Witness Statement I am DAVID JOHN CAWDELL IRVING, a professional historian of British nationality, of 81 Duke Street, London, W1M 5DJ. 2. I was born in Hutton, Essex on March 24, 1938. My mother was a Slade School of Art commercial illustrator (children's books, The Radio Times, Nursery World, etc), my father a naval officer whose service spanned two world wars including the Battle of Jutland (1916) and the North Russian convoy actions. My twin brother is an ex RAF officer, now a civil servant; my older sister, now retired, was public relations officer to a Tory Cabinet minister; my older brother was a career RAF officer (wing commander), later a Regional Commissioner in Civil Defence, and is now a senior councillor (Liberal-Democrat) on Wiltshire County Council. 3. My mother was very poor. I was awarded a free place at Brentwood School and educated there 1949-56 to "A" Level and Scholarship Level standard, attaining seven O-levels and three A-levels, to which I added four more A-levels in the next year at Imperial College, University of London (a transfer course from the arts to the sciences, for which I won a one-year ICI scholarship), and three more A-levels required by University College as their entry requirement. Since I was unable to pay tuition and boarding fees at the university from 1958-9 I worked my way, with a manual labouring job at John Laing Ltd. 4. On leaving Imperial College in 1959 I volunteered for a three-year short service commission with the Royal Air Force; I passed the entrance examinations, but was rejected on medical grounds. 5. To perfect my knowledge of spoken German in 1960 I worked as a steelworker in the Ruhr in Germany; to perfect my spoken Spanish, I worked with the US air force Strategic Air Command on a base in Spain; while attending University College, studying political science and economics, in 1961 I started a career as a freelance author, writing a series of articles for the German illustrated magazine Neue Illustrierte. Simultaneously I started research at my own expense into the history of the Allied bombing raid on Dresden of February 13-14, 1945 about which I had now heard for the first time. 6. As a product of this research I produced the book UND DEUTSCHLANDS STÄDTE STARBEN NICHT (Germany's cities did not perish) published in German by a major Swiss publishing house; and I wrote the book THE DESTRUCTION OF DRESDEN, which was published on April 30, 1963 by William Kimber Ltd and since then by the leading publishing houses of many countries around the world and in many languages. The latter book earned two private handwritten commendations in letters to me from Marshal of the Royal Air Force Sir Arthur Harris. I published an updated edition of this book in 1996, under the title APOCALYPSE 1945: THE DESTRUCTION OF DRESDEN. 7. Immediately following publication of THE DESTRUCTION OF DRESDEN, a short-lived campaign of harassment began, directed by bodies close to the Board of Deputies of British Jews. A Mr Gerald Gable and two accomplices were caught red-handed by police while burgling my North London apartment on November 27, 1963, and subsequently convicted for that and for using a stolen GPO identity card. Gable has spent the last thirty-six years smearing me in his publication Searchlight; several of his products are among items introduced by the Defendants in their discovery. While Gable and his accomplices were awaiting trial, there was a failed attempt by a Mr Franz Davis to entrap me in committing an act of terrorism, which I reported at once to Special Branch. 8. Writing career: since 1961 I have published thirty or more works of history and biography (some of them written and published only in German). The Widener library at Harvard University lists as of August 8 this year [1998] forty-seven of my books as being available in their shelves. Most of my books have been published and republished by world's leading publishers, with translations into many languages. 9. No book that I have written has ever been banned by any country on any ground whatsoever: not by the former communist powers; not by Germany's notorious "Office for the Protection of Children from Dangerous Writings"; not even by Canada Customs, which exercises a startling degree of censorship. 10. My books have received high praise from established academic, official, and government historians in every country in which they have been published, including (in the UK): Professor Hugh Trevor Roper (now Lord Dacre); A J P Taylor; Professor M R D Foot; Captain Stephen Roskill; Professor Norman Stone; Professor Donald Cameron Watt. In recent years each new book of mine has received first-place review status in major Sunday newspapers -- GOEBBELS. MASTERMIND OF THE THIRD REICH (1996) and NUREMBERG, THE LAST BATTLE (1997) were given the front page of The Sunday Times book review sections, no mean achievement for works of "self-publishing", as my less benevolent critics describe my works. 11. My works are also cited by other historians around the world, and by the official historians like the late Professor Sir F H Hinsley. 12. Recognised experts have also praised my writings. Difficult though the subject of German uranium research in the war was, my book on that topic received a glowing half-page review from no less than the physicist Professor Werner Heisenberg (Nobel-prizewinning discoverer of The Heisenberg Principle) in the Frankfurter Allgemeine Zeitung; I found that Lieutenant-General Leslie Groves, chief of the US army's Manhattan Project, had also reviewed this book THE GERMAN ATOMIC BOMB magnificently in a manuscript in his private papers. 13. I shall introduce many of these printed reviews during the trial of this action; here I will quote only what John Keegan, Defence Correspondent of The Daily Telegraph, has written: "Two books in English stand out from the vast literature of the Second World War: Chester Wilmot's The Struggle for Europe, published in 1952, and David Irving's HITLER'S WAR, which appeared three years ago." The latter book was as recently as 1997 a best-seller in Poland, of all countries, leading to wry comments from Poland's neighbour, Germany, where, as the Frankfurter Allgemeine Zeitung observed, I am now banned from setting foot. 14. Russian editions of my books were sold in the former Soviet Union; I researched there twice during the Soviet regime, and in official Hungarian and East German communist archives in the 1970s and 1980s. 15. When the German edition of HITLER'S WAR was published by the prestigious Ullstein publishing house in 1975, I had to halt its further sale within a few days because I discovered that their chief editor Wolf Jobst Siedler had made unlicensed changes to my text. (Notwithstanding which, Siedler, who latterly published Daniel Goldhagen's much-discussed work on Hitler's Willing Executioners, and I have remained mutual admirers, and he recently expressed positive written interest in publishing my projected biography of Heinrich Himmler, despite, as he acknowledged, the hostile campaign now running against my name). 16. In about 1975 Adolf Hitler's private secretary the late Christa Schroeder, an elderly lady living in Munich whom I had interviewed on very many occasions, gave me a small pencil sketch, a self portrait of Hitler which she had retrieved from his desk at Berchtesgaden on his instructions in the last days of the war. It is probably a very valuable object, and I kept it locked in a case. It was never displayed over my desk. 17. HITLER'S WAR was published in 1977. On June 9, 1977 it was the object of a famous David Frost Programme on television (in which Frost produced one Dr Gerald Fleming as his champion against me). Later that year the book was subjected to an extraordinary critique by the late Professor Martin Broszat, the doyen of the German post-war historians, director of the Institut für Zeitgeschichte in Munich. I had researched archives at that institute since 1964. 18. Underlying this dispute were personal differences, which are no concern of the court. They concerned my earlier personal, but quite proper friendship, with a research assistant whom Professor Broszat later married. He vented his pique in an ill-judged, unfair, and unbalanced 54-page swipe at my book, in the Vierteljahrshefte für Zeitgeschichte, the quarterly journal of his institute, to which I have made a full response in my Reply to the Defences served in this action. 19. Broszat's article was otherwise provoked by the entirely new research prospects and hypotheses which my Hitler biography ventilated. Historians of right and left have quite rightly acknowledged that the Broszat article triggered (a) the Historikerstreit, the famous ongoing twenty-year dispute, still unresolved, between European and American historians over whether the Holocaust was a tragedy/atrocity waiting to happen, or whether it was deliberately ordered from above; and (b) all of the "academic" research into the Holocaust, which until then had been fragmentary and dilettantish in the extreme. Apart from Gerald Reitlinger's The Final Solution, they now recognise, there was before HITLER'S WAR no research whatever into the Holocaust. 20. I consider myself to be an expert on the careers of the principal Nazi leaders, including specifically Adolf Hitler, Hermann Göring, and Dr Joseph Goebbels; the archival and documentary evidence for assertions about those careers, and the part they played in the Third Reich; the current state of research into the German and other wartime persecution and liquidation of the European Jewish communities; the conflicting views which have emerged on that history, including but not limited to the so-called Historikerstreit; further, on the perceived role of the Jewish people in directing the Soviet revolution, managing the Soviet police state, and running the satellite nations in the Soviet empire until its recent collapse, with special reference to their role in the ÁVH (Álamvedelmy Hatosag), Hungarian secret police, before the Budapest Uprising of 1956, on which I published a well-received history, partially based on Central Intelligence Agency materials, in 1981. 21. I have also become perforce an expert as a writer, international lecturer, and publisher on the problems of establishing, publishing, printing, and disseminating controversial and often distasteful minority views which run counter to the prevailing or received opinions of the majority; and on the methods used by specific international organisations to attack the fundamental, and in many countries including Canada and the Commonwealth of Australia, chartered, human rights of individuals including the rights to freedom of speech, freedom of association, and freedom of thought. My political opinions: 22. As the Defendants have chosen to refer to these and wrongly categorise them, I shall set them out: (a) I belong to no Political Party or organisation, of either right or left, and never have. I believe that my parents, who died in 1965 and 1967, were Conservative until the 1945 Labour landslide. My father stood as a Labour candidate at Bassetlaw; at school I stood as the Labour candidate in a mock election in about 1954. I have rarely if ever voted in general elections, having often been overseas at the time, and since I regarded Westminster as being unshakeably in Conservative hands. I have regarded myself as a Conservative for the last two or three decades. At the last election I entered the polling station intending to vote Conservative, but then found that Sir James Goldsmith's referendum party was standing Sir Alan Walters, with whom I had become acquainted after he attended a dinner lecture I delivered in Washington two years ago, so I gave him my vote instead. (b) I regard myself as a laissez-faire liberal with a strong personal compassion in the fates and fortunes of the individual against the interests of the State or community. Notwithstanding my own origins as the scion of a family of officers and gentlemen, I incline to put the interests of the working class above those of the higher classes, in the certain belief that a secure and contented working class is the foundation of a solid and productive economy. I do not look down on any section of humanity -- either coloured immigrants (I have employed them regularly), or females (my five children are all daughters), or the mentally or physically disabled. I admit to having little patience with smokers and none at all with drug abusers. I have a clean criminal record and driving licence, I do not smoke, I am a law abiding citizen. This is not to say that I have applauded the uncontrolled tide of Commonwealth immigration. Like most fellow-countrymen of my background and vintage, I regret the Passing of the Old England which our armies and air forces fought to defend in two world wars. We girded ourselves to fight off one invasion; then sighed, relaxed, and allowed the other without a murmur. I deprecate too that it has become politically incorrect to speak aloud of our regrets at that Passing; and I regret more still that laws have been passed to make the moderate expression of such public regrets illegal. By allowing this mass immigration into this country we have failed to learn from other countries' misfortunes. We have shown scant respect for the achievements of our fathers and their forefathers. It has been a tragedy for us, and a tragedy for the immigrants too. I blame generations of abdicating politicians for this British national tragedy. While my family is descended, I am told, from Robert the Bruce, I fear that most of our post-war politicians' ancestors were sired by æthelred the Unready. Summary thus far: 23. My reputation as an historian rests entirely on my published output of books, and to a lesser degree on my participation in radio and television broadcasts in this country and overseas. The documentary evidence of that reputation is assembled in 19 ring binders, some seven linear feet, of press notices, all of which files have been introduced into and listed in my Discovery, but none of which so far the Defendants have troubled to inspect. 24. The contents of those folders can be summarised as follows: famous and respected historians saying nice things about my research and the readability of my books where it was not risky to do so; hedging their bets where it seemed more prudent; and joining the baying crowd of critics when it might seem advantageous to them to do so. I have no problem with that. That is part of the rough and tumble of being a published author. Where the article is not motivated by its author's personal animus or malice aforethought, by vested interests, or by a conspiracy to defame and destroy, I have no complaint. The conspiracy to destroy and defame: 25. In about 1992 I began to suspect that there was a concealed conspiracy to defame me abroad, and to destroy my reputation and thereby injure my professional career. It has become possible only in retrospect to piece together how these aims were achieved or partially achieved. Since this material is relevant to the issues before the court, I have introduced it in evidence. 26. Disturbed by what was happening, I obtained access, by instructing firms of reputable solicitors in Canada, Germany, Australia, and elsewhere, and by proper use of legal instruments (e.g. in Canada, the Access to Information Act) to previously secret documents about me which astonished me. Sometimes they even revealed academics whom I had trusted and with whom I had co-operated as treacherous characters who simultaneously but secretly sought to achieve the suppression of my views, the failure of my books, the silencing of my lecture tours, my public humiliation, expulsion from countries, exclusion from archives, and even imprisonment. 27. Although a best-selling, high-profile professional historian, I have been subjected to a campaign of boycotting, hounding, persecution and de facto punishment by organisations based in the U.K., Australia, and elsewhere overseas, designed to harass, vilify, threaten, assault, silence, and permanently commercially ruin me. I am aware of other historians who have similarly suffered. I noticed that the phrase "Holocaust denier" came into the common currency of the published media. I was physically and violently attacked in the street and in a restaurant in 1992. My family and I have been subjected to an organised barrage of obscene, violent, and abusive telephone calls. The Board of Deputies of British Jews and its satellite and related organisations staged violent street demonstrations, for which they publicly took the credit, at my place of residence and at venues where I was to speak, which required heavy police reinforcements to protect. 28. These opponents have furthered their aims by clandestine means, furnishing perjured statements about me to foreign governments and starting whispering campaigns against me -- spreading for example the odious tidings that I had supplied the trigger mechanism used for the Oklahoma City bomb in 1995; they have applied violent and/or psychological pressure to my reputable publishers (like Macmillan Ltd in 1989 and again in 1991 and 1992) to violate fair contracts freely entered into, and they even forced them on one occasion (The Sunday Times, London in July 1992) to refuse to pay moneys owing to me under such a contract. Among their methods of intimidation, which bear a close comparison with the methods used by the Nazis in the 1930s, these organisations have started campaigns of book-burning and window-smashing against bookstores in the U.K., and they have blackmailed printers in Britain and Denmark, to my knowledge, to abandon production plans for books written by me. 29. The Work Complained of, Denying the Holocaust, written and published by the Defendants, was the principal instrument deployed in the campaign to destroy me. The author, the Second Defendant, was financed and promoted by the same organisations as lay at the root of the international campaign, and funded with copies of the same smear materials that these organisations had concocted against me. 30. The Second Defendant, who boasts of having personally coined the otherwise meaningless phrase "Holocaust denier," made no attempt to inquire of me whether any of the allegations were true. Despite service of my Writ on her, which put her on notice that the contents are held to be defamatory and untrue, and even more so after service of the Reply to her defence, which confirmed that there was no basis for her allegations, she and her publishers have continued to peddle the work unchanged in this country and in countries around the world. It is required reading in several establishments of learning in the USA.