Hearing transcripts

4 March 2008 - Morning session

1 Tuesday, 4th March 2008
2 (9.30 am)
3 LORD JUSTICE SCOTT BAKER: Can you hear us, Mr Lyons?
4 THE WITNESS: Yes, sir.
5 LORD JUSTICE SCOTT BAKER: We are just taking a moment or
6 two while the jury come in and then we will be ready to
7 start.
8 Is that Mr Carlisle QC beside you?
9 MR CARLISLE: It is.
10 (Jury present)
11 MR HILLIARD: I think we have Mr Lyons on the right and his
12 lawyer on the left, if I have that the right way round.
13 If Mr Lyons could take the oath, please, or
14 affirmation, whichever.
15 MR DARRYN PAUL LYONS (sworn)
16 Questions from MR HILLIARD
17 MR HILLIARD: Good morning, Mr Lyons. My name is
18 Nicholas Hilliard. I am going to ask you some questions
19 first of all on behalf of the Coroner and then you may
20 be asked questions by other people, all right?
21 A. Fine, sir.
22 Q. Mr Lyons, are you still the chairman of Big Pictures?
23 A. I am, sir.
24 Q. Big Pictures, I think, is an international photographic
25 agency --

1
1 A. That is right, sir, it is.
2 Q. -- based in Clerkenwell Road in London.
3 A. That is right, sir.
4 Q. To try to summarise it, does Big Pictures specialise in
5 obtaining and selling photographs of celebrities?
6 A. Indeed, that is right, sir.
7 Q. I think you were also chairman in 1997, the period that
8 we are particularly interested in.
9 A. Yes.
10 Q. Can you tell us, by 1997, for how long had you been
11 chairman?
12 A. The business had started in 1992 -- four or five years,
13 sir.
14 Q. On the night of the crash in the Alma Tunnel, I think
15 you received a set of pictures of it; is that right?
16 A. That is correct, sir.
17 Q. Subsequent to that, is it right that the police were
18 called to the offices of Big Pictures because of threats
19 that the company had received?
20 A. Yes, sir.
21 Q. We are going to go into all of that in a moment or two,
22 but just before that, a bit of history.
23 I think you have spoken, is this right, in the past,
24 to officers of the Metropolitan Police about these
25 events?

2
1 A. Yes.
2 Q. Have you also spoken to representatives of
3 Mr Mohamed Al Fayed?
4 A. I have indeed, sir.
5 Q. I do not know, have you spoken on occasions to the
6 media? Have you appeared on television programmes, that
7 kind of thing?
8 A. Yes. It is part of my job and we have many television
9 interests as a production company as well, sir.
10 Q. Is this right, I think you have a book coming out
11 tomorrow about your career in photography, which
12 includes a chapter about the Princess of Wales?
13 A. Yes, it is an autobiography, sir, only coming out in
14 Australia.
15 MR CARLISLE: Forgive me for interrupting. In fact it came
16 out yesterday in Australia.
17 MR HILLIARD: Thank you.
18 The title, I think, is "Mr Paparazzi, Inside
19 the World of a Celebrity Photographer".
20 A. That is right, sir. That is true.
21 Q. If we go back, please, Mr Lyons, to 1997, did you know
22 somebody called Laurent Sola?
23 A. Indeed, I did, sir.
24 Q. Can you just help us, who was he? What did he do?
25 A. As Big Pictures is a photographic press agency, we have

3
1 other agents in several different parts of the world.
2 Laurent ran a press agency called "LS Presse Diffusion"
3 in Paris where he had photographers -- several
4 photographers supplying him, and we were his UK agent.
5 Also we sold his pictures in the USA and in Australia.
6 Q. Did you get a call from him in the night of 31st August
7 into the early hours of 1st September 1997?
8 A. Indeed I did, sir.
9 Q. Mr Lyons, where were you when you got the call?
10 A. I was at home at my address in Kensington.
11 Q. About what sort of time did you get the call?
12 A. On reflection, sir, I think it was around five past
13 midnight.
14 Q. What did he say?
15 A. He said that the Princess of Wales had been involved in
16 a car accident in Paris and that he had photographers at
17 the scene and that pictures would be on the way at some
18 stage in the future. He did not have the images then.
19 Q. Did he say who the photographers were that he had at
20 the scene?
21 A. Not at that stage, sir. I had no idea who the
22 photographers were at that stage.
23 Q. At this early stage, Mr Lyons, was anything said about
24 payment or the amount of money that would be involved or
25 was this just too early?

4
1 A. No, sir. It was -- the situation is that we would have
2 a standard agreement with all agents, probably 40 or
3 50 agents, that had many photographers from all over
4 the world. It is a standard arrangement that we have
5 a percentage basis, that we sell these images and that
6 we take a percentage as in a normal agency fee, as in
7 managing a celebrity or any other situation such as
8 this.
9 Q. Mr Sola would have been very familiar with that?
10 A. Yes, Mr Sola and myself had done business for months, if
11 not possibly 12 months prior to this happening.
12 Q. Having got the call, did you leave home and go to your
13 office?
14 A. I did, sir, immediately, yes.
15 Q. At your office, in due course, did you receive pictures
16 by means of something called an "ISDN line"?
17 A. That is correct, sir.
18 Q. When did you get the pictures? When did they come over
19 the line?
20 A. From the phone call, I would say within the hour, sir.
21 I cannot be specific about that particular time, but
22 I would say within the hour of the phone call.
23 Q. How many of them were there?
24 A. Exactly, I cannot remember, but I would say in
25 the vicinity of about ten images.

5
1 Q. Did you know by this time who had taken them?
2 A. No, I did not know at this time who had taken
3 the images.
4 Q. What was the quality of the pictures like?
5 A. A couple of pictures were quite out of focus and
6 a couple were sharp. I mean, the scene, because in
7 the actual wide scene, there was 'camera movement', and
8 the others were as a news picture would be of a car
9 accident, sir.
10 Q. Mr Lyons, if I can just jump ahead, in due course
11 I think you handed the photographs, or your agency did,
12 to the police in this country.
13 A. Yes, I did.
14 Q. Mr Lyons, I just want to explain, for the benefit of
15 everybody here and in particular the jury, that we have
16 those photographs, sir. They are ones taken by
17 Mr Odekerken and Mr Chassery. I am not going to
18 identify which, but they are nothing that we have not
19 seen already.
20 LORD JUSTICE SCOTT BAKER: Thank you.
21 MR HILLIARD: So, Mr Lyons, what did you do then, once you
22 had got possession of the photographs?
23 A. I called a member of my staff in at the time to meet me
24 at the office that we were receiving images.
25 The pictures were then put into a low resolution form so

6
1 that they would not be able to be published, ie, to
2 explain that to the jury and the members in the court,
3 they were sent over as unusable quality. The reason
4 being for this is that it was a momentous occasion and
5 the fact of the matter is I did not want anyone to use
6 them in an illegal way under these circumstances. They
7 were offered to -- they were sent out as a contact
8 sheet, low resolution form, for editors to view.
9 At the time, sir, the news was reporting and we felt
10 at the time that the Princess of Wales was concussed and
11 possibly had a broken arm. We were receiving many calls
12 to the office on that evening, after it had come out on
13 the wire services that there had been an accident.
14 Q. So by sending them out to editors in a low resolution
15 form, it means they can get an idea of what it is that
16 you have, but they are not in a useable form?
17 A. Absolutely, sir, that is correct.
18 Q. Who did you offer them to? Can you remember now?
19 A. Yes. News of the World at the time, sir.
20 Q. Do you remember what sort of sum of money you were
21 discussing with them?
22 A. Yes, it was in the vicinity of quarter of a million
23 pounds.
24 Q. Were you also in touch with the National Enquirer
25 magazine in the United States, do you remember?

7
1 A. Yes, someone had made contact there and wanted their US
2 rights. Obviously it was a very different timeslot at
3 that stage. It was not a call from an editor. I cannot
4 actually remember who was it was from, but yes.
5 Q. The figure that was discussed there with the
6 National Enquirer was quarter of a million dollars, is
7 that right?
8 A. That is correct, sir.
9 Q. Once you had done that, with the low resolution copies,
10 spoken to those editors, did you then telephone Mr Sola
11 again?
12 A. Yes, we were on the phone discussing the deal. This
13 would have been normal practice as the agent acting on
14 behalf of either the photographers or himself, in a huge
15 news story situation like this, would have wanted to
16 know how the negotiations were going.
17 Q. Whilst you were talking to him, did you in fact learn
18 that the Princess of Wales had died?
19 A. No, I do not think so, sir. I think the situation was
20 that I made a phone call to Mr Sola as soon as that was
21 announced, I think at the time on Sky News, which was
22 a complete shock at the time. Then obviously the News
23 of the World telephoned me, the editor, and said that
24 she had now died and that the interest in the pictures
25 and a deal that was going to go -- because they were

8
1 negotiating for both the daily newspaper and possibly
2 use in the Sunday newspaper. It was a situation where
3 I phoned Mr Sola and said that, you know, obviously
4 these pictures could not be sold at this time.
5 Also, daily newspapers had received low resolution
6 forms, and I had spoken to the editor in the early hours
7 of the morning, Mr Piers Morgan, about the situation on
8 his way into the offices as a lot of editors were going
9 in at that time, and I had spoke to Mr Sola and we were
10 both of the agreement that the pictures should not be
11 dealt with any further.
12 Q. Did you make it plain to the newspapers who had them,
13 who had received them from you, that the pictures were
14 not to be used?
15 A. Absolutely. A ring-around was done immediately on both
16 the Sunday and the daily newspapers. I think the only
17 people that had high resolution at that possible time
18 would have been News of the World, but I cannot
19 remember. Everyone had low resolution forms and
20 unusable.
21 Q. Thank you. Now just before we move away from this
22 topic, Mr Lyons, one or two more questions about timing.
23 Do you remember that in due course -- and we will come
24 on to this -- when you saw a representative of
25 Mr Al Fayed, you gave some information about the times

9
1 of these calls?
2 A. I do not recall, sir, but I know I spoke to one of
3 Mr Fayed's people, yes.
4 Q. It is only this: in that document, you put the time of
5 the first call from Mr Sola at about half past midnight
6 and you refer to receiving the photographs at your
7 office at about 3 o'clock in the morning.
8 A. Okay, sir, if I said that, possibly. Those statements
9 were taken a long, long time ago. I think the first
10 call was just after midnight, as I remember the
11 specifics of it. If I said that at the time -- I mean
12 my recollection -- maybe it was a couple of hours, but
13 I would have thought an hour to an hour and a half after
14 the original call, but it is a long time ago, sir.
15 Q. It is very difficult so many years after, no doubt.
16 A. Indeed, sir.
17 Q. Well, now, Mr Lyons, notwithstanding what you told us
18 you had said to the newspapers concerned, in fact, did
19 the story circulate that your company was still offering
20 pictures of the crash for sale?
21 A. That is very true, sir, yes, it was.
22 Q. Is it right that film crews arrived and camped out at
23 your offices in Clerkenwell Road?
24 A. Absolutely, sir, they did.
25 Q. I think there was a piece on the 9 o'clock news the next

10
1 evening to that effect; is that right?
2 A. That is correct, which I was very upset about, yes.
3 Q. Now, was your general manager at the time somebody
4 called Greg Allen?
5 A. That is correct, sir.
6 Q. I want to see if you can help with this. We are going
7 to hear from a witness after you, a Police
8 Constable Kennils, who I anticipate will tell us that at
9 8 o'clock in the morning, on Tuesday 2nd September of
10 1997, that he went to your offices, he saw Greg Allen,
11 who told him that, at 9.40 the evening before, he had
12 taken a phone call to the agency saying, "You killed
13 Diana, we are going to kill you, we are going to blow up
14 your building".
15 A. That is correct, sir.
16 Q. Now were you aware of that call the evening before,
17 the evening that it happened?
18 A. I was, sir. There were several calls at the time after
19 the news that appeared, and, yes, I do recall that
20 particular conversation and I would have advised
21 Mr Allen at the time to call the police immediately.
22 Q. Do you remember that day, the 2nd, when Police
23 Constable Kennils came, that he asked for a copy of the
24 photographs and the computer disc that contained them?
25 I think you came to learn of that request.

11
1 A. I do recall that, sir, yes indeed.
2 Q. Those pictures were provided to the police, is that
3 right?
4 A. Absolutely correct, sir.
5 Q. Can you help us, did you in fact keep any copy or did
6 you provide everything you had to the police?
7 A. Being a picture library, we keep copies of every
8 picture, the 8.5 million pictures in our archive. So
9 all the copies -- all the digital images that
10 we received were given to the police, but we keep a copy
11 of every image that comes into the agency, sir.
12 Q. Right. The next incident I want to ask you about,
13 please, Mr Lyons, is the early hours of 5th
14 September 1997. So we are moving on three days or so
15 from the Tuesday, all right?
16 A. Yes, sir, yes.
17 Q. We have -- and again perhaps we will hear about this
18 later -- a police computer print-out that deals with
19 a call, I think at 00.52, so 8 minutes to 1 in the
20 morning of 5th September 1997 --
21 A. That is correct, sir.
22 Q. -- when the police were called and came to the premises
23 of Big Pictures.
24 A. Yes, sir.
25 Q. Now, I think you had gone out, is this right, to dinner

12
1 with staff that evening?
2 A. That is right, sir.
3 Q. Can you help us, please, with what happened when you
4 came back to the offices?
5 A. Yes, sir. As we came back, I noticed, walking back
6 towards the office, that the whole of Clerkenwell Road
7 was lit up, except for my office, which I found
8 obviously strange, and there was not a light on in
9 the building. As I approached over to the building,
10 I unlocked the door, the alarm was not on, there was no
11 power to the building. As I entered, I saw a faint
12 light or something behind it with a -- to describe it to
13 you, sir, there was a wall between the front and back
14 office computer room that was all bricked glass, so
15 it was diffused. I walked in and saw this, found it odd
16 and -- it seemed like some kind of a flashlight or --
17 there was certainly a fuzzy light and then I heard
18 a ticking noise.
19 Now, obviously, as you can imagine at the time, with
20 what was going on around us, the first thing that
21 registered in my brain was a degree of panic as I felt
22 that this could be -- came from the earlier threat that
23 had been made to our offices and other threats
24 throughout this particular time. I immediately ran from
25 the office and dialled the emergency services and

13
1 several police cars arrived within four to five minutes,
2 I think. I cannot be specific on the time, but pretty
3 much immediately.
4 The police offers told me, when they arrived, not to
5 panic, entered the building, and they could find at the
6 time, sir, no visible force of entry into my premises.
7 From what I have said before, nothing seemed to have
8 been stolen, so ...
9 Q. Right, but if we take it bit by bit, they found nobody
10 on the premises, is that right?
11 A. That is correct, sir.
12 Q. Although you heard the ticking sound and no doubt
13 because of what somebody had said in the phone call
14 earlier in the week, they were going to blow
15 the building up, you were concerned about that, but no
16 ticking bomb was found, is this right, in the premises?
17 A. No, it was not, sir, indeed, but you can understand
18 the worry at the time with that kind of sound.
19 Q. I quite understand because, as I say, of the call that
20 you had had earlier in the week.
21 A. Indeed.
22 Q. In the police computer print-out for that night, at
23 18 minutes past 1 in the morning, there is an entry that
24 says that the ticking sound was clocks ticking in
25 the newsroom.

14
1 A. If that is what the police statement says, that could
2 well be the case, sir. There certainly were several
3 clocks up on the newsroom wall, behind quite a solid
4 glass panel, from all our country destinations and
5 offices round the world, whether it be Sydney,
6 Los Angeles, New York, London and Tokyo.
7 Q. The light that you had seen, the kind of flashlight, did
8 that transpire to have come from a computer screen that
9 was still on?
10 A. The police -- that is exactly what the policeman said to
11 me. The strange thing was that the power was completely
12 cut out.
13 Q. Right. Just one other part of this topic.
14 A. Yes, sir.
15 Q. You have expressed, I think, in the past, the opinion
16 that the security services were in your offices that
17 night.
18 A. Sir, I think that comes from a situation where certainly
19 there had been -- on the street and talk between
20 the photographers at the time, there had been another
21 break-in to another French gentleman, I think it was
22 Lionel Cherruault's home or office --
23 Q. We heard all about that yesterday --
24 A. Okay.
25 Q. -- so we know what what you are talking about.

15
1 A. Okay. I think that -- the talk that came back to my
2 office at the time was that people had been saying that
3 the security services broke into his situation and stole
4 computers. I think the assessment at that stage, sir,
5 was made on why would two picture agencies have people
6 break in at the same time. So it was another situation
7 of -- I suppose one would say "assumption". I have no
8 evidence of who was in my office that particular night
9 at all. I got out of there as quickly as I could.
10 Q. I suppose we have to add if anyone was actually in your
11 office that night.
12 A. Point taken, sir, yes.
13 Q. In due course, did you make a statement -- I asked you
14 about this earlier -- to somebody who was acting on
15 behalf of Mohamed Al Fayed? Did you talk about the
16 events that you have been telling us about?
17 A. Yes, I did. I recall -- I think it was a Mr Macnamara
18 at the time.
19 Q. How did that contact come about? What was the first
20 contact?
21 A. It was a telephone conversation. He phoned me and was
22 extremely polite and asked me could he come -- I cannot
23 remember the time or date this took place or the time
24 after the incident, but he asked if he could come down
25 and meet me privately to discuss the situation.

16
1 Mr Fayed had felt that my thoughts on the subject of
2 what happened and those particular nights surrounding
3 that time would be helpful, and also to get some
4 photographs of the last days of his son that were taken
5 with the Princess of Wales in the South of France, which
6 I packaged up and sent over to his office as a gift.
7 Q. So, what, there had been some initial contact after
8 which you had sent some photographs?
9 A. That is correct, sir, and then a meeting was arranged.
10 Mr Macnamara came over and met me in a bar in
11 Clerkenwell, a bar called "1920". We sat down and had
12 a frank discussion. I think he asked me would I make
13 a statement and of course -- I said of course I would.
14 In these circumstances, I would be willing to help
15 Mr Fayed in every way I could.
16 Q. Were you paid any money for the photographs that you had
17 provided?
18 A. No, sir, I was not. I was offered, for my time and
19 expenses, an envelope, which I refused to take, but
20 thanked him anyway.
21 Q. Did you know what was in the envelope?
22 A. No. I assumed it was money because I was told at the
23 time, "Mr Fayed would like you to have this for your
24 time and expenses", sir.
25 Q. In any event, you had provided, is this right,

17
1 photographs of them on the holiday in the South of
2 France by this time? You had already provided those?
3 A. That is right, as a gift. Yes, sir, I sent them over
4 because they were wonderful pictures of the two of them
5 together and I felt that it was a nice thing to do in
6 the circumstances, and he was very -- I also received
7 a call back from Mr Macnamara after that, that Mr Fayed
8 was extremely appreciative of this.
9 Q. The last topic I want to ask you about is this, please,
10 Mr Lyons: I want to go back to the night of the crash
11 and to the Princess of Wales and Dodi Al Fayed leaving
12 the Ritz Hotel by the rear entrance.
13 A. Right, sir.
14 Q. Do you know whether, and if so how, any photographer
15 learned that they were leaving by the rear exit?
16 A. Sir, I do not know how, no, not to my knowledge.
17 Q. All right.
18 A. I cannot recall anyway. I know that there would be --
19 there are passages with regard to an interview with
20 photographers on that particular night. It may well be
21 documented there. But do I personally know? Not of my
22 recollection. I certainly did not discuss this on the
23 night with anyone, but I have since conducted interviews
24 with regard to my book, since, with photographers that
25 were at the scene.

18
1 Q. Well has any photographer told you how, if they did,
2 they learned that the exit was going to be at the rear
3 of the hotel?
4 A. I cannot recall exactly, sir, I am sorry.
5 Q. It is all right.
6 A. There could well have been a reference, but I cannot be
7 totally specific. There could have been a reference
8 that there was a tip-off given or I may have been told
9 that there was a tip-off given that they would be
10 leaving from the back door, but I think that most of the
11 photographers, with all of the people at the front, were
12 assuming that everyone was told that they were going to
13 leave by the front door. But I cannot be specific about
14 that, I am sorry, sir.
15 MR HILLIARD: Thank you very much, Mr Lyons.
16 LORD JUSTICE SCOTT BAKER: Mr Mansfield?
17 MR MANSFIELD: No questions, sir.
18 MR WEEKES: No, thank you, sir.
19 MR CROXFORD: Just a few, please, sir.
20 Questions from MR CROXFORD
21 MR CROXFORD: Mr Lyons, my name is Ian Croxford. I am
22 acting for the Ritz Hotel. Just a few questions please.
23 A. Hello, Mr Croxford. Certainly, sir.
24 Q. You told Mr Hilliard that you had been negotiating
25 a figure of £250,000 with, I think, the News of the

19
1 World. Is that right?
2 A. That is right, sir.
3 Q. That figure was for a single use of photographs which
4 you might have supplied, is that correct?
5 A. That is correct, sir.
6 Q. In addition, to get an idea of how valuable information
7 about the Princess was at the time, is it also right
8 that you were paid for tipping off three UK editors that
9 the Princess had been involved in a crash?
10 A. There was certainly -- another part of our business,
11 sir, is a news agency and, yes, we do receive money for
12 tip-offs, yes.
13 Q. I am not criticising you. You got £10,000 from each of
14 three newspapers just to tell them the news that
15 the Princess had been involved in a crash; correct?
16 A. Sir, I think certainly from one newspaper. Whether it
17 be three, I cannot recall exactly.
18 Q. Well, I have what I understand to be a copy of your
19 book. Does this ring a bell?
20 "I quickly rang around three of the editors I was
21 closest to, offering them the tip of the year for
22 a healthy fee of £10,000 each. They reacted to the news
23 with incredulity but of course started chasing it up."
24 A. Yes, that was the offer. Whether it was taken up or
25 not, sir, I cannot recall.

20
1 Q. Very well. Let me ask you about something different.
2 A. Yes.
3 Q. The set of photographs sent to you, you understand were
4 taken by a Mr Odekerken and Mr Chassery; is that
5 correct? You call them "David" and "Fabrice" in your
6 book.
7 A. That is correct, sir.
8 Q. For the purposes of writing your book, did you have
9 conversations with Mr Odekerken or Mr Chassery?
10 A. Yes, I did. I spoke to them in, I think, 2006 about
11 what occurred, yes.
12 Q. Did you speak once or more than once, sir?
13 A. Well, we were acting as an agent for their company in
14 Paris, subsequently, many years after this, a company
15 called KCS Presse, so it would have been normal practice
16 that we would have discussed business on a regular
17 basis, sir.
18 Q. So what you have written in your book would have been
19 the outcome of a composite account of several
20 conversations in 2006; is that right?
21 A. No, that would have been done specifically over one
22 conversation, sir.
23 Q. Very well. This is right, is it, that Mr Odekerken told
24 you how he had found himself in his car, travelling
25 behind the Mercedes in which the Princess was

21
1 travelling, and that the Princess's car slowed at a red
2 traffic light?
3 A. That is what he said, sir, yes.
4 Q. He also told you, did he, that that slowing allowed him
5 to take photographs or, as he called or you described
6 it, "bang off a couple of frames"?
7 A. I cannot recall that, sir. Can I make reference to
8 where that is written?
9 Q. Try page 258, Mr Lyons.
10 Sir, I do not propose to trouble the jury with these
11 very short references.
12 MR CARLISLE: It is the start of the second paragraph on
13 that page, I think.
14 MR CROXFORD: Thank you very much, Mr Carlisle. Mr Lyons,
15 you have written:
16 "In front of David, the Princess's car slowed at a
17 red light, allowing him to optimistically bang off a
18 couple of frames."
19 Take photographs, yes?
20 A. Yes, that is what he would have said.
21 Q. Very well. Did he also tell you that he and Mr Chassery
22 separated and he, Mr Odekerken, found himself in the
23 Alma Tunnel at or shortly after the time of the crash?
24 A. They were -- said to me that they were heading home that
25 night after that situation and had been alerted by an

22
1 alarm in the tunnel and, as it says, they walked -- or
2 one of them walked into the tunnel to find that
3 situation, sir, yes.
4 Q. I just want to follow that if I may, for a moment.
5 It is page 259, if it helps you, Mr Lyons --
6 A. Thank you.
7 Q. -- but was the account of events given to you by
8 Mr Odekerken and Chassery that Odekerken telephoned
9 Chassery to give him the news of the crash and that
10 Chassery had to travel to the scene?
11 A. What is written there is what he told me, sir, yes.
12 Q. When you say "his", is that Odekerken or Chassery or
13 both?
14 A. I know them as Fabrice and David, sir. Can you --
15 Q. Let's deal with it that way. Was it Fabrice or David or
16 both who told you?
17 A. They were both in the room when we were discussing it,
18 sir.
19 Q. So that was the 2006 account that they gave you, is that
20 right?
21 A. Yes. Yes, sir.
22 Q. Lastly, I would like to ask you about Jason Fraser.
23 Page 263 for your help and, sir, if you are following
24 it.
25 A. Yes, sir.

23
1 Q. You have written:
2 "David and Fabrice maintain that Jason [I assume
3 that is Jason Fraser] told his partners in France, an
4 excellent outfit called Eliot Press, not to turn up and
5 follow Diana that night."
6 Is that correct?
7 A. Yes. That was hearsay at the time, though, sir. That
8 was a situation that they told me.
9 Q. Jason Fraser, of course, was a photographer,
10 a paparazzo.
11 A. That is right. He ran an agency in London too, sir,
12 yes.
13 Q. Did David or Fabrice identify how it was that they knew
14 what they were telling you about Fraser telling his
15 colleagues, his partners, not to turn up and follow
16 the Princess?
17 A. No. It was conjecture and rumour at the time.
18 Q. That was all, was it?
19 A. Yes, sir.
20 MR CROXFORD: Very well. Thank you very much.
21 A. Thank you.
22 LORD JUSTICE SCOTT BAKER: Mr Horwell?
23 Questions from MR HORWELL
24 MR HORWELL: Mr Lyons, my name is Richard Horwell, and
25 I represent the Commissioner of London Police. Good

24
1 morning.
2 A. Hello, sir, how are you? Good morning.
3 Q. I only have a very few questions to ask you.
4 A. Yes, sir.
5 Q. It seems from what you have said that, in the period
6 following this crash, there was a great deal of hysteria
7 and rumour as to what had happened.
8 A. That is correct, sir.
9 Q. You have been asked to look at several passages from
10 your book. Could I ask you please to return to
11 page 258?
12 A. Yes, sir.
13 Q. Do you have that?
14 A. Yes.
15 Q. Only a sentence has been read from this paragraph and
16 I am going to read it in its entirety, Mr Lyons, if
17 I may:
18 "In front of David, the Princess's car slowed at
19 a red light, allowing him to optimistically bang off
20 a couple of frames. The Mercedes then jumped a red
21 light at the corner of Rue de Rivoli and Rue Cambon and
22 began to accelerate wildly away. The speed the car was
23 doing through the crowded Place de la Concorde was
24 unbelievable and very dangerous. David began to slow
25 down because he did not want to have an accident. As

25
1 a result of his reduced speed, he lost them almost
2 immediately and did not know whether they had taken
3 the Champs-Elysees or the tunnel. The scooter paps who
4 were better able to weave through the traffic roared on
5 ahead of David."
6 Is that information that you got from David?
7 A. That is correct, sir.
8 Q. Can I ask you also please to turn to page 263?
9 A. Yes, sir.
10 Q. You have spoken of the hysteria and the rumour that
11 followed the crash. One of the rumours that we have
12 heard of is that a French photographer, James Andanson,
13 was in Paris that night. Now did you know of
14 James Andanson?
15 A. No, sir, I did not.
16 Q. Can you please confirm that David Ker and
17 Fabrice Chassery informed you that Andanson was not in
18 Paris that night?
19 A. That is correct, sir.
20 MR HORWELL: Mr Lyons, thank you.
21 LORD JUSTICE SCOTT BAKER: Well, there is a passage in
22 the book about that, isn't there? I do not know if you
23 want to put it specifically, at the bottom of 263.
24 MR HORWELL: Sir, I am more than happy to read it.
25 Mr Lyons, I am just going to read the passage

26
1 I asked you to have in front of you, at page 263:
2 "The photographers at the scene were all known to
3 Fabrice and David. The rumours about French
4 photographer, James Andanson, being present are simply
5 not true. He was not there. It had been said that
6 Andanson was driving a white Fiat Uno that collided with
7 the Mercedes, causing the accident. David and Fabrice
8 refute that. Since Andanson was not there, the
9 other ghoulish rumours ...", I am not going to read on,
10 "... also are not true."
11 Is that an accurate reading of your book?
12 A. It is, sir.
13 MR HORWELL: Thank you very much.
14 A. Thank you, sir.
15 LORD JUSTICE SCOTT BAKER: I had almost forgotten about you,
16 Mr Carlisle. I am sorry about that. Do you have any
17 questions you would like to ask the witness?
18 MR CARLISLE: I have no questions, thank you, sir.
19 LORD JUSTICE SCOTT BAKER: Mr Hilliard?
20 MR HILLIARD: Neither have I. Thank you very much indeed,
21 Mr Lyons.
22 LORD JUSTICE SCOTT BAKER: Thank you, Mr Lyons. We are very
23 grateful to you for making yourself available on the
24 other side of the world. It was important that
25 we should have evidence from you. Thank you very much.

27
1 That is all that is required.
2 A. Thank you very much, sir.
3 LORD JUSTICE SCOTT BAKER: It will now be necessary to break
4 off for a moment while we close down the video equipment
5 before calling Mr Kennils.
6 We will have our short break now, members of the
7 jury.
8 (10.18 am)
9 (A short break)
10 (10.35 am)
11 LORD JUSTICE SCOTT BAKER: I call next PC Kennils.
12 PC JOSEPH KENNILS (sworn)
13 Questions from MR HILLIARD
14 MR HILLIARD: Are you Joseph Kennils?
15 A. I am, sir, yes.
16 Q. Mr Kennils, I think you are a Metropolitan Police
17 officer; is that right?
18 A. I am, sir.
19 Q. You have been in court, I think, this morning and you
20 heard the evidence of Darryn Lyons.
21 A. Yes.
22 Q. I think this is right, that you were the police officer
23 who, on 2nd September 1997, at about 8 o'clock in
24 the morning, went to the Big Pictures offices in
25 Clerkenwell Road in London; is that right?

28
1 A. That is correct, sir, yes.
2 Q. Do you have a copy of a witness statement that you made
3 I think the same day, is that right?
4 A. That is correct, sir.
5 Q. In addition, there is something we have heard about as
6 well, a crime report, which deals with what the crime
7 was and what steps were taken to investigate it. Do you
8 have both there with you?
9 A. Yes.
10 Q. Good. When you got there, I think you met somebody
11 called Greg Allen, the general manager of the company.
12 Is that right?
13 A. That is correct, sir.
14 Q. Did he tell you what had happened?
15 A. Yes, he did.
16 Q. I think he explained to you what -- I am looking now at
17 the entry in the crime report. There is probably more
18 detail there. I think he explained to you what the
19 business of Big Pictures was. Is that right?
20 A. That is correct, sir, yes.
21 Q. He told you that the company had been sent pictures of
22 the crash in the Alma Tunnel via a computer and that
23 somehow the news agencies had found out about that. Is
24 that right?
25 A. That is correct, sir, yes.

29
1 Q. That the 9 o'clock news on the BBC had broadcast that
2 fact on 1st September 1997?
3 A. Yes, sir.
4 Q. It was shortly after that, I think at 9.40 or so in the
5 evening on the 1st, that a telephone call had been
6 received at the agency?
7 A. Yes, sir.
8 Q. The caller had said this:
9 "I thought your answerphone would be on. You killed
10 Diana. We are going to kill you. We are going to blow
11 up your building."
12 A. That is correct, sir.
13 Q. Did he also explain that freelancers and TV crews had
14 been at the premises of the agency that day --
15 A. Yes, sir.
16 Q. -- and that the staff were all very frightened and
17 anxious?
18 A. Yes.
19 Q. Did he say that he had received a second call after
20 that, which had just been screaming down the telephone,
21 but no threats made in that one?
22 A. That is correct, sir, yes.
23 Q. Did you say to him that the photographs could be of
24 evidential value, if they still existed, to any
25 investigation?

30
1 A. Yes, sir.
2 Q. Did he say to you that he would consult with his boss,
3 Mr Darryn Lyons, and get back to you?
4 A. Yes.
5 Q. Did you then go back to Islington Police Station, but
6 telephone him later, that is Mr Allen?
7 A. Yes.
8 Q. Did he tell you that he had spoken to Mr Lyons and, as
9 a result, you would be able to come and collect a copy
10 of the photographs and also the computer disc that
11 contained them?
12 A. Yes, sir.
13 Q. Did you go back at about midday on 2nd September and
14 collect those items?
15 A. I did, sir, yes.
16 Q. Looking at the crime report, page 6, I think, if yours
17 are paginated like mine, had you also spoken to
18 Detective Superintendent Rees, Jeffrey Rees, who we have
19 heard from?
20 A. Yes, sir.
21 Q. Did he say that if the photos existed, then something
22 called the "French desk" at ICPO were to be informed
23 immediately?
24 A. Yes.
25 Q. What is ICPO?

31
1 A. It is the International Criminal Police Organisation,
2 Interpol.
3 Q. Finally, I think it did not actually end there. On
4 8th September, did you have to go back to the premises
5 again?
6 A. Yes, sir, I did.
7 Q. Because this time they had a leaflet through
8 the letter-box, something of that sort?
9 A. There were leaflets through the letter-box, that is
10 right, but there were also leaflets posted to the shops
11 next door and along the street.
12 Q. What did they say?
13 A. The leaflets said, "Photos of Diana as she lay dying.
14 Your neighbour tried to sell them. Paparazzi scum.
15 Remember their names, Greg Allen, Big Pictures,
16 50 Clerkenwell Road".
17 Q. So you had to try and deal with that one as well on
18 the 8th?
19 A. Yes.
20 MR HILLIARD: Thank you very much, Mr Kennils.
21 MR MANSFIELD: I have no questions.
22 MR WEEKES: No, thank you, sir.
23 MR CROXFORD: No, thank you, sir.
24 MR HORWELL: No, thank you, sir.
25 LORD JUSTICE SCOTT BAKER: Thank you very much. I am sorry

32
1 you have been troubled, but we are grateful to you.
2 A. Thank you.
3 LORD JUSTICE SCOTT BAKER: Well now the next witness --
4 MR HILLIARD: What we were going to do --
5 MR HOUGH: Mr Meynell, sir.
6 LORD JUSTICE SCOTT BAKER: Yes. I call Mr Meynell then.
7 MR DAVID MEYNELL (sworn)
8 Questions from MR HOUGH
9 LORD JUSTICE SCOTT BAKER: Would you prefer to sit or stand?
10 A. I prefer to stand, sir, please.
11 MR HOUGH: Is your full name David Norman Meynell?
12 A. That is correct.
13 Q. As I have explained to you, I will be asking questions
14 first on behalf of the Coroner and then you will be
15 asked questions by other lawyers.
16 A. Sir.
17 Q. I think you were a Deputy Assistant Commissioner in
18 the Metropolitan Police.
19 A. That is correct.
20 Q. You made a statement for these inquests on 15th February
21 of this year.
22 A. That is correct.
23 Q. Do you have a copy of that with you?
24 A. I do.
25 Q. I think you retired at that rank, the rank of DAC, in

33
1 September 1995, after around 35 years of service.
2 A. In the regular force, sir, yes. I was a cadet prior to
3 that.
4 Q. Thank you. I think in the last few years of your
5 service, you were in charge of SO14, which is
6 the royalty and diplomatic protection department.
7 A. In total SO14 to 17, sir. That included the Palace of
8 Westminster.
9 Q. Thank you. Your statement says that you took up that
10 post in autumn of 1993.
11 A. That is incorrect. My wife's diary tells me that it was
12 in fact the previous year, in about February.
13 Q. February of 1992 then.
14 Just dealing with the hierarchy very briefly: you,
15 of course, would have reported to then Sir Paul Condon,
16 now Lord Condon, the Commissioner.
17 A. Yes, sir.
18 Q. Below you in the hierarchy was somebody else we have
19 heard from, Superintendent Trimming --
20 A. That is correct.
21 Q. -- who I think was the senior officer in charge of the
22 Princess of Wales' protection in detail.
23 A. That is correct.
24 Q. From time to time you had meetings directly with members
25 of the Royal Family and also with their private

34
1 secretaries?
2 A. That is correct.
3 Q. And you also, from time to time, obviously would have
4 had discussions with their protection officers directly
5 about their tasks?
6 A. Indeed.
7 Q. Can I take you back to December of 1993? The jury have
8 already heard about this, but I think a meeting was
9 arranged for you with the Princess of Wales on
10 14th December 1993. Is that right?
11 A. That is correct.
12 Q. The jury have some documents relating to these meetings
13 under, I think, tab 21 of the jury bundle. It is
14 a small clip of documents that was handed in last month.
15 Now you have said in your witness statement that
16 that you were aware that the Princess was likely to
17 request the removal of her personal protection officer
18 detail and that you were aware of that before
19 the meeting actually took place.
20 A. That is correct, sir.
21 Q. How did you become aware that the Princess had that
22 intention?
23 A. It became fairly general knowledge within my protection
24 officers, and also, within the Royal Household, I think
25 there was a fairly firm idea that it was a question of

35
1 time.
2 Q. Can you remember who you first heard it from?
3 A. I quite honestly cannot.
4 Q. Before the meeting actually took place, were you aware
5 that there was any particular catalyst or reason for her
6 request or her likely request?
7 A. No, sir.
8 Q. We know also that Lord Condon was aware of that meeting
9 because he mentioned it in a discussion with
10 Lord Fellowes on 10th December, which is minuted. Is it
11 right that you briefed Sir Paul Condon in advance of
12 that meeting with the Princess?
13 A. That is correct.
14 Q. Can we have a look at the note that you prepared of that
15 meeting? It is [INQ0058863].
16 For the jury, it is page 3 of the file of documents
17 under tab 21 of the bundle.
18 If you look at the screen and look at the first
19 paragraph, this is referring to a meeting on
20 13th December 1993, a note made by you on the following
21 day.
22 In the first paragraph it records, does it not, that
23 the Princess of Wales came straight to the point and
24 requested the removal of I think all of her protection
25 officers?

36
1 A. That is correct.
2 Q. Is it right that the note records that she stated that
3 the basis of her request was that, with effect from
4 the end of the month, she would have completed her
5 public engagements?
6 A. That is correct.
7 Q. It also records that she had discussed this issue with
8 a Queen. Do you recall that taking place?
9 A. I do.
10 Q. If we go down to the next paragraph, this is you
11 skipping ahead in time a little. It records, does it
12 not, that you telephoned Sir Robert Fellowes,
13 the Queen's Private Secretary, to check what
14 the Princess had said to you and just to explore
15 the views that he and the Queen had?
16 A. Indeed.
17 Q. Can we go down to the third paragraph? It records, does
18 it not, that the Princess was adamant as to the removal
19 of her protection, but that you attempted to dissuade
20 her?
21 A. I did.
22 Q. Can we move over to the next page, please, of
23 the document, again, to the top of page? It records
24 that you suggested that a number of the officers,
25 a specific proportion of them, be withdrawn on

37
1 a temporary basis.
2 A. I was trying to do a tapered arrangement, yes.
3 Q. Was that accepted by the Princess as a compromise and
4 temporary measure or not?
5 A. Eventually, yes.
6 Q. Now I do not think I need to take you to any further
7 parts of that minute, so it can be removed from
8 the screen.
9 Now is it right that after that meeting, you briefed
10 Superintendent Trimming on what had passed between you
11 and the Princess?
12 A. I did.
13 Q. Is it right that when you returned to your office
14 the next day, you prepared that note to help you brief
15 the Commissioner?
16 A. As an aide memoire, yes.
17 Q. Can we move forward to January of 1994? Can we have on
18 screen, please, [INQ0058857]?
19 Do you recognise this as an instruction, dated
20 6th January 1994, regarding the removal of the personal
21 protection detail for the Princess?
22 A. I do.
23 Q. That refers, does it not, to the Princess only being
24 accompanied by personal protection officers on official
25 occasions?

38
1 A. That is correct.
2 Q. So by this stage, January 1994, was she still being
3 accompanied by some officers under the provisional
4 arrangement, the temporary arrangement, or had they all
5 been removed by this stage?
6 A. That had then finished. She was getting protection on
7 official engagements or when other members of the
8 Royal Family were with her.
9 Q. Now we have already heard that in mid-January, so after
10 this instruction, there were conversations between
11 Lord Condon, Lord Fellowes and Sir Clive Whitmore,
12 the Permanent Under Secretary at the Home Office, about
13 the Princess's protection, and that they led to a letter
14 from Sir Clive setting out the need for a formal
15 documented agreement.
16 A. Indeed.
17 Q. Were you aware that those discussions were taking place?
18 A. I knew the discussions were taking place, yes.
19 Q. Can we have please on screen [INQ0058860]? This is
20 a letter from Sir Clive Whitmore to Lord Fellowes and
21 refers to a meeting arranged between Lord Fellowes,
22 Commander Jephson and yourself for early February to
23 discuss protection arrangements.
24 If we run down the screen, please, Mr Foley.
25 Do you see, about the middle of the page, you had

39
1 already arranged a meeting for 2nd February to discuss,
2 with David Meynell and Patrick Jephson,
3 Her Royal Highness's future security arrangements?
4 A. We set it a month in advance.
5 Q. I think we can have that off the screen.
6 So, by this stage, there was a scheduled meeting to
7 discuss the future security arrangements?
8 A. And how the interim had actually worked out.
9 Q. I think, in fact, you had a discussion with Commander
10 Jephson, the Princess's Private Secretary, before
11 the scheduled meeting because of a specific event that
12 occurred.
13 A. That is right.
14 Q. What was that event?
15 A. It was an incident in Australia where a gunman had got
16 up out of a crowd and gone towards a dais upon which
17 the Prince of Wales was seated and his protection
18 officer, Haywood-Trimming, had to intervene. This
19 caused obviously a great deal of press interest again in
20 the Princess and Kensington Palace in particular.
21 Q. Can we look on the screen at [INQ0058856]?
22 Is this a note by you documenting a conversation on
23 Wednesday 26th January 1994 with Patrick Jephson?
24 A. It is.
25 Q. As we see, this refers to the event in Australia

40
1 involving the Prince of Wales and you expressing concern
2 as to the consequences of that for the Princess.
3 A. Yes.
4 Q. Does it refer to a subsequent call, after your first
5 conversation with Commander Jephson, in which he said
6 that he had discussed the issue with the Princess and
7 that she was considering her position and grateful for
8 your concern?
9 A. Yes.
10 Q. Does it also record that the Private Secretary felt that
11 the Princess would avail herself of some protection in
12 relation to more public outings but, in the event, this
13 was not to be?
14 A. Yes.
15 Q. Now, in your witness statement, you locate that note as
16 having been written on 1st February 1994, actually after
17 the meeting you had with Lord Fellowes and Commander
18 Jephson.
19 A. Indeed.
20 Q. Why do you locate it at that time?
21 A. The meeting actually triggered the memory that I
22 actually had not made a note of what I considered at
23 that time to be something which should be recorded. It
24 had possible ramifications.
25 Q. So after you had the meeting in early February, you

41
1 thought, "Gosh, there are a couple of conversations
2 I had a few days ago that need to be minuted now"?
3 A. (Witness nods)
4 Q. Can we move to that meeting in early February? Can
5 we have on the screen [INQ0058850]? For the jury, this
6 is page 7 of tab 21.
7 Is this a minute made by you of the meeting on
8 1st February 1994, with Commander Jephson and
9 Lord Fellowes?
10 A. Again, it is an aide memoire rather than a minute as
11 such.
12 Q. So do you make the distinction because it is not
13 a verbatim note or --
14 A. That is right.
15 Q. But is it broadly accurate an account of the meeting?
16 A. I would hope so.
17 Q. We have gone through this with Lord Fellowes so I will
18 take it fairly shortly. In the note, it records that
19 Commander Jephson indicated that the Princess remained
20 determined that there should be no protection detail.
21 These are the words that appear, about ten lines down:
22 "The Princess was totally aware of the possible
23 outcome of the decision, but valued the freedom that
24 such a decision had brought about and could not be
25 persuaded to change her mind."

42
1 Having looked at that, can you tell this jury what
2 your recollection is of the Princess's motivation for
3 removing her protection detail and keeping it removed?
4 A. Yes. She actually volunteered the fact that she felt
5 that as she was largely retiring from public life, she
6 wanted a private life for herself, which she felt she
7 could not achieve if she had protection officers with
8 her all the time.
9 During one meeting, I actually attempted to get her
10 to hire private security officers, if she felt that that
11 would be a middle way. I have to say that had she have
12 done so, it would have posed considerable difficulties
13 for us in terms of the security, but, nevertheless, the
14 offer had to be made.
15 Q. We see further down in this note that Lord Fellowes
16 asked for an assurance that the Princess would formally
17 accept responsibility for any consequences of the
18 removal of her protection detail. Do you remember him
19 saying that?
20 A. I do.
21 Q. Then there is a discussion further down in the note of
22 arrangements for overseas trips. I do not need to take
23 you to that. Can we have a look at Lord Fellowes' note
24 of the meeting? It is [INQ0058855]. I do not know if
25 you have had the chance to see this before, Mr Meynell.

43
1 A. Yes, I have.
2 Q. Recently?
3 A. Yes, I have, recently yes.
4 Q. Again, this broadly accords with your minute of the
5 meeting, does it not?
6 A. It does.
7 Q. I think that draft was submitted to you for your
8 comment, under a short covering note.
9 A. That is correct.
10 Q. Now moving on to October of 1994, I think you had
11 a meeting with the Princess on 18th October 1994.
12 A. That is correct.
13 Q. Can we have a look at the note of that meeting, which is
14 [INQ0058847].
15 This is a note the jury have seen on number of
16 occasions, so they are very familiar with it, but
17 we need to take this stage by stage.
18 First of all it refers, in the first sentence, to
19 your "last meeting" with the Princess. Can you remember
20 approximately when your previous meeting had been?
21 A. No, I cannot, sir. I have tried to recall. There were
22 a number of meetings where the Princess raised issues
23 and was fairly adamant about several things. In one
24 particular one she was persuaded to have her premises
25 swept for bugs by a private company. When I got to find

44
1 out about it, bearing in mind that her residence was
2 part of a greater controlled secure area, I had to go
3 and see her to point out that whilst the people
4 concerned may be totally honest and professional,
5 nevertheless I could not be satisfied that something had
6 not been left behind by them, because, on that
7 particular occasion, not only did they try to sweep her
8 apartment, but they asked for access to our mainframe
9 computer, which obviously rang all sorts of alarm bells.
10 Q. A few questions running from that: first of all, can you
11 remember who told you that her premises had been swept?
12 A. One of the protection officers.
13 Q. Do you know from where that person received his
14 information?
15 A. I do not. Memory says it was Inspector Wharfe who told
16 me, but I cannot be certain about that. But certainly
17 there was no denying the fact that the premises were
18 searched by a company that had previously been used to
19 search another set of -- household.
20 LORD JUSTICE SCOTT BAKER: I do not think there is any
21 mystery about it. The Duchess of York had had them and
22 recommended them.
23 A. I did not know whether that was within the knowledge of
24 this --
25 MR HOUGH: Yes, we have heard evidence that the

45
1 Duchess of York made a recommendation to the Princess
2 of the particular company.
3 A. Fine.
4 Q. Did you find out the name of the company and check it
5 out in any way?
6 A. It was checked out, yes.
7 Q. Did you know, either from your conversation with
8 the Princess or from your checking, how many times the
9 company had performed sweeps?
10 A. No, it is not within my personal knowledge.
11 Q. Did you know whether any other companies had ever
12 performed sweeps --
13 A. I have no knowledge of that.
14 Q. Returning to the note and the reference to the last
15 meeting, did you have regular scheduled meetings or did
16 you simply meet when the Princess asked or when you
17 asked?
18 A. The latter, sir.
19 Q. You may not able to remember the timing of the last
20 meeting, but in the note you refer to a "confrontational
21 attitude" evident during the last meeting. Was
22 the Princess, as far as you can recall, confrontational
23 about anything in particular or just generally?
24 A. Having her premises swept, sir.
25 Q. Can you remember in what context or in what way the

46
1 Princess was confrontational about a step which, after
2 all, she had taken?
3 A. It causes a great deal of disruption to have the job
4 done thoroughly and correctly, and I expect she was not
5 looking forward to having her life disrupted twice in
6 a very short space of time.
7 Q. Had she told you on that previous occasion who she
8 thought might have been bugging her premises or why she
9 might have been concerned about bugging of her premises?
10 A. No.
11 Q. Did you ask?
12 A. No.
13 Q. Moving on to the first long paragraph, this refers to
14 some discussion of security since the removal of her
15 protection, and it records, does it not, that the
16 Princess was adhering to her view that there should be
17 no personal protection detail except for on high profile
18 official occasions?
19 A. She was quite gleeful about it, sir.
20 Q. Then, if we look over the page to the next page of the
21 note, we see, in the first paragraph, reference to
22 discussion of security for the two Princes, then
23 a paragraph relating to official visits and then
24 a paragraph relating to a conversation with
25 Robin Janvrin, again relating to the Princess's private

47
1 protection requirements. Do you recall those being, in
2 order, the sequence of topics discussed in the meeting?
3 A. Yes.
4 Q. Can we now move on to the key part, which begins,
5 "During the course of the conversation ..."? Now, are
6 we right, as with your previous note, that this is not
7 a verbatim note of the conversation?
8 A. No, this is again just to assist me to do further
9 briefings.
10 Q. If we see the text, it says that the Princess bluntly
11 asked you if her car had been bugged. Did this comment
12 come out of the blue or had it been sparked by
13 something?
14 A. No, this came out of the blue, sir.
15 Q. It records you saying that you would have her car
16 examined to establish the fact and she then said:
17 "Even when no one knows where I am going in my car,
18 there are people waiting for me at the other end."
19 That is in quotation marks.
20 A. Yes.
21 Q. Then she asked you if you had any knowledge of whether
22 her vehicle was bugged, and it records you saying that
23 you, the police, had not placed any kind of device on
24 her car.
25 A. That is correct.

48
1 Q. Why did you refer to what you, the police, may have
2 done? What caused you to talk about your activities?
3 A. Well, she asked me if we had bugged her vehicle.
4 Q. What your note records is her asking if you had any
5 knowledge of whether her vehicle was bugged, rather than
6 whether you had done it. Do you think she was hinting
7 at --
8 A. No, she asked me if I had bugged her vehicle.
9 Q. How did you respond to the questions about bugging?
10 A. I responded by saying to her -- and in this context,
11 I have to say that it was in two parts. I said that
12 certainly I personally had no knowledge and had not
13 bugged any vehicle and, to my knowledge, we, the police
14 service, had not taken any such action.
15 Q. Did you say anything else in response to the passage
16 which appears in quotation marks?
17 A. The ...?
18 Q. The reference to people waiting for her at the other
19 end.
20 A. Yes, indeed. In fact this caused the conversation to
21 change somewhat. I pointed out to her that a bug on
22 a vehicle would not be able to predict the destination
23 of the vehicle. There would have to be some direct
24 conversation indicating, within the vehicle, the
25 destination of it. The conversation changed then, sir.

49
1 She then came on to the next part.
2 Q. Does the next part concern telephone tapping?
3 A. It does indeed.
4 Q. We see here you recording the Princess saying that her
5 telephones were being tapped and she was certain that
6 the same applied to her vehicle and that she was sure
7 about the phones being tapped because she had "set traps
8 on four occasions" and had got the necessary evidence.
9 Did she provide you with that evidence?
10 A. No.
11 Q. Did you ask for it?
12 A. I did.
13 Q. You then say that you told her that you should be
14 allowed to deal with the matter and she responded that
15 she was using her knowledge to her advantage, and while
16 she felt a great loss in not being able to use her
17 telephones, she had use of other devices and the fact
18 that she was not using her telephones would squeeze
19 those people into different action.
20 A couple of questions arising out of that. First of
21 all, did she say what the other devices were?
22 A. No, sir.
23 Q. Did you ask?
24 A. I did.
25 Q. Secondly, "those people", did she explain who those

50
1 people were?
2 A. She would not explain, no.
3 Q. Next sentence:
4 "I explained to HRH that I had available a team of
5 experts who were responsible for ensuring the integrity
6 of Parliament. These were ordinary uniform officers and
7 I could get them to do the necessary sweep of both
8 vehicle and premises."
9 Who were those officers? What was their
10 designation?
11 A. They were a POLSA team attached to the Palace of
12 Westminster.
13 Q. The note records that after you had made that offer,
14 the Princess responded to say that while she had a lot
15 of enemies, she had a lot of friends, some in places of
16 knowledge.
17 A. Yes.
18 Q. Did she explain what she meant by "enemies" or could you
19 infer what she meant?
20 A. As opposed to friends.
21 Q. She goes on, in relation to her friends in places of
22 knowledge, to say that she could not name them because
23 they could lose their jobs, but she had been told that,
24 without any doubt, five people from an organisation had
25 been assigned full-time to oversee her activities,

51
1 including listening to her private phone conversation
2 and that, from the same source, she knew that two people
3 from the same organisation performed a similar function
4 in respect of Parliament.
5 There are a few questions arising out of that.
6 First of all did she identify the organisation?
7 A. No, sir.
8 Q. Secondly, did she say why she was identifying five
9 people for her and two people for Parliament?
10 A. No, sir, and she did not offer details of any other
11 situations of a similar nature either.
12 Q. So that was going to be my next question, did she
13 mention anybody else who might have been bugged in this
14 way, and you say "No".
15 A. No, just those two examples.
16 LORD JUSTICE SCOTT BAKER: So she was not really being very
17 helpful. If she had given you the information, you
18 could have checked it out and found out whether there
19 was anything in it, one way or the other.
20 A. Absolutely, sir.
21 MR HOUGH: The note records you saying that you told her
22 that it was a very serious matter and that it indicated
23 that your team working in Parliament were not doing
24 their job properly.
25 Is that a reference back to the two people

52
1 supposedly overseeing the workings of Parliament?
2 A. Indeed, sir. I was effectively trying to call her
3 bluff, as it were.
4 Q. Then it goes on to record that she replied by saying
5 it was not a question of them not doing their job
6 properly, but a question of them being against
7 the experts in this field.
8 Did she say anything to shed light on this phrase,
9 "the experts in this field", or what she meant by that?
10 A. She did not.
11 Q. Then it records you saying:
12 "I told her that I could get no comfort from
13 the situation and again stated that the matter should be
14 investigated. She stated that whilst she was certain of
15 her ground, she could not assist further without
16 jeopardising the identities of her friends and this she
17 was not prepared to do."
18 Then comes a sort of summary comment:
19 "My view is that today's meeting was basically to
20 ask me whether I had placed some form of device on her
21 vehicle."
22 A. That is correct, sir.
23 Q. Your conclusion, expressed in that final sentence, is
24 a summary of your feeling of the meeting, is it?
25 A. The meeting was very distinctly in three parts.

53
1 The first part was quite proper, discussing protection
2 arrangements, and I found nothing untoward with that.
3 The second part was to do with the bugging of her
4 vehicle. Once I had pointed out to her that possibly
5 a bug could not do what she was saying it was doing, she
6 then swapped tack and came on to the telephones.
7 I got the impression that that was an add-on because
8 she had not got very far with the vehicle situation.
9 That is what led me to the final sentence on my
10 aide memoire.
11 Q. If your conclusion about her motives is right, she was
12 getting to her point rather indirectly, wasn't she?
13 A. Yes, sir.
14 Q. Now after this meeting, I think you briefed the
15 Commissioner, who in turn briefed the Home Secretary.
16 A. That is correct.
17 Q. If we have up again the first page of the note, we will
18 see the Commissioner's handwriting on the bottom, "Home
19 Secretary briefed" and Lord Condon has identified that
20 as being his note.
21 Now, after this meeting, did you investigate further
22 or call in your team of officers to sweep the Princess's
23 apartment?
24 A. Not at that time, sir, no.
25 Q. Did you conduct any investigations regarding Parliament

54
1 and whether your team in Parliament was missing
2 something?
3 A. My team in Parliament continued doing what they were
4 doing, sir. I was quite satisfied that they were
5 performing the function that they had been asked to do.
6 Q. Did you give them any specific instructions arising out
7 of this meeting?
8 A. I did not, sir.
9 Q. I have to ask you this: the meeting note suggests that
10 you were rather concerned about her comments about
11 the bugging of her premises and Parliament. That is
12 certainly what it records you saying to her.
13 A. I was more concerned about the thought that I had had
14 a hand in anything of that nature because that would
15 have shown a loss of confidence in me. But certainly
16 I did not take lightly her allegation that there had
17 been bugging. But, in the absence of her being able to
18 provide any evidence and bearing in mind I had had her
19 premises swept -- I knew that Parliament was being swept
20 regularly -- it did not leave me a lot of leeway as far
21 as investigation was concerned.
22 Q. You say you had had her premises swept. Was that in
23 addition to the sweeping that she had had done?
24 A. Previously, yes.
25 Q. Can you remember approximately what time of the year

55
1 that was?
2 A. That would be after the carpet-fitting incident.
3 Q. So in 1994, but before this meeting?
4 A. No, no. It would be -- it goes back to 1993, surely.
5 Q. If we follow the note in its order, the sequence of the
6 meeting, it suggests that you were keen to carry out
7 a further sweep of her premises; that is to say after
8 the October meeting, even after the Princess had said
9 'No, I will not name my sources'. Is that right?
10 A. I was offering the sweep, sir, to see what her reaction
11 to it was going to be.
12 The allegation, when it came in the middle of the
13 meeting, I have to say it took me somewhat by surprise
14 and my instinctive reaction was, "Okay, let's see if
15 there is anything in it". So that is why the offer was
16 made there and then.
17 Q. At the end of the meeting, did the Princess tell you or
18 did you infer from her conversation that she wanted you
19 to take things any further, at that stage?
20 A. No, sir. She was quite adamant that she was not
21 prepared to do anything further.
22 Q. The note does not quite record that, does it, what you
23 have just said in your last answer? If we could have it
24 again on screen, it might help. It is the last page,
25 [INQ0058849]. It suggests that she was certain of her

56
1 ground, she could not assist further, but it does not
2 say quite what you have just said about not wanting
3 things taken any further.
4 A. Fine. I accept that that is so.
5 LORD JUSTICE SCOTT BAKER: You might have concluded the note
6 by saying, "We could only help the Princess if she was
7 prepared to help us, which she was not prepared to do".
8 A. That would have been useful, sir, yes.
9 LORD JUSTICE SCOTT BAKER: But that is really where you got
10 to?
11 A. It was indeed.
12 MR HOUGH: Did you have any further meetings with
13 the Princess at which any of these topics were further
14 discussed?
15 A. Not to my recollection, sir, no.
16 Q. Did you have any further meetings with her before you
17 ceased in your post in 1995?
18 A. Yes, I did, sir.
19 Q. How many? Do you have any idea?
20 A. I would think -- I may be mistaken -- two.
21 Q. Did she, on either occasion, ask you whether you had
22 performed a sweep either of her premises or of anywhere
23 else?
24 A. No.
25 Q. Did she ask you whether you had performed any

57
1 investigations?
2 A. No.
3 Q. Did she seem concerned to follow up any of the matters
4 which had been discussed in this meeting?
5 A. No, sir.
6 Q. A few general questions: did the Princess ever tell you
7 that the brakes on her car had been tampered with?
8 A. No.
9 Q. Did she ever tell you that someone had taken a pot-shot
10 at her in Hyde Park?
11 A. Most certainly not.
12 Q. Did she ever ask you to have security checks performed
13 on her car separate from questions of bugging?
14 A. No, sir.
15 MR HOUGH: Thank you very much. Those are my questions.
16 LORD JUSTICE SCOTT BAKER: Mr Mansfield?
17 Questions from MR MANSFIELD
18 MR MANSFIELD: Good morning, Mr Meynell. I am
19 Michael Mansfield. I represent Mohamed Al Fayed.
20 I have a number of questions for you.
21 I am sorry it is a little time ago, but in view of
22 what you have said today, I am afraid I do have some
23 detail to ask you.
24 When were you first asked to make a statement about
25 all of this?

58
1 A. About three weeks ago.
2 Q. Do you have it in front of you?
3 A. Yes.
4 Q. It is dated 15th February of this year, is that right?
5 A. That is right.
6 Q. That is the first statement that you have made about
7 these matters over these years, is it?
8 A. It is indeed.
9 Q. Now, since you made this statement -- I want to ask you
10 very carefully a number of questions -- do you
11 appreciate what you said today is not what you have put
12 in your statement? Do you appreciate what you have said
13 today in relation particularly -- and I will be
14 precise -- to the meeting on 18th October is not what
15 you have said today?
16 A. I am still waiting, sir.
17 Q. You don't appreciate that it is different?
18 A. Until you tell me --
19 Q. All right. I will come to it. So you don't appreciate
20 that it is different. I will come to how I say it is
21 different in a moment.
22 Between making this statement and coming here today,
23 first of all, have you been shown any documents?
24 A. Yes, sir.
25 Q. You have. What documents have you been shown?

59
1 A. There is a list of them here, sir.
2 Q. May I see the list please? Thank you. (Handed)
3 MR HOUGH: If it assists my learned friend, the witness has
4 also been shown Lord Condon's evidence.
5 MR MANSFIELD: Yes, I was coming to that.
6 A. There is one other thing as well which is not on the
7 list.
8 Q. This is a list of 44 items that you have been shown.
9 Now, were these shown to you after you made your
10 statement?
11 A. They were shown to me before I made my statement.
12 Q. These 44 items were shown to you before you made your
13 statement?
14 A. Yes.
15 Q. If you just bear with me, I am just looking at what you
16 have seen before, between making your statement and
17 coming here today. But this list relates to everything
18 that you had seen before, is that right?
19 A. That is correct.
20 Q. Right.
21 A. In addition to that, I was shown this morning
22 the cross-examination by yourself of Lord Condon --
23 Q. Yes.
24 A. -- and additionally I was shown a note which indicated
25 that inquiries into one of the matters which will be

60
1 raised had a negative result.
2 Q. What was that that you were shown?
3 A. This is in relation to the so-called Squidgy tape.
4 Q. Now, when you were shown my cross-examination of
5 Lord Condon, were you directed to a particular part of
6 it?
7 A. No, sir.
8 Q. But when you read it, did it cause you to change what
9 you were going to say?
10 A. No, sir.
11 Q. Are you sure?
12 A. Yes.
13 Q. I will come to the point and then I want to develop it.
14 The point is this: I suggest that what you were going to
15 say, following 18th October, was that there was a search
16 of the premises and the vehicle after 18th October, with
17 a report back to the Commissioner that it was negative.
18 You are shown my cross-examination of Lord Condon,
19 which is emphatically denying there was ever a search,
20 and you now, as it were, change the version of events.
21 Now, do you understand what I am putting to you?
22 A. Right.
23 Q. Do you understand what I am putting?
24 A. I think I do, yes.
25 Q. Is there any possibility that you have been influenced

61
1 by what you see Lord Condon is claiming happened at this
2 time in relation to Princess Diana?
3 A. I am sorry, I do not follow that.
4 Q. Yes. Don't you? You see, you were shown particularly
5 my cross-examination of Lord Condon in relation to
6 18th October, particularly. You read that, did you,
7 this morning?
8 A. I skip-read it, sir, yes.
9 Q. You skip-read it, and you gleaned, did you, from reading
10 it, that he was saying emphatically, in view of the
11 questions I was putting to him, that she had refused to
12 cooperate, that is why there was no search and that is
13 what was reported to the Home Secretary. You saw that
14 in his cross-examination by me, did you?
15 A. Yes.
16 Q. Right. Now, I do not know whether it is possible
17 because I do not have an inquiry number for this, but
18 I would like how you put it in your statement to be up
19 on screen, please. It is the second page of your
20 statement.
21 I want to deal with the whole passage of how you put
22 it on 15th February, this year.
23 It starts at the bottom of the page, so there is no
24 question but that we are coming to the -- you have done
25 it in chronological order in this statement, do you

62
1 follow, starting on 14th December 1993 and so on.
2 At the bottom of page 2, so the jury can follow it:
3 "In respect of the note 'Meeting with
4 HRH Princess of Wales 10.45 am on 18th October 1994'.
5 This was a meeting instigated by Diana, Princess of
6 Wales. During this meeting I attempted to persuade her
7 that if she did not wish to accept police protection,
8 that she should, as a second best, consider taking up
9 private security, but she just laughed this suggestion
10 of."
11 So now we are on page 3. Can this be on the screen
12 so that the jury can follow it because they don't have
13 copies of it. At the top -- it is just the rest of this
14 paragraph:
15 "During the meeting, Diana, Princess of Wales,
16 indicated that she believed her phones were being
17 'tapped'. I was aware that recently her apartments had
18 been visited by individuals from a private security
19 company and that they had conducted a 'sweep' for
20 surveillance devices. As such, I could not consider
21 the apartments secure. I offered Diana, Princess of
22 Wales, the opportunity to have a team of officers from
23 the Palace of Westminster conduct a deep search of her
24 apartments and vehicle in order to re-establish their
25 security and to reassure the Princess. I told her that

63
1 I was not so concerned about what these individuals had
2 taken out, but was more concerned about what they may
3 have left behind. This was clearly something she had
4 not considered and agreed to the search. The apartments
5 and her car were searched with negative result by
6 the team from the Palace of Westminster. I conveyed
7 the result of this search to the Commissioner in an oral
8 briefing. There was no written record kept."
9 Now I want to take it slowly. What you are saying
10 in this statement, only three weeks ago, is that --
11 nothing first of all in the statement about Diana
12 refusing anything, is there, in relation to a search?
13 A. No.
14 Q. What you are saying in the statement is not only that
15 she is not refusing a search, but that a search is
16 carried out in relation to the meeting on 18th October;
17 correct?
18 A. No.
19 Q. Oh. Well --
20 A. I have obviously been very clumsy in my wording, but you
21 will see that it was after the so-called carpet fitting.
22 Q. That is because you have been shown a document today,
23 haven't you, that relates to the carpet occasion? Is
24 that what you were shown?
25 A. No. I have told you exactly what I have seen today.

64
1 Q. Lord Condon's cross-examination and another document.
2 A. The other document was a single sheet of paper which
3 indicated that there was a negative result in a search
4 for an official inquiry into the Squidgygate case.
5 Q. Just that?
6 A. Just that.
7 Q. I will come to that in a moment. What you are saying
8 perfectly clearly -- I suggest there is no clumsiness --
9 you were a senior officer for a very long time?
10 A. Yes, sir.
11 Q. And you were used to, at one stage in your career,
12 having to give evidence?
13 A. Many years ago, yes, sir.
14 Q. I appreciate many years ago. But you would also
15 recognise, given your position and your experience, that
16 it is very important, when committing yourself to paper,
17 to ensure that you are accurate and truthful. Do you
18 agree?
19 A. Yes, sir.
20 Q. I am going to suggest to you that what has happened here
21 is that once you see the cross-examination of
22 Lord Condon, who is talking about a refusal and talking
23 about no search, that you somehow or another -- and
24 I make it blunt to you -- you have had to amend your
25 version so that now you are saying, I suggest clumsily,

65
1 that there was an earlier search.
2 A. Sir, these events, as you are well aware, are some
3 considerable years ago. You are quite right in saying
4 that the first time that I have had occasion to recall
5 them was some three weeks ago. During the making of
6 that statement, you will see that I actually -- my
7 memory said that I did not take up my post until 1993,
8 whereas manifestly I had taken it up in 1992.
9 Q. Well, I will have some questions to ask you about that
10 in a moment.
11 A. Let me continue please.
12 Q. Certainly.
13 A. My recollection is that following the carpet incident,
14 when it was brought to my attention, I asked fairly
15 forcibly of the Princess that the premises would need to
16 be re-swept and she quite reluctantly agreed.
17 Q. You see, this is the first time that we have ever heard
18 this today. I do not suppose you have been shown this.
19 Do you know what Mr Haywood-Trimming said about any
20 search by the police?
21 A. No, sir.
22 Q. It did not happen, not by the police. He knew about
23 private security firms, but not by the police.
24 Now I would like you to think very carefully about
25 this.

66
1 A. I am quite adamant, sir, that I used a POLSA team from
2 the Palace of Westminster to do the search.
3 Q. Well, now the question is going to arise, since you are
4 now pre-dating it -- in other words you are saying it
5 does not arise out of the meeting on the 18th, but
6 arises after the carpet sweep. I think you appreciate
7 what will be coming: is there any single document
8 indicating, first of all, an earlier conversation with
9 Princess Diana by you on this topic?
10 A. As far as I am aware, you have -- any notes or
11 aides memoires that I made have been made available to
12 this inquest, sir.
13 Q. Would you accept from me that we do not have a single
14 document from you or anybody else suggesting that there
15 was, at an earlier stage to 18th October 1994, any
16 discussion with any member of the protectorate, as it
17 were, the royal protection group, let alone you, of that
18 kind?
19 So there is no note of any discussion; there is no
20 note of any search. Now, of course, there would be
21 a record of a pulsar search, wouldn't there?
22 A. Not necessarily, sir, because there was no damage done
23 and nothing untoward was found.
24 Q. No, no. Wait a minute. You have a log kept, do you
25 not, by POLSA squads? They don't just wander into

67
1 premises and out again without a log being kept of who
2 goes -- particularly in Royal Palaces, who goes, how
3 long they are there and particularly important is
4 a negative result, given that there is a complaint by
5 a member, as she was then, of the Royal Family. A log
6 is kept, isn't it?
7 A. I am saying to you, sir, if no damage is caused and
8 nothing untoward is found, it would be part of their
9 routine day.
10 Q. I am sorry. What was the question? I am sorry to have
11 to ask this of a number of police witnesses. What was
12 the question?
13 A. You repeat it, sir, and I will --
14 Q. I have already repeated it twice. Please listen.
15 A log is kept by a POLSA squad of their activities
16 daily, isn't it?
17 A. What do you call a "log", sir?
18 Q. I am not allowed to answer questions, but is that
19 a serious question, "What is a log?"
20 A. Yes. I am asking you what sort of record do you think
21 they keep.
22 Q. No, what sort of record do you think they keep?
23 A. I am saying to you that I had a verbal response from
24 the Palace of Westminster after the sweep had been
25 conducted to say that nothing untoward had been found,

68
1 either in the premises, on the vehicle or, more
2 importantly perhaps, on our mainframe. You will recall
3 that the incident with the so-called carpet fitters came
4 to light because they attempted to gain access to our
5 mainframe.
6 LORD JUSTICE SCOTT BAKER: But Mr Mansfield's point is that
7 surely there would have been some record somewhere of
8 the subsequent search that you had directed, some
9 written record.
10 A. It may be that the Palace of Westminster made one at the
11 time, but certainly, sir, by now it would be no longer
12 available. In fact, I did ask if a search could be made
13 in an effort to clear this matter up, but unfortunately
14 I have received no answer to that.
15 Q. That may mean they have not got as far as finding
16 something or it may mean that there is not anything. It
17 may mean a number of things, so we will leave that.
18 I suggest to you a POLSA team would have a record,
19 whether it is called a "log" or an "incident book" or
20 whatever, but more importantly even than the squad
21 keeping a record, there ought to be at the very least
22 a document from you either to Patrick Jephson,
23 the Commander who was her Private Secretary, or a note
24 to the Commissioner, saying, "We have carried this out
25 because Diana is very concerned but we have done it for

69
1 her; vehicle and premises on such-and-such day, deep
2 search, nothing found". Now there is no memo from you
3 to anyone that is now available.
4 I will take it in stages. Did you write one?
5 A. No.
6 Q. Why not?
7 A. Because it was a negative, sir.
8 Q. That is the point, Officer, as you once were, sorry.
9 That is the point. The point is allaying the concerns,
10 if this is what happen, of the Princess, that in fact
11 you had found nothing and allaying the concerns of her
12 Private Secretary and so forth.
13 A. Sir, it was allaying my concerns.
14 Q. Oh, yours, yes.
15 A. Yes. The premises, which were part of a larger secure
16 complex, had been entered by non-police officers who had
17 had wide access to the premises and, therefore, I felt
18 that they could no longer be considered secure.
19 LORD JUSTICE SCOTT BAKER: Your point was that they might
20 have bugged the premises?
21 A. Indeed, sir.
22 Q. But her point was -- you do have consideration for her,
23 don't you?
24 A. I do.
25 Q. Did you tell her?

70
1 A. In so many words, no.
2 LORD JUSTICE SCOTT BAKER: I thought you said a little while
3 ago that it was not what they had taken away, but what
4 they had left behind. Did you say that to her?
5 A. When I told her the reason that it should be done, sir,
6 it was at that stage that I said I was not concerned
7 with what they had found -- which she told me was
8 nothing, anyway -- but the opportunity that they had had
9 to leave other things behind.
10 MR MANSFIELD: I will come back to the point. Did you tell
11 her that you were very happy that, you know, nothing had
12 been left? Did you tell her that? I think your answer
13 is "no".
14 A. No. That is quite right, sir.
15 Q. Quite right. Why not?
16 A. She would have known the result from the person,
17 the inspector leading the team, sir.
18 Q. She really was being treated as a second-class citizen,
19 wasn't she?
20 A. No, sir.
21 Q. Lord Condon does not get back to her about anything and
22 you don't get back to her. The question I am really
23 posing is: did you really have a search made and where
24 is any verification of it?
25 A. I have already answered that question.

71
1 Q. You say there was and there is no verification.
2 A. There is no written verification, no.
3 Q. Who was in the squad who would have done it?
4 A. It was the POLSA team from the Palace of Westminster,
5 sir.
6 Q. Well, the Palace of Westminster team goes to
7 Kensington Palace and her vehicles, is that what you are
8 saying?
9 A. And the mainframe.
10 Q. You see, we have had documents about the intrusion, but
11 we have had absolutely no documents about any follow-up.
12 Do you follow?
13 A. I follow, sir.
14 Q. Right.
15 Now, I do not want to trespass on any sensitive
16 information, but how many officers in the squad,
17 roughly?
18 A. Do you mean how many went to the premises?
19 Q. Yes.
20 A. I cannot answer that because I do not know, sir.
21 LORD JUSTICE SCOTT BAKER: Would they have done the car
22 the same day as the premises?
23 A. Indeed, and also our mainframe computer, sir.
24 MR MANSFIELD: All of that in the same day by the same
25 squad?

72
1 A. Yes.
2 Q. I continue to ask if there is any documentation to
3 support that.
4 Now, if that is what you say happened, do you have
5 any idea which year that happened?
6 A. I have a feeling it would be about 1993, sir.
7 Q. Now, can we go back to the document that you wrote up
8 explaining this meeting of 18th October? Can we have
9 [INQ0058848]? Can we have the paragraph highlighted?
10 It is at the bottom:
11 "During the course of the conversation ..."
12 As the jury has been taken through it a number of
13 times, I am not going to do it again, but I do have
14 a number of questions.
15 Where in this account do you say -- well, first of
16 all, I will ask it this way round. Did you tell her,
17 "Look here, Diana", or whatever you called her, "your
18 Royal Highness, we have already done this, you know.
19 Only last year we searched your car and your premises
20 and, you know what, there was nothing there"? Did you
21 tell her that?
22 A. Not directly, sir, no.
23 Q. Did you tell her indirectly in this meeting?
24 A. No.
25 Q. No.

73
1 A. The fact that I made comment about the Palace of
2 Westminster and the deep search team should have
3 reminded her.
4 Q. Officer -- I am sorry to call you "officer" but acting,
5 as you were, as a senior police officer -- the obvious
6 thing to say to her, if you were caring about her
7 security -- or were you treating her as a joke?
8 A. Sir, I have already explained to you that her security
9 must be paramount because, if not for herself, for
10 the fact that her premises and her vehicle were within
11 a greater area of security. So you cannot possibly say
12 that I did not have concern for her security. I most
13 certainly did.
14 Q. How is she going to know in this meeting that you have
15 already done it and you have found nothing if you have
16 never told her?
17 A. She would have been aware, sir.
18 Q. How?
19 A. Through her staff.
20 Q. How?
21 A. Her staff would have been told.
22 Q. No, they weren't. We have had evidence from them.
23 Commander Jephson I asked about this. He knew nothing
24 about any searches by the police. Can you explain that?
25 A. No, sir, I cannot.

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1 Q. Unless, of course, it did not happen.
2 A. It happened.
3 Q. Well, let's just go on. You agree that you don't tell
4 her in the first place that it has happened. You agree
5 that you don't repeat it in this meeting, that it has
6 already happened. Now, dealing with the question of the
7 car being bugged, what she was interested in, do you
8 agree, was not so much whether there was a listening
9 device in the car, but whether the car could be tracked
10 by a tracking device. Now, first of all, did you know
11 then what a tracking device is?
12 A. I know what a tracking device is.
13 Q. Yes. It is something fitted to a vehicle which allows
14 somebody else to know where the vehicle is. You can
15 monitor the movements.
16 A. Yes.
17 Q. Right. That is what she was interested in, whether
18 somebody had tracked her vehicle because she was
19 concerned about somebody waiting at the other end, as it
20 were; in other words, a vehicle being tracked between
21 places. Did that occur to you then, that that is her
22 concern?
23 A. She made the statement that she felt that people knew
24 her destination through a bug in her vehicle. I pointed
25 out that bugs cannot predict destinations.

75
1 Q. No, but tracking devices, which show you the route or
2 rather allow somebody who is, as it were, receiving
3 the tracking device's, as it were, vibrations, in other
4 words, receiving messages from the tracking device,
5 might have a clue as to which direction somebody is
6 going, for example towards Kensington Palace or
7 whatever; you follow the question?
8 A. Yes.
9 Q. Did that occur to you, that that is what her concern
10 was?
11 A. No.
12 LORD JUSTICE SCOTT BAKER: Mr Meynell, it would have been
13 helpful, wouldn't it, if, after the POLSA team had gone
14 in, you had written a letter saying, "Dear Princess,
15 I am happy to tell you that the team has now had a look,
16 nothing was found in the premises or the car and
17 the mainframe computer is fine. Please don't get
18 a private security firm coming in pretending they are
19 a carpet company in the future and doing this, but all
20 is well now".
21 A. Quite so, sir.
22 LORD JUSTICE SCOTT BAKER: But you did not write that
23 letter, did you?
24 A. I did not.
25 LORD JUSTICE SCOTT BAKER: The problem is that nobody from

76
1 her staff appears to have known about this search and
2 it is very difficult to identify when it happened now,
3 isn't it --
4 A. Yes, indeed.
5 LORD JUSTICE SCOTT BAKER: -- or indeed, some might say, if
6 it happened. Mr Mansfield says that.
7 MR MANSFIELD: You see, what I am suggesting is this was not
8 a minor matter, the Princess complaining in this way,
9 was it? Was it? It was not a minor matter?
10 A. I am sorry, I do not follow the question.
11 Q. Her complaint about her being surveyed, monitored,
12 eavesdropped, it was not a minor matter, was it?
13 A. As I have already explained, sir, at that meeting,
14 the meeting was very much in three parts.
15 Q. Sorry, it is a preface. I will come to the meeting.
16 I am not going through it in great detail. As,
17 I suggest, not a minor matter, it is impossible for you
18 not to have made records about this initial search that
19 took place before this meeting on the 18th; impossible,
20 if it had happened, for there not to be some record of
21 it happening. Do you agree?
22 A. No, sir.
23 Q. You don't?
24 A. No.
25 Q. I see.

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1 A. Because if you look at the converse of that, it would
2 mean that I had deliberately left a possible security
3 breach in Kensington Palace, not only in
4 Kensington Palace, but also on our mainframe computer.
5 Q. You have it in one. Did you leave it? Did you suspect
6 at that time that in fact it was possible for security
7