I shall invite the Court to hear expert evidence on the relationship between the world's Jewish communities and the rest of us, given by a professor of sociology at a leading American university who has published a number of book-length studies on the topic.

The Jewish community, their fame and fortunes, play a central role in these proceedings. It will not surprise the Court, I suppose, that among the allegations leveled against me by the Defendants and by their Experts is the adjective of "anti-Semitic."

This adjective is both the most odious and the most overworked of epithets. Almost invariably, it is wielded by members or representatives of that community to denigrate those outside their community in whom they find disfavour.

It does not matter that the person whom they label as anti-Semitic has conducted himself towards that community in an irreproachable manner until then; it does not matter that he has shown them the same favours that he has shown to others; it does not seem to matter either that that same community who thus labels him or her, has conducted against him an international campaign of the most questionable character in an attempt to destroy his legitimacy, the economic existence upon which he and his family depends.

If he defends himself against these attacks, he is sooner or later bound to be described as anti-Semitic

It has become a ritual. No doubt the English people, who in 1940 found it necessary to defend themselves against the Germans, would by the same token earn the title of anti-German. Is a person who defends himself, ultimately and wearily and after turning the other cheek for twenty or thirty years, ipso facto no better than the most incorrigible kind of ingrained anti-Semite with whom we are probably all familiar? I submit that he is not

This Court will find that like most Englishmen, I have had dealings with both English and foreign Jews throughout my professional life.

There were to my knowledge no pupils of the Jewish faith to my at the minor Essex Public School that I (in common with our present Home Secretary) attended from 1947 to 1956; I was surprised when I recently heard the suggestion that there had been.

I encountered many Jewish students when I attended London University however -- I would like to commemorate here the name of my flat mate at Imperial College, Mike Gorb, who died tragically in an mountaineering accident; I regarded as a good friend another senior student, Jon Bloc. True, there was one student, a Mr. Peter L., who began agitating against me for the views that I propounded while at University, views I can no longer remember; and I have to confess that I found his agitation both perplexing and irritating, as it seemed rather petty and spiteful at the time.

As my own Witness Statement recalls, at the time of the Anglo-Israeli--French "police action" in Suez in 1956, I joined student demonstrations on behalf of the Israelis, though for the life of me I now cannot remember why.

When my first book was published, THE DESTRUCTION OF DRESDEN, in 1963, I became uncomfortably aware that I had somehow offended the Jewish community. I did not at the time realise why and I do not fully realise why even today. Whatever the reason, their journalists were in the spearhead of the attack on me. As other books appeared, this polarisation among the English critics became more pronounced. I remember the name of Arthur Pottersman, writing for a tabloid newspaper -- the Daily Sketch -- as being one of the few vicious critics, not of the Dresden book but of my person.

My publisher, Mr. William Kimber, to whom I have earlier referred, recommended to me the services of his lawyer, Mr. Michael Rubinstein, a name with which the older members of this Court may perhaps be familiar. Mr. Kimber said to me in his drawling, affable voice, "You will like Michael. He is Jewish, but a very Christian kind of a Jew -- like Jesus Christ."

It is the kind of inexplicable sentence that one remembers even now nearly forty years on down the road of life. I found Michael an enormously capable, energetic and likeable person -- indeed very English, his advice always sound, and he stood by me as my Legal Adviser for the next two decades. He had a rhinoceros hide, as I remarked once in my diary -- a remark seized upon by the Defendants as evidence of my anti-Semitism!

I also formed a long-term friendship, which exists to this day, with well-known writers like the American David Kahn, an expert on code breaking. Being an author dealing with American and British publishers I frequently came into contact with the Jewish members of the publishing profession.

The editor of HITLER'S WAR for the Viking Press Inc. was Stan Hochman, who became, as the correspondence and for all I know also the diaries show, a good friend; Peter Israel, who purchased UPRISING, my book on the 1956 Hungarian uprising, was editorial director at Putnam's. And so on.

The Discovery documents show that there was also some kind of relationship between myself and our own George Weidenfeld which was the usual kind of love/hate relationship between authors and publishers. George published several of my books, include my biographies of top Nazis like Field Marshal Erhard MILCH and Field Marshal Erwin ROMMEL, and I do not believe that he made a loss on those operations; behind my back, however, I learned that he made unhelpful remarks about me and I had occasion to write him one or two terse letters about that. But I believe that we are still friends, and my relations with the present Managing Director of Weidenfeld & Nicholson are of the very best.

Those however are all individuals.

Even as I speak of Weidenfeld, it reminds that during the 1960s and 1970s I became vaguely aware of forces gathering to oppose me. George had originally bought the rights to publish my biography of ADOLF HITLER. At some stage Weidenfeld's repudiated the contract. Publishers can always find an excuse to do so if they want, and I was not unhappy as it gave me the chance to offer it to an equally prestigious Publishing House, Messrs. Hodder & Stoughton, for an even larger fee.

At the Frankfurt book fair on October 13, 1973 -- my diary entry relates the whole of this -- George Weidenfeld sat next to me at dinner and lamented, after a few cocktails, his mistake in "tearing up" the contract for HITLER'S WAR; when I asked him why he had done so, he explained, shifting uneasily, "I had to do so, I came under pressure from three Embassies. One of them was a Nato power," which I took to be Germany, "one of them was France and the other was Israel."

It is right that I should state here, and the correspondence shows, that he later denied having said this, but I took a very detailed diary note that same night, which is in my Discovery, the bundle of which (it is marked "GLOBAL") we shall glance at briefly over the next few days, if your Lordship pleases.

So it became gradually evident -- and I have to emphasise that I cannot pin down any particular year in which I finally realised that I was being victimised by this hidden campaign -- that I was the target of a hidden international attempt to exclude me, if it could be done, from publishing further works of history.

It did not affect my attitude towards the Jews in the way that perhaps people might have expected it to. I did not go on the stump, up and down the land, vituperating against them.

I merely made a mental note that I had to be on the look-out for trouble. Such trouble had begun already in November 1963 when a three-man squad of burglars, evidently at the commission of the English body to which I earlier made reference, was caught red-handed by the police, whom I had alerted, as they raided my North London apartment, disguised as telephone engineers and equipped with stolen GPO passes.

The leader of that gang, whose name I shall not mention as he is not represented in this Court, told the police that he had hoped to find my secret correspondence with Hitler's henchman, Mr. Martin Bormann!

I mention this episode for a reason. This gentleman subsequently became Editor of a Left-Wing "Anti-Fascist" magazine called Searchlight, and he has made it his lifelong task over the intervening thirty years to take his malicious revenge upon me for the criminal conviction which he earned as a result of his felony.

His magazine repeatedly inveighed against me, reporting sometimes true, often part-true but usually totally fictitious rumours about my activities and alleged "Nazi" connections around the world, in an attempt to blacken my name.

I will not say that the rumours are all untrue. They never are. Mr. Winston Churchill once famously said, "The world is full of the most dreadful stories and rumours about me, and the damnable thing about them is that most of them are true!" At least, so rumour has it.

But the untrue ones about me are the ones that have a habit of surfacing again and again, with their original polish undimmed. I mention this case, as the defendants here seek to rely heavily on the outpouring of this troubled soul, the editor of Searchlight.

This Court might wonder why I took no action against this journal, or indeed against any of those parties who had defamed me over the years. One of the things that Michael Rubinstein, like Mr. Kimber my publisher, dinned into me very early on was to avoid at all costs taking libel action.

My Lord, I am sure I don't need to labour the reasons why, in this opening statement. Suffice it to say that I had already realised by 1970, at the time of the "Convoy PQ.17" libel action -- that is, Broome vs. Cassell -- that libel actions are time-consuming, costly, and vexatious, and are indeed in the words of the cliche "to be avoided like the plague".

Besides, this particular magazine had no assets, so any kind of litigation would have been pointless. I might add that only once in recent years have I been forced to take action in this jurisdiction under the Defamation Act, against a major national newspaper four or five years ago, which resulted in an immediate settlement out of Court which I can only describe as most satisfactory; the terms of this settlement are covered by the usual Court Order -- though I fancy they are known to the Defendants here, who asked for, and were given, full disclosure of the relevant papers.

It will become evident to this Court from the evidence that I lead over the next few days that the international community started to intensify its campaign to destroy me and to truncate my career as an author either before or at about the same time as The Viking Press and other publishers published my well-known biography of Adolf Hitler, HITLER'S WAR, in 1977.

The Court will be shown one internal document, dated April 1977, which I have identified as emanating from the Washington files of the so-called Anti-Defamation League, a part of the B'nai Brith, in the United States, which reveals quite unabashedly how they tried to pressure television producers to cancel invitations to me to discuss the HITLER'S WAR book on their programmes. It failed, the programme in question went ahead, and the ADL noted, aghast, in a secret memorandum, that I was well versed in the matters of history, a formidable opponent who could not however be called anti-Semitic.

I would have to be destroyed by other means.

This is a document in my Discovery. By various entirely legal means I obtained several such disturbing documents from within their files.

From them, and in particular from their details registered under the Data Protection Act in this country, it appears that these bodies, which are also embedded in our society in Britain and elsewhere, have seen their task, unbidden, as being to spy upon members of our society, maintain dossiers on us all, and to deploy those dossiers when necessary to smite those of us of whom they disapprove.

As the Court will see, the dossiers are explicitly designed to hold such material on the subjects' personal lives, criminal records, credit delinquencies, marital difficulties, dietary habits, and even sexual proclivities. That is what we know from their details of registration.

It is not anti-Semitic to reveal this. The spying and smearing by these bodies goes on against fellow Jew and non-Jew alike. The Jewish writer Noam Chomsky relates that he found quite by chance that they were "monitoring" -- for that is the word they use -- him too.

Several of our own most notable personalities have already commented on this unsavoury element of British life: in an article in a U.K. magazine the writer Mr. Auberon Waugh remarked upon how he too inadvertently found that such a file was being kept on him.

May I add that these "dossiers" provided by this London body to the Canadians, to the Anti-Defamation League, and to various similar bodies in Australia, South Africa and elsewhere, have been drawn upon heavily and without question by the Defendants in this action, which is my justification, I submit, for drawing your Lordship's attention to this disturbing and sleazy background.

When I attempted to take the libel action against the London-based body that I have mentioned, its Director, Mr. Michael Whine, admitted in an Affidavit that his body had taken it upon itself to "monitor" my activities -- there was that word again -- as he called them for many years: he also freely admitted that when secretly called upon by his Canadian associates in 1992 to provide them with a smear dossier for the purposes of destroying my presence in Canada, by planting it in government files in Ottawa, he willingly agreed to do so.

This is how that file turned up in Canadian Government resources; which in turn is how it came into my hands, years later, through lengthy "Access to Information Act" procedures. Otherwise I would never have known why I found myself being taken in handcuffs aboard an Air Canada flight in 1992, after thirty years as an honoured visitor to that country, and deported, an event to which the Defendants make gleeful reference in their book Denying the Holocaust.

I may be rather naïve, but this kind of thing offends me as an Englishman, as no doubt the idea will offend many of those present in Court 37 today . The notion that a non-Governmental body, equipped evidently with limitless financial resources, can take it upon itself to spy upon law-abiding members of the community for the purpose of destroying them is one that I find discomfiting.

I have never done it to my fellow human beings, and I can think only of the wartime Gestapo and its offshoots in Nazi-occupied Europe as a body engaged in similar practices. It is offensive and ugly comparison, I warrant, and one that I have never made before; but in a legal battle of this magnitude, I consider it necessary to use ammunition of the proper calibre.

I now come to the matter of the glass microfiche plates containing the diaries of the Nazi propaganda Minister, Dr. Joseph Goebbels. Your Lordship will have seen from the Statement of Claim that the Defendants accuse me of having improperly obtained these glass plates from the Moscow archives, or damaged them.

May I set out some of the antecedents of this matter? Your Lordship will perhaps remember the widespread newspaper sensation that was caused by the revelation at the beginning of July 1992 that I had succeeded in retrieving from the former KGB archives in Moscow the long lost diaries of Dr. Joseph Goebbels, a close confidant of Hitler and his propaganda minister and successor as Reich Chancellor.

I may say here that scholars have been searching for a number of diaries ever since the end of World War Two: I would mention here only the example of the diaries of Hitler's Intelligence Chief, Vice-Admiral Wilhelm Canaris, in the search for which I was concerned in the 1960s and 1970s. (The diaries offered to myself and Messrs William Collins Ltd. on that occasion turned out to be fake, which I established by use of the appropriate forensic laboratory in the City of London, Messrs. Hehner & Cox.)

Forensic tests are to play quite a large part in these current proceedings too.

In writing my own biographies of the leading Nazis I have attached importance to primary sources, like the original diaries which they wrote at the time. When I have found these documents, as many scholars know, I have invariably and without delay donated them or copies of them either to the German Federal Archives in Koblenz or to the Institut für Zeitgeschichte in Munich; and, in the case of the Goebbels diaries, after I retrieved them, I additionally gave a set of copies to the archives of Mönchen-Gladbach, his home town, where they maintain a collection of Goebbels documents.

In fact the only items which I consider to be of greater source value than diaries, which are always susceptible to faking or tampering, are private letters; in my experience, once a private letter has been posted by its writer, it is virtually impossible for him to retrieve it and to alter its content.

If I may take the liberty of enlightening the Court at this point by way of an example, I would say that I had earlier also found several diaries of Field Marshal Rommel; some I retrieved in shorthand from the American archives, and had them transcribed. Those in typescript turned out to have been altered some months after one crucial battle ("Crusader") to eradicate a tactical error which the Field Marshal considered he had made in the Western desert; but the hundreds of letters he wrote to his wife were clearly above any such suspicion.

On a somewhat earthier plane, while the diaries of the Chief of the SS, Heinrich Himmler, which have in part been retrieved recently from the same archives in Moscow, yield little information by themselves, I have managed to locate in private hands in Chicago the two hundred letters which this murderous Nazi wrote to his Mistress, and these contain material of larger historical significance.

Until my career was sabotaged therefore I had earned the reputation of being a person who was always digging up new historical evidence; that was until the countries and the archives of the world were prevailed upon, as we shall see, to close their doors to me!

After I procured the 600 pages of manuscripts of Adolf Eichmann in Argentina in October 1991, the German Federal Archives grudgingly referred to me in a press release as a Truffle-Schwein, which is (I hope) more flattering than it sounds.

We are concerned here, however, primarily with the diaries of Dr. Joseph Goebbels of which the Defendants made mention in their book. This is the inside story on those.

I had begun the search for these diaries about thirty years earlier. In my Discovery are papers relating to the first search that I conducted for the very last diaries which Dr. Goebbels dictated, in April 1945 -- right at the end of his life; since there was no time for them to be typed up, he had the spiral-bound shorthand pads buried in a glass conserving jar in a forest somewhere along the road between Hamburg and Berlin.

Chance provided me in about 1969 with the "treasure map" revealing the burial place of this glass jar, and with the permission of the Communist East German Government I and a team of Oxford University experts, equipped with a kind of ground penetrating radar (a proton magnetometer in fact) mounted a determined attempt to unearth it in the forest.

We never found that particular truffle. Unfortunately, the topography of such a forest changes considerably in twenty years or more, and despite our best efforts, aided by the East German Ministry of the Interior and a biologist whose task would be to assess the age of the fungi and other biological materials found in and around the jar, we came away empty-handed. This is nothing new. Field work often brings disappointments like that.