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I received both written and oral instructions to provide expert opinion on the historical writings and speeches of David Irving with reference to the allegations made about them by Deborah Lipstadt.

I have been given access to the Statement of Claim served on 5 September 1996; the Defences of the First and Second Defendants served on 12 February 1997 and 18 April 1997 respectively; the Reply to both Defences served on 19 April 1997; documents disclosed by the Plaintiff pursuant to his discovery obligatoons, and various documents from the Plaintiff's various Lists of Documents as referred to in the footnotes to this report. dissertation in 1969, I have acquired an excellent knowledge of German: I wrote my book (Rowohlt Verlag, Reinbek bei Hamburg, 1989) in German myself, and I have lectured in German at numerous German universities and on various public venues.

Some of my most important work, however, has also dealt with the Second World War.

The only references to him in any of my books come on pages 38 and 76 of (New York, 1989), in the context, not of a detailed examination of Irving's work itself, but of a discussion of the work of other historians, namely Ernst Nolte and Hans Mommsen.

I am familiar with Germany and the Germans as well as with the German language.

My research has ranged widely over German history in the last three centuries.

It has become well known for the thoroughness and comprehensiveness of its use of unpublished manuscript material.

Much of it has concentrated on the nineteenth century.

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