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   David Irving to Ian Kershaw

London, April 3, 1999

Dear Professor Kershaw,

Please regard this letter, for various legal reasons, as confidential. As you may know from the grapevine, I have brought in 1996 a libel action against the American author, Professor Deborah Lipstadt, and her UK publisher Penguin Books Ltd, for passages in her book Denying the Holocaust. It turns out that most of these passages were supplied to her by bodies that I will call "all the usual suspects", principally outside the UK. These bodies have run a reckless and continuous defamation campaign against me since 1977, even for example trying to implicate me in the Oklahoma City bombing.

From the documents produced in her Discovery, it is clear that I was not mentioned in her original manuscript; I am sorry to say that Professor Yehuda Bauer, for whose integrity I formerly had considerable respect, and whose agency commissioned the book, then wrote her asking her to make me one of the principal objects of attack, even at that late stage. The libel action is the result. If you are interested in the nature of the Claim, her Defence, and my Reply, you will find them on my Website at:

You are familiar with my writings, so you may feel that I have brought this nuisance on my own head by my obstinacy and refusal to accept blindly what I cannot find archival proof of. (In short, I have probably found and published more Holocaust-related documents, like the Bruns and Aumeier dossiers, than any other historian: but I refuse to buy the whole package, and this has outraged their establishment).

After a slow, ostrich-like start, Lipstadt retained Anthony Julius and Messrs. Mishcon de Reya for her defence. Julius has created a multi-million dollar defence fund. The High Court has last week fixed the date for the trial to begin. It will begin on January 11, and is estimated to last twelve weeks. It may even drag on as long as the MacLibel case. I do not expect to start calling witnesses before the end of January. I shall be bringing in expert witnesses from New Zealand, Australia, and Canada. The High Court has allowed me six historians, and six political scientists. Needless to say, I am shooting for only the finest names &emdash; "revisionists" are firmly out. I wonder how much the Court will allow me to introduce, and how much they will (no doubt rightly) exclude as irrelevant.

Anyway, the purpose of this message is twofold:

1. I am looking for an expert on the wartime spoken and written German language, who can testify impartially for a couple of hours one day, probably in February, on the meaning of Third-Reich words: the knotty problem of Nazi euphemisms (like Umsiedlung); how words change their meaning as time passes, and even depending on who is speaking them and to whom they are being spoken. May I state straight away I am not looking for a blind advocate of any cause: merely a button-down collar type of expert, at whom both sides can with profit fire questions, and who can educate the judge in this respect (this is not being heard by a jury).

2. Would you yourself be confident in answering such questions, given your eminent background?

3. Would you be willing to give expert testimony for a couple of hours on the same basis about my products as a researcher and writer? Given your own solid and uncontroversial background, I am sure that the court would attach great weight to your remarks. Part of the reckless Lipstadt allegations against me is that I have manipulated evidence, mistranslated documents, suppressed items, damaged and destroyed archives (and even that I stole the Goebbels diaries from the Moscow archives!)

If you would agree to assist the Court in this way, as what is called "an expert witness", one of the formalities is that I must draw up before the end of April a brief outline of the areas you would cover. It is all part of the new Rules: there is nothing "Perry Mason" allowed -- no last-minute opening of the courtroom doors and surprising production of a witness who solves the mystery in the final three minutes of the soap-opera. All cards are on the table, in advance.

May I repeat, that I am (perhaps surprisingly) not looking for partiality; if any of my witnesses needs to say things that run counter to my cause, so be it. I want to get at the truth on a number of matters, and the real experts are the ones who will count for more in my view than the David Cesaranis and Walter Laqueurs. (Incidentally, I never knew that L. was not a trained historian).

Yours sincerely,

David Irving

Professor Ian Kershaw
Department of Modern History
University of ShefÞeld
ShefÞeld S10 2TN


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