David Irving portrait

David Irving

[Photo by David Gamble for The Independent on Sunday]


About the Author,

a biographical letter, August 11, 1996


EXPLANATION: In 1992 the Board of Deputies of British Jews, a powerful and secretive British organisation, smeared David Irving in a secret report sent to the League of Human Rights of the B’nai Brith Canada, to enable them to block his next visit to Canada. JuliusOnly in 1994 did David Irving obtain, through Access to Information Act procedures, the report and establish that the Board was its author; he then sought High Court leave to commence (out of time) libel proceedings in Britain.

First however he negotiated behind the scenes with the Board's lawyers for an amicable settlement, whereby the Board would agree to withdraw its lying document, and he would not claim damages. Anthony Julius, the Board's lawyer (photo), quite properly challenged Mr Irving on the veracity of the Board's allegations. This letter is the author's confidential reply, in which he herewith waives privilege.

THIS LETTER is reproduced here with hyperlinks and illustrations added by this Website. See too Notes for Counsel, 1970, Torpedo Running, 1985, and a New Zealander's Independent (Jewish) assessment (1998)


81 Duke Street, Grosvenor Square, London W1M 5DJ

telephone 0171 499 9409; fax 409 7048

London, Sunday August 11, 1996

Your reference: 5/AJ/JLL/m

Without Prejudice

Dear Mr Julius,

The Board of Deputies of British Jews

First I must apologise for not having responded earlier substantively to your letter of March 5 [1996] with the enclosed Questionnaire.[Neither document is posted on this Website]

I was stricken down with pneumonia for several weeks, and was then swept up with the affairs surrounding the successful U.K. publication of my latest book, and the U.S. non-publication of the same, which I shall adduce in due course as further evidence of the pecuniary damage that I have suffered because of the campaign mounted in Canada, Austria, Germany, South Africa and elsewhere by your clients or their agents.

The Answers to the Questionnaire which you enclosed are as follows:-

David Irving's father6.2 Irving claims that his father was also a polar explorer

1. Do you claim this?

ANSWER: No. I claim that he was "an author, Arctic explorer, and naval officer who served in the Battle of Jutland in 1916…" etc. See enclosed page from my biographical brochure TORPEDO RUNNING.

2. Was your father a polar explorer?

ANSWER: As a Royal Navy officer in the 1920s my father served on expeditions to Antarctica aboard HMS Discovery and the William Scoresby.

COMMENT: The defamatory sting is in the word claims, since in the context of the Report complained of it implies that I am boasting about something knowing it to be untrue.

8. Parents "divorced"

1. Did your parents divorce? If not, did they separate?

ANSWER: They were not divorced; they were separated, he living in North Wales, she with us in Essex.

9. [No questions were asked.]

10. "Untrue … 800 Washington Street, Key West, Florida."

1. What is the nature of your relationship with this address?

ANSWER: This is a hotel, at which I occasionally stayed from January 1987 when visiting Key West.


2.2.5 "Untrue … civil war."

 1. Please tell us his full name. We will then seek independent verification.

ANSWER: My first wife's father was Enrique Stuyck Candela, who died aged 54 in February 1962, a few days after the death of his wife. He was a businessman with a Chemistry degree. He was never in the Spanish armed forces on either side. Like him, most of his family (brothers) were on the Republican side in the Spanish civil war; his brothers had to flee to South America after Generalisimo Francisco Franco came to power. Her mother's brother Enrique Roma Jover was shot by the communists in error (his father, the real target of the communist assassins, was already dead).

COMMENT: The defamatory sting is in the innuendo that I deliberately married into a top Spanish falangist, fascist or militarist family.

3.1/3.2.1. "let me state quite categorically that neither then nor since have I 'received funding or other material assistance from Nazis' even taking the broadest definition of those words."

1. Please explain which of the following groups and individuals you include in your 'broadest definition' of 'Nazis' to enable us to understand what you mean by this.

ANSWER: For the purposes of this answer I include the groups numbered by you 2, 3, 4, 5, 6 in this definition of the word "Nazis"; I do not exclude the possibility that one or other member of those groups may have, with or without my knowledge, purchased individual books or similar material either directly or indirectly from me in the normal course of my business as an historian, author, and publisher. As for the other numbers, while I am unable to adjudge whether they count as "Nazis" or not, the following data on my financial relations (or non-relations) with them should adequately serve the purposes of your Questionnaire:

6. British National Party 1980 to present. I am not familiar with their programme or policies, so cannot judge if they are "Nazi" or not. I find that we (Focal Point Publications) have in the past supplied books to them, and on precisely the same terms as to other booksellers, i.e. not on more favourable terms. There is otherwise no other point of contact whatever between the BNP as such and myself or my publishing operation.

7. Freedom Books/Videos. I have not heard of them, and they are not listed on my bookseller database. There is no other point of contact whatever between Freedom Books / Videos and myself or my publishing operation.

8. John Tyndall. I hold this gentleman at arm's length. When CHURCHILL'S WAR vol. i was presented at a press conference aboard HMS Belfast in November 1987, Mr Tyndall was observed to be present: he had not been invited, and I conducted an internal inquiry as to how he came to be there. (It turned out that one of the guests had invited him, without my authorisation).


9. Anthony Hancock. He has been one of the several printers used by us on a normal commercial basis over the last years. His right-wing views are well known. This fact no more dissuades me from using his firm than the fact that B & H Newman Printers [of London] were Jewish enjoined me from using their firm for many years (I stopped using the latter firm in 1994 after I learned that they had volunteered private materials on me and my book publications without consulting me and without my authorisation to a third party, namely a lawyer for a German plaintiff in a lawsuit).

10. Gerhard Frey. Hired me for a series of history lecture tours in Germany from about 1982 to about 1988. His organisation awarded to me two certificates during this period, which were each linked with a cash award; one was called the Freedom Prize (I think), and the other the Rudel prize, named after a German WW2 fighter ace. As his organisation is legal, properly constituted under the Federal German law, and has never been banned, I do not consider the word "Nazi" would be appropriate for it.

11. François Genoud. His views have become widely known since his recent death. When we met we never talked about his views, since our negotiations were purely those of an author and historian dealing with a man sitting on and controlling exclusive access to important caches of wartime documents. Since there was never any commercial or pecuniary relationship between us, on even the slightest scale, and no money between us ever changed hands, whether or not he was a "Nazi" is irrelevant.

12. Ewald Althans. I first met this odd young man in October 1989; at that time he had views which to me were excitable rather than eccentric or extreme. He was not at that time a "Nazi" by any standard. He subsequently became relatively extreme (i.e. not advocating violence), and by 1991 it was plain to me that he had become a hired agent provocateur of the Federal German government. He subsequently, during his trial in Berlin, admitted as much. He thus became not so much a "Nazi" as a fake "Nazi". I made plain to him in 1991 that I wished nothing further to do with him, and I was very angry when--it now turns out, on German government pay--he turned up like a Bad Penny everywhere I was, whether in Los Angeles or Ontario.

13. Jean Marie le Pen. There is no point of contact whatever between this gentleman (or his organisation) and myself or my publishing operation. We have never met, corresponded, or spoken.

14. Ernst Zündel. I first met this gentleman in Ontario in November 1987, and in April 1988 I was accepted by the District Court in Toronto as an expert defence witness to give evidence as an historian at his trial on the charge of spreading false information. Along with the other witnesses called by the prosecution and defence, I was subsequently paid a witness-fee and expenses for the six days I was in Toronto. After many appeals and counter-appeals, he ultimately was cleared of the offence. I do not consider him to be a "Nazi," though he has been driven into adopting extreme positions by the organised Jewish harassment and the orchestrated violence to which he has been subjected.


15. Kirk Lyons. See my attached affidavit [*], which provides the relevant data. I do not consider him to be a "Nazi" for the purposes of this Questionnaire.

16. Nick Griffin. There is no point of contact whatever between this gentleman (or his organisation) and myself or my publishing operation. To the best of my belief we have never met or spoken.

17. Eric D Butler. I do not consider him to be a "Nazi" for the purposes of this Questionnaire. Although it is possible that he, along with hundreds of other Australians, has contributed to the David Irving Fighting Fund (Australia) I have no proof of this as it is managed Down Under.

18. Willis Carto. I do not consider him to be a "Nazi" for the purposes of this Questionnaire. Apart from receiving orthodox and modest fees for lecturing on two or three occasions on historical topics on which I had amassed expertise to the Institute for Historical Review (IHR) at the time when he was running it, I have received no funds from him. In 1993 he offered me a fee to write an article on his legal dispute with the IHR; having spent some days scrutinising the papers on the affair which he sent me, I declined the offer.

Speer19. Albert Speer. I consider him to be a "Nazi" for the purposes of this Questionnaire.

20. National Front (1979). I am not familiar with their programme or policies, so cannot judge if they are "Nazi" or not. There was and is no point of contact whatever between the NF as such and myself or my publishing operation.

21. Martin Webster. There was and is no point of contact whatever between this man as such and myself or my publishing operation. He on one brief occasion carried out typesetting work for us, under a pseudonym. When I learned of his real identity--which had not been known to me--I instructed my staff to make no further use of his firm.

22. Martin Wingfield. There was and is no point of contact whatever between this man as such and myself or my publishing operation.

3.2.3. "… opulent lifestyle"

1. Do you life in Mayfair?

ANSWER: I have lived since [November 1968] in north Mayfair; in 1985 I was given the opportunity to purchase a lease on my property at about half of its real value.

2. Do you or did you ever drive a Rolls-Royce?

ANSWER: In about 1977 I purchased for £9,000 a second hand Rolls Royce; I sold it twelve years later for £5,000. I bought it because of its low maintenance costs compared with the previous British Leyland cars I had driven.

3. Do you or did you ever travel extensively abroad?

[* Not posted here. This was provided at the request of the lawyers investigating the Oklahoma City bombing]


ANSWER: Working, yes.

4. Are your suits tailored?

ANSWER: I have two suits only, both tailored in February 1986.

5. Please provide accounts, as offered, for the periods 1960-69, 1970-79, 1980-89, and 1990-present.

ANSWER: Nice try. As it is my contention that your clients and their agents have gone to great lengths to try to ascertain and to deprive me and my family of our sources of livelihood I shall not at this at this stage provide such accounts, nor were they "offered" as you maintain. For the purposes of this Questionnaire I am prepared to instruct my accountant, who has been my accountant at all material times, to answer confidentially a Question framed by yourselves, along these lines:

"It has been suggested that your client David Irving enjoys an opulent lifestyle, and has done for many years. It does not seem that he could maintain such a standard of living without source of income other than his books. From your knowledge of his finances can you confirm whether
(a) Mr Irving's lifestyle over the years that you have known him could reasonably be described as opulent? And whether

(b) he has been funded by Nazis living abroad or in Britain?

"Or has he, in the alternative, sustained himself and his family entirely by royalties from his books, radio and television appearances, lecture income, and bank and other loans including loans from his family?"

Leuchter Report4.1.

1. Have you ever published the Leuchter Report? Have you commented on it? Have you analysed its contents? What is your current view of it?

ANSWER: The Leuchter Report was not mentioned in my complaint of November 14. The answers are however as follows: Yes, trading as Focal Point Publications, in June 1989 I published the U.K. edition of what is commonly called the Leuchter Report, embellishing it with an Introduction in which I drew attention to its gravamen and to its shortcomings. My current view is that although flawed in peripheral details, it provided a worthwhile stimulus to the debate on the gas chambers issue; but that it has been supplanted and complemented by other revisionist research, notably by Jean-Claude Pressac's investigations, and by Germar Rudolf, at the time employed as an expert chemist by the Max Planck Foundation.

2. Do you acknowledge that Hitler was responsible for the mass shootings and mass gassings of approximately 6 million Jews in Nazi-occupied Europe during World War Two?

ANSWER: These allegations were not mentioned in my complaint of November 14. The answers are however as follows: As head of state, Hitler was responsible for any and all crimes within the areas over which he exercised authority at the time in which they were committed.


1. "I was not dismissed as Editor of the Phoenix" [for the reason stated]

1. You describe Albert Vögler as a 'former Nazi". Please forward us a copy of your article on him.

ANSWER: It is not my duty to assist your clients in building their muck-raking archive. I did however spend an hour searching for a copy of The Phoenix (1956) containing the article by me which you requested--it was entitled "Hitler's Paymaster was a Guildsman," and had a photograph showing Hitler and ex City & Guilds student Fritz Thyssen [not Albert Vogler: that was a lapsus linguae by me] touring the Vereinigte Stahlwerke with Albert Vogler, which I remember obtaining from Hodder & Stoughton who had published Thyssen's book "I paid Hitler". That copy of The Phoenix is unaccountably missing from my file, but if it seems important I will try to obtain one.

2. Do you deny that you attempted to conceal the existence of your special supplement to Carnival Times, and that this was the reason for your dismissal by the relevant authorities?

ANSWER: There was no special supplement to Carnival Times; the pages were numbered consecutively right through. As editor, I had discretion on which articles to include and which to exclude. The university student authorities knew the identity of the printing firm, the Haycock Press, and no attempt was made at concealment. I was not dismissed; when the London Student Union announced that they disapproved of my choice of articles, I of course resigned.

2. "The special supplement contained racist cartoons."

1. Did the supplement contain any cartoons? If so please provide a copy.

ANSWER: There was no supplement. The Carnival Times contained a dozen or so comic strips and cartoons of which one addressed the colour issue, being a stinging comment on the hypocrisy of Lefty students who proclaimed their solidarity with anti-apartheid campaigners but were not willing to march with Coloured students in their midst. Copies are attached herewith.

3. "Alleged quotations" in the Daily Mail, May 1, 1959.

1. Which of the quotations in the article do you dispute?

ANSWER: I have dealt with this often over the intervening thirty-seven years, since your clients have never tired of ensuring that the quotations--shorn of their date!--are kept in circulation. I can answer your question most readily by including a copy of the schedule of errors which I drew up for Defence Counsel for the famous PQ.17 libel action twenty-six years ago.

2. The "mild fascist" quote has been used by numerous commentators since 1959. Have you objected to it before. If so when?

ANSWER: Yes, on every occasion that has been brought to my attention, until I have grown sick of it. See above answer.

4. "It is libellous to state that I was active in the BUF."

1. Have of have you had any other involvement or association with the Union Movement.


2. Do you have any involvement with the Friends of Oswald Mosley or its publication Comrade?



2. "Broome deliberately abandoned the convoy to Nazi U boats."

1. What was the judgement of both the Court and the Court of Appeal?

PQ.17 bookANSWER: The quoted allegation is stated nowhere in the book The Destruction of Convoy PQ.17, and when Broome's lawyers authorised changes to enable the book to be published in a sanitised version not one of the changes impinged upon this allegation. The jury in the first instance found against the Defendants and awarded punitive damages; since in Counsel's Opinion their judgement did not accord with the evidence in Admiralty records which we offered as evidence, or with what was actually written in the book, the insurers of the First Defendant (Cassell & Co) authorised an appeal, which ultimately went to the House of Lords. Here it was adjudged that we had established one-third of our case, namely on the issue of Broome's disobedience to orders. In a subsequent Appeal to the Lords, he was ordered to pay one-third of the costs, and ruined, much to my regret.

9. Otto Frank

1. Why did Ullstein remove the reference?

ANSWER: You would have to ask Ullstein. At no stage did they consult me, nor did they inform me, nor did they ask me to indemnify them.

13. "Very few of my talks in Germany were organised by the GFP"

1. How many of your talks in Germany between 1970 and 1980 were organised by the GFP and can you prove this with documentation?

ANSWER: I estimate two or three such functions; I have no documentation other than the printed texts that were subsequently issued of the said talks.

2. How many of your talks in Germany between 1970 and 1980 were delivered at meetings organised by the GFP?

ANSWER: This appears to be the same question as No. 1?

3. Do you accept that GFP functions during this time (c. 1978) were regularly featured in the German neo-Nazi press, including Deutsche National-Zeitung, Deutsche Wochen-Zeitung, and Eckaltbote. Where else were the meetings advertised?

ANSWER: (a) I do not accept the adjective "neo-Nazi" for the first two newspapers, which so far as I am aware are not banned in Germany and never have been; (b) I have no information on whether GFP functions were regularly

featured in these publications, as I do not subscribe to them; (c) I have never heard of Eckaltbote, nor have I seen a copy. I do not know where else the meetings were advertised, but I assume that they were advertised by direct mail to their extensive membership lists. Public advertisement of meetings was avoided, as it usually resulted in the attendance of violent opponents, organised and paid for by groups similar to your clients.


1. In which years has your name appeared on the public list of "Enemies of the State" of Germany.

ANSWER: You tell me! In my para. 27 I stated that this was the first that I had heard of this allegation which features in your clients' Report complained of.

2. What were the reasons for your inclusion on the list?

ANSWER: See above answer. I have considered it important to put in writing to the German office for the protection of the constitution (Verfassungsschutz) my protests about lies about me which they have included in their annual reports, but they have failed to respond or even answer.

3. When was Focal Point established? When did it cease publication?

ANSWER: (a) As an irregular newsletter, Focal Point began informally appearing in about 1980, and ceased publication in 1982. (b) Focal Point is now the imprint of my publishing firm.

28. Clarendon Club

1. Which of the persons listed did you, or did you not, know?

ANSWER: Of those listed by your clients as present at the dinner, I have never knowingly met the following: Beardson, Chaldecott, Webber, Rushton, Griffin, Souter Clarence; I have met John Ormowe, a schoolteacher, but I have no knowledge of his association with any "Column 88"--as is the innuendo of the words in brackets after his name. According to my computer records however the first Focal Point was sent to Chaldecott and Rushton, in 1980/1; and on April 20, 1994 Rushton sent an unsolicited donation to the David Irving Legal Fighting Fund.

2. Which of the persons' "alleged associations" (affiliations) are correct, and which are incorrect?

ANSWER: Tell your clients to do their own research! If I never knowingly met them, and do not know them, how could I answer except with speculation.

3. What exactly do you "not believe to be true?"

ANSWER: That I was aware of their alleged affiliations.

4. Did you buy the National Front mailing list in 1979? If so, why?

ANSWER: I did not personally buy the list, and this is the first time I have heard of this allegation. I would have to locate and ask my then secretary about


his activities. At about that time (I would have said 1980/1/2) we bought several mailing lists, including that of the Young Conservatives or their university association, with the intention of trying mailshots of Focal Point to them.

5. Did Focal Point advertise for secretaries of Far Right groups to sell their mailing lists to Focal Point?

ANSWER: See above. My secretary placed advertisements in, I believe, Spectator, for general secretaries of right-wing and conservative (but not "Far right") groups to sell their mailing lists to us.

6. (a) Who joined the Clarendon Club? (b) You are the proprietor and General Secretary, who else holds, or has held, official positions in the Clarendon Club?

ANSWERS: (a) In general, respectable collar-and-tie people who ate with a knife and fork. We had no screening process, so it is impossible to be more specific. At its most recent head-count it comprised 962 names. (b) You are not entitled to this information, in my view.

7. Where did you promote or advertise the Clarendon Club?

ANSWER: Nowhere; except by direct mailing handbills to its mailing list.

18. Rudel

1. Did you attend a memorial meeting or service for Hans Ulrak [Ulrich] Rudel?

ANSWER: Not that I recall. If your clients provide a date, I will search my diaries. Your clients after all make the allegation.

2. If so, when and where was it?

ANSWER: Your clients make the allegation. They must know.

3. Did you speak at it?

ANSWER: Depends on if there was such a function. I recall speaking once briefly about Rudel's exploits as a tank-killer on the eastern front, but to my recollection he was still alive at that time.

4. Who was it organised by?

ANSWER: Depends on if there was such a function.

5. Approximately how many people attended?

ANSWER: Depends on if there was such a function.

6. Was Rudel a member of the group who organised the meeting?

ANSWER: Depends on if there was such a function. Even if so, I have no means of knowing if he was or was not a member of the organising group. It's all rather vague--meaning your questioning.

1982 - 1984

10. "I have never heard of WISE"

1. WISE was one of a number of prominent Far Right groups in Britain at this time. Are you sure you have never heard of it? If you have heard of it, what was your relationship with it, and its leading activists.


ANSWER: I have never heard of WISE.


1984 - 1985

4. Visit to North London Polytechnic & Patrick Harrington

1. Are you aware that this was reported in Time Out 10-16.5.84. Did you dispute this report when it first appeared?

ANSWER: I do not subscribe to Time Out. I have no recollection of such a meeting. I have genuinely searched all my pocket notebooks for 1984 and find no trace of the meeting. I cannot rule out that my memory is at fault. I would first have to check my main diaries for 1984, which are at present inaccessible. From what I hear lately, Mr Harrington speaks most disparagingly of me.


1988 - 1989

1. Churchill's War

1. Where in the report does it state that "Michael Joseph Limited rejected Churchill's War owing to the severity of its attacks on Churchill"?

ANSWER: Paragraph 1, lines 4 - 6. See attached photocopy.

2. What in this paragraph is untrue and can you supply documentation to prove this?

ANSWER: I stated in my letter of Complaint, November 14, what was untrue. Yes, I can supply documentation to prove it and shall do so in due course under the RSC rules on Discovery. The same editor [Alan Brook] (formerly at Michael Joseph) only recently phoned me to state that he is eagerly awaiting volume ii, since he would like to publish my entire Churchill opus as a boxed set.


6. Berlin Document Centre

1. Please provide the relevant correspondence. See attached photocopies. [Not posted on this Website]

14. War Crimes Leaflet

1. What is your relationship with Focal Point Publications?

ANSWER: It is the publishing imprint under which I do business and publish and distribute books by myself and other authors.

2. Do you know Anthony Hancock?

ANSWER: Yes. I have commercial relations with his Print Factory. See above.


1990 - 1991

 6. March in Munich

1. Verfassungsschutzbericht 1991 states that the Munich County Court fined you over DM7,000 because of an unregistered gathering in Munich on 21.4.90. Do you have documentation to the contrary?

ANSWER: See my comments on the Verfassungsschutz above. They do not respond to letters in which I draw their attention to errors. Their report appears to be largely compiled from press clippings. I have a very bulky file arising from that episode, about ten inches thick; so yes, I do have documentation to the contrary. In summary: After I spoke at a public meeting in Munich on April 21, 1990 I was arrested on the way back to my hotel and accused of participating (actually "leading") an unlicensed demonstration. (Germany is not yet a free-speech country). This allegation was dropped, when it was determined by the police that the demonstration--of which I had not even been part--was actually not an unlicensed one.

Instead I was now charged with what I had stated at the foregoing meeting, namely that the gas chamber shown to tourists at Auschwitz is a fake built after the war. This fact has now been confirmed by the Polish authorities as true; they admit the building was constructed in 1948. Nonetheless I was fined first DM3,000 in absentia, which fine was raised to DM10,000 at the first instance, which fine was increased to DM30,000 on January 13, 1993 because I refused to recant. (Why, indeed, should I? What I had said was true, as has now been confirmed by the French weekly news magazine L'Express, January 26, 1995).

7. "Hitler book and the Jewish Question"

1. What is your relationship with the Faksimile Verlag Bremen publication, "Adolf Hitler und die Judenfrage"?

ANSWER: I am currently only under contract with Faksimile Verlag, or its dependants, to produce two works: (a) Nuremberg, the Last Battle; (b) the Eichmann Papers. The first is the translation of the book which Focal Point are to publish in October. The latter is a facsimile edition of Eichmann's papers, which were handed to me in Buenos Aires in October 1991, with a commentary and introduction by me. Faksimile Verlag may represent this as being the first of a series of volumes under the rubric, Hitler and the Jewish Question. I don't know.

8. IHR Newsletter

1. Who was the "British principal"?

ANSWER: I don't know. It was not I. Like it or not, there are sixty million other British citizens. I am not an official of the IHR, nor privy to their secrets. I can inquire, if you wish.

2. Do you accept that the IHR is a legal organisation?



7.4. Churchill's War

1. Are these quotations not your own, as reported in the press?

ANSWER: They are not quotations from any of my works, including CHURCHILL'S WAR. Nor would I ever use such language. Nor do I believe everything I read in the press.


1. You state, "No ban on entering Germany has ever been notified to me." Are you claiming that you have never been banned from Germany?

ANSWER: The reference is to the years up to 1991, and to an Einreiseverbot, which is different from the Aufenthaltsverbot. There was word-of-mouth report that a ban had been issued against my entering Germany, i.e. the Einreiseverbot. I was never notified of this, however, despite entering Germany many times. The authorities were legally unable to expel me in the absence of an Aufenthaltsverbot. In November 1993 I was handed this latter document (Aufenthaltsverbot) by agents of Germany's political police in a restaurant in Munich. I have not visited Germany since then. As said, not for the first time in its existence Germany is no longer a free-speech country.

2. If you have been banned, when was the ban effective?

ANSWER: See above for answer.

3. What meetings did you speak at?

ANSWER: By this time I had established a large circle of individual private friends and supporters in Germany, and these private individuals organised local audiences for me to address. I do not propose to identify these individuals. As said, Germany is no longer a free-speech country and I do not want to endanger them.

4. Who organised them?

ANSWER: See above.

5. Where and how were they publicised?

ANSWER: See above.

6. Who attended them?

ANSWER: See above.

Hitler's War8. "The Waterstone's group has never 'refused to sell' my book HITLER'S WAR"

1. There are numerous reports from 1992 in which you criticise branches of Waterstone's for withdrawing Hitler's War from sale, and declare that you will distribute it yourself. Are you now saying that this has never happened?

ANSWER: In November 1991 Focal Point republished a special edition of HITLER'S WAR (which is now sold out). Initially Waterstone's stocked it well. Individual branches of Waterstone's--in Norwich, Newcastle, Nottingham,--came under physical attack, as local Jewish groups organised window-smashing festivities, rather like Kristallnacht (or the Nazi Book-burning--I am not

sure which is the most apposite simile here). At that time Waterstone's shops were all part of a chain owned by Mr Tim Waterstone. He wrote to me assuring me that his company would never condone censorship of any sort. A few misguided Marxist department heads within his stores individually decided not to stock my books. The "Waterstone's group" never refused to sell the book however, and it has been selling the latest book, GOEBBELS. MASTERMIND OF THE THIRD REICH very powerfully (it is now owned, I understand, by W H Smith).




You will recall that my purpose in submitting to this Questionnaire was to enable your clients to satisfy themselves that the Report or Reports on me which they had written and published and which had found its or their way into the secret files of various foreign governments was or were essentially not only defamatory but untrue.

I observe that your Questionnaire does not ask questions about very many of the defamatory statements about which I made complaint, which fact I take as tacit acceptance by your goodselves that no defence is contemplated on those points. I hope that you will accept that on those points about which you still had questions, namely those voiced in the Questionnaire, my answers establish that your clients' defamatory remarks were also untrue.

May I point out that regardless of the date on which the report or reports complained of were first composed and published by your clients to third parties, they were marked Confidential and Secret, and they were withheld from my attention as the aggrieved party until years later; and that as recently as September 7 of last year your clients were stoutly denying that they had maintained any such reports (a denial which they were not however prepared to swear in an affidavit). It was not until December that you very properly admitted that your clients were the originators of the report or reports complained of, i.e. it was only then that I knew "all the facts relevant" to the cause of action (Limitation Act 1980 as amended by the Administration of Justice Act 1985). I do now however have my eye firmly on the clock. In the event that we fail rapidly to reach agreement as contemplated in our Without Prejudice correspondence, I shall make timely application to a Master for permission to commence proceedings under the Defamation Act 1952.

If these proceedings are to be conducted in the open, they will be more painful than the settlement which I put in prospect.

As you know, I am not seeking monetary compensation from your clients, subject to our reaching agreement on other matters, namely that your clients agree in writing to withdraw the report or reports complained of in their entirety, admitting that they are defamatory and untrue in essential parts and undertaking not to repeat the defamatory and untrue statements contained therein; this agreement to remain confidential to all parties, except that I shall have the right to disclose it to those persons to whom the original report or reports complained of were published or otherwise disclosed.


I have, it is worth remarking, last year obliged a major Sunday newspaper to pay very substantial damages for just one of precisely the kind of libels contained in the reports complained of in the present correspondence (Queen's Bench 1995 No. I-1803). On May 1 this year furthermore I served a Writ under the Act against The Observer for essentially the same kind of libels (Queen's Bench 1996 No. I-604). Only this last week I have settled out of court, again with the payment of damages, an action which I brought against a West End hotel (CL.535062) which had been encouraged by people none too distant from your clients to violate a contract between us; I am, you will understand, enjoined under the Consent Order from publishing details. I am also about to issue a Writ under the Act against two firms of publishers and the authoress Deborah Lipstadt, and I have issued the first warning letter to the British distributors of the Swedish newspaper Svenska Dagbladet preparatory to serving a Writ for libel on them too, as well as commencing proceedings under ch. 5 of Sweden's Criminal Code for slander.

Let us therefore proceed swiftly to the painless settlement of my complaint against the Board of Deputies, your clients, along the lines that I proposed. Failing which, I shall make application to the High Court Master on or before September 3 for leave to commence proceedings.

Yours sincerely,


David Irving


Mishcon de Reya, Solicitors
• attn.: Anthony Julius •
21 Southampton Row
London WC1B 5HS

File: Ill Wind - a


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