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an undertaking by me not to pursue the matter in the courts).

First, your "article" Lies of Our Times (forgive the quotation

marks, but as you call me an "historian" it seems justified).

David Irving

David John Cawdell Irving is a British "historian", born in

1938.

* Correct.

According to David Cesarani of the Wiener Library in London,

England, he attended Imperial College at the University of

London, but never graduated. He holds no academic degree

and no academic position at any university or college.

* Correct. The same can be said for Winston S.

Churchill, Thomas Babington Macaulay (The

History of England), and the Gibbon who wrote

The Decline Fall of the Roman Empire, etc.

Would you denigrate them as "historians" too?

He calls himself a "moderate fascist",

* Incorrect. Please produce the source of this

spurious and libellous allegation.

and claims, among other things that the gas chambers at

Auschwitz (in which an estimated 2-3 million people died)

were "built by the Poles after the war as a tourist attraction."

* Not quite correct. I stated (on April 21, 1990 and

other occasions): "The gas chamber which is

shown to the tourists in Auschwitz is a dummy

(Atrappe) built after the war by the Polish

communists as a tourist attraction." In 1990, Dr

Franciszek Piper, the then director of the Auschwitz

State Museum Archives, confirmed that this is

true. As recently as 1995 the present directors

confirmed in an interview with Eric Conan, of the

well-known liberal French weekly L'Express, that

the gas chamber shown to the tourists was

constructed on the orders of the Polish communist

government in 1948. "Tout y est faux," reported

Conan, and the deputy chief of the site stated:

"Pour l'instant, on la laisse en l'йtat et on ne

prйcise rien au visiteur. C'est trop compliquй. On

verra plus tard" (L'Express, January 26, 1995).

(For this remark, he was fined DM 10,000 by a Munich court in

May 1992.

* Correct. On January 13, 1993 the fine was

increased to DM30,000 in view of my refusal to

retract the statement. (Why should I? It was true). In

addition, on July 1, 1993 I was permanently

banned from setting foot in the German Federal

Archives, which had benefited over the years from

my donations of half a ton of archival material

including the diaries of Canaris, Himmler,

Rommel, etc., which I had located, and which they

have now had to relinquish to me; and on

November 13, 1993 I was permanently banned

from Germany. How's that for freedom of speech!

The judge was quoted as saying that the gas chambers of

Auschwitz were "an historically certain fact.")

* Correct. The word used is offenkundig, and is

used in German law to deny defence lawyers the

introduction of any defence exhibits or witnesses,

e.g. the aforementioned Dr Franciszek Piper whom

we were prepared to call. There has been an

outcry in the German legal profession against

these methods, and Germany is to face a rebuke

from the United Nations for her repression of

freedom of opinion by such means. Of course, if

you believe they are correct to adopt such tactics,

such is your right.

Irving denies being a "Holocaust denier" or "Hitler apologist",

and seems willing to resort to legal action if necessary.

* Correct. Last year one of Britain's biggest Sunday

newspapers was forced to pay me substantial

damages after they printed such a libel. I issued a

Libel Writ in the High Court. (For legal reasons,

namely the settlement agreed, I am not permitted

to identify the newspaper or the amount, except off

the record). I am currently pursuing Libel action in

the British courts against The Observer, Deborah

Lipstadt, (whose odious little tract has been

foolishly published here, i.e. within the jurisdiction,

by Penguin UK Ltd) and Svenska Dagbladet. You

have been warned!

In a recent fax printed in the K-W Record, he is reported as

saying, "I have warned 22 British newspapers that I shall not

hesitate to commence libel action if they use smear phrases

such like 'Hitler apologist' or 'Holocaust denier' to embellish

their writings." But Bernard Levin, writing in The Times of

London in May of this year, quoted Irving as saying, "I hope

the court will fight a battle for the German people and put an

end to the blood lie of the Holocaust which has been told

against this country for 50 years."

Irving first entered the headlines in 1970.

* Incorrect. Ever since 1963 my books have been

the subject of wide comment and much praise in

the British media.

In July of that year, he was forced to apologize in the High

Court of London for "making a wholly untrue and highly

damaging statement about a woman writer."--not an

auspicious start for someone who claims to be in pursuit of the

truth.

* Correct. A Sunday Express journalist, Jill -----,

stated that Rolf Hochhuth, the German playwright

and one of my closest friends had granted her an

exclusive interview. Hochhuth assured me he had

not even spoken to her. I mentioned this in a letter

to the newspaper's editor. She sued. As I was

fighting the hideously costly PQ.17 Libel Action at

the time, I had no alternative but to settle out of

court-- "shortening the front," is what military

commanders call such action. Make of that what

you will. Nothing has been heard of that

"journalist" since.

Later that year, Irving was back in the headlines, concerning

publication of his book, "The Destruction of Convoy PQ17".

Ostensibly an expose of an ill-fated 1942 Arctic convoy

headed for the Soviet Union during World War II, it eventually

resulted in Irving being fined 40,000 British pounds for libel.

* Incorrect. In actions for Libel--a tort--the defendant

is not fined, but can be required to pay damages.

The book was published by Simon Schuster and

other leading pubishers around the world. Not bad

for an "historian", eh?

Irving's book faulted Captain John Broome, commander of the

convoy at the time, saying he was guilty of "downright

disobedience" and "downright desertion of the convoy."

* Incorrect. No such allegations or quotations are

contained within the book.

Broome brought suit against Irving for false statements, and

won a judgment in August of 1970. Irving's lawyers appealed,

and lost in March, 1971.

* Correct. We then appealed to the House of Lords,

twice, and lost 4-to-3,which is a pretty close call.

Needless to say the insurers of Cassell Co Ltd,

the British publishers, would not have authorised

such defence actions had their counsel not studied

all the documents available and concluded that we

had a powerful defence, based on the Admiralty

records; this they in fact did, and wrote Opinions to

that effect. Libel actions in Britain are tried by jury.

Make of that what you will.

The case is revealing because of what it says about Irving's

abilities as a historian and his motives as an author.

According to The Times of London, Irving showed a copy of

the manuscript to Broome before publication.

* Correct. I showed the late Captain Broome the

mansucript in 1966, and he agreed to read it and

make comment (as did a score of other officers

involved); breaking his undertaking, he alone

decided not to co-operate, but to wait for

publication and then sue for profit. So be it.

Broome objected to the accuracy of some thirty passages in

the book, and threatened to sue for libel if Irving did not make

changes.

* Incorrect. He objected in reality to six words

("Captain Broome was a broken man"), and after

these words were expunged, years later, his

lawyers permitted the book's republication by

William Kimber Ltd.

At that point, William Kimbers Ltd., Irving's publisher, notified

him that they would not publish the book as it was then

written.

* Incorrect. I was in dispute with William Kimber

after they paid me only J67 instead of the agreed

fee of J200 for translating the book, The Memoirs

or Field-Marshal Wilhelm Keitel. This being so, I

removed the PQ17 manuscript physically from

their offices; Kimber's secretary came running

down the street after me, pleading for me to return

it. I keep a very detailed diary of events. In court,

Kimber, already probably suffering from the

Parkinsonism from which he later died, gave a

totally different version, namely yours; he later

apologised to me, which did not assist me much of

course. Unfortunately, our counsel elected to call

no witnesses in the case but to rest securely on the

Admiralty documents.

Later, Irving published the book with another publisher.

The court found that Irving "was warned from most

responsible quarters that his book contained libels on Captain

Broome ... To make [the book] a success he was ready to risk

libel actions ... Documentary evidence .... showed that [Irving]

had deliberately set out to attack Captain Broome and in spite

of the most explicit warnings persisted in his attack because it

would help sell the book." The court labeled Irving's conduct

as "outrageous and shocking."

Irving's misrepresentations did not end with the publication of

his book. According to Cesarani, in 1979 a German publisher

had to pay compensation to the father of Anne Frank after

printing the German edition of Irving's book, Hitler's War. Irving

had claimed that Anne Frank's diary was a forgery.

* Correct as written. Without consulting me, the

Ullstein Verlag publishing firm, part of the

pro-Israeli Axel Springer Group) made some

unspecified payment to Otto Frank at his demand. I

had already halted production and publication of

the book for other reasons (tampering by Ullstein

with my text). The German Bundeskriminalamt

found that parts of the diary had been written in

(post-war) ballpoint ink-paste, which made its

authenticity problematic. My opinion on it now is

ambivalent: it is unimportant, not a historical

document of any value.

Irving claims that according to his "research", the Holocaust is

greatly exaggerated.

* Correct. I think the figures have been magnified

by an Order of Magnitude. Events in Auschwitz

alone suggest that I am right:: here the figure has

been effortlessly brought down from 4 million to 1

million, and now to even less.

(He was recently quoted in the K-W Record as saying that the

number of Jews who died in concentration camps was "of the

order of 100,000 or more.")

* Incorrect. Do you really believe all the

newspapers say? I may have said "killed", not

"died".

But during the 1988 trial of pro-Nazi publisher Ernst Zundel,

he was forced to admit under cross-examination that he hadn't

even read all of Eichmann's 1960 trial testimony. (In this

testimony, Eichmann admitted that Nazi leaders discussed

the so-called "Final Solution to the Jewish

problem"--extermination, in 1942.)

* Incorrect. I have Eichmann's manuscript

memoirs, given to me in Buenos Aires in

November 1991. He states that to him Final

Solution always meant the Madagascar Solution.

Anyway, do you really want to base your case on

the utterances of a Nazi war criminal?

In November 1991, a reporter from The Independent showed

that Irving omitted crucial lines from a translation of Goebbels'

diaries--lines that would have contradicted his theory that

Hitler knew nothing about the extermination of the Jews.

* Incorrect. Which "crucial lines" am I supposed to

have omitted?

Irving's record is clear: he is not an historian, and he has

made false statements and been forced to apologize for them.

As Andrew Cohen, reporter for the Financial Post, has said,

"David Irving should be denied credibility."

* Well, that really wants to make me hang up my

shingle: namely, that a shyster from a money-rag

doesn't believe me. What a waste of kilobytes,

when there are megabytes of reputable historians

saying precisely the opposite about me.

Yours sincerely,

David Irving

Focal Point Publications

Professor Jeffrey Shallit

Associate Professor

Computer Science Department

University of Waterloo,

Waterloo, Ontario

Canada

The following is the full text of the article by Mr. Shallit that Mr.

Irving quotes in the preceding letter.

&&&&& LIES OF OUR TIMES

by Jeffrey Shallit

How the Words of the Holocaust Deniers and Their Allies

Show Them For What They Are

1. Background

Canada has a long tradition of tolerance and multiculturalism.

That's why many residents of the K-W area were shocked and

saddened to learn that a stereo store on King Street in

Kitchener was displaying posters advertising a talk by David

Irving, a self-described historian who says that the estimates

of six million Jews killed by the Nazis during World War II are

greatly exaggerated. Inside the store, according to the K-W

Record, one can find for sale a book by Fred Leuchter that

claims that the gas chambers at Auschwitz were never used

for mass killing. After local protests, the store owner retaliated

by putting up posters about the banking system based on the

writings of anti-Semite Eustace Mullins. Subsequently, these