Irving v. Lipstadt

 1A. [Professor Christopher Robert Browning]     Yes.
 2Q. [Mr Rampton]     That would mean there would be six hours, roughly
 3speaking, five and a bit, between each trip. Does that
 4seem feasible?
 5A. [Professor Christopher Robert Browning]     We know the Saurer truck was much bigger than 40. We do
 6not know the size ----
 7Q. [Mr Rampton]     What do you think its capacity was?
 8A. [Professor Christopher Robert Browning]     The Saurer truck was, depending on, you know, women and
 9children or adults, would be between 50 and 80.
10Q. [Mr Rampton]     Right.
11A. [Professor Christopher Robert Browning]     But, in general, you know, I mean, I think as they show
12that the number per day is not beyond the capacity of the
13two and three trucks.
14Q. [Mr Rampton]     Right. So four trips a day, that would actually cover the
15numbers involved, would it not?
16A. [Professor Christopher Robert Browning]     Yes, we know in Semlin when they made -- they could do two
17trips a day and that would be all the way across Belgrade
18to a burial site that was much further away than the
19distance between the burial grounds and the Chelmno camp
20here.
21Q. [Mr Rampton]     I mean, how long does it take to drive 20 kilometres in
22one of these trucks?
23A. [Professor Christopher Robert Browning]     We are talking about driving about two or three kilometres
24from the camp.
25Q. [Mr Rampton]     Two or three? That is a matter of minutes?
26A. [Professor Christopher Robert Browning]     Yes. The longer period would be the period to gas. That

.   P-203

---

 1is why the motors had to run inside the camp before they
 2left or the passengers would not be dead when they
 3arrived.
 4Q. [Mr Rampton]     From start to finish of the operation, what is your
 5estimate of how long it would have taken?
 6A. [Professor Christopher Robert Browning]     Well, would you have to let the desired number of people
 7into the basement of the main building where they would be
 8undressed, force them up ramp into the truck, close the
 9truck doors, run the motor for probably 20 minutes, and
10then drive, given the issue of undressing and the driving,
11on the generous side, we would say an hour, and then you
12must empty the van and clean it out and drive back.
13MR IRVING:    My Lord, this is purely speculative. He is not an
14expert on gassing operating ----
15MR JUSTICE GRAY:    No, Mr irving, you must understand if you ask
16almost identical questions in cross-examination,
17Mr Rampton must be entitled to ask the same sort of
18questions in re-examination.
19MR IRVING:    Well, I was objecting really to the question that
20was asked about how long would it take to gas them and...
21MR JUSTICE GRAY:    But you went into the arithmetic, Mr Irving.
22That opens the issue for Mr Rampton. I am afraid you have
23to take that as being the rule.
24MR IRVING:    Well, I asked a slightly vaguer question. He asked
25a specific expert question.
26MR JUSTICE GRAY:    Again that is legitimate, I am afraid.

.   P-204

---

 1A. [Professor Christopher Robert Browning]     I would say this is not speculation in the sense that
 2I have read through virtually all the testimony of the
 3Chelmno trial and have seen a number of descriptions of
 4the operations, so to call what I have said speculation
 5would be unfair characterization.
 6MR JUSTICE GRAY:    Well, it is speculation in the sense it is
 7reconstruction.
 8A. [Professor Christopher Robert Browning]     Correct.
 9MR RAMPTON:    Yes, reconstruction. My real question is this.
10Those sorts of rates, whether it is two or three trucks in
11operation at any one time, whether it is 40 or 50 people
12in the truck at a time, whether there are three or four or
13five trips a day for each truck, does the figure of 97,000
14seem to you to be credible?
15A. [Professor Christopher Robert Browning]     It is entirely credible.
16Q. [Mr Rampton]     Can we please turn back to your L1 tab 7 documents and
17turn to page 74 where I think you were accused -- this is
18Hans Frank on 16th December accused by Mr Irving of
19deliberately suppressing significant parts of the German.
20It is the paragraph that begins "Die Juden"?
21A. [Professor Christopher Robert Browning]     Yes.
22Q. [Mr Rampton]     I only want you to look at the sentence, the next
23sentence, which begins: "[German - document not
24provided]". What would you say if you were going to say
25"gas" there?
26A. [Professor Christopher Robert Browning]     "Vergasung".

.   P-205

---

 1Q. [Mr Rampton]     "Vergasung". So he cannot shoot them, he cannot poison
 2them, then he says "verden aber", that means "but", does
 3it not?
 4A. [Professor Christopher Robert Browning]     Yes.
 5Q. [Mr Rampton]     [German], what does that mean?
 6A. [Professor Christopher Robert Browning]     Well, "Verden aber" would be in the sense "but
 7nonetheless".
 8Q. [Mr Rampton]     "Nonetheless"?
 9A. [Professor Christopher Robert Browning]     And "eingriffa" would be, you know, "steps would be
10undertaken".
11Q. [Mr Rampton]     Yes, [German] "We can do something"?
12A. [Professor Christopher Robert Browning]     Yes.
13Q. [Mr Rampton]     And then it says: "Die [German - document not provided]"
14That means what?
15A. [Professor Christopher Robert Browning]     That is "one way or another", "in some way".
16Q. [Mr Rampton]     [German] and then the word "vernichtung erfolch". What
17does that mean?
18A. [Professor Christopher Robert Browning]     "That would lead to a successful", literally in the way
19Germans combine words it means "a destruction success" and
20an English translation usually would be, we would invert
21those and say "a successful destruction".
22Q. [Mr Rampton]     So "We will find a way to bring about a successful
23destruction"?
24A. [Professor Christopher Robert Browning]     Correct.
25Q. [Mr Rampton]     "One way or another"?
26A. [Professor Christopher Robert Browning]     Yes, yes.

.   P-206

---

 1Q. [Mr Rampton]     Then I think you will be pleased, Professor, that that is
 2that, but I would like, if you can give me the answer --
 3what is this? Finally, I would like a little bit of
 4history from you. You were asked about the Wannsee
 5conference?
 6A. [Professor Christopher Robert Browning]     Yes.
 7Q. [Mr Rampton]     Was the date in January, 20th January, I think it was,
 8'42, its original date?
 9A. [Professor Christopher Robert Browning]     No, it was originally scheduled for December 8 or 9.
10Q. [Mr Rampton]     And when was it cancelled, do you know, or postponed?
11A. [Professor Christopher Robert Browning]     Just right before that, basically at the time of the
12Russian counter offensive around Moscow on 5th and Pearl
13Harbour on the 7th. I forget the exact date. The notices
14of -- when the marginal note that Rademacher makes on the
15invitation, you know, that he hears it has been cancelled,
16I do not remember the exact date, but it comes just
17before.
18Q. [Mr Rampton]     So does one know the reason why it was cancelled?
19A. [Professor Christopher Robert Browning]     They do not stipulate -- they do not specify, but I think
20a probable inference is that at that point a crisis is
21going on and the people who are invited have too many
22other things to do.
23MR IRVING:    It says "because of intervening events", I think,
24does it not?
25A. [Professor Christopher Robert Browning]     It would suggest that the 5th and 7th were very important
26events that suddenly did not allow -- that Heydrich's

.   P-207

---

 1schedule had to be changed.
 2MR RAMPTON:    Right. Thank you very much, Professor. My Lord,
 3those are all the questions I have in re-examination.
 4MR JUSTICE GRAY:    Mr Irving, if you think there is anything
 5raised by the re-examination would you like to further
 6question the Professor about, feel free.
 7< FURTHER CROSS-EXAMINED BY MR IRVING.
 8MR IRVING:    My Lord, going in reverse order, the "We cannot
 9shoot them, we cannot poison them", what would the
10objections to shooting and poisoning have been that would
11not also have applied to gassing, if any?
12A. [Professor Christopher Robert Browning]     The shooting of 3 million or 2 million in this case very
13possibly would have, simply it would have been much too
14public. I do not know why Frank would have said they were
15impossible. He is not the one that has been charged with
16trying to figure out how to do it. This is an
17extraordinary thing that is to about to take place, and
18the mind boggles that Frank could not conceive immediately
19of how this would be done strikes me as ----
20Q. [Mr Irving]     He was not talking from a script, was he?
21A. [Professor Christopher Robert Browning]     No.
22Q. [Mr Irving]     Finally, on this document which has been put to which
23I have not seen mentioned before, which is the Event
24Report No. 80.
25A. [Professor Christopher Robert Browning]     Yes.
26Q. [Mr Irving]     

.   P-208

---