THE CHAIRPERSON: Good morning.

MR. FREIMAN: I wonder, Mr. Chairman, whether, prior to continuing with the proceedings, I might quickly raise an issue of some concern. That is, again, with regard to witnesses ‑‑ the order, identity and the opinions of witnesses.

I am given to understand by Mr. Taylor that Mr. Christie is declining at present to notify the Commission as to the identity of any witnesses past this one and one after that. We have some concerns that, clearly, it is not within the 10-day notice provisions envisaged in your order. In fact, the notice we had of both this witness and the next one was well short of the 10-day notice period.

I also have some concerns that at least one of the statements of intended evidence, in fact, does not tell us what the opinion is. It gives a number of areas that are going to be covered, but it does not tell us what the opinion is.

It is very difficult, obviously, to prepare for cross-examination without adequate notice. I would ask that the Tribunal make an appropriate direction. It does not seem as though it will be possible to have this matter resolved in the normal course on the basis of discussions between counsel.

THE CHAIRPERSON: Mr. Christie, please.

MR. CHRISTIE: At the very close of the case for the prosecution you made a ruling respecting issues that are very crucial to and fundamental to the response. In light of that, we may have had to consider changing some of our position in preparation for the response. We could not, of course, anticipate that you would necessarily rule that way.

As far as the 10-day rule is concerned, we have given to our opponents the curriculum vitae and opinion of Dr. Jacob in written form. We have given them the curriculum vitae and opinion, as far as it has been able to go at the moment, from Dr. Countess.

The position we take is that there are many aspects to the 10-day rule that can indeed be unworkable, particularly when, as here, we cannot foresee your position vis-à-vis the qualifications of this witness.

It is the habit of the Commission and their supporters not to tell us their position until they announce it, which is their right, and they just announced yesterday that they intend to deny the validity of Dr. Jacob's qualifications and to say that he has no right to even express an opinion. They can, of course, say that because they didn't know that much in advance who Dr. Jacob was. Of course, we don't know how you are going to rule on any position they take in that regard. What we might have to do, depending on that ruling we still don't know.

In light of those circumstances, it is impossible to say precisely who the next witness would or could be, depending upon the scope of the ruling that you might make in relation to their position that there is no entitlement for this particular witness to express an opinion. That, of course, could obviate the necessity for any other opinion. It could indicate that we have to bring opinion evidence from some other source. It could indicate that we have to discontinue the response altogether. It could indicate a number of things which we cannot foresee.

In light of those uncertainties, I think it is a little bit presumptuous for the Commission to demand that we strictly comply with the 10-day rule when we cannot anticipate. We have done the best we could in the circumstances.

The ruling that you made at the close or perhaps the day before the close of the Commission's case was not a ruling that we could anticipate. In fact, it is not entirely clear precisely how that will work in relation to our proposed evidence. We hope that Dr. Jacob will be able to testify about what Dr. Schweitzer said, but even that remains to be seen. I expect we will hear vehement denunciations of his right to testify about anything.

In the face of all those uncertainties, I hope you can accept the proposition that it is virtually impossible to give assurances. Much as we would all like to know in advance what you would rule or what my friends' position might be, neither of those things can be known with any certainty at all, and they have a very fundamental effect on what subsequent evidence is possible.

That is our position.

MR. FREIMAN: Very briefly, it is somewhat surprising to hear Mr. Christie express his views as to the unexpected nature of the intention to cross-examine Dr. Jacob on his qualifications, given that with every witness that the Commission has called that is precisely what Mr. Christie did, and at great length. He can hardly be surprised about that.

He can hardly be surprised about the ruling that you provided on Monday, since that was something that was in the cards for 10 days previous to that. As the Panel had noted to him yesterday, there were only two possibilities. Either the Commission's objection would be upheld or it would be dismissed, and he should have been able to anticipate both those things.

Nothing that he said really touches the central issue. We are entitled to some knowledge ahead of time of who his witnesses are. If he can't call them, then he won't call them, but we are entitled to that notice.

My fear is that the result of all this is to make it impossible to proceed in a timely manner. Clearly, if the Commission and the Complainants and Intervenors do not have adequate notice as to who is coming, what his or her qualifications are and what the substance of their evidence is, it is impossible to prepare for cross-examination, and we will be put into the invidious position of having to ask for an accommodation, which is the last thing we want to do in terms of pushing this forward in a timely manner.

We have not objected to Dr. Jacob testifying, even though notice of his evidence was not provided to us until Monday. We are prepared to deal with Dr. Jacob, but we cannot deal with subsequent witnesses without knowing who they are and what they are going to say.

THE CHAIRPERSON: What notice do you have at this point as to how many witnesses the Respondent is calling?

MR. FREIMAN: We were given at the outset of the proceedings a list of 20 names with the caveat that some of those or all of those might be called or others might be called. Subsequently we were given notice of a witness during the proceedings that we held at the Transport Board. We were given notice of that well within the 10-day period. We were informed on Monday that due to logistical difficulties that witness was not appearing.

We have been given notice of Dr. Jacob and of his opinions on Monday. We were given notice of a second witness and of the areas in which he is to testify also on Monday, but not of his opinions in any of those areas.

THE CHAIRPERSON: Ms Matheson, please.

MS MATHESON: I just want to underscore one point, Mr. Chairman, and that is that these are expert witnesses. I think it is fundamental that, before an expert witness gets in the box, you know what the opinions are that are going to be introduced. It forms the framework for everything.

I accept Mr. Christie's statement that that has been given with respect to the witness who is presently testifying, but that is the only witness with respect to whom we have been provided an opinion. We have been provided a curriculum vitae for Dr. Countess, but we have only been provided with a list of topics upon which he will speak, which is insufficient.

With respect to the individual of whom we were notified two weeks ago, we were given notice of his background but no list of topics nor an opinion of any kind from that witness. That witness is apparently unavailable, so perhaps that is not an issue.

These are experts, and that is the basic information that anyone needs before an expert testifies in any hearing.

THE CHAIRPERSON: Mr. Christie, I will hear from you again, but I just want to make a comment.

The Tribunal is extremely reluctant to interfere with the assigned days which we have gathered with great difficulty both from the point of view of all counsel, witnesses and last, and perhaps least, the Tribunal Members who have adjusted their schedules to be here on the appointed days. That was the purpose for the issuing of the practice direction dealing with notice.

We, as Tribunal Members, understand that perfect compliance is not always possible and that there are opportunities to abridge times, et cetera. I wonder what you can do to accommodate the Commission and the Intervenors to make sure that we can proceed next week without interruption.

We have this witness in hand. Dr. Jacob is here and, if he becomes qualified, I assume his evidence will last for an indefinite period of time, maybe a day or many days; I don't know. What comes after that?

MR. CHRISTIE: What I am suggesting is not as Mr. Freiman said, that I am in any confusion about their right or need to cross-examine. Yesterday, in Mr. Freiman's absence, Mr. Rosen indicated that he would object to his being allowed to testify at all.

THE CHAIRPERSON: What is new about that? It happens in almost every situation where a witness is sought to be qualified. They may do that. We here will decide whether he is qualified or not.

MR. CHRISTIE: I understand that, but I was just making the point that Mr. Freiman suggested that I would be wise to understand that he would be cross-examined. I understand that he would be cross-examined. Until yesterday it was not clear that the position would be that he was not qualified. That I simply want to clarify as to my remarks.

As to what was or was not in the cards, we don't necessarily have a means of reading the cards. The fact is that the ruling that you made is subject to the caveat that historical statements of Dr. Schweitzer, for instance on matters of fact, which were given in-chief, could be tested as to their truth. I assume that ruling would apply to all witnesses and, in that context, it requires some consideration of how that would impact and precisely who is qualified in that area and to what extent they would be entitled to testify on matters of fact regarding issues of history. Where he was, can they?

These questions are not entirely at this moment even clear, and it is not going to be easy to resolve precisely how that ruling will impact on those issues.

I have on Monday of this week given Dr. Jacob's précis and curriculum vitae; Dr. Countess' curriculum vitae was given. They are the two intended witnesses. The 10-day rule, as I understand it, means that 10 days before they are to testify there must be some compliance or an attempt at it. Unless there is a reason why it can't be complied with, it would be quite justifiable to demand a reason.

If I understand the present situation, this is Thursday. Assuming Dr. Jacob is qualified, he would be entitled to testify on our behalf for a day, perhaps a day and a half; we don't know precisely what the objections or limits would be. Then we would be perhaps looking at Tuesday before cross-examination began, and we gave notice on Monday. So it would probably be 10 days before Dr. Jacob is through, and we will satisfy the request of the Commission, if we can, to give details of Dr. Countess' opinion.

Due to the difficulties of communication and the issues that are changing from time to time in the case, we have not been able to focus precisely on what areas his opinion could countenance. The limits that are placed on our rights are varying from time to time according to your rulings, and we have to assess those rulings in relation to what his opinion would be allowed to do.

We are going to try today to prepare that and to fax it probably tonight to the parties, as to areas in which his opinion would be tendered and what he would have to say in those areas. That is only possible when we have the opportunity not only to do that, but to assess what the opinion would be allowed to say, at least as far as we are aware to the best of our knowledge.

THE CHAIRPERSON: Is it your present intention to call two experts?

MR. CHRISTIE: No. I have given notice regarding Dr. Martin. It is our intention to assess the situation on the basis of your rulings, as and when the objections arise and the rulings occur. Certainly nothing in the nature of new witnesses would be, in our view at least, likely within the next 10 days, in terms of experts. The duration of these witnesses' testimony, of course, depends on your rulings.

If we are required to fill the available time with the witnesses that are factual, we would at the first opportunity advise you of those, but they would probably have to come from either out of the country or certainly out of the province and we would have to make arrangements to see how and when they would be here.

I hope it is understandable that these circumstances make it virtually impossible to give hard and fast assurances. Knowing full well how readily my estimates are taken as some sort of misrepresentation if I can't fulfil them, I am not too inclined to put in writing or give assurances things that I cannot guarantee. I can do my best to estimate but, when I do that, I don't want it to be misconstrued.

Until I am sure of something, I don't think it is wise to say anything. In those circumstances, unless I am directed to do something else, I intend to proceed to watch matters unfold as they will and as they must.

THE CHAIRPERSON: I guess the direction that you might expect from us is that you be ready to proceed with your next witness during the time that is allotted.

MR. CHRISTIE: I understand that. We will have witnesses in the time that is allotted; I am quite sure of that. I don't intend to ask for any adjournments in the time allotted.

THE CHAIRPERSON: You realize that what you have said is sufficiently vague that it makes it difficult to cope with scheduling, even from the Tribunal's point of view. I think the Tribunal has some sympathy with other counsel in the vagueness of your response. It seems to me that in a normal setting the Tribunal would have a list of witnesses and a summary of what they are going to say, so that they can prepare their cross-examination in a timely way.

MR. CHRISTIE: The Tribunal or the Commission?

THE CHAIRPERSON: Pardon me?

MR. CHRISTIE: I thought you said the Tribunal.

THE CHAIRPERSON: The Tribunal is interested in seeing that there is an appropriate scheduling and compliance with the order of the Tribunal so that we don't have this long discussion.

MR. CHRISTIE: As far as I can see, in the next 10 days the two witnesses will be the present witness and Dr. Countess.

MR. FREIMAN: May I just say that that is in the highest degree unlikely. The Commission and the Intervenors and the Complainants do not foresee themselves cross-examining ‑‑ even in the event that these witnesses are qualified, we do not foresee a cross-examination of the magnitude that Mr. Christie inflicted on Professor Schweitzer.

I just want to add the real point. The real point is that we are not going to get any notice. As I understand the circumlocutions that have preceded, what we will get is announcement of fact witnesses on the day that they are called, with no notice of who they are and what they are going to say. That is not satisfactory either.

The concern the Commission is raising before the Tribunal is that there appears to be a situation created where witnesses will be called with little, if any, prior notice, putting others in the position of either having to proceed to cross-examine blind or to ask for an indulgence. That is just not appropriate in terms of efficient use of this Tribunal's time.

THE CHAIRPERSON: Are you talking about experts or factual witnesses?

MR. FREIMAN: Both. The Tribunal has stated that even factual witnesses need to be identified. It has made a special ruling with regard to how expert witnesses are to be dealt with. We do need to know the identity of factual witnesses also.

THE CHAIRPERSON: I understood you to say that you have a list of witnesses, including factual witnesses.

MR. FREIMAN: No, we have a list of 20 potential expert witnesses. There are no factual witnesses on that list.

THE CHAIRPERSON: I am going to direct that Mr. Christie deliver a list of the factual witnesses that he intends to call not later than tomorrow, Friday, at five o'clock. I am going to further direct on behalf of the Tribunal that those witnesses be alerted to be here so that there is no interruption in the presentation of the evidence next week and the week following.

MR. KURZ: Mr. Chairman, just dealing with that, the problem still remains with Dr. Countess in that with the notice that we have been given, even if Dr. Jacob is qualified and testifies into early next week, we have not been given a report by Dr. Countess. What we have been given is a document that presumably was prepared by Mr. Christie outlining the issues that he proposes to testify on. We don't have his report.

Mr. Christie indicated, in effect, that the 10-day rule will be satisfied and that Dr. Countess will be able to testify next week. In fact, that is not the case. With Dr. Jacob we received notice on Monday, and we are here today ready to go, but with Dr. Countess it is unclear whether we will get any notice of a report, certainly not 10 days in advance but in any way in advance.

THE CHAIRPERSON: Can I ask you to address that issue, Mr. Christie?

MR. CHRISTIE: I said that I am going to do my best and I am going to give you in writing, to the best of my knowledge, what he has to say, his opinion. I concede that it is important and, if I could have done it sooner, I would have. I was not able to do so, and I believe that I can now. I said I would do so tonight by fax to all the parties.

THE CHAIRPERSON: Our direction will apply to that as well, by five o'clock tomorrow.

Mr. Fromm, you wanted to say something.

MR. FROMM: Mr. Chairman, I am not sure of the rules of procedure here. If it would assist the Tribunal, we have indicated that we are prepared to call two expert witnesses, and one of them would be available not this coming week but the following week. I don't know if that would interrupt what the Respondent's lawyer would want to do or how you would wish to proceed, but we could provide on Monday a CV and notice of some of what this witness would have to contribute.

THE CHAIRPERSON: You understand what the ruling is and what the practice direction is in terms of notice. Perhaps the Clerk at the break will give you a copy of the ruling of the Tribunal in that regard.

MR. FREIMAN: I believe what Mr. Fromm is getting at is that he is proposing that the order of proceedings be interrupted so that he could bring his expert witnesses in the middle of the Respondent's case.

MR. FROMM: That is correct.

THE CHAIRPERSON: Why is that?

MR. FROMM: I was suggesting that it might assist the Tribunal if the fear is that there might be an interruption in the proceedings.

THE CHAIRPERSON: We would prefer that the Respondent's case be put in and then, if you have evidence to call, upon proper notice we will consider that at that time.

MR. FROMM: Thank you.

THE CHAIRPERSON: Mr. Christie, have you finished your examination of this witness?

MR. CHRISTIE: I think I may have indicated that, but there are a couple of questions I want to ask.

THE CHAIRPERSON: I would like to hear your last statement which I didn't make a full note about, in the course of what you are doing now, as to why he is being called and the burden of his evidence as an expert in what.

MR. CHRISTIE: I said that at the outset.

THE CHAIRPERSON: You said it at the end and, I am sorry, I didn't make a full note of it.

MR. CHRISTIE: Just let me say, in regard to Mr. Fromm's request, that I personally want to put on record that I am not opposed ‑‑ in fact, we consent to the interruption of our case to allow the calling of any of their expert opinion evidence. I have no objection to that. In fact, I would very much like to have the opportunity to go last. Since we are the Respondent, we should be able to address and respond to whatever is before you by way of information and evidence.

Our position is that we would think it appropriate to request the right to go last since my client is the Respondent. If other evidence is to be called, we would like the opportunity to be able to respond to that, not knowing precisely what it is. That is our concern and, for the record, that is our position.

You asked me a direct question. I said that our position is that this is a witness competent to testify on the subject of the history of ideas. He is competent to express views on the subject of antisemitism, its various forms, its meaning, its nuances and its various motives and effects.

In my submission, he will be entitled to analyze and comment on the opinions of Dr. Schweitzer. His essential evidence will relate to the propositions expressed in Dr. Schweitzer's opinion as set out in tab 3, called "Memorandum on Lethal Antisemitism Old and New" and the proposition that all of the Zundelsite material is necessarily related and part of a continuum of lethal antisemitism. That opinion, which was admitted, was admitted on the basis of his qualifications as a historian and as an expert in antisemitism. Our view is that, if it was relevant to express his opinion in that way, which we say in essence was not so, to establish the foundational facts for that, the law being established in the Zundel case that historians could testify to those matters, as a competent student of intellectual history ‑‑ and it is, after all, Dr. Schweitzer's opinion that this is a controversy over the history of ideas ‑‑ this witness is competent to testify on the history of ideas and to analyze the opinions expressed by Dr. Schweitzer from the perspective of his analysis, and that is what we would propose that he be allowed to do.

I hope that is a clear answer to your question.

THE CHAIRPERSON: Thank you. Mr. Fromm, please.

MR. FROMM: I wonder if I might ask Dr. Jacob a few questions regarding his qualifications.

THE CHAIRPERSON: That reminds me that I did say at the outset that I had intended to ask a couple more questions. May I?

THE CHAIRPERSON: Yes.

MR. CHRISTIE: Thank you.

EXAMINATION-IN-CHIEF RE QUALIFICATIONS, Continued

MR. KURZ:

Q. Just before I begin, you said something about fears of Jewry. I take it that you are talking about fears of Jews? Could you explain that answer?

A. "The Jewry" means that community of people constituted of the Jews. I meant in particular the Jewry in academics. This is an academic subject, and few publishers will dare to publish a work on Eugen Dühring because there are so many Jews among the publishing houses today, the leading publishing houses.

Q. So people are unwilling to publish studies on antisemitism because Jews run the publishing houses. Is that your evidence, sir?

A. I don't mean to suggest that they run all the publishing houses, but they have important places in most of them. If a book like this were published by a mainstream publisher, the reviews would be devastating because many of the academics who review these books are clearly Jewish, in the history departments and in the political science departments and philosophy as well. So the publishers are fearful.

Q. Publishers are fearful of the reactions of Jewish academics?

A. Yes.

Q. And what the Jewish academics can do to them for publishing these materials, sir?

A. Yes. I can give you a concrete example if you wish.

Q. Please.

A. I published a book in 1992 called "De Naturae Natura: A Study of Idealistic Conceptions of Nature and the Unconscious." It was published by Franz Steiner, a very distinguished publishing house in Stuttgart.

Q. That is at page 2 of your CV?

A. Yes, in the middle of it.

Q. Yes...?

A. As I briefly mentioned yesterday, it contains an appendix on race and philosophical capacity. It has a rather extensive discussion of Jewish thought in comparison to Indo-European.

Q. I am sorry, in comparison to what?

A. Indo-European.

Q. Thank you.

A. When the editors read that appendix, they were very fearful that they would get adverse reaction to the book and pleaded constantly that I drop the appendix because it had references to all these antisemitic, idealistic thinkers and also to Alfred Rosenberg who happens to be a National Socialist thinker, but a very serious one. They thought it dangerous for them to publish a book which included such names and said that it would be much better if I did not have the appendix at all.

It was only on my own insistence that it finally was published in its entirety. I had reactions from several European academics, and they all refer to the appendix in one way or another. That is what immediately catches their attention.

Q. And that is an example of how Jewish academics have tried to stop writing about antisemitic topics?

A. That is how they have deterred non-Jews from writing about antisemitic topics.

Q. So your view is that it is okay for Jewish academics to allow other Jewish academics to write about antisemitism, but that they wanted to stop you from writing about antisemitism because you are not Jewish? Is that the way you feel?

A. Because I have an objective viewpoint that does not immediately denounce European thought and raise Jewish thought in comparison. You will find that there are many Jewish thinkers, historians, sociologists writing about Jewish politics and philosophy, almost in a critical manner. It would seem that they are all anti-Semites, but ultimately the conclusion would be that this is a way to reform the Jewish society or conduct or whatever and, therefore, it is permissible to publish such books.

In my case, I have no interest in reforming. I am not directing my discussion to the Jewry. It is open to the entire intellectual community of which the predominant part has always been the European.

Q. Again, just to fully understand the answer you just gave, your objective view with regard to this European philosophy that you talked about is that you are objective about the antisemitism of these writers. You don't condemn it out of hand. Would that be a fair statement?

A. Yes, completely.

Q. You feel that the antisemitism of the writers that you are discussing is actually quite useful for reformation. Is that correct?

A. Yes.

Q. It helps, in effect, to reform European and perhaps North American society of the Jewish influence. Is that right?

A. Yes.

Q. So that people like Rosenberg, who you said is a National Socialist ‑‑ did you describe him as an ideologue or a philosopher?

A. An ideologue.

Q. A National Socialist ideologue ‑‑ that their ideas were useful to reform western society. Is that right?

A. Yes, and they still are.

Q. When you say Rosenberg was a National Socialist ideologue, was he not a prominent publisher and writer in Nazi Germany?

A. Yes, for the journal of the National Socialist Party.

Q. And he would have been considered one of their prime writers, propagandists. Would that be a fair statement?

A. Yes, he was. He had that particular designation.

Q. With regard to the appendix ‑‑

MEMBER JAIN: I am sorry, could you repeat the last answer. I couldn't understand what you said.

THE WITNESS: He had that particular designation. He was the Minister for Propaganda.

THE CHAIRPERSON: Is this Alfred Rosenberg?

THE WITNESS: Alfred, yes.

MR. KURZ:

Q. And his book, the book that you described in German ‑‑ and, I apologize; I don't have your German knowledge nor do I have your knowledge of almost any other language. That translation is "The Myth of the Twentieth Century?" That is the book you are talking about?

A. Indeed.

Q. That is a book that takes off from The Protocols of the Elders of Zion?

A. It does not. It takes off from Houston Stewart Chamberlain's "The Foundations of the 19th Century." This is a work of cultural history.

Q. I apologize. If I could go back to something you said earlier, you were talking about how this influence of Jewish academics tried to prevent you from publishing an appendix that dealt with antisemitic authors and that the reason is that they didn't want you, as a non-Jew, to write on that subject. I just want to ask you about that appendix, if I may. I have not had the opportunity to read it.

You did not simply mention the names of these antisemitic writers; would that be a fair statement?

A. No, I discussed their thought.

Q. I didn't hear your answer, I am sorry.

A. I discussed their thought.

Q. You discussed their thought. Would it be fair to say that the problem that these Jewish academics had with your discussion of their thought is that you took an objective view of their thought? Would that be accurate?

A. What Jewish academics are you talking about?

Q. The ones ‑‑

A. Who responded, do you mean?

Q. Yes. My understanding, if I am correct, is that the reason that you told us about this appendix was that it is an example of how Jewish academics try to stop non-Jewish academics from writing about antisemitism. Is that correct?

MR. CHRISTIE: He didn't say that.

THE WITNESS: I suggested that publishers in general are very careful of publishing books that are antisemitic in one way or another or sympathetic to antisemitic authors. This is the evidence I gave of Franz Steiner. At Franz Steiner all the editors are not Jewish; the people I dealt with are Germans. They had a much greater fear than I suppose anybody else would have and so deterred me.

The responses are also not all the time from Jewish authors. In fact, most of them just abstain from reviewing a book like this because they like to ignore it. That is also, in a way, bad for a book because it reduces its popularity and the publicity. If they do review it, if they have the competence to do so, then they would denounce it.

In my case I did get a few reviews. I cannot make out from the names whether they are Jewish or European entirely; they seem more European than Jewish. They all referred immediately to the appendix, even though it is only an appendix and not the major burden of the book. So you can see how strong a reaction I got to such a small part of the book.

MR. KURZ:

Q. The reaction of the reviews, was it positive or negative?

A. Mostly critical and sometimes non-committal. The German academic who wrote about it said, "I should not like to comment on such a position."

Q. Just talking about criticisms and reviews and how important they are, is the problem you have experienced because you write about antisemitism that you don't get reviewed very much? Is that what you are saying?

A. That is certainly one reason. The other reason is that the other books were published more recently, and it takes time for reviews to come out. I am still anticipating.

Q. So not too many of your books have been reviewed. Is that what you are telling us?

A. No. In fact, I have four books reviewed out of eight.

Q. I see. So half the books have been reviewed and half your books have not been reviewed.

A. The others are in the process of being reviewed. Edgar Julius Jung is being reviewed in France and in America.

Q. And you don't know what the review is going to say, I take it.

A. No. One never knows.

Q. Getting back to the book that was published in Germany and your appendix, the criticisms in the reviews, I take it, were with regard to your view of antisemitism. Would that be a fair statement?

A. Criticism is always concentrated on National Socialism. The very name Rosenberg is frightening to people, and they were all surprised that I had included him in my discussion. I had a justification to do that, because of the similarity of his views to many of the more serious thinkers I had earlier discussed in the course of the book.

Q. Are you saying that Rosenberg was or was not a serious thinker?

A. I am suggesting that he was, yes.

Q. You feel that he is an important thinker in terms of understanding problems with Jews. Would that be fair?

A. Certainly. My discussion was restricted to his comments on natural philosophy, because that is the subject of the book.

Q. That is your area of expertise. Right?

A. That is one of my areas. The other is political philosophy, idealistic political philosophy.

Q. I am sorry, the other area is idealistic political philosophy, Doctor? I didn't hear you.

A. Yes, conservatism which is the most clear representative of idealistic political philosophy.

Q. You mentioned Alfred Rosenberg. You are not the only writer who has mentioned Alfred Rosenberg. The fact that you mentioned Mr. Rosenberg isn't the reason that all these people were upset, is it?

A. It was because I was not opposed to his views of natural philosophy and on Jewish thought. Most people who comment on anything to do with antisemitism in the Reich will just comment on it and proceed from there with no sympathy shown to the point of view expressed by a National Socialist, because that is too dangerous.

Q. So the difference between you and the others with regard to Mr. Rosenberg is that you were sympathetic to his views on natural philosophy and the Jews. Is that how I understand your evidence?

A. Yes, on Jewish thought and, in fact, the complete lack of natural philosophy in their tradition. That is what it amounts to.

Q. You are saying that Jews don't have a natural philosophy?

A. No. They have little regard for nature. They have little sympathetic understanding of it, which is even more serious.

Q. I don't understand. Jews have little regard for or understanding of natural philosophy?

A. They have little sympathetic understanding of the inner springs of natural philosophy, of the metaphysical aspects of nature which constitutes its first principles.

Q. You are talking about Jews in general, that they just don't get it, as it were?

A. They lack the insight.

Q. They lack the insight? I am sorry, I don't hear very well and I don't know philosophy very well, so I need you to help me.

A. They lack the insight.

Q. They lack the insight that is necessary to understand something as complicated or as metaphysical as natural philosophy?

A. Yes.

Q. I understand. I take it that natural philosophy is something that requires ‑‑ could I call it something spiritual? Would that be a fair way of saying it?

A. All philosophy is spiritual.

Q. All philosophy is spiritual. Is there something more spiritual about natural philosophy or not?

A. No, only equally.

Q. Do your comments apply to Jewish inability to understand philosophy in general or just in this one area of philosophy?

A. Idealistic philosophy.

Q. I am sorry, I didn't hear you.

A. Idealistic philosophy.

Q. Idealistic philosophy. What is it about idealistic philosophy that Jews lack the capacity to understand?

A. All idealistic philosophy is based on a priori principles, a priori meaning an earlier philosophical intuition of the realm of ideas which are eternal and constant. This is the basis of Platonic philosophy, where there is the idea of the good and the beautiful and the true, and so on. This is what informs all the other conceptions of political philosophy as in a republic or social thought as in the symposium, and so on. It is the basis of neo-Platonism which consolidates Platonic philosophy and it informs all of German idealistic philosophy as well because it is not empirically based. It is based on first principles.

Most Jewish philosophy is empirical and based on material evidence which will not lead to any understanding of nature, because nature is not concrete. It is first ideal before it appears concrete.

Q. So Jews are not really able to understand things that are not concrete.

A. They have shown no evidence of anything but empirical philosophy.

Q. Again, I apologize because I don't hear you very well.

A. They have shown no evidence of anything but empirical philosophy in the course of their tradition, and much of that tradition is not metaphysical at all. Their so-called spiritual tradition is only an ethic that keeps the people together and forces a rule of conduct amongst themselves and vis-à-vis other people. It is not philosophical at all.

Q. So Jewish thought and Jewish religious thought is not philosophical. Is that what you are saying?

A. Yes.

Q. Because it is too concrete?

A. It is too mundane.

Q. I am trying to understand. Why is it that Jews are incapable of doing this? Are we missing ‑‑ and I guess I am revealing myself as a Jew. Are Jews missing something genetic or is it something in the Jewish character?

A. Both. What they are like genetically is revealed in their character.

Perhaps, if you read my reply to Dr. Schweitzer, you will have noticed that I refer to the sharply-developed intellect of the Jews. This, itself, is partly the problem. The problem is that the intellect is that mental capacity which is created precisely to deal with the material world. It is not, as many think, something very metaphysical. It is just an instrument like a computer. This faculty has been passed on from generation to generation. It is a faculty that passes from the mother to the child. It is a feminine quality, in fact.

Q. A feminine quality?

A. Intellect is a female characteristic.

Q. All intellect or Jewish intellect?

A. All intellect.

Q. I understand. Since you preserve the maternal line very carefully, it is not surprising that this intellect has been preserved in its purity through the generations, and this explains the brilliance of intellect. But it also explains that there is little apart from it. The spiritual capacity is a masculine character which is passed from the father.

Q. Spiritual qualities are masculine and intellectual qualities are feminine.

A. Yes, male and female, I suppose.

Q. I understand that ‑‑ I guess.

A. Fortunately or unfortunately, there is not much evidence of this philosophical spiritual quality among the Jews.

Q. So the Jews are smart, like computers, really smart. Is that right?

A. Yes, I don't deny that.

Q. And they are like computers in that they can make, if I can put it this way, cold calculations about material things?

A. Yes. All the evidence of more 'cultural', with inverted commas, activity among the Jews is through participation in the European stock. There have been a lot of admixtures and marriages into European families. Marcel Proust, for instance ‑‑ his mother was a Jewess, but his father was French, so he will have an enormous French quality in his writings, and so on.

All of that is to be attributed to the European part of it, that part which has imbibed the surrounding tradition. It is not native to the Jewish mind.

Q. So Jews who are pure stock Jews, whatever that may mean, really aren't capable of participating in cultural activities. The only ones who have been successful in doing so are people who are from intermarriages. Is that what you are saying?

A. Not the only people; most of the people have that. I have no evidence of a Jew of pure stock ‑‑ I suppose that would be the Sephardic Jews

‑‑ producing anything at all.

Q. So the Sephardic Jews haven't produced any culture at all?

A. No, I am talking of European culture, not Jewish culture which ceased to exist after the Diaspora or something. I am not talking about Jewish culture which I know little about and have little interest in. I am talking about Jewish participation in western society.

I don't have much evidence of a Jew of pure stock producing anything in European society, even if it were Sephardic.

Q. Even if it were...?

A. Sephardic.

Q. The Sephardic are the pure stock, but the Ashkenazic or European Jews are not of pure stock?

A. They are pure insofar as they are closer to their origins, and that is the criterion for purity. The Ashkenazic are much more mixed with Russian and Polish and German elements.

Q. I always thought the Jews were very prominent in the arts, in music and what have you.

A. These are all Ashkenazic, all mixed with European blood and also fully brought up in the European tradition.

Q. So, in effect, it is their non-Jewishness that allows them to participate in culture, the non-Jewish side of them.

A. Yes.

Q. And the Jewish side of them would be the opposite, would be non-cultural. Would that be fair to say?

A. It is not non-cultural. It is not culture that is fruitful on European soil. The Jews themselves may have produced a culture of their own; I have no idea what it was like or what it is like. I have never been to modern Israel. I don't know what sort of culture prevails. It is not the subject of my discussions.

Q. I see. If I could take you back, you talked about Alfred Rosenberg. You feel that he is a serious thinker.

A. Very serious.

Q. A very serious thinker. When you say "serious thinker," you think he is somebody who needs to be listened to. Right?

A. Yes.

Q. Rosenberg posited that there are some ways to deal with the Jewish problem. Would that be a fair statement?

A. Yes, indeed.

Q. Just so that I understand what the Jewish problem is, first of all, tell me: Is one aspect of the Jewish problem that Jews are an exploitive social group?

A. Because they have indulged typically in commercial activity which tends to be of that sort.

Q. That is the computer part of their intellect, their sharp intellect. Would that be a fair statement?

A. It would be. I have never stated that, but the connection is fairly obvious.

Q. I guess it is, from what you are saying. That is something where Jews have a very strong influence in mercantile matters, in the economy, in making lots of money.

A. Yes. By the way ‑‑

THE CHAIRPERSON: Witness, will you put your hand down so that I can hear you?

THE WITNESS: Yes.

There are different types of mercantile activity also. Werner Sombart, who wrote that book on Jews and Economics, is a person you should read on the subject.

MR. KURZ:

Q. Who is the writer, I am sorry?

A. Werner Sombart, S-o-m-b-a-r-t. I have not translated any of his works, but I have referred to him in my reply.

Q. Yes.

A. The ideal society that all German thinkers propound is one based on quasi-mediaeval guilds, the corporate system, where there is a close relationship between the leader of an economic enterprise and the apprentices. This is how the tradition is maintained in the guild from generation to generation, through the perfection of technique and expertise.

In such a patriarchal system, there is little scope for exploitation. There is always concern for one another, and this is overturned in the capitalist system which imposes a monetary ethos where money breeds on money. This is a system ultimately deriving from the usury that the Jews were engaging in when they first settled in Europe. Capitalism is simply the offshoot of usury.

Q. So capitalism is an offshoot of Jewish usury?

A. Yes.

Q. So capitalism is really a Jewish invention. Would that be a fair statement ‑‑ if not directly, indirectly?

A. As you probably know, Max Weber has also written a similar book called "The Protestant Ethic and Capitalism". He attributes capitalism, the rise of capitalism, to the Puritans and their work ethic and the Protestant ethic.

I can correct that by demonstrating that the Puritan ethic is a fully biblical one and one that is based particularly on the Old Testament. The entire Puritan revolution was a quasi-Jewish revolution. They all called themselves Israelites and worked for the new Jerusalem, and so on. There is little difference between the original Puritan English ethos and Judaism.

One may say that the modern form of capitalism is a product of the Jewish mind.

Q. And the problems with modern capitalism are that kind of Jewish exploitive aspect. They are in it for themselves; they make lots of money; they don't help others.

A. Through as little work as possible.

Q. Through as little work as possible. That is the real problem with society, at least from a financial point of view. Right?

A. That is not the real problem. The problem is the deterioration of the mind in such a society. The only desire, the only dream, is to gain more and more money.

Q. Talking about the deterioration of the mind, the problem is that the mind has gone toward this Jewish idea, the concrete, rather than something that is more thoughtful or philosophical? Do I understand you?

A. Yes. The entire religious sensibility is eroded. As you can see, there is hardly any religion left in the country or in any country in the west. That metaphysical orientation is lost, quite.

Q. In favour of this Jewish computer-like exploitive economy.

A. Mechanical and commercial.

Q. That is one of the problems facing our society, and that is part of the Jewish problem. Right?

A. It is. It is also the problem pointed to by Rosenberg, if I may add.

Q. Right, and Dühring as well, by the way. Right?

A. Yes. All thinking anti-Semites ‑‑ I mean all philosophical anti-Semites.

Q. I take it you are not just talking for Rosenberg, but you agree with this. Right? This is your view as well?

A. Yes.

Q. Rosenberg, Dühring and yourself would also agree that Jews are over-represented in the halls of power, and that is how they are able to influence things. Would that be a fair statement?

A. If you say so, yes.

Q. I am asking you. I need to understand what you have to say because I am not a philosopher and I really don't understand.

A. That is true. Over-represented, yes. But, you see, when the system of power has already been altered so that it does not represent the ideal society of a true philosopher, then it doesn't matter who represents that system of power. Over-representation is almost a tautology.

Q. It's a tautology because it doesn't matter that the Jews ‑‑

A. It doesn't matter who runs a bad government.

Q. The problem is the government itself, and that the government holds to the wrong ideals. Right?

A. The wrong directions, yes.

Q. Do you think Jews are over-represented in government, or am I wrong about that?

A. They certainly hold very key positions, even if they may not be a majority in numbers. The case of Mendelssohn, a minister without portfolio in the British cabinet, is a case in point.

Q. Tell me about him, please.

A. He is the one who organized the campaign very successfully on lines that were supposed to resemble the Democratic election campaign of Clinton, so you can see there is a similarity and a co-operation, an international methodology, in the political campaigns being conducted. The fact that he occupies a portfolio without any specification indicates the power that he possesses next to the Prime Minister.

Q. Mendelssohn, you are saying, is a British minister who helped Bill Clinton with his campaign? I misunderstood your evidence.

A. He modeled his campaign for the British Prime Minister ‑‑

Q. I see. Finish your answer; I apologize.

A. Even if you have to point to just one person, that will suffice because of the power that that position represents.

Q. You talk about international co-operation. Is that part of the way that Jews have been able to influence governments and obtain power, this international co-operation you are talking about?

A. Yes, because they are an internationally dispersed community. They always have been since the Diaspora. First, their international connections are commercial, the Rothschild family business for instance. Then it becomes political because you gain political power through commercial.

Q. So, because the Jews have these vast networks, they use those networks to help them keep the governments going in the way they like. Would that be a fair statement?

A. Yes. They have certainly succeeded in doing that when no other community, European or otherwise, has done so.

Q. No other community has done so?

A. Because they have not been so dispersed.

Q. Whether numerically there are too many Jews in government or not, the Jews, through their international networks, have really been able to ensure that governments around the world follow the Jewish interest. Would that be a fair statement?

A. Yes.

Q. Would it also be fair to say that, because Jews are so international and they are trying to pull the same strings around the world, their interest is in themselves and not in the countries that they are resident in?

A. Yes.

Q. How did the Jews get to the position? How did the Jews get so much power? Did they do it by earning it, by being elected? How was it that they got there?

A. As I said, it is through financial mastery. Once you have control of the banking system, then it is not difficult to control first princes and then other potentates, prime ministers and just about any senator or any politician with that resource.

Q. So they use their financial acumen and their financial power to exert influence on governments around the world. Is that right?

A. Yes, particularly in America.

Q. Do they do this openly or not?

A. Openly, through lobbying. Anybody who has read Findley's book knows that, about the APAC and its connections to Israel.

Q. If I understand your writings, your criticism of this is, at least in part, from a moral point of view. Would that be a fair statement?

A. Yes.

Q. You think what the Jews are doing is immoral. Would that be a fair statement?

A. Not in the way you put it. It is a moral question because it leads to a deterioration of morals in the populations in which they work. It is not immoral because, once the system has been established, everybody behaves in the same way. They are not any worse than anybody else.

Q. So Jews aren't worse than anyone else, but the problem with the Jews is that they keep society in the same kind of degenerate way that it is now. Is that right?

A. They have instituted this form of an unpleasant society.

Q. I am sorry, I didn't hear.

A. They have instituted this form of unpleasant, morally unpleasant, society where criminality is almost glamorous.

Q. So they have helped make a society or they have made a society where criminality is glamorous.

A. The example of Hollywood is so pertinent in this regard.

Q. Help me with that.

A. Anybody who goes to any film that has been produced from Hollywood will be only too easily impressed by the glorification of gangsterism and violence of the most extreme sort, all of this pretending to be true heroism, so that little children imbibe these ways and are indoctrinated right from their earliest childhood. It is not surprising that you have so many cases of child violence.

Q. But a lot of these movies are not made by Jews. I am thinking of "The Godfather" which was made by Francis Coppola, and I think he is Italian; Martin Scorcese made ‑‑ I forget what movie it was, but it was another gangster movie ‑‑ "Goodfellows." What do the Jews have to do with that?

A. The Italians have always been specific, those Italians you have mentioned, with their choice of subjects, and that is the Italian Mafia and their gangsterism which is almost no longer present in its original Al Capone form. They are historical films and relevant to that particular period.

What the other Jewish directors and producers ‑‑ all the producers, I believe, are Jewish ‑‑ make are films projecting cartoon heroes, Batman and this and that and the other, Superman, all represented as American heroes and indulging in the most horrible violence all the time.

Q. That is a Jewish thing as well?

A. Yes. That is only one example. There is no end of it.

Q. Dr. Jacob, do you think the Jews can be reformed, that they can be better, become more philosophical?

A. I have little evidence to that effect. It is really left to be seen.

Q. So you don't have any confidence that such a transformation can occur in the Jews, do you?

A. At the moment, little.

Q. What we have been just talking about for the last little while would be the Jewish question or the Jewish problem. Right?

A. Yes, in short.

Q. Rosenberg talked about a solution to the Jewish problem, and you have described him as a serious writer and he has, I take it, serious solutions. Were they useful solutions, do you think?

A. Yes.

Q. And they were solutions that you would approve?

A. Yes.

Q. Do you think of Rosenberg as a moderate National Socialist?

A. A moderate one, yes.

Q. Could I ask you whether the moderate solution to the Jewish problem that Rosenberg suggested and that you approve of would be as follows ‑‑ and I see you are opening your book on Dühring. Maybe you could look to page 44 ‑‑

A. I am pleased to note that you have a copy of it.

Q. I don't have a copy; I just have a couple of pages.

THE CHAIRPERSON: What book is this?

MR. KURZ:

Q. Perhaps you could identify the book that you have, sir.

A. The book is "Eugen Dühring on the Jews," a translation of "Die Judenfrage", the Jewish question from 1881.

Q. We don't have to read from the book ‑‑

THE CHAIRPERSON: By...?

THE WITNESS: Eugen Dühring.

THE CHAIRPERSON: Thank you. I have it now.

MR. KURZ: That book is the second book on page 2 of your CV.

Mr. Chairman, I am going to ask him a couple of questions about it. I have copies of the portions, and I can refer the witness to those passages, just talking about what Rosenberg has to say. I can give you copies if you wish. I am in your hands.

THE CHAIRPERSON: Carry on.

MR. KURZ:

Q. I understand that Rosenberg had eight legislative ways to deal with the Jewish problem. Would that be a fair statement?

A. Yes, in an early work that he wrote. This was published before he became a minister.

Q. But this legislative reform that I am asking you about is something that you endorse, though. Would that be a fair statement?

A. Yes.

Q. Let's just go through the eight legislative reforms that you endorse. Obviously, this applies to Germany and, if you endorse it, you think it should apply wherever the Jews are living. Would that be a fair statement?

A. Yes.

Q. "1. The Jews are recognized as a

nation living in Germany. Religious confession or lack of confession play no role."

Correct?

A. Yes.

Q. So whether Jews call themselves Jews or not doesn't matter. Right?

A. No.

Q. Whether a Jew converts to Christianity doesn't matter.

A. No.

Q. A Jew could go on and become a bishop, but he would still be a Jew. Right?

A. Certainly for the first few generations of conversion.

Q. It would take at least a few generations to ‑‑

A. And also it would take a few generations of intermarriage to change somewhat.

Toronto, Ontario

‑‑- Upon resuming on Thursday, May 28, 1998

at 9:38 a.m.

RESUMED: ALEXANDER JACOB

THE CHAIRPERSON: Good morning.

THE CHAIRPERSON: Mr. Christie, please.

That is our position.

THE CHAIRPERSON: What notice do you have at this point as to how many witnesses the Respondent is calling?

THE CHAIRPERSON: Ms Matheson, please.

These are experts, and that is the basic information that anyone needs before an expert testifies in any hearing.

THE CHAIRPERSON: Mr. Christie, I will hear from you again, but I just want to make a comment.

THE CHAIRPERSON: What is new about that? It happens in almost every situation where a witness is sought to be qualified. They may do that. We here will decide whether he is qualified or not.

These questions are not entirely at this moment even clear, and it is not going to be easy to resolve precisely how that ruling will impact on those issues.

THE CHAIRPERSON: Is it your present intention to call two experts?

THE CHAIRPERSON: I guess the direction that you might expect from us is that you be ready to proceed with your next witness during the time that is allotted.

MR. CHRISTIE: I understand that. We will have witnesses in the time that is allotted; I am quite sure of that. I don't intend to ask for any adjournments in the time allotted.

MR. CHRISTIE: The Tribunal or the Commission?

THE CHAIRPERSON: Pardon me?

MR. CHRISTIE: I thought you said the Tribunal.

THE CHAIRPERSON: The Tribunal is interested in seeing that there is an appropriate scheduling and compliance with the order of the Tribunal so that we don't have this long discussion.

MR. CHRISTIE: As far as I can see, in the next 10 days the two witnesses will be the present witness and Dr. Countess.

THE CHAIRPERSON: Are you talking about experts or factual witnesses?

THE CHAIRPERSON: I understood you to say that you have a list of witnesses, including factual witnesses.

MR. FREIMAN: No, we have a list of 20 potential expert witnesses. There are no factual witnesses on that list.

THE CHAIRPERSON: Can I ask you to address that issue, Mr. Christie?

THE CHAIRPERSON: Our direction will apply to that as well, by five o'clock tomorrow.

Mr. Fromm, you wanted to say something.

MR. FROMM: That is correct.

THE CHAIRPERSON: Why is that?

MR. FROMM: I was suggesting that it might assist the Tribunal if the fear is that there might be an interruption in the proceedings.

THE CHAIRPERSON: We would prefer that the Respondent's case be put in and then, if you have evidence to call, upon proper notice we will consider that at that time.

MR. FROMM: Thank you.

THE CHAIRPERSON: Mr. Christie, have you finished your examination of this witness?

MR. CHRISTIE: I think I may have indicated that, but there are a couple of questions I want to ask.

MR. CHRISTIE: I said that at the outset.

THE CHAIRPERSON: You said it at the end and, I am sorry, I didn't make a full note of it.

I hope that is a clear answer to your question.

THE CHAIRPERSON: Thank you. Mr. Fromm, please.

MR. FROMM: I wonder if I might ask Dr. Jacob a few questions regarding his qualifications.

THE CHAIRPERSON: That reminds me that I did say at the outset that I had intended to ask a couple more questions. May I?

THE CHAIRPERSON: Yes.

MR. CHRISTIE: Thank you.

EXAMINATION-IN-CHIEF RE QUALIFICATIONS, Continued

MR. CHRISTIE:

Q. In relation to your work, Dr. Jacob, in order to study the texts and documents that contain the ideas that you have identified or you intend to identify as being the various forms of antisemitism, first of all, what languages do you speak?

A. I speak French and German. I read those languages as well. I also read Greek, Latin and Sanskrit.

Q. You read Greek, Latin and Sanskrit?

A. Yes.

Q. Do you speak any other languages other than French, English and German?

A. I speak a couple of Indian languages, Hindi and Tamil.

Q. Has this been of any use or assistance to get at the sources of these ideas?

A. Yes. French and German are indispensable for any intellectual studies. Particularly in the case of German history and philosophy, German is necessary.

MR. CHRISTIE: Thank you. Those are my questions.

THE CHAIRPERSON: Mr. Fromm, please.

CROSS-EXAMINATION RE QUALIFICATIONS

MR. FROMM:

Q. Dr. Jacob, in his Memorandum surveying lethal antisemitism from antiquity to the present, Dr. Schweitzer made extensive references to mediaeval ‑‑

THE CHAIRPERSON: Mr. Fromm, what we are dealing with now are the qualifications as indicated by his evidence and by his curriculum vitae. We have not admitted the aide-memoir, if that is what you are referring to.

MR. FROMM: I recognize that.

MR. CHRISTIE: The question was Schweitzer, not this witness.

THE CHAIRPERSON: Go ahead.

Q. In order to critique mediaeval antisemitism, would it be necessary to have a working knowledge of Latin?

A. Yes, because all of the mediaeval texts are not readily available in translation.

Q. Do you have a working knowledge of Latin?

A. Yes, I do. I translated two books from Renaissance Latin, two of Henry More's. As you probably know, in the 17th century they still wrote in Latin, even if they were English or French.

Q. A major emphasis in Dr. Schweitzer's memorandum was European, particularly German, antisemitism. Do you have a working knowledge at a scholarly level of German?

A. Yes, I do.

Q. You indicated yesterday that you had translated several works of authors you identified as German conservatives in the late 19th and early 20th centuries.

A. Yes.

Q. Were these often considered antisemitic writers?

A. Not completely so, except for Eugen Dühring who is a professed anti-Semite. Jung is not to be characterized as an antisemitic thinker, though he does comment on the Jewry, and so, too, Chamberlain in "Political Ideals."

Q. Are there many other scholars writing in this field now, Dr. Jacob?

A. No, very few, because of the fear of the Jewry.

MR. FREIMAN: I didn't hear that comment.

THE CHAIRPERSON: Repeat your answer, please.

THE WITNESS: Because of the fear of the numbers of Jews in academics today.

MR. ROSEN: I think his term was "the Jewry."

THE WITNESS: The Jewry, yes. That is more customary.

MR. FROMM:

Q. Eugen Dühring was an important figure in the formation of the thoughts of Adolf Hitler; is that correct?

A. Indirectly. There is no evidence that Hitler actually read Dühring, but it was certainly in the social atmosphere at the time.

Q. Are there many experts in the field of Eugen Dühring?

A. A couple in Germany, but nowhere else.

Q. Would it be fair to say that you are one of the world's experts?

A. I must be, since few others have showed an interest or readiness to study him.

MR. FROMM: Thank you.

THE CHAIRPERSON: Are you cross-examining, Mr. Kurz?

MR. KURZ: Thank you, Mr. Chair.