Hearing transcripts

5 February 2008 - Afternoon session

5 (2.05 pm)
6 (Jury present)
7 LORD JUSTICE SCOTT BAKER: I call Mr Laffan next.
8 MR PAUL LAFFAN (sworn)
9 LORD JUSTICE SCOTT BAKER: Do you prefer to sit or stand,
10 Mr Laffan?
11 A. I am happy standing.
12 LORD JUSTICE SCOTT BAKER: Very well.
13 Questions from MR HILLIARD
14 MR HILLIARD: Can you give us your full name please?
15 A. My name is Paul Laffan.
16 Q. Mr Laffan, can you help us? What is your occupation at
17 the moment?
18 A. I am a lawyer with the Financial Services Authority at
19 Canary Wharf in London.
20 Q. Before that, were you a detective sergeant in
21 the Metropolitan Police?
22 A. That is correct, yes.
23 Q. When did you leave the Metropolitan Police Service?
24 A. I left in September 2006 to take up employment with
25 the Financial Services Authority.

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1 Q. When you left the Metropolitan Police, were you what is
2 called an "accredited financial investigator"?
3 A. I was and am still, to this day, sir.
4 Q. When you were working for the Metropolitan Police, if
5 there was a financial aspect to a case -- I do not know,
6 for example where the proceeds of a crime had gone,
7 something of that sort, how somebody had made their
8 living, those kind of questions -- were you the sort of
9 person who would be put on that inquiry?
10 A. I was. I worked on a team of investigators carrying out
11 financial investigations.
12 Q. With that as your background, were you asked to look by
13 the Operation Paget team at materials that had been
14 gathered in the course of the French investigation which
15 related to Henri Paul's financial position?
16 A. I was, yes.
17 Q. When did you start your work? If you have files and
18 notes, then obviously, by all means, help yourself.
19 A. I believe that I was instructed first of all in 2004.
20 I am not sure of the exact month.
21 Q. It is all right. Some time, you think, in 2004.
22 Your final report, I think, is dated May of 2007.
23 Is that right?
24 A. Yes, that is correct -- I am sorry, I have a date of
25 June 2006.

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1 Q. That is when you were --
2 A. That is my second report, June 2006.
3 Q. Don't worry. What I am interested in are the two
4 things, the first and the last. So you say you think it
5 was 2004 that you first started your work. Is that
6 right or wrong?
7 A. That is correct, yes.
8 Q. Then your final report, is it right that it is May 2007
9 or not?
10 A. The report that I have is June 2006.
11 LORD JUSTICE SCOTT BAKER: I have one of eight pages, I am
12 looking at, which is dated 1st May 2007, but it does
13 describe you as a detective sergeant, but you had left
14 the Met by then.
15 A. I had, yes. The work I concluded was concluded before
16 I left the Metropolitan Police, so it must have been in
17 June 2006.
18 MR HILLIARD: All right.
19 A. I am sorry, the first report was around April 2004.
20 Sometime after April 2004.
21 Q. Right. But anyway, in the course of your work, it is
22 right, is it, that you had access to the material that
23 the French investigation had gathered and that is really
24 what you had to work on?
25 A. Exactly, yes.

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1 Q. Did it come to this, that at the time of his death,
2 Mr Henri Paul was 41 years old and was living in a flat
3 in somewhere called Rue des Petits Champs in Paris? Is
4 that right?
5 A. Yes, that is the information I received.
6 Q. That was a flat that he actually rented, is that right?
7 A. Yes, as I understand it. Yes, that is correct.
8 Q. Did you also understand that he owned another flat that
9 he rented out? So there is one flat that he is living
10 in himself that he rents, but there is another flat that
11 he actually owned that he rented out. Did you
12 understand that?
13 A. At the time I prepared my second report, I did not have
14 that information.
15 Q. Are you aware of that now?
16 A. I am aware from the report that subsequently followed.
17 Q. So a flat that he is renting to somebody else to live
18 in.
19 Just as far as the property that he owned is
20 concerned, did you ever find out how much that was
21 valued at, what the worth of that was, what any mortgage
22 on that was?
23 A. There was no information around that area at all.
24 Q. So one flat he is living in; another one he owns. You
25 knew about his employment as the assistant head of

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1 security at the Ritz in Paris?
2 A. Yes, I did.
3 Q. Did you then look to see what the position was as far as
4 bank accounts and credit cards were concerned?
5 A. I did, yes. I was supplied with a number of documents
6 relating to credit card -- sorry, bank transactions.
7 Q. Did you make a list of those?
8 A. I did, yes.
9 MR HILLIARD: Sir, we have copied just the two sheets.
10 There is an unexplained, as it were, items section from
11 the account, which is one table, and then a first table
12 which I think you have a copy of. It is the two sheets.
13 A. From my report I have table 3 which lists all his bank
14 and credit cards --
15 Q. That is it.
16 A. -- and table 4 which lists credits to his accounts.
17 Q. It will be easier to look at those if we all have it.
18 So if we can hand those to the jury please.
19 So, looking at your table 3 then, Mr Laffan, five
20 credit or charge cards with three different
21 institutions. We can see first off -- do you see really
22 1 and 2 on the first sheet are American Express cards?
23 Do you see?
24 A. Yes, ending in "02" and "03".
25 Q. That is right. Then, if we go on down, five up from

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1 the bottom, there is a Diners Club card, then, above
2 that, another Diners Club card, and then another credit
3 card just above that. Do you see?
4 A. Yes, 953.
5 Q. So that makes five cards in all. Is that right?
6 A. Yes, that was the information I was supplied with.
7 Q. But as far as those were concerned -- we are going to
8 look at the balance, as it were, at the bottom later
9 on -- and if, for example, money was owed on any or all
10 of those cards, you had no information about that?
11 A. No, and I actually requested -- for my first piece of
12 work, I requested that they find that information.
13 Q. But did you ever get it?
14 A. No.
15 Q. All right. We will come on to shares at the bottom, but
16 otherwise I think you totalled up, is this right, 15
17 accounts --
18 A. Yes.
19 Q. -- which we have sandwiched between the credit cards
20 that we have just looked at. Is that right?
21 A. That is correct, yes.
22 Q. If we just go down the sheet, number 3, that is
23 a Barclays account. You can see that you put "Share
24 account?". Again were you really missing information
25 about the nature of that account?

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1 A. Yes, I was at that time. Yes, yes.
2 Q. That implies that you are not anymore or ...?
3 A. Sorry, it is the 801 account which I believe is a share
4 account.
5 Q. I am looking at the 101, where you have put "Share
6 account?".
7 A. I was not sure. It looked to me like a share account,
8 but I was not able to confirm.
9 Q. But you were able to see that that had been opened in
10 1993 and that the last balance that you were aware of,
11 we can see, 313-odd francs. Is that right?
12 A. Yes, that is correct.
13 Q. Did you have information, if we take that as an example,
14 for that account solidly from the period 1993 until end
15 of August 1997 or not at all?
16 A. No. The earliest transactions I had on any of the
17 accounts was October 1996 --
18 Q. Or November, I think it might have been, but towards
19 the end of 1996. All right.
20 Then another Barclays account, the one ending in
21 "01", should we get rid of the question mark after
22 "share account"? Are you now satisfied that that is
23 what it was?
24 A. Yes.
25 Q. You have recorded the balance for that. Another

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1 Barclays account, 851, "Share account?". Are you still
2 unsure about that?
3 A. I mean, I believe that these are share accounts.
4 The question mark was there for someone to confirm.
5 I do not know whether that ever happened.
6 Q. All right. Then a Barclays account that was in fact
7 closed in 1994 and nothing in that. It had been shut
8 for some time. Yes?
9 A. 1992.
10 Q. That is right. Opened in 1992, closed in 1994 and
11 nothing in it anyway.
12 A. Absolutely, yes.
13 Q. Then, three -- what does that stand for -- National Bank
14 of Paris accounts, is it?
15 A. Yes, it is.
16 Q. A cheque account, a savings account and a house purchase
17 savings account that had nothing in it, but we can see
18 the balance in the other two; yes?
19 A. That is correct, yes.
20 Q. Another account, Caisse d'Epargne de Bretagne,
21 50,000-odd francs in that; yes?
22 A. Yes, that is correct.
23 Q. Another account at the same institution which had not
24 been used since 1988 and there was no money in it
25 anyway?

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1 A. Yes, that is correct, sir.
2 Q. Another account with that institution, but it looks as
3 if it is the Paris branch. We can see the balance.
4 Another account, it looks like the same institution,
5 same branch. That account not used since April of
6 1995 -- is that right -- or no activity on the account.
7 Is that as you understood it?
8 A. Yes, that is right. In fact, I think it was only
9 the Caisse d'Epargne 435 account that really has any
10 movement in it throughout the period that we are looking
11 at.
12 Q. So that is the one with the balance of 371,000-odd
13 francs; yes?
14 A. Yes. That to me was his day-to-day account.
15 Q. That is the one that appeared to be active?
16 A. Yes. There were transactions in and out.
17 Q. There is then an account, one ending "976". It looks as
18 if you did not even know the balance; is that right?
19 A. Yes. That was from a letter that we were provided with
20 I think by the authorities, but no other information on
21 it.
22 Q. Then an account balance of 112,000-odd francs. Next
23 one, 453,000 francs or so. Yes?
24 A. Yes, that is correct.
25 Q. Next one, 2,094-odd francs.

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1 A. Yes.
2 Q. Then the three credit cards that we looked at, and then
3 four -- what are they -- effectively portfolios of
4 shares that he owned?
5 A. They were, yes.
6 Q. We can see the figures for each of those. Did he appear
7 to be trading; buying and selling on his own account
8 shares?
9 A. The share transactions appear to have taken place in
10 the Barclays accounts 801.
11 Q. Just hold on a minute.
12 A. That is the fourth account down on table 3.
13 Q. Right.
14 A. The portfolio of shares I think is what was left over at
15 the end, what he had at the time of his death.
16 Q. Anyway, subject to two things, the first being that you
17 did not know what, if anything, he owed on any of the
18 credit cards; the second being, we have heard, that
19 there was 12,500 or so francs in his possession at the
20 time of his death, those things aside, the figure here,
21 when subject to an exchange rate change, about £170,000;
22 is that right?
23 A. Yes, that is right, sir.
24 Q. Now, as far as money going in and out of his accounts
25 was concerned, did you try to see what the position was

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1 about his income from the Ritz Hotel?
2 A. Yes, we identified from his account 435,
3 the Caisse d'Epargne account.
4 Q. That is a couple below the first hole-punch, isn't it --
5 A. Yes, it is.
6 Q. -- that one ending in "435". Did you think that was the
7 account into which his salary was going?
8 A. That was his account, yes.
9 Q. Consistent with what you have told us about
10 the information you had, did you look at what he had
11 apparently received in from the Ritz by way of salary
12 over a ten-month period between November 1996 and
13 August 1997?
14 A. Yes, I did. That is set out in table 1 of my report.
15 Q. We have not all got that. So what did that come to?
16 What was the figure?
17 A. In francs, 172,992.51 francs.
18 LORD JUSTICE SCOTT BAKER: Over how many months?
19 A. Sir, between end of November, 29th November, through to
20 28th August.
21 MR HILLIARD: So that was a ten-month period?
22 A. That is right.
23 Q. That sum, it is about 173,000 francs, just a bit more
24 than £173,000(sic); is that right?
25 So if he was getting £17,500 or so per month, that

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1 would be about it.
2 A. Sorry?
3 Q. I am sorry, £1,750 or so; yes?
4 A. Yes, that is right. Yes.
5 Q. Whilst you were looking at the accounts, if we turn over
6 to our second page, we have your table 4, which you have
7 headed "Unexplained/unusual credits". Is that right?
8 A. Yes.
9 Q. What exercise had you carried out here, just so that
10 we understand what we are looking at?
11 A. Well, we put all the transactions together in date order
12 and I was looking for any credits which did not appear
13 to have a corresponding debit, so they were not
14 inter-account transfers. So I was looking essentially
15 for any credits that had come in from any sources we had
16 no knowledge of, eg his work.
17 Q. Now you have set those out on this page.
18 Just help us, though, about this: the first one
19 we can see is December 1996, top of the page.
20 A. Yes, that is right.
21 Q. You have told us that the information you had began in
22 October or November of 1996.
23 A. That is right, yes.
24 Q. I just want to understand: does it follow from that that
25 you have actually no way of knowing in fact whether this

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1 pattern was repeated over the years or not? You just
2 cannot tell us?
3 A. No. There is absolutely no way of knowing. I cannot
4 tell what happened before.
5 Q. But if we just look down this sheet, first,
6 18th December 1996, that is almost 50,000 francs into
7 the account, is that right, as a cash deposit?
8 A. It is a cash deposit, yes. It is made up of 99
9 500-franc notes and two 400-franc notes and it was paid
10 in at 11 o'clock in the morning.
11 Q. Does it say who paid it in?
12 A. The credit slip that I have seen appears to be
13 the account holder, Mr Paul, however I have no way of
14 knowing that that is his signature.
15 Q. Then the next day, two more cash deposits -- is that
16 right -- one for 49,900 francs; the other for 20,000.
17 Do you see?
18 A. Yes, that is right.
19 LORD JUSTICE SCOTT BAKER: So the identical amount goes in
20 two days running; followed by another 20,000 on
21 the second day?
22 A. Yes, that appears to be the case, sir.
23 LORD JUSTICE SCOTT BAKER: You have no explanation for
24 the two 49,900s?
25 A. No.

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1 MR HILLIARD: I am sure you know, because of the work you
2 do, but large amounts of cash going into accounts, there
3 are circumstances, aren't there, in which banks have to
4 make enquiries about big sums of cash? Is there any
5 figure above or below which, in France, enquiries have
6 to be made, do you know?
7 A. No. The French system is similar to our own, that it is
8 a subjective-based suspicion.
9 Q. I am looking at those two, just both below 50,000, but
10 anyway, all right.
11 We have looked at that one which you have told us
12 about. Then we go to 26th March of the next year,
13 30,000 francs going in.
14 A. Yes, that was paid by way of a cheque. Again, I have no
15 information as to from which account that cheque came.
16 Q. Then out of the account -- do I have this right -- on
17 21st May 1997 go 80,000 francs.
18 A. Yes, that is right, by cheque.
19 Q. Did you ever have that cheque to be able to see where
20 the money had gone?
21 A. No, I did not.
22 Q. Now, eight days later, 40,000 francs came in to
23 the account, do you see, the same account, out of which
24 the 80,000 had gone, the 29th. So eight days later,
25 40,000 francs come back in. That is paid in in cash, is

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1 that right?
2 A. It is, yes.
3 Q. Then, on 4th June, another 40,000 francs come in, again
4 to that same account. Is that right?
5 A. It is, yes.
6 Q. So that is 80,000 that has gone out and then 80,000 that
7 has come back in, in cash. Is that right?
8 A. Yes, it is. When I analysed the accounts, it appeared
9 to me and it is possible that the two 40,000 deposits
10 may have come from the 80,000 that was withdrawn. I say
11 that because I never saw any deposits into any of his
12 other accounts for 80,000, but I can say no more than
13 that really.
14 Q. All you can do is raise the possibility: is the 80,000
15 coming back in after the 80,000 has gone out? It is one
16 possibility?
17 A. It is.
18 LORD JUSTICE SCOTT BAKER: So you never saw to whom
19 the cheque was payable, the 80,000?
20 A. No, we never had that information, I am afraid, sir.
21 MR HILLIARD: Then, 19th June, 40,000 francs going into
22 the 658 account. A comment there; it just says
23 "deposit". Does that mean that you don't know if it was
24 cheque or cash?
25 A. I was not able to ascertain that from the cash

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1 statements.
2 Q. All you were able to say was that it was money going in?
3 A. It was, yes.
4 Q. The same applies to the next entry which is 3rd July.
5 It is again 40,000 francs, and again you cannot help,
6 cheque or cash?
7 A. No. That is right.
8 Q. Same day, 40,000 francs in cash, paid into the 435
9 account, is that right?
10 A. Yes, that was a cash payment.
11 Q. Any indication as to who, again, paid that in?
12 A. No. I did not have the deposit slip.
13 Q. Then, 5th August, the 801 Barclays account,
14 40,000 francs. That is again cash paid in. Is that
15 right?
16 A. It is, yes, and I believe that was paid in by Mr Paul.
17 Q. Then, lastly -- again also they are the same day --
18 another 40,000 francs going in. Again, that was cash,
19 is that right?
20 A. That is how it appears on the account, yes.
21 Q. Any indication as to who paid that in?
22 A. No. It was only the Barclays accounts that we had
23 information to assist us as to when and where the
24 account had been deposited.
25 Q. If you added all of those credits up, you came to the

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1 figure there, 429,800 francs; is that right?
2 A. Yes, that is correct.
3 Q. That includes, is this right, the 80,000 which might
4 be -- who knows? -- the repayment of the 80,000 which
5 had gone out?
6 A. It does include that, yes, indeed.
7 Q. So if you took that off, those were explained because
8 they were simply money that had gone back to him. It
9 would be 349,000, as I think the figure would then be;
10 yes?
11 A. Yes, whatever 80,000 --
12 Q. -- off that is. I think it is something like 349.
13 Again you did the conversion exercise using
14 the pounds/francs rate at 31st August 1997. Is that
15 right?
16 A. Yes, and the figure is 43,683.73.
17 Q. Now part of what you have already told us, you could not
18 say whether there had been any deposits like this before
19 the end of 1996 because you just did not have the
20 information, so you did not know that. In addition,
21 were you able to come to any conclusion at all as to
22 where this money had come from?
23 A. No. There are any number of possibilities.
24 Q. Absolutely, but in terms of, as it were, certain
25 answers, by which I mean sure answers, you had none?

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1 A. I put to the inquiry team suggested lines of inquiry,
2 but that is all really.
3 LORD JUSTICE SCOTT BAKER: Could you ascertain how active
4 a share dealer he was? Did he buy shares and sit on
5 them or did he buy and sell quite frequently?
6 A. In the short time that I had to look at, between
7 October 1996 and August 1997, I think there were only
8 one or two transactions. Most of the time it was
9 dividends being paid in as a result of fluctuations in
10 the market.
11 MR HILLIARD: Yes, all right. Thank you very much.
12 LORD JUSTICE SCOTT BAKER: Mr Mansfield?
13 Questions from MR MANSFIELD
14 MR MANSFIELD: Thank you. My name is Michael Mansfield and
15 I represent Mohamed Al Fayed and I want to ask you
16 a number of questions.
17 I am sorry because you probably did this work
18 a little time ago.
19 Does it appear in this fashion: as far as
20 the French inquiries are concerned, there does not
21 appear to have been very many -- the inquiries by
22 the French authorities, would you agree?
23 A. In what regard, sir?
24 Q. Well, you have not been given much information from
25 the French, the most obvious of which is looking at

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1 the pattern of financial transactions when the French
2 were originally looking at Henri Paul in 1997 and would
3 have had access to French banks. Would you agree?
4 A. I am sorry, I am not sure of the question. The question
5 is: did they -- they got some bank accounts, they just
6 did not get credit card accounts.
7 Q. No, no. I am trying to take an overview to make it
8 quicker. I will go more slowly.
9 The position in 1997 -- I appreciate you come on
10 the scene a little later. It is no criticism of you.
11 Do you follow? I am just trying to do another audit
12 trail in the way that you did.
13 A. Sure.
14 Q. In 1997, if the French authorities really wanted to get
15 a grip on what Henri Paul was up to in terms of his
16 money, the first thing you do is get hold of all his
17 accounts from all the banks and look at the pattern of
18 expenditure, income and so on; yes?
19 A. Which I think they did. They just did not go far enough
20 back.
21 Q. Do we have anything, as far as you are aware, before
22 November of 1996?
23 A. No. The earliest transactions appear to be -- I think
24 I have one in October 1996, but -- yes, certainly no
25 earlier than that.

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1 Q. You see one of the points might be is to have a look and
2 see whether there has been an unusual pattern of credits
3 which cannot be explained and I cannot get it from you.
4 We don't know whether, in 1996, there is another pattern
5 of unexplained credits; in 1995 there is another pattern
6 of unexplained credits. We just don't know, do we?
7 A. We don't, no.
8 Q. So one of the things the French authorities did not do
9 was to have a look at the pattern of expenditure and
10 income for this particular individual beyond November or
11 October perhaps, at the earliest, 1996; is that right?
12 A. Yes.
13 Q. Of course, when you came onto the scene, as it were, you
14 raised a number of questions. I have an earlier report
15 which is undated. I assume it is the one in 2004 --
16 A. That is right.
17 Q. -- in which you raise a lot of questions, don't you?
18 A. There are 26 in all.
19 Q. They have not all been answered, have they?
20 A. No, they have not, or I certainly have not been given
21 any information which suggests they were, no.
22 Q. You see one of the things that would help obviously --
23 and I suggest again it is something the French
24 authorities could have done and it does not appear to
25 have been done since -- is question number 4. So that

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1 you know what I am reading from, on your original -- for
2 those who have it, it is [INQ0019701] -- I think this
3 must be your June 2004 report, in raising questions,
4 there are two questions on this page. I might as well
5 deal with them both while we are on this page.
6 One is "What were his credit card liabilities?"
7 That has never been answered, has it?
8 A. No.
9 Q. Your fourth question to the Paget team, "Were
10 the account statements and deposit slips obtained in
11 relation to financial transactions on both the bank and
12 credit card accounts?" You have not had that one
13 answered, have you?
14 A. They go back to October, but no earlier. I think
15 I suggested January 1996, but I suppose, in an ideal
16 world, you would want them earlier.
17 Q. Yes. That is in terms of the information. Obviously
18 you can only go on what you have been provided with, but
19 even there, as I suggest to you, there are problems.
20 Now, before I go through these lists, I want you to
21 have a look at another document to see if you have ever
22 seen it. Can we have on screen [D969], please?
23 So that you are clear where this comes from, this is
24 a document handwritten almost certainly by Henri Paul,
25 found in his flat on September 3rd, on a living room

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1 table, amongst a number of other documents; business
2 cards and so on and handwritten names and addresses.
3 Now have you ever seen that before?
4 A. It is not one of the documents that I was provided with.
5 Q. No, I think looking at what you say you were provided
6 with, this was not one of them.
7 A. No, I have not seen that document.
8 Q. Now, plainly -- I do not want to take you by surprise
9 particularly. It is quite clear on the left-hand side
10 that these are referring to French accounts. Do you
11 see?
12 A. Sorry, you say "plainly". I do not know why you say
13 that. I do not know the accounts.
14 Q. I am going to suggest "Coderi", you see on the left-hand
15 side, is equivalent to a current account. "Livre A" is
16 a liquid assets account. I am not expecting you
17 necessarily to know. These appear to relate to
18 accounts. Now, presumably at this moment, you are not
19 able to help about what these actually do represent. Is
20 that right?
21 A. As I say, I do not even know they came from Mr Paul. As
22 I say, this is the first that I have seen of them sir.
23 Q. All right. You see there, "Cash, 400,000". Assuming he
24 is talking about francs there, that is plainly quite
25 a large such of money, isn't it?

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1 A. That is about £4,000.
2 Q. Yes, if that is what it is.
3 We see at the bottom a total to save you having to
4 do it -- well, I say a "total"; we see a line with
5 another figure. Again, if it is accurately recorded, it
6 appears to be 1,870,000. Do you see that?
7 A. Yes, it says "1.870".
8 Q. You can do it quickly if you wish, but it is plainly not
9 the total of the figures above because, if you add them
10 all together, they come to 1.410.000, so, in other
11 words, roughly 460,000 francs short. Do you follow? If
12 it is meant to indicate a total or perhaps it is
13 a separate figure, we just don't know.
14 Then, on the right-hand side, there appears to be
15 another figure: 16,095.54.
16 A. Is that a "0" or is it a "2"?
17 Q. It could be a "2". I am not going to take time. I see
18 your point.
19 As far as any of these figures are concerned -- I am
20 not expecting you to have a ready view, as it were,
21 standing in the witness box -- do any of these figures
22 marry up with any of the accounts that you have seen, as
23 far as you are aware, or would you need time to think
24 about it?
25 A. I would definitely need time to think about it.

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1 Q. I fully understand, particularly as it is a document
2 that you have not seen before.
3 Can we just deal with some other matters? I will
4 take the tables in order as the jury has not seen them
5 before. I will take table 3 first of all.
6 Now, of course, a further inquiry that you have not
7 had relates to -- first of all, we see the Amex
8 accounts. Do you see those at the top of table 3?
9 A. Yes.
10 Q. Another of the questions you asked was to ascertain from
11 the credit cards that he had -- there were five
12 altogether -- whether any of them had been used at
13 the relevant time; particularly let's take 29/30/31st
14 1997. Do you remember?
15 A. Yes, I do.
16 Q. Of course the relevance of that was to see where he was
17 when he used them if he did?
18 A. Yes.
19 Q. Do you know the result of any of those inquiries?
20 A. I do not, no.
21 Q. So that it is clear, certainly as far as we are
22 concerned, the only one that has been tracked down
23 apparently is the Carte Bleue account, which is a credit
24 card relating to the main account. It is on the bottom
25 half of the Caisse d'Epargne Visa credit; that is a

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1 Carte Bleue. That is the only one. That does not
2 appear to be new. There are two Amex and two Diners, so
3 we do not appear to know whether in fact he has used any
4 of those on that day.
5 Moving down on table 3, the share accounts which are
6 questioned is because you have not really had sufficient
7 information, is that right, to confirm that that is what
8 they are? You just assume they are?
9 A. I believe that it is because I looked at the French,
10 the original French documents that were not translated,
11 and they appeared to me to be share accounts. Obviously
12 reviewing them in advance of today, I think they are
13 share accounts.
14 Q. You think they are. Very well.
15 I come further down to the Bank of Paris, BNP. Do
16 you see that?
17 A. Yes.
18 Q. One of the other questions you asked originally --
19 because this is somebody who has more than one bank that
20 he is dealing with, as we can see. On this page there
21 are three. Do you see table 3?
22 A. Yes.
23 Q. Sorry, I will go slowly here. One of the questions you
24 asked in relation to the Bank of Paris, we will see in
25 the column "Date opened", they are opened, the accounts,

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1 one in June, one in July and one in August. The point
2 that you made originally was: why was he needing to open
3 these accounts at that time? That was the question. Do
4 you remember?
5 A. I am not sure it was phrased that way, but --
6 Q. No, it was not, but that was the object of it. Sorry,
7 do you want to find where you --
8 A. I would just like to know the question I asked.
9 Q. It is number 10:
10 "Is there significance to the fact that three of the
11 BNP accounts listed were opened in the three months
12 before Henri Paul died?"
13 You have not had an answer to that question, have
14 you?
15 A. No, I have not.
16 Q. Because one of the ways the French police and possibly
17 those coming later would be, of course, to approach
18 the bank and find out whether -- provided they are
19 prepared to obviously answer these questions -- what
20 reason Henri Paul gave for having to open these
21 accounts. For example, you might have to make an
22 application to a bank, might you not?
23 A. That is right, yes.
24 Q. Then you would have to explain what you were doing. So
25 for the moment you have no explanation as to why he

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1 opens those three accounts. Then we come to the main
2 account. Can we just turn over the page -- it is our
3 page -- but it is the bottom of the table? Is
4 the position, the shares portfolios that you have been
5 about, that you now believe that they are all share
6 accounts, but you were not sure when you did the report?
7 Is that the position?
8 A. Yes, they are shares, I have seen.
9 Sorry, may I take you back to the BNP account?
10 Q. Yes, certainly.
11 A. It is just to clarify that one was opened as a cheque
12 account, the second as savings and the third as a house
13 purchase savings account. So there is information, if
14 you like, that says what the purpose of the account was,
15 but we have no idea of specific purpose, ie whether
16 it was to purchase a house or --
17 Q. Well, there is nothing in that account.
18 A. No, not at the end, but there were transactions.
19 Q. We will come to those accounts in a moment. But on the
20 face of it, cheque account, savings account and a house
21 purchase. Now, just on the property front, did you know
22 that in fact he bought a flat which he rented out?
23 A. At the time I prepared this, no. I do now, yes.
24 Q. How much did he pay for the flat?
25 A. I do not know that.

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1 LORD JUSTICE SCOTT BAKER: How much was the rent, do you
2 know?
3 A. I do not know. I believe it was contained in the
4 original report. I do not recall, but I do remember
5 reading somewhere.
6 MR MANSFIELD: You are quite right. He does rent it. I do
7 not have a figure either to put to you at the moment,
8 but he certainly rented out the one that the police went
9 to where the document was found. He rented it and then
10 he bought another property, a studio property which he
11 rented to somebody else. I think the other person is
12 Sylvie Lambert so it can be checked through.
13 Can we look at table 4, if you wouldn't mind? First
14 of all, as we go down, take the first one, the very
15 first one on 18th December. You had a denomination
16 breakdown of the monies paid in, 99 500-franc notes and
17 two 400-franc notes.
18 A. That is right, yes.
19 Q. So quite large denominations -- quite large -- are going
20 in. Do you have that information in relation to any of
21 the other deposits?
22 A. I have it in relation to the Barclays account deposits.
23 Q. The next down?
24 A. Yes. That was made up of 99 500-franc notes, one
25 200-franc and two 100-franc notes.

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1 Q. One of the features here is that the money going in, we
2 will see, are remarkably rounded figures, aren't they,
3 in nearly all of these cases.
4 A. They are round figures, yes.
5 Q. That is quite difficult to achieve if you are just
6 accumulating a series of tips in different
7 denominations, isn't it?
8 A. I do not know the answer to that.
9 Q. All right. I will not trouble you with it. But they
10 are rounded figures. So you can deal with the second
11 one that you just have. So does it follow that there is
12 no other deposit where you are able to say that the
13 denominations of the notes were so and so?
14 A. Yes, the last Barclays account deposit, 801.
15 Q. At the bottom, well, the bottom of my sheet?
16 A. Yes. Bear with me.
17 Q. I am hoping the jury have the right sheets here.
18 A. That was paid in -- I have eighty 500-franc notes.
19 Again, that was paid in on the morning of 5th August.
20 Q. It seems that the denomination of favour is 500-franc
21 notes every time he pays in to Barclays. That is not
22 exclusively, but it is predominantly 500-franc notes
23 that are going in.
24 A. I think that is the largest note you can pay in.
25 Q. It is the largest note you can pay in.

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1 Can I move down the list therefore? We are dealing
2 with the first two Barclays. Then there is a cash
3 deposit at his account, and I am assuming from what you
4 have said that you have no idea how that was made up.
5 Is that right?
6 A. Where are we now? Sorry.
7 Q. I am so sorry. Table 4, third entry.
8 A. "Caisse d'Epargne, 435"?
9 Q. Yes, that one.
10 A. No, that was taken from the account statement, which
11 just merely says "cash deposit".
12 Q. We get down to the next one, the 80,000. That is
13 a cheque going out.
14 A. The next deposit is 330,000 on 26th March.
15 Q. Sorry, I skipped that one for a moment. As you pointed
16 it out, presumably again you don't have the cheque, so
17 you don't know where that has come from --
18 A. No.
19 Q. -- let alone any deposit slip or anything of that kind;
20 you don't have deposit slips for this, is that right?
21 A. We don't have any deposit slips for the Caisse d'Epargne
22 accounts.
23 Q. Right, otherwise you would be able to tell what was
24 going in. So that is a cheque paid in, we don't know
25 from whom.

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1 Then, the next one down, the same account, ending in
2 "435", 80,000 is taken out by cheque. Now, if he has
3 taken it out by cheque and it relates to the next two or
4 may do, then he would have to take the cheque somewhere
5 to cash it, wouldn't he, if he was paying in cash?
6 A. I think he could make a cheque to cash. I think that
7 would be the way to do it.
8 Q. Can you tell whether that happened?
9 A. I cannot. I did not have a copy of the cheque.
10 Q. Because, if we go here, he is paying them in on
11 different days. Do you see? Cash paid into the same
12 account on 29th May and then another lot into the same
13 account on 4th June.
14 A. Yes.
15 Q. So if has taken out 80,000 in one cheque or he has paid
16 it -- we don't know whether he has paid it to somebody
17 else and got it back or whether he has paid a cash
18 cheque for himself, do you think, to draw out the
19 80,000?
20 A. It is impossible to tell.
21 Q. He goes into his bank and wants 80,000. He could
22 obviously get 80,000 either in cash or he could get it
23 on what sort of cheque? A cheque to himself from
24 the bank?
25 A. Yes. There is any number of reasons. He may have

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1 needed 80,000 and then that need was no longer there and
2 he paid it back in. I do not know. I simply don't
3 know.
4 Q. I will not take up time as you simply don't know whether
5 it is or whether it is not, the 40,000 there.
6 One of the striking features that comes up in
7 the next sequence is that they are not only rounded
8 figures, they are the same rounded figures, aren't they?
9 40,000, 40,000, 40,000 each time.
10 A. That is right, yes.
11 Q. That is unusual, isn't it, unexplained?
12 A. It is definitely unexplained, yes. I don't know whether
13 it is unusual because he may have been getting these
14 sorts of deposits for the last five or six years.
15 Q. Oh, absolutely. What we know is he is certainly not
16 getting that kind of deposit out of his salary, all
17 right, because you have already indicated what his
18 salary is. I am going to suggest to you very clearly
19 that these are sums far in excess of an accumulation of
20 a myriad of tips which come to an exact figure of 40,000
21 each time. Do you follow?
22 A. I follow your point, yes.
23 Q. I want you to look at it a little more closely. I am
24 sure you have looked at it in this way. Once we get
25 down to 4th June, which is a payment into his main

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1 account which may be part of the original 80 -- all
2 right? I start with that one. That is June. But then,
3 in the same month, into another bank, one of the ones
4 that has just been opened -- in fact, he has opened it
5 on the 10th June, the 658 BNP -- he pays in a similar
6 amount to another bank, doesn't he? It is obvious from
7 the face of the statement here; do you follow?
8 A. 15 days later.
9 Q. 15 days later he pays another similar amount into
10 another bank?
11 A. Yes, that is correct. I say -- we don't know that it is
12 cash. It is worthwhile pointing that out. The bank
13 statements I had did not give a clear indication of
14 whether it was cash or not.
15 Q. Well, if it is not cash, then there might be a way of
16 tracking down where the money has come from. For
17 example, if it has come from somebody who owed him
18 the money, it might be possible to track it. But
19 I appreciate all you can say is it is money going in,
20 but he has plainly decided to put it into a different
21 account which he has only just opened. Do you follow?
22 A. Yes. I do not actually see that there is anything
23 unusual about that as such, if he is opening an account.
24 Q. Of course not. Opening an account is not unusual, but
25 as you have already pointed out, we don't have any idea,

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1 other than what is on the face of the other table, what
2 these accounts were actually needed for at that point.
3 He already has a Barclays account, he already has
4 a main bank in Paris, and at the main bank he has lots
5 of different accounts, hasn't he?
6 A. Yes, subsets of his original account. I think they are
7 share accounts ...
8 LORD JUSTICE SCOTT BAKER: What we have got is seven
9 payments of 40,000 francs into his accounts over
10 a period of about nine weeks between 29th May 1997 and
11 5th August 1997.
12 A. Absolutely, yes, sir.
13 LORD JUSTICE SCOTT BAKER: But nothing of a similar pattern
14 earlier, as far as you are aware?
15 A. Well, apart from the cash deposits that go on just
16 before Christmas.
17 LORD JUSTICE SCOTT BAKER: But they were not
18 40,000-francers.
19 A. No. Yes, I understand, yes, sir.
20 MR MANSFIELD: Now, you have given us a total at the bottom,
21 429,000. There is another figure I want to add to it.
22 It may be that it does not make an incredible amount of
23 difference.
24 He had a safety deposit box, didn't he?
25 A. I believe he did.

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1 Q. You asked about that?
2 A. I did, yes.
3 Q. Did you get an answer?
4 A. No, I did not.
5 Q. I am going to provide you with, I hope, an accurate
6 answer. It appears from other documents that he may
7 have had something in the region of 30,000 in that as
8 well.
9 LORD JUSTICE SCOTT BAKER: Francs or pounds?
10 MR MANSFIELD: Francs. I am so sorry. He had 30,000 in
11 that. So one has to bear in mind that there is a safety
12 deposit box to be added.
13 Did you make any inquiries of the French banks as to
14 whether there was a threshold -- you were asked it by my
15 learned friend a minute ago -- above which questions get
16 asked for all sorts of reasons, tax and so on?
17 A. I am aware from dealing with the French authorities that
18 it is a subjective-based approach. They don't
19 automatically report a transaction when it reaches, say,
20 50,000 francs.
21 Q. Do all the banks approach it in the same way, as far as
22 you are aware; all subjective, it just depends what they
23 think?
24 A. That is my understanding of the money-laundering regime
25 in France.

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1 Q. That may be in terms of money laundering. Are there
2 other caps that the Government puts on investments and
3 investment accounts and so on?
4 A. I am not aware of that.
5 Q. You are not aware? All right.
6 LORD JUSTICE SCOTT BAKER: Did you ever get an answer to
7 your question about whether he was a member of a casino?
8 A. No, I did not get that and I did not know whether he was
9 receiving any expenses from the Ritz either.
10 MR MANSFIELD: Does it come to this, if I summarise
11 the position, that there are still quite a lot of
12 unanswered questions, are there not?
13 A. There are, yes.
14 MR KEEN: No questions, sir.
15 MR CROXFORD: No, thank you, sir.
16 Questions from MR HORWELL
17 MR HORWELL: I have only a few questions, Mr Laffan.
18 If we can perhaps stand back for a moment.
19 Henri Paul died aged 41, we know. We also know that he
20 had worked for all of his adult life. We know that he
21 had no dependents and it is obviously reasonable for
22 such a man aged 41 to have built up healthy balances in
23 his accounts.
24 A. That was my assessment, yes.
25 Q. His income cannot be determined with any precision

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1 because of tips. We know that on occasions he certainly
2 received very large tips. How many and what amount is
3 impossible to determine. It appears from what you have
4 seen that he invested in shares, and again, how
5 successfully or unsuccessfully, we will never know.
6 A. That is right, sir.
7 Q. That is why you have been at pains to point out
8 throughout your evidence that it is very important, when
9 approaching these two schedules, to bear in mind that
10 the information you had was very limited?
11 A. That is absolutely right, yes, sir.
12 Q. Now, the table number 4, which is possibly the more
13 important of the two, these payments, most of them in
14 cash coming into his accounts, in the plural, from
15 December 1996.
16 If we take a few moments -- and it will only be
17 a few moments, I promise -- just to look at the details,
18 if we look at the first account that is mentioned,
19 the Barclays account, 101, that in fact was opened in
20 1993 and you were only given records going back to
21 December 1996. Is that right?
22 A. Yes, that is right, sir.
23 Q. So, as an example, we are missing three years of
24 accounts or statements for that account.
25 A. We are, yes.

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1 Q. If we go to the next individual account that is referred
2 to on the table, Caisse d'Epargne, ending "435", that,
3 in fact, was opened in 1981 and you had records going
4 back to November 1996 only.
5 A. That is right, yes.
6 Q. So 15 years of missing statements. The next account is
7 about six further down the list. This is the next new
8 account in terms of details on this list: BNP, ending
9 "65". In fact, you do have the complete records for
10 that -- is that right?
11 A. I --
12 Q. -- because that payment on 19th June 1997 -- the account
13 was opened on 10th June.
14 A. Yes. I say that we have complete records; we have
15 the account statements. Unfortunately we have nothing
16 behind the transactions.
17 Q. All right, but this is one instance where you do in fact
18 have all the statements?
19 A. That is right, sir.
20 Q. The reason for that is because of the very late opening
21 of that account.
22 Finally, three entries down, this is Barclays ending
23 "801", that account opened in October 1992 and you only
24 had records going back to October 1996. So four years
25 of missing statements?

107

1 A. Yes, that is right.
2 Q. So, whether or not this is a pattern, again, impossible
3 to say?
4 A. It is right. That is impossible.
5 Q. This activity may have been taking place for years; we
6 will never know.
7 A. Yes, and also he did have opening balances at the time
8 that we first got his accounts that were reasonably
9 high. So the Caisse d'Epargne account was consistently
10 a reasonably high balance from the time that we first
11 started getting records.
12 Q. Ideally you would have liked statements going back at
13 least two years and preferably longer?
14 A. Well, in the work I do in this country, we would
15 normally go back six years. That would normally be
16 the starting point.
17 Q. Thank you. Other information that is not available to
18 you which would have been of considerable assistance,
19 his tax returns?
20 A. Absolutely, yes.
21 Q. His probate?
22 A. That, to me, is a fundamental file. That would give
23 a lot of detail about his liabilities as well because,
24 of course, we don't know how much money he owed to
25 offset the balances in his accounts and we don't have

108

1 any details of his credit card transactions.
2 Q. Well, Mr and Mrs Paul are represented in these inquests,
3 Mr Laffan, and I ask if they can assist in any way,
4 through you, to produce tax returns, probate and credit
5 card statements.
6 A small matter, and it can only be a small matter,
7 but simply again to emphasise the incomplete nature of
8 the records concerning the financial life of Henri Paul:
9 we know he had a flat. It was rented to a student,
10 Sylvie Lambert. So one can anticipate that the amount
11 of money was not considerable. But there is no record
12 in the accounts that you have for payments of that rent
13 by her to him, indicating that the payments were
14 probably in cash?
15 A. That is right, yes.
16 Q. So, again, that is another source for his income.
17 A. Another area was the expenses from the Ritz. I do not
18 know how they were paid and whether he received them,
19 but that would again have been a helpful -- that would
20 be helpful background information really when looking at
21 these sorts of transactions.
22 MR HORWELL: Mr Laffan, thank you.
23 LORD JUSTICE SCOTT BAKER: Mr Hilliard?
24 MR HILLIARD: Thank you very much.
25 LORD JUSTICE SCOTT BAKER: Mr Laffan, that is all

109

1 we require. We are very grateful. Thank you very much.
2 I think it is sensible to have the break now and
3 then continue with Mr Quaife.
4 (3.08 pm)
5 (A short break)
6 (3.22 pm)
7 LORD JUSTICE SCOTT BAKER: Mr Quaife, please.
8 MR MARTIN QUAIFE (sworn)
9 LORD JUSTICE SCOTT BAKER: Do you prefer to sit or stand?
10 A. I prefer to sit, please, sir.
11 Questions from MR HOUGH
12 MR HOUGH: Is your name Martin Quaife?
13 A. Yes, sir.
14 Q. As I have explained, I will ask you questions first on
15 behalf of the Coroner.
16 I think you were on duty as a member of
17 Mr Al Fayed's operations room staff on the night of
18 30th/31st August 1997 at Park Lane.
19 A. That is correct, sir, yes.
20 Q. You gave a witness statement to the British police in
21 May 2005.
22 A. Yes, sir.
23 Q. Then, last month, you gave two statements to
24 Mr Al Fayed's lawyers, and those statements were made
25 specifically in relation to the daily occurrence book?

110

1 A. Yes, sir.
2 Q. They were made after questions had been raised in this
3 court?
4 A. I believe they were, yes.
5 Q. Although those statements make a number of additional
6 points and a couple of changes to your previous evidence
7 in relation to the daily occurrence book, in those
8 statements you don't change anything else in your
9 statement you made to the British police?
10 A. No, sir.
11 Q. Now can I deal just briefly with your background? You
12 spent, I think, six years in the Royal Merchant Police
13 before you joined Mr Al Fayed's security operation?
14 A. Yes, sir.
15 Q. You joined it in 1995?
16 A. Yes, sir.
17 Q. You began it as a member of the team covering
18 the Park Lane residence?
19 A. That is correct, sir, yes.
20 Q. You were working there in August 1997 and you later,
21 I think, became team leader at the Park Lane residence?
22 A. Yes, sir.
23 Q. Then, at the time of your statement to the British
24 police in May 2005, you were security collator at
25 Harrods?

111

1 A. Yes, sir, that is correct.
2 Q. What post do you currently hold?
3 A. It is the same post I hold today.
4 Q. Dealing with the structure of the Park Lane residence
5 team, I think at any one time, in any one 24-hour
6 period, there would be five staff on duty; four staff
7 members and one team leader?
8 A. That is correct.
9 Q. I think this is right, that you worked rotas: seven days
10 on and seven days and nights off; seven nights on, seven
11 days and nights off?
12 A. That is correct, sir, yes.
13 Q. I think you changed on Tuesday?
14 A. Yes.
15 Q. And you worked 12-hour shifts, changing at 8 am and
16 8 pm?
17 A. Predominantly, yes.
18 Q. During the day, there were two staff on duty with a team
19 leader also on duty?
20 A. Correct.
21 Q. During the night, there were two staff on duty and
22 the team leader on call?
23 A. Yes, sir.
24 Q. Is this right also, that during the night one of the
25 staff members at any one time would sit in

112

1 the operations room --
2 A. Yes, correct.
3 Q. -- and one would sit in a security cabin at the entrance
4 to number 60 Park Lane, which was called "the bubble"?
5 A. That is correct.
6 Q. At 11 pm, I think the building would be locked down, and
7 after that, there would be regular foot patrols --
8 A. Correct.
9 Q. -- by one of the two staff members?
10 A. Yes, sir.
11 Q. Is this right as a whole -- it is certainly what has
12 been said by the others -- that the phones in
13 the operations room would be manned by at least one
14 person at all times?
15 A. That is correct, sir, yes.
16 Q. Also, when taking over a shift, would the two staff
17 members coming on duty receive a briefing from those who
18 had been on duty?
19 A. Normally, yes, sir.
20 Q. Would that be expected to include details of where all
21 members of the Al Fayed family were?
22 A. Yes.
23 Q. Is this right, that the staff on duty would know where
24 all members of the family were because their movements
25 would be called in by their bodyguards?

113

1 A. Yes, sir.
2 Q. Can I turn now to the daily occurrence book?
3 You deal with this towards the bottom of page 2 of
4 your statement to the British police, as well as in your
5 two subsequent statements. I think this is also right,
6 that yesterday Mr Al Fayed's lawyers wrote a letter to
7 the Coroner's secretariat and to all interested persons
8 which set out some more information which you had on
9 this topic.
10 A. It did, sir, yes.
11 Q. You have seen that?
12 A. Yes, I have a copy.
13 Q. When you spoke to the British police, you were asked
14 about the physical characteristics of the daily
15 occurrence book and how it was used.
16 A. Yes, sir.
17 Q. In this respect you have always maintained this
18 particular version, that the page on the left of the
19 book was a chart entitled "Occurrences" and the page on
20 the right was entitled, I think, "Details and taskings".
21 A. That is correct, sir, details of occurrence and details
22 of taskings, yes.
23 Q. The occurrences section was mostly devoted to recording
24 the movements of family members?
25 A. Yes, sir.

114

1 Q. And the taskings included all kinds of tasks that you
2 and other members of staff were recording for yourselves
3 to perform?
4 A. That is correct, sir, yes.
5 Q. Now you told Operation Paget, in 2005, that the daily
6 occurrence book was a loose-leaf lever-arch file in
7 which any number of pages would be put and pages could
8 be added and taken out at will.
9 A. That is correct, sir, yes.
10 Q. But I think you have subsequently indicated that that
11 was a mistake; that was the way it operated in 2005, but
12 not the way it operated in 1997.
13 A. That is correct, sir, yes.
14 Q. I think that your evidence now is that, in 1997,
15 the daily occurrence book would come as a series of
16 pages bound together by a green plastic spine with
17 spiral binding?
18 A. That is correct, sir, after seeing the original DOB,
19 yes.
20 Q. I would like to check one other thing that you said
21 about the daily occurrence book to Operation Paget in
22 May 2005. This is page 3 of your statement. It is the
23 third full sentence down.
24 "At that time, we used to encrypt the entries in
25 the DOB. The encryption we used was a simple one that

115

1 we would make up on ABCD sheets and would be rotated
2 regularly. In effect there were four sets of
3 predetermined codes under the headings A, B, C or D and
4 these would be changed on a regular basis."
5 Now "at that time" refers there back to 1997,
6 doesn't it?
7 A. Yes, sir, yes.
8 Q. Is this right, that you were telling Operation Paget in
9 2005 that the DOB was prepared in an encrypted form in
10 1997?
11 A. Yes, sir.
12 Q. With this ABCD code?
13 A. It would be.
14 Q. Turning to what would be in the occurrences section of
15 the DOB, the vast majority of that would be family
16 movements, is that right?
17 A. Yes, sir, that is correct.
18 Q. We have heard from several witnesses who have given
19 evidence that bodyguards would be expected to call in
20 every significant movement.
21 A. Yes, sir.
22 Q. That is your understanding as well, is it?
23 A. That is correct, sir, yes.
24 Q. Now, after the daily occurrence book had been used up,
25 I think it is your evidence that it would be placed in

116

1 an envelope and archived.
2 A. That is correct, sir, yes.
3 Q. Do you know where it would be archived?
4 A. I believe in 1997 it went round to Alison Smith.
5 Q. Where was she based?
6 A. In 55 Park Lane.
7 Q. Do you know how long a daily occurrence book would be
8 kept for?
9 A. No.
10 Q. Turning to another matter of background, this is your
11 experience of your principals and specifically of
12 Dodi Al Fayed. This is pages 4 and 5 of your statement
13 to the British police. I think you have driven a number
14 of members of the Al Fayed family on quite a number of
15 occasions.
16 A. Yes, sir, that is correct.
17 Q. You say this about that experience at the bottom of
18 page 4:
19 "The SOPs [that is standard operating procedures,
20 I think] that we worked to would dictate that seat-belts
21 should be worn by the principals. I would always try to
22 get them to belt up. I did this rather cheekily by just
23 sitting looking at them without starting the engine.
24 This did not always work. I would use this same tactic
25 if I was driving Dodi, but it did not always work with

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1 him. Nine times out of ten, if he was accompanied by
2 someone, he would sit in the back in any event and
3 rarely, if ever, would wear seat-belts in the rear."
4 Then you make a comment about Mr Al Fayed Senior's
5 brothers.
6 Is that a fair summary of your experience of driving
7 Dodi Al Fayed and other members of the family?
8 A. Yes, sir.
9 Q. Also in these inquests, we have heard various accounts
10 of Dodi Al Fayed's attitude to security. I would like
11 to quote something you say in your statement about that
12 and see if that is a fair summary as well. It is
13 further down page 5, the third main paragraph. You say
14 this:
15 "I thought Dodi was a lovely guy, but I thought his
16 stint at Sandhurst had made him into a wannabe officer
17 and he treated us in an accordingly manner because of
18 that. Generally Dodi was interested in what we were
19 doing and was security conscious. But his knowledge was
20 limited and like with many things a little knowledge can
21 be a dangerous thing. Sometimes he would try and go
22 solo, by which I mean he would take the two-way radio
23 from his BG [his bodyguard] and then try to lose his
24 security when they tried to flank him. On occasion,
25 under these circumstances, it was necessary to send out

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1 a couple of guys to keep him under surveillance from
2 a distance."
3 Is that the experience that you had of working at
4 the operations centre for some years?
5 A. Yes. One point to comment there, when Operation Paget
6 took the statement, what is added to there is generally,
7 if he went to his private members' club at the end of
8 South Street, that is when he would try to go solo, so
9 we are only talking a matter of a few hundred metres,
10 just to clarify.
11 Q. So you would like to qualify what you have said about
12 that by saying --
13 A. That was in the original notes to Paget, but this came
14 in the statement.
15 Q. I see. Other than that qualification, is that paragraph
16 that I have just read out a fair summary of your
17 evidence?
18 A. Yes, sir.
19 Q. Can we now turn to 30th and 31st August 1997? We have
20 heard that you were on duty on that night. I think
21 the other person on duty with you was a gentleman called
22 Shaun Smith.
23 A. That is correct, sir, yes.
24 Q. You would have started at 8 o'clock in the evening?
25 A. Yes.

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1 Q. 9 o'clock French time, obviously.
2 In your statement you say that you don't have any
3 specific recollection of the handover briefing and what
4 you might have been told about family positions and
5 movements.
6 A. No, sir, I do not.
7 Q. But, in any event, that briefing would have indicated
8 where the different members of the family were?
9 A. Yes, sir.
10 Q. Now, Shaun Smith recalls that he did the first stint of
11 the evening in the operations room; that is to say he
12 spent an hour and a half in the operations room at
13 the start, from 8 o'clock onwards, while you spent that
14 period in "the bubble".
15 A. That is correct, sir, yes.
16 Q. So that would put you in the operations room from
17 9.30 pm to 11.00 pm; 10.30 to midnight French time.
18 Now the daily occurrence book was provided in
19 summary form by Mr Macnamara, Mr Al Fayed's head of
20 security, some years ago, and then last month
21 we received the original that you had been referring to.
22 Can we just have up on the screen [INQ0005674]? Can
23 we maximum that?
24 Now, as you will see here, this is a summary
25 prepared of the entries in the daily occurrence book for

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1 family movements, but only those relating to
2 Dodi Al Fayed and the Princess of Wales. We will see
3 there that there are no calls recorded for the dates
4 28th or 29th August.
5 A. That is correct, sir, yes.
6 Q. These inquests have heard evidence of phone records of
7 Kieran Wingfield, one of the bodyguards stationed with
8 Dodi Al Fayed, and those phone records five telephone
9 calls to the operations room on 28th August and two
10 calls on 29th August, some of those calls using up quite
11 a number of units. That would, on its face, indicate
12 that some calls had been made and entries had not
13 resulted from those calls. Do you see what I mean?
14 A. I can see the assumption, yes.
15 Q. Is it right, on that basis, for us to take away from
16 that that some calls were made and no log entry was
17 made?
18 A. Yes. It is dependent on the family members' movements.
19 If they are still, as they are, in Sardinia on the boat,
20 if they have not moved location, Trevor or Kes would
21 ring up and say "We are still in the same place".
22 Q. So you don't think a log entry would be made in
23 the principals were in a position where they had been at
24 the time of the previous call?
25 A. Yes.

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1 Q. So when you see, at 21.50 on 21st August 1997,
2 "Dodi Al Fayed and Diana on the Jonikal" and then, on
3 24th August, 9.45, "Dodi Al Fayed and Diana at
4 Portofino", then on 26th August, "Off Sardinia in
5 the morning", and then 27th August, "Moving to the other
6 side of the island", you are indicating that all that
7 would be recorded are significant movements?
8 A. Yes, sir, that is correct.
9 Q. Looking further down the page, 30th August, 1997, we see
10 that calls are logged at 11.35, indicating that they had
11 got on the Gulf Stream to go to Paris; at 20 past 2 in
12 the afternoon to indicate their arrival in Paris; 20
13 past 3, their journey from the Villa Windsor to
14 the Ritz; then a gap; 20.50, indicating that they are at
15 the Ritz; then a further gap until after the tragic
16 crash. These are, of course, English times.
17 Now we know that Dodi Al Fayed and the
18 Princess of Wales went back to the Rue Arsene Houssaye
19 apartment and then back to the Ritz between 15.20 and
20 20.50. Of course, you would have been on duty for part
21 of that time.
22 A. Yes, sir.
23 Q. Are you able to say whether calls were made and not
24 logged or whether no calls were made?
25 A. No, I cannot, I am afraid. I cannot say whether calls

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1 were made or not.
2 Q. Can I ask you about one specific call to see whether you
3 have any recollection of this occurring a little later?
4 There is CCTV evidence from the Ritz which shows
5 Trevor Rees-Jones on his mobile phone at about 20 to
6 midnight French time, 20 to 11 English time. He has
7 said -- this is transcript 23rd January, page 94 -- that
8 he believes he was calling the operations room to give
9 journey details and plans for the following day. That
10 would have been when you were on duty and in the
11 operations room itself. If he made that call, according
12 to this summary, it would not have been logged?
13 A. If he was passing details of possible movement
14 the following day, it would have been logged.
15 Q. So do you believe that the call was never made?
16 A. Yes, sir.
17 Q. Do you believe that because it is not on the sheet and
18 it should be on the sheet?
19 A. Yes, sir.
20 Q. Can you recall now, at ten years' distance, what calls
21 you actually received that night?
22 A. I can certainly remember the call from Kes.
23 Q. I am sure you can remember that call, but can you
24 remember what other calls you received in the evening?
25 A. No, sir, I am afraid I can't.

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1 Q. Are you aware that the position with Trevor's calls
2 cannot be checked conclusively because his call records
3 of the phone, belonging I think to Mr Al Fayed's
4 organisation, have never been located?
5 A. I am aware of that, sir, yes.
6 Q. Obviously, on the basis of your evidence so far, you
7 have no recollection of being informed about the decoy
8 plan in advance?
9 A. No, sir.
10 Q. You say this about the decoy plan at page 6 of your
11 statement, right at the bottom of the page. It is
12 the last three sentences:
13 "I was unaware of and had nothing to do with
14 the decoy plan. My understanding was that Mr Al Fayed
15 and his son dealt with it. If I had known of it,
16 I would have voiced a negative opinion about it."
17 Let me take that piece by piece. What led you to
18 have the understanding that Mr Al Fayed and his son
19 dealt with the decoy plan?
20 A. As far as I recollect, it was from after speaking with
21 Kes.
22 Q. You were on duty in the operations room talking to quite
23 a lot of people, weren't you?
24 A. For which timeframe? Could you be a bit more specific?
25 Q. In the immediate aftermath of this collision.

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1 A. I was, yes.
2 Q. If you had received information to contradict what Kes
3 said, would you have formed the understanding that
4 Mr Al Fayed Senior and his son had dealt with the decoy
5 plan?
6 A. Could you please be a bit more specific?
7 Q. You formed the understanding that Mr Al Fayed Senior and
8 his son had dealt with the decoy plan.
9 A. Yes, sir.
10 Q. We have heard evidence that that was what Mr Wingfield
11 had been told directly by Dodi Al Fayed. That is what
12 he has said. It has obviously been challenged, but that
13 is what he has said.
14 If you had been in the operations room and had heard
15 other people telling you that this decoy plan had never
16 been called into anybody, never been approved by
17 anybody, and then, on the other hand, had Kes come and
18 say, "This is what Dodi told me", you would not have
19 been able to form a clear understanding, as you did in
20 your statement, that Mr Al Fayed Senior and his son had
21 dealt with it, would you?
22 A. No, sir.
23 Q. So is it right to say that the only information that you
24 had was that from Kieran Wingfield?
25 A. Yes, sir.

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1 Q. And nobody else said anything else to contradict that?
2 A. No, sir, not at all.
3 Q. You also say here that if you had known about the decoy
4 plan, you would have voiced a negative opinion about it.
5 A. That is correct, sir.
6 Q. Why is that?
7 A. Because they were due to leave without a back-up
8 vehicle.
9 Q. And that is against good security procedure?
10 A. Certainly at that present moment in time it was, yes.
11 Q. Can I ask you a few brief questions finally about
12 the way the daily occurrence book has come to us, just
13 to understand that. In your statement at page 7, you
14 say that sometime after the tragic events of late
15 August, you were asked by the security manager,
16 a Mr Black, to decipher the encrypted pages of the DOB,
17 and that, after you had done so, they were taken to
18 Mr Macnamara's office.
19 A. That is correct, sir, yes.
20 Q. Mr Macnamara has said in a statement that he received
21 the original of the book from Paul Handley-Greaves and
22 that he then prepared the summary which is on the screen
23 at the moment. Is that right?
24 A. No, the summary I prepared.
25 Q. So you prepared the summary?

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1 A. Yes, sir.
2 Q. Can we look at [INQ0060344]? This is one page of the
3 daily occurrence book which was provided in court last
4 month. We see there the entries, some of which we have
5 been looking at; for example, at 20.50, "DF and DW at
6 the Ritz"?
7 Do you see that?
8 A. Yes, sir.
9 Q. It may be my mistake or misunderstanding, but this does
10 not seem to be encrypted in an ABCD code.
11 A. No, it was not, no.
12 Q. So is it the case that the daily occurrence book was not
13 encrypted in 1997 or is there an original which was
14 encrypted and which has been transcribed into this?
15 A. As you can see from previous entries, at 11.35, the
16 third down from the top, "Eagle and Springbok towards
17 G4".
18 Q. "Eagle" I think is Dodi Al Fayed and "Springbok" is
19 Diana?
20 A. That is correct, sir, yes.
21 Q. Those are obviously code names, but is that an
22 encryption using an ABCD code?
23 A. The sheets A, B, C or D, would have had names for
24 specific family members.
25 MR HOUGH: I see. Thank you very much. That is very

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1 helpful.
2 A. Thank you, sir.
3 LORD JUSTICE SCOTT BAKER: Mr Mansfield?
4 Questions from MR MANSFIELD
5 MR MANSFIELD: My name is Michael Mansfield. I represent
6 Mohamed Al Fayed. A few questions: if I can start with
7 the sheet, if we could have that last sheet back up
8 again, the handwritten sheet.
9 Can we have the reference for the handwritten sheet
10 because I do not have it on this?
11 MR HOUGH: [INQ0060344], I think.
12 MR MANSFIELD: Thank you. I just want to ask you about that
13 page that you see there, particularly in relation to the
14 30th for example. Is any of the writing yours?
15 A. Towards the bottom, 21.15 and 23.50, they are my
16 entries, sir.
17 Q. So, just looking at it carefully, does it mean that
18 the whole of those two entries are yours?
19 A. The top two on the page, 05.05 and 07.30.
20 Q. The top two?
21 A. Yes.
22 Q. So, in other words, the entry alongside those times is
23 all written by you?
24 A. Yes, sir.
25 Q. I just want to ask you some questions, obviously again

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1 about the 30th in particular.
2 In relation to the gap that you have already been
3 asked about, that is the one at 15.20 -- and I
4 appreciate I am just asking you in principle -- you see
5 that "DF and Diana from Villa to Ritz", and then there
6 is a gap until 20.50. We know that in fact there was
7 movement, as has already been pointed out, the movement
8 being from the Ritz back to the apartment, towards
9 a restaurant and then finally back to the Ritz. That
10 all fills part of that gap. Do you follow?
11 A. Yes, sir, I do.
12 Q. Are those kind of movements meant to be, as it were,
13 transmitted to the ops room by the bodyguards?
14 A. Yes, sir, they are.
15 LORD JUSTICE SCOTT BAKER: Or if they were not, you would
16 think that they were at the Ritz when in fact they were
17 at the apartment.
18 A. That is correct, sir, yes.
19 MR MANSFIELD: I appreciate, of course, that there is
20 a possibility, and I put it this way: there is
21 a possibility they were, is there, and somebody did not
22 record it? Is that possible?
23 A. It is a possibility, yes.
24 Q. So that can happen?
25 A. Yes.

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1 Q. But there is a movement which does not get recorded --
2 either does not get transmitted in the first place when
3 it should be or is transmitted and then is not entered
4 up as it should be?
5 A. That is a possibility, yes.
6 Q. Those are mistakes that can happen. I just want in
7 principle to know what should be going into the log from
8 time to time.
9 Plainly there comes -- after the next entry, 20.50,
10 after that we know, of course, that there is firstly
11 a decoy plan and, secondly, a departure from the rear of
12 the Ritz towards the Alma Tunnel. Now, in principle
13 again, a departure from the Ritz should be transmitted
14 to the ops room?
15 A. That is correct, sir, yes.
16 Q. And if it is, should be entered up?
17 A. Yes.
18 Q. Now, as far as the ops room is concerned, the people on
19 duty in the ops room that night -- you were on duty for
20 part of it?
21 A. Yes, sir.
22 Q. How long had you been doing the job by this time?
23 A. Over two years.
24 Q. And the other people on duty that night --
25 A. Shaun Smith.

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1 Q. How much experience had he had?
2 A. He had only recently joined the organisation.
3 Q. Now, leaving aside the question of transmitting the time
4 that they are leaving, which ought to be transmitted,
5 and if it is, ought to be entered up, the next question
6 is the decoy plan. Now, several questions arising out
7 of that: first of all, I do not know whether you can
8 help about this, but if a bodyguard is concerned about
9 the security of a certain plan that is being talked
10 about and its safety and so on, is there any problem
11 about them ringing up the ops room to express a concern?
12 A. None at all, no.
13 Q. In fact, is that what they should do?
14 A. It is their choice. On the ground they would either
15 come through to us or they might go direct to
16 Paul Handley-Greaves or even higher.
17 Q. So they have a choice of avenue?
18 A. They do indeed, sir.
19 Q. The most obvious one is to come through to you and say
20 "Look, I have a problem"?
21 A. Possibly, yes.
22 Q. If it isn't the most obvious, what is the most obvious?
23 A. From past experience, if it was to do with Dodi, then
24 primarily he might well have gone to Mr Al Fayed direct.
25 Q. Direct to Mr Al Fayed.

131

1 Now, just dealing with calls direct to Mr Al Fayed,
2 again, is there any problem for a bodyguard to ring up
3 Mr Al Fayed at this time?
4 A. No, not at all. Certainly with people that work with
5 members of his family, it is a very precious job that
6 they do for him, so yes.
7 Q. No problem to do that.
8 If he did do that, what is the route? Is it through
9 you in the central ops or does he have another number
10 that he rings, not involving the ops room?
11 A. There is another number that he could possibly ring.
12 Q. Or he could come through you?
13 A. Or he could come through us.
14 Q. Plainly, if he went through you, is it something that
15 you would enter up? There is no suggestion he did, but
16 I am trying to work out the principle. If he were to
17 come through you, would it get entered up on the --
18 A. No, sir.
19 Q. That would not. And, of course, if he went direct to
20 Mohamed Al Fayed, not through the ops room, it would not
21 appear on a log?
22 A. No, sir.
23 Q. So there is no problem with him doing that, actually
24 ringing, and you are saying, of course, so far as you
25 are concerned, you knew nothing about it and you would

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1 have said "no" to it?
2 A. Yes, sir, I would.
3 Q. Mainly because there is no back-up?
4 A. Yes.
5 Q. That was a fairly basic principle that had been
6 operating both in London and down there?
7 A. That is correct, sir, yes.
8 Q. Particularly, at that stage, when Princess Diana was
9 accompanying Dodi, whether in London or Paris?
10 A. That is correct, sir, yes.
11 Q. Now, as far as your understanding, when did you get
12 the understanding about a decoy plan having been, as it
13 were, dealt with by others? When did you get
14 the understanding?
15 A. As far as I can recollect, it was when I spoke with Kes.
16 Q. Was it that night?
17 A. Yes, it would have been.
18 Q. So he is telling you.
19 It was put to you, of course, that it was coming
20 from Dodi. We have seen the CCTV and, in fact, there is
21 an issue about really whether it was coming from Dodi or
22 in fact coming from Henri Paul, who does most of the
23 talking on the CCTV. Now did you have any dealings with
24 Henri Paul? Did you know who he was first of all?
25 A. I knew who he was.

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1 Q. Is there any problem about Henri Paul ringing up ops
2 room to say he is worried about a back-up plan?
3 A. As far as I can recollect, he never called us in London.
4 Q. We know -- sorry, I haven't pointed it out -- from
5 the list of numbers found at his address or on his
6 personal organiser, the ops room number is amongst all
7 the numbers he had.
8 A. It probably would be because obviously we would travel
9 with family members to the Ritz from time to time.
10 Q. The way it was put to you is that the information only
11 came from Kes that night. On that night,
12 the information coming to you by Kes, that is after
13 the crash -- can you help -- or before or what?
14 A. The initial call from Kes at 23.45, obviously in
15 a fairly excited state -- he rang and said they had got
16 back to the apartment. As far as he was aware, Dodi and
17 Diana should have been there before them and they were
18 not and Philippe had heard over the radio that there
19 appeared to have been a crash.
20 Q. So, it is around that time that you hear?
21 A. Yes.
22 Q. Now, of course, at that time, you did not speak to
23 Mohamed Al Fayed about this issue at all, did you?
24 A. No, not at all, sir.
25 Q. Of course, as far as Dodi is concerned, you never spoke

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1 to him about this issue either?
2 A. No, sir.
3 Q. So it is not as though you were in a position at 23.45,
4 when Kes tells you this, to say, "Well, that is not
5 the information we have", are you?
6 A. No, sir, not at all.
7 LORD JUSTICE SCOTT BAKER: When you got the information at
8 23.45 that they had not arrived at the apartment and
9 that there had been a crash, did you say, "Well, hold on
10 a minute, we did not know they had moved from Ritz. Why
11 didn't anybody tell us?"
12 A. No, sir. I simply said to Kes, "Look, I need to get
13 confirmation before we do anything".
14 MR MANSFIELD: Of the crash?
15 A. Yes, sir.
16 Q. In fact it appears that that is the next entry at the
17 bottom, that you get confirmation. Do you know who you
18 got that from?
19 A. No, I cannot recall. I believe it would have been Kes,
20 but I am not certain.
21 Q. Could I just go back a little bit earlier in the
22 evening? It may be at a time when you are not entirely
23 on duty, but again, in principle -- what
24 Trevor Rees-Jones is saying is that they come back to
25 the Ritz in the evening after 10 o'clock French time --

135

1 A. That is right.
2 Q. -- and that he leaves the Bar Vendome and he goes
3 outside the hotel and he is on his mobile for ten
4 minutes, he thinks, to the ops room. Would that be
5 a very unusual thing, for a bodyguard to be on the phone
6 for ten minutes to the ops room?
7 A. From past experience, it would not lead me to believe
8 it is an operational call, no.
9 Q. Meaning it does not sound as though it is a call to
10 the ops room?
11 A. No, not at all, sir.
12 Q. Not at all.
13 One other matter. As you know, I represent Dodi.
14 Do you agree that in terms of his personality -- you
15 have used the words "a lovely guy" -- he was charming,
16 he was polite, he was not abusive?
17 A. Yes, sir.
18 Q. Seat-belts: if you asked him either by saying "I think
19 you should wear them" or somebody else has described
20 giving him the nod that he ought to wear them, he put
21 them on, didn't he?
22 A. Yes, generally he did.
23 MR MANSFIELD: Yes. Thank you very much.
24 MR KEEN: No questions, sir.
25 MR CROXFORD: I have no questions, sir.

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1 LORD JUSTICE SCOTT BAKER: Mr Horwell?
2 Questions from MR HORWELL
3 MR HORWELL: Mr Quaife, if you can help us please as to how
4 these occurrence books were physically compiled in 1997.
5 A. Yes, sir.
6 Q. We have a copy of the August 1997 occurrence book. So
7 what would physically happen?
8 A. Generally, leading up to the prior month, an operative,
9 most likely somebody on nights, would be asked to get
10 the DOB ready for the following month. They would print
11 off the said amount of sheets, generally 31 days,
12 31 sheets.
13 As you can see, the first sheet is the title, "Daily
14 occurrence book". The second sheet would generally be
15 details and taskings, but it would be left blank because
16 when we opened it up, we wished as if you could read it
17 like a book, so it was easy for us.
18 What then happened was in those days we used to have
19 a spiral binder. The spiral binder would be attached,
20 opened up, and then the sheets that were punched would
21 be placed in and then it would be shut.
22 Q. So how many sheets for the use of recording events would
23 there be, 31 sheets?
24 A. Yes generally.
25 Q. What would happen if, for whatever reason, the book was

137

1 full before the end of the month? What would happen
2 then?
3 A. As in this case, for continuity, we carried on on loose
4 sheets.
5 Q. Just so that we understand the process: so there would
6 be loose sheets kept?
7 A. Yes.
8 Q. And they would be stapled at the end of the month?
9 A. They would either be stapled at the time, on a daily
10 basis, or at the end of the month.
11 Q. So one might have two pieces of paper stapled together
12 at the end of each day and then that bundle stapled at
13 the end of the month again?
14 A. That is correct.
15 Q. So there would be one staple for each two pages and
16 another staple for the entire bundle?
17 A. Yes.
18 Q. At the end of the month, what would happen to the log?
19 A. It would be archived, put into an envelope and then
20 obviously the date and the year -- month and year,
21 sorry.
22 Q. You have told us that the summary that we have seen,
23 the typed summary, was compiled by you.
24 A. Yes, sir.
25 Q. When did you make that summary?

138

1 A. Sometime after.
2 Q. I want you to be more specific, please, Mr Quaife.
3 When?
4 A. I am afraid I cannot, sir.
5 Q. Help as to roughly when.
6 A. I cannot. I have not got a date.
7 Q. There is a gap of ten years.
8 A. No, sir, not at all.
9 Q. When do you think the summary was made within the ten
10 years that have passed?
11 A. Possibly some weeks or months after. I do not recall.
12 Q. Weeks or months?
13 A. Yes, possibly.
14 Q. It was Mr Macnamara that asked you to make this summary?
15 A. Via Andrew Black, yes.
16 Q. Where were you when you actually made it?
17 A. In Park Lane.
18 Q. And the log was presented to you, was it?
19 A. I would have been given the log, yes.
20 Q. So you had the original log weeks or months after these
21 events and you compiled your summary. What then
22 happened to the log?
23 A. It would have gone back to Andrew Black, I believe.
24 Q. That is the last you saw of it, was it?
25 A. Yes, sir.

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1 Q. What happened to your summary?
2 A. That went with the log to Andrew Black.
3 Q. Now, it is clear, is it not, that during the second
4 cruise, the cruise that Trevor and Kes worked together
5 on, they were unhappy about the lack of information that
6 they were getting from Dodi?
7 A. I believe they were, sir, yes.
8 Q. They made it quite clear to you that they were, didn't
9 they?
10 A. They were unhappy, yes.
11 Q. On this very topic of Dodi's treatment of his security
12 bodyguards and his attitude towards them, here we have
13 one example of Kes and Trevor complaining about a lack
14 of information. There is another example in your
15 statement that has already been referred to of -- your
16 assessment is that because of Dodi's time at Sandhurst
17 and his wanting to be a "wannabe officer", to use your
18 words, that sometimes Dodi would try to "go solo";
19 again, to use your words, Mr Quaife. Now, are you
20 suggesting that this reference to Dodi's "going solo"
21 only applied to his walking 200 metres up the road to
22 his club?
23 A. Certainly from what I recollect, yes.
24 Q. Let's just look at how you put this in your statement,
25 Mr Quaife.

140

1 "Sometimes he would try to go solo, by which
2 I mean he would take the two-way radio away from his
3 bodyguard ..."
4 A. That is correct, sir, yes.
5 Q. Just to go 200 metres up to the club?
6 A. Possibly, yes.
7 Q. "... and then tried to lose his security when they tried
8 to flank him ..."
9 A. That is correct, sir, yes.
10 Q. 200 metres?
11 A. Yes. It is a built-up area.
12 Q. It is 200 metres nonetheless, isn't it?
13 A. Yes, sir.
14 Q. "On occasion, under these circumstances, it was
15 necessary to send out a couple of guys to keep him under
16 surveillance from a distance."
17 A. If need be, yes, sir.
18 Q. These are your words, Mr Quaife.
19 "... necessary to send out a couple of guys to keep
20 him under surveillance from a distance ..." when he was
21 embarking on a journey of 200 yards?
22 A. If it was 200 yards. If it was further, then we would
23 send guys out.
24 Q. Your words, Mr Quaife, not mine. Is this not
25 a reference to Dodi on occasion simply trying to lose

141

1 his bodyguards and not having anything to do with
2 a visit to his club 200 yards away, Mr Quaife?
3 A. No.
4 Q. In your statement again -- and I am only asking you
5 because you make reference to it -- there is a reference
6 to Philippe Dourneau being a dangerous driver.
7 A. Yes, sir.
8 Q. Why did you say that?
9 A. At times it was fairly difficult to try to get him to
10 see from our point of view what we really wanted to
11 achieve if we were in Paris or France.
12 Q. Why do you say that in your assessment Philippe Dourneau
13 was a dangerous driver. What made you say that?
14 A. Generally, if you are a VIP driver, ie you drive in the
15 car in front with the principal, you try to drive for
16 two cars. So your back-up PS vehicle would stay with
17 you at all times for protection, but Philippe generally
18 would not do that.
19 Q. What, he would drive away and leave the back-up
20 vehicle --
21 A. Not intentionally, but if the gap was not there for two
22 vehicles, he would possibly take that route.
23 Q. Did Dodi complain?
24 A. I do not know, sir.
25 Q. The log itself, I only have a few questions to ask you

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1 about it and I really am asking far too much of
2 Mr Foley, I am afraid. Are you able to put up
3 22nd August? I do not have the INQ numbers, but
4 Mr Hough comes to the rescue.
5 MR HOUGH: If it is occurrences for Friday 22nd August with
6 the word "Shaun" in the top left, it is [INQ0060328].
7 MR HORWELL: Yes. That is it. Thank you very much indeed.
8 Are you able to see that, Mr Quaife?
9 A. Yes, sir.
10 Q. If I may sit down. Thank you.
11 The entry at 14.10, I think it is. It is the entry
12 after 13.40. Do you have that?
13 A. Yes, sir.
14 Q. "DF [Dodi Fayed] and Springbok [Princess of Wales] at
15 villa. PHG(P) ..."
16 Can you explain that entry to us, and what
17 the PHG(P) means?
18 A. The entry at 14.10 was written by or came from Gary, who
19 was in the South of France. Outlined was that Dodi and
20 Diana were at the villa, and whoever was on the desk
21 paged Paul Handley-Greaves.
22 Q. "(P)" is for paged?
23 A. Yes, sir.
24 Q. Thank you.
25 And 28th August again, if Mr Hough can be kind

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1 enough please? It is 28th August, details and taskings.
2 MR HOUGH: I think that should be [INQ0060341].
3 MR HORWELL: Thank you.
4 And Mr Foley, if you could maximise the entry for
5 10.31, please?
6 So this is Thursday 28th August. This is a message
7 from "Trevor", Trevor Rees:
8 "DF and DW may stop over in Paris on Saturday
9 night -- PHG ..."?
10 A. "... informed".
11 Q. Thank you. So that was their state of information, that
12 they may be going to Paris; no certainty about it at
13 all?
14 A. That is right.
15 Q. If, finally, please, we could turn to the details of
16 occurrence, 30th August. In fact I have it,
17 [INQ0060344], we have had this already. Now, if we can
18 keep the whole page.
19 If you can see this that, Mr Quaife, you have
20 indicated that the initials two at the top and two at
21 the top, "MQ", are yours?
22 A. That is correct, sir.
23 Q. The other writing on that page; there are not many
24 initials, can you help?
25 A. The one below mine at the top, "MB", would be more than

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1 likely Mark Browning(?). The one below that, "DM", is
2 David Moody and then the entry at 17.20 looks like
3 Steven Horvath.
4 Q. Right.
5 A. And the entry at 20.20 is obviously Shaun Smith.
6 Q. Not a lot occurring, was there?
7 A. No, sir.
8 Q. Is that normal for a Saturday?
9 A. It could be. Yes, sir.
10 MR HORWELL: Thank you.
11 Further questions from MR HOUGH
12 MR HOUGH: I have just one matter to raise in view of that
13 last answer.
14 We have heard evidence from Mr Wingfield that in
15 general -- this is 29th January at page 199 -- that
16 there would have been pages and pages of logging that he
17 would have expected, given in general what had been
18 happening those two days.
19 Do you regard the amount of log entries as unusually
20 and remarkably few, given the movements of principals
21 around Paris?
22 A. No, sir, not at all.
23 MR HOUGH: Thank you.
24 LORD JUSTICE SCOTT BAKER: When was your last contact with
25 Paul Handley-Greaves?

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1 A. I cannot put a date to it, sir. I think it would have
2 been shortly after 1997, early 1998 possibly.
3 LORD JUSTICE SCOTT BAKER: You have no idea where he is now?
4 A. No, sir. I am afraid not.
5 LORD JUSTICE SCOTT BAKER: Thank you very much. Thank you.
6 That is all for you and all for today and we are
7 grateful to you for coming to give evidence.
8 A. Thank you, sir.
9 LORD JUSTICE SCOTT BAKER: The morning, we have videolink
10 from Paris again. Half past nine, members of the jury.
11 (4.20 pm)
12 (The hearing was adjourned until 9.30 am
13 on Wednesday, 6th February 2008)
14
15
16
17
18
19
20
21
22
23
24
25

146

1 INDEX
2
3
4 MR JEAN-CLAUDE MULES (affirmed) ................. 1
5
6 Questions from MR HILLIARD ................ 1
7
8 Questions from MR MANSFIELD ............... 38
9
10 Questions from MR KEEN .................... 47
11
12 Questions from MR CROXFORD ................ 62
13
14 MR PAUL LAFFAN (sworn) .......................... 70
15
16 Questions from MR HILLIARD ................ 70
17
18 Questions from MR MANSFIELD ............... 87
19
20 Questions from MR HORWELL ................. 105
21
22 MR MARTIN QUAIFE (sworn) ......................... 110
23
24 Questions from MR HOUGH ................... 110
25

147

1 Questions from MR MANSFIELD ............... 128
2
3 Questions from MR HORWELL ................. 137
4
5 Further questions from MR HOUGH ........... 145
6

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