THE Plaintiff is David Irving, a British author of about thirty works of history, published by respected mainstream UK and international publishers since 1963, and accorded the widest attention in the popular and serious press. He has been called one of the most widely read historians in the English language. His books are widely quoted as references by others including HM Government's official historians. Until about 1993 he had access to every country in the world and their archives, including the former communist countries.

Disaffected by his findings, various British and international organisations, primarily of the Jewish communities, began in the 1970s to make overt and covert attempts to destroy the plaintiff's career by robbing him and his works of their legitimacy. They also secretly sought to have him physically barred from other countries and their archives. The Second Defendant [Prof Lipstadt] made herself the willing executioner of this campaign, accepting a fee to insert Mr Irving's name and works into a manuscript that she had written analysing the people whom she calls the "Holocaust deniers", an odious phrase which she herself claims to have coined; until thus instructed by those paying her, Prof Lipstadt had not even mentioned Mr Irving in her completed book. The First Defendants published the work.

The work attacks the Plaintiff both ad hominem and as an historian, depicting him as a neo Nazi who has knowingly distorted and manipulated the historical record in pursuit of a political agenda.

The collateral attempt by the Defendants to blacken further the name of the Plaintiff, while risky in itself, is one which is permitted for the purposes of mitigation of damages only, and can be dealt with readily by the normal procedures of court.

It is appears however, from the Defendants' pleadings, that they:

1. intend to offer no defence on libels which they, but not the Plaintiff, regard as lesser (e.g., the allegation that the Plaintiff consorted with Louis Farrakhan and the Hizbollah terrorist leaders, and that he deliberately cheated a colleague out of the credit for finding the Goebbels Diaries in the KGB archives in Moscow);
2. intend to concentrate their courtroom effort primarily on restating in exhaustive, tedious and confusing detail the historical record, as it is known today, on the persecution of the Jews by the Nazis and their collaborators.

What is known today (most of which is not and has never been disputed by the Plaintiff) is not however what is at issue in this part of these proceedings: the issue here is solely whether the Defendants (upon whom the burden of proving their pleaded defence of justification lies) can show that the Plaintiff manipulated historical evidence i.e. what matters is what the Plaintiff knew at the time, yet wilfully and perversely disregarded in pursuit of his alleged agenda.

The Plaintiff will resist any attempt to use the court room to refight World War II, or to rewrite the history of that war. The issues are those pleaded in the statement of claim, which is already wide enough.