Q.   Whether or not Hans Ficher is talking about this meeting
one does not know because one has not got the full text,
but assume that he is, then what he said was: From the
invitation, whatever that means, it was evident that
evacuation or sterilization were on the agenda.  What was
discussed at that meeting was to how to deal with the
mischlinge and their parents the mischehen, and the
question arose should they be sterilized, should they be
evacuated, should they be allowed to stay where they are?
That is what was discussed, was it not?
A.   Well we have of course two different versions of the same
meeting.  We have several different versions of the same
meeting.  We have the wartime minute taken by the one that
you referred to us from the Foreign  Ministry files, which
of course was before me, but we also have the other
sources of that meeting.
Q.   Mr Irving, the document that you referred to and relied on
in the account that you gave in your book Goebbels is this
A.   I specifically refer also to these interrogations of
Ficher and Bohle and the rest in this paragraph.
Q.   Do not move the goal posts please, Mr Irving.  It is no
good talking about some other memorandum.  This is the
memorandum which you footnoted in Goebbels, is it not?
A.   These gentlemen are clearly referring to this conference
in their interrogations because they say it was at the
headquarters of Heydrich, which pins it down as being this
conference where the talk is about Jews being supplied
like cattle.
MR JUSTICE GRAY:  You are missing, I think, Mr Rampton's point
on this, and I do not think we want to spend very long on
it.  It is that the evacuation and sterilisation that were
on the agenda may have been the evacuation or
sterilisation of mischlinge?
A.   It may be.
MR RAMPTON:  You do not tell your readers that, do you? You do
not tell your readers that the discussion at this
conference was confined to the fate of the mischlinge and
the mischehen.
A.   I am sure that Professor Evans would have spent eight
pages on this one detail, but I am writing a book which
has to be kept into the confines of one bound volume.
Q.   Unless you will answer my questions, we are going to have
a bad day.  Will you answer my question?  You do not tell
the readers that the discussion at this conference was
confined to the fate of the mischlinge and mischehen, do
A.   Will you allow me to read again what I have written?
Q.   Yes, indeed.
MR JUSTICE GRAY:  Do not take long because really the answer to
that question must be yes, that you are conveying to the
reader that it is the whole question that is being
postponed until the end of the war?
A.   I think, My Lord, that I have stated on several occasions
in the Goebbels' book, and your Lordship will remember the
case of Gottschalt having caused Hitler particular agony,
in my submission; that I have repeatedly referred to the
fact, to the question of the mixed marriages and mixed
races was a thorn in the side of the Nazis because they
did not know how to treat them, which side of the line to
put them.
I cannot keep on, in a book which is for
publication, coming back and reminding readers of things
that the intelligent reader will be carrying in his brain
MR JUSTICE GRAY:  No, Mr Rampton was asking you about the
passage at page 388, I think.
MR RAMPTON:  I was, yes.
A.   Well, I think that the lines, about 10 lines down, where
Goebbels is quoted as saying:  "For the time being that it
be concentrated in the East, undoubtedly, there will be a
multitude of personal tragedies, but this is
unavoidable".  We then go straight on to talk about the
March 6th conference.
I am making it in a way that a responsible
writer should.  I did not want to put the whole contents
of this 10 page memorandum into a book at this point.
That would have been acres of sludge again.
MR RAMPTON:  Mr Irving, I am going to put it once more and
I cannot go on making speeches through questions which are
never answered.  The fact is you that you led the reader
in this passage to believe that what was discussed at the
conference on 6th March was the fate of the Jews
generally, that that then went to Hitler, via Lammers, and
Hitler made a ruling that the fate of the Jews generally
was not to be considered or discussed at that time.  That
is a total distortion of the evidence which you had before
you when you wrote that.
A.   I totally disagree with you, Mr Rampton.  The evidence of
Bohle, that there was talk there of delivering the Jews to
the East like so many head of cattle, that is no longer
talking about the mixed marriage problem.  They are
talking about the overall Holocaust in the way that I have
accepted it can be defined and perceived.
Q.   If you can find in this memorandum which you have cited in
your book reference to the general question, please show
it to us, otherwise that is my last question.
A.   Mr Rampton, I have referred to the fact that I do not just
rely on one document.  I do not jump from mountain peek to
mountain peek.  I look at all the surrounding hills as
MR JUSTICE GRAY:  There we are.  That is the Schlegelberger
MR RAMPTON:  I think, my Lord, that will do.
MR JUSTICE GRAY:  Thank you very much.
MR RAMPTON:  My Lord, I was not intending to embark on anything
new at the moment.
MR JUSTICE GRAY:  I think the plan is we have your witness so
he is not kept waiting.
MR RAMPTON:  As Professor Cameron Watt is here, he had
give evidence.
MR JUSTICE GRAY:  That is what I think so, Mr Irving, if
would like to revert to your role as counsel?
< (The witness stood down)
MR IRVING:  Can Professor Cameron Watt be called?
MR JUSTICE GRAY:  Yes, of course.
< PROFESSOR CAMERON WATT, sworn.
< Examined by MR IRVING.
MR JUSTICE GRAY:  Professor Watt, would you be more
sitting down?  You are welcome to sit down.
MR IRVING:  I was going to make precisely the same
suggestion,
my Lord.  (To the witness):  Professor Watt, thank you
very much for coming today.  You are appearing, of
under a witness summons.  I want to make that quite
to the court and you are not appearing voluntarily, so
odium can attach to you for coming and being called
the defence, for my defence, in other words, for the
Plaintiff in this action.
MR JUSTICE GRAY:  Shall we introduce Professor Watt and ask
about his background?
MR IRVING:  Yes.  Professor Watt, your name is Donald
Watt?
A.   It is.
Q.   You are Emeritus Professor of International History at
London School of Economics and Political Science?
Q.   How long were you teaching at the London School of
Economics?
A.   From 1954 to 1993.  39 years altogether.
Q.   39 years a Professor of History at the London School
A.   I did not have the rank of Professor until 1971, but I
on the staff.
Q.   You enjoy the reputation of being something of a grand
gentleman, a doyen, of the historical profession in
country?
A.   I think it is very difficult for an individual to say
their reputation is in the minds of other people.
I certainly can only say that I have held a number of
senior positions in international organizations
devoted to
historical research.
Q.   Thank you.  You describe yourself as an historian,
and broadcaster.  You are all three things?
A.   These are the various sources of my income, yes.
Q.   You were educated at Rugby and at Oriel College in
Oxford;
is that correct?
Q.   You served in the Army in the Intelligence Corp.?
A.   I did.
Q.   And that you were with the British troops in Austria
the occupation forces after World War II?
A.   From 1947 to '48, yes.
Q.    1947 to '48.  Would you tell the court, Professor
what you were engaged with in the years following your
Army service?
A.   Following my Army service, I had three years reading
politics, philosophy and economics at Oxford because
that way could you deal with 20th century history at
time; and I indulged myself in the usual activities of
undergraduate.  That is to say, I wrote, I played
opera, I
ran the Poetry Society -- I had a number of activities
that kind.
Q.   And you became a member of the Foreign Office Research
Department?
A.   I was attached to it, yes -- I do not think I was ever
full member -- from 1951 to 1954, and then again on a
part-time basis from 1957 to 1960.
Q.   Yes.  Interesting.  So you are quite familiar in a way
with the kinds of documents, Foreign Office,
documents, that we have been looking at in this court
morning, for example.  The ones with the serial
numbers,
the six digit serial numbers stamped on the bottom?
A.   The ones with the serial numbers are the ones -- those
serial numbers are the way we recorded them on our
cards.  They represent the serial number of the
film and the frame number of the particular page.
Q.   The British, in fact, captured all the German Foreign
Office records?
A.   They fell into the hands mainly of the British and
Americans, were collected in Berlin and were
evacuated.
The whole project for editing them and publishing them
evacuated from Berlin at the time of the Berlin
airlift.
Q.   Did they go to a place called Waddon Hall?
A.   Waddon Hall near Bletchley, yes.
Q.   Near Bletchley, near the code breaking establishment?
A.   Yes.  We had no relationship with them at all.
Q.   Nobody knew about them?
A.   Well, we knew they were there.  There wee too many of
to be concealed and some of them played their part in
ordinary social activities, but what they were
doing, no, we did not know.
Q.   Would you give the court, in most general terms, one
two lines, a picture of the scale and scope of the
captured German documentation?  Was it small or large?
A.   Well, at Waddon itself, we had 400 tonnes ----
Q.   400 tonnes?
A.   --- of documents covering the records of the German
Foreign Ministry and of its Prussian predecessor from
onwards.  We also had access to those files of the
Navy, the Reichsmarines, had fallen into British hands
Blenzburg and we had an odd collection of documents
the Nazi leaders, from the offices of the adjutantur
the Fuhrer, for example ----
Q.   Hitler's Adjutants?
A.   --- and a number of private, collections of private
that were found with the Foreign Ministry archives.
Q.   Interrupting here at this moment, Professor Watt.  Can
just ask you, when did we last meet -- 30 years ago?
A.   30 years ago, I think it was, yes.
Q.   Have we had any discussion about what you are going to
saying today beyond just the invitation and my saying
it would just be very painful and very short?
A.   No.
Q.   I have not rehearsed you in any way as to what to say?