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TBR History Article - Christopher Browning, Court Historian Extraordinaire
A leading proponent of the standard “Holocaust” narrative repeatedly fails to scholarly demonstrate his primary thesis
By John Wear
American
historian Christopher R. Browning is a professor of history at the
University of North Carolina at Chapel Hill. His research focuses on
National Socialist Germany and the so-called Holocaust. He has written
extensively about three issues:
1) German policy and decision
making regarding the “Holocaust”; 2) The behavior and motives of various
German personnel involved in implementing National Socialist Germany’s
Jewish policy; and 3) The use of survivor testimony to explore Jewish
responses and survival strategies.i
In addition to writing numerous books on the “Holocaust,” Browning has served as a paid expert witness in at least two major trials. Browning testified as an expert witness for the prosecution in the 1988 criminal trial of Ernst Zündel in Toronto, Canada.ii He later testified as an expert witness in David Irving’s libel suit against Deborah Lipstadt and Penguin books.iii This article discusses some of the weaknesses of Browning’s research regarding the “Holocaust.” EXTREME GENOCIDE
Like most mainstream historians, Christopher Browning regards the so-called Holocaust as history’s most extreme case of genocide. Browning writes concerning the “Holocaust”:
I believe that the Holocaust was a watershed event in human history—the most extreme case of genocide that has yet occurred. What distinguishes it from other genocides are two factors: first, the totality and scope of intent—that is, the goal of killing every last Jew, man, woman, and child, throughout the reach of the Nazi empire; and second, the means employed—namely, the harnessing of the administrative/bureaucratic and technological capacities of a modern nation-state and western scientific culture.iv
Browning further defines the Final Solution as “the Nazis’ plan to kill every last Jew in Europe on whom they could lay their hands.”v Browning says Hitler’s goal of a Nazi-dominated Europe free of Jews was to be obtained “through the systematic and deliberate murder of every last Jew—man, woman, and child—caught within the Nazi sphere of domination.”vi If, as Browning claims, the Germans had the goal of killing every last Jew throughout their empire, they certainly didn’t do a very good job of it. As of January 1984, there were 4.39 million successful individual restitution claims under the terms of the German Federal Compensation Law (BEG) of 1953 and 1956. This law provides monetary compensation to individuals who were “persecuted for political, racial, religious or ideological reasons” by the wartime German government. The great majority of these successful restitution claims were from Jews. Jewish Holocaust historian Raul Hilberg estimated that about two-thirds of the allowed claims had been from Jews.vii Using Hilberg’s conservative estimate would mean that over 2.9 million Jews had received BEG restitution claims by January 1984.
The number of 2.9 million Jewish claimants understates the number of Jews who survived World War II. As of 1985, Jews in Poland, the Soviet Union, Hungary, Romania, and Czechoslovakia were not eligible for BEG restitution. Also, some European Jews who survived World War II died before the German BEG restitution law was enacted in 1953. The Atlanta Journal-Constitution newspaper estimates that only half of the Jewish “Holocaust survivors” around the world in 1985 had received restitution under the BEG.viii If this 50% estimate is accurate, it would mean that approximately 5.8 million European Jews survived German persecution during World War II. Such a large number of surviving Jews is not consistent with a German program of genocide against European Jewry.
The New York Jewish publication Aufbau documents that on June 30, 1965, 3,375,000 inmates, the vast majority of whom were Jewish, had survived the German camps and were receiving reparations from Germany.ix How could there be 3,375,000 survivors of the German concentration camps receiving reparations from Germany 20 years after the war was over if Germany had mass murdered 6 million Jews? Norman Finkelstein, the author of The Holocaust Industry, quotes his mother as asking, “If everyone who claims to be a Holocaust survivor actually is one, who did Hitler kill?”x Stephen F. Pinter, who was a U.S. War Department attorney stationed in Germany after the war, also disputed the claim that millions of Jews were murdered by Germany.
In a statement made in 1959, he wrote: “From what I was able to determine during six postwar years in Germany and Austria, there were a number of Jews killed, but the figure of a million was certainly never reached. I interviewed thousands of Jews, former inmates of concentration camps in Germany and Austria, and consider myself as well qualified as any man on this subject.”xi Another problem with Browning’s statement is that a large number of Jewish children survived the so-called “Holocaust.” Carlo Mattogno has prepared a long list of children and twins at Auschwitz-Birkenau who survived the camp.xii These children were not fit for work and could not have survived the war if Auschwitz-Birkenau had been the extermination camp it is claimed to have been.
Browning’s statements also do not take into account the fact that a large number of disabled Jewish adults who were not fit for work survived their internment at Auschwitz-Birkenau and other German camps. For example, Anne Frank’s father, Otto Frank, contracted typhus at Auschwitz-Birkenau and was sent to the camp hospital to recover. He remained at Auschwitz-Birkenau when the Germans abandoned the camp in January 1945, survived the war, and died in Switzerland in August 1980.xiii If Auschwitz-Birkenau had been a place of mass exterminations, why would the German authorities leave behind thousands of disabled Jews such as Otto Frank to testify to their genocide? Primo Levi, a Jewish Communist, is another disabled Jew who one would think would have been executed at Auschwitz-Birkenau. However, along with about 7,000 to 8,000 additional disabled Jews, Levi was left behind in Auschwitz. Although the Germans could have easily gassed and cremated these Jewish inmates in crematorium V at Birkenau during the first week of January 1945, they let them survive the war to tell their stories about Auschwitz-Birkenau.xiv
NO EXTERMINATION ORDER
Originally the “Holocaust” story assumed that Germany had a plan or program for exterminating the Jews. In the 1961 edition of his book The Destruction of European Jews, Raul Hilberg wrote that in 1941 Hitler issued two orders for the extermination of the Jews.xv However, even though the Allies captured most of Germany’s government and concentration camp records intact, no order or plan has ever been found to exterminate European Jewry. In the revised 1985 edition of Hilberg’s book, all references to such extermination orders from Hitler were removed. Browning, in a review of the revised edition of The Destruction of European Jews, wrote: “In the new edition, all references in the text to a Hitler decision or Hitler order for the ‘Final Solution’ have been systematically excised. Buried at the bottom of a single footnote stands the solitary reference: ‘Chronology and circumstances point to a Hitler decision before the summer ended.’ In the new edition, decisions were not made and orders were not given.”xvi
With respect to Hitler’s role in the alleged extermination of European Jewry, Browning testified at the 1988 Ernst Zündel trial that there was no proof of a written order from Hitler to exterminate Jews. Browning testified that Hitler had adopted the nod theory, which held that it only took a nod from Adolf Hitler to exterminate Jews. “I did indeed coin the phrase that it would have only taken a nod of the head, or it could have only taken yes,” Browning testified. “We have, I have argued, circumstantial evidence of at least incitements or initiative.”xvii
Then what proofs exist of the so-called “Final Solution”? Browning testified at the 1988 Ernst Zündel trial that, in his opinion, the Wannsee Conference protocol and the diary of Hans Frank, the wartime governor of German-ruled Poland, were the two most striking proofs of a plan of extermination.xviii Other Holocaust historians also claim that the Wannsee conference held on January 20, 1942, was the start of a program to systematically exterminate Europe’s Jews. The documentary evidence of this meeting, however, shows that no extermination program existed. Instead, the German policy was to evacuate the Jews to the East. Israeli Holocaust historian Yehuda Bauer has declared, “The public still repeats, time after time, the silly story that at Wannsee the extermination of the Jews was arrived at.”xix
Likewise, Israeli Holocaust historian Leni Yahil has stated in regard to the Wannsee conference, “[I]t is often assumed that the decision to launch the Final Solution was taken on this occasion, but this is not so…”xx Hans Frank’s diary also does not indicate that Germany had an extermination program against Jews during the war. Instead of destroying his diary, Frank voluntarily handed his 43-volume diary to the officers of the American army who arrested him.xxi
It should be noted that Frank had a volatile personality, and that blood thirsty and inflammatory statements were also made by the Allies during the war. In a war in which many millions of people were killed, emotions ran high. Highly provocative and heated statements, including ones made by Frank in parts of his diary, were made by supposedly responsible leaders on both sides of the war.xxii
Hans Frank testified at the International Military Tribunal (IMT) that he had not known of a program of mass killings of the Jews during the war. However, when asked if he had participated in the annihilation of the Jews, Frank stated: “I say yes… particularly after hearing the testimony of the witness [Rudolf] Höss, my conscience does not allow me to throw the responsibility on these minor people… A thousand years will pass and still this guilt of Germany will not have been erased.”xxiii This last sentence has been repeatedly quoted in books and articles about National Socialist Germany. It does not prove that Germany had a program of genocide against the Jews. It only shows that Hans Frank believed the false testimony by Höss at the IMT that had been criminally obtained by the Allies through the use of torture.
EXTERMINATION OF JEWISH WORKERS
To his credit, Browning writes that the German use of Jewish slave labor was not a matter of consensus and could vary greatly as to time, circumstance, and place.xxiv However, Browning frequently cites instances where Germans used extreme measures to exterminate Jewish workers. For example, Browning writes that Heinrich Himmler labored furiously between the spring and fall of 1943 to murder the Polish “work Jews.” Browning writes:
This elimination of these “work Jews” was not, I must emphasize, achieved through what the Nazis euphemistically termed “destruction through labor.” For the most part, the victims were not gradually worked and starved to death. Rather, the workers in these camps and remnant ghettos were killed in a relentless campaign of systematic mass murder, exemplified above all by the great Erntefest or “harvest Festival” massacre of 42,000 “work Jews” in the Lublin district in a mere two days on November 3-4, 1943.xxv
Browning describes the Erntefest massacre as one of the largest German killing operations against Jews in the entire war.xxvi However, Browning provides no credible documentation that these 42,000 “work Jews” were massacred in two days. He apparently thinks that we will take it on good faith that these mass murders happened. Browning is correct that there were instances where Jewish inmates were overworked. For example, Mauthausen in Austria was a German concentration camp in which the working conditions were horrible.
The camp was located near a quarry which was a principal supplier of paving stones for Vienna and other cities. Stone cutting and hauling is a strenuous occupation in the best of circumstances, but at Mauthausen the work was especially arduous. Most of the labor in the quarry was done with pick and axe, and prisoners hauled heavy chunks of granite on their backs up 186 steps that connected the camp to the quarry. Conditions at Mauthausen got even worse after the evacuation of Auschwitz, when thousands of Hungarian Jews were sent to Mauthausen and its sub-camps. Marched through the winter without adequate clothing and food, prisoners who survived to enter Mauthausen were usually in desperate physical and psychological condition.xxvii
Mauthausen also spawned an especially brutal system of close to 50 sub-camps. The major sub-camps were Gusen and Ebensee. In addition to quarry work, inmates at Gusen built underground armament factories for the production of machine guns and other weaponry, as well as fuselages for Messerschmidt aircraft. Ebensee was created in 1943 to provide labor for the construction of underground factory tunnels. Both sub-camps in 1945 became end-destinations for dying transported workers from other camps. By the end of the war, conditions at Mauthausen and its satellite camps were so bad that everyday hundreds of prisoners died from exhaustion, starvation, dehydration, typhus, and other diseases.xxviii Browning is not correct, however, that German work policies were designed to kill Jewish workers.xxix
There are numerous documents indicating that the Germans attempted to improve working conditions for their Jewish inmates. For example, on December 28, 1942, SS officer Richard Glücks, who was the head of the camp administration office, sent a directive to commandants of the concentration camps. This directive ordered that “…camp physicians must use all means at their disposal to significantly reduce the death rate in the various camps… The camp doctors are to see to it that the working conditions at the various labor sites are improved as much as possible.” The directive also stressed that “the Reichsführer SS [Heinrich Himmler] has ordered that the death rate absolutely must be reduced.”xxx
Glücks followed up his directive in January of 1943 by informing the concentration camp commandants, “As I have already pointed out, every means must be used to lower the death rate in the camps.”xxxi German camp administrator Oswald Pohl, in an order dated October 26, 1943, gave specific measures to ensure the health and productivity of the internees of the camps. A copy of the order was sent to Himmler. Pohl began by stating the importance of the camps in the war effort. In addition to stressing the importance of proper nutrition, clothing, and rest, Pohl specified that ill prisoners were to receive a special diet to help restore their health.xxxii While such directives were not always implemented as ordered, such directives did help lower the death rates in the camps. Such orders are inconsistent with a plan to commit genocide against European Jewry. GENOCIDE ON THE EASTERN FRONT
Christopher Browning writes that the Germans used gas vans to murder Jews in the Soviet-occupied territories.xxxiii Ingrid Weckert writes regarding the alleged German gas vans:
There is no document to indicate that [homicidal] “gas vans” had ever come up for discussion in the Third Reich. The term dates from post-war times… To automatically connect the term “Special Motor Vehicle” with the murder of Jews reveals gross ignorance of the facts… To date, no vehicle which clearly could have served as [a] “gas van” has ever been found.xxxiv
Browning does not tell us how the alleged German homicidal gas vans operated. This is typical of virtually all “Holocaust” historians. American engineer Friedrich Paul Berg wrote regarding the “Holocaust” literature that “as far as the actual mechanics of the extermination process are concerned, about all one ever finds is an occasional short and vague description.”xxxv Browning never provides even a short and vague description of how purported German homicidal gas vans operated. Browning also disputes Jewish Princeton University historian Arno Mayer’s belief that the murder of Soviet Jews was not part of a comprehensive German plan of extermination. Mayer writes:
Even so, and notwithstanding the unparalleled magnitude of the Jewish suffering, the extermination of eastern Jewry never became the chief objective of Barbarossa. The fight for Lebensraum and against Bolshevism was neither a pretext nor an expedient for the killing of Jews. Nor was it a mere smoke screen to disguise the Jewish massacres as reprisals against partisans. The assault on the Jews was unquestionably intertwined with the assault on Bolshevism from the very outset. But this is not to say that it was the dominant strand in the hybrid ‘Judeobolshevism’ that Barbarossa targeted for destruction. In fact, the war against the Jews was a graft onto or a parasite upon the eastern campaign, which always remained its host, even or especially once it became mired deep in Russia. When they set forth on their mission, Einsatzgruppen and the RSHA were not given the extermination of Jews as their principal, let alone their only, assignment.xxxvi
Mayer states that the killing of Jews in the Soviet Union occurred as the result of the inexorable radicalization of the war in the east, and because many Soviet Jews were classified by the SS as carriers of Bolshevism.xxxvii Browning writes: “Mayer sees the mass murder of European Jewry as a byproduct of Nazi Germany’s anticommunist crusade on the one hand, and its hyperexploitation of impressed labor on the other.”xxxviii Browning says that Mayer “refuses to understand the Final Solution for what it was—the Nazis’ plan to kill every last Jew in Europe on whom they could lay their hands.”xxxix Browning thinks that Mayer has gone astray in his understanding of the “Holocaust.” Browning relies on the Einsatzgruppen reports to indicate that extremely large numbers of Jews were murdered in the Soviet Union, and that these killings were part of a program that had been coordinated and monitored by Berlin.xl However, Carlo Mattogno has shown that the figures quoted in the Einsatzgruppen reports are inaccurate. Mattogno writes:
For example, in the summary of the activity of Einsatzgruppen A (October 16, 1941 to January 31, 1942) the number of Jews present in Latvia at the arrival of the German troops is 70,000, but the number of Jews shot is reported as being 71,184! Furthermore, another 3,750 Jews were alive in work camps. In Lithuania, there were 153,743 Jews, of which 136,421 were allegedly shot, whereas 34,500 were taken to the ghettos at Kaunas, Wilna, and Schaulen, but the total of those two figures is 170,921 Jews!xli
The British trial of German Field Marshall Erich von Manstein also proved the inaccuracy of the Einsatzgruppen reports. The prosecution’s case was based on the reports showing that Einsatzgruppe D under the command of Otto Ohlendorf had executed some 85,000 Jews in four and one-half months. Manstein’s defense attorney, Reginald T. Paget, wrote that these claims were quite impossible:
In one instance we were able to check their figures. The S.D. claimed that they had killed 10,000 in Simferopol during November and in December they reported Simferopol clear of Jews. By a series of cross checks, we were able to establish that the execution of the Jews in Simferopol had taken place on a single day, 16th November. Only one company of S.D. was in Simferopol. The place of execution was 15 kilometers from the town. The numbers involved could not have been more than about 300. These 300 were probably not exclusively Jews but a miscellaneous collection of people who were being held on suspicion of resistance activity… It was indeed clear that the Jewish community had continued to function quite openly in Simferopol and although several of our witnesses had heard rumors about an S.D. excess committed against Jews in Simferopol, it certainly appeared that this Jewish community was unaware of any special danger… By the time we had finished with the figures and pointed out the repeated self-contradiction in the S.D. reports, it became probable that at least one “0” would have to be knocked off the total claimed by the S.D. and we also established that only about one-third of Ohlendorf’s activities had taken place in von Manstein’s area. It is impossible to know even the approximate number of murdered Jews, for not only was Ohlendorf lying to his superiors but as we were able to show his company commanders were lying to him.xlii
Von Manstein testified that he had no knowledge that the Einsatzgruppe D or the German army had a policy of murdering Jews. The court believed Manstein and found him innocent of murdering Jews.xliii Peter Winter has also exposed the fraudulent nature of the Einsatzgruppen reports.xliv Thus, the Einsatzgruppen reports do not support Browning’s statement that there was “a conscious Nazi policy aimed at the systematic extermination of every last Jew in Europe.”xlv Arno Mayer is correct that the deaths of Soviet Jews were not attributable to a German policy of genocide. CONCLUSION
Deborah Lipstadt writes that Christopher Browning and her other four expert witnesses—Richard Evans, Peter Longerich, Robert Jan van Pelt, and Hajo Funke—“constituted the historian’s ultimate dream team.” She says these professors were appalled by David Irving’s cavalier treatment of the historical record and made an exceptional commitment in her defense against Irving’s libel suit.xlvi I agree with Lipstadt that Christopher Browning and her four other well-compensated expert witnesses made an exceptional commitment in her defense against David Irving’s libel suit. However, none of these expert witnesses has been able to prove a German policy of genocide against European Jewry.
ENDNOTES
1. https://history.unc.edu/emeritus/christopher-r-browning/.
2. Kulaszka, Barbara, (ed.), Did Six Million Really Die: Report of Evidence in the Canadian “False News” Trial of Ernst Zündel, Toronto: Samisdat Publishers Ltd., 1992, pp. 84-157.
3. Lipstadt, Deborah E., History on Trial: My Day in Court with David Irving, New York: HarperCollins Publishers Inc., 2005, pp. 189-198.
4. Browning, Christopher R., Nazi Policy, Jewish Workers, German Killers, New York: Cambridge University Press, 2000, p. 32.
5. Browning, Christopher R., The Path to Genocide: Essays on Launching the Final Solution, New York: Cambridge University Press, 1992, p. 84.
6. Browning, Christopher R., Remembering Survival: Inside a Nazi Slave-Labor Camp, New York: W. W. Norton & Company, 2010, p. 65.
7. Hilberg testimony in the Ernst Zündel case, Toronto District Court, Jan. 18, 1985. Transcript p. 1229.
8. Atlanta Journal and Constitution, Sunday, March 31, 1985, p. 15A. See also Weber, Mark, “Wilhelm Höttl and the Elusive ‘Six Million’,” The Journal of Historical Review, Vol. 20, No. 5/6, Sept./Dec. 2001, pp. 29-30.
9. Stäglich, Wilhelm, Auschwitz: A Judge Looks at the Evidence, Institute for Historical Review, 1990, p. 31.
10. Interview with Norman Finkelstein, by Viktor Frölke, in Salon.com, “Shoah business,” Aug. 30, 2000. See also Finkelstein, Norman, The Holocaust Industry, New York: Verso, 2000, p. 81.
11. Pinter letter in the national Catholic weekly, Our Sunday Visitor, June 14, 1959, p. 15. See also Kulaszka, Barbara, (ed.), Did Six Million Really Die: Report of Evidence in the Canadian “False News” Trial of Ernst Zündel, Toronto: Samisdat Publishers Ltd., 1992, p. 153.
12. Mattogno, Carlo and Nyiszli, Miklos, An Auschwitz Doctor’s Eyewitness Account: The Bestselling Tall Tales of Dr. Mengele’s Assistant Analyzed, Uckfield: Castle Hill Publishers, 2020, pp. 391-407.
13. Weber, Mark, The Journal of Historical Review, May/June 1995, Vol. 15, No. 3, p. 31.
14. Faurison, Robert, “Witnesses to the Gas Chambers of Auschwitz,” in Gauss, Ernst (ed.), Dissecting the Holocaust: The Growing Critique of Truth and Memory, Capshaw, AL.: Thesis and Dissertations Press, 2000, p. 142. See also Mattogno, Carlo, Auschwitz: The Case for Sanity, Volume Two, Washington, D.C.: The Barnes Review, 2010, p. 558.
15. Hilberg, Raul, The Destruction of European Jews, New York: Harper & Row, 1986.
16. The Revised Hilberg, Simon Wiesenthal Annual, Vol. 3, 1986, p. 294.
17. Kulaszka, Barbara, (ed.), Did Six Million Really Die: Report of Evidence in the Canadian “False News” Trial of Ernst Zündel, Toronto: Samisdat Publishers Ltd., 1992, p. 110.
18. Ibid.
19. Canadian Jewish News, Toronto, Jan. 30, 1992, p. 8.
20. Yahil, Leni, The Holocaust: The Fate of European Jewry, 1932-1945, Oxford University Press, 1990, p. 312.
21. Kulaszka, Barbara, (ed.), Did Six Million Really Die: Report of Evidence in the Canadian “False News” Trial of Ernst Zündel, Toronto: Samisdat Publishers Ltd., 1992, p. 113.
22. Ibid., p. 115.
23. Taylor, Telford, The Anatomy of the Nuremberg Trials: A Personal Memoir, New York: Alfred A. Knopf, 1992, p. 368.
24. Browning, Christopher R., Remembering Survival: Inside a Nazi Slave-Labor Camp, New York: W. W. Norton & Company, 2010, p. 153.
25. Browning, Christopher R., Nazi Policy, Jewish Workers, German Killers, New York: Cambridge University Press, 2000, p. 89.
26. Browning, Christopher R., Ordinary Men: Reserve Police Battalion 101 and the Final Solution in Poland, New York: Harper Collins Publishers, 1992, p. 135.
27. Abzug, Robert, Inside the Vicious Heart: Americans and the Liberation of Nazi Concentration Camps, New York and Oxford: Oxford University Press, 1985, pp. 106-107.
28. Ibid., pp. 108, 123.
29. Browning, Christopher R., Nazi Policy, Jewish Workers, German Killers, New York: Cambridge University Press, 2000, p. 60.
30. Nuremberg document PS-2171, Annex 2, NC&A (The “red series”), Vol. 4, pp. 833-834.
31. Document NO-1523, NMT (The “green series”), Vol. 5, pp. 372-373.
32. Pohl order to camp commandants, Oct. 26, 1943. Bundesarchiv (Koblenz), Bestand SS-Wirtschafts-Verwaltungshauptamt. Signatur NS 3/386. Sammlung von Verwaltungsanordnungen, insbes. KL.
33. Browning, Christopher R., The Origins of the Final Solution: The Evolution of Nazi Jewish Policy, September 1939-March 1942, Lincoln, NE: University of Nebraska Press, 2004, p. 304. See also Browning, Christopher R., The Path to Genocide: Essays on Launching the Final Solution, New York: Cambridge University Press, 1992, p. 81.
34. Weckert, Ingrid, “The Gas Vans: A Critical Assessment of the Evidence,” in Gauss, Ernst (ed.), Dissecting the Holocaust: The Growing Critique of Truth and Memory, Capshaw, AL.: Thesis and Dissertations Press, 2000, pp. 217-218.
35. Berg, Friedrich Paul, “The Diesel Gas Chambers: Ideal for Torture—Absurd for Murder, “ in Gauss, Ernst (ed.), Dissecting the Holocaust: The Growing Critique of Truth and Memory, Capshaw, AL.: Thesis and Dissertations Press, 2000, pp. 435-436.
36. Mayer, Arno, Why Did the Heavens Not Darken? The ‘Final Solution’ in History, New York: Pantheon Books, 1988, p. 270.
37. Mattogno, Carlo and Graf, Jürgen, Treblinka: Transit Camp or Extermination Camp?, Washington, D.C.: The Barnes Review, 2010, p. 208.
38. Browning, Christopher R., The Path to Genocide: Essays on Launching the Final Solution, New York: Cambridge University Press, 1992, p. 77.
39. Ibid., p. 84.
40. Lipstadt, Deborah E., History on Trial: My Day in Court with David Irving, New York: HarperCollins Publishers Inc., 2005, p. 190.
41. Rudolf, Germar and Mattogno, Carlo, Auschwitz Lies: Legends, Lies & Prejudices on the Holocaust, Washington, D.C.: The Barnes Review, 2011, p. 243.
42. Lipstadt, Deborah E., History on Trial: My Day in Court with David Irving, New York: HarperCollins Publishers Inc., 2005, pp. 307-308.
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