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613-737) on the 'Third Reich', of which Chapter 16 (pp.689-737) deals exclusively on the war years 1939-45, using particularly files of the Reich Ministry of Justice in the German Federal Archive (Bundesarchiv) in Koblenz.I am a Fellow of the Royal Historical Society and was elected a Fellow of the British Academy in 1993.My reputation as a recognized authority on Germany, German history and the theory and practice of history has led to frequent invitations to broadcast on the BBC, in particular Radio 3 and Radio 4, on programmes including I have never met, spoken to, or corresponded with David Irving.Some of my most important work, however, has also dealt with the Second World War.In particular my book (Oxford University Press, 1996), based on unpublished manuscripts and typescripts in 26 archives, contains three Chapters (pp.I am a recognized authority on modern German history and have been teaching and researching it for the last thirty years. As a result of my book on the Hamburg cholera epidemic of 1892 ( (Oxford University Press, 1987; German edition 1990) I was invited to deliver the principal address in German at the centenary commemoration in Hamburg City Hall in 1992.

and because of its style and content considered it a work of journalism rather than of professional history.These claims can be summarised under four headings.They are as follows (references are to the page of the book on which they occur): This report has been prepared on the instructions of Davenport Lyons and Mishcon de Reya, the solicitors respectively to the First and Second Defandants.I have not previously concerned myself with his work in any way.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.

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