MR. CHRISTIE:

Q. In your cross-examination yesterday you were accused of sophistry by Mr. Rosen for the way you cited portions of documents or books to support statements made in some essays that you had written.

Is it or is it not a common practice for professional historians and other scholars to cite sources in this way?

A. It is a very common practice to cite sources in the way that I cited them, as I did in the case of the affidavit by Sergeant Coward. I am quoting it as a kind of admission against interest.

Very often, in citing testimony in a trial or citing works of history, one will take a portion of a book or a testimony and cite that as evidence for one's own point of view, even though the person making the argument in a book or in a testimony may have a point of view very different from the one that I or another person is holding in citing that. That is very commonly done.

Raul Hilberg in his major work on the Holocaust issue cites any number of sources, including the memoir of Otto Eichmann or Mein Kampf to say, "This is what Hitler or Eichmann says on this particular issue," but he doesn't quote the entire context of the thing because that is not the point he is trying to do.

A better example might be citations from the testimony of witnesses at the Nuremberg trials. A person will cite testimony by one of the German defendants to make a point, but they don't cite all the other things that are said by the defendant on that point because that is not what the purpose of it is.

It is a very common practice in historiography to cite a portion of a document or a testimony in validation of a particular point. It is not at all unusual. In fact, it is more fair to do that in that way than it is to make a statement without any supporting justification or references whatsoever, as I mentioned that Arno Mayer did in his book on "The Final Solution" in which he provides no footnotes whatsoever.

Q. In relation to the affidavit of Sergeant Coward, it was pointed out to you that in other parts of his affidavit he had said that everyone knew and that certain people knew, and that the portion you quoted, although it was there, was contradictory to the suggestions made in other parts of the affidavit. You were asked if that was misleading, and you said "no."

Why is it no misleading?

A. It is not misleading because I am only citing one portion of his affidavit which, in fact, does justify what I said in this short leaflet, that there were leaflets dropped on Auschwitz in Polish and German saying that people were being gassed there. What Coward says at that point does justify what I said.

It is not misleading; it is just not. It does support what I said it says.

Q. What is your position regarding all the other things that he said in the affidavit?

A. I could spend a great deal of time analyzing the entire document, but it is an affidavit issued several years after the events took place, in the context of a trial in which clearly he is trying to make as strong a case as he can against the defendants. I think the main defendant was a man named Duerrfeld whom he refers to in the document.

As I think was brought out the other day with specific reference to gassings or gas chambers, what Coward says in his affidavit is entirely hearsay. He doesn't have any personal knowledge of gassings or gas chambers.

As I mentioned the other day, one of the most striking things about the affidavit is that, even though he spent this time at Auschwitz, he seems totally unaware that there was any special treatment or mistreatment of Jews as Jews in the Auschwitz complex.

Q. Was the portion that you quoted, where Sergeant Coward refers to seeing leaflets, hearsay?

A. No, that was one part of the affidavit which is not hearsay. He says he personally read and saw leaflets that were dropped by Allied war planes around the camp in Polish and German, stating that people were being gassed there at the camp. That was the one significant portion of the affidavit that was not hearsay.

Q. You were asked about Walter Laqueur's book and references you had made to it where you cited evidence there that persons were released from Auschwitz in support of the proposition that, if there were exterminations there, there would not be releases.

You said that you cite other evidence for that now. Could you tell us what other evidence you cite for that now.

A. I cited Laqueur's book primarily because at that time it was a fairly readily available source in English. Laqueur's own evidence for that statement is an article that appeared in the German historical quarterly, Vierteljahresheft fuer Zeitgeschichte. Because it was in German and because this was a leaflet for English-speaking readers, I cited Laqueur.

Since that time I have revised the leaflet to refer to that specific point by citing a book called "Anatomy of the Auschwitz Death Camp" which gives more detail on that particular point. It gives more specifics about the numbers of releases and where they were released to. Again, that is a leaflet.

The other day a good question was asked: How does one know whether a piece of writing should be evaluated as scholarly or as polemical? That is a difficult thing to say, but generally one just trusts the reader to understand that, when something is fairly short, it is not a scholarly book and that a book that is scholarly and lengthy and detailed should be evaluated differently from a short leaflet.

Q. In being confronted with the Laqueur book, it was brought to your attention that some parts of the book referred to undertakings never to reveal anything on the release from prison and that no one believed those who were released.

Did you examine that and consider it in relation to your quoted portion?

A. Yes, of course, but it is entirely understandable that the Germans had prisoners who were at Auschwitz sign such a statement because the work of Auschwitz was a military secret or very important in the German military effort. Auschwitz 3, one of the important camps at Auschwitz, was an important centre for the manufacture of synthetic gasoline during the war made from coal, for example. Just a routine thing, the Germans insisted that prisoners who were in facilities like this sign these statements that they were not to reveal it.

However, the importance is that a person who is at Auschwitz and may be released back to Holland, for example, even though his neighbours may not believe him, certainly had the opportunity if he wished to write up a lengthy statement or paper about his experiences and send it to representatives of neutral countries that were in Europe during the Second World War, a point that Laqueur goes into in great detail in other portions of his book.

Contrary to the impression that many people have, it was very hard to keep secrets in Europe during the Second World War. Neutral countries like Switzerland or Sweden had not only embassies but consulates all over. The International Red Cross had representatives. The Vatican had representatives. In addition to prisoners that were released, there were many German civilian labourers in the Auschwitz complex who went back and forth, in and out of the camp.

It is very difficult, as Laqueur himself points out in another portion of the book, to reconcile the notion on the one hand that Auschwitz was this top secret extermination centre and, on the other hand, that it was so accessible during the war to so many people.

Q. You were confronted in cross-examination with Sylvia Rothchild's book in which what you referred to as Marika Frank's testimony was reported.

First of all, you were accused of misleading by referring to it as testimony. What method would you say would exist to distinguish between court testimony and verbal accounts in your own bibliography?

A. I don't understand. You mean in the source references?

Q. I guess so.

A. I suppose anyone can see that the reference in my footnotes to each of those two statements or testimonies, if you will, makes a distinction. The first one refers to court testimony, and the second one refers to a book. One can see that.

The word "testimony" is commonly used in a context outside of a judicial hearing.

Q. It was put to you that Marika Frank Abrams was writing 52 years after the fact and that you should have referred to that in her lack of recall or reference to or knowledge of gas chambers. Did you have any reason for not mentioning that it was written 52 years after the fact?

A. Partly, I suppose, space. One of the most incredible things is that generally the tendency after a period of time is to, as it were, "remember" things in exactly the opposite way. Many people ‑‑ and this has been pointed out by a number of Jewish historians ‑‑ as time goes on imagine themselves having been at places that they were not or imagine things often as being worse than they were, rather than the other way of actually conceding, "I didn't really know at the time that people were being gassed."

In fact, there is a tendency usually of survivors of any kind of experience in wartime and so forth to embellish or exaggerate the horrors of what they underwent rather than to diminish them.

Q. If she had experience or knowledge of gas chambers, would she have forgotten after 52 years?

A. It would be hard to believe, especially in light of how much it has been talked about since that time, that she would forget such a thing.

Q. You were accused of misleading in relation to the reference to Arno Mayer's book. In Arno Mayer's book was there any reference to gas chambers or reference to proof of their existence?

A. Arno Mayer, it should be understood, came under tremendous criticism for having written ‑‑

MR. ROSEN: I have to object, with respect. This is not proper re-examination.

MR. CHRISTIE: Let me understand.

I understand that there was an accusation that he had misled in citing Arno Mayer's book in some article. At page 365 he is alleged to have misled by citing. That was, as I recall, a reference to ‑‑ maybe I should look at the exact article.

I think it is SW-3. That is the accusation of misleading in relation to the statement that more died of natural causes than unnatural causes. In my understanding, the distinction is between dying from natural and normal causes and being killed by shooting, hanging, phenol injection or gassing.

Therefore, I was inquiring as to whether the witness had any knowledge of evidence that would contradict that or if he had misled by withholding such evidence in his knowledge of Arno Mayer's position respecting gassing, which was one of the ‑‑

THE CHAIRPERSON: We will allow it.

MR. CHRISTIE: Thank you.

Q. From your knowledge of Arno Mayer's book, would it be misleading to have presented the portion of his book which says that more people died of natural than of unnatural causes, specifically in relation to the unnatural cause of gassing?

A. I don't remember what page it is on, but in that same book Arno Mayer makes the astonishing admission that evidence for gassings at Auschwitz is, I think he says, rare and unreliable. This is in stark contrast to the claim that was made for many decades, including at Nuremberg, that evidence for gassings was supposedly not rare and unreliable but, to the contrary, abundant and very reliable.

In that regard, Arno Mayer's skepticism or his revisionism, if you will, of the claims that people were killed by the millions supposedly at Auschwitz in gas chambers is a very striking one. It is a great contrast to the story we have been told. Precisely for that reason Arno Mayer came under tremendous criticism from Jewish organizations and Jewish writers for making this, as it were, concession to the revisionist view of the subject.

It is not just on the one page that was cited by Mr. Rosen.

Q. You were also accused of misleading in that in the portion you cited from Arno Mayer's book, and it was read to you, it referred to cremation statistics. Why did you not quote or refer to the cremation statistics in your article?

A. Arno Mayer's references to the number of people who were or could have been cremated at Auschwitz are completely wrong. Anyone familiar with and who studied the cremation facilities at Birkenau and who knows about cremation can readily establish that these figures, which are not unique to Arno Mayer ‑‑ they are quoted elsewhere ‑‑ are entirely impossible.

I was really struck that the Director of the Calgary crematory facility who testified in the Zundel trial in 1988 dealt with precisely those claims and said they were preposterous or impossible.

Cremation is a complicated and involved process, and the facilities at Birkenau were simply unable, as Jean-Claude Pressac and a number of other anti-revisionist historians have conceded in recent years.

Q. In your evidence yesterday assertions were made that the Institute for Historical Review ‑‑ and I don't mean to misquote ‑‑ is basically a bunch of quacks and that no reputable historian gives them any credence. There was a suggestion that there was no support from recognized scholars at all. You went through the masthead, and it speaks for itself.

What persons of recognized historical scholarship have either identified with, spoken at, or in any way supported the IHR and its work?

A. In addition to the scholars who are listed on the masthead, I would mention that one speaker at an IHR conference was John Toland who is the author of numerous respected works of history and for one of them he received a Pulitzer Prize in the United States for non-fiction for a work of history he did. He spoke at an IHR conference.

David Irving has spoken at several IHR conferences. He is the author of numerous best-selling and highly acclaimed works of history dealing with the Second World War, modern 20th century history.

Another speaker was Ideo Mikei. He is a retired professor at Japan's National Defence Academy. He spoke at an IHR conference.

One of the books published by the IHR, written by Henri Roques ‑‑ it was a doctoral thesis that was translated ‑‑ was praised by Hugh Trevor Roper who is recognized as one of the outstanding or most prominent British historians on Second World War history. Hugh Trevor Roper called it an entirely legitimate, praiseworthy work of ‑‑

THE CHAIRPERSON: Which work?

THE WITNESS: This is a book called "The Confessions of Kurt Gerstein" by a Frenchman named Henri Roques. It was a doctoral thesis that was translated into English, and we published it.

Kurt Gerstein has been widely cited as one of the main sources or witnesses about gassings. Henri Roques' thesis dealt in great critical detail with the so-called evidence or confessions of Kurt Gerstein who committed suicide in 1945.

Hugh Trevor Roper praised this work.

In addition to that, a number of recognized scholars have been published in the Journal of Historical Review, including Jewish scholars. One I might mention is a professor in Oklahoma named Howard Stein who wrote an essay for the Journal on how the Holocaust campaign is used for self-serving purposes and that it is actually dangerous to Jewish interests in the long run, he feels.

In addition to that, I regularly receive and have received many letters from scholars and historians who support the work of the IHR but are very afraid of making that support known publicly, precisely because of the tremendous climate of intimidation that exists in the United States and especially in Europe affecting anyone who publicly supports Holocaust revisionism in particular.

As you know, in a number of countries it is actually illegal to publicly contest the official Holocaust extermination story. That is why it takes great courage and bravery for scholars to publicly express support for the Institute for Historical Review. The support of the IHR by recognized scholars is much greater than even the public support that has been given would indicate.

Q. You mentioned Henri Roques. Has he anything to do with the Journal of Historical Review?

A. Yes, he is on the masthead of the Journal of Historical Review. He has spoken at IHR conferences.

MR. FREIMAN: I have to rise at this point. I don't know how a litany now of supposedly famous historians can possible arise on re-examination, complete with the setting out of their credentials in circumstances where no one can now cross-examine.

THE CHAIRPERSON: The entry point that he placed before us is in connection with the course of cross-examination which tended to question the integrity of the IHR as an organization of reputable historical renown, I suppose. I am going to allow this within limits.

MR. CHRISTIE: That was my last question in that area anyway.

Q. It was asserted to you in cross-examination that Holocaust revisionists constitute pariahs, to put it as succinctly as I can, a group of very unusual eccentrics who either from a level of reasons or from delusion claim to false beliefs. I am not misphrasing what I think the presented arguments were. It was stated at one point that they are a very small percentage of scholars. Is that true?

A. It's a small percentage, I suppose, as would be true of any group of historiography that is dissident. What is extraordinary is how much support we get despite the tremendous involvement ‑‑

Q. I didn't ask you that, so I don't you had better go into that.

A. It is not a large percentage of historians in general, but it is a significant one.

Q. In your view, does the percentage of numbers affect the validity of historiography?

A. It is irrelevant whether the percentage of scholars and historians supporting a given view is a high one or a low one. Historiography scholarship would never make any advance at all if there was constantly an evaluation of the merits of a given view of history according to what the popularity of it is among historians.

Historiography and scholarship of all kinds must take place within an atmosphere that permits even a single historian who presents a startling different view to express it and argue it. Charles Darwin and Darwinism would never have been accepted if Charles Darwin had not been a single man to put forth a thesis that at the time was considered outrageous. That is what happens throughout all of not only historical but scholarship in other fields as well.

Q. In one part of your cross-examination you were asked ‑‑ there was an allegation, I think, with regard to the work of Eugen Kogon, and there was some discussion about an article in the Journal of Historical Review about Japan. At some point you said there was more justification for interning Jews in Nazi Germany than there was for interning Japanese in America. You said that there were hundreds of murders and sabotage and arson carried out by Jews against Germans prior to September-October 1941.

Specifically, what were you referring to in relation to that ‑‑ what murder, what sabotage and what arson are you talking about by Jews in Europe?

A. I know that for many people it sounds extraordinary or amazing that one can say that there was some justification by German authorities for rounding up Jews and treating them as a separate group and putting them in concentration camps. I don't support that necessarily, but in times of war governments often do very brutal, very sweeping things, treating groups of people in a very harsh and separate way.

Specifically in this regard, the treatment of the Jews has to be understood in the context of an ongoing struggle that was taking place between Jews and Germans. In 1933, as I alluded, as soon as Hitler came to power, major Jewish organizations organized a worldwide economic boycott and declared a kind of war against Germany. In March 1933 the London Daily Express ran a report on this under the headline "Judaity declares war on Germany."

In 1936 a young Jew named David Frankfurter assassinated a German official in Davos, Switzerland. In 1938 another young Jew named Hershl Gruenspan went into the German embassy in Paris and assassinated a German diplomat there.

That may seem like not much to justify very much, but just in that one regard in 1982 the Government of Israel carried out an invasion of Lebanon on the pretext that their ambassador in London had been the victim of an assassination attempt by a Palestinian.

THE CHAIRPERSON: We are getting pretty far afield here. Let's not talk about Lebanon in 1982. The specific question was in relation to 1933. We take the point that you have made, but I don't think we need to have a historical review.

THE WITNESS: In addition, there were many other acts of partisan or underground warfare, sabotage, attacks and so forth. I can go into detail about that; there is much more to be said on that subject.

MR. CHRISTIE:

Q. What were you speaking of when you spoke of alleged acts of murder, sabotage and arson carried out by Jews? Do you mean Frankfurter and Gruenspan?

A. Those are two, but more before September-October 1941 Jewish underground organizations and sabotage organizations had already been set up in France, in Poland, in the occupied Soviet territories, specifically Jewish ones, as any number of Jewish Holocaust historians have affirmed and have even expressed some pride about.

Q. In the first day of your cross-examination your entire article from 1978 was read, and I don't intend to go over it by any means. In the course of it, I think it is fair to say that you were accused of being a racist and a bigot.

What I would like to do is refer to Exhibit SW-1 and I would like to refer to page 6554, lines 10 to 23.

A. I don't have it readily ‑‑

Q. You are not going to have it unless I am allowed to ask this question.

THE CHAIRPERSON: What are you going to be asking?

MR. CHRISTIE: I was going to ask him, in the context of his beliefs about race, did he say that?

We had a cross-examination line by line; we went through the whole thing to that point. I just want to ask him if this accurately reflects his beliefs about race then and now.

THE CHAIRPERSON: Perhaps the witness should step outside for a moment.

‑‑- Witness Withdraws

MR. CHRISTIE: Let me say that I think I put it this way. I have found my notes now:

It was that Mr. Weber would testify that the effect of revisionism brings a humanizing and rational perspective to the Holocaust account by offsetting the dogmatic aspects that put Jews in a category of human suffering beyond all other humans. In other words, it is my submission that I will endeavour to show through Mr. Weber's evidence that the debate and discussion about the Holocaust has a salutary effect on Jews. It is not something productive of antisemitism; it is productive of a greater understanding and compassion for Jews in the long run. That does not mean that every Jewish advocate for the Holocaust will be happy with the debate; that never is the case, but in the long run Mr. Weber's experience is that there is not a greater animosity created by virtue of discussing the subject from this rational perspective, but a greater humanizing influence and a greater understanding and eventually compassion for Jews.

My submission is that, without debate and discussion about the Holocaust, there would hardly need to be so much written about it. It is an important historical event in our time and it is an event that involves intense emotion.

MR. KURZ: Mr. Chair, I apologize for interrupting Mr. Christie. The question is whether Mr. Weber should be in the room.

THE CHAIRPERSON: We excluded you, Mr. Weber. Thank you.

The word I have down is "important", and I am not sure what you said after that.

MR. CHRISTIE: I said that the Holocaust is an important event in our time; that, in order for adequate discussion to occur, it cannot just be presented in one-dimensional, dogmatic terms with only one version of the event accepted and entrenched by law, which is the effective result if revisionist views cannot be expressed.

He will also, I think, be able to put in context many of the statements of the Zundelsite in relation to this discussion and what he will call the Holocaust Lobby.

In my submission, he will be giving evidence that will show the existence of a very threatening and frightening academic oppressive force in that even those representatives of groups in this room, he will say, participate in the attempted suppression of debate and discussion, and that this is contrary to the best interests of Jews, contrary to goodwill, and destructive of feelings of humanity and compassion. It is, in fact, productive of antisemitism to deny debate on the subject.

He will state that revisionist scholarship helps the public to see Jews as well as non-Jews as sharing in the suffering of humanity in much the same say, caught in the tragic events of what is not an inexplicable chapter of history but one that needs to be analyzed rationally and explained to bring about increased tolerance and understanding, certainly between Germans and Jews but between people of all races. To understand how these tragedies occurred is necessary to overcome feelings of hatred and animosity.

The opinions of Dr. Schweitzer in this case ‑‑ and I hope I am not oversimplifying, but inevitably will in some ways not do justice to his evidence. In some sense, it is accurate to say that Dr. Schweitzer asserted that the Zundelsite documents are just an ongoing part of the continuum of historic antisemitism, that there is no rational element and no redeeming virtue, value or content to that which is expressed in the documents in HR-2.

Mr. Weber, on the other hand, will suggest that opinions of Dr. Schweitzer about the alleged hateful content of the Zundelsite are wrong, and he will be able to explain why it is important in context to have open and vehement debate on these historic issues.

It is clear that Dr. Schweitzer certainly has more academic credentials than Mr. Weber; there is no debate about that, but that is not the only criterion, of course, for qualification of any expert. The best evidence of an expert is the rational quality of their opinion, in the end tested by cross-examination.

I can think of no case in my experience where a witness' qualifications have been so severely tested, so frankly confronted and opposed and vehemently opposed for two days. It is quite remarkable. In all of that time, in my submission, Mr. Weber presented a rational position which, whether one accepts it or not, was not presented with malice or bigotry. He seemed to be, in my submission, fairly candid about things that might be embarrassing ‑‑ for example, his racial views which might be, and no doubt will be, argued as a reason to disqualify him.

It is very strange in this situation that Mr. Zundel is accused of being a Nazi and a racist and a bigot; eventually, no doubt, that will be one of the accusations. In his defence, no one who agrees with him can escape the same accusations; therefore, he can have no witnesses. That would seem to be the logic of the argument. He can have no experts. He might have other kooks like himself, but no experts.

My submission basically is that the world is comprised of many people with different opinions, some that are vehemently opposed to others. There are those who would categorize as racist anyone who thinks there are racial distinctions and would say that such people have no right to speak or organize.

I vaguely remember such a slogan outside of a meeting once. It struck me then and it strikes me now as valid to submit to you, as I would to them, first of all: How do you know without hearing them that they are racist and precisely what kind of racist? What are they? Is all racism equally diabolical that we do not listen to them first? Secondly, assuming that they were racists, even of the worst kind, have they a right to rational opinions, however feeble or erroneous, and can they not be defeated in argument? If they can, then they have a right to speak and organize and to do so in our society like anyone else.

It would be equally invalid to argue, for instance, that anyone who spoke in defence of communism could not do so because of Stalin, Stalin being a murderer ‑‑ and maybe not racist, although some people said he acted as if he was. One could never advocate a position that was associated with the crimes of a dictator of that position or of someone with authority in that type of political arrangement.

It would be, in my submission, the wrong way to disqualify people because, after all, if only experts who agreed with one side were qualified, there would be no room or even possibility for debate in a rational sense and, as we are speaking in a human rights context, hopefully to bring about harmony between different points of view even on the issue of race. In my submission, it is probably better to allow whatever rational expression there may be in defence of a position than to say, a priori, because of a definition, be it racist or non-racist, that one cannot have that point of view and cannot express it.

I am saying that, if the first day of cross-examination proves anything, it proves that Mr. Weber is truthful and that he had racialist views, and he still has racialist views. He says that he believes in the integrity of races, the separation, if you want to put it that way, and that there are racial differences.

If that was enough to disqualify someone, then I would think it would disqualify most except for those who are dishonest. It would disqualify a lot more than we would at first think, because most people would never have the courage to admit that they held such views. But Mr. Weber did.

In my submission, it does not disgrace or discredit him ‑‑ and certainly it has nothing to do with his opinions vis-à-vis the Second World War or history or revisionism or the Holocaust. No doubt, it might be argued to the contrary, but in my submission his own evidence was that it really has nothing to do with revisionism.

Dr. Schweitzer had never been qualified to testify in any court before and, to my knowledge, there has never been a determination that the history of antisemitism was a field of expertise known to law. But every day we learn new things; every day things are expanded, and the history of antisemitism was accepted as a legitimate field of expertise. Beyond it, of course, he gave us the history of the world, his views of the Christian religion, and a great many other things, much of which no doubt he believes but much of which might be beyond the scope of his expertise, but was allowed. I agree that I didn't object to everything in that regard.

What I am submitting is this. Before you is a witness who was qualified in an Ontario court in 1988 in the very same area that we are considering today ‑‑ that is, Holocaust revisionism. I have the judgment of the Court in the exact words, I think. If there is any doubt about it, I would be willing to provide it. I brought copies of everything that preceded his qualification.

As you know, I was surprised to find that what I had thought came before actually came after. The cross-examination on his publication in 1988 came after his qualification. No doubt my friends will argue that, had those questions been asked beforehand, he would not have been qualified. That is an argument which I would suggest is not on good grounds because there is no doubt that the Crown had that in their hands beforehand and qualified him nonetheless or did not introduce that type of cross-examination. Had they, it really does not impeach his qualifications; it impeaches, perhaps, his credibility, and that is a different issue.

MEMBER DEVINS: It actually supports your point in that it goes to credibility, not admissibility of the evidence.

MR. CHRISTIE: That is what I understood at the time, and I understood that was why they did it that way. In the old days, it used to be clear in my mind, but now maybe I misunderstand things more than I did then.

It seems with respect to that that he was qualified in this area because "Did Six Million Really Die?" was a publication that was in issue in that case, and it is very much a part of this case. In fact, I think it is the first item in HR-2.

It seemed then that it was relevant; it seemed then that it was true that he was qualified to speak on the subject by a court. Nothing has really changed. There have been other documents added, but I think, with respect, the thrust of the case is very much the same. It is Holocaust revisionism or the way it is expressed ‑‑ I don't know quite which; in the end we will hear the argument. Is it in our society a legitimate form of expression?

There are other aspects to this case that involve this witness directly. Some of the things that he has written, like the "Jewish Soap" article and the article that he was cross-examined on about Auschwitz ‑‑ these were actually written by him. These are publications of the Institute for Historical Review, of which he is the Director. Those are certainly things that he might testify to as matters of fact. They certainly would not entitle him to go beyond those simple facts to discuss the basis of them or their relationship and his experiences with them in the debate about these issues in history.

In effect, he is one of the attempts of the Respondent to answer Dr. Schweitzer's views. He has, in my submission, read more widely on the subject of the Second World War and the Holocaust in particular than Dr. Schweitzer who had really no knowledge, and claimed no expert knowledge that I know of, about the subject.

This is an area which, of course, is quite controversial, but Dr. Schweitzer said that, had there been truth to what was published, he would have taken the view that it was not part of the stream of historic antisemitism. Of course, I maintain that, even if truth is not a defence here, if an expert witness says that truth would disqualify it from his own categorization, then truth becomes relevant not to the truth or falsity being a defence but to prove that what is alleged to be part of the stream of historic antisemitism is actually outside of it because there may be truth to it.

That is a matter which you would have tell me whether I can lead evidence on or not, but I would submit that that is one of the areas that Mr. Weber would be able to assist with in regard to some of the statements that are in HR-2.

The other aspect of it is that, even if it were not possible by virtue of your ruling to say that some aspects of the Zundelsite documents were historically accurate, he could still, in my submission, put it in the context of what is an ongoing valid historical debate ‑‑ that is, in my submission, to put it in the social context in which a reasonable person would view it.

The reasonable person ‑‑ and the test, hopefully, is applicable here. That is something which has not, as far as I know, been judicially determined. If a reasonable person were to hear a shouting match in a historical context about a historical issue, they might take a different view of it in relation to whether or not it exposes someone to hatred, contempt or ridicule by virtue of race, religion, ethnic origin, et cetera.

Seen in a historical debate context, strongly-worded expressions of opinion are not necessarily directed at persons by reason of race, religion or ethnic origin or necessarily in the reasonable person's mind productive of or exposing to hatred, contempt or ridicule on the basis of race, religion or ethnic origin. In the context of historical debate ‑‑ a valid ongoing one; not some fictitious possibility, but a real debate ‑‑ it would be, in my submission, that one who is a reasonable person would see it as part of a controversy about history, not a controversy about race.

After all, when we talk about history, we cannot avoid talking about race and we cannot avoid talking about religion. We cannot, for example, discuss the Spanish Inquisition without talking about religion and exposing some people in a religious context to hatred or contempt incidental to and separate from the primary thrust of the historic discussion. Nor could you talk about the Reformation, nor could you talk about the conflicts between Islam and Christianity in the 800s in France without discussing things that incidentally and accidentally could have those effects, but primarily are directed to the discussion of a legitimate historical controversy.

Of course, intent is not an issue in these proceedings; we understand that. Even if there were some elements of animosity from some other movie, so to speak, in the mind of some speaker about a historic topic, that would not necessarily disqualify the validity of the observation of an expert who would testify about matters that put it in the context of a historic debate or controversy.

This witness has testified for, I think, at least a week ‑‑ and I mean testified under cross-examination just as strenuous as the cross-examination here ‑‑ about a line-by-line analysis of "Did Six Million Really Die?" It was partly to prove truth, but it was also to prove that it is part of an ongoing and serious inquiry into truth ‑‑ not to say that anybody is telling the whole truth, not to say that anybody knows the truth completely. We all try to see things through a glass darkly perhaps.

THE CHAIRPERSON: He seems to have come to his philosophy not from the point of view of a scholarly pilgrimage but through study. We go back and we see what happened to him at the age of 18. He is, like St. Paul, struck from his horse and comes up with a point of view of the world.

MR. CHRISTIE: Yes, that is true.

THE CHAIRPERSON: That point of view seems to have fastened or consolidated his view of history.

MR. CHRISTIE: That is very possibly true; I don't deny that.

I would say that it is quite likely that this is true of most of us, that we have certain predilections. Say, for example, we are born into a family of MacDonalds and we are brought up nursing hatred of Campbells from our mother's milk, if we happen to be Scottish, or, if we happen to be Jews, brought up in an atmosphere of suspicion and fear and anxiety about the treatment we receive from Gentiles. We have a predilection created by our background.

Very few of us are as honest about it as Mr. Weber. I don't deny that it is quite possible that his views about race, his views about Germany, his sensitivities created by his stay in Germany, which was attacked by Mr. Rosen, may be the foundation of his bias. If so, he is much more honest about his bias, in my submission, than Dr. Schweitzer who, after all, wrote his first book for the Anti-Defamation League of B'nai Brith, one of the parties here. He, too, of course, has a bias. He has a very strong view about Christianity. He didn't write an essay on how he got those views, and we don't have the right ‑‑ and, frankly, I think it is irrelevant once it is established that we have a bias. I don't think we can say that, therefore, everything someone says, because they have a bias, is untrue. It might be suspect. It has to be weighed with the evidence of whatever bias is provable.

It is quite consistent with both logic and common sense and human nature that Mr. Weber acquired perhaps a sympathy for Germans and a predilection to take another view. He may have had what a lot us have, the sympathy factor for losers. You will find that there is a common thread through many of the articles in the IHR Journal; it is sympathy for the losers in war, such as the Japanese. You will find articles about the Confederates; you could also say that is because they are racist, but it might not apply too much to the Japanese. It is a predilection to look on the other side of a controversy, and the worst form of controversy in our world is war. It is the most violent and the most devastating and permanent.

THE CHAIRPERSON: The views he expressed at an early age were basically views about race which have not changed. You will remember the expression about the Bourbons: They have learned nothing and forgotten nothing, He has not changed his views over all this time.

I am not suggesting that that is inappropriate. As a historian, he can take a point of view. The fact of the matter is that it is not a classical description of a historian.

MR. CHRISTIE: Is there a classical description of a historian? I would suggest that maybe from a liberal point of view one takes the position that all historians are liberal in that they are neutral ‑‑ emotionally, racially, culturally neutral.

Really, in all honesty, if we were frank about it, I think most of us would have to admit that we have some biases in favour of some cultures, maybe even in favour of some races.

Let's put it this way. Assuming that he is biased in favour of the White race or feels a legitimate, or illegitimate, fear of its demise or disappearance ‑‑ and that certainly was a theme reflected in his 1978 article. Does that disqualify him as an expert historian?

If there is a point of view to be argued for, and maybe there is, that the White race has a right to have its advocates, there are definitely today recognized scholars who espouse Native culture. In universities we are gradually developing Native Studies courses. What are they? People who don't sympathize with Natives? Of course they do. They will present views that White society destroyed valid Native culture, that it was indigenous, that it was beautiful, that it was harmonious, that it was harmless, that it never made war, that it didn't oppress people like Whites do. This is quite common.

It is not abnormal for people to have bias, even legitimate experts. Why are they allowed to have a bias? Because, in order to have balance, we cannot have everybody agreeing to be neutral. We have to have some advocates for one position and some advocates for another, or we don't have an argument; we have an agreement not to disagree. That is not even discussion. We don't even have a rational discussion.

If everybody takes the view that race is irrelevant, then those who take the view that it isn't will never be allowed to have an opportunity to participate ‑‑ and there are those who say they should not be allowed to.

I suggest that, to disqualify people on the basis of a previous and present view that races are different, that their differences are important and valuable ‑‑ there is no suggestion that should disqualify them from being entitled to participate in debates about historical issues.

One cannot separate history from either race or religion in any real way. It is true, for instance, that in the Second World War we interned people not because they were from Japan or Japanese citizens, but because they were Japanese by race. We did it. Was that justified? Certainly many people say "no", but if somebody said "yes," would they be disentitled to present their case because we automatically assume they are racists and, therefore, they are wrong?

Then we do not have a discussion in any real way that comes anywhere close to the truth.

It would be wrong to disqualify people who had racist views. It would be wrong to disqualify people who had anti-racist views or people who had anti-White views. There may be very valid reasons for those views. We can never find those reasons if we disqualify them in advance because we say, "They don't like Whites; therefore, they cannot speak." If they had reasons for their dislike, we would never hear them and we would never know whether they were valid or not. We could never even discuss them, I guess.

I agree that there is clear evidence, probably strong evidence, that Mr. Weber has a racial bias which he has been frank about.

For instance, in many universities they speak about the Eurocentric historical analysis and how biased that has been and unfair to Afro-Americans. There are now Afro-American Studies, and there are people who advocate the Afro-American point of view. This is not necessarily sufficient to disqualify anyone from having not only a valid point of view but an expert point of view which would be, after all, a point of view that actually has more factual information than, for example, those of us who are not familiar with the debate.

That is basically all that is necessary to qualify someone as an expert, that they know more than a judge does. That is not to say that judges don't know a great deal, but there are many aspects of life, many areas of history, for example, where historians or people who have studied in the field, which would be the same thing, know more than those who have not. We don't all know everything. Some of us admit that we know virtually nothing, but that doesn't make us either idiots or incapable of learning.

In fact, I, who claim to know virtually nothing, would say that the essence of an expert is someone who has knowledge, who can assist you to know more about the subject of which they speak than you would have known if you did not talk to them.

THE CHAIRPERSON: The general principle is that the witness is an expert if he or she has something to offer to assist the Court or the Tribunal.

MR. CHRISTIE: Whether they are skilled with some particular knowledge. It doesn't mean that it is right knowledge or wrong knowledge or good knowledge or bad knowledge. It is knowledge and, when we hear it, then we can assess whether it is right, wrong or bad.

Therefore, it would be an a priori disqualification to say that racists cannot be experts or that those who have a preference or sympathy for the German side in the war or sympathy for Nazis cannot be experts. If such were the disqualification process, we would, hopefully, have been able to succeed that those who have sympathy for Jews would be disqualified, and that would be a preposterous proposition.

Dr. Weber, it seemed, quite clearly had a sympathy for Jews. No doubt, he has ‑‑

MR. FREIMAN: Dr. Schweitzer you mean.

MR. CHRISTIE: What did I say?

MR. FREIMAN: Dr. Weber, a double error.

MR. CHRISTIE: It's not the first and it won't be the last ‑‑ as to survival only.

The essence of Dr. Weber's evidence was not totally unbiased.

MR. FREIMAN: You said "Dr. Weber" again.

MR. CHRISTIE: I am getting in the habit here.

THE CHAIRPERSON: We are going to give you a chance to untie your tongue.

MR. CHRISTIE: Thank you.

‑‑- Short Recess at 11:25 a.m.

‑‑- Upon resuming at 11:47 a.m.

MR. CHRISTIE: I would like to carry on for a few moments on the subject of precisely how expertise is not necessarily based upon general acceptance or upon majority opinion or academic qualifications.

Just looking at a few examples, Thomas Edison did not have a degree in electrical engineering. Henry Ford did not have a degree in mechanical engineering. Alexander Graham Bell did not have a degree in telephony.

THE CHAIRPERSON: He would have to have one today.

MR. CHRISTIE: He would today, but he would still be an expert even if he were called today on the subject with which he was familiar.

With regard to history, in particular the Holocaust, Elie Wiesel, although he would not be called a Holocaust historian, certainly writes on the subject and would be considered an expert in aspects of it. He is not either a historian, certainly not a history professor. He was at one time a newspaper reporter.

Gerald Reidlinger who was the first to write on the subject with any great depth was an art dealer. Raul Hilberg was a political scientist. Deborah Lipstadt was a teacher of religion. All of these people are well-known, recognized historians of this particular subject.

In any area of history, traditionally you will find examples of people who write about it or involve themselves in study of it because of interest. The history of the death of John Fitzgerald Kennedy could not be written without books by Mark Lane, a lawyer who wrote about it, or Oliver Stone the film-maker. These are people who have had specific interest in the area which they are experts.

It is basically true to say that throughout history those who have had unorthodox opinions have been often the forerunners of change. For example, even Sigmund Freud had difficult experiences trying to overcome the orthodoxy of the psychiatric profession in his day. Until he did, of course, he was considered an outcast, a pariah practically, and did not find it easy to become accepted.

The subject of Holocaust studies in universities did not become a recognized study until around 1985. There are several universities who still don't have studies specifically in that field. It is not something one could have a long-standing academic experience with.

In general terms, victors write history and the vanquished become revisionists. That is true of almost every war, in fact. It is only recently, with the emergence of Scots' nationalism, that the version of history that would be presented by, for instance, Edward I, has been reversed. Now the English are the bad oppressors and the Scots are just valiant freedom fighters.

This is what happens over time and sometimes more quickly than in others. Seven hundred years is a long time.

My submission is that in the area of history revisionism is inherently necessary and it is also necessary that those who are not specifically trained in that area would have to be recognized when they have worked and studied in that area to acquire their expertise.

I was going to just refer briefly to Marquard. In my submission, it is about as much as I need to produce to demonstrate that at least ‑‑ I will just give you copies of this case. I will only refer to the headnote and, in my submission, that is all that is necessary.

In the judgment of Madam Justice McLachlin for the Court, she makes the point ‑‑ and I suggest that it is very clear and well established:

"The only requirement for the admission of expert opinion is that the 'expert witness possesses special knowledge and experience going beyond that of the trier of fact.'"

Then she cites R. v. Beland.

"Deficiencies in the expertise go to weight, not admissibility. As stated by Sopinka, Lederman and Bryant, The Law of Evidence in Canada ‑‑"

I know that is trite but, in my submission, it seems that from time to time it has to be reiterated, as it was in 1993 in the Supreme Court, that that is the only requirement. It is not so much a matter of credibility as admissibility, and I submit that that is very clear.

The case of Rice v. Sockett is actually referred to in Marquard, I believe, at one point. It is an Ontario Court of Appeal judgment which I want to refer to briefly. Rice v. Sockett is an old case, but it has been referred to many times with approval.

The judgment states at page 85:

"The term 'expert,' from experti, says Bouvier, 'signifies instructed by experience.'

'The expert witness is one possessed of special knowledge or skill in respect of a subject upon which he is called to testify:' Words and Phrases Judicially Defined, volume 3, page 2594.

Dr. John Lawson, in 'The Law of Expert and Opinion Evidence,' 2nd edition, at p. 74, lays down as Rule 22, 'Mechanics, artisans and workmen are experts as to matters of technical skill in their trades, and their opinions in such cases are admissible'; citing numerous authorities and illustrations.

'The derivation of the term "expert" implies that he is one who by experience has acquired special or peculiar knowledge of the subject of which he undertakes to testify, and it does not matter whether such knowledge has been acquired by study of scientific works or by practical observation; and one who is an old hunter, and has thus had much experience in the use of firearms, may be as well qualified to testify as to the appearance which a gun recently fired would present as a highly educated and skilled gunsmith'."

That is just a general statement, but I think it is of some value in submitting to you that Mr. Weber's evidence is as valuable, in fact more germane, more pertinent and more on the point, than Dr. Schweitzer's evidence simply because it is dealing with the essence of the case. It is dealing with the historic significance of revisionism generally.

I have one other authority I would like to provide on the subject. It is the publication called "The Expert, A Practitioner's Guide" published by Carswell. It covers the subject of both relevance and admissibility.

I think it helps to observe the statements on page 1-10 on qualifying the expert. Essentially, it reiterates what is said in Marquard.

"The first step involved in bringing out the evidence of an expert witness is to demonstrate to the court that the witness has particular or special knowledge in the area in which he or she proposes to testify. This knowledge may have been acquired either through study or experience. It is essential to qualify an expert witness in this manner because usually the main purpose of calling the witness is to testify about matters which are beyond the knowledge and experience of the trier of fact."

They cite Rice v. Sockett.

May I say that the subject of the Second World War and the subject of the Holocaust is something that we have all heard about and we all have strong views about. Many of the facts and circumstances behind it are not necessarily well-known. For that reason, this witness has unique skill and ability in that regard.

Of course, that can be tested, as it was in his qualification process, by reference to anything that he has cited. That is exactly what I would expect my friends to do. However, I would submit that his experience in this area is beyond that of most of us. Certainly most reasonable people would not know as much about the subject as he does.

Essentially, that is all I have to say. Thank you for hearing me. Those are my reasons for submitting that this expert should be qualified to testify in the areas I have suggested.

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

MR. FREIMAN: Thank you.

ARGUMENT ON BEHALF OF CANADIAN HUMAN RIGHTS COMMISSION

MR. FREIMAN: I will try to be brief because I expect that Mr. Rosen, who conducted the bulk of the cross-examination, will have interesting and important things to say ba

Toronto, Ontario

‑‑- Upon resuming on Thursday, December 10, 1998

at 10:03 a.m.

RESUMED: MARK WEBER

MR. ROSEN: Mr. Chairman and Member Devins, I want to apologize for sort of rambling yesterday. I think I was just getting tired, and I am glad you stopped as early as you did. I will try to be a little more succinct today.

One of the matters that I wanted to raise was this publication. Rather than read it into the record, since it has been raised, I was wondering if we could just mark it as an exhibit on this voir dire type proceeding. I am not going to ask the witness any more about it.

THE CHAIRPERSON: Yes.

MR. CHRISTIE: Did I hear that right? He is not going to ask the witness anything about it?

MR. ROSEN: Any more about it.

MR. CHRISTIE: I didn't understand that this required filing of the whole document.

THE CHAIRPERSON: It was referred to in evidence. Let me just review what was done with it.

You read from portions of it.

MR. ROSEN: I did.

THE CHAIRPERSON: I have a general concern about the scope of the record here.

MR. ROSEN: Also Mr. Fromm in his cross-examination, so to speak, of this witness referred to every single article in the Index and didn't refer to the articles. I also went over the Editorial Advisory Committee, and you have the list.

THE CHAIRPERSON: Are there certain things that you anticipate referring to in argument?

MR. ROSEN: Yes.

THE CHAIRPERSON: We will mark if then.

THE REGISTRAR: The Journal of Historical Review will become SW-8.

EXHIBIT NO. SW-8: The Journal of Historical Review, Volume 16, Number 3, May/June 1997

MR. ROSEN: The only other area I wanted to deal with is as a result of Mr. Fromm's questioning.

CROSS-EXAMINATION, continued

MR. ROSEN:

Q. Sir, you have obviously been in Toronto since the weekend.

A. I think I arrived here on Monday. No, I arrived here on Saturday, excuse me.

Q. And you have met, obviously in preparation for your evidence, with counsel for the Respondent, Mr. Christie. Is that right?

A. I have met with Mr. Christie.

Q. And with Mr. Zundel?

A. Yes.

Q. And with Mr. Fromm?

A. I haven't met with Mr. Fromm.

Q. At all?

A. Only in the court room here.

Q. Just in the court room.

A. Just to say hello.

Q. In preparation for Mr. Fromm's examination, I take it that you spoke with him about the production of one of these Journals.

A. No, I did not.

Q. Whom did you speak to about it?

A. I didn't speak with anyone about it.

Q. The reason I ask is that Mr. Fromm, when he was asking you questions, had the document in his hand and you seemed to be well versed in anticipation of his questions about the document and what he was going to ask you about it and what was in it. I take it that you spoke to Mr. Christie or Mr. Zundel or Mr. Fromm about that.

A. What is your question, please?

Q. You spoke to any or all of them about what you were going to be asked by Mr. Fromm. Is that right?

A. No, that is not right.

Q. Tell me what happened.

A. What happened was what you saw happen.

Q. In anticipation of re-examination, I take it that you have met with Mr. Christie as well to talk about your re-examination?

A. No, that is not correct.

Q. Where have you been staying, sir?

A. I have been staying at the Zundel house, Mr. Zundel's residence.

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

THE CHAIRPERSON: I have just a couple of questions, Mr. Weber.

You have contributed an article to the Zundel publication which has been referred to. Do you regularly contribute to it or was that a unique occasion?

THE WITNESS: I am glad you asked the question, and I want to make something very clear.

I never, in the sense, contributed anything to the Zundelsite. Someone, I don't know who, downloaded some material from our IHR site and put it on the Zundelsite. We freely make material available to anyone who wishes to reprint or otherwise circulate it.

I don't recall or even know of any specific permission that was asked to reprint material from our site or from the Journal on the Zundelsite. It is a matter of standing policy that we invite and encourage anyone to reproduce material from our site or from the Journal as long as credit is given. To the best of my knowledge, there was no specific inquiry made by anyone to have the material that comes from me or from our site put on the Zundelsite.

THE CHAIRPERSON: I see. In the past have you ever been asked to contribute anything to the Zundelsite?

THE WITNESS: I have never been asked to contribute anything to the Zundelsite. In fact, I was surprised to learn, I forget when it was, that there even was some material by me on the Zundelsite. I didn't know about it ahead of time.

THE CHAIRPERSON: Thank you. How long have you known Mr. Zundel?

THE WITNESS: In person, I guess, since 1988 when I testified at the time of the trial.

THE CHAIRPERSON: You are the Director of the IHR.

THE WITNESS: That's right.

THE CHAIRPERSON: It has a publication, the Journal. What other activities does it have?

THE WITNESS: It publishes books. It holds meetings. It distributes video and audio tapes and distributes books. Most of the books that the IHR sells are not published by the IHR; they are published by other publishers. Many of the books sold by the IHR are published by the IHR as well.

THE CHAIRPERSON: Is it fair to say that its predominant activity is in relation to historical revisionism and the Holocaust?

THE WITNESS: It is important to make a distinction between historical revisionism and Holocaust revisionism. I think it is fair to say that the majority of the activity of the IHR is not devoted to the Holocaust. The majority of the books that are published or distributed by the IHR and the tapes we distribute do not deal with the Holocaust.

It is a very large part of what the IHR deals with, as was brought out yesterday. In this issue of the Journal that is being submitted here, most of the articles do not deal with the Holocaust issue.

THE CHAIRPERSON: In my examination of the Index ‑‑ and perhaps I am wrong ‑‑ it seems to me that of the roughly 12 articles six were devoted to Holocaust revisionism. Is that fair?

THE WITNESS: It may be that that is the number. The major articles deal with the Hiroshima bombing.

THE CHAIRPERSON: You mean in terms of scope of the individual articles?

THE WITNESS: Yes. I would say that the percentage of material dealing with the Holocaust in the Journal is higher by far than the percentage of books and tapes that we sell through the IHR on this one issue.

THE CHAIRPERSON: Concerning what is being advanced as your expertise in historical revisionism, this is all self-taught, is it not?

THE WITNESS: Absolutely not. I see what you are saying; you mean just with regard to the Holocaust issue.

THE CHAIRPERSON: It is not in relation to your formal qualifications. Your formal qualifications are as a historian, and your thesis was on the Hapsburg regime.

THE WITNESS: It was actually on 1930s and 1940s Hungarian intellectual themes.

THE CHAIRPERSON: It is about European history.

THE WITNESS: Right.

THE CHAIRPERSON: You are being held out as an authority on historical revisionism, including Holocaust revisionism.

THE WITNESS: Right.

THE CHAIRPERSON: And that is something that you have undertaken from your studies since your formal qualification.

THE WITNESS: That is not unfair. That is similar to a number of other historians who have written on this subject, who are, as it were, self-taught. Raul Hilberg, arguably the leading Holocaust historian in the United States, is entirely self-taught on this issue. He has no formal education in the Holocaust issue; he did this entirely on his own. His degree and his background is in political science.

THE CHAIRPERSON: I understand; I am not testing that. There are schools where historical revisionism is on the curriculum?

THE WITNESS: Historical revisionism is really just a way of looking at history. It just means that one takes a critical look at history. All history is revisionist in the sense that history is looked at critically or from a new point of view.

Historical revisionism is not a special school that is taught. It is just part of how we look at history. The distinction is that historical revisionism was a distinct trend, especially in the 1920s, 1930s and 1940s with regard to the origins of the First World War, and it came to be applied to a dissident or non-governmental look at world wars in general.

For example, historical revisionism includes a look at the Vietnam War which is contrary, you might say, to the official view. Historical revisionism with regard to the Hiroshima bombing is only historical revisionist in the sense that it rejects the official view of that.

THE CHAIRPERSON: I am speaking of places of learning where the specific rubric of revisionism is used.

THE WITNESS: It is not used as a specific rubric, no. In fact, I have some qualms about using it because I like to feel that all legitimate and serious historical scholarship is revisionist.

There is no question that all over the United States, all over the world, many, many historians take views on issues similar to the ones that we do.

THE CHAIRPERSON: I am talking about historians who use the term "revisionism." You use it, and I suppose other historians use it as well.

THE WITNESS: It's a little bit, sir, like saying ‑‑ there might be a historical journal that says that it is a conservative or a liberal historical journal. There is no specific branch of historiography in universities that would say, "We are liberal historiography or conservative or Marxist historiography." It is not divided that way.

There may be journals that present a view of history that might be either Marxist or liberal or conservative, but it is not divided that way in the academic world.

THE CHAIRPERSON: Thank you. Is there anything arising from that, Mr. Rosen?

MR. ROSEN: Not from me, thank you.

THE CHAIRPERSON: Mr. Christie, please.

RE-EXAMINATION