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Denial is a 2016 Law Procedural film that dramatises the libel suit brought against American historian Deborah Lipstadt (Rachel Weisz) - as well as her British publishers, Penguin Books - by British writer David Irving (Timothy Spall) after Lipstadt called him a Holocaust denier and an anti-Semite in one of her books. Since British law places the burden of proof on the defendant in libel cases, Lipstadt has to prove that she did not slander Irving by saying he created false evidence and misinterpreted existing evidence to deny the truth of the Holocaust.

Lipstadt is helped by an ace team of British lawyers, including solicitor Anthony Julius (Andrew Scott) and barrister Richard Rampton (Tom Wilkinson). When Lipstadt wants to testify on her own behalf and bring Holocaust survivors to the stand, however, the lawyers see Irving — who is acting as his own lawyer — as too dangerous a manipulator to allow him a chance at a cross-examination. Outside of the courtroom, the trial also gains a wealth of attention from the media, which spin the cases into a trial about the truth of the Holocaust.

Denial contains the following tropes:

  • Adapted Out: The film mostly portrays Irving as calm and collected and does not depict his more infamous lowlights from the real-life trial, such as pedantically arguing with defense witness Richard J. Evans over which of them was an "expert in pit-digging" for five minutes, and addressing the judge as "mein Führer" in front of the entire court. It also does not include the moment during the post-trial Jeremy Paxman interview where Irving, becoming aware that Paxman was not going to give him the easy ride he had somehow expected, blurted out "You're not Jewish, are you?".
  • A Dog Named "Dog": Deborah's dog is named "The Mutt" in the credits.
  • Appeal to Flattery: Deborah's lawyers want to have the case decided by the judge rather than a jury because they fear Irving can influence a jury more easily with his grandstanding techniques. However, Irving has to agree to trial by a judge. They get him to agree by appealing to his ego.
    Julius: We all know that Mr. Irving has devoted his life to the study of the Third Reich. I admit myself to having sometimes struggled with the demands of the material. I wonder if Mr. Irving really believes it's fair to ask the regular Joe or Joan who walks in from the street to grasp in a mere few weeks what he himself has taken a lifetime to master?
    Irving: (Beat) I agree. The issues before the court are sufficiently complex to require the attention of a learned judge, and too complex to confront a jury with.
  • Armor-Piercing Question: After Irving makes an argument that the gas chamber at Auschwitz was only used to delouse the corpses of people who had already died of typhus, Rampton asks him what happened to the corpses next. After Irving confirms that they were taken to the crematorium for disposal, Rampton asks:
    Rampton: What is the point in gassing a corpse that is about to be burnt?
  • Army of Lawyers: For once, this is actually used on the good side. Deborah winds up with a dozen people working on her case, thanks to its historic importance, while Irving is alone on his side of the room, representing himself. Irving is somewhat Genre Savvy about this trope, however, as he's compared himself to David vs Goliath a few times, and is aware of how it will look to the reporters.
  • Artistic License History: A minor example; the real Richard J. Evans found the film's depiction of the events mostly accurate, except for the fact that it portrays him and his assistants as already convinced of Irving's dishonesty when they agree to testify for Lipstadt. In reality, Evans had not read any of Irving's work and had no prior opinion on his credibility as an historian, which is one of the main reasons she approached him in the first place (that and his fluency in German, so he could examine the original documents quoted by Irving).
  • Attention Whore: David Irving, oh so much. The first time we see him he's jumping up in the audience of Deborah's lecture, waving money around to anyone who can prove Hitler knew about the Holocaustnote , talking over her despite her repeated requests for him to leave, and offering free copies of his books. He made sure to have a friend set up his camera to video the whole incident before he started too.
  • Backfire on the Witness Stand: This is what Julius spells out will happen if any survivors take the stand against Irving - he's an expert at pushing their buttons and badgering them, and he'll break them and compromise the case if he gets the chance to. Lipstadt is frustrated when her legal team agrees that the same is likely true of her; whether or not she "breaks," per se, she'll still be giving Irving what he wants when their entire strategy involves denying him the ability to bring his charisma and browbeating to bear.
  • Based on a True Story: The film is based on Lipstadt's memoir of the trial, which took place in the spring of 2000. Much of the dialogue in the courtroom scenes is taken word-for-word from the transcript of the actual trial.
  • Blatant Lies:
    • Even as he's confronted with his own virulently racist writings and speeches, Irving continues to flatly deny that either he or his audience (who laughed uproariously at the offensive jokes) are racist.
    • Irving in his post-trial interview actually tries to claim that the verdict means that he won the judgement. Deborah immediately refers to him as a "verdict denier".
  • Both Sides Have a Point:
    • Defied with how Irving's ideas are approached. Prior to Lipstadt writing her book that Irving would sue over, she notes that several student newspapers (some of which are even run by Jews) ran adverts proclaiming Holocaust denial and asking for debate by Bradley Smith, under the reasoning that "both sides deserve to be heard". This ignores that one side is demonstrably wrong, and almost certainly arguing in bad faith anyway, never mind actively offending the memory of the millions murdered in the Holocaust, the survivors, and their descendants. After the verdict comes down on her side, she rams this point home in her remarks to the press:
    Not all opinions are equal. And some things happen, just like we say they do. Slavery happened. The Black Death happened. The Earth is round, the icecaps are melting, and Elvis is not alive.
    • Played straight, however, with the conflicts that arise between Lipstadt and her legal team. The main one is that she wants survivors to be heard and vindicated, but Julius refuses to let Irving lay hands on a testifying survivor and subject them to further trauma. She also wants to be able to confront Irving personally in court on the witness stand, something which her legal team argues would only bolster his case and credibility with the judge. The movie portrays both sides as being right, because Lipstadt speaks as a Jewish-American with a conscience and from an emotional, cathartic place; Julius, Rampton, and company focuses on the legal standpoint of ensuring they win the case, regardless of whether they come off as heartless or disrespectful. Through the course of the film, Deborah has to reconcile herself with the fact that what feels best isn't always what works best.
  • Brooklyn Rage: Deborah is a New Yorker and very brash, emotional and opinionated. Irving even invokes this trope in an even interview after the trial in a petty effort to paint her negatively. Deborah simply responds upon seeing it that she is from Queens, not Brooklyn.
  • Bunny-Ears Lawyer: Richard Rampton. He drinks wine in his office (from plastic cups! He even jokes that he prefers plastic!), he cracks jokes, he shows up late when they visit Auschwitz, then swears loudly when he gets a bit of barbed wire stuck in his shoe, he offers decidedly non-kosher foodstuffs (black pudding, which is made with pig's blood) to Deborah, he seems to be avoiding eye-contact with Irving in court... and we discover that he was late because he was pacing off the distance from the barracks to the gas chambers in anticipation of Irving's argument that they were air-raid shelters, he keeps the fragment of barbed wire on his desk as a reminder of why he is doing the job, and he is avoiding eye contact with Irving because he knows it drives the man up the wall. See The Unfought, below, for more of his verbal badassery.
  • Character Development: The fiercely independent Deborah learns to trust and respect her team, the power of teamwork, and their knowledge of the British legal system, and to "hand her conscience over" to them. By the time of the verdict, she bows to the judge without prompting, something she had initially refused to do.
  • Compliment Backfire: Deborah tells Anthony Julius that she hired him because a friend told her that he's a real "junkyard dog". She means this in a good way, but he doesn't quite get that, likely due to the cultural differences. After she clarifies what she actually meant, he then explains he's not actually going to be her "junkyard dog", as he is a solicitor, thus he will only prepare the case for a barrister (in this case Richard Rampton) to actually defend in court.
  • Condemned by History: Invoked in-universe. This is what ended up happening to Irving after the trial. He went from a highly successful popular historian to a bankrupt bigoted Holocaust-denying Neo-Nazi discredited "historian".
  • Confirmation Bias: invokedAn intentional depiction (which is why this isn't listed on the YMMV page). Irving's MO is to loom through documents and twist their meaning to whatever pro-Hitler conclusion he wanted to reach. One notable example is him taking an order from Heinrich Himmler not to exterminate a specific arrival of Jewish prisoners to be Himmler saying not to exterminate any Jews and citing it as proof that the Holocaust never happened.
  • Conviction by Contradiction: Irving tries to disprove the Holocaust in this exact way, as Julius notes: he looks for some tiny inconsistency in the testimonies, then makes the whole case seem to stand or fall on it. For instance, historian Robert Jan van Pelt (Mark Gatiss) shows blueprints of the Auschwitz gas chambers as described by the man who designed them, including holes in the roof used to drop in cyanide gas. Irving points out that no holes were found in the ruins of the chamber roof, and loudly declares: "No holes, no Holocaust!".note 
  • Courtroom Antics: The word "antics" is directly used when Deborah's team express their fear of what Irving might do if he had a jury to play to, hence their Appeal to Flattery above to get him to agree to having it decided by a judge.
  • Crazy-Prepared: Rampton devotes every moment of his day to prepping for the case, no matter where he is. He walks the entire length of the Auschwitz barracks to the gas chambers specifically to prepare for Irving's argument over them being bomb shelters and immerses himself in historical documents so he knows exactly how to refute everything Irving throws at him.
  • Culture Clash: The film has some fun with the contrast between the outspoken Queens girl and her Stiff Upper Lip British lawyers. More seriously, she has trouble understanding the different attitude toward free speech, which makes it so hard to defend oneself in a libel case.
  • Deadpan Snarker: Deborah Lipstadt, mostly about how the only thing her legal team allows her to decide on is who to ask for donations for funding the legal case.
  • Death Glare:
    • Deborah gives Irving some good ones over the course of the film.
    • Subverted in the case of Rampton; Deborah notices that he, rather than glaring at Irving, barely meets his eye at all during the trial, and broadcasts contempt and disgust with his voice and body language rather than passionate outrage. She acknowledges that it's very effective at getting under the skin of a man who thrives on conflict and expects to be challenged, but doesn't know what to do when people simply don't take him seriously.
    • Irving himself hands out a strategically placed one to Deborah and her team during the "verbal yellow star" speech.
  • Door Stopper:
    • David Irving's diary spanning 20 years. It occupies all the top shelf cases of a single division in his home, and he says it's between 10 and 20 million words long. Deborah's team have to hire extra legal researchers and history students to actually find the useful material in there.
    • The judge's verdict is no lightweight either, being 334 pages long.
  • Due to the Dead: The preparation for the trial includes a visit to Auschwitz, which both Deborah and van Pelt treat as a "shrine", eventually praying and singing a Hebrew hymn over the ruins of the gas chamber where so many were killed.
  • Dumbass Has a Point: In both real life and the film, Irving was one of the first to correctly call out the Hitler diaries as fakes. To prove it was a fluke, he reversed his opinion a few days later, saying that there was much that was authentic in the diaries and the documents in its accompanying collection, likely because the forged diaries don't mention the Holocaust.
  • Even Evil Has Loved Ones: When two legal assistants go to Irving's house to gather evidence, they find him on the floor playing adoringly with his young daughter. The sweetness of the scene is rather soured later when it's revealed that he sings her a ditty about how she'll never marry outside the White race.
  • Faux Affably Evil: Irving, while browbeating and rudely interrupting people he's dropping in on unannounced and making jaw-droppingly racist speeches to groups of like-minded individuals, is generally perfectly courteous to whoever he's speaking to at the moment in private.
  • Fiery Cover-Up: Auschwitz is in ruins because the Nazis wrecked it at the end of the war to cover up the Holocaust, van Pelt explains. This is why hard physical evidence of what happened there is difficult to come by.
  • A Fool for a Client:
    • Irving acts as his own lawyer, and he does an impressive job of it... for a while.
    • This is the main reason Julius is adamant that survivors not be brought in to testify; a dispassionate cross-examination by a professional lawyer might just about be acceptable, but the thought of them being directly questioned by Irving, who is someone that will do everything he can to trip them up, humiliate them and accuse them of lying is the one thing that makes the composed Julius lose his cool.
  • Frivolous Lawsuit: The very lawsuit Irving launched against Lipstadt and Penguin that is the subject of this movie. Lipstadt and Penguin took it very seriously - perhaps more seriously than Irving had intended originally.
  • Graceful Loser: Irving attempts to do this, congratulating and extending his hand to Rampton. Rampton completely ignores him, demonstrating that his contempt for the man was not just a court tactic to get under Irving's skin, but also completely genuine. Irving is less graceful after they exit the court, where he makes a ridiculous attempt to claim that the verdict is actually in his favour.
  • The Heckler: Irving acts as this to Deborah in an early scene when he disrupts her lecture by challenging her to a debate and offering $1,000 to anyone who can provide him with a written order from Hitler authorizing the Holocaust. Naturally, he's having the whole thing filmed.
  • Here We Go Again!: As pointed out by Deborah, Irving starts the story as a Holocaust denier and ends it as a verdict denier, on top of still denying the Holocaust.
  • Historical Beauty Update:
  • Hoist by His Own Petard: David Irving, in bringing the libel lawsuit, forced the court to render a legal judgement that not only was he a Holocaust denier (and thus Deborah Lipstadt was not defaming him by calling him one), he was an anti-Semite and generally racist, and that he had in fact mistranslated documents and falsified research in order to cast Adolf Hitler in the best possible light in his work. The judgement destroyed any possibility of continuing his career as a historian and the legal payments (he was required to pay Lipstadt's legal costs) bankrupted him.
  • Hollywood Law: A minor example. In England, the phase of the trial where both parties present their evidence and respond to the other party's requests for evidence is called "disclosure", not "discovery", ever since a 1996 reform (strangely, they also use the term "litigant in person" instead of pro se, which was also adopted in the same reform).
  • Immediate Self-Contradiction: On the first day of the trial, Deborah is confronted on the way into the courthouse by a man who calls her a "lying Jewish bitch," then the very next sentence asks if she believes "it all ended with Hitler" and threatens her by claiming he knows the hotel she's staying in.
  • Implausible Deniability: Irving claims he's not racist even as the court reads his own diaries and views recorded speeches that show him making blatantly racist statements.
    Rampton: You sued because you said that we had called you a racist and an extremist.
    Irving: Yes, but I'm not a racist.
    Rampton: Mr. Irving, look at the words on the page.
  • Insane Troll Logic: Irving's general approach. He will twist anything he can to line up with his biases, no matter how flimsy the reasoning. Notable examples include claiming a gas chamber was actually an air-raid shelter despite being located over two miles from the soldiers and later trying to say any gas used was simply a delousing procedure to kill lice. Even after losing the case, he tries to insist the testimony was actually good for him.
  • Ironic Name: Joe Crooks is the name of Emory University's chief legal counsel who immediately offers to help fund Lipstadt soon after Irving begins the lawsuit.
  • "Just Joking" Justification: Irving uses this to deny his racism when the defense attorneys show video clips of him making racist jokes at past lectures.
  • Malicious Misnaming: More like Malicious Mispronouncing. Irving, the antagonist, is almost the only person who pronounces "Lipstadt" the German way (Lip-shtat), while nearly everyone elsenote  pronounces it the American way (how Deborah says her own name) with a "s" sound.
  • Meaningful Name: Deborah says that her mother named her after the Biblical judge, charging her with the obligation to stand up and fight when her people are attacked.
  • Moving the Goalposts: Irving continuously redefines things to suit himself, both in his history books and in court. Afterwards he tries to argue to a disbelieving Jeremy Paxman that the verdict was actually quite favourable to him.
  • Noodle Incident: Rampton tells Deborah that in his last case he was representing McDonald's, and that's all he or the film says on the matter. This was, in fact, the epic McLibel case — specifically, the appeal against the judgement in the original, nearly ten year long trial — which is the subject of its own movie.
  • Not So Stoic: Julius is generally very composed, but he is visibly emotional at the thought of letting Irving undermine and humiliate survivors on the stand.
  • Oh, Crap!:
    • Deborah has this when the Judge questions whether Irving honestly believing what he says because he is a racist and anti-Semite can refute their claim that he's deliberately lying. To make it worse, this question is pretty much the last thing the Judge says before retiring to consider his verdict, leaving her to stew for weeks.
    • There's no relief for her when her printed copy of the verdict is delivered, either; per standard procedure, she only gets the 333 pages detailing the Judge's legal reasoning, not the final page with his actual finding in the case. Her lawyers get the finding, but are not permitted to tell her what it is, which further exasperates her but, again, is standard procedure.
  • One Dose Fits All: Deborah points out that Fred Leuchter, the supposed "execution expert" who claimed to debunk Auschwitz as being an extermination camp because more gas was used to delouse lice than kill prisoners, assumed this when comparing them. In reality, it takes twenty times more gas to kill lice than humans.
  • One-Word Title: The film's title is a lot more concise than the book's, which was History On Trial: My Day in Court With a Holocaust Denier (which has its own website).
  • O.O.C. Is Serious Business: Julius is normally a very reserved, self-confident man, who exerts control over any situation, including taking the defence in any direction he wants and calmly, even smugly shooting down some of Lipstadt's desired ideas or strategies. However, he gets visibly agitated and emotional whenever the idea of letting Irving question Holocaust survivors comes up. The second time Deborah brings it up, Julius loses it and shows her a video of Irving gloating about asking a survivor how much money she has made from the Holocaust.
    Julius: Oh you want that, do you?! You think that's helpful?!
  • Politically Incorrect Villain: David Irving is not just a Holocaust denier, he is an all-purpose hater: Jews, Black people, women, you name it.
  • Pull the Thread: Used to GREAT effect against Irving during the examination about Auschwitz. So the gas chamber was built to delouse corpses? And it has a gas-proof door with a peep hole with double 8mm glass and a metal grill on the inside because it doubles as an air raid shelter for the guards who were garrisoned 2½ miles away? And it was built with those features at a time they weren't facing the threat of air raids from the British? Also, why delouse a corpse you're about to incinerate? Irving is forced to admit that he's not a Holocaust historian, he's a Hitler historian.
    Rampton: Then why don't you keep your mouth shut about the Holocaust?
  • Reasonable Authority Figure: the good Judge is even-handed, pleasant and attentive through the case. While Deborah is horrified at the implication he may decide the case in favor of Irving after his tough questioning of Rampton on Irving actually believing what he says (as opposed to being a liar), the Judge is well aware Irving is a liar and his question is just to ensure Rampton has his bases covered. He delivers a ''blistering' judgment against Irving and as detailed below, it's hinted he's well on the side of the defendants.
  • Revenge Myopia: Some in the media framed the case as Irving defending his free speech against Deborah Lipstadtnote , even though it was him who sued her because he objected to a comment she made about him and his work in her 1993 book Denying the Holocaust, and he did so in, of all places, England, which has notoriously very pro-plaintiff libel laws which have more often than not themselves been used as tools against free speech. (It is worth noting that, had he filed the suit just one year earliernote , he would have to have done so in the United Statesnote , where laws are as pro-defendant as England's are pro-plaintiffnote .)
  • Rewatch Bonus: Though muted, there are some hints that the Judge has long decided the case in favour of Lipstadt and Penguin. Before the Judge starts the trial he is reading a copy of Irving's book Hitler's War and closes it with a disgusted sigh. When Irving says pompously and proudly that the gas chambers at Auschwitz were 'for fumigating cadavers' the Judge barely holds back a sneer of contempt and uncharacteristically asks a question that is later more directly and forcefully asked by Rampton.
    Judge Gray: I'm sorry, this seems a crude question, but what is the point in gassing a corpse?
  • Riches to Rags: The discrediting of David Irving also brought him real-life financial ruin. He was saddled with a £2 million (US$3.2 million) bill in Penguin's legal feesnote  and what had been Penguin's attorneys had him declared bankrupt over this in 2002 - he actually lost his then home for more than 30 years, a flat in Mayfair, central London, which was his main asset.
  • Rule of Symbolism: The last two shots of the movie. Deborah looks up and smiles at the statue of Boadicea and her daughters, another redhead at the center of an uprising in Britain after a horrific violation. Zooms out to the ground at Auschwitz, a shrine to the murdered and the survivors - they have the metaphorical last word of the movie.
  • Self-Made Man: Irving is described as one, having gone from being a factory worker to a respected historian entirely on his own. Anthony Julius describes him as wanting it both ways, to be seen as both the outsider and maverick who shakes things up but also given respect by his more educated peers.
  • Shown Their Work: Other than a few very minor changes, the film is overall a very accurate portrayal of the case with much of the dialogue in the court scenes being taken word for word from the actual trial transcripts.
  • Some of My Best Friends Are X: Irving uses a more-clueless-than-usual version of this when he argues that he can't be racist because he employs Black and Asian servants, while adding that "some of them have very beautiful breasts." The dumbfounded reporter has to ask him to repeat that.
  • The Spock: Deborah's legal team maintain a degree of emotional distance that Deborah finds frustrating, especially during their visit to Auschwitz, mistaking it for heartlessness or disrespect for the dead. Later she accepts that they are simply focusing their passion into doing the most professional job they can.
  • Stiff Upper Lip: It takes a while for Deborah to see that British reserve is not heartlessness or apathy.
  • Teeth-Clenched Teamwork: The case is sometimes like this for Deborah, who is frustrated with many of the decisions that her lawyers make about how to win, which leads to some noisy arguments.
  • Title Drop: The word "denial" is repeatedly used in the context of Holocaust-denial, but it is also used when Rampton finally convinces Deborah to be The Unfought, and calls it "an act of self-denial".
  • Tranquil Fury: Look at Julius as he says what will happen if Irving is able to cross examine a Holocaust survivor. He can scarcely leash his contempt and hate for the man when he says he will not allow Irving to do it. He's less tranquil when he plays a video of Irving describing exactly how he'd mock a survivor and shouts at Deborah if she wants more of that.
  • Translation with an Agenda:
    • A key point in the defense's case is that Irving, a fluent German speaker, incorrectly translates key documents from German to English to bolster his case (namely, interpreting an order by Heinrich Himmler not to liquidate a specific transport of Jews as an order not to liquidate any Jews, period). Richard J. Evans,note  an historian who (unlike Lipstadt or her attorneys) also speaks fluent German, calls him out on this during the trial.
    • Irving deliberately distorts the meaning of the word Vergasungskeller, claiming it means "fumigation cellar." In German, the word Vergasung exclusively refers to killing someone by gas, and would certainly never be used to indicate "fumigation" or "disinfection."
  • Twofer Token Minority: Deborah thinks this is partly why Irving goes after her, as she's a Jewish woman, so he "gets more bang for his buck".
  • The Unfought:
    • Deborah never actually goes head-to-head with Irving in a cross-examination, and indeed the only time she speaks directly to him is when he gatecrashes her lecture and heckles her. This is because Deborah is convinced (albeit very reluctantly) not to take to the stand herself, or allow survivors to do so, on the grounds that it would look like there was actually a legitimate debate to be had on the subject. Deborah is well aware that this will make it easy for Irving to say she's a coward (and indeed he does after he loses), but she trusts that her legal team know what they're doing.
      Rampton: A strange thing, conscience is. Trouble is, what feels best isn't necessarily what works best. I mean, by all means, stand up, look the Devil in the eye, tell him what you feel. Why not? It's very satisfying, see what happens. And risk losing. Not just for yourself, for the others. For everyone. Forever.
      Deborah: Or?
      Rampton: "Or?" You know "or." Stay seated. Button your lip. Win. An act of self-denial.
    • Averted, however, with the libel case itself. Deborah Lipstadt, contrary to what some of her friends suggested her, chose to fight it all the way through, even though she could have just settled it (and open herself to suggestions that the facts of the Holocaust were negotiable, as well as actually having to apologize to David Irving and withdraw her book from the market) or simply not dispute the case (and being stuck with a default verdict, where she basically admitted Irving was right, as well as, again, having to withdraw her book from the market). In any case, the wider public would not have had access to the veritable treasure trove of facts that so thoroughly discredited Irving as an historian.
  • Villain with Good Publicity: Irving, to a surprising degree, was considered a reputable historian by many people (including fellow historians) prior to the trial, even if some expressed concern about his sympathies with Hitler and fascism with Anthony saying they "see him as a serious historian who just happens to see things from Hitler's point of view". Afterwards, there was no longer any doubt about his true beliefs and dishonest portrait of the Holocaust.
    • And this was not without reason: he was noted for his discoveries of previously unknown documents (which he got to know due to his deep links to neo-Nazi circles even at his highest point in popularity), having discovered that the Allies broke the Enigma code 10 years before that became public knowledge, his books on the V-2 missiles and nuclear weapons programs (which are the only ones still highly regarded after the trial), and being the first to question the Erwin Rommel myth.
  • Worthy Opponent: Irving tried to invoke this post-trial by approaching Rampton and congratulating him on the verdict. Rampton and the rest of the team just shuffle away in disgust.
  • Would Be Rude to Say "Genocide": Irving's argument in a nutshell. He strongly objects to labels like "denier," preferring softer and more legitimate-sounding terms like "revisionist."
  • You Have GOT to Be Kidding Me!: Deborah's face has this written all over it when Irving's opening statement describes the label of "denier" as being "a verbal yellow star".