Closing Speech
by David Irving
Part
V Auschwitz Concentration
Camp Auschwitz has been a football of politicians and
statesmen ever since World War II. The site has
become, like the Holocaust itself, an industry, a
big business in the most tasteless way. The area
is, I am informed, overgrown with fast food
restaurants, souvenir and trinket shops, motels,
and the like. Under prime minister Josef
Cyrankiewicz (who had been prisoner number 62,993)
it was known at its opening in 1948as a "monument
to the martyrdom of the Polish and other
Peoples."104 Auschwitz was overrun by the Red Army in January
1945. The last prisoner had received the tattooed
number 202,499. Informed by Colonel-General Heinz
Guderian that the Russians had captured Auschwitz,
Hitler is recorded by the stenographers as merely
acknowledging: "Yes."105 The Court might find it
significant that he did not prick up his ears and
say something like, "Herr Himmler, I hope you made
sure that the Russians will find not the slightest
trace of what we have been up to." (Or even, "I
hope you managed to get those holes in the roof
slab of Krema II cemented over so there's no trace,
before you blew it up." I will shortly explain the
significance of that.) When the name of
SS-Gruppenführer Hans Kammler, the architect
of the concentration camps, was mentioned to him a
few days later by Goebbels, it was evident that
even Kammler's name meant little to Hitler.106 How many had died at Auschwitz? We still do not
now with certainty, because the tragic figure has
become an object of politics too. Professor Arno
Mayer, Professor of European History at the
University of Princeton, a scholar of considerably
greater renommée than Professor Evans, and
himself a Jew, expressed the view in one book that
most of the victims of the camp died of exhaustion
and epidemics. "From 1942 to 1945 more Jews died,
at least in Auschwitz, and probably everywhere
else, of 'natural' causes of death than of
'unnatural.'"107 The Russians who captured the camp did not at
first make any mention in their news reports of
"gas chambers". Moreover, as we saw on the newsreel
which I showed on the first day of the trial, even
the Poles, with access to all the records, claimed
only that "altogether nearly 300,000 people from
the most different nations died in the Auschwitz
concentration camp." It concluded that the camp now
stood "as a monument of shame to the lasting memory
of its three hundred thousand victims." (Again,
gassing was not mentioned).108 The New York Times
quoted the same figure, 300,000 when the trial
began in 1947.109 The figure gradually grew
however. The Russians set up an inquiry including
some very well known names - including the
"experts" who had examined the "Nazi mass graves"
at Katyn, and even the notorious Lysenko, and they
announced that four million had been murdered at
Auschwitz. Under the Polish communists, a monument
to "four million dead" was duly erected, a number
adhered to until the 1990s, even under Franciszek
Piper, one of the later (but still communist)
directors of the Auschwitz State Archives. After
the communist regime ended that the figure was
brought down, to 1.5 million, and then to 750,000
by the acknowledged expert Jean-Claude Pressac.110
The Defendants' own expert Peter Longerich spoke of
one million deaths there from all causes, and in
response to cross-examination by myself and to Your
Lordship's queries Dr Longerich confirmed that he
included all non-homicidal deaths, deaths "from
other causes," including epidemics and exhaustion,
in that figure.111 As for the overall deathroll of the Holocaust,
what meaning can one attach to figures? The
International Military Tribunal (IMT) at Nuremberg
found that "the policy pursued resulted in the
killing of six million Jews, of which four million
were killed in the extermination institutions"? But
the six million figure derives, as US chief
prosecutor Mr Justice Robert H Jackson recorded in
his diary in June 1945, from a back of the envelope
calculation by the American Jewish leaders with
whom he met in New York. Professor Raul Hilberg put
the figure at 5.1 million or less.112 Gerald
Reitlinger had the figure at 4.6 million, of which
he stated about three million were conjectural as
it was not known how many Jews had escaped into the
unoccupied part of the USSR.113 The Israeli Prime
Minister's office, we are told by Norman
Finkelstein, recently stated that there were still
nearly one million living survivors.114 There are doubts not only about precise figures
but about specific events. The same IMT ruled on
October 1, 1946 that the Nazis had attempted to
"utilise the fat from the bodies of the victims in
the commercial manufacture of soap." In 1990
historian Shmuel Krakowski of Yad Vashem announced
in the world's press that that too had been a
("Nazi") propaganda lie.115 Gradually the wartime
stories have been dismantled. As more documents
have been found, widely stated propositions have
been found to be doubtful. For a long time the
confident public perception was that the Wannsee
protocol, of the January 20, 1942 meeting, recorded
the actual order to exterminate the European Jews.
Yehuda Bauer, the director of Yad Vashem, the
world's premier Holocaust research institution in
Israel, - one of the correspondents of the Second
Defendant - has stated quite clearly: "The public
still repeats, time after time, the silly story
that at Wannsee the extermination of the Jews was
arrived at." In his opinion Wannsee was a meeting
but "hardly a conference," and he even said:
"Little of what was said there was executed in
detail."116 Despite this, Your Lordship has had to
listen to the "silly story" all over again in this
Court from the expert witnesses. Surely, say my critics, there must now be
evidence for a Hitler Order? Back in 1961 Raul Hilberg, one of Yehuda Bauer's
great rivals for the laureate, asserted in The
Destruction of the European Jews that there had
been two such orders, one in the spring of 1941 and
the other soon after. By 1985 - after I had
corresponded with him and voiced my own doubts -
Hilberg was back-pedalling: Hilberg went
methodically through his new edition, excising the
allegation of a Hitler Order. "In the new edition,"
as Professor Christopher Browning, an expert who
testified before this Court, criticised in a
learned journal, "all references in the text to a
Hitler decision or Hitler order for the 'Final
Solution' have been systematically excised. Buried
at the bottom of a single footnote stands the
solitary reference: 'Chronology and circumstances
point to a Hitler decision before the summer
[1941] ended'." "In the new edition,"
Browning repeats, scandalised, "decisions were not
made, and orders were not given."117 Your Lordship
will find my exchange with Browning as to whether
he had indeed written those words in 1986 on Day 17
at page 121: you will find too that he regretted
that he could not recall clearly the events of
fifteen years ago, which invited a rather obvious
riposte from me about the probably similar
memory-deficiencies in the eye-witnesses on which
he had on occasions relied. The director of the Yad Vashem archives has
stated that most survivors' testimonies are
unreliable. "Many," he writes, "were never in the
places were they claim to have witnessed
atrocities, while others relied on second-hand
information given them by friends or passing
strangers" - the phenomenon I have referred to as
"cross-pollination."118 Your Lordship may have been
as startled as, I confess, was I, upon learning the
degree to which the case for the mass gassings at
Auschwitz relies on eye-witness evidence, rather
than on any firmer sources. Your Lordship will
remember the exchange I had with Donald Watt,
professor emeritus of history at the London School
of Economics and a learned diplomatic historian,
early on in the trial, about the value of
difference categories of evidence: - "IRVING: Professor, I was not going to ask
you about eyewitness evidence but where would
you rank eyewitness evidence on the scale, if
you had, for example, aerial photographs, if you
had prisoner of war intelligence, contemporary
prisoner of war intelligence, if you had
intercepts from Bletchley Park, if you had
captured documents, either captured during the
war or after the war, and eyewitness evidence,
in other words, anecdotal evidence and, finally,
interrogations, whether under oath or not in
Court, how would you classify those in order of
reliability, starting with the least
reliable?
- PROFESSOR WATT: I do not know that there is
any way of classifying those, because it depends
so much on the individual. I did a great deal of
interviews, particularly in the period before
the 1967 Public Records Act released documents
of 30 years of age, and in my experience the
kind of evidence I got differed according to the
personality of the person giving it. In some
cases I found that the man I was interviewing
had his own documentary record and was
consulting it, and that what he said was
confirmed later. In other cases, including at
least one Minister of the Crown, I was given a
very plausible and, for all I know, a very true
story of a meeting at which he was supposed to
have been present; and when the records of that
meeting subsequently became available, it was
clear that he was not. He should have been, but
he just was not that day, and he must have heard
the story from one of the people there and then
repeated it.
- IRVING: But he seriously believed that he
had been there?
- PROFESSOR WATT: [...] If a gentleman
who holds the rank of Admiral of the Fleet and
is a junior Minister in the Cabinet tells you
that he is there, one's reaction is not to
question him [...]
- IRVING: So to repeat my original question,
where you would rank on that scale of material
that is lying before you, at one end of the
bench you have the eyewitnesses and at the other
end of the bench you have, for example, the
Bletchley Park intercepts?
- PROFESSOR WATT: The Bletchley Park
intercepts, in so far as they are complete, are
always regarded as the most reliable because
there is no evidence that the dispatcher was
aware that his messages could be decoded and,
therefore, he would put truth in them."
This supports my view that eyewitness evidence
is less credible than forensic evidence and the
Bletchley Park intercepts. I do not completely
ignore eye-witness evidence, but I feel entitled to
discount it when it is contradicted by the more
reliable evidence, which should then prevail The Leuchter Report I am criticised by the Defendants for having
relied initially on what is called the Leuchter
Report. At the time they levelled their criticism
at me, the Defendants appear to have been unaware
that subsequent and, more able, investigations were
conducted by both American and Polish researchers.
The tests were in other words replicated. First, the Leuchter Report: In April 1988 I was
introduced by defence counsel at the Canadian trial
of Ernst Zündel to the findings made by a
reputable firm of forensic analysts of samples
extracted from the fabric of various buildings at
Auschwitz and Birkenau by Fred Leuchter, who was at
the time a professional American
execution-technology consultant. These, and his
investigations at the Majdanek site, formed the
backbone of his "engineering report". Since there have been tendentious statements
about why the Leuchter Report was not admitted in
evidence at that trial I have studied the
transcripts of that trial. It emerges that
engineering reports are not generally admissible
under Canadian rules of evidence unless both
parties consent; in this case the Crown did not
consent. As Mr Justice Thomas explained, "I get
engineering reports all the time [in civil
cases]. That doesn't make them admissible
because they've prepared reports. They [the
expert witnesses] go in the box, they're
qualified as experts, and they testify."119 The
non-admission of the report by Mr Justice Thomas
was no reflection on the worth of the report or on
the qualifications of the witness. Mr Leuchter testified on April 20 and 21, 1988
as an expert in gas chamber technology. He had
inspected the three sites in February and taken
samples which were subsequently sent for analysis
by a qualified analytical chemist in the United
States, a Dr James Roth of Cornell University, who
was not told where the samples had come from. His
firm, Alpha Laboratories, were told on the test
certificates only that the samples were from
brickwork. Mr Justice Thomas ruled that Leuchter
could give oral evidence, but that the report
itself should not be filed.120 He held further that
Mr Leuchter was not a chemist or a toxicologist.121
But he agreed that Mr Leuchter was an engineer,
because he had made himself an engineer in a very
limited field.122 A summary of the rest of the judge's findings
was that Leuchter was not capable in law of giving
the expert opinion that there were never any
gassings or exterminations carried on in the
facilities from which he took the samples.123 For
the same reasons he was not capable of testifying
regarding the results of the analysis. He was
restricted to testifying as to the actual
extraction of the samples,124 and his own
observations on the feasibility of the buildings
that he had examined being used as gas
chambers.125 The Second Defendant therefore was wrong to
state on page 164 of her book, "The judge ruled
that Leuchter could not serve as an expert witness
on the construction and functioning of the gas
chambers."126 To give evidence in a criminal trial,
Mr Leuchter must have been accepted as an expert.
Professor Lipstadt further stated, on pages 164-5
of her book: "The judge's finding as to Leuchter's
suitability to comment on questions of engineering
was unequivocal." In fact the Judge's findings
referred only to his lack of qualifications to
testify on the results of the laboratory tests for
cyanide and iron (this was Dr Roth's area, and he
gave the testimony on those matters). On page 169,
Professor Lipstadt insists: "The exposure to the
elements lessened the presence of the hydrogen
cyanide. . . Nor did Leuchter seem to consider that
the building had been exposed to the elements for
more than forty years so that cyanide gas residue
could have been obliterated. He also took samples
from a floor that had been washed regularly by
museum staff." Dr Roth however testified under oath
that the formation of Prussian Blue was an
accumulative reaction, that it augmented with each
exposure to the gas; and that it did not normally
disappear unless physically removed by sandblasting
or grinding down.127 Roth seems since then to have changed his mind,
to judge by the television film "Mr Death" which is
shortly to be shown on Channel Four, and upon which
film both I and learned counsel in the current
action rely. Zündel's counsel comments, "He
[Roth] obviously is frightened" and no
wonder, considering what was subsequently inflicted
upon Mr Leuchter. Your Lordship will remember that
in order to destroy Roth's absurd argument, quoted
to the Court by learned Counsel, that the Prussian
Blue stain would have penetrated only a few microns
into the brickwork, I showed a photograph of the
stain penetrating right through the brickwork to
the outside face of one of the cyanide fumigation
chambers, where it has been exposed to sun, wind,
and rain for over fifty years, and where it is
still visible, as deep and blue as ever. Krema II
has been protected from these outside elements; it
is possible to crawl beneath the famous roof -
about which roof I shall have more to say - but
neither Jan Sehn, nor Fred Leuchter, nor James
Roth, nor Germar Rudolf, nor any of the subsequent
investigations found any significant traces of
cyanide compounds present in the fabric of this
building, despite the eye-witness accounts of that
same chamber having been used for the gassing of
half a million people. Moreover, the wood-grain of
the original wooden formwork (or moulds) can still
be seen on the face of the concrete, which is
evidence that it has not been sandblasted or ground
down. The Morgue roof I referred earlier to the expert witness on
Auschwitz and Birkenau in this case, Professor
Robert Van Pelt. He has made unequivocal statements
both here and elsewhere about Krema II, crematorium
No. II at Birkenau. To him, it was the factory of
death, the mass gassing chamber of Birkenau. He did
not mince his language. In the new television film
MR DEATH we saw him, and we saw him, as the film
camera showed Fred Leuchter descending into the
hole which was broken post-war through the
collapsed concrete roof slab and reinforcing bars
of Leichenkeller 1 (morgue No. 1) of Krema II, and
we heard him (Van Pelt) uttering these words: " Crematorium II is the most lethal
building of Auschwitz. In the 2500 square feet
of this one room, more people lost their lives
than any other place on this planet. 500,000
people were killed. If you would draw a map of
human suffering, if you created a geography of
atrocity, this would be the absolute Center."128 The Court will recall that on the ninth day of
this action I cross-examined this witness most
closely about this statement, and I offered him a
chance to change his mind about the pivotal
importance of Krema II and its underground
Leichenkeller 1, the chamber which Pelt alleged had
been a mass-gassing chamber. Irving: Very well. You say: "In any case,
Krematorium II is the most [something] of
Auschwitz. In the 2500 square feet of this one
room", and you are pointing downwards, "more people
lost their lives than in any other place on this
planet. 500,000 people were killed. If you would
draw a map of human suffering, if you create a
geography of atrocities, this would be the absolute
centre." That is a reference to Krematorium II and
you are standing on the roof of Leichenkeller No.
1? - PROF. VAN PELT: It is a reference to
Krematorium II, but I am actually not in the
picture. It is Fred Leuchter standing on the
roof of Leichenkeller 1.
- IRVING: But you are speaking yourself?
- PROF. VAN PELT: But I am
speaking.[...]
- IRVING: Professor, just so that we can be
completely clear about this and the record can
be clear, you are describing Krematorium II as
being the place where 500,000 people were killed
or -
- PROF. VAN PELT: Yes.
- IRVING: - give or take a few numbers.
- PROF. VAN PELT: Yes.
- IRVING: And that this was the centre of the
atrocity?
- PROF. VAN PELT: Yes.
- IRVING: So if I am to concentrate a large
part of my investigation in this
cross-examination on that one building and, in
fact, on Leichenkeller 1, the one arm of the
crematorium, this is not entirely unjustified if
I am trying to establish that the factories of
death did not exist as such?
- PROF. VAN PELT: No. I think that that the
obvious building to challenge would be
Krematorium II.129
The expert witness could hardly have been
clearer in his answer. At page 53, I then asked him
to identify the buildings referred to, on the
aerial photographs of Birkenau and Krematorium II,
so that there could later be no doubt as to which
precise building he had just agreed was the
"factory of death." The great problem about accepting that this
building was an instrument for mass murder is that
the evidence produced by Professor Van Pelt relies
on three "legs": a handful of eye-witnesses; a few
architectural drawings; and a slim file of
documents. The eye-witnesses have turned out to be liars,
particularly those who testified to the SS guards
opening manhole covers on top of the flat roof of
Leichenkeller 1 (morgue No. 1) and tipping tins of
Zyklon B pellets inside. One witness was David
Olère, an artist, who drew sketches years
later in Paris, obviously intending to sell them.
His sketches show flames and smoke belching from
the crematorium chimney of Krema III, which was
quite impossible130; he portrays the victims of the
Nazi killers mostly as nubile young females, all
naked and sketched in a pornographic way, often
clutching naked teenage children to their
breasts.131 It was Olère, I invite the Court
to remember, who told Jean-Claude Pressac that the
SS made sausage in the crematoria out of human
flesh (a passage which Mr Van Pelt did not inform
us of).132 Ada Bimko proved at the Belsen Trial
that she too had lied. Entering another "gas
chamber" building at Auschwitz she said she
"noticed two pipes which I was told contained the
gas. There were two huge metal containers
containing gas." She evidently did not even know
that the "gas" supposed to have been used, Zyklon
B, was actually in pellet form, not cylinders.133
Distorting her account too, Pelt also omitted this
part of her testimony. Dr Bendel, another of Pelt's
eye-witnesses, stated that at Krema IV the people
crowded into the gas chambers found the ceiling so
low that "the impression [was given] that
the roof was falling on their heads."134 This too
was untrue, as the Court has seen how high those
ceilings were in the computer-generated "walk
through." The Court will find that in my
cross-examination of Van Pelt, I destroyed the
worth of each supposed eye-witness after
eye-witness in the same way. Let us first look for those holes. The roof
pillars were blown up in 1945, and the reinforced
concrete roof slab pancaked downwards into the
morgue basement, starred but otherwise intact. Van
Pelt suggested that the Zyklon B introduction holes
in the roof of Leichenkeller 1 were not much larger
in diameter than tennis balls. The evidence of his
eye-witnesses Henry Tauber and Michal Kula was that
they were closer to the size of manholes - "70
centimetres [27 inches] square."135 Kula
testified that the wire-mesh columns that he had
made were of that cross section and three metres
(ten feet) tall. One witness said the concrete
covers had to be lifted off "with both hands". As
the ceiling height in Leichenkeller 1 was 2.40
meters, 60 cm of each column would have had to
extend through the "holes" in the concrete ceiling,
with about six inches poking up outside.136 There
is no trace of those holes in the roof today. The
underside, which can be inspected and photographed
from beneath, is intact. Even if one could lose
sight of the much smaller, three-inch diameter
holes in the pancaked concrete roof, of which Van
Pelt spoke137, one could not possibly have lost
sight of four holes as large as manholes. Those
holes would be perfectly obvious today, on the
ground at Auschwitz, to any observer using the
naked eye, without the slightest possible doubt as
to their location. Van Pelt accepts that those holes are not in
that roof slab now. In his expert report and for
this honesty I give him full credit - he
writes: Today, these four small holes that connected the
wire-mesh columns and the chimneys cannot be
observed in the ruined remains of the concrete
slab. Yet does this mean they were never there? We
know that after the cessation of the gassings in
the fall of 1944 all the gassing equipment was
removed, which implies both the wire-mesh columns
and the chimneys. What would have remained would
have been the four narrow holes and the slab. While
there is no certainty in this particular matter, it
would have been logical to attach at the location
where the columns had been some formwork at the
bottom of the gas chamber ceiling, and pour some
concrete in the hole and thus restore the
slab.138 Van Pelt thus asserts, without any evidence at
all, that late in 1944, with the Red Army winding
up to launch their colossal final invasion only a
few miles away on the River Vistula, the Nazi-mass
murderers would remove the "Zyklon introduction
columns" and then fill in the holes to "restore the
slab" (before dynamiting the pillars supporting it
anyway). He again asserted when I cross-examined
him on January 25 that: "It would have been logical
to attach at the location where the columns had
been, some formwork at the bottom of the ceiling,
and pour some concrete in the hole and thus restore
the slab."139 How would this have been more logical than
completely removing the roof of Leichenkeller 1, as
the Nazis had removed the roof of Leichenkeller 2,
identified by Van Pelt as the "undressing rooms,"
as shown in the aerial photos taken on December 21,
1944 that one can see on page 15 of THE HOLOCAUST
REVISITED, the book published by Dino A Brugioni of
the CIA. The originals of this photo were shown to
Van Pelt in Court. To believe his version, we would
have to believe that the Nazis deliberately created
architectural relics of Leichenkeller 1 to confound
later generations of tourists and Holocaust
researchers. The fact is that the holes are not there - at
least they are not visible from a distance of zero
to four feet, or when photographed from the
underside. Unable to point them out to us in
close-up at ground level, the Defendants invited us
to consider instead either vertical aerial
photographs taken from 35,000 feet up, or a
horizontal photograph taken from several hundred
yards away, past a locomotive, where three (not
four) unidentified objects are placed irregularly
on the rooftop (the fourth "object" turns out to be
a window on the wall behind). The Court will recall
what my response was to the not unexpected
discovery that during building works such objects
as barrels of tar were parked on a large flat slab,
and I shall not repeat it in detail here.140 The
notion that the high flying plane could have
photographed an object of 27 cm diameter, let alone
of tennis ball size, protruding six inches above
the ground, is quite absurd. The four smudges seen
on one photograph are evidently many feet long. On Day 11, I brought into the Court half a dozen
vertical aerial photographs taken by the Americans
or South African airforces during 1944, and I
invited Van Pelt to find those same smudges on that
roof.141 Where until this moment he had seen dots on
another photograph with no difficulty, the witness
Van Pelt now pleaded poor eyesight ("I have now
reached the age I need reading glasses," he said,
"and I do not have them with me. I did not expect
this kind of challenge." Precisely.) Had he used
even a microscope, he would not have found the dots
on the 1944 pictures I showed him. Because the
holes were not there, and are not there, and he and
the Defendants know it. Even if the Nazi architects did willingly agree
to the weakening of the roof by having makeshift
holes of that size cut through the slab right next
to the supporting pillars - I say "makeshift"
holes, because there is no provision for them in
any of the architectural drawings - we should
certainly expect to see the holes now. My Lord, the
Court will recall two things: 1. I asked the witness Van Pelt if he
was familiar (in view of the fact that he is not
qualified architecturally) with the expression
"fair faced concrete finish".142 He confirmed
that it is concrete left untreated. It is not
covered with, e.g. cement or plaster or
pebble-dash or tiling. He confirmed that it is
the most expensive such finish that an architect
can specify, because the concrete has to be
poured right first time: blemishes like holes
and cavities can never be retouched afterwards.
Filling in the holes with cement, as Van Pelt
suggested in an extraordinary piece of
naiveté, would have been evident in the
concrete face for ever after by differences in
general appearance, colouring, wear and
fracturing; there would have been a visible
"drying line" as a ring around the patch, and
the wood grain pattern left by the wooden
formwork would have been interrupted. Common
sense tells us all of this as well.2. We have photographed the underside of that
slab. There is no trace of any such blemish on
the concrete roof's underside. On two occasions I stated a challenge in Court,
including to the witness Van Pelt. I challenged the
Defendants to send somebody to Auschwitz even now,
to scrape the thin layer of gravel and dirt off the
topside of the roof slab where they "know" the
"holes" must be - because the eye-witnesses agreed
they were next to the main columns - and bring back
a photo of just one of the holes or evidence that
it had been filled in. If they did, I said, I would abandon my action
forthwith, because my position would have become
indefensible. To my knowledge, the Defendants have
not attempted this exercise. They know, and they
knew from the outset, that I was right about that
roof. Their entire case on Krema II - the untruth
that it was used as a factory of death, with SS
guards tipping canisters of cyanide-soaked pellets
into the building through those four (non-existent)
manholes - has caved in, as surely as has that
roof. Accordingly the eye-witnesses who spoke of those
holes also lied, or bluffed: and I have called
their bluff. In the absence of the holes
themselves, and minus his "eye-witnesses,"
Professor Van Pelt's only remaining proofs that
Leichenkeller 1 of Krema II was an instrument of
mass murder - a factory of death in which five
hundred thousand Jews were gassed and cremated -
are these: architectural drawings (rather oddly for
a "professor of architecture" he calls them
blueprints); and wartime documents. He confirmed
this to Your Lordship, when your Lordship
asked. As for the wartime documents, he referred for
instance to the - to him, sinister - requirement
that the morgue should be vorgewärmt by a
central heating plant. In cross-examination I drew
his attention to the relevant section of the
wartime NEUFERT, the architect's handbook or
building code which was standard for the S.S.
architects, which specifies that morgues must have
both cooling and central heating facilities to
avoid damage to the corpses.143 Document after
document fell by the wayside in the manner. Mr
Rampton introduced the timesheet of one humble
workman in March 1943, showing him actually
concreting "the floor in the Gaskammer." But
Birkenau camp was full of gas-chambers. In his fine
facsimile book of the camp documents, Jean-Claude
Pressac has printed the drawing No. 801 of November
8, 1941, for an Entlausungsanlage (delousing
installation) for the prison camp, right in the
middle of which drawing is a Gaskammer.144 He also
reproduces drawing No. 1293 dated May 9, 1942, of
the drainage and water supply of the delousing
barracks, buildings BW5b. Here too there is a
Gaskammer smack in the middle of the
drawing.145 The real handling capacity of the crematoria is
also surprisingly difficult to establish. Professor
Van Pelt produced a histogram, on an easel, for us,
which showed truly staggering projections of
cadavers to be cremated in coming years; but on
cross-examination he admitted that the projection
was based solely on one document, the questionable
"crematorium capacities" document of June 28, 1943,
and that all else was extrapolated backwards from
that.146 Pelt relies heavily on this document.147
Even if genuine, the handling figures which this
document gives for the furnace installation in
Krematorium II do not tally with any of the figures
in the specifications provided by the
manufacturers, the Topf Company, for this type of
equipment.148 Furthermore, the document refers to
some crematoria which were at that time shut down,
and to others that were due to be taken out of
commission.149 I had shown the Court on the previous day that
this one page of paper contained not just one or
two, but four or even five bureaucratic
discrepancies which indicated that the document is
not authentic.150 Any one of those flaws would
normally be enough to call its integrity into
question: but five in one document, including the
wrong rank for the highest man in the SS
site-construction system, SS Gruppenführer
Hans Kammler? Van Pelt was unable to explain these
flaws; he had not noticed them. The document was
first published in East Berlin in the 1950s, and it
is now to be found in the Auschwitz archives,
because it was sent there in 1981. That alone is
why it now bears an Auschwitz archival stamp.151 It
did not originate there, but elsewhere. Even if the
flaws can be explained, and the figures were
genuine, there is no indication of how such huge
numbers of bodies were to be handled within 24
hours; nor of where the coke was to come from
(there is no acceptable evidence that the Auschwitz
staff found any way of improving on the average
coke consumption of 30 kg per cadaver achieved by
other camps). The bottleneck in the entire Krema II "factory
of death" story is however the little freight
elevator that was installed between Leichenkeller
1, as in any such state-of-the-art crematorium, to
haul the bodies from the basement-level morgue up
to the crematorium furnaces on the ground floor. We
are told by the Defendants that this elevator was
never anything more sophisticated than something
like a builder's hoist. The real elevator was never
delivered. It had no door, or cage, or walls - it
was just a platform jolting up and down that
elevator shaft. We do know that as finally
installed it had a specified load bearing capacity
of 1500 kg. Van Pelt suggested that the hoist could
therefore have hauled twenty-five cadavers at a
time.152 In practice, as there was just a flat
platform with no walls or door, jolting up and down
the narrow concrete elevator shaft, it would have
been impossible to stack onto one small flat
platform twenty-five naked cadavers in the
conditions of filth and slime that were described
by the eye-witnesses. It does not bear thinking about, I agree. We can
not produce hard figures for this part of the
exercise, but one thing is plain: that one elevator
in Krema II was the inescapable bottleneck, and it
makes plain that, whatever was happening downstairs
in Leichenkeller 1, it was not on the huge scale
that history now suggests. In response to Your Lordship's helpful
questioning, Professor Van Pelt stated that the
wartime documents had to be interpreted if they
were to be relied on for this proof. These
interpretations are tenuous. He produced to us a
document referring to the special secrecy to be
attached to the crematorium drawings, and suggested
that this was because of the mass gassings being
carried on in it. It stressed that this was because
of the wehrwirtschaftlich importance
[importance to the military economy] of the
work being conducted there. But Van Pelt confirmed
under my cross-examination that the homicidal Final
Solution, the genocide, was never regarded as being
wehrwirtschaftlich important. I submitted that the
reference was clearly to keeping secret the ugly
business of the looting by the SS of gold and
valuables from the corpses processed by the
building, a system which was undoubtedly
wehrwirtschaftlich important to the SS.153 Similarly, the architectural drawings seemed to
provide the required "proof" only when one was
compared with another. As Van Pelt said: ". . . we
can look now at two or three drawings together and
. . . we start to observe some very weird things
and some modifications made between one drawing and
the other drawing . . ."154 Is that the best level of proof that is
available now, even after fifty-five years? During
his slide-show Professor Van Pelt told us that one
cardinal piece of evidence in these drawings was
the relocation of an internal double-door which
sealed off Leichenkeller 1 from the interior of the
building, from the inside of the Leichenkeller
doorframe (in a December 1942 drawing) to the
outside (January 1943). I pointed out that in the
new layout, the doors were showed as being actually
rebated into the doorframe, and I suggested to the
witness that this was indicative of a gas-tight
door being fitted as in any standard air raid
shelter design. Air raid shelter doors are fitted
outside the shelter, to open outwards, so as to
withstand blast. NEUFERT, the wartime architects'
handbook, bears this out. The witness seems not to have considered this
possibility. The doors allegedly found around the
Birkenau and Auschwitz sites subsequently are all
of standard air-raid shelter design, complete with
the obligatory peephole that is fitted to air raid
shelter doors. The amendment of the drawings to
provide for an external door, leading from the far
end of the subterranean Leichenkeller 1 to the open
air, was also consonant with its dual use as a
shelter, and I put this to the witness on Day
11,155 as was the relocation of the main entrance
staircase from the back of the building, to the
street-side. Among the architectural drawings
provided to us from the Auschwitz archives is one
entitled: "Modification of the old Crematorium,"
namely Krema I in Auschwitz; subtitled: "Air Raid
Bunker for SS Station HQ with an Operating
Theatre."156 So such modifications of the morgues
to provide air raid shelters were clearly nothing
extraordinary. Mr Rampton made a lot of the order
for doors with peepholes.157 But peep holes were
standard fittings not only on the gastight air raid
shelter doors, but also to delousing facilities.
Jean-Claude Pressac prints photos of two such doors
on the "Canada" delousing chamber at
Birkenau.158 Krema II as air raid
shelter Krema II, like its mirror-image Krema III on the
other side of the road, was originally designed as
a state-of-the art crematorium, possibly not just
for the camp but for the whole catchment area of
Auschwitz which had for centuries been an area of
pestilence and plague. No expense was spared in its
design; the best equipment and architects were used
on what was clearly a permanent facility. Building
the Leichenkeller underground, instead of above
ground, increased construction costs by several
times, but provided for keeping the morgue cool
during the baking hot Central European summers. Had
the building been designed from the start as a
human slaughterhouse, it would certainly not have
been designed on several levels, with the resultant
handling problems. Slaughterhouses are normally
built on one level.159 We saw in Professor van Pelt's slide-show the
pouring of the concrete roof slab of the
subterranean Leichenkeller 2; the roof was
undoubtedly much the same as Leichenkeller 1 with a
six inch reinforced steel mesh.). This undoubtedly
made the new building one of the most robust on the
site: certainly more robust and fireproof in an air
raid than the flimsy wooden horse-barracks in which
the prisoners and slave labour were housed. The captured Bauleitung records of Auschwitz
housed in Moscow confirm that from mid 1942 onwards
they began to consider the construction at the camp
of shelters, splinter trenches, and other Air Raid
Precaution (ARP) measures.160 To be fair to the
witness, when these Moscow catalogue entries were
put to Van Pelt he seemed unfamiliar with them.
After the air raids on Cologne, Rostock,
Lübeck etc., in March/April 1942, the German
High Command recognised the likelihood that air
raids would spread across Poland and central
Europe, and they ordered the construction of
extended ARP facilities throughout the occupied
eastern territories insofar as they were within
bomber range. Existing basements were to be
converted into shelters, and anti-gas-equipment
provided, and personnel trained in anti-gas
warfare, as gas attack was widely expected.161 I
put one such document to Prof. Longerich, and on
Day 10 I said (at page 95): "[...] the
Defence rely on a number of photographs of doors
found scattered around the compound of Auschwitz
and Birkenau, and we will show that these are
standard German air raid shelter doors complete
with peep holes." (Photographs of such air raid
shelter doors will be found in the bundle that I
provided at page ••). These precautions were not in vain. In May 1943,
there was an air raid on the nearby Auschwitz Buna
plant. This is reflected in Auschwitz documents. At
least one of the American aerial photographs of
Birkenau that I produced to the Court and to the
witness Van Pelt shows a stick of heavy bombs just
released by the plane that took the photograph. By
the end of the war there was also an anti-aircraft
unit assigned to defending the region, as shown by
the reference to Judge Stäglich's membership
of the Flak unit that manned it.162 Your Lordship will also recall that during his
slide show the Dutch historian Van Pelt showed the
Court a series of most interesting
computer-generated "walk-through" reconstructions
of the interiors of Kremas IV and V. Your Lordship
memorised the dimensions of the shutters designed
to be fitted on the openings inside: 30cms by
40cms. There were also said to be steps leading up
to the openings. The wartime German civil defence
journal Luftschutz (Air Raid Protection) shows
precisely this arrangement of gas-tight shutters
and steps as a standard air raid shelter feature,
designed for the event of gas warfare. I put this fact to the witness Van Pelt: "Would
you agree that those shutters that have been found
in the Auschwitz camp are in fact standard German
air raid shutters supplied by manufacturers to a
standard design?"163 The eye-witnesses stated that thousands of
victims were gassed in these rooms, and their
bodies burned in large pits to the building's rear.
But the contemporary air photographs reveal no such
pits, nor are they evident today. Confronted with
what your Lordship has yourself referred to as the
lack of any documentary evidence for the gassings,
Van Pelt could only offer the suggestion that the
use of gas chambers at Auschwitz and Birkenau was a
"moral certainty". Three times in his report he
fell back upon that semi-religious phrase.164 The
available proofs certainly do not support the
belief that the gassings there occurred on a mass
scale. I will not dwell long on the uniformly poor
evidentiary basis on the other extermination camps,
known to the Court as the Operation Reinhard camps.
- Belzec, Sobibor and Treblinka. Here we do not
even have the "moral certainty" which comforted
Professor Van Pelt. I can challenge here only the
scale and the systematic nature of the alleged
gassing of more than one million people in these
centres. The Defendants' own witness, Professor
Browning, admits that the documentation for these
camps is "scant". I place great weight on this
admission. Here, the expert cannot even find one
contemporaneous document. He relies entirely upon
the eye-witnesses - men of the ilk of Kurt
Gerstein, Jan Karski, Adolf Eichmann and Rudolf
Höss. The fictional elements - the "130 foot
mountains of clothes" which Browning in his first
draft skipped over,165 the "electrocution
chambers", the "steam chambers"166, the
deliberately inflated death tolls which would
otherwise shriek their warnings to critical
researchers are ignored or suppressed, in order to
maintain appearances. There is an impressive level of documentation
which demonstrates that the liquidation by shooting
of hundreds of thousands of Jews, probably over a
million, by the Einsatzgruppen, but there is
nothing of equivalent value for the Reinhard camps.
One word, Why?, justifies a revisionist's
scepticism. The Walter Föhl letter produced a similar
response. Found in his Berlin Document Center
personnel file, this man, in charge of a
resettlement office at Krakow, is seen writing on
June 21, 1942 to his SS comrades, "Every day, trains are arriving with
over 1000 Jews each from throughout Europe."We provide first aid here give them more or
less provisional accommodation, and usually
deport them further towards the White Sea to the
White Ruthenian marshlands, where they all - if
they survive ( and the Jews from
Kurfürstendamm or Vienna or Pressburg
certainly won't) - will be gathered by the end
of the war, but not without having first built a
few roads. (But we're not supposed to talk about
it.)"167 The expert witnesses, unable otherwise to
explain this document, dismissed it as obvious
"camouflage" talk.168 But why should Föhl use
camouflage writing to his "SS comrades"? As I
pointed out to Dr Longerich, Reinhard Heydrich
himself had spoken of the White Sea option on
February 4, 1942 in Prague too.169 It was also noticeable elsewhere that none of
the experts was willing to give documents their
natural meanings when they did not accord with
their views. The Ahnert document, recording a
meeting at the RSHA in Berlin, under Eichmann, on
August 28, 1942, was one example. There was talk of
the need for the deportees to be provided with
blankets, shoes , eating utensils before dispatch
to Auschwitz. Eichmann requested the purchases of
barracks for a Jewish deportee camp to be erected
in Russia, with three to five such barracks being
loaded aboard every transport train. In each case,
because the document did not accord with their
"exterminationist" views, the expert had failed to
pursue it. Dr Longerich who included it as appendix
94 in Die Ermordung der europäischen Juden,
had forgotten it even existed when I cross-examined
him about it.170 
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