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4. JHR Volume 18

A British Historian Defends His Livelihood and Honor

Opening Statement in the London Libel Trial

David Irving

In 1993 a 278-page book called Denying the Holocaust: The Growing Assault on Truth and Memory began appearing in book stores across the United States. In this fervent polemic, author Deborah Lipstadt lashes out against those who dispute Holocaust extermination claims. An entire chapter, packed with distortions and factual errors, is devoted to the Institute for Historical Review. (Journal reviews of the book appeared in the Nov.-Dec. 1993 and Sept.-Oct. 1995 issues.)

Lipstadt also took aim at British writer David Irving — author of some two dozen works of history, several of them best-sellers — calling him a “Holocaust denier” and “one of the most dangerous spokespersons for Holocaust denial.” Her attack against him included demonstrably false statements.

Not confining her anti-revisionist activism to this book. Lipstadt wrote and spoke frequently about the alleged danger to truth itself posed by Holocaust skeptics. She played a role in the vicious campaign that ended with the announcement in early April 1996 by St. Martin’s Press that it was cancelling its scheduled publication of Irving’s eagerly-awaited biography, Goebbels: Mastermind of the Third Reich.

Irving had had enough. Now effectively blacklisted among “mainstream” publishers, he brought a libel suit in London against Lipstadt and Penguin Books, the British publisher of Denying the Holocaust. While such a lawsuit would be virtually unthinkable in the United States, where there is an almost unlimited right to smear any “public figure,” Irving is on much more solid ground in Britain, where libel laws are far tighter.

On January 11, 2000, the trial opened before the High Court of Justice in London. Whereas the 61-year-old Irving appeared representing himself, on opening day some 20 men and women on the defendants' legal team were present in the courtroom.

“At times during his legal battle in the high court, David Irving, a man of natural military bearing, resembles a beleaguered Wehrmacht general in some God-forsaken pocket on the Eastern front, desperately trying to beat off the Jewish-Bolshevik hordes,” remarked one Jewish observer. “He stands or sits alone on one side of the courtroom, while the large defense team occupies most of the rest of it.”

Expected to last three months, the non-jury trial is widely regarded as a major battle about “Holocaust denial” and, more broadly, the Holocaust extermination story. Whereas Irving seeks to keep the trial focused on the narrower issue of libel under British law, the defendants want to make Irving himself, and “the Holocaust,” the central issues. (Much more about the trial, including news reports and texts of important documents, can be found on Irving’s web site: http://www.fpp.co.uk)

The stakes in this case are enormous, not least because the loser almost certainly will be ordered to pay the costs of the winner. The defendants, together with their associated law firms and allied Jewish organizations, have already invested enormous time and money in the case. If Irving loses, he faces complete financial ruin. But a victory by him would be a tremendous boost for freedom of historical inquiry and expression, and an embarrassing setback for the international Holocaust lobby and, more generally, for Jewish-Zionist interests worldwide.

In his opening statement, Irving said that Denying the Holocaust had generated “waves of hatred” against him and gravely harmed his livelihood as a writer. He charged that Lipstadt has been active in an “organized international endeavor” to destroy his career and reputation. Irving has also contended that Lipstadt’s book, far from being the careful work of a serious scholar, is actually the “product of a research contract funded by an Israeli agency.”

Defense attorney Richard Rampton responded by telling the court that Irving “is not an historian at all, but a falsifier of history. To put it bluntly, he is a liar.”

In keeping with its long-standing support for free speech and free historical inquiry, the Institute for Historical Review supports Irving in this legal battle. At the same time, though, we do not necessarily endorse all his views on history — views that, anyway, he has modified over the decades.

Here is the complete text of Irving’s opening statement in the trial. Brief explanatory or elucidating remarks have been added in brackets.

— The Editor

May it please your Lordship, this is my Opening Statement in the matter of David Irving vs. Penguin Books and Deborah Lipstadt. I appear as a litigant in person, and the Defendants are represented by Mr. Richard Rampton and Miss Rogers of counsel and by Mr. Anthony Julius. There were originally three other Defendants, who can be characterized here as booksellers; but your Lordship will observe that they no longer figure in this action, a settlement having been reached.

This is an action in libel arising from the publication by the First Defendant of a book, entitled Denying the Holocaust, written by the Second Defendant, Professor Lipstadt.

As your Lordship is aware, the work complained of has attracted considerable attention, both in this country and in the United States and elsewhere since it was first published in 1993. Your Lordship will have before you my Statement of Claim in which I set out the grounds for my complaint, the consequence of which I am asking that the Defendants be ordered to pay damages of an amount which I will venture to suggest, and I will invite your Lordship issue an injunction against further publication of this work and that the Defendants should make the usual undertakings.

It is almost 30 years to the day since I first set foot in these Law Courts and I trust that your Lordship will allow me to digress for two or three minutes, being (in my submission) something of an historian, on the history of those events; because they are not without relevance to the proceedings upon which we are about to embark.

The occasion of that visit to this building, was an action heard before Mr. Justice Lawton, which became well known to law students as Cassell vs. Broome and Another. It too was a libel action, and I am ashamed to admit that I was the “Another,” having written a book on a naval operation, The Destruction of Convoy PQ.17.

That was the only actively fought libel action in which I became engaged in 30 years of writing. There were two reasons for this abstinence: first, I became more prudent about how I wrote; and second, I was taught to turn the other cheek.

The man who taught me the latter lesson was my first publisher. He had signed up my first book, The Destruction of Dresden, which was eventually published in 1963.

I had been approached in about 1961 by a well known English publisher, Mr. William Kimber. When I visited him in his offices — which were on a site which has long since been buried by a luxury hotel, the Berkeley, in Belgravia — I found him surrounded by files and documents, rather as we are all in this court room today. He wore an air of exhaustion.

Your Lordship may remember that Mr. Kimber and his author Mr. Leon Uris had become involved through a book which Uris had written, entitled Exodus, in a libel action brought by a London doctor who had been obliged to serve at Auschwitz. That case was also heard before Mr. Justice Lawton. There was one other similarity that closes this particular circle of coincidence: like me now, Mr. Kimber was in consequence also obliged to spend two or three years of his life wading, as he put it, “knee-deep” through the most appalling stories of atrocities and human degradation.

That day he advised me never, ever, to become involved in libel litigation. I might add that, with one exception that I shall later mention, I have heeded his advice.

There have since then been one or two minor legal skirmishes, which have not involved much “bloodshed": there was an action against an author, which I foolishly started at the same time as the PQ.17 case and, having lost the latter, was obliged for evident reasons to abandon on relatively painless conditions; and a more recent action against a major London newspaper, who put into my mouth, no doubt inadvertently, some particularly offensive words which had in fact been uttered by Adolf Hitler; that newspaper settled out of Court with me on terms which were eminently acceptable.

I have often thought of Mr. Kimber’s predicament since the 1960s, and more particularly the last three years. I have been plunged into precisely the same “knee-deep” position, ever since I issued the originating writs in this action in September 1996. If I am late with the bundles and papers upon which this Court relies, I can only plead this in mitigation.

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 in anything at all, I may be so immodest as to submit that it is in the role that Adolf Hitler played in the propagation of World War II and in the decisions which he made, and the knowledge on which he based those decisions.

As a peripheral matter to that topic, on which I have written a number of books, I inevitably investigated the extent to which Hitler participated in or had cognizance of the Holocaust. That was the sum total of my involvement as a book author up to the launching of these writs.

Since then, because of the tactics chosen by the Defendants, I have been obliged, willy nilly, to become something of an expert, through no desire of my own. To my utmost distaste it has become evident that it is no longer possible to write pure history, untrammeled and uninfluenced by politics, once one ventures into this unpleasant field.

I have done my best to prepare the case that follows, but I respectfully submit that I do not have any duty to become an expert on the Holocaust; it is not saying anything unknown to this Court, I remind those present that, the Defendants having pleaded justification, as they have, it is not incumbent upon me as the Claimant to prove the wrongness of what they have published. It is for them to prove that what they wrote was true.

I intend to show that far from being a “Holocaust denier,” I have repeatedly drawn attention to major aspects of the Holocaust and have described them, and 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.

It will be found that I selflessly provided copies of the documents, that I had at great expense myself unearthed foreign archives even to my rival historians, as I felt that it was important in the interests of general historical research that [they] should be aware of these documents (I am referring for example to the Bruns Report, which we shall shortly hear; and to the dossier on Kurt [Hans] Aumeier in British files, a dossier which even the Defense Experts admit is one of the most important historical finds, since the writings of Rudolf Höss, the commandant of Auschwitz, were published after the war.

There is one essential plea that I wish to make of this Court; I am aware that the Defendants have expended a considerable sum of money in researching all over again the harrowing story of what actually happened in what they call the Holocaust.

I submit that, harsh though it may seem, the Court should take no interest in that tragedy. The Court may well disagree with me, and show a profound interest in it; but in my submission, we have to avoid the temptations of raking over the history of what happened in Poland or in Russia 50 years ago: what is moot here is not what happened in those sites of atrocities — but what happened over the last 32 years, on my writing desk in my apartment off Grosvenor Square.

To justify her allegations of manipulation and distortion, it will not suffice for Professor Lipstadt to show, if she can, that I misrepresented what happened, but the following: that I knew what happened; and that I perversely and deliberately, for whatever purpose, portrayed it differently from how I knew it to have happened.

That is what manipulation and distortion means, and the other, though fundamental, story of what actually happened is neither here nor there. In effect, this inquiry should not leave the four walls of my study: it should look at the papers that lay before me — and not before some other, magnificently funded researcher or scholar — and at the manuscript that I then produced on the basis of my own limited sources.

My Lord, if we were to seek a title for this libel action, I would venture to suggest “Pictures At An Execution.”

Your Lordship may or may not be aware that I have had a reputation as an historian and as an investigative writer arising from the 30 or so works which I have published in English and other languages over the years since 1961. I am the author of many scores of articles in serious and respected newspapers, including over the years in this country The Daily Telegraph, The Sunday Telegraph, the Jewish Chronicle, the Sunday Express, the Evening Standard, Encounter, and publications of similar repute in Germany, my articles have appeared in newspapers ranging from Die Welt, Die Welt am Sonntag, and magazines and journals like Stern, Der Spiegel, Neue Illustrierte, and Quick.

My books have appeared between hard covers under the imprint of the finest publishing houses. I might mention in this country the imprints of William Kimber, Ltd., Cassell & Co., Ltd., Macmillan, Ltd., Hodder & Stoughton, Penguin and Allen Lane and others. As the Second Defendant is, I understand an American citizen, it might be meritorious for me to add that my works have also been published by her country’s leading publishing houses, too, including the Viking Press; Little, Brown; Simon & Schuster; Holt, Reinhardt, Winston; St Martin’s Press; and a score of no less reputable paperback publishing houses.

Each of those published works by me contained in or near the title page a list of my previous publications and frequently a sample of the accolades bestowed on my works by the leading names of literature and historiography on both sides of the Atlantic.

This happy situation, namely having my works published in the leading publishing houses of the world, ended a year or two ago under circumstances which I shall venture, if your Lordship permits, to set out later in my remarks. Suffice it to say that this very day the Australia/Israel Review has published in Sydney a presumably well-informed article, coming as it does from their corner, which provides one missing link in the circumstances under which St. Martin’s Press finally terminated their contract to publish my book Goebbels: Mastermind of the Third Reich:

… One of the catalysts for the case was Irving’s experience with American publisher St. Martin’s Press, which, after being warned by Lipstadt and others about Irving’s approach to history, then cancelled its agreement to publish Irving’s book Goebbels: Mastermind of the Third Reich in the US.

So these Defendants have done very real damage to my professional existence. May I first of all set out the very real pecuniary damage which can be done to an author by an attack on his reputation. It is not merely that he suffers injury and hurt to his feelings from unjustified attacks, whatever their nature.

An author, by virtue of his trade, lives a precarious financial existence. A tenured professor or other scholar can look forward to a brief career, lengthy vacations, high rewards, and eventually a pension. Perhaps some members of the legal profession enjoy the same fortunate expectations.

A writer leads a much lonelier and more hazardous existence. When he first embarks on his career he may write a string of works that are never published. I was fortunate in this respect; when I first started advertising in The Times in 1961, inviting British airmen who had taken part in the principle operations of Royal Air Force Bomber Command to come forward, among those who contacted me was Mr. William Kimber, a publisher of great repute who himself felt deeply about the ethical questions raised by these saturation bombing operations.

I therefore did not have the usual problem that faces most first-time authors, namely that of crossing the difficult threshold from being an unpublished, to a published author. My first book, The Destruction of Dresden, was serialized by The Sunday Telegraph and attracted much critical acclaim. It was only then that I took the, perhaps fateful, decision to become a writer.

If I may now advance rapidly some 20 or 30 years — and I sense the Court’s relief — I would repeat a brief conversation I had with my accountant, at a time when I was earning more than £100,000 in royalties per year. My accountant, no doubt with his eye on the commission involved, asked what steps I had taken in anticipation of retirement. My immodest reply was that I did not intend to retire, and when he murmured something about pensions, I replied that my books were my pension fund.

If I may explain that remark: if an author has written a good book it will be published and republished, and on each occasion a fresh ripple of royalties reaches the author’s bank account. Admittedly the ripples become smaller as the years recede, but if he has written enough books in his 30 or 40 years of creativity then the ripples together make waves large enough to sustain him into and beyond the years of retirement. Indeed, they should also provide something of a legacy for his children, of whom I still have four.

That situation no longer obtains.

By virtue of the activities of the Defendants, in particular of the Second Defendant, and of those who funded her and guided her hand, 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.

In private, the senior editors at those publishing houses still welcome me warmly as a friend, invite me to lunch in expensive New York restaurants — and then lament that if they were to sign a contract with me on a new book, there would always be somebody in their publishing house who would object. Such is the nature of the odium that has been generated by the waves of hatred recklessly propagated against me by the Defendants.

In short my “pension” has vanished, as assuredly as if I had been employed by one of those companies taken over by the late Mr. Robert Maxwell.

I am not submitting that it is these Defendants alone who have single-handedly wrought this disaster upon me. I am not even denying that I may have been partly to blame for it myself.

Had I written books about the Zulu Wars, as the Air Ministry earnestly advised me in 1963, when my book The Destruction of Dresden was first published, I would no doubt not have faced this hatred.

Unfortunately, World War II became my area of expertise; I generated a personal archive of documents, a network of sources and contacts, a language ability, and a facility to research in foreign archives, and eventually a constituency of readers who expected and wanted me to write only about the Third Reich and its criminal leadership.

What obliges me to make these sweeping opening remarks, is that I shall maintain 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. I have seen the papers. I have copies of the documents. I shall show them to this Court. I know how they did it, and I now know why.

Nearly all of these villains acted beyond the jurisdiction of these Courts. Some of them however acted within, and I have on one disastrous occasion tried to proceed against them too.

I mention here and, only in a few words, that one example: as the Court will no doubt hear, I was expelled in the most demeaning circumstances from Canada in November 1992. I need not go into the background of that event here, but I shall certainly do so later if in their attempts to blacken my name further, the Defendants indulge in that exercise in this Court.

Seeking to establish why Canada — a friendly government — a country which I had entered unhindered for 30 years or more, should suddenly round upon me as savagely as a rottweiler, I used all the appliances of Canadian law to establish what had gone on behind closed doors.

I discovered in the files of the Canadian government, using that country’s Access to Information Act, a mysterious and anonymous document blackening my name which had been planted there for the purpose of procuring precisely the ugly consequence that had flowed from it in 1992.

Among the stupid lies that this anonymous document contained about me, was the suggestion that I had married my first wife because she was “the daughter of one of General Francisco Franco’s top generals,” in order to ingratiate myself with the Spanish fascist regime. Another suggestion was that I lived too well for an author (I have lived for over 32 years in the same house off Grosvenor Square in Mayfair) — that to sustain such a level of living purely from my income as an author was impossible; the implication being that I was receiving secret checks from Nazi fugitives in South America.

I telephoned my first wife to ask her what her father had been, and she reminded me that he was an industrial chemist, a dedicated enemy of the regime after two of his brothers had been shot by Franco’s men.

It took over a year to establish beyond doubt who was the author of this infamous document. Eventually it turned out to have been provided secretly to the Canadian government by an unofficial body based in London, whose name I do not propose to state in this Court here, as they are not formally represented in this action [identified out of court as the Board of Deputies of British Jews].

Suffice it to say that when I applied to a judge in chambers for leave to take libel action out of time, the culprits made no attempt to justify their libels, but pleaded that the Statute of Limitations had run; which plea was allowed, though with regret, by Mr. Justice Toulson. The mendacious body concerned then had the temerity to pursue me to the threshold of the Bankruptcy Court for the legal costs that it had incurred in that one day hearing, amounting to over £7,500. It is a rough life, being an independent author.

This brings us to the present case. In 1993 the First Defendant, as they allow in their witness statements, published Denying the Holocaust, the work complained of, within the jurisdiction, written by the Second Defendant.

The book purports to be a scholarly investigation of the operations of an international network conspiracy of people whom the Second Defendant has dubbed “Holocaust deniers.” It is not. The phrase itself, which the Second Defendant prides herself on having coined and crafted, appears repeatedly throughout the work, and it has subsequently become embedded in the vernacular of a certain kind of journalist who wishes to blacken the name of some person, where the more usual rhetoric of neo-Nazi, Nazi, racist, and other similar epithets is no longer deemed adequate. Indeed, the phrase appears over 300 times in just one of the Defendants' experts reports!

It has become one of the most potent phrases in the arsenal of insult, replacing the N-word, the F-word, and a whole alphabet of other slurs. If an American politician, like Mr. Patrick Buchanan, is branded even briefly a “Holocaust denier,” his career can well be said to be in ruins. If a writer, no matter how well reviewed and received until then, has that phrase stuck to him, then he too regard his career as rumbling off the edge of a precipice.

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 past century.

The word “denier” is particularly evil: because no person in full command of his mental faculties, and with even the slightest understanding of what happened in World War II, can deny that the tragedy actually happened, however much we dissident historians may wish to quibble about the means, the scale, the dates and other minutiae.

Yet meaningless though it is, the phrase has become a part of the English language. It is a poison to which there is virtually no antidote, less lethal than a hypodermic with nerve gas jabbed in the neck, but deadly all the same: for the chosen victim, it is like being called a wife beater or a pædophile. It is enough for the label to be attached, for the attachee to find himself designated as a pariah, an outcast from normal society. It is a verbal Yellow Star.

In many countries now where it was considered that the mere verbal labelling was not enough, governments have been prevailed upon to pass the most questionable laws, including some which can only be considered a total infringement of the normal human rights of free speech, free opinion and freedom of assembly.

Germany has not had an enviable reputation in any of these freedoms over the last century. True to form, in Germany it is now a criminal offense to question the mode, the scale, the system, or even the statistics of the Holocaust. No defense is allowed. Some good friends of mine, I have no hesitation in allowing to this Court, are sitting at this very moment in German prisons for having ventured to voice such questions.

In France the situation is even more absurd: any person found guilty in France, under a new law aptly named an “amendment of the law on the freedom of the Press” finds himself fined, or imprisoned, or both. This law, passed in 1991, makes it a criminal offense to challenge (the French word is contester) any war crimes or crimes against humanity “as defined by the Nuremberg Statute” of 1945.

Fifty years on, it has become a criminal offense to question whether Nuremberg got it right. History is to be as defined by the four victorious powers in the Nuremberg trials of 1945-1946.

I respectfully submit and would, indeed, hope that your Lordship would find such laws, if enacted in this country, to be utterly repugnant. For that same reason I have no hesitation in saying that some more good friends of mine have been fined under precisely this French law. Indeed, in 1993 or 1994, I myself was fined the sum of £500 by a Paris court under this law: I had given an interview to a French journalist in the study of my home in London; this interview was published in a reputable journal, there were complaints in Paris; and I was summoned before the French magistrates, and fined along with the publisher, editor and journalist concerned for having given this interview. It is indeed a very sorry state of affairs.

We may hear the word “conspiracy” uttered during the next few days and weeks. If there has been a conspiracy, it is a conspiracy against free speech.

I might mention that my father fought as an officer in the Royal Navy in both wars, both in the Battle of Jutland in 1916 and in the Arctic convoys of 1942, and that both my brothers have served in the Royal Air Force. My father was an arctic explorer between the wars, and admiralty charts show two island points in the South Sandwich Islands named after him and his first officer, my uncle.

I come from a service family and I find it odious that at the end of the twentieth century writers and historians going about their own respective businesses, writing books that may indeed have been completely wrong have found themselves suddenly and vicariously threatened with imprisonment or with crippling fines for having expressed opinions on history which are at variance with these new freshly enacted laws, which have been introduced at the insistence of wealthy pressure groups and other enemies of the free speech for which we fought two World Wars in this country.

Your Lordship will undoubtedly hear from the Defendants that I was fined a very substantial sum of money by the German government under these witless new laws. It is no matter of shame for me, although it has had catastrophic consequences, as it now makes me de facto “a convict,” with a criminal record, and as such liable to a concatenation of further indignities and sanctions in every foreign country which I now wish to visit.

The circumstances: I may say here quite briefly that on April 21, 1990, nearly ten years ago, I delivered an address, quite possibly ill-judged, to an audience at a hall in Munich.

When one agrees to attend such functions, one has little way of knowing in advance what kind of audience one will be addressing, and one has no control over the external appearance of the function. I make no complaint about that.

Your Lordship will hear, that in the course of my speech, of which apparently no full transcript in survives, I uttered the following remark:

“We now know that the gas chamber shown to the tourists at Auschwitz is a fake built by the Poles after the war, just like the one established by the Americans at Dachau.”

This may well raise eyebrows. It might be found to be offensive by sections of the community, and if they take such offense, I can assure this Court that I regret it and that such was not my intention. The fact remains that these remarks were true, the Poles admitted it (in January 1995) and under English law truth has always been regarded as an absolute defense.

We shall hear, indeed from the Defense’s own expert witnesses, though perhaps the admission will have to be bludgeoned out of them, that the gas chamber shown to the tourists at Auschwitz was indeed built by the Polish Communists three years after the war was over.

I do not intend to go into the question of whether or not there were gas chambers at Birkenau, some five miles from Auschwitz, in these opening remarks. By the time this trial is over we shall probably all be heartily sick of the debate, which has little or no relevance to the issues that are pleaded.

So what are the issues that are pleaded and how do I propose to address those issues in opening this case?

First, let me emphasize that I also have no intentions, and neither is it the purpose of this trial, to “refight World War II.” I shall not argue, and have never argued, that the wrong side won the war, for example; or that the history of the war needs to be grossly rewritten. I must confess that I am mystified at the broad thrust which the Defendants have taken in the vast body of documentation which they have served upon this Court — another 5,000 pages were delivered to me on Friday evening, and more last night.

It is all something of an embarrassment to me, and I am being forced into positions that I have not previously adopted. I have never claimed to be a Holocaust historian. I have written no book about the Holocaust. I have written no article about it. If I have spoken about it, it is usually because I have been questioned about it. On such occasions, I have emphasized my lack of expertise, and I have expatiated only upon those areas with which I am familiar. In doing so, I have offended many of my friends, who wished that history was different. But you cannot wish documents away, and it is in documents that I have always specialized as a writer.

Your Lordship will find upon reviewing my various printed works that I have very seldom used other peoples' books as sources. I have found it otiose and tedious, not only because they are ill-written, but also because in reading other peoples' books you are liable to imbibe the errors and prejudices with which those books are beset.

If however, you go to the original documents, you will often find to your joy that the weight of documents you have to read is, pound for pound, or indeed ton for ton, less than the weight of books that you might otherwise have to read upon the same subject. And you are kilometers closer to the original real history.

As for the nature of documents: I remember that in 1969 I visited Professor Hugh Trevor Roper, who is now Lord Dacre and I am glad to say still with us. He very kindly made available to me his collection of several thousand original intelligence documents for my biography of Adolf Hitler, but in doing so he advised me as follows: when considering new documents, you should ask yourself three questions: and if I remember correctly, those three criteria were,

1. Is the document genuine? (possibly, in the light of the “Hitler Diaries” scandal, an unfortunate pre-requisite in this case)
2. Is the document written by a person in a position to know what he is talking about? and
3. Why does this document exist?

The latter is quite interesting, as we have all experienced, in the archives, coming across documents obviously written for window-dressing or for buck passing purposes.

It is the documents in this case which I think the Court will find most interesting and illuminating. And by that I mean documents at every level. The Court will have to consider not only the documents originating in World War II on both sides, but also the documents that have been generated by that painful process known as Discovery.

It will not escape the Court, my Lord, when the time comes, that like many personalities, I have kept the most voluminous records throughout my career as a writer, and indeed even before it. Along with my writing career I kept a diary; sometimes I wondered why, but I think that the reason was basically this — if you are a writer, and self-employed, you need the discipline that a diary imposes upon you. You cannot in conscience enter in a diary at the end of the day: “I did nothing all day.”

Your Lordship will be amused no doubt to hear that at one stage in the Discovery process in this action, at the request of Mr. Julius, I readily agreed to make available to the Defense my entire diaries, in so far as they still exist (a few pages are missing); and that Mr. Julius only then learned that these diaries occupy a shelf eight feet long; and that in them there are approximately there are probably 10 or 20 million words to be read.

Mr. Julius and his staff have, however, risen most nobly to the challenge that these pages presented, and I am sure that over the next few days and weeks we shall be hearing more than one morsel that they have dredged out if these pages. They will hold it aloft, still dripping with something or other, and read it to this Court with a squeal of delight, proclaiming this to be the Philosopher’s Stone that they needed to justify their Client’s libels all along. We shall see.

But that is not what this trial is all about.

This trial is not really about what happened in the Holocaust, or how many Jews and other persecuted minorities were tortured and put to death. This Court will, I hope, agree with me when the time comes that the issue before us is not what happened, but how I treated it in my works of history: it may be that I was totally ignorant on some aspects of World War II (and I hasten to say that I do not believe I was). But to be accused of deliberate manipulation, and distorting, and mistranslating is perverse: the Defendants must show, in my humble submission,

1. that a particular thing happened or existed,
2. that I was aware of that particular thing, as it happened or existed, at the time I wrote about it, from the records then before me;
3. that I then wilfully manipulated the text or mis-translated or distorted for the purposes that they imply.

I will submit that in no instance can they prove this to be the case. They certainly have not done so in the documents so far pleaded.

I readily concede that what I have read of the reports submitted by the Defendants' experts, particularly those of the historians, is of the utmost interest. I have to congratulate Professor Jan van Pelt, for the literary quality of his lengthy report on Auschwitz, which will no doubt eventually see general circulation in the bookstores: indeed, I congratulated him three years ago already on the first book that he published on this topic.

I admit too that there are documents contained in the expertise of Professor Browning of which I was not aware, and which have changed my own perception of some aspects of the Nazi atrocities on the Eastern front: for example, I was not aware that the SS Obergruppenführer Reinhard Heydrich had issued instructions to his commanders in the Baltic States, after Operation Barbarossa began in June 1941, not only to turn a blind eye upon the anti-Jewish pogroms started by the local populations in those countries, but also actively to initiate them and to provide assistance.

This document, however, emerged only recently from the Russian archives and there can surely be no reproach against me for not having known that when I wrote my biography of Hitler, published in 1977, or in my later works. That cannot be branded as manipulation or distortion.

What is manipulation or distortion of history would be, in my submission this: knowing of the existence of a key document and then ignoring it or suppressing it entirely, without even a mention.

If, for example, it should turn out, and be proven in this very Courtroom, that in the spring of 1942 the Nazi leader Adolf Hitler was quoted by a senior Reich Minister, in writing, as repeatedly saying that he “wanted the final solution of the Jewish problem postponed until the war is over"; and if the document recording those remarkable words has been found in the German archives; it would surely be classifiable as manipulation or distortion if a historian were to attempt to write the history of the Holocaust without even mentioning the document’s existence? Would it not, my Lord?

The Defendants have, as said, arbitrarily and recklessly decided to label me a “Holocaust denier” — their motivation for doing so we shall shortly hear about. My Lord, before I continue to address this point in my opening statement, may I take this opportunity to read to the Court, and into the public records, a two-page document, which I shall refer to as the Walter Bruns interrogation. I do so because perceptions matter, and I want at this late afternoon hour to leave a firm perception in the minds of all those present. It is a document which first came into my hands some time before 1985.

I should say, my Lord, by way of introduction, that this document, which is in my Discovery, was originally a British Top-Secret document. Top Secret is only one rung lower than Ultra Secret, the classification given to the British decoded intercepts. It was Top Secret, because it is the record of an interrogation which was obtained by methods that were illegal, I understand, under the Conventions.

Enemy prisoners of war were brought into British prison camps, treated lavishly, well-fed, reassured by their relaxed surroundings, and gradually led into conversation, unaware that in every fitting and appliance in the room were hidden microphones capable of picking up. (That was the illegality: you are not allowed to do that under the [Geneva] Conventions.) Released to the British archives only a few years ago were all of these reports, but I had already obtained several hundred 15 or 20 years earlier. I consider these transcripts to be a historical source which, if properly used and if certain criteria are applied, can be regarded as part of the bedrock of real history.

I would say further by way of preamble, my Lord, that the speaker whose recorded voice we are about to hear, as reproduced in this typescript, was on November 30, 1941, the day of the episode he narrates, a Colonel in the German Army Engineers force (the sappers, or Pioniere); he was commanding a unit based at Riga, the capital of Latvia. He had learned to his vexation that it was intended by the local SS unit to round up all the local Jews, including “his Jews” in the next day or two and to liquidate them.

I read from the document itself. It is headed: “Top secret. CSDIC (UK)” which is Combined Services Detailed Interrogation Center UK. “GG Report. If the information contained in this report is required for distribution, it should be paraphrased so that no mention is made of the prisoners' names, nor of the methods by which the information has been obtained” because, of course, it was illegal.”

“The following conversation took place between General-Major Bruns,” his full name was Walter Bruns. At this time he was at the Heeres-Waffenmeisterschule which was an army school, an armament school, in Berlin, “captured at Gottingen on April 8th 1945, and other Senior Officer Prisoners of War whose voices could not be identified.” In other words, it is a conversation between this General and various other prisoners overheard by hidden microphones on April 25th, 1945. “Information received: 25 April 1945,” in other words, the war is still running.

Translation: “Bruns: As soon as I heard those Jews were to be shot on Friday, I went to a 21-year-old boy and said that they had made themselves very useful in the area under my command, besides which the Army MT park had employed 1500 and the 'Heeresgruppe' 800 women to make underclothes of the stores we captured in Riga; besides which about 1200 women in the neighborhood of Riga were turning millions of captured sheepskins into articles we urgently required: ear protectors, fur caps, fur waistcoats, etc. Nothing had been proved, as of course the Russian campaign was known to have come to a victorious end in October 1941!” Sarcasm there. “In short, all those women were employed in a useful capacity. I tried to save them. I told that fellow Altenmeyer(?) whose name I shall always remember and who will be added to the list of war criminals: 'Listen to me, they represent valuable manpower!' 'Do you call Jews valuable human beings, sir?'” That was the answer. “I said: 'Listen to me properly, I said valuable manpower. I didn’t mention their value as human beings'. He said: 'Well, they're to be shot in accordance with the Führer’s orders!' I said: 'Führer’s orders?' 'Yes', whereupon he showed me his orders. This happened at Skiotawa(?) eight kilometers from Riga, between Siaulai and Jelgava, where 5,000 Berlin Jews were suddenly taken off the train and shot. I didn’t see that myself, but what happened at Skiotawa(?) — to cut a long story short, I argued with the fellow and telephoned to the General at HQ, to Jakobs and Aberger(?) and to a Dr. Schultz who was attached to the Engineer General, on behalf of these people.” It is a bit incoherent the way that people talk when they are gossiping with each other. “I told him: 'Granting that the Jews have committed a crime against the other peoples of the world, at least let them do the drudgery; send them to throw earth on the roads to prevent our heavy lorries skidding'. 'Then I'd have to feed them!' I said: 'The little amount of food they receive, let’s assume 2 million Jews — they got 125 grams of bread a day — we can’t even manage that, the sooner we end the war the better'. Then I telephoned, thinking it would take some time. At any rate, on Sunday morning,” that is November 30th 1941, “I heard that they had already started on it. The Ghetto was cleared. They were told: 'You're being transferred: take along your essential things.' Incidentally, it was a happy release for those people, as their life in the Ghetto was a martyrdom. I wouldn’t believe it and drove there to have a look.” The person he is talking to says: “Everyone abroad knew about it; only we Germans were kept in ignorance.”

Bruns continues his narrative: “I'll tell you something: some of the details may have been correct, but it was remarkable that the firing squad detailed that morning — six men with tommy-guns posted at each pit; the pits were 24 meters in length and three meters in breadth — they had to lie down like sardines in a tin with their heads in the center',” like that in the pit.

“'Above them were six men with tommy-guns who gave them the coup de grace,” who shot them. “When I arrived those pits were so full that the living had to lie down on top of the dead; then they were shot and, in order to save room, they had to lie down neatly in layers. Before this, however, they were stripped of everything at one of the stations — here at the edge of the wood were the three pits they used that Sunday and here they stood in a queue one and-a-half kilometers long which they approached step by step — a queuing up for death. As they drew nearer they saw what was going on. About here they had to hand over their jewellery and suitcases. All good stuff was put into the suitcases and the remainder was thrown on a heap. This was to serve as clothing for our suffering population — and then a little further on they had to undress and, 500 meters in front of the wood, strip completely; they were only permitted to keep on a chemise or knickers. They were all women and small two-year old children. Then all those cynical remarks! If only I had seen those tommy-gunners, who were relieved every hour because of over-exertion, carry out their task with distaste, but no, nasty remarks like: 'Here comes a Jewish beauty!' I can still see it all in my memory: a pretty woman in a flame-coloured chemise. Talk about keeping the race pure: at Riga they first slept with them and then shot them to prevent them from talking.

“Then I sent two officers out there, one of whom is still alive,” in April 1945, “because I wanted eyewitnesses. I didn’t tell them what was going on, but said: 'Go out to the forest of Skiotawa(?), see what’s up there and send me a report'. I added a memorandum to their report and took it to Jakobs myself. He said: 'I have already two complaints sent me by Engineer “Bataillone” from the Ukraine'. There they shot them on the brink of large crevices and let them fall down into them; they nearly had an epidemic of plague, at any rate a pestilential smell. They thought they could break off the edges with picks, thus burying them. That loess there” — that is a kind of ground — “was so hard that two Engineer 'Bataillone' were required to dynamite the edges; those 'Bataillone' complained. Jakobs” — he was the engineer general in charge of the pioneer corps — “had received that complaint. He said: 'We didn’t quite know how to tell the Führer',” Adolf Hitler. “'We'd better do it through Canaris', the Chief of the German Intelligence. “So Canaris had the unsavoury task of waiting for the favourable moment to give the Führer certain gentle hints. A fortnight later I visited the Oberburgermeister, or whatever he was called then, concerning some over business. Altenmeyer(?)” who was the SS man on the spot “triumphantly showed me: 'Here is an order just issued, prohibiting mass shootings on that scale from taking place in future. They are to be carried out more discreetly'. From warnings given me recently, I knew that I was receiving still more attentions from spies.”

Then his interlocutor says to him: “It’s a wonder you're still alive.” Bruns says: “At Göttingen, I expected to be arrested every day.”

My Lord, permit me a word about the credentials of that particular document. It is authentic. It comes from the British archives. A copy can be found in the Public Record Office this very day if anyone wishes to go and see it. First: is the General describing something he had really seen?

I mention this because later, on his sworn oath in the Witness stand in Nuremberg, he claimed only to have heard of this atrocity. Yet there can surely be no doubt of the verisimilitude: it does not take university level textual analysis to realize that if a General says, “I can see her in my mind’s eye now, a girl in a flame-red dress,” this is a man who has been there and seen it with his own eyes.

This document has in my submission considerable evidentiary value. It is not self-serving. The General is not testifying in his own interest. He is merely talking, probably in a muffled whisper, to fellow prisoners at a British interrogation center, and he has no idea that in another room British experts are listening to and recording every word. We also have the original German text of this document I might add, my Lord.

To what purpose do I mention this? Well, firstly because I shall, later on in these proceedings, add further unknown documents, from the same superb British archives — that is, the Public Records Office — to the events of this one day, documents which show Hitler taking a most remarkable stand on this atrocity.

But I also adduce this document for the following reason:

• if an historian repeatedly refers to this document;
• if he quotes from it;
• if he immediately writes showing it to fellow historians, both Jews and non-Jews alike, and in writing draws their attention to the existence of this document, and its fellow documents, all of which were hitherto unknown to them;
• if moreover that historian reads out this document in public, with its awful, infernal descriptions of the mass killings of Jews by the Nazis on the eastern front, on multiple speaking occasions;
• if this historian, speaking to audiences even of the most extreme hues of left and right, heedless as to their anger, insists on reading out the document in full, thus “rubbing their noses in it” so to speak; and
• if he continues to do so over a period of 15 years, again and again, right up to the present date, and
• if he quotes that document in the text, and references that document in the footnotes of all his most recent works, beginning with the Hitler’s War biography republication in 1991, through Goebbels: Mastermind of the Third Reich in 1996 and Nuremberg, the Last Battle in 1997:

Then — is it not a libel of the most grotesque and offensive nature to brand that same historian around the world as a “Holocaust denier,” when he has not only discovered and found and propagated this document and brought it to the attention of both his colleagues and his rivals and his foes, regardless of their race or religion, and to countless audiences? [Irving cited and quoted from this document, for example, at the Eleventh IHR Conference, October 1992. See the March-April 1993 Journal, pp. 23-35, and the July-August 1995 Journal, p. 46.]

This is not an isolated example, my Lord. In the introduction to my biography of Adolf Hitler, Hitler’s War, which was published by The Viking Press in America and by Hodder & Stoughton in the United Kingdom and later by Macmillan, we shall find that I have drawn specific and repeated attention of the reader to the crimes that Adolf Hitler committed.

How did all this happen? 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 disfavor.

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 favors 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 20 or 30 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. [sic]

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 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 a 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 perplexing and irritating because it all 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 now I 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 realize why and I do not fully realize why even today. Whatever the reason, their journalists were in the spearhead of the attack on me. As other books appeared, this polarization 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, very Jewish, but a very Christian kind of a Jew — rather like Jesus Christ.”

It is the kind of inexplicable sentence that one remembers even now nearly 40 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 me 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 look at briefly over the next few days, if your Lordship pleases.

So it became gradually evident — and I have to emphasize that I cannot pin down any particular year in which I finally realized that I was being victimized 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 already begun 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! (Perhaps I ought to add that there is no secret correspondence with 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 30 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 rumors about my activities and alleged “Nazi” connections around the world, in an attempt to blacken my name.

I will not say that the rumors are all untrue. They never are. Mr. Winston Churchill once famously said, “The world is full of the most dreadful stories and rumors about me, and the damnable thing about them is that most of them are true!” At least, so rumor 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 labor the reasons why, in this opening statement. Suffice it to say that I had already realized 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 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 programs. It failed, the program 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 unsavory 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 30 years as an honored 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 naive, 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 caliber.

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 II: 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 [Institute for Contemporary History] 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 München-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 200 letters which this murderous Nazi wrote to his mistress, and these contain material of much larger historical importance.

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 I hope is 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 30 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 20 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.

Twenty-five years later, I had the conversation which was to lead the retrieval of the Goebbels diaries in Moscow, and indirectly to our presence here in these Courts today.

In May 1992, I invited a long-time friend, a leading historian at the Institut für Zeitgeschichte, to have lunch with me at a restaurant in Munich. We had been good friends since 1964, and she is still in the Institute’s employ today. As my diaries show, this friend and colleague, Dr. Elke Fröhlich, had dropped several hints during the previous twelve months that she had traced the whereabouts of the missing Goebbels diaries.

We all knew, those of us who had engaged in research in Hitler, Goebbels, and the Third Reich, that Dr. Goebbels had placed these diaries on microfiches — photographic glass plates — in the closing months of the War, to ensure that they were preserved for posterity. But they had vanished since then. His Private Secretary, Dr. Richard Otte, whom I had questioned over 20 years earlier in connection with our search in the forest in East Germany, had told us about these glass plates. I should mention that he was one of the small burial party who had hidden the jar, but he was unable to accompany us, as at that time he was still in West German government employment. We could only presume that the glass plate microfiches were either destroyed in the last weeks of the war, or that they had been seized by the Red Army.

During this lunchtime conversation in Munich in May 1992, Dr. Elke Fröhlich revealed to me that the latter supposition was correct. She had seen them herself a few weeks previously — had held them in her hands! — on a visit to the archives in Moscow.

My recollection of the conversation at this point is, that she continued by saying that the Institute’s directors were unwilling to fund a further expedition to procure these diaries.

Now that I have seen some of the documentation provided to the defendants in this action by the Russians and by the Institute, it is possible that my recollection on this point is wrong, namely, that the Institute were not willing to pay for it.

My recollection of the following is however secure: Dr. Fröhlich informed me that the director of the Russian “trophy” archives, as they were known, Dr. Bondarev, was in a serious predicament, as he was faced with the economic consequences of the collapse of the Soviet empire; he no longer had the means necessary for the upkeep of the archives and the payment of his staff.

The plates, in my view, were seriously at risk. Dr. Fröhlich indicated that if I were to take a sufficient sum of foreign currency to Moscow, I could purchase the glass plates from Dr. Bondarev. It was clear from her remarks that Dr. Bondarev had already discussed this prospect with her.

Dr. Fröhlich added that the glass plates were in a fragile condition and needed to be rescued before they came to serious harm. I recall that she said “If you are going to this deal with the Russians, you will have to take a lot of silk paper with you from England, to place between the glass plates. The plates are just packed into boxes — with nothing between them.”

I asked how much money we were talking about, and either she or I suggested a figure of 20,000 US dollars. I immediately contacted my American publishers in New York, who seemed the most immediate source of money; I informed them of this likely windfall, and asked if we could increase the cash advance on my Goebbels manuscript accordingly.

My manuscript of the Goebbels biography was at that time complete, and undergoing editing by myself. It was already ready for delivery to the publishers.

The American publishers responded enthusiastically at first, and upon my return from Munich to London I began negotiations through intermediaries with the Russian archivist Dr. Bondarev. (Dr. Bondarev will not, unfortunately, be called by either party in this action; he seems to have vanished, and is certainly no longer employed by the “trophy” archives.)

The first intermediary I used was a Russian-language specialist employed by Warburg’s Bank in Moscow; he undertook the preliminary negotiations with Dr. Bondarev. I instructed him to tell Bondarev as openly as was prudent of my intention to come and look at the glass plates, and also to make it quite plain that we were coming with a substantial sum of hard currency. Many American institutions were currently engaged in the same practice, as I knew from the newspapers.

At about this time it became plain that the German government was also keen to get its hands on these glass plates. Naturally I desired to beat them to it: first, because of professional pride, and the desire to have a historical scoop; and secondly, years of working with the German government archives had proven both to me and many scholars that as soon as high-grade documents like these dropped into their hands they vanish for many years while they were assessed and catalogued and indexed; and sometimes they were even squirreled away for later exploitation by the chief archivists themselves (the “Hossbach Papers” were one case in point).

These vital Nazi diaries would therefore vanish from the public gaze possibly for five or ten years; my fears in this respect had been amply confirmed by events, because many of those glass plates which I saw in Moscow in 1992 have since vanished into the maw of the German government and the Munich Institut für Zeitgeschichte and they are still not available even now.

I considered therefore that I should be rendering to the historical community the best service by doing the utmost that I could to extract those glass plates, or failing that copies of them, or failing that copies of the maximum number of pages possible, by hook or by crook, from the KGB archives before a wind of change might suddenly result in the resealing of all these former Soviet archives (and once again this apprehension has been largely confirmed by the attitude of the Russian archive authorities, who have resealed numbers of these files and made them once again inaccessible to Western historians).

The second intermediary upon whom I relied was the former KGB Officer, Lev Bezymenski. I have known Mr. Bezymenski for about 35 years, and over these years we have engaged in a fruitful exercise of exchanging documents: I would hasten to add that the documents which I furnished to Mr. Bezymenski were entirely of a public-domain nature: Mr. Bezymenski in return extracted from Soviet archives for me vital collections of documents, for example, their diplomatic files on Sir Winston Churchill, and the private papers of the commander-in-chief of the German Army, Colonel-General Werner von Fritsch. From the Russian archives I obtained, via Mr. Bezymenski, Fritsch’s personal writings during and about the “Blomberg-Fritsch scandal” of 1938, which had historic consequences for Germany, for Hitler and ultimately for the world. I immediately donated a complete set of those Fritsch papers to the German government archives, where they can still be seen.

Dr. Bezymenski proved unfortunately to be something of a “double agent.” Fearing that Dr. Bondarev was not properly getting my message, I asked Mr. Bezymenski to approach him, and to inform him that there were certain documents he held in which I was interested, and that I was coming as a representative of the Sunday Times, well armed with foreign currency. Mr. Bezymenski inquired what those documents were; I refused to tell him, and he replied, “You are referring to the Goebbels diaries I presume.”

This I affirmed. Ten minutes after this telephone conversation from me in London to Mr. Bezymenski in Moscow, I received a telephone call from Dr. Fröhlich in Munich, complaining very bitterly that I had revealed our intentions to Mr. Bezymenski. Instead of acting as I had requested, my friend had immediately sent a fax to the Institut für Zeitgeschichte to alert them to what I was “up to.” This set the cat among the pigeons, and the Institut für Zeitgeschichte left no stone unturned to prevent the Russians from providing me with the diaries or other materials, for reasons which this Court can readily surmise.

I had in the meantime approached the Sunday Times after my American publishers got cold feet, and I had succeeded in persuading Mr. Andrew Neil that I could obtain The Goebbels Diaries from the Moscow archives, and that I was by chance one of the very few people capable of reading that handwriting.

Two years previously, in 1990, my Italian publisher, Mondadori, had commissioned me to transcribe the hand-written 1938 diary volume of Dr. Goebbels, a copy of which they had purchased from a Russian source. I was thus acquainted with the difficult handwriting of the Nazi propaganda minister. At that time there were probably only three or four people in the world who were capable of deciphering it.

The negotiations with Andrew Neil proceeded smoothly. He did express at one stage nervousness at the prospect of entering into another “Nazi diaries” deal — his newspaper group having been made to look foolish for its purchase and publication in 1983 of the forged “Hitler Diaries.” I pointed out that I had warned them in writing months ahead, in 1982, that the diaries were fakes. I added “I am offering the Sunday Times the chance to rehabilitate itself!”

Armed with the prestige and the superior financial resources of the Sunday Times I went to Moscow in June 1992, and negotiated directly with Dr. Bondarev and his superior, Professor Tarasov, who was at that time the overall head of the Russian Federation Archival System.

Dr. Bondarev expressed willingness to assist us, although there could no longer be any talk of the clandestine purchase of the plates which we had originally hoped for, since Mr. Bezymenski had let the cat out of the bag. I say “clandestine,” but I understand that the same archives sold off many other collections of papers, for example to the Hoover Institution in California, and to US publishing giants, and to my colleague the late John Costello. But my own little deal was not to be.

Professor Tarasov is one of the witnesses in this case, my Lord, and your Lordship will be able to study the documents exhibited by him to his Witness Statement; I confess that I fail to see the relevance of very many of them, but no doubt we shall see that difficulty removed by Mr. Rampton in due course.

The Moscow negotiations were not easy. We negotiated with Professor Tarasov for access to the glass plates. The negotiations were conducted in my presence by Mr. Peter Millar, a freelance journalist working for the Sunday Times, who spoke Russian with a commendable fluency. He will also be giving evidence in this action. With my limited “O"-level Russian, I was able to follow the gist in conversation and also to intervene, speaking German, after it emerged that Professor Tarasov had studied and taught for many years at the famous Humboldt University in Communist East Berlin.

By now both Dr. Bondarev and Tarasov were aware, if they had not been aware previously, that these Goebbels diaries were of commercial and historical value. The negotiations took longer than I had expected.

I produced to Professor Tarasov copies of the Soviet edition of my books, which had been published years earlier, and I donated to him, as well as later to the Archives staff, copies of my own edition of the biography Hitler’s War.

This established my credentials to their satisfaction, and Tarasov gave instructions that we were to be given access to the entire collection of the 'Dr. Goebbel’s diaries.'

It was quite evident to me, when I finally saw the glass plates, that the diaries had been hardly examined at all. It seemed to me, for example, from the splinters of glass still trapped between the photographic plates, that there had been little movement in the plates for nearly 50 years; the boxes were the original boxes, the brown paper around them in some parts was still the original brown paper. The plates were in total disarray and no attempt had been made to sort them. I have seen no work of history, Soviet or otherwise, that has quoted from them before I got them.

My excitement as an historian, getting my hands on original material like this, can readily be imagined.

There is now a dispute as to the nature of the Russian permission — and this alleged agreement is one of the issues pleaded by the Defendants in this action.

It is difficult for me to reconstruct seven years later precisely whether there was any verbal agreement exceeding a nod and a wink, or what the terms were, or how rigid an agreement may have been reached. There is no reference to such an agreement in my contemporary diaries. Certainly the Russians committed nothing to paper about such an agreement. Professor Tarasov’s word was law, and he had just picked up the phone in our presence and spoken that word to Bondarev.

My own recollection at the time was that the arrangement was of a very free-wheeling nature, with the Russians being very happy, and indeed proud, to help us in the spirit reigning at that time of glasnost and perestroika, and extreme co-operativeness between West and East; they were keen to give us access to these plates, which they had hitherto regarded as not being of much value. Tarasov did mention that the German government were also interested in these plates, and that they were coming shortly to conduct negotiations about them.

I remember clearly, and I think that this is also shown in the diary which I wrote on that day, that Tarasov hesitated as to whether he should allow us access without first consulting the German authorities; I rather mischievously reminded Dr. Tarasov of which side had won the war, and expressed astonishment that the Russians were now intending to ask their defeated enemy for permission to show to a third party records which were in their own archives, and this unsubtle argument appears to have swayed him to grant us complete access without further misgivings.

There was no signed agreement, either between the Russian authorities and us, or at that time between the Russians and the German Authorities.

I would add here that I was never shown any agreement between the Russians and the German authorities, nor was I told any details of it; nor of course could it have been in any way binding upon me.

We returned to the archives the following morning, Mr. Millar and I, to begin exploiting the diaries.

Millar went off on his own devices. I had brought a German assistant with me to act as a scribe.

Her diary is also in my Discovery, and I admit I have not yet found time to read it (I have an odd aversion to reading other people’s diaries). I must admit that I was rather perplexed by the chaotic conditions that I found there — in the Russian archives. There was no technical means whatever of reading the diaries, which the Nazis had reduced to the size of a small postage stamp on the glass plates.

Fortunately, Dr. Fröhlich had alerted me about this possibility, and I had bought at Selfridges [department store] a 12X magnifier, a little thing about the size of a nail clipper, with which by peering very hard I could decipher the handwriting. It was even more alarming to someone accustomed to working in Western archives — with their very strict conditions on how to handle documents, and cleanliness and security — to see the way that the shelves and tables and chairs were littered with bundles of papers; at one stage the Archivist brought in bottles of red wine and loaves of bread and cheese which were scattered among the priceless papers on the tables for us to celebrate the end of the week. That would have been unthinkable in any Western archive building.

My German assistant had worked with me in the US National Archives previously. We spent the first day cataloguing and sifting through all the boxes of glass plates and identifying which plates were which — earmarking, figuratively speaking, the glass plates which were on my shopping list to be read and copied.

Very rapidly, we began coming across glass plates of the most immense historical significance, sections of the diaries which I knew had never been seen by anybody else before. I was particularly interested in the Night of Broken Glass, November 1938, and the Night of Long Knives, June 1934. I also found the glass plates containing the missing months leading up to and including the outbreak of World War II in 1939, diaries whose historical significance need not be emphasized here.

Given the chaotic conditions in the Archives, I took the decision to borrow one of the plates overnight and bring it back the next day, so that we could photograph its contents. I shall argue about the propriety of this action at a later stage. I removed the plate, its contents were printed that night by a photographer hired by the Sunday Times, whose name was Sasha, and the glass plate was restored to its box the next morning, without loss or damage.

The Sunday Times editor Andrew Neil was coincidentally in Moscow at this time, and I showed him one of the glass plates at his hotel, the Metropol. He stated, “We really need something spectacular to follow the Andrew Morton book on Princess Diana, and this is it!”

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.

I returned to London and over the next few days a contract was formalized between myself and the Sunday Times under which the newspaper was to pay me £75,000 net for procuring the diaries, transcribing them and writing three chapters based on the principle extracts from the diaries. The contract with the Sunday Times contained the usual secrecy clauses — nobody was to learn of the nature of the contract, or its contents, or the price, or of the existence of the diary.

For reasons beyond my knowledge the Sunday Times, when it came under extreme pressure from international and British Jewish organizations, subsequently put it about that I had only been hired to transcribe the diaries — with the implication that they had obtained them on their own initiative. I was not, however, just a hired help: this was my project which I took to them and which they purchased, as the documents before this Court make quite plain.

It may be felt that £75,000 would have been a substantial reward for two weeks' work; but my response would be that it was for “30 years plus two weeks' work” — we are paid for our professional skills and expertise and experience and reputation. For our track-record, in short.

I returned to London, with arrangements to revisit Moscow in two or three weeks' time.

The Court will find that 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, namely those vital records recording the 1934 Nazi “Night of Long Knives.”

The reasons for doing so I have already hinted at earlier — the fear that they would either vanish into the maw of German government, or be resealed by the former Soviet archives, or be sold off to some nameless American trophy-hunter, and thus never see the light of day again.

I took these two borrowed plates straight to Munich, to the Institute, where I knew that they had a microfiche printer and reading machine; together with the Institute’s Dr. Zirngiebel, who was their expert in the archives, we inserted the appropriate lenses in the microfiche printer for a microfiche of this magnification, and I printed out two copies of each of the 100 or so documents on those two microfiches.

There was no secrecy about this. I at once sent two of these pages upstairs to the experts in the Institute itself, and two more to the German Federal Archives, with the written request that they formally identify these pages as being in the handwriting of Dr. Joseph Goebbels. This was a necessary part of agreement with the Sunday Times, who were being no less cautious than I.

The other principal reason that I had borrowed these two glass plates temporarily from the Russian archives was in order to put them to London forensic experts for the purposes of authentication; in the same manner that others had tested the “Adolf Hitler diaries” and I the Canaris diaries, the Sunday Times quite properly wished to have final proof that the glass plates were indeed of wartime manufacture: namely, that the glass was of wartime origin, and that the photographic emulsion was of wartime chemicals.

The Court may marvel at these precautions that we as, as non-scholars, took; but it seemed perfectly natural to me and to the officials of the Sunday Times. After all, not only were large sums of money involved but also the reputations of myself and a major international newspaper group. We wished to be absolutely certain.

On my return from Moscow and Munich to London, in June 1992 therefore the two glass plates were sent their separate ways, heavily wrapped and protected; one to an Agfa photographic laboratory which tested the age of the emulsion, in a non-destructive manner, and the other to the Pilkington Glassworks, whose laboratory specialists carried out similar tests on the age of the glass. Their reports are part of my Discovery, and these confirm that the tests were appropriate under the circumstances.

My Lord, if I may just anticipate by a few paragraphs what happened to those two glass plates: I returned to Moscow at the end of June, the glass plates were brought out to Moscow personally by a courier of the Sunday Times as soon as the tests on them were complete, and handed to me, standing outside the archives building, as my diary records; and within three minutes I had taken them back into the Archives building and replaced them in the box where they had been for the last 47 years.

What follows is not strictly relevant to the glass plates, but it is relevant to this case and it is best inserted here because of its chronology. When I returned to London with the remaining diaries which the Sunday Times had requested, an awkward situation had developed. Our secrecy had been compromised by an astute reporter of The Independent, a Mr. Peter Pringle, who was based in Moscow at the time that I was using the archives. He too has submitted a witness statement, for the Defendants. He stalked me into the archives, confronted me and learned from Dr. Bondarev of my work on the Goebbels diaries.

The resulting scoop in the The Independent set the press world about its ears, and before I returned to London on July 4, 1992, the entire Fleet Street press and the broadcast media fell over themselves to print stories about the diaries and my own participation. In order to blacken the name of the Sunday Times and its unpopular editor, I was described with every possible epithet.

It is of relevance to this action, in my submission, because the same organizations which had gone to great lengths to furnish the Defendants with the material they needed to blacken my name in the book, Denying the Holocaust, now applied heavy pressure to Andrew Neil and to Times Newspapers, Ltd., to violate their contract with me, and to pay me nothing of the monies which were due to me under the contract.

Under this pressure, which Mr. Neil described to me at the time as the worst that he had ever experienced in his life, the Sunday Times (having in fact paid me the first installment), welshed on the rest of the payments. I was forced to sue them in these courts for breach of contract. The financial consequences of this violation of the contract, in round terms about £65,000, were serious for me.

When I reviewed all the press clippings, and read all the statements made by these various bodies, boards, campaigns, agencies, and organizations attacking my name both during my absence in Moscow and upon my return, I could only say, sadly, from a lengthening experience: “The gang’s all here.”

The same gang, whom I loosely describe as the traditional enemies of free speech, were to be seen on the following days behind the metal police barricades thrown up outside my apartment, screaming abuse at myself and other leaseholders in our building, spitting, harassing passers by, and holding up offensive placards and slogans including one reading, in the most execrable taste, “Gas Irving” — it can be seen in the newspaper photos. From the photographs of this demonstration, it appears that representatives of every ethnic and other minority were present in these. It was the most disagreeable experience.

On my second visit to Moscow, as your Lordship will find from the relevant passages of my diary, I found a frostier atmosphere. The boxes with which I had so readily been provided on my previous trip, were said to be “missing” and not found. For three or four days I was unable to do anything, and then one box was released to me, which I devoured rapidly.

On the last day but one it became plain that I had jealous and envious rivals in Munich to thank for the difficulties that the Russians were now making. Dr. Bondarev’s secretary came into the reading room and said that there were allegations that I had “stolen” the glass plates. I assured her that while I had borrowed some, every glass plate which had been in my custody was at that moment back in the Archives and that nothing was missing — which was true. I also voluntarily wrote a Statement, which was handed to Dr. Bondarev.

Your Lordship will find that this document in both Russian and English, in my handwriting, is in the Discovery both of myself and of the Defendants, as an exhibit to the report by Professor Tarasov. Professor Tarasov is to be giving evidence before your Lordship, and I shall examine him with particular pleasure.

Dr. Bondarev’s secretary came back a few minutes later, and said that this was just what they required. She now vouchsafed to me the information: “The information came from Munich.”

Your Lordship will see from the “information” which came from Munich, which is in the Defendants' Discovery, that the Institut für Zeitgeschichte had faxed to Moscow a particularly hateful letter about me in an attempt to destroy my relationship with the Russians.

However I already had all the documents that had been on my shopping list. Either in longhand, or by dictating them on to a hand-held tape recorder, or typed onto my portable typewriter, or as photocopies of a few pages of November 1938, or as photographic prints obtained from the glass microfiches, I had collected several hundred pages of the most important Goebbels diary entries that had been missing ever since the end of the war, and I see no reason not to be proud of this achievement.

It is indicative of the general attempt to blacken my name, and to silence me, that when I spoke to a meeting organized by my private “supporters' club,” the Clarendon Club, on the evening of July 4, 1992 — my return from Moscow — the hall in Great Portland Street was subject to violent demonstrations outside which required a very large police presence to protect the members of my audience. This will be one of the photographs in the bundle that I shall shortly be submitting to your Lordship.

Later on that year when I addressed a further meeting in a West End Hotel, there even more violent demonstrations.

Such demonstrations do not occur spontaneously. Somebody has to pay for the printing and the bill posting and the bus rentals. I might mention that on one of the days that followed I was violently attacked by three men who identified themselves to me as Jews when I was having a Sunday lunch at a public restaurant in Mayfair with my family. They had laid an ambush for me.

I only recently learned that on the Monday morning after my return from Moscow, July 6 [1992], my long-time publishers, Macmillan, Ltd., seeing the clamor and coming under pressure from unnamed members of the Jewish community, panicked and issued secret instructions for the destruction of all remaining stocks of my books, without ever informing me that they had done so.

This particularly repulsive act by a publisher, reminiscent of the Nazis in 1933, cost me of course many tens of thousand of pounds in lost royalties. At the same time as they were taking these secret decisions to destroy all my books, at the cost to themselves of hundreds of thousands of pounds, my editor at Macmillan continued to write me ingratiating letters expressing interest in the early delivery of my Goebbels biography.

It was altogether a most unhappy period.

My Lord, I am coming toward the end as you can see. I can add one further brief example of how different is my attitude to such documents as the Goebbels diaries from the attitude of my rivals and the scholars.

Dr. Ralf Günther Reuth approached me, saying that he was preparing a five-volume abridged edition of the other Goebbels diaries for Piper Verlag in Germany and had nothing for 1938. There were large gaps in the other years too. I foolishly allowed him to have photocopies of some of the most important passages which until that moment had been exclusive to myself and my as-yet-unpublished Goebbels biography. The thanks that I received for this generous act were scant indeed.

I provided copies to the German Federal Archives of the entire Goebbels diary extracts that I had brought back from Moscow on July 1, 1993. Ten minutes later the director of the Archives informed me, in extreme embarrassment, that on the instructions of the Federal Ministry of the Interior I was permanently banned from the selfsame Archives forthwith and in perpetuity, which is to my knowledge the only time that such a sanction has been ever been applied to a historian. He explained that this decision had been taken “in the interests of the German people.”

I mention these facts, my Lord, to show that it was not just one single action that has destroyed my career but a cumulative, self-perpetuating, rolling onslaught, from every side — engineered by the same people who have propagated the book which is the subject of this action.