he declared, “There are no gas chambers at Auschwitz, there are only dummies built by the Poles in the post war years, just as the Americans built the ones in Dachau…” This of course has been a proven fallacy given the eyewitness accounts from Nazis that actually saw the chambers being used at the various camps.

In relation to the claim that extermination of the Jews was in no way organized or systematic, he stated at Zundel’s trial, “I don’t think that there was any overall Reich policy to kill the Jews”[69].  Giving a reason, he said that it seemed puzzling that if the Nazis were supposed to have such a such a ruthless and deliberate plan of extermination, in Auschwitz and “other places of murder”, how is it that hundreds of thousands passed through those camps and survived? This of course was his tactic of clouding the facts with words yet again.  He knows Auschwitz was also a work camp, so to say that people survived from it is no surprise, however, note that instead of naming other camps he says “other places of murder”.  This is most likely because other camps such as Treblinka and Chelmno had very minimal survivors, but by not stating this he is manipulating the meaning. [70]

It was now just a matter of whether Irving had succumbed to the idea that the Allies originally peddled the whole Holocaust as propaganda that the Jews later propagated themselves to further their own ends.  In his second volume of his Churchill biography  Irving revealed that he believed that the “rumor” of the gas chambers originated when it was supplied to the British by Gerhard Riegner in 1942. Riegner was the director of the Geneva Office of the World Jewish Congress from 1939-45. Irving contends that the Foreign Office didn’t believe him, so any use of it by the British would have been with the knowledge that it was not true[71].  When Evans did more investigating he found that there had been no evidence that the British Political Warfare Executive had invented the story of the gas chambers, in fact they had they had received a report from people with contacts in Central Europe about them. He also found that it was not true that the Foreign Office didn’t believe that there were gassings going on but rather who was being gassed. Their doubts were about Poles being gassed[72].   Irving tried to explain away eyewitness accounts of Jews by saying they were due to “mass hysteria” or just plan lying.  In a much more serious accusation Irving implied that the State of Israel was using the Holocaust/gas chamber myth as a way to continue to soak Germany and America for money. He stated such a view in an interview in 1992, saying, “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 from American taxpayers, who put up with it because of the way Israelis or the Jews suffered”[73]. This line of thinking directly relates to the idea that Israel is being paid for the “alleged” number of Jews killed. That being the reason it is so high when actually these people mostly fled to Israel.  This, of course, is silly, but it would also be unlikely even to such a mindset given that the money given to the state of Israel was based on the number of survivors, in order to help them resettle.

Finally, the defense wanted to prove that Irving had close ties with members of extremist groups and organizations.  The most obvious was the Institute for Historical Review. A journal which has published much in the way of Holocaust denial, it features a board made up of members who Irving claimed “…held established academic qualifications”.  He failed to mention none held academic qualifications in history[74].  Though it is true Irving is neither on the board nor on the editorial board of its journal, yet he spoke at the ninth, tenth, eleventh and twelfth conferences. He also is a frequent writer for the journal and his web site would often preview his work there. He has even been described as “a good friend of the Institute”, in a 1993 edition of the journal[75].

A Closer Look

The case of Irving versus Lipstadt was a high stakes one, to say the least. Both sides, as well as Justice Gray, had tried to make it perfectly clear that it was not the Holocaust on trial but rather the work ethics of Irving according to Lipstadt. Still, the Media fed on this case. So, like it or not, the two respective sides had to have realized that a loss on the side of the defendant would have resulted in, at least to some degree, a questioning of the Holocaust.  “Expectations on all sides were high. Irving’s supporter’s clearly thought that this would be his opportunity to wipe the floor with the liberal Establishment and resurrect his flagging career as a writer and political activist”[76].

There was a lot of talk about how the two sides were squaring off.  Here Penguin and Lipstadt had a fine legal team to fall back on while Irving was representing himself. As Evans recalls it was not clear whether this was due to the fact that “…he could not afford the legal fees or whether he was so convinced that he knew more about the subjects under discussion than anyone else could ever do, that he simply did not trust a lawyer to put his case”[77].  Certainly some of Irving’s fellow Revisionists had an opinion on that. One of them, Michael A. Hoffman II said, “But his single handed performance in court was consistently magnificent …Under relentless assault for two months …Irving was seldom short of a credible retort or a telling bon mot and maintaining his composure and credibility throughout intensive cross-examination…Harvard’s Daniel Goldhagen …would have been reduced to shards in court had he faced the kind of legal firepower Irving stared down…” [78]. It seemed obvious to others, however that his courtroom tactics were not winning him any points. Even Eva Menasse, of the Frankfurter Allgemeine Zeitung said, “the biggest disappointment in this trial up to now has been the intelligence of David Irving ,”and, “It is painful to hear how Irving tries to bend every detail, even the tiniest, every translation, every word in his direction. In doing so he is not in any way convincing, not for a second”[79]

Opening arguments saw Irving setting up his case by carefully defining in his own terms what kind of damage the defendants had been ultimately responsible for. Mr. Rampton minced no words in his opening statement, coming right out and labeling Irving as a falsifier of history and, quite bluntly, a liar[80].  Though the case went immediately into full swing, the fact of the matter remained that often the material that was deemed too complicated for a jury ended up bogging down the pace of the trial.  Very often there would be roadblocks that sprung up in relation to the meaning of a word or phrase.  As an example, on day two Irving could not get past the word “systematic” to reach a suitable definition of the Holocaust[81].  It also became evident within a few days of the trial that it seemed a lot less like Lipstadt was on trial than it did that Irving was. By the defense having to back Lipstadt’s accusations it turned into a fine toothed look at the life and work of Irving.

When it came to the subjects that the media and supporters on both sides had been waiting for, it seemed that the pace slowed even more. The  subject of the Leuchter Report  got highly technical with the discussion of which crematorium was which and the misprinting of KG milligrams as opposed to KP, and so on. At one point even caused Justice Gray to admit, “I am completely lost”[82].    There were two revelations dealing with the Leucher Report that came to light, one being that Irving had initially suppressed the report when he feared that the findings of the work had not proven what he had hoped. The other was a much subtler discovery. At one point while discussing the Leuchter report Irving kept referring to “Us”, speaking of the report and how its results were getting to him. After a moment, Mr. Rampton asked whom “Us” referred to. Most grudgingly Irving was forced to admit his connection with the Institute of Historical Review, again. Along with Ernst Zundel[83]

The subject of Auschwitz and the gas chambers was yet another time when it seemed both sides were out to score points.  When asked about the reasons for why what were essentially fumigation rooms would have a peep hole and metal protection, Irving jumped at the answer that they were also ready to be used incase of Allied bombings and subsequent gas attacks.  However, when Mr. Rampton asked “ If this is an air raid shelter why would the doors open outwards? It only has a single door.” Irving seemed only able to repeat the question, then skipped back to the previous question[84].

Another tedious moment in the trial was the discussion of the Himmler phone call. The phone call is a bit of a controversy because it is the one that Himmler relayed that sent the message not to liquidate the trainload of Jews.  Made from outside Hitler’s bunker, it seemed very obvious to Irving that this order came straight from Hitler.  However, the discrepancy comes from the fact that Himmler did not meet with Hitler until an hour later. Irving’s continued argument was that he believed that the order had to come from Hitler because Himmler was in and out with Hitler all day. What it really boiled down to was that Irving’s only “proof” was that the call had been made from Hitler’s bunker.  Seemingly still unable to see any flaw in his own reasoning, Irving ends his statement on the subject obviously aimed at Mr. Rampton, saying, “…it would take a very perverse and obtuse person indeed to say there is no connection between the two facts”[85].  The significance of this exchange is not only in information that it conveyed but also in the way the two opposing councils interacted through it.  Mr. Rampton’s calm and collected demeanor in trying to point out the lack of logical proof to Irving’s argument was quite a contrast to the flustered and defensive Irving, who’s best tactic seemed to be to simply repeating what he had already said.  In fact, this exchange could easily be used as a representative of the attitudes, tactics and procedures of the trial in general.

Finally, the day for the judgement came. When Justice Gray handed down the final judgement  it was in quite a lengthy text form. It consisting of 350 pages, of which the judge read about sixty or so aloud to the court.  The Judgment included a few kudos for Irving. He said that concerning WWII Irving had “unparalleled” knowledge and a “remarkable” command of document.  However, he cited that Irving as a historian needed to specify for his readers whether he was speculating or reciting established facts, which he had failed to do. The Judge also stated that he felt the inevitable inference on a number of accounts was that this manipulation was deliberate.  Lastly, he pronounced that, beyond a doubt, Irving was a Holocaust denier. Justice Gray labeled him both anti-Semitic and racist, and said, “In my view the defendants have established that Irving has a political agenda. It is one which, it is legitimate to infer, disposes him, where he deems it necessary, to manipulate the historical record in order to make it conform to his political beliefs”[86].  So it was said. The defense had proven its case that Lipstadt was justified . Irving’s liable action was rejected.

Looking back over the whole case it is here that it can finally be asked if Irving got the fairest trial that is possible.  It is of the opinion of Serge Thion, a Revisionist, that Mr. Rampton and Justice Gray were in league with one another to try and trap Irving throughout the trial with verbal snares that no one could have gotten out of.  A Revisionist colleague of his, Michael A. Hoffman, felt that the media played a foul role in the affair, somehow lending power to Lipstadt by covering her in a favorable light while painting Irving as the villain[87]. This seemingly wooed the judgement to her side for fear of offending the public.  But what really happened?  Yes, it is true that Irving defended himself against a team of high-powered lawyers.  However, Irving was the one who chose to go about this action in this manner. He chose to defend himself.  Was he given a fair chance in the courtroom setting?  His complaints would probably stem from the overwhelming amount of material that he had to wade through in order to get through the proceedings each day.  We see this from the second day when he comments on the “5000 pages from the Van Pelt report” he hasn’t been able to get through[88]. Yet again, I would have to cite his determination to do it on his own.  In relation to this, I also think that both the Judge and the defense were more than flexible with not only time lines, bending to Irving's wishes about the order the trial would go in. Not to mention that they both seemed to have a lot of patience with Irving, who not only did not know legal procedures well but time and again tried their limits with what could only be explained as his paranoid fear of being trapped into any answer on basically anything. On more than one occasion Justice Gray interrupted the flow of questioning in order to get a better picture of what Irving was trying to convey, and take in all the data. Irving was notably disappointed that he did not have a chance to cross-examine Ms. Lipstadt, which could amount to his other complaint.  Yet, with the line that the defense was taking, it really did not matter that Lipstadt did not take the stand, she would have been superfluous in a trial that already needed to be slightly reigned in. Giving it a sincere overlook I cannot find a true reason why Irving did not have a fair chance in his legal venture. He may have bitten off more than he could chew, but for that there is no one to blame but himself.

The Wrap up

When the self titled “Revisionists” got wind of the verdict, they could not have had more to say.  A.S. Marques said, “Nevertheless I must say I expected a partial vindication of Irving’s position since clear instances of liable existed. I was impressed by his courtroom performance and his mastery of the subjects under examination”[89].  Fellow Revisionist, Michael A. Hoffman chimed in with, “Gray’s verdict in the Lipstadt-Irving case was predictable given the display of naked Jewish power during the trial.”[90]. They were not the only ones surprised by the verdict.  It seems that Irving himself was not quite ready for what Justice Gray had to say about him.  But Irving didn’t let that stop him.  He was soon the hit of all the talk and news radio shows. He knew that this was his chance to shine, so he needed to take advantage of every opportunity that he could.  In fact, he went on so many that the Board of Deputies of British Jews lodged an official complaint with the BBC.  However, he was up to his old tricks again. When interviewed on channel 4’s 7 o’clock news he told the anchor that the Judge had described him as “Britain’s preeminent military historian”[91]. This is, of course, what Irving had stretched out of the Judge merely saying that there was much to be commended in Irving as a military historian. Still, what could be expected to happen after this trial? Irving still wants to rattle a few cages and almost as a side note, wants to get his views out there as well. Since the trial he has been busy getting his new book ready, the second volume on Churchill.  Anyone who has been to his web site knows his commitment to promoting the “truth” is still a top priority for him, as well as asking for donations due to the “financial damage” that Lipstadt and world Jewry have inflicted upon him.

As for Lipstadt, she finally broke her silence about the trial, and at a press conference declared herself fully vindicated.  Many reporters and historians had criticized Lipstadt during the trial for participating in it because they felt that it was giving Irving too much of a forum.  It seems that in doing so they had neglected to recall two factors in all this trial mess. One was that Lipstadt had always been the one who had contended that it would be better to never appear in a forum where you could be possibly giving them a way to express their view.  The second was that Lipstadt had no choice but to take on Irving in court.  The alternative would have been to bow to his wishes and withdraw the book .  Lipstadt did what she felt was necessary . In a post trial interview she relayed how “On the first day of the trial, as I’m walking in, a small woman with a number on her arm throws her arms around me and says ‘We’re counting on you.’ I knew I would be representing survivors still alive today,”[92]. So it seems that the trial that wasn’t supposed to be about the Holocaust, actually ended up as a victory for precisely that. Of course, Irving will probably have his own take on that notion.   

Bibliography

1. Evans, Richard J. Lying About Hitler. New York: Basic Books, 2001.

2. Hoffman, Michael. David Irving and the Verdict of History. Revisionists on Irving.  http://www.abbc.com/aaargh/fran/polpen/dirving/rev000220.html

3. Irving verses Lipstadt, Google.com internet source.  Day1,pp.1-103.

4. Irving verses Lipstadt, Google.com internet source. Day 2, pp.104-292.

5. Irving verses Lipstadt, Google.com internet source. Day 3, pp. 1-204.

6. Irving verses Lipstadt, Google.com internet source. Day 4, pp.1-207.

7. Irving verses Lipstadt, Google.com internet source. Day 7, pp.1-199.

8. Irving verses Lipstadt, Google.com internet source. Day 8, pp.1-191.

9. Irving verses Lipstadt, Google.com internet source. Day 12,pp.1-154.

10.  Irving verses Lipstadt, Google.com internet source. Day 13, pp.1-186.

11.  Irving verses Lipstadt, Google.com internet source. Day16, pp.1-176.

12.  Lipstadt, Deborah. Denying the Holocaust: The Growing Assault on Truth and Memory. New York: Penguin Books Ltd.,1994.

13.  Marques, A.S., The Dogma of the 20th Century. Revisionists on Irving. 
http://www.abbc.com/aaargh/fran/polpen/driving/rev000220.html

14.  Wohlgelernter, Elli. No Denying Her Now. The Jerusalem Post : Internet Ed., June 6, 2000. 
http://www.focal.org/online/JerusPost/050600.html


Notes

[1] “Richard Rampton’s 2000 Testimony at the Irving/Lipstadt Trial,” on Irving vs. Lipstadt & Penguin Books. Holocaust Denial Libel…website
http://www2.prestel.co.uk/littleton/irving-v-lipstadt.htm :
“Holocaust Denial,”, (day1),99.

[2] Deborah Lipstadt, Denying the Holocaust: The Growing Assault on Truth and Memory, (Penguin Books Ltd,1993),111.

[3] Lipstadt, (1993), 161-163.

[4] Lipstadt, (1993), 161-163.

[5] Lipstadt, (1993), 14.

[6] Lipstadt, (1993), 111.

[7] Lipstadt, (1993),179.

[8] Lipstadt, (1993), 181.

[9] “David Irving’s 1996 Statement of Claim” on Irving vs Lipstadt & Penguin Books . Holocaust Denial Libel… website
http://www.fpp.co.uk/Legal/Penguin/LipstadtClaim.html : “International Campaign for Real History,”, (9/5), 1.

[10] “David Irving’s 1996 Statement of claim,”  7.

[11] Richard Evans, Lying About Hitler, (Basic Books,2001), 191.

[12] “David Irving’s 1996 Statement of Claim,” 7.

[13] Evans, (2001), 192-193.

[14] Michael Hoffman, David Irving and the verdict of History, Revisionists on Irving  website
http://www.abbc.com/aaargh/fran/polpen/driving/rev000220.html .

[15] “Deborah Lipstadt’s 1996 Defence of the Second Defendant” on Irving vs Lipstadt & Penguin Books. Holocaust Denial Libel… website
http://www.fpp.co.uk/Legal/Penguin/Defence/1.html : “International campaign for Real History,”, 2.

[16] Evans, (2001), 192.

[17] Evans, (2001), 119.

[18] “David Irving’s 1996 Statement of Claim”, 7.

[19] “David Irving’s 2000 Testimony at the Irving/Lipstadt Trail,” on Irving vs Lipstadt & Penguin Books . Holocaust Denial Libel… website
http://www2.prestel.co.uk/littleton/irving-v-lipstadt.htm : “Holocaust Denial,”, (day1), 24-25.

[20] “David Irving’s 2000 Testimony,” (day2),155.

[21] “David Irving’s 2000 Testimony,” (day 2), 158.

[22] “David Irving’s 2000 Testimony,” (day 1), 16.

[23] “David Irving’s 2000Testimony,” (day1), 19.

[24] “David Irving’s 2000 Testimony,” (day1), 17.

[25] “David Irving’s 2000 Testimony,” (day2), 15-16.

[26] “David Irving’s 2000Testimony,” (day2), 129.

[27] Evans, (2001), 19.

[28] “David Irving’s 2000Testimony,” (day1), 30.

[29] “David Irving’s 2000 Testimony,” (day1), 13.

[30] Lipstadt, (1993), 180.

[31] “David Irving’s 2000 Testimony,” (day1), 72.

[32] “David Irving’s 2000Testimony,” (day1), 72.

[33] “David Irving’s 2000 Testimony,” (day1), 77.

[34] “David Irving’s 2000Testimony,” (day1), 76.

[35] “CameronWatt’s Testimony at 2000 Irving/Lipstadt Trial,” on Irving vs Lipstadt & Penguin Books . Holocaust Denial Libel… website
http://www2.prestel.co.uk/littleton/irving-v-Lipstadt.htm : “Holocaust Denial,”, (day7),41.

[36] “Sir John Keegen’s Testimony at 2000 Irving/Lipstadt Trial,” on Irving vs Lipstadt & Penguin Books . Holocaust Denial Libel… website
http://www2.prestel.co.uk/littleton/irving-v-Lipstadt.htm : “Holocaust Denial,”, (day16),11.

[37] “David Irving’s 2000 Testimony,” (day1), 12.

[38] “David Irving’s 2000 Testimony,” (day2), 162.

[39] “David Irving’s 2000 Testimony,” (day2), 107.

[40] “David Irving’s 2000 Testimony,” (day2), 203-205.

[41] “David Irving’s 2000 Testimony,” (day2), 207.

[42] “David Irving’s 2000Testimony,” (day2), 206.

[43] “David Irving’s 1996 Reply to the Defense of Second Defendant” on Irving vs. Lipstadt & Penguin Books. Holocaust Denial Libel… website
http://www.fpp.co.uk/Legal/Penguin/Defence/1.html : “International campaign for Real History,”,8.

[44] “David Irving’s 2000Testimony,” (day2),208-209.

[45] “David Irving’s 2000 Testimony,” (day2), 210-212.

[46] ‘Kevin MacDonald’s Testimony at 2000 Irving/Lipstadt Trial,” on Irving vs. Lipstadt & Penguin Books. Holocaust Denial Libel… website
http://www2.prestel.co.uk/littleton/irving-v-Lipstadt.htm : “Holocaust Denial,”, (day12), 21.

[47] “David Irving’s 2000Testimony,” (day2), 178-181.

[48] “David Irving’s 2000Testimony,” (day2), 238.

[49] “David Irving’s 2000 Testimony,” (day2), 231.

[50] “David Irving’s 2000 Testimony,” (day2), 243.

[51] “David Irving’s 2000 Testimony,” (day2), 233.

[52] “David Irving’s 2000Testimony,”(day8), 91-93.

[53] “David Irving’s 2000 Testimony,” (day8), 108-110.

[54] “David Irving’s 2000Testimony,” (day8), 164-165.

[55] “David Irving’s 2000Testimony,” (day8), 179.

[56] “David Irving’s 2000 Testimony,” (day2), 193.

[57] “David Irving’s 2000 Testimony,” (day2), 264.

[58] “David Irving’s 2000Testimony,” (day4), 34.

[59] “David Irving’s 2000Testimony,” (day1), 21.

[60] Evans, (2001), 7-8.

[61] Evans, (2001), 43.

[62] Evans, (200), 41.

[63] Evans, (2001), 52.

[64] Evans, (2001), 54.

[65] Evans, (2001), 110.

[66] “David Irving’s 1988 Testimony at the Trial of Ernst Zundel,” on Irving’s website
http://www.fpp.co.uk: “Documents on Auschwitz controversy,”, 30, 82-83,138.

[67] Evans, (2001), 116.

[68] Evans, (2001), 123.

[69] Evans, (2001), 127.

[70] Evans, (2001), 127.

[71] Evans, (2001), 129.

[72] Evans, (2001), 131.

[73] Evans, (2001), 135.

[74] Evans, (2001), 141.

[75] Evans, (2001), 143.

[76] Evans, (2001), 197.

[77] Evans, (2001), 192.

[78] Michael Hoffman, David Irving and the verdict of History, Revisionists on Irving website
http://www.abbc.com/aaargh/fran/polpen/driving/rev000220.html.

[79] Evans, (2001), 200.

[80] “Richard Rampton’s 2000 Testimony,” (day1), 88.

[81] “David Irving’s 2000 Testimony,” (day2), 219.

[82] “David Irving’s 2000 Testimony,”(day8), 70.

[83] “David Irving’s 2000Testimony,”(day8), 64.

[84] “David Irving’s 2000Testimony,” (day8), 85-88.

[85] “David Irving’s 2000Testimony,” (day8), 285.

[86] Evans, (2001), 226.

[87] Michael Hoffman, David Irving and the verdict of History, Revisionists on Irving website
http://www.abbc.com/aaargh/fran/polpen/driving/rev000220.html.

[88] “David Irving’s 2000Testimony,” (day2), 115.

[89] A.S. Marques, The Dogma of the20th Century, Revisionists on Irving website
http://www.abbc.com/aaargh/fran/polpen/driving/rev000220.html.

[90] Michael Hoffman, David Irving and the verdict of History, Revisionists on Irving website
http://www.abbc.com/aaargh/fran/polpen/driving/rev000220.html.

[91] Evans, (2001), 233.

[92] Elli Wohlgelernter, No Denying Her Now, (The Jerusalem Post: Internet Ed., June 6, 2000)
http://www.focal.org/online/JerusPost?050600.html.


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