1 Hitler's War, 1991 edition, at page 17.
2 The Independent, "Holocaust Case Result will deliver Judgment on Irving", March 4, 2000.
3 She gives her source as release from the Jewish Telegraphic Agency, Nov 26, 1992.
4 Statement of Claim, para 9(i).
5 Statement of Claim, para 11.
6 Denying the Holocaust, page 161.
7 Literary Review, March 2000, Kenneth Rose, review of Owen Lloyd George: A Tale of Two Fathers.
8 Report in The Daily Telegraph, July 29, 1999:"PREACHER HAS RIGHT TO BE HEARD, HOWEVER IRRITATING." Citing Socrates and two famous Quakers, William Penn and William Mead, Lord Justice Sedley said: "The irritating, the contentious, the eccentric, the heretical, the unwelcome, and provocative have a right to be heard."
9 Day 7, January 20, at pages 48-9.
10 Eberhard Jäckel, in Michael Berenbaum and Abraham J Peck (eds.), The Holocaust and History, Inidana University press, 1998, at page24.
11 Defence of the First Defendants, Section.6.
12 Day 19, February 14, at page 83. I had supplied Deutsch with the General von Fritsch papers. He used them before me. I was then accused of having plagiarized his research without attribution. Cross examination of Prof. Evans. Evans: "I agree. I will climb down on Professor Deutsch." In another instance, I gave crucial entries in the Moscow Goebbels diaries to Hans-Georg Reuth, who published them in his five volume digest edition three years before I used them in my biography. His publishers Piper Verlag then vilified me on German television.
13 Day 20, February 15, at page 91.
14 See Days 4, January 17 at page 195; Day 5, January 18, at page 44; Day 16, February 7, at page 41.
15 See my opening statement; and Peter Millar's evidence, Day 15, February 3, pages 40-41.
16 Day 19, February 14, at page 45.
17 L. Gruchmann, R. Weber (eds.), Der Hitler-Prozeß 1924. Wortlaut der Hauptverhandlung vor dem Volksgericht München I, Vol. 2 (Munich, 1998), 545-546.
18 See Day 19, February 14, page 77. Philippe Burrin, Hitler and the Jews, the Genesis of the Holocaust, at page 57: "While Hitler could only have endorsed the concept of exacting reprisals, namely on the Jews, he seems to have been surprised by the extent of the destruction. [...] In each case Hitler covered for Goebbels who did not derive the hoped for benefits from the affair." Copy in my Bundle F, "Prof. Evans", No. 48.
19 Burrin, op. cit.: "... It is a good thing we are preceded by the ominous reputation of exterminating the Jews..."
20 Ereignismeldung No. 60, dated September 11, 1941, at page 9: "Günstig wirkt sich das Gerücht aus, daß von den Deutschen alle Juden totgeschossen würden." And see Ereignismeldung No. 81 of September 12, 1941 where Einsatzgruppe C reported, "The gratuitous evacuation of hunderds of thousands of Jews may be considered to be an indirect success of the work of the Security Police. As we hear mostly from the other side of the Urals, this is a considerable contribution to the solution of the Jewish question in Europe." Translation in Arad, Krakowski and Spektor in The Einsatzgruppen Reports, page 131.
21 Goebbels diary, printed text, November 22, 1941;
22 See the answers by Peter Millar, examined on Day 15, February 3, page 40:
23 See the argument on Day 16, page 135.
24 Van Pelt, report, page 390.
25 These items of the Claimant's Discovery relate to the task put to Dr Fröhlich, 1970-1971: Nos. 247, 269, 271-4, 279 (her fees and expenses, etc).
26 Bundle E, page 9: David Irving to The Sunday Telegraph, June 19, 1977. Claimant's Discovery item No. 2069: Letter from the Plaintiff to Professor Raul Hilberg, December 5, 1975, and reply, December 12, 1975, referred to in Item No. 440, Letter from Plaintiff to Teresa Egan, The Viking Press, March, 1976.
27 For the full list of thirty such bodies and names, see para. 10 of my affidavit of September 4, 1998, in support of a successful application for specific Discovery against the Second Defendant, to be found in Bundle E at pages 245-7.
28 Day 27, page 42; day 28, pages 37, 189.
29 Bundle E, pages 6-7: David Irving diary, October 13, 1973; Discovery, No. 372.
30 Bundle E, pages 11b-d: Typescript ADL report, headed "ADL" and 4/17/77 in pencil; published in full on my website at http://www.fpp.co.uk /BoD/ADL1977IntelliReport.html.
31 Bundle E, page 16: ADL backgrounder, 1983.
32 On Noam Chomsky's experiences with the ADL, see his book Language and Politics (Black Rose Books, 19988), at page 642, quoted in a letter in Bundle E, page at page 248.
33 Bundle E, page 33, David Irving to Justin Finger, ADL, October 15, 1983; Claimant's Discovery, No. 925.
34 Bundle E, page 35: David Irving to his literary agent, Max Becker, January 7, 1984; Claimant's Discovery, No. 946.
35 Bundle E, page 36: Lipstadt to Bauer, August 15, 1984; Second Defendant's Discovery, No. 36.
36 Bundle E, page 45. Vidal Sassoon Center for the Study of Anti-Semitism at the Hebrew University of Jerusalem: Agreement, May 31, 1988.
37 See Bundle E, pages 61-62..
38 Bundle E, page 40: The Times, July ... 1986.
39 re Australian libraries: see Bundle E, page 59, para 3.
40 Bundle E, page 46: Elisabeth Gale (ADL Orange County Regional Office), memorandum to Betsy Rosenthal, March 15, 1989: "IHR conference, reporter's account." Second Defendant, Second List, item No. 66.
41 Bundle E, Deborah Lipstadt, DenyING THE HOLOCAUST.
42 Bundle E, pages 41-44: Anonymous: Confidential, October 233, 1986: "Profile on David Irving."
43 Bundle E, page 263: The New York Times, "Hitler's Spin Artist," April 3, 1996.
44 Bundle E, page 170, 171-2 : Deborah Lipstadt, quoted by Marc Fisher in The Washington Post, April 3, 1996: "The Publisher in a State of Denial"
45 Bundle E, page 12: Ion Trewin, Hodder & Stoughton Ltd., to David Irving, April 3, 1981.
46 Bundle E, page 15: Peter Carson, Penguin Books Ltd., to David Irving, April 24, 1981.
47 Day 19, page 92: cross-examination of Prof. Evans. In direct consequence of the premature (pre-embargo) Lukacs review, the next day's pre-recorded segment on nationwide television's Good Morning America show was scrapped; later reviews parroted Lukacs's list of my "mistakes".
48 Bundle E, page 56: Canadian Jewish News, October 25, 1990.
49 Bundle E, page 75: League of Human Rights of the B'nai Brith Canada Ian Kagedan to Franco Giammaria, Tudor Hall Restaurant, Ottawa, September 17, 1991.
50 Bundle E, page 59: David Irving to Andrew Lownie, November 30, 1990; Claimant's Discovery, No. 1318.
51 Bundle E, page 49: The Jewish Chronicle, June 30, 1989, Irving publishers won't drop him, Claimant's Discovery, No. 1215.
52 Day 20, February 15, 2000; speech at Milton, Ontario, October 5, 1991: "They [the Board of Deputies] scurry and hide furtively, they re like the cockroaches who you don t see normally by light of day."
53 Bundle E, page 64: The Jewish Chronicle, July 12, 1991: "Keep Holocaust 'apologists' out of Britain, Home Secretary is told.
54 We have only the BfV's reply, August 9, 1991 to Neville Nagler of the Board of Deputies. Bundle E, pages 669. It is in the files of the Prime Minister of Australia, an indication of the world-wide networking that has gone on an endeavour to deprive me of free speech.
55 Bundle E, page 70: Walter F Magrutsch to Neville Nagler, Board of Deputies, June 22, 1992.
56 Bundle E, page 78: La Nación, October 18, 1991: "La DAIA advirtío sobre un 'agitador internacional'."
57 Lipstadt wrote: "Peter Pulzer, a professor of politics at Oxford and an expert on the Third Reich, observed that it was ludicrous for [Andrew] Neil to refer to Irving as a 'mere technician,' arguing that when you hired someone to edit a 'set of documents others had not seen you took on the whole man.'" For the full list of names of those people and organisations who subjected Neil and The Sunday Times to pressure to violate the Goebbels Diaries contract with me, see Bundle E, pages 202-207.
58 Bundle E, page 82: Minutes of meeting on December 12, 1991.
59 Bundle E, page 83: Internal Memo by Roland Philipps to Steven Kennedy, January 2, 1992.
60 Bundle E, page 85, Deborah Lipstadt to USHMM, May 6, 1992; Lipstadt second Discovery, No. 78.
61 Bundle E, page 94: clippings from The Guardian, Jun 22, Jun 23, 1989; forwarded by USHM to Martin Smith, undated. Lipstadt second Discovery, No. 78.
62 Bundle E, page 84: The Jewish Chronicle, Jun 12, 1942: Irving book store attacked.
63 Bundle E, page 86: Newcastle Evening Chronicle, Jun 10, 1942: "WAR BOOK GOES UNDER COVER."
64 Bundle E, page 87: Today, Jun 1942:"Holocaust book [sic] fury."
65 Bundle E, page 89: David Irving to Tim Waterstone, June 19, 1992.
66 Bundle E, page 91: Evening Standard, June 19, 1992.
67 Bundle E, page 95: Metropolitan Police to David Irving, Jun 24, 1992, about demo planned in Duke Street, July 4, 1992.
68 Bundle E, pages 97-99: Committee to Stop Irving, anonymous, leaflet: the phone numbers given were 0171 277 0817 (which is now disconnected) and 277 1314, which has an anonymous ring-back system. And sticker, "Mass demonstration to stop the fascist bigots," calling for demonstrators to "meet" at my home at 11 a.m. on July 4, 1992.
69 Bundle E, page 102: The Observer, July 5, 1992: Arrests at protest over Goebbels historian.
70 Bundle E, page 153: Department of Home Affairs, Pretoria, to David Irving, April 1, 1992.
71 Bundle E, page 155: David Kopelowitz, National Director, SAJBOD, to M Whine, Board of Deputies, June 5, 1992.
72 Bundle E, pages 193ff: Tel Aviv University, "Anti-Semitism Worldwide - 1993" here at page 200; and see ibid., page 216, David Irving to Louis Stofberg, MP, January 5, 1994.
73 Bundle E, page 154. Die Welt, June 15, 1992, sent to the Board of Deputies with a covering letter from Gerald [Fleming].
74 Response, Wiesenthal Center World Report, winter 1992, vol. 13, no. 3, page 13.
75 Bundle E, pages 180ff: League of Human Rights of the B'nai Brith Canada, Annual Report to the 1993 B'nai Brith Canada Convention. Claimant's Discovery No. 1679.
76 Bundle E, page 277, Affidavit of Michael Whine, November 1996: "Mr Irving's Activities have been monitored by the Board for a number of years. [...] The report was compiled by my department as part of its normal day to day activities. [...] At some time in 1992 I received a request for information on Mr Irving by the B'nai Brith League of Human Rights, a similar organisation to the Board in Canada. They were in the process of providing information to the Canadian Department of Citizenship and Immigration which, at the time, was considering whether to permit Mr Irving to enter Canada. Mr Irving obtained a copy of the report following his inquiries in Canada under the Canadian Access to Information Act. . ."
77 Bundle E, page 116: [Board of Deputies], confidential Intelligence report, David Irving, Biographical Information, 31pp, June 1992.
78 Bundle E, page 184: US Embassy, Legal Attaché, to David Irving, April 23, 1993: Claimant's Discovery, No. 1681.
79 Bundle E, pages 209-201: David Irving to U.S. Consul, London, June 6, 1993; Claimant's Discovery, No. 1687; ibid., page 211: reply, June 14, 1993, Claimant's Discovery, No 211.
80 Bundle E, page 221: Washington Jewish Week, May 26, 1994.
81 Bundle E, pages 251ff. [Anonymous, Simon Wiesenthal centre, Toronto]: History Rewritten: The World of David Irving. Here, pages 256 last paragraph, and 258 last paragraph. Lipstadt Discovery, No. 500.
82 Response, Wiesenthal Center World Report, winter 1992, vol. 13, no. 3, page 13.
83 The Toronto Star, November 19, 1999: "JudGE REJECTS HATE EXPERT": "Although Farber has previously testified as an expert in about a dozen cases, Mr. Justice Russell Otter ruled in this instance he could be perceived as having a bias."