Hearing transcripts

17 March 2008 - Morning session

1 Monday, 17th March 2008
2 (9.30 am)
3 (Jury present)
4 LORD JUSTICE SCOTT BAKER: Mr Burnett, just before we begin,
5 there is one matter I want to raise with Mr Keen.
6 Mr Keen, I made a direction that everybody should
7 provide written submissions on the law by 4 o'clock on
8 Friday afternoon. Everybody else, except for your
9 client, managed to provide written submissions with hard
10 copies by the deadline.
11 A message came after the deadline that Mr Benson
12 required an extension. That was refused and
13 the submissions eventually arrived at 20 minutes past 6
14 on email with no hard copies, thus causing considerable
15 inconvenience to the tribunal and everybody else.
16 Now, orders of that kind are made to be complied
17 with and any competent solicitor with the resources of
18 Mr Benson ought to have been able to comply with it and
19 if there was any problem, the court should have been
20 informed in good time.
21 I trust that nothing like this will happen again.
22 MR KEEN: I am sure it will not, sir. If I could add this
23 explanation; it was in fact necessary that instructions
24 should be taken on one particular matter from
25 the parents of the late Henri Paul and in order to do

1

1 that, Mr Benson was in fact in Paris, trying to speak to
2 Maitre Meyer, the Paris lawyer for the Pauls and in
3 light of that, there was some delay and Mr Benson did
4 advise the Secretary to the Tribunal that some slight
5 delay had been encountered.
6 LORD JUSTICE SCOTT BAKER: He did not advise the Secretary
7 to the Tribunal until after the deadline had passed.
8 That is unacceptable and it is also unacceptable that
9 other parties plainly had the submissions, including
10 the Ritz Hotel, well in advance because they are
11 referred to in their submissions. It is not good
12 enough, there is no excuse and it is not to happen
13 again.
14 MR KEEN: With respect, the other parties did not have the
15 submissions well in advance, the Ritz Hotel had a copy
16 of the draft submission in advance, in respect of which
17 instructions had to be taken before it could
18 be intimated further --
19 LORD JUSTICE SCOTT BAKER: In which case there is no reason
20 why the tribunal should not have had a draft as well
21 with the point being made that there might have to be
22 was some particular problem about getting instructions.
23 MR KEEN: That is the position, sir.
24 LORD JUSTICE SCOTT BAKER: Matters of this kind cause
25 considerable disruption to the organisation of the

2

1 inquests and it is very difficult to keep to the
2 timetable if people like your instructing solicitor do
3 not comply with what is required. Thank you.
4 MR KEEN: All I can say is that reasonable efforts were made
5 to comply --
6 LORD JUSTICE SCOTT BAKER: They plainly were not and one
7 might have expected an apology. But there we are.
8 Yes, Mr Burnett, Mr Roulet.
9 MR CLAUDE ROULET (recalled)
10 (evidence via videolink)
11 LORD JUSTICE SCOTT BAKER: Thank you for coming back again,
12 Mr Roulet.
13 A. You are welcome.
14 Questions from MR BURNETT
15 MR BURNETT: Now, sir, Mr Roulet gave evidence on 5th and
16 6th December last year and so has already been sworn and
17 there is one additional or two additional matters that
18 he wishes to draw to the attention of the jury.
19 Can you hear me okay, Mr Roulet?
20 A. I can hear you, yes.
21 Q. As I mentioned, you gave evidence on 5th and 6th
22 December. You were in London on that occasion?
23 A. Yes, I was.
24 Q. And you took the oath on that occasion and so it is not
25 necessary for you to take it again as you are still

3

1 bound by your oath. You understand that?
2 A. That is right, yes.
3 SECRETARY TO THE INQUEST: Mr Burnett, we are hearing
4 the sound back in Paris when (inaudible).
5 MR BURNETT: I am afraid, Miss Gaffney, I cannot even begin
6 to describe what it sounds like here. Let me try for
7 a few moments more and if the link is bad, we will have
8 to redial. How am I sounding now?
9 SECRETARY TO THE INQUEST: You are sounding clearer and
10 the echo has gone. Thank you, sir.
11 MR BURNETT: Amazing.
12 Mr Roulet, I was indicating, and I think this is now
13 the third time, you were here on 5th and 6th December
14 and you gave evidence in London and in English, so
15 although the interpreter is next to you, it may be that
16 he will have an easy few minutes at least to begin with
17 today. Mr Roulet, can I remind the jury through you who
18 you are. You were the assistant to Mr Klein; that is
19 right, isn't it?
20 A. That is right, yes.
21 Q. And you gave evidence before the jury about a number of
22 matters which included going to the Chez Benoit
23 restaurant and waiting for Dodi and Diana, yes?
24 A. Yes, that is right.
25 Q. And your involvement with Repossis and so forth?

4

1 A. Exactly so. Yes.
2 Q. Now, you can be assured that you are not going to have
3 to go over all of that again. It is simply some
4 additional matters that I wish to ask you about. Now,
5 Mr Roulet, once you got back to France after giving your
6 evidence, did you look at the Coroner's website to read
7 the evidence of a number of other witnesses?
8 A. Yes, that is what I did.
9 Q. And amongst those witnesses whose evidence you read, did
10 you look at the evidence of M Musa and M Dourneau?
11 A. Yes, I did.
12 Q. Now, again, the jury will remember that M Dourneau was
13 the chauffeur and M Musa was concerned with
14 Etoile Limousine; is that right?
15 A. Yes, that is right.
16 Q. Now, you told us in the course of your evidence when
17 we saw you in December that after the tragedy, some time
18 after the tragedy, you had gone to the Alma Tunnel.
19 A. Yes.
20 Q. And that is right, is it?
21 A. It was during the night, around 20 or half past 1 at
22 night.
23 Q. And when you looked at the evidence of M Dourneau and
24 M Musa, did something come back into your mind,
25 concerning your visit to the Alma Tunnel?

5

1 A. Yes, suddenly, after reading M Musa and M Dourneau's
2 witness, I again tried to know why M Musa always says he
3 met me at the Ritz before the accident, and suddenly it
4 came that I met him with M Dourneau after the accident
5 at the Alma Tunnel.
6 Q. Just to take that in stages, maybe the jury will
7 remember that M Musa thought you were still at the Ritz
8 towards the end of the evening but that was not right
9 and we were able to verify that via the video footage.
10 Do you remember?
11 A. Yes, that is right.
12 Q. And so the memory that came to you was that you had met
13 M Dourneau and M Musa after the crash, at
14 the Alma Tunnel?
15 A. Exact, yes.
16 Q. Then we will come on to what happened there, but is it
17 right that you mentioned that both to Mr Witchell of the
18 BBC and you then got in touch with one of the Coroner's
19 officers, Mr Easton?
20 A. Well, it was -- no, on 10th December, it was on
21 10th December that I remembered this. I sent
22 immediately a text message to Mr Easton to call me back
23 when he comes out of the court. That is what he did.
24 I explained him that I remembered this, this fact, and
25 he told me he would inquire what I have to do and I did

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1 not heard any news any more from him. So when I was
2 interviewed by Mr Witchell, I spoke to him about this.
3 And Mr Witchell suggested that I contact directly
4 the office of the Coroner.
5 Q. I see. And that is what happened and then in due course
6 you made another short statement?
7 A. That is it. Yes.
8 Q. Do you remember anything of the conversation that you
9 had with M Dourneau and M Musa in the tunnel after
10 the crash?
11 A. Yes, I remember clearly. They were both very nervous,
12 a little bit anxious. They came to me, speaking both
13 together, and they said, "You know, we have seen that
14 Mr Paul was not in a normal state". I remember even
15 M Dourneau's word; "Il etait un peu pompette".
16 Q. Can you tell us what that means?
17 A. What that means --
18 THE INTERPRETER: "He seemed to be a bit drunk".
19 A. Slightly drunk. We tried to tell him not to drive, he
20 refused to hear us and we could not insist, you know,
21 because everybody knows he is protected by Mr Klein.
22 Q. Which of them said that to you?
23 A. Well, M Dourneau told me, you know, he was a little bit
24 drunk, and M Musa told me we could not insist because
25 everybody knows he is protected by Mr Klein.

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1 Q. Now, this is very striking evidence, Mr Roulet, which it
2 might be thought that you would have remembered before
3 you gave your evidence over two days in December.
4 Can you provide any explanation for that?
5 A. Well, you know, after these days, these days I tried
6 maybe to forget lots of things and to forget all this
7 nightmare I had to live. And maybe a few memories went
8 in the back of my memory. And also, this happened very,
9 very shortly before I saw what happened. I did not see
10 what happened when they spoke to me and I just answered
11 yes, yes and wanted to go further, under the tunnel, to
12 see what happened. And maybe due to this, I forgot this
13 short conversation. It happened in a time, not even in
14 one minute's time.
15 Q. All right. The Coroner has caused inquiries to be made
16 of both M Dourneau and M Musa. Now, M Dourneau has
17 a recollection of meeting you in the tunnel, but he does
18 not recollect talking about Henri Paul's condition and
19 doubts that such a conversation could have taken place.
20 Does that lead you to doubt the accuracy of your
21 recollection?
22 A. No. No, no. I am absolutely sure about what I heard.
23 Q. Then, M Musa, from whom we will be hearing, does not
24 recollect seeing you in the tunnel and although he says
25 it is possible that he did, he is sure he would not have

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1 discussed with you anything about Henri Paul's ability
2 to drive. Does that in any way lead you to doubt your
3 recollection?
4 A. Absolutely not.
5 Q. And he goes on to say that the only reservation he had
6 about M Paul's ability to drive concerned the fact that
7 M Paul did not have the right licence.
8 A. This is true too. Mr Paul had not the right licence.
9 Q. But do you think that that is all that was discussed?
10 A. No, absolutely not.
11 Q. Can you remember how long you were with M Dourneau and
12 M Musa in the tunnel; for how long did you talk to them?
13 A. I would say not even one minute, maybe 30 seconds.
14 It was very, very rapid, very quick. It was in the time
15 that I was admitted to go under the tunnel and the time
16 I reached the place of the crash and this was very
17 quick.
18 Q. And when you say the time you were admitted into
19 the tunnel, is that the time at which the police allowed
20 you to go into the tunnel?
21 A. Yes.
22 Q. I see. All right, well others will ask you about that.
23 There is one other matter I wish to explore with you.
24 You are aware, aren't you, that we have heard from
25 Mr Willaumez; you know that?

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1 A. I know that.
2 Q. And you know that he said some things which were rather
3 disobliging as far as M Paul was concerned?
4 A. Yes.
5 Q. You know that. Are you able to enlighten the jury at
6 all about the working relationship between Mr Willaumez
7 and Mr Paul?
8 A. Their relations were very bad. In fact, M Paul was
9 a kind of instructant to inquest about M Willaumez and
10 also distract him in order to have him either giving his
11 notice or find a mistake which could allow the hotel to
12 dismiss him.
13 Q. Why was that?
14 A. At this think M Willaumez was counted as a negative
15 employee at the bar.
16 Q. And that was a problem between them for some time before
17 M Paul's death; is that right?
18 A. Oh yes, because M Paul was looking very well after his
19 duty and it was stressing M Willaumez a lot.
20 Q. So you thought it important that the jury should
21 understand, when considering M Willaumez's evidence,
22 that he actively disliked M Paul?
23 A. Yes. I think he really disliked M Paul.
24 MR BURNETT: Thank you very much, M Roulet, if you stay
25 there, there will be other questions.

10

1 LORD JUSTICE SCOTT BAKER: Mr Mansfield?
2 MR MANSFIELD: Yes, I wonder if I might ask your permission
3 to revert to one topic which has been qualified before
4 but at that time, I did not have certain documents which
5 I now have. They have been disclosed since. It is
6 purely the whereabouts of Henri Paul on the way home
7 from M Roulet, if I may ask about that.
8 LORD JUSTICE SCOTT BAKER: This relates to some document
9 which has come on the scene since he gave evidence?
10 MR MANSFIELD: Yes.
11 LORD JUSTICE SCOTT BAKER: Yes, very well.
12 MR MANSFIELD: I will make clear what the document is in
13 a moment.
14 LORD JUSTICE SCOTT BAKER: I should make it clear,
15 Mr Mansfield, that this is not an exercise whereby we
16 are going to go over past territory. I am giving you
17 permission to explore this on a very narrow basis.
18 MR MANSFIELD: It is very narrow. I will focus.
19 Questions from MR MANSFIELD
20 MR MANSFIELD: Good morning, Mr Roulet.
21 A. Good morning, Mr Mansfield.
22 Q. You know who I represent, so I will be very quick. I am
23 sorry to revisit one topic, and the topic is whether you
24 saw Henri Paul on the way home and then to Chez Benoit
25 on the night of the 30th August 1997. It is that topic,

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1 do you follow?
2 A. Yes. I understand, yes.
3 Q. I am going to be very quick about it and summarise.
4 Initially, you told the police this you left the hotel
5 somewhere around 7.00/7.15 and you saw Henri Paul
6 shortly after that?
7 A. That is true.
8 Q. You also told the police that it took you about 5 to
9 7 minutes to walk from the hotel to the bar where you
10 saw him shortly. Do you remember saying that?
11 A. Yes, yes.
12 Q. You were then shown the CCTV footage and it was clear
13 that you did not leave the hotel, the Ritz, until 20
14 past 8. Do you remember that happened?
15 A. I remember that, yes.
16 Q. Because you had a question on that. Now, if that is
17 right, you leave at 20 past 8, it takes 5 to 7 minutes
18 to get to the bar, you would be getting to the bar,
19 roughly, around 25 past 8 or half past 8. Would that be
20 right?
21 A. That would be right, yes.
22 Q. Now, before I put a document to you, is there any doubt
23 in your mind about this?
24 A. No.
25 Q. The document that I have now that I did not have before,

12

1 but I think you have seen it, it is a record of your
2 mobile phone calls.
3 A. Yes.
4 Q. Now you had seen that, I think, by the time you gave
5 evidence because you referred to it. Do you remember?
6 A. Well, I remember having seen it to the French police,
7 yes.
8 Q. I am going to ask, do you have a copy there? If not,
9 I will put it on screen.
10 A. No, I do not have a copy.
11 Q. Could we have it on screen, please. I do not have
12 a page number but it starts -- in fact, the top date is
13 29th. There is more than one page. If somebody could
14 help me, give me a page number for that?
15 MR BURNETT: Page 1 [INQ-tel-records].
16 MR MANSFIELD: It is page 1.
17 Sir, do you have this? If not, I can hand up a hard
18 copy so that it is a little easier to follow. Could
19 I hand this up (Handed).
20 LORD JUSTICE SCOTT BAKER: Thank you.
21 MR MANSFIELD: Now, perhaps you would follow with me. This
22 is a print-out of your telephone calls.
23 Does that have the 29th at the top? So that we can
24 follow, this facteur runs from left to right. So taking
25 the left-hand corner, for example, on the 29th there is

13

1 a call at 15.15. The next call is at the top of the
2 right hand column, 15.21. Do you follow that?
3 A. Yes.
4 Q. It is slightly different to the way that bills are made
5 up here.
6 Now, on the right-hand column, the first call on the
7 13th is in fact the fifth entry down, do you see that?
8 If you count five down, it is 14.10. Perhaps that could
9 be highlighted?
10 A. Oh, yes.
11 Q. On the 30th. And then the next call, on the 30th, is in
12 the left-hand column, and it is at 22 minutes past 8.
13 In other words, 2 minutes -- if that could be
14 highlighted, 20.22 --
15 A. Yes.
16 Q. All right?
17 A. Yes.
18 Q. And the next call, I am taking you through so that you
19 have time to get used to it. The next call is 20.33 on
20 the 30th. That is on the right-hand side.
21 Now, 20.33, the number ends with 0137; do you see
22 that?
23 A. Yes.
24 Q. Whose number is that?
25 A. Oh, I do not remember.

14

1 Q. It is the landline for Henri Paul at home. Now, I want
2 you to think very carefully; if you have just seen him
3 in the bar, you would hardly be ringing him at home,
4 would you?
5 A. Well, I have no idea why I rung him at home at this
6 time.
7 Q. Because, if we go across to the left-hand column,
8 the next call is 20.35, and do you see, once again,
9 there is another call ending with the same number.
10 A. Yes.
11 Q. Now, again, it is the landline of Henri Paul which you
12 are ringing again.
13 A. Yes.
14 Q. Sir, there are other initials of HP. I do not know who
15 wrote them on but they are not all Henri Paul's numbers.
16 May I just indicate that his home number ended in
17 137, and his mobile 0275, which we can see called much
18 later on.
19 Now, there are two calls there to his home and
20 I want to ask you whether in fact, in the light of those
21 calls, in the light also of the bar staff who say he was
22 not in the bar that night, whether you in fact have made
23 a mistake and you were contacting him for some other
24 reason?
25 A. No, absolutely not. As you see, 20.35 was 10 minutes

15

1 after I met him in the street. I was already home or
2 even leaving home to go to Chez Benoit.
3 Q. 20.33 is only a few minutes after, for example, 20.27.
4 If it has taken you 7 minutes to get to the bar, you
5 have talked to him for a couple of minutes, that is
6 8.29, you are hardly going to be ringing him at home,
7 are you, at 8.33?
8 A. Well, I do not know why I tried to call his home. Maybe
9 I had things to tell him and I tried all the numbers to
10 reach him. But --
11 Q. If he had --
12 A. -- what is true in my mind, I come back again on this,
13 I met him that evening in the bar, as I said.
14 Q. If you had just met him in a bar and you had something
15 to tell him, you would ring him on his mobile, wouldn't
16 you?
17 A. Maybe he told me at the time he would go home so that is
18 why I tried to call home.
19 Q. Of course, anything could have happened. The point is,
20 you have no recollection of this, do you; these calls?
21 A. I have no recollection. If you see, there are so many
22 calls in a few minutes. I do not remember why I called
23 him at this point; maybe I forgot to tell him something.
24 Maybe I wanted to know something from him. I have no
25 idea.

16

1 Q. You see, the next call, just to complete the picture so
2 I am not leaving any out, if we go down the left-hand
3 column, at 21.57 there is a call to his mobile, do you
4 see that, 8275? In fact, it has his initials by it.
5 That is the first call to the mobile and then you do two
6 others to the landline in the right-hand column, if
7 we just switch across to that. And there are two calls,
8 this time to the home number, at 21.58 and then 22.09.
9 Do you see those?
10 A. Yes.
11 MR MANSFIELD: That is completing the picture. Thank you
12 very much, I am obliged.
13 LORD JUSTICE SCOTT BAKER: Mr Mansfield, can you help me
14 about this: looking at the first two phone calls to 137,
15 they appear each to have been --
16 MR MANSFIELD: Eight seconds.
17 LORD JUSTICE SCOTT BAKER: -- eight seconds' duration;
18 correct?
19 MR MANSFIELD: That seems to be the case.
20 LORD JUSTICE SCOTT BAKER: One possibility that occurs to me
21 is presumably no timing is recorded and no phone call is
22 recorded unless there is a connection.
23 MR MANSFIELD: Yes. My assumption is that it is a call to
24 the home with no answer and possibly no message left.
25 LORD JUSTICE SCOTT BAKER: I wonder if it was simply

17

1 the answerphone.
2 MR MANSFIELD: Yes, I accept that.
3 LORD JUSTICE SCOTT BAKER: But what is the position about
4 the answerphone at the moment? I do not remember
5 immediately.
6 MR MANSFIELD: I had asked for it. May I take one second.
7 The last information I had was it had not been found.
8 MR BURNETT: Sir, you may remember that it was one of the
9 things that Mme and M Paul were going to look out when
10 they got back to Brittany but my understanding is that
11 it has not been provided.
12 LORD JUSTICE SCOTT BAKER: What is the position, Mr Keen?
13 MR KEEN: I cannot immediately answer, sir, but I will
14 certainly take instructions.
15 LORD JUSTICE SCOTT BAKER: There has been some
16 correspondence about this, I think, out of court?
17 MR BURNETT: Sir, there has.
18 LORD JUSTICE SCOTT BAKER: The Pauls were asked to provide
19 it and no doubt those instructing Mr Keen have been
20 taking some steps about this.
21 MR BURNETT: One hopes so, sir.
22 LORD JUSTICE SCOTT BAKER: We would like to know what they
23 are.
24 MR KEEN: I do not know what they are, sir, but I will
25 advise as soon as I have instructions.

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1 MR BURNETT: Can I say as far as these calls are concerned,
2 two things: the first thing is that these records were
3 provided fairly recently by the Ritz Hotel. We are
4 obviously grateful for that.
5 LORD JUSTICE SCOTT BAKER: Yes.
6 MR BURNETT: The second thing is that they have been looked
7 at by Mr Stokes and there will be available a rather
8 easier document to follow than the one that has gone up
9 on the screen, which we will introduce in due course.
10 LORD JUSTICE SCOTT BAKER: Well, there we are, members of
11 the jury. That is the best I can do for you at the
12 moment.
13 Yes, Mr Keen.
14 Questions from MR KEEN
15 MR KEEN: Good morning, Mr Roulet.
16 A. Good morning, Mr Keen.
17 Q. You gave your first statement to the Brigade Criminelle
18 on 1st September 1997. Do you recall that?
19 A. Yes, I recall.
20 Q. And you gave a second statement on 2nd September 1997.
21 Do you recall that?
22 A. Well, maybe. If you tell it, it must be true.
23 Q. And you gave a third and a fourth and a fifth and
24 a sixth and seventh and an eighth and a ninth statement,
25 through 1997, 1998; as far as 2005 and 2006, indeed.

19

1 And do you recall that in all of those statements you
2 said -- because your recollection, you claimed, was
3 clear -- that on 30th August 1997, you left the Ritz
4 Hotel at about 7.15 in the evening and saw Henri Paul
5 about 7 minutes later, outside the Bar de Bourgogne. Do
6 you remember saying that repeatedly to the police when
7 you were interviewed?
8 A. Yes, I remember.
9 Q. And then you came here to give evidence in December 2007
10 and I showed you in incontrovertible evidence that you
11 could not have left the Ritz Hotel at about 7.15 on that
12 date, because there was CCTV film showing you did not in
13 fact leave until about 8.20 on that evening. Do you
14 recall that?
15 A. I recall, yes.
16 Q. And you then responded by saying, well, it is all an
17 hour out, so what happened was I left at 8.20, and it
18 took me about 7 minutes to walk along towards
19 the Bar de Bourgogne and it would have been about 8.22
20 that I saw Henri Paul. Do you remember giving that
21 evidence to the jury on oath?
22 A. Can you repeat, I did not get what you asked?
23 Q. Certainly.
24 After you had decided that everything was an hour
25 out, you said that what actually happened was that you

20

1 left at 8.20, that it took you about 7 minutes to walk
2 along to the Bar de Bourgogne and that it would have
3 been about 8.22, not 7.22, when you saw Henri Paul. Do
4 you remember giving that evidence on oath to the jury?
5 A. Did I say 22?
6 Q. You said it was about 5 to 7 seven minutes?
7 A. Yes.
8 Q. So it may have been about 8.22 or you may have said
9 8.27.
10 A. Yes, 8.27. If I left at 8.22 and you add 7 minutes, it
11 makes 8.27 (sic).
12 Q. Very well, 8.20 to 8.27. Yet now we have seen
13 the telephone records, we can identify the fact that
14 within minutes of that alleged meeting, you are
15 telephoning Henri Paul's home, when you are supposed to
16 be actually standing talking to him and you cannot
17 explain that. Is that my understanding of your
18 evidence, Mr Roulet?
19 A. Well, I cannot say if it was 8.27, 8.28 or 8.29. I know
20 that I need approximately 7 minutes but it could have
21 been 8 or 9 minutes this evening. I do not know. What
22 I know is I left the Ritz, I went straight home.
23 The Bar de Bourgogne is on my way to my home. In
24 August, it is very rapid because the streets are empty.
25 7 minutes is the right time to be there.

21

1 Q. Of course, because your evidence was very clearly when
2 you gave it repeatedly in signed statements. It was
3 that you had left at about 7.15 and then it took you
4 that period of time to walk along and that you saw
5 Henri Paul at about 7.27. But then, when you were
6 eventually contradicted by the incontrovertible evidence
7 of the CCTV, you moved that on an hour. The problem
8 now, Mr Roulet, is having moved it on an hour, you face
9 the problem of what is contained clearly in your
10 telephone records, which show that when you allege that
11 you were actually with Henri Paul on 30th August, you
12 are in fact recorded as telephoning his home, which is
13 not something you would do if you were with him, is it?
14 A. Well, you are playing with the minutes, I think.
15 Q. I do not think so. It is not a matter of minutes,
16 Mr Roulet. Whether you had seen him a minute earlier or
17 a minute later is neither here nor there. If you had
18 actually seen him at or about that time you would have
19 no reason to telephone him twice at home at 8.35 and
20 again at 8.33, just 2 minutes earlier, would you?
21 A. Well, it can be that he told me, "I am going to home
22 now" and I wanted to speak to him. You know, this part
23 of Paris, this very, very small street, Rue des Petits
24 Champs, it is very hard to get mobile phone there. And
25 when I had to get Henri Paul, I tried all the way to get

22

1 him, because he can be one metre from the place that you
2 want to speak to him and there can be no telephone line
3 any more. So I also needed to ask something to Mr Paul
4 which I forgot to tell him when we met and I tried all
5 the way to reach him.
6 Q. There is no record of you attempting to phone him on his
7 mobile phone, Mr Roulet, no record whatsoever?
8 A. It maybe means that he told me he was going home so
9 I expected him to be home.
10 Q. Maybe, maybe, maybe, Mr Roulet. The point is that at
11 each turn when you change your evidence, we find more
12 evidence that contradicts --
13 A. I do not change my evidence. I do not change anything.
14 I met Henri Paul this evening on the street.
15 Q. You told us originally at 7.20. Then you told us at
16 8.20.
17 A. Yes, well it means just because I was confused at
18 the time I left the hotel.
19 Q. Confused?
20 A. That was my only confusion.
21 Q. There is also the confusion about why you were phoning
22 him at home --
23 LORD JUSTICE SCOTT BAKER: Can we move on, please, Mr Keen.
24 This has arisen from the late arrival of some telephone
25 records on the scene. We are not going to go back over

23

1 the whole of Mr Roulet's evidence. You are entitled to
2 ask him about the other fresh matter which relates to
3 the position in the tunnel.
4 MR KEEN: Well, with respect, sir, the whole issue of this
5 witness's reliability and credibility --
6 LORD JUSTICE SCOTT BAKER: The jury have the point.
7 MR KEEN: Yes, sir, but --
8 LORD JUSTICE SCOTT BAKER: Can we please move on. It is
9 perfectly clear that there is an issue about Mr Roulet's
10 credibility and can we move on now?
11 MR KEEN: Very well. If it is perfectly clear.
12 Mr Roulet, you gave your evidence on 5th and 6th
13 December 2007. Do you recall that?
14 A. Yes.
15 Q. You then returned to Paris and you began making
16 a documentary with Martyn Gregory, the journalist and
17 documentary film maker. Do you recall that as well?
18 A. No. I met Martyn Gregory just a short while ago.
19 Q. Yes, you did, after you had given evidence to the jury
20 in this inquest.
21 A. No.
22 Q. Yes.
23 A. No, I met Martyn Gregory last week only.
24 Q. And you filmed with Martyn Gregory in the Place Vendome
25 and elsewhere.

24

1 A. Do you have the date?
2 Q. Yes, it was 10th March, Mr Roulet, wasn't it?
3 A. 10th March, yes. That is not 10th December.
4 Q. I did not say it was.
5 You began filming your documentary with
6 Martyn Gregory around Paris, didn't you?
7 A. Yes.
8 Q. And in the course of that, you began giving your account
9 of events in order that you could feature in this
10 documentary, didn't you?
11 A. In order that I what?
12 Q. In order that you could feature in this documentary, in
13 order that you could be a star of the documentary,
14 Mr Roulet?
15 A. No, I do not need to be a star. I do not need to be
16 a star.
17 Q. Then why are you appearing in the filming by
18 Martyn Gregory?
19 A. Why should I not?
20 Q. Well, is it in fact the case that you have been tempted
21 to embellish your account of events in order to bring
22 yourself into a more significant position in this matter
23 than might otherwise truly be the case?
24 A. That is your position, sir.
25 Q. Really. You now tell us about an incident in

25

1 the Alma Tunnel and you said, and I quote you:
2 "I remember clearly ..."
3 You used those words just a few minutes ago about
4 the opening of the alleged conversation with Mr Musa and
5 Mr Dourneau. Do you remember using the words
6 "I remember clearly"?
7 A. Yes.
8 Q. And this is an event that not only did you not remember
9 clearly, but you did not remember at all when you gave
10 a statement to the judicial police on
11 1st September 1997; is that correct?
12 A. Can you repeat?
13 Q. Certainly. This alleged conversation that you now
14 remember clearly is one that you did not only not
15 remember clearly but did not remember at all when you
16 gave a statement to the judicial police on
17 1st September 1997. Is that not the case?
18 A. Yes. It was -- it is the case. I did not remember and
19 I was also not asked about.
20 Q. Then, by 1st September 1997, the Public Prosecutor in
21 Paris put out a statement saying that Henri Paul had
22 been drunk at the time of the crash, do you remember
23 that?
24 A. Yes.
25 Q. And then, on 2nd September, you gave a second detailed

26

1 statement to the judicial police in Paris. Do you
2 remember that?
3 A. Yes. Maybe, yes. If you tell it, it must be true.
4 Q. And in that, there is no reference to any alleged
5 conversation in the Alma Tunnel with Mr Musa and
6 Mr Dourneau, is there?
7 A. It must be, yes.
8 Q. And you were actually asked about Henri Paul's condition
9 on the night in question --
10 A. Yes, I was.
11 Q. -- in that statement. And you referred to him being
12 perfectly lucid when you had spoken to him on
13 the telephone and you made no suggestion or reference to
14 anyone indicating otherwise in respect of his position.
15 Is that not the case?
16 A. Well, that is the case. Maybe other people saw him in
17 a different way than. Anyway, I did not see Mr Paul.
18 I spoke on the phone with him only.
19 Q. Yes, and you said again in your next statement on
20 8th September 1997, "Henri Paul did not give me
21 the impression of someone who had been drinking" and
22 again, there was no attempt by you to suggest that
23 anyone had indicated the contrary. There was no
24 reference by you to any conversation in the Alma Tunnel,
25 was there?

27

1 A. No.
2 Q. So this conversation that you now so clearly recall was
3 again not mentioned. And then when you appeared before
4 the examining magistrate, you were asked about
5 the possibility of Henri Paul having drunk on the night
6 in question. And again, there was no reference to any
7 conversation in the Alma Tunnel, was there? Was there,
8 Mr Roulet?
9 A. It was, yes.
10 Q. And so it goes on through 2005, 2006 and 2007. This
11 conversation that you now so clearly remember, as you
12 become a star of a documentary, is one that you never
13 mentioned to any police officer or any examining
14 magistrate over ten years and in fact, which you never
15 mentioned when you gave evidence on oath to this jury in
16 December 2007; is that correct?
17 A. Yes.
18 Q. It is.
19 A. Well, Mr Keen, during ten years, no one knew that I left
20 the hotel at 20 past 8. You bring this to me ten years
21 later. This is the same.
22 Q. But you must have known, Mr Roulet, only you did not
23 mention it.
24 A. Well, did you need such an evidence? Did you spend
25 a whole night with two dead bodies under a tunnel?

28

1 The human memory can have some faults sometimes. Until
2 you lead such an experience, I think you have nothing to
3 say.
4 Q. With respect, Mr Roulet, over ten years, you have been
5 asked to give signed, sworn statements about the events
6 that you knew of relating to the crash. Over that ten
7 years, it has been repeatedly suggested that Henri Paul
8 was drunk and over that ten years, you never once hinted
9 at, let alone suggested the existence of any
10 conversation in the Alma Tunnel after the crash with
11 Mr Musa and Mr Dourneau and that is the truth of the
12 situation; isn't it? Isn't it?
13 (Question interpreted)
14 MR KEEN: It would appear, sir, that the witness is being
15 directed by someone off screen.
16 SECRETARY TO THE INQUEST: No, the magistrate is talking to
17 the interpreter, sir.
18 THE INTERPRETER: Asking me to say that Mr Roulet is
19 a witness and not a convict.
20 MR KEEN: Well --
21 LORD JUSTICE SCOTT BAKER: Mr Keen, you have a perfectly
22 good point about recollection over a period of time.
23 But it is not appropriate to treat this as if it was
24 a criminal trial and ask the witness questions in an
25 offensive way and you are getting, it seems to me, very

29

1 close to that at the moment.
2 MR KEEN: Well, sir, this is a situation in which
3 the allegation of unlawful killing is being directed
4 against the late Henri Paul and this is the situation in
5 which this witness, for the first time after ten years
6 and after becoming involved in a documentary has come
7 forward with further apparently stunning evidence that
8 he now claims to clearly recall. And it does seem to me
9 that it is important that it be tested --
10 LORD JUSTICE SCOTT BAKER: This is an inquiry, Mr Keen, as
11 I have said many, many times.
12 MR KEEN: Well, if you feel, sir, that I should not take
13 this matter further with this witness --
14 LORD JUSTICE SCOTT BAKER: You have a perfectly good point
15 which appears to me to have been made on numerous
16 occasions now, in the last half an hour.
17 MR KEEN: I shall ask no further questions, sir.
18 LORD JUSTICE SCOTT BAKER: Thank you. Mr Croxford?
19 MR CROXFORD: No thank you, sir.
20 LORD JUSTICE SCOTT BAKER: Mr Horwell?
21 MR HORWELL: No questions.
22 LORD JUSTICE SCOTT BAKER: Mr Burnett?
23 Further questions from MR BURNETT
24 MR BURNETT: Just one matter, Mr Roulet.
25 You told the jury that you recollected this

30

1 information on 10th December 1997 and got in touch with
2 one of the Coroner's officers; is that right?
3 A. Yes, I got in touch on 10th December. I sent a text
4 message to Detective Sergeant Easton.
5 Q. Now, Mr Keen did in fact suggest to you, and I think
6 I quote his words correctly:
7 "You then returned to Paris [that is, after giving
8 evidence here] and began making a documentary".
9 I think you told the jury that you were not involved
10 with a documentary until very recently; is that right?
11 A. That is exact.
12 Q. When did you first become involved in the documentary
13 process?
14 A. It was end of -- I think beginning of March.
15 Q. And therefore, does your involvement in the documentary
16 have any connection with your recollecting this
17 evidence?
18 A. Absolutely not.
19 MR BURNETT: Thank you.
20 LORD JUSTICE SCOTT BAKER: Yes. Thank you, M Roulet, for
21 coming back. Thank you very much.
22 M Musa then, next.
23 MR JEAN-FRANCOIS MUSA (recalled)
24 Questions from MR HOUGH
25 (evidence via videolink, interpreted)

31

1 LORD JUSTICE SCOTT BAKER: Good morning, Mr Musa, can you
2 hear us?
3 THE INTERPRETER: Yes, we can sir.
4 LORD JUSTICE SCOTT BAKER: Thank you very much for coming
5 back to assist the court further. We are very grateful
6 to you.
7 MR HOUGH: Now, M Musa, you took the oath, I believe, when
8 you gave evidence previously and I asked you some
9 questions on 4th December.
10 A. Yes, I did.
11 Q. And to remind everybody here, you are the manager of
12 Etoile Limousine and you gave evidence about
13 the arrangements for the provision of cars on the night
14 of 30th August 1997.
15 A. Yes.
16 Q. Now, I think recently, you have been informed of an
17 account of M Roulet from whom we have just heard about
18 a meeting he recall having with you on that night?
19 A. This is correct.
20 Q. And you are aware, I think, that he recalls meeting and
21 conversing with both you and M Dourneau in
22 the Alma Tunnel or near the Alma Tunnel in
23 the early hours of Sunday 31st August, 1997.
24 A. Yes. I know this is what he said.
25 Q. Taking this in stages, first of all were you in or

32

1 around the Alma Tunnel on the morning of Sunday 31st
2 August?
3 A. Yes, I was.
4 Q. Was M Dourneau there?
5 A. Yes.
6 Q. Do you recall meeting M Roulet there at that time at
7 all?
8 A. Sincerely, I cannot remember.
9 Q. Is it possible that you met him there?
10 A. Well, it is possible. You know, there were numerous
11 people. We could not focus on M Roulet. There were
12 hundreds of people there, the police, the fire brigade,
13 everybody walking et cetera.
14 Q. Now, Mr Roulet has said that you and M Dourneau told him
15 that you were nervous and that M Paul had not been in
16 full possession of his faculties that night. Is that
17 something that you or M Dourneau said?
18 A. No, I do not remember having this conversation.
19 Q. He specifically said that M Dourneau -- this is M Roulet
20 specifically said -- had said that M Paul seemed
21 a little drunk. Is that something you recall him
22 saying?
23 A. No, I do not remember this conversation.
24 Q. And M Roulet has also given evidence that you said that
25 you could not do anything about that, because everybody

33

1 knew that M Paul was protected by M Klein?
2 A. No, I do not believe I heard or participated in such
3 a conversation.
4 Q. These would have been fairly dramatic comments, if you
5 and M Dourneau had said them, wouldn't they?
6 A. No, I do not remember having a conversation, anyway,
7 with Mr Roulet concerning the condition of Mr Paul.
8 I do not even remember if I met him there. Maybe I did,
9 but I cannot be sure.
10 Q. But do you think that these comments would have stuck in
11 your mind if they had been said at all?
12 A. Yes, I would have recalled making such comments, but
13 it was not my concern that evening.
14 Q. In the light of M Roulet's evidence, do you still take
15 the view that there was nothing to suggest to you that
16 M Paul was drunk?
17 A. No, nobody had the view that Mr Paul's condition was
18 the one of somebody who had been drinking, so obviously
19 there was no conversation about that matter.
20 Q. And other than the question of whether M Paul had
21 a grande remise, about which you told us last time,
22 a particular kind of licence, did you have any
23 reservations about him driving the Mercedes that
24 evening.
25 A. Well, I stressed some reservations when Mr Roulet asked

34

1 me for the car and for the possibility for Mr Paul to
2 drive it when we were under the peristyle at the hotel.
3 But then I expressed no more reservations.
4 Q. Now, I think you have already been asked about the fact
5 that the CCTV footage shows that M Roulet had departed
6 the hotel by the time that you were under the peristyle
7 at that point.
8 A. Well, I do not want to question what can be claimed from
9 the CCTV. I do not know who made -- who filmed or
10 arranged this CCTV footage but what is for sure is
11 I think that it is very surprising that Mr Roulet would
12 not be there, even though the most famous couple on
13 earth was staying at the hotel at that time. It is
14 difficult to believe that he would have left, to come
15 back later.
16 MR HOUGH: Thank you very much, those are my questions.
17 MR MANSFIELD: No thank you.
18 MR KEEN: No thank you.
19 MR CROXFORD: No thank you, sir.
20 MR HORWELL: No thank you.
21 LORD JUSTICE SCOTT BAKER: Mr Musa, thank you very much for
22 returning, that is all we require. We are very grateful
23 to you.
24 MR HOUGH: Perhaps we can next call Mr Foley to deal with a
25 statement received from Mr Dourneau.

35

1 LORD JUSTICE SCOTT BAKER: Is that the conclusion of the
2 requirement for the videolink at the moment?
3 MR HOUGH: For this morning.
4 LORD JUSTICE SCOTT BAKER: But we are returning at 1.30?
5 MR HOUGH: We are, for M Delbreilh.
6 LORD JUSTICE SCOTT BAKER: Thank you very much. We can
7 close down the videolink now until we resume from Paris
8 at half past 1 this afternoon.
9 MR HOUGH: If Mr Foley can squeeze next to the screen, I do
10 not know?
11 MR THOMAS FOLEY (recalled)
12 Questions from MR HOUGH
13 MR HOUGH: Mr Foley, you are still on oath and you have
14 explained your position. Now, is this right, that in
15 the light of M Roulet's account, as well as M Musa, who
16 was involved in the conversation, M Dourneau was
17 contacted by the inquest secretariat.
18 A. That is correct.
19 Q. I should have said: involved allegedly in
20 the conversation.
21 Now, was a statement taken from M Dourneau dated
22 7th March 2008?
23 A. It was.
24 Q. And was that then circulated to the interested persons
25 on the same day?

36

1 A. It was.
2 Q. And perhaps I can read that statement out, it says this:
3 "I Philippe Dourneau, chauffeur, make the following
4 supplemental statement.
5 "I have been informed that in a supplemental
6 statement dated 29th February 2008, M Claude Roulet
7 states that he has recently remembered meeting and
8 conversing with me and M Musa in the Alma Underpass
9 after the crash on 31st August 1997.
10 "After thinking about it, I vaguely recall meeting
11 M Roulet in the Alma Underpass after the crash.
12 However, I do not recollect talking to him about
13 Henri Paul's condition. Indeed, I doubt that such
14 a conversation could have taken place. If I had
15 detected any abnormal behaviour from Henri Paul, I would
16 have gone straight to Dodi Al Fayed and told him he
17 should not get into a car that he was driving."
18 He says:
19 "I believe that the facts stated in this statement
20 are true."
21 If you wait there, there may just be --
22 LORD JUSTICE SCOTT BAKER: Anyone want to ask Mr Foley any
23 questions?
24 Thank you very much.
25 MR HOUGH: Thank you very much.

37

1 LORD JUSTICE SCOTT BAKER: Well, that takes us to Mr Faux.
2 I wonder if we ought to have our break first. He is
3 going to take a little time?
4 MR HILLIARD: A little time, not very long.
5 (10.37 am)
6 (A short break)
7 (10.51 am)
8 (Jury present)
9 LORD JUSTICE SCOTT BAKER: I call Mr Faux.
10 MR MICHAEL RONALD FAUX (affirmed)
11 Questions from MR HILLIARD
12 LORD JUSTICE SCOTT BAKER: Would you prefer to sit down,
13 Mr Faux?
14 A. If I may please, thank you.
15 MR HILLIARD: Mr Faux, I am going to ask you some questions
16 first of all on behalf of the Coroner. Then I daresay
17 you will be asked questions by other people.
18 A. Thank you.
19 Q. Can you start, please, by giving us your full name?
20 A. Michael Ronald Faux.
21 Q. And that is FAUX?
22 A. Yes.
23 Q. And date of birth, is this right, 30th June 1963?
24 A. It is, yes.
25 Q. Are you currently. The chief executive of something

38

1 called Executive Group Holdings?
2 A. Yes, I am.
3 Q. What does Executive Group Holdings do?
4 A. I own a holding company which has three divisions; there
5 is a security division, a cleaning division and
6 a concierge division.
7 Q. Security, cleaning and concierge services?
8 A. Yes.
9 Q. And how many people do you employ?
10 A. Approximately 84 full-time staff.
11 Q. How long have you been chief executive of the company
12 for?
13 A. Of this particular company?
14 Q. (Nods)
15 A. Probably two or three years.
16 Q. If we go back a bit, was there a time when you were in
17 the Army?
18 A. No.
19 Q. Never?
20 A. No.
21 Q. Was there a time when you trained with the SAS?
22 A. Yes.
23 Q. But you were not in the Army yourself?
24 A. Yes.
25 Q. How did you come to do that?

39

1 A. I was invited to train.
2 Q. Why?
3 A. Because I was involved in the close protection sector
4 within my business.
5 Q. I am afraid it is me, this morning. I just cannot hear?
6 A. I was involved in the close protection industry and
7 I was invited to go on a training scheme down near
8 Bournemouth in a place called Sopley, which is where
9 the Special Air Services do their training.
10 Q. How long did that last for?
11 A. Three weeks.
12 Q. When was that, please?
13 A. I do not recall.
14 Q. Ever so roughly: five months ago, five years ago?
15 A. Twenty years ago, 15/20 years ago.
16 Q. Now, we are going to hear about the circumstances in
17 which you met Paul Burrell, all right?
18 A. Yes.
19 Q. And we will come on to all of that in a moment or two.
20 But what I want to know first of all is this: have you
21 been in contact with any newspaper or other media outlet
22 about Paul Burrell and the time when you knew him?
23 A. Yes.
24 Q. And which company or which organisations is this?
25 A. There has been numerous.

40

1 Q. Right and when have you been in touch with them?
2 A. I would say probably in the last -- within the last two
3 years, I have probably spoken to two, The Sun and
4 the Daily Mirror, I think.
5 Q. Right. And were you paid money by them?
6 A. No.
7 Q. Did they publish what it was that you had to tell them?
8 A. No. That was not the purpose of me speaking to them.
9 Q. What was the purpose of your speaking to them?
10 A. The purpose of me speaking to the newspapers was because
11 I was confined to a confidentiality agreement and I was
12 unable to voice what I wanted to voice and I thought
13 that by going to the newspapers, I would be able to use
14 their lawyers. They would be able to help me oversee
15 the confidentiality agreement, what was in place.
16 Q. So forgive me, you saw them with a view to getting
17 round, if you could -- I am not criticising you, I just
18 want to know what the position is --
19 A. Yes.
20 Q. -- see if you could get round the confidentiality
21 agreement?
22 A. Yes.
23 Q. Did you manage to get round it or not?
24 A. No, not until now.
25 Q. And does it follow that you did not tell the newspapers

41

1 anything about your time with Paul Burrell, if you had
2 not managed to get round the agreement, or did you in
3 fact tell them?
4 A. No I had to tell them. I had to tell them as much as
5 I could possibly tell them for them to be able to
6 approach their lawyers, to whether or not they would be
7 able to actually print or go to print or actually do
8 anything about it.
9 Q. To help with this, on the face of it, did that involve
10 breaching the confidentiality agreement, it sounds as
11 though it must have done?
12 A. No.
13 Q. You were able to tell them about your time with
14 Paul Burrell, which was otherwise covered by
15 the agreement?
16 A. It was in confidence.
17 Q. Forgive me; the confidentiality agreement, if you tell
18 anybody else, as long as you tell them in confidence, it
19 did not matter? I am really struggling with that,
20 Mr Faux. Just think about it for a minute.
21 Do you think you were perhaps on the face of it in
22 breach of the confidentiality agreement in telling
23 the newspapers?
24 A. I did not believe I was at the time.
25 Q. You really did not?

42

1 A. No, otherwise I would not have done it. I would not
2 have done it if I had thought I was.
3 LORD JUSTICE SCOTT BAKER: Can you try to speak more slowly
4 and speak up so the jury can hear you at the back.
5 It is very difficult to hear what you are saying.
6 MR HILLIARD: Have you been in touch with any newspaper or
7 media outlet more recently than over the last two years;
8 I mean in recent weeks, days, months.
9 A. Yes.
10 Q. Is that in connection with the evidence that you are
11 going to give the jury this morning?
12 A. Yes.
13 Q. When did that happen?
14 A. When you say reference to a newspaper, in what respect?
15 Q. Let's not confine ourselves to newspapers, because as it
16 were, if there is a television programme, don't leave
17 that out because I have not used the words. That is why
18 I say newspaper or other media outlet?
19 A. Then no, no I have not.
20 Q. I am sorry, I thought you just said you had.
21 A. I misunderstood.
22 Q. What did you misunderstand?
23 A. I understand that I have come to the courts today
24 because I feel that I want to obviously discuss what
25 I need to discuss. I have spoken to the newspapers

43

1 prior, because I have felt that I have wanted to, but
2 was unable to because of the confidentiality agreement.
3 I am now sat in front of the court enabling me to do
4 that. I was a little bit confused of what you said to
5 me with reference of did I speak to a paper because no,
6 I did not speak to a paper.
7 Q. Right. When you saw The Sun and The Mirror, whenever
8 that was, did they pay you any money?
9 A. No.
10 Q. Has anybody paid you any money or offered you any reward
11 for your account of your time working with Paul Burrell?
12 A. No.
13 Q. Do you have any expectation of being paid any money or
14 do you hope for any after you have given your account?
15 A. No.
16 Q. And have you any arrangement with any newspaper in
17 the future?
18 A. No.
19 Q. There is no newspaper or media outlet that you have
20 spoken to about possibly publishing your story when
21 the inquest is over or anything like that. Just so that
22 we understand, we will not be seeing that in the paper?
23 A. No.
24 Q. You are quite sure?
25 A. Have I spoken to a newspaper to discuss this, what I am

44

1 discussing now?
2 Q. No, no. What I want to know is this: have you made or
3 do you have arrangements or have you had any discussions
4 with a newspaper or media outlet that after you have
5 given your evidence or when the inquest is over, about
6 publishing a story of yours; that is what I want to
7 know?
8 A. No.
9 Q. So we will not be reading about that?
10 A. No.
11 Q. As you have indicated, we will look at the circumstances
12 of it, you had signed a confidentiality agreement with
13 Mr Burrell.
14 A. I did, yes.
15 Q. And on 5th March, a solicitor acting on your behalf got
16 in touch with the solicitor to the inquests. I think
17 you know about that.
18 A. Yes.
19 Q. And in a statement that you made after that, to
20 the solicitor to the inquests -- do you have a copy of
21 it there?
22 A. Yes.
23 Q. In my copy, at paragraph 18, do you have that? It
24 reads:
25 "I have been asked to explain how it is that I have

45

1 only recently contacted the Solicitor to the Inquests.
2 I very rarely read the newspapers and have not followed
3 reporting of the inquest hearing at all. It has been
4 eating away at me for four or five years to tell someone
5 about what I know, but I have felt that I was not able
6 to do so because I felt bound by the confidentiality
7 agreement that I signed. I do, however, feel duty-bound
8 to come forward. For some reason, I cannot answer why,
9 I want people to know."
10 Is that all true?
11 A. Yes.
12 Q. I have been helpfully provided this morning with an
13 email sent by your solicitor. Was that someone called
14 Mr Lucas?
15 A. It is, yes.
16 Q. To the Chairman and it says:
17 "Dear Sir.
18 "I act for Paul Burrell's former bodyguard. He has
19 information that I think you will be interested in.
20 Please contact me."
21 Yes? That was to Harrods, is that right?
22 A. I have no idea. I have not seen the email.
23 Q. Is this right, you then went to see Mr Benson and
24 Mr Macnamara?
25 A. Yes.

46

1 Q. And your statement says: "They questioned certain
2 elements of what I have to say"; is that right, they
3 went through what it was that had you to say?
4 A. Yes.
5 Q. It may just be me but I am struggling. What about
6 the confidentiality agreement; there you were, you had
7 gone to Harrods. Did it happen in Harrods, I do not
8 know?
9 A. The confidentiality agreement that you keep insisting on
10 talking about was obviously in place and has been in
11 place and I do feel that it is still valid.
12 Q. I am just asking why was it then that you were able to
13 go through matters from Mr Benson and Mr Macnamara?
14 A. Because I was taking advice by my solicitor.
15 Q. And that was that it was all right to do it?
16 A. Yes.
17 Q. Can you help us, when was it that you first met
18 Paul Burrell?
19 A. It was towards the end of 2002.
20 Q. And what were the circumstances of the meeting?
21 A. The newspaper, the Daily Mirror, contacted my office and
22 asked me whether or not I could help them to move a VIP
23 from a holding place that they had them in the hotel,
24 Mr Burrell and his family. At the time they did not
25 disclose who the particular VIP was.

47

1 Q. And in late 2002, did you say that you would do that?
2 A. Yes.
3 Q. And did that involve just you or other people who worked
4 for you?
5 A. Eventually, it was -- at the time it was just myself and
6 it eventually moved to being more of my staff.
7 Q. So the first bit is simply you moving Mr Burrell from
8 a hotel to somewhere else?
9 A. Yes.
10 Q. What was the need for you to get involved in moving him
11 from one location to another, just so that
12 we understand?
13 A. Mr Burrell was held in a hotel. It was due to the cause
14 that the paparazzis and media were chasing him for his
15 story. So the daily paper, the Daily Mirror, had him in
16 the hotel for their exclusive and for them, they wanted
17 to make sure that they kept the family out of other
18 people and other photographers and other media.
19 Q. So as it were, they did not want their story spoiled by
20 other people getting photographs, interviews, that kind
21 of thing?
22 A. Yes.
23 Q. And so, you did that. You moved him from the one
24 location to another?
25 A. Yes.

48

1 Q. And was that the end of the work you did for Mr Burrell,
2 or not?
3 A. No, it continued from there until probably late 2003.
4 Q. What, for about a year?
5 A. Just under a year, yes.
6 Q. And did you carry on doing jobs for the Daily Mirror as
7 far as Mr Burrell was concerned?
8 A. Yes, I worked for the Daily Mirror probably for maybe
9 two months.
10 Q. What would this still be, at the end of 2002?
11 A. To the beginning of 2003, yes.
12 Q. And what were you doing, just, as it were, minding him
13 every day?
14 A. Mr Burrell became very popular after the exclusive story
15 broke out and Mr Burrell employed me more then as his
16 personal assistant, because I was more acting as
17 a buffer, if you like, to eliminate people trying to
18 contact him so that they would more or less contact me
19 and I would arrange for appointments, et cetera.
20 Q. I do not know whether it is needed, but had you got any
21 experience doing that kind of thing?
22 A. Yes, I had.
23 Q. What experience have you got?
24 A. I have worked in the industry now for the best part of
25 18 years and by working in the industry, I mean I have

49

1 worked with very high profile people and sometimes when
2 you work with them, you build a relationship with them
3 so that they depend on you to take bookings for them, do
4 their daily diary, so it was very much the same.
5 Q. Just so we understand, principally speaking, certainly
6 at the start with him, was it security?
7 A. Yes, it was.
8 Q. The employment on behalf of the Daily Mirror, did that
9 come to an end then?
10 A. Yes.
11 Q. What then happened, as far as you and Mr Burrell was
12 concerned?
13 A. He wanted to continue in my services, for me to work
14 with him, so I continued. We were taking bookings,
15 travelling overseas, et cetera, et cetera so I basically
16 gave up my own business and lifestyle, if you like, and
17 concentrated on looking after him and his family.
18 Q. This would be round about the start of 2003 to the end
19 of 2003; roughly that?
20 A. Roughly towards the end of 2003. Yes.
21 Q. And what arrangement, if any, was made about payment for
22 you?
23 A. We had arranged and we had agreed that we would open
24 a company and within that company, he would pay me
25 20 per cent of his income as an agent would, because

50

1 I was now virtually working as his agent as well as his
2 personal assistant and as well as his security. So
3 we opened a business account. We opened up a business
4 and we split the -- we were going to split the funds on
5 a 80/20 split.
6 Q. Is that what happened?
7 A. Yes.
8 Q. I do not want the figures, but is that essentially what
9 happened?
10 A. Yes, we formulated the company and so on.
11 Q. The confidentiality agreement, can you tell us how that
12 came about?
13 A. I had a phone call to ask if I could go to Paul's house,
14 because he wanted to have a meeting with myself and
15 a gentleman called Steve Dennis.
16 Q. Pausing, was this the house in Cheshire or somewhere
17 different?
18 A. Yes, in Farndon.
19 Q. And Steve Dennis was --
20 A. He was the reporter and ghostwriter for Paul Burrell.
21 Q. And the telephone call was --
22 A. To ask him to go to his house. He would not divulge
23 over the phone what this was regarding. We went to his
24 house and we sat round a table and he said that because
25 his work was getting busy and he wanted to move forward

51

1 and so on that he would like us both to sign a trusted
2 confidentiality agreement which I felt, after working
3 for him so many months it was a little bit late for
4 that. So I declined at that particular time.
5 Q. Pause there. What was your thinking, did you have any
6 difficulty, any problem with signing an agreement that
7 you would keep his affairs confidential?
8 A. Not really, no. But generally a confidentiality
9 agreement is given to you prior to you being employed by
10 somebody, not halfway through or three-quarters of
11 the way through a term or time being with somebody.
12 Q. So you said you would not?
13 A. That is right.
14 Q. What about Mr Steve Dennis, was he a yes or a no?
15 A. No.
16 Q. He would not either. Right, well did you hear from
17 Mr Burrell about it again?
18 A. Yes.
19 Q. And when was that?
20 A. Virtually the following day.
21 Q. And did he telephone you again?
22 A. Yes.
23 Q. And what did he say this time?
24 A. He asked me would I come and see him, because he wanted
25 to discuss the future. So I drove to Farndon. At the

52

1 time he was at his florist's shop and he came out and
2 came over to the car and we sat in the car to discuss
3 it.
4 Q. And what was the discussion in the car?
5 A. He said to move things forward and for us to work
6 together and so on, please would you sign
7 the confidentiality agreement, to the point that he was
8 upset. He was virtually crying and it was quite obvious
9 to me that he was quite upset about the whole point,
10 that I would not sign the confidentiality agreement.
11 Q. Did you ask him why he wanted you to sign it?
12 A. We did discuss it and I could not understand. I tried
13 to point out that I could not understand why he was so
14 adamant in me signing the confidentiality agreement at
15 such a late time of my employment with him.
16 He then continued to tell me that he needed me to
17 sign it because we were going to go over to America, to
18 tour, a book tour, et cetera et cetera. So I said to
19 him if it is that important to you, I will sign
20 the document. He said: if you sign the document, there
21 is something else I need to let you know. So I signed
22 the document and he then told me that the reason more he
23 wanted me to sign the document was because his lawyers
24 had asked him to do that because he had an engagement
25 ring and he needed to get it signed because if it was to

53

1 come out in the future, he could well get into serious
2 trouble.
3 Q. Pause there. Really, the reason he had got you to sign
4 the confidentiality agreement was because he had an
5 engagement ring and if it was to come out -- do I have
6 this right -- in the future he might get into trouble?
7 A. Yes.
8 Q. Pausing there, before he told you about it, did you know
9 anything about an engagement ring at all?
10 A. No.
11 Q. Did you say to him, well, the simplest thing would have
12 been not to tell me about the ring, then there would
13 have been no need for the tears, the confidentiality
14 agreement; you did not --
15 A. No.
16 Q. What did he tell you about an engagement ring?
17 A. He did not. It is only what I just said. He said he
18 wanted me to sign a confidentiality agreement and he
19 said now I have signed it, I can now tell you that one
20 of the reasons is because my lawyers have advised me
21 I can get into trouble, the fact that if it was to get
22 out that I have the engagement ring --
23 Q. But what I want to know, I am getting at this: Whose
24 engagement ring was it?
25 A. Princess Diana's, as I was led to believe.

54

1 Q. Is that what he said to you?
2 A. Yes.
3 Q. And how did he say he had it?
4 A. He took it off the body in Paris.
5 Q. Did he say he had any way of demonstrating that it was
6 hers?
7 A. Yes.
8 Q. And what was that?
9 A. There was still blood on the ring and he could prove
10 it was hers by the DNA.
11 Q. No doubt you asked him if you could have a look at it?
12 A. No. No.
13 Q. Why not?
14 A. Because we were sitting in a car outside his florist and
15 I did not think for one minute he would have it --
16 Q. No, not then, but at some point?
17 A. No, not at all.
18 Q. We have heard from Mr Burrell about a Bulgari friendship
19 ring that the Princess of Wales had been given and
20 we saw pictures of her wearing it. Mr Burrell said that
21 he was given that after the crash and that he took it
22 back to Kensington Palace, put it in his pantry there
23 and presumed it had been returned to the Princess's
24 family, all right. But it has never actually been seen
25 again. Did he mention any of that to you?

55

1 A. No.
2 Q. He told you that this was a ring that he had taken off
3 her finger?
4 A. Yes.
5 Q. What did you say to him about that?
6 A. Not so many words. I was disgusted with him.
7 MR MANSFIELD: Sir, I wonder if the witness might speak up.
8 There are quite a number having difficulty.
9 A. Sorry.
10 LORD JUSTICE SCOTT BAKER: Try to project your voice to
11 the members of the jury, right at the back, would you?
12 A. Yes, sir, sorry.
13 Sorry.
14 MR HILLIARD: What I wanted to know is what did you say to
15 him when he said that to you?
16 A. I do not recall that moment in time. At the moment in
17 time when it was discussed --
18 LORD JUSTICE SCOTT BAKER: You are dropping your voice
19 again. It is very, very difficult to hear you even
20 here, so could you please make an effort.
21 A. When we were in the car and we were discussing the topic
22 of the confidentiality agreement and the ring was
23 discussed at that moment in time, there was a multitude
24 of things that were being said of how -- I did not know
25 what to say to him when he said something like that.

56

1 MR HILLIARD: But did you return to the topic?
2 A. No.
3 Q. Did it ever cross your mind that he was actually just
4 making it up?
5 A. It did, on many occasions, but the fact that he made
6 the statement with his own lawyers telling him that he
7 had to get me to sign the confidentiality because if it
8 was to come out that he had the ring he could get into
9 serious trouble led me to believe he was telling
10 the truth.
11 Q. But if you had thought about it for a moment, if that
12 was right, the simplest thing would just have been not
13 to tell you about it. You must have appreciated that?
14 A. If he wanted me to continue working with him and he
15 wanted me to sign the confidentiality agreement, maybe
16 he wanted to let me know.
17 Q. Was this a topic, I am asking you this, that was
18 obviously always on his mind? I think what you are
19 saying is it was mentioned to you once and never again?
20 A. More or less, I can only recall the once in his car, in
21 the car outside the florist.
22 Q. As you understood it, where was the ring?
23 A. I have no idea.
24 Q. But I thought he was worried about getting into trouble
25 if anybody found out he had it?

57

1 A. That is correct.
2 Q. You were there employed as his PA and security and so
3 on?
4 A. That is correct.
5 Q. Because you wanted to go on working for him, you had not
6 expressed, as I understand your evidence, any
7 disapproval to him or anything like that?
8 A. I expressed my disapproval of a lot of things throughout
9 the time I was working with him.
10 Q. As I understand it, about the ring you were saying, or
11 did you?
12 A. Yes, I said I did.
13 Q. What did you say to him?
14 A. I said I was disgusted with him.
15 Q. What did he say?
16 A. He did not say anything more about it.
17 Q. Did he ever say anything about getting rid of the ring?
18 A. Yes.
19 Q. What was that?
20 A. It was the ring amongst other things.
21 Q. What other things?
22 A. He had jewellery and paperwork and papers that he had
23 hidden away.
24 Q. Yes?
25 A. Which he wanted to dispose of.

58

1 Q. Would this have been sometime in the year 2003?
2 A. During the course of the time that I was working with
3 him, yes.
4 Q. And did he tell you about them?
5 A. Tell me about what?
6 Q. About these items that he wanted to dispose of?
7 A. Yes.
8 Q. And where were they?
9 A. In this house next door to where he lived in Farndon.
10 Q. Who lived in the house next door?
11 A. A lady called Maddy.
12 Q. Did this property, as you understood it, include
13 the ring?
14 A. As I stood it.
15 Q. What was said about disposing of that property?
16 A. I was taking a booking for the Saga Rose, I think
17 it was, for one of the Cunard ships for him. They were
18 negotiating for him to do an after the dinner speech on
19 the ship and he wanted me to take some boxes of his old
20 books, I would describe it. And during the course of
21 a conversation of saying how he wanted me to get the
22 books on board, he expressed that that is where he could
23 put the jewellery to be able to throw it overboard on
24 the ship.
25 Q. And how much jewellery did you understand that there

59

1 was?
2 A. I am not sure of how much jewellery he would have had.
3 Q. And what did you say to that, to this suggestion?
4 A. I did not say anything at the time, I just planned and
5 spoke to the people who were dealing with the Cunard
6 ship and made sure that it did not happen, by cancelling
7 the engagement.
8 Q. Right. As you understood it, now, by this time,
9 the ring was in the house next door?
10 A. Yes.
11 Q. Right. Did you actually see him disposing of any
12 property that had come from the house next door?
13 A. Yes.
14 Q. And again, would this have been in 2003?
15 A. Thereabouts, or could be the beginning of 2003/end of
16 2002.
17 Q. And what did you see happen?
18 A. I was in his house in Farndon and he ran outside
19 the back of the house quite frantic, to the point that
20 I did not know where he was going or what he was doing.
21 I then followed him outside to the back, where he came
22 from the next door's house carrying a bin liner, which
23 he then set on fire.
24 Q. Just so we have the picture: you are -- I do not know,
25 what are the two of you doing, sitting talking and he

60

1 gets up and runs out?
2 A. No, people were in and out of the kitchen, his wife, his
3 children, his mother-in-law and Paul just, as he does,
4 just disappeared and ran out of the house, ran round
5 the back. For me, from a security point of view, I was
6 concerned which was why I tried to find him and
7 I eventually found him coming out of next door, out of
8 the back of the house.
9 Q. You said in your statement that this was when it was
10 getting dark; is that right?
11 A. Yes.
12 Q. And so when you next see him, what does he have with him
13 then?
14 A. A bin liner.
15 Q. One or more than one?
16 A. I do not recall. I would say definitely one.
17 Q. What did he do with it?
18 A. He set fire to it.
19 Q. Were you able to see what was in the bin liner?
20 A. Only to see that it was papers.
21 Q. That was all you could see?
22 A. Meaning all I could see in reference -- you mean did
23 I see what was on the paper, did I see it was just
24 containing papers?
25 Q. Stage by stage. First of all, as far as you could see

61

1 all that you could see that was in the bag was papers?
2 A. Yes.
3 Q. And then as far as what the paper was, were you able to
4 see that?
5 A. Yes.
6 Q. Is this right, you are standing -- I am looking at your
7 statement -- 2 metres away from him while he is doing
8 the burning; is that right?
9 A. More or less, yes.
10 Q. And is it dark now, when he is doing the burning?
11 A. It is getting dark.
12 Q. And what could you see of the paper?
13 A. That it was actually typed and handwritten paper.
14 Q. And I do not suppose from 2 metres away with it getting
15 dark you were able to read anything on the paper?
16 A. No.
17 Q. So, really, all you can say is that it is some typed and
18 some handwritten pieces of paper?
19 A. No, there was letterheaded paper.
20 Q. What was the letterhead?
21 A. Buckingham Palace.
22 Q. And for those of us who don't know, what does
23 a Buckingham Palace letterhead look like?
24 A. It has the crest and Buckingham Palace at the top of the
25 paper.

62

1 Q. Right. But is this right, I do not know, you help us:
2 what the documents were, what was on them, whether they
3 were a letter or a memorandum, presumably anything like
4 that you cannot help?
5 A. Not really, no.
6 Q. And you have said recently I think, is this right, that
7 some of the documents appeared to be typed on an
8 old-fashioned typewriter?
9 A. Yes.
10 Q. Now, you saw I think Metropolitan Police officers in
11 March 2007. Do you remember that?
12 A. Yes.
13 Q. A Detective Inspector Scotchbrook I think and some
14 others?
15 A. Yes. Can I get a copy of that statement?
16 Q. Yes, by all means, by all means.
17 A. It is not a statement, it is a copy of a note.
18 Q. Yes, do you have that all right?
19 A. Yes.
20 Q. Mr Faux, you mentioned there that you had seen
21 Mr Burrell -- the note says this:
22 "I saw him going to and from his house with bin bags
23 full of paperwork that he was taking into his garden to
24 burn and he was making sure that it was thoroughly
25 burned."

63

1 A. Yes.
2 Q. There is no reference I think in that note, if I am
3 right, to what was actually on the paperwork?
4 A. No.
5 Q. When did you remember that some of the documents
6 appeared to be typed on an old-fashioned typewriter?
7 A. It was not a case of me remembering, I always knew.
8 I define -- if I said to you it was typed, that is how
9 I would define typed on an old-fashioned typewriter.
10 It was not a word processing letter.
11 Q. Did you ask him anything about what he was doing and why
12 he is doing it?
13 A. No. Not at the time, no.
14 Q. Just so that we have the picture, you are there standing
15 outside with him and he is, what, going to and from to
16 next doors, coming back with a bin bag of property?
17 A. No, the words I define as saying he was to and fro,
18 I would define as being he was running round the garden
19 backwards and forwards to his house, back to the house
20 next door frantically, that was the toing and froing
21 from the house. Then he emerged with the bin bag and
22 went to the back garden and set fire to it I stood there
23 watching for paparazzis and for photographers maybe
24 coming over the back garden which he had been doing
25 because Mr Burrell, as I felt, was burning the papers

64

1 and should not have been doing. I did say something in
2 reference to what he was doing. He never would ever
3 reply, as he would not do on many an occasion.
4 Q. When you say burning papers that he should not have
5 been?
6 A. That is my opinion, if you have stuff hidden away and it
7 is hidden away in the house next door and you are
8 looking towards it getting -- going dark to then wanting
9 to go out the back without me knowing to burn them,
10 I would say it was paperwork he should not have been
11 burning.
12 Q. What I want to know is this: did you say anything to him
13 about why he was doing what he was doing?
14 A. Yes.
15 Q. What did you say?
16 A. Words like, "What are you doing, why are you doing this,
17 Paul? What is going on?" "Nothing, I need to do this,
18 Mike, I need to do this". These would be the sort of
19 phrases and way that he would speak to me.
20 Q. In terms of actually getting any information or
21 an explanation from him --
22 A. He never -- he would very rarely divulge.
23 MR HILLIARD: -- you would get nothing.
24 Right. Yes, thank you very much indeed, thank you.
25 LORD JUSTICE SCOTT BAKER: Mr Mansfield?

65

1 Questions from MR MANSFIELD
2 MR MANSFIELD: Just a few questions please. I will do it
3 chronologically in terms of who you have seen.
4 I want to ask you first of all about the occasion
5 last year when you saw the police, do you follow? That
6 is what I want to ask first because until last week
7 we had no idea, that is those of us on this side of this
8 tribunal, had no idea that had you spoken to the police,
9 do you follow?
10 A. Yes, sir, I do.
11 Q. We now understand that you did and a record was kept
12 which you have in front of you now?
13 A. Yes.
14 Q. First of all, did the police ask you to make a statement
15 in 2007?
16 A. No.
17 Q. Did they say they were going to ask you to make
18 a statement?
19 A. I do not recall. I do not think so, no.
20 Q. By which I mean a written statement signed by you. That
21 is what I mean.
22 A. No.
23 Q. They did not. And how long did they spend with you,
24 roughly speaking? Half an hour? An hour?
25 A. 20 minutes/half an hour.

66

1 Q. Did they keep a written note as you were speaking?
2 A. They were taking notes.
3 Q. Did they ever show you the notes?
4 A. No.
5 Q. Or ask you to sign the notes?
6 A. No.
7 Q. Or ever get back to you about the interview that they
8 had had with you?
9 A. No. Sorry, sir, there was one occasion where they had
10 phoned to ask, they wanted to know the dates of when
11 I actually started to work with Mr Burrell. That was
12 the only occasion.
13 Q. And the date on the notes is 20th March 2007. How long
14 before that did the police contact you, again, roughly
15 speaking?
16 A. Can you repeat that, sorry?
17 Q. Yes. How long before the date on the message, it is
18 called a message which is a note of a meeting with you
19 and the date is 20th March and I am assuming that is
20 the day on which you met them, that is the police; how
21 long before that did they contact you, do you remember?
22 A. I do not, sir, no.
23 Q. Did they tell you why they wanted to speak to you before
24 they got to you, as it were?
25 A. Yes.

67

1 Q. Right. What did they say?
2 A. It was regarding a ring.
3 Q. Regarding a ring. Now, do you remember which officer
4 asked that? Because we know from the note that there
5 were at least two there. There is a DI Scotchbrook and
6 she is here today and also DS Grater. Do you know which
7 of the two mentioned a ring before they ever got to you?
8 A. I beg your pardon, I am not sure whether it was
9 discussed on the telephone during the course of making
10 the appointment or actually it was discussed once they
11 had arrived at the office that it was to do with
12 the ring.
13 Q. It was to do with a ring. And of course, the notes
14 indicate that you did talk about the ring to those
15 officers. It is there on the second page, isn't it?
16 A. Yes.
17 Q. Because your impression was, as you told them, that
18 the ring belonged to the Princess of Wales and was
19 amongst of materials that Burrell was suggesting he
20 might dispose of?
21 A. Yes.
22 Q. Now, I want to take up then, that is what happened last
23 year. Between last year and your solicitor making
24 contact with the lawyers at Harrods, had any police
25 officer made any contact with you asking you to come and

68

1 give evidence?
2 A. No.
3 Q. When you went and saw somebody in order to take
4 a statement, which we know you have, a witness
5 statement, was anything said to you when this statement
6 this year -- it is dated 17th March, so it is very
7 recent indeed. I do not know whether yours is dated.
8 I have just been handed one.
9 A. It is sir, yes.
10 Q. Was that dated on the day you signed it and was that
11 the same day as you made the statement?
12 A. No.
13 Q. So when were you interviewed in order to get a statement
14 of the kind that is now dated 17th March, do you recall?
15 It is all very recent.
16 A. It is. It was only last week.
17 Q. Whenever it was precisely before the 17th that you
18 actually were seen to make this statement, was anything
19 said about a message recording a meeting the previous
20 year?
21 A. Yes, they mentioned and presented me with the statement,
22 the notes.
23 Q. Was anything said about why nothing had been done about
24 that message?
25 A. No.

69

1 Q. The reason I want to ask you carefully about some of the
2 matters is that you told the police almost exactly
3 a year ago that Paul Burrell had in fact stored property
4 not at his own address and that the police had searched
5 the wrong house. That is how you put it, isn't it?
6 A. Yes.
7 Q. Now, can you help us because the question is whether or
8 course anybody has bothered to go and investigate this
9 matter further. Which next door neighbour were you
10 referring to a year ago, as housing property relating to
11 Burrell and Princess Diana?
12 A. If you looked at the front of the house, it was
13 the house to the left and it was a flat which was above
14 a shop on the left-hand side.
15 Q. I ask you: what was the shop engaged in? Do you
16 remember what it was about, that shop?
17 A. I recall, I think it was a car insurance --
18 Q. Right. The reason I ask you is that Mr Burrell has been
19 asked about all of this since and he says on one side
20 was an insurance company. So, it is above the insurance
21 company that somebody lived?
22 A. Yes.
23 Q. And you told the police the names, didn't you?
24 A. I told them the lady's name, that I believe is Maddy.
25 Q. You give a description. I am not going to read it out

70

1 in public, but you gave the police a description of her,
2 her age and her condition.
3 A. Yes, but not in the words in that statement.
4 Q. I do not want to cause anybody any personal
5 embarrassment or intrusion, so I am not going to read
6 out what is on the note, do you follow?
7 A. Yes, sir, thank you.
8 Q. Again, I am not going to ask for details but she had
9 a teenage son living with her in the flat?
10 A. Yes.
11 Q. So it is clear that she and her son would know that he
12 was keeping something at her address?
13 A. Yes I would have thought so, yes.
14 Q. Did you ever go there yourself to the --
15 A. No, sir, I did not.
16 Q. So how much property did you see coming from that
17 address, as it were, just the bin bags that you have
18 talked about?
19 A. Yes.
20 Q. One, possibly two.
21 A. Yes.
22 Q. Now, when you went out and out the back after him, was
23 he coming out of the rear of the premises to the left,
24 in other words, the insurance with the flat above?
25 A. Yes.

71

1 Q. He was. Did you ask him what he was doing or why he was
2 doing it?
3 A. I asked him why he was doing it.
4 Q. And did he give you a reply?
5 A. No.
6 Q. Now, on this occasion, I appreciate now that it is
7 a little time ago and you have given us a statement of
8 when it was, could you give us a month of the year or
9 not, as to when this happened?
10 A. Of the burning of the --
11 Q. Yes, the burning of the bin liner or liners.
12 A. I would say it was either November or December 2002.
13 Q. Right. I am sorry to be particular, there are reasons
14 to do with follow-ups; was this a weekday or a weekend?
15 Can I approach it that way, can you help?
16 A. I would be guessing if I was to say.
17 Q. Is there anything else that could assist in trying to
18 identify more precisely when it happened, something else
19 that may have happened, either in the public domain or
20 in your life or Mr Burrell's life for that matter? Do
21 you follow what I am asking.
22 A. Can I look at this? I have found this Filofax which has
23 some notes from 2002 so there might be something, if
24 I can look through that, if I may.
25 Q. I would have to ask the learned Coroner's permission,

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1 but can I identify what it is. Is it your Filofax?
2 A. Yes.
3 Q. And you have kept notes in it?
4 A. I started to take notes of bookings and so on and I am
5 trying to define, I think, when the booking was for
6 the Cunard ship, which was around about the time of
7 him --
8 MR MANSFIELD: Sir, I wonder if he might look at it.
9 LORD JUSTICE SCOTT BAKER: Yes.
10 MR MANSFIELD: Could you look at the Filofax and help us
11 either with regard to the Cunard booking or anything
12 else?
13 A. Sorry, sir, to be keeping the court.
14 LORD JUSTICE SCOTT BAKER: No. Take your time.
15 A. I have a date of January, Sunday 5th, of 2003, where
16 I have put: "Ship sails, books need to be at
17 Southampton". Prior to that, I have a date, it is in
18 the diary for December, Saturday 30th, "Phone Margaret
19 regarding the cruise for the Saga Rose". So I can only
20 say that it was around that time.
21 MR MANSFIELD: So it is around that time.
22 Now, beside the neighbours, that is the woman and
23 her son, on the occasion when the burning took place,
24 Paul Burrell's wife was present in his home.
25 A. Yes.

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1 Q. And his mother-in-law, did you say?
2 A. Yes.
3 Q. Did they know what he was doing?
4 A. Probably not. No.
5 Q. I want to ask you, can you help us, what was it that
6 suddenly galvanised, if you understand, Paul Burrell to
7 do this? What was the trigger? Why did he suddenly
8 rush out of the house?
9 A. He was a very irrational person. He would do things but
10 he would keep it very private and keep it to himself.
11 On that particular evening, I could not answer to this
12 day as to why he would frantically run outside and start
13 burning documents in his back garden, especially with
14 him knowing that the attention was on him at that time
15 by the media in the first instance.
16 Q. He accepts, because he has been asked, that he often
17 burned his personal correspondence outside in a brazier.
18 First of all, did you see him doing it often?
19 A. No, never.
20 Q. If he is doing that, which is what he is now saying he
21 did do, it was obviously not when you were around?
22 A. Yes.
23 Q. And he is also accepting that he may have burned
24 documents with Buckingham Palace typeface on them. Is
25 there any doubt in your mind that you saw that?

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1 A. No.
2 Q. I want to ask you about something you told the police
3 a year ago. Paul Burrell had said that it would need
4 a truck to move all the jewellery and items, there was
5 so much of it. This is in relation to disposal of
6 property. Is that what he told you?
7 A. Yes.
8 Q. And when he was doing this exercise of burning, did he
9 appear to make sure there was no trace left of the
10 paperwork; in other words, that it was thoroughly
11 burned?
12 A. Yes.
13 MR MANSFIELD: Thank you very much?
14 LORD JUSTICE SCOTT BAKER: Thank you.
15 MR KEEN: No questions sir.
16 LORD JUSTICE SCOTT BAKER: Mr Croxford?
17 MR CROXFORD: No thank you, sir.
18 LORD JUSTICE SCOTT BAKER: Mr Horwell?
19 Questions from MR HORWELL
20 MR HORWELL: Mr Faux, do you believe that by giving evidence
21 today, you will be released from the confidentiality
22 agreement?
23 A. Yes.
24 Q. So, by putting yourself forward as a witness at these
25 inquests, you believe that you will be released from

75

1 your confidentiality agreement as a matter of law, it
2 will no longer apply to you?
3 A. I have been led to believe that by giving evidence today
4 in this court, that my confidentiality agreement would
5 not be in place during the course of this inquiry in
6 this court.
7 Q. And what about once you give evidence and you leave
8 court, does the confidentiality agreement still apply or
9 not?
10 A. I believe so.
11 Q. You were asked a question by Mr Hilliard at the start of
12 your evidence it was a very straightforward question:
13 "Question: Have you been in touch with any media
14 outlet or newspaper in recent weeks, days or months?
15 "Answer: Yes.
16 "Question: Is that in connection with the evidence
17 that you are going to give the jury this morning?
18 "Answer: Yes."
19 What did you mean by that?
20 A. I am trying to work out in my mind as to what dates
21 I may well have spoken to a newspaper, because
22 the question was whether I had spoken to a newspaper
23 with reference to this inquiry and yes, I have and
24 the purpose of doing that was to able to see whether or
25 not I could come forward to get over my confidentiality

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1 agreement.
2 Q. The question was very much aimed at the recent past.
3 That is why Mr Hilliard posed the question that he did,
4 no doubt:
5 "Question: Have you been in touch with any media
6 outlet or newspaper in recent weeks, days, months?
7 "Answer: Yes."
8 A. Yes.
9 Q. When was the last time that you were in contact with any
10 newspaper or media outlet?
11 A. Probably within the last two months.
12 Q. And who was that?
13 A. It was the -- was it The Sun? I think it was The Sun.
14 The Sun newspaper.
15 Q. And what happened?
16 A. Nothing.
17 Q. Well, what happened?
18 A. Nothing happened.
19 Q. You contacted The Sun, what happened?
20 A. Nothing happened.
21 Q. You contacted The Sun, Mr Faux, so something must have
22 happened. Do you understand?
23 A. Yes, sorry. Well, I contacted them, told them that
24 I had maybe something to say. I wanted to see whether
25 or not their lawyers could do anything about it and

77

1 the answer to that was basically, no, they could not,
2 which is why nothing went to press.
3 Q. Why a couple of months ago? Why then? I thought you
4 had been told this before, Mr Faux; is that not right?
5 A. Yes, many an occasion, yes.
6 Q. So on many occasions you had gone to newspapers or media
7 outlets and you have been told that there is no way
8 around the confidentiality agreement?
9 A. Yes.
10 Q. Yet notwithstanding the fact that you have been told
11 that on many occasions, you had one more try a couple of
12 months ago with The Sun newspaper?
13 A. Yes, I would have continued to try until I was able to
14 say what I had to say.
15 Q. Are you hoping to be able to make money out of your
16 account of your time with Burrell?
17 A. No.
18 Q. You are not interested in money at all?
19 A. Of course I am, as much as anybody else would be.
20 Q. But in relation to selling the story?
21 A. No.
22 Q. So money is not your motive in going to the press; is
23 that right.
24 A. No, it was not my motive, no.
25 Q. Have you at any stage raised the topic of payment with

78

1 the press or any media outlet?
2 A. The media outlet have raised the topic, I have not
3 raised the topic.
4 Q. What sort of figures have been spoken about?
5 A. £10,000, maybe more.
6 Q. And you would accept that, if you were able to sell your
7 story, would you?
8 A. No.
9 Q. You would sell the story and say: I do not want a penny,
10 keep your £10,000 or more?
11 A. I was not going to the papers to sell my story, I was
12 going to the papers to get round my confidentiality
13 agreement.
14 Q. So if The Sun two months ago had said, "We have this
15 amazing lawyer and we can get around the confidential
16 agreement", what would have happened?
17 A. I probably would have spoken to the lawyers.
18 Q. And sold your story?
19 A. If it was to be sold as a story, yes.
20 Q. And taken money?
21 A. Yes.
22 Q. You have told the jury about the company that you have,
23 Executive Group Holdings; a holding company for
24 security, cleaning and concierge services.
25 A. That is correct.

79

1 Q. What has happened to that company?
2 A. Nothing has happened to the company.
3 Q. It exists today?
4 A. The company -- the Executive Group Holdings is a dormant
5 company. The company that I trade under is Executive
6 North, trading as Bodyguard Protection.
7 Q. That company exists today and is trading?
8 A. Yes.
9 Q. And how many people do you employ today?
10 A. 84.
11 Q. I want to take you first, Mr Faux, through a reply that
12 Burrell has given these inquests, I think on Friday
13 it was received. This is a reply to your statement:
14 "Michael Faux was employed by the Daily Mirror
15 newspaper as a bodyguard for myself. He was employed by
16 the Daily Mirror for a period of three months. After
17 three months, I employed him as my own bodyguard."
18 Do you agree with that?
19 A. Yes.
20 Q. "At no point did I employ him either as a personal
21 assistant or as an agent. He was only ever employed as
22 a bodyguard for me."
23 A. It is lies.
24 Q. He will explain that in a moment, but I will carry on.
25 "He had no contract of employment with myself.

80

1 I paid him cheques or cash whenever he asked for any
2 money. I think in total, I probably paid him between
3 £15,000 and £20,000. I also bought him and his wife
4 expensive jewellery. He followed me wherever I went and
5 came on all-expenses-paid trips."
6 A. Some of it is true and some of it are lies.
7 Q. What is a lie?
8 A. I have represented him as an agent and it was working --
9 I was going to get 20 per cent of whatever his earnings
10 would be. During the course of his bookings and his
11 engagements I accompanied him and went on the trips,
12 ie to America, which would be expenses paid by
13 the people that were engaging Paul and their
14 appointment.
15 Q. But did he pay you between £15,000 and £20,000?
16 A. No.
17 Q. He goes on to say this:
18 "I can categorically state that he had no skills as
19 either a personal assistant or as an agent."
20 A. What would you like me to say to that? It is quite
21 obvious that he is going to say that. If you would like
22 me to show documentation to prove that I was acting as
23 his agent and acting as his personal assistant, then
24 I can.
25 Q. Had you worked for anyone else previously as a personal

81

1 assistant or agent?
2 A. Not as an agent, no.
3 Q. Had you worked for anyone else as a personal assistant?
4 A. Yes?
5 Q. Who was that, and when.
6 A. Personal assistant can be construed in different
7 phrases, ie being a tour manager. I was a tour manager
8 for many years with different band members and so on and
9 so forth in the music industry which would entail doing
10 exactly what I was doing for Paul Burrell.
11 Q. How long ago had you finished doing that?
12 A. I was continuing doing that. I was doing that prior to
13 Mr Burrell.
14 Q. "At no time did I agree an 80/20 split with him in
15 respect of my royalties."
16 A. Utter lies.
17 Q. Well, no doubt there is a written contract setting that
18 out, Mr Faux, could we have sight of that?
19 A. There was no written contract. It was an agreement made
20 in my home. If you look at Companies House, you will
21 see that there is Mr Cassidy Kirk(?) - Cassidy & Kirk
22 Limited(?) is the name that we both made up as the
23 company, which was his mother's maiden name and my
24 mother's maiden name. So that would prove and show that
25 he is lying.

82

1 Q. I am not asking whether you and Mr Burrell set up
2 a company together, Mr Faux. I am asking you, please,
3 for written evidence of this 80/20 split.
4 A. It is at home, or in my office.
5 Q. "I could pay him the money which he needed because I had
6 at that stage been paid quarter of a million pounds by
7 the Daily Mirror for my story."
8 Did you know that?
9 A. No, I did not know that.
10 Q. He had obviously made a lot of money by this time from
11 selling his story to the Daily Mirror?
12 A. I would assume so, yes.
13 Q. And you were to get a 20 per cent split of that, were
14 you?
15 A. No, not at that time, because that was the exclusive for
16 the newspaper; the newspaper were paying me a salary.
17 Q. What were you going to get 20 per cent of?
18 A. Anything thereafter, that was agreed.
19 Q. His books?
20 A. Book, yes.
21 Q. And have you received your 20 per cent of his income
22 from the books?
23 A. No.
24 Q. And have you done anything about that?
25 A. No.

83

1 Q. You have not sued him?
2 A. No.
3 Q. Even though you say you have a written contract clearly
4 setting out that you are entitled to 20 per cent of his
5 income for anything published after the Daily Mirror
6 article?
7 A. I have approached lawyers regarding it. I cannot afford
8 to take him to court and sue him.
9 Q. "I did not treat him as a confidant. He was only ever
10 treated as a colleague and a friend."
11 You will not agree with that, presumably?
12 A. No.
13 Q. "Steve Dennis suggested that both he and Mr Faux should
14 sign confidentiality agreements. I think it was Steve
15 who drafted the agreement. Mr Faux originally refused
16 to sign the agreement. I was upset because if he
17 wouldn't sign the agreement then I could not continue to
18 employ him. I did meet him in my car outside the shop.
19 I was not in tears. I asked him to sign the agreement
20 again. He agreed to sign the agreement."
21 A. I agreed to sign the agreement, yes, as I have stated.
22 Q. That confidentiality agreement contains no reference to
23 the 80/20 split at all, does it?
24 A. No.
25 Q. "At that point, there was no conversation about a ring.

84

1 I had never referred to the Bulgari friendship ring as
2 an engagement ring. This is not my opinion of what
3 the ring was. I had never told anybody that I have had
4 possession of that ring. I am not in possession of that
5 ring."
6 We have seen a photograph of this ring, Mr Faux, and
7 it is not in any sense a conventional engagement ring.
8 I am just asking you as to whether or not Mr Burrell has
9 ever described the Bulgari ring as an engagement ring?
10 A. No. No, sir, he did not.
11 Q. So he was not saying that he had the engagement ring?
12 A. His statement in the car was when he said he had
13 "the engagement ring" and that was the only time he
14 referred to a ring as being an engagement ring.
15 Q. The engagement ring has either been at Arsene Houssaye
16 or under Mr Fayed's control ever since the crash in
17 the Alma Tunnel. No one has ever suggested that
18 Mr Burrell had the engagement ring. He had another
19 ring, a Bulgari ring referred to as a friendship ring.
20 I am just wondering why on earth Mr Burrell would
21 have ever described that ring as an engagement ring,
22 Mr Faux. Do you understand?
23 A. I do understand.
24 Q. But you say he did?
25 A. Yes, he did.

85

1 Q. "My recollection is that after he signed
2 the confidentiality agreement, he was employed for some
3 time after. After a while, I no longer needed his
4 protection and therefore, our working relationship came
5 to an end."
6 Do you agree with that, or not?
7 A. No, I do not agree with it.
8 Q. "Mr Faux makes reference to me collecting property from
9 my next door neighbour's. At no time did I store any
10 property next door. On one side was an insurance
11 company and on the other side were my friends Emma and
12 Grant. At no time did I store any documents or other
13 items in either of these two premises."
14 You say he stored items in the flat above
15 the insurance shop, the flat that was Maddy's?
16 A. Yes.
17 Q. "I accept that I often burned my personal correspondence
18 outside in the brazier. I will burn personal letters
19 which I have received and bank statements, et cetera.
20 However I have never burned anything of an important
21 nature in the brazier."
22 You say there was this occasion?
23 A. Yes.
24 Q. No doubt he burned property on other occasion, Mr Faux?
25 A. No idea.

86

1 Q. "I cannot recall any incident whereby Mr Faux was
2 standing with me in the garden whilst I burned
3 documents. I would not normally set fire to the bin
4 bag. I would put the documents into the brazier one
5 page at a time."
6 How did he burn these documents?
7 A. Through the bin bag, by setting fire to the bin bag.
8 Q. Just put the bin bag in the brazier?
9 A. There was no brazier, he put it on the grass.
10 Q. Did he have a brazier?
11 A. Not that I can recall.
12 Q. What, he had a fire on the grass?
13 A. No, he brought the bin bag out onto the grass and set
14 fire to it .
15 Q. So any wind that was blowing could have blown documents
16 away?
17 A. Could well have done, yes.
18 Q. "I may have burned documents with the Buckingham Palace
19 typeface on them. This is because all memorandums and
20 documentation which we received when we were working at
21 Buckingham Palace had the typeface on them. These were
22 not important documents and would have been burned to
23 prevent them cluttering my home. I do not recall
24 burning any documents which had an old-style typewriter
25 writing on them."

87

1 You have been asked about the crest, what colour was
2 the Buckingham Palace crest?
3 A. If I recall, the paperwork was yellow and the crest was
4 like of a gold colour.
5 Q. A gold crest?
6 A. Well, it was gold at the top, that is all I can recall.
7 Q. "Mr Faux makes reference to me being booked on Cunard to
8 book a tour. I was only ever booked on Cunard before my
9 trial in 2001. I have not been booked with Cunard since
10 this date. The person who arranged this was Philip
11 Gosling."
12 A. It is a lie.
13 Q. You say there was a booking later, but he never went on
14 the cruise?
15 A. That is right.
16 Q. Because you cancelled it?
17 A. That is right.
18 Q. And what he did say about that?
19 A. He did not say anything. He wanted to do it but I felt
20 that he wanted to do it for the wrong reasons, which is
21 why I made sure that we did not go.
22 Q. This is because he was going to throw jewellery.
23 A. That is correct.
24 Q. Are there rivers nearby where he lived?
25 A. Yes.

88

1 Q. "At no time did I discuss with Mr Faux disposing of
2 property over the side of a boat.
3 "At no time did Mr Faux cancel an engagement I had
4 with Cunard, because I never had one in the first
5 place."
6 You disagree with that?
7 A. Totally.
8 Q. He refers to a box file containing photographs which you
9 were given and he accepts?
10 A. Yes.
11 Q. You also say that he told you about the occasion on
12 which the Princess was told that Mannakee had died?
13 A. Yes.
14 Q. And the account that you have given of
15 the Prince of Wales breaking that news to her.
16 A. Yes.
17 Q. Are you suggesting anything sinister in this, Mr Faux?
18 A. I am not suggesting anything.
19 Q. You are not?
20 A. No.
21 Q. You also mention Burrell explaining that the Princess
22 had an injury to her neck --
23 A. Yes.
24 Q. -- at the hospital?
25 A. Yes.

89

1 Q. When she was laid to rest, when she was laid to rest.
2 Meaning what? What do you take from that, Mr Faux?
3 A. When he explained and described what he had seen at
4 the hospital, he explained that it was very upsetting
5 for him and that he could only go and view the body from
6 one side because the other side of her body was
7 disfigured.
8 Q. That is it, nothing to take from that?
9 A. Well, reference to her neck being twisted.
10 Q. Mr Burrell says:
11 "I never spoke to him about any injury to her neck.
12 I certainly never suggested that her neck had been
13 deliberately broken. This is not my opinion and I would
14 never have expressed this opinion to him."
15 Finally this:
16 "Mr Faux states that he did not contact the Coroner
17 because of the confidentiality agreement which he
18 signed. The reality of the situation is that Mr Faux
19 has already contacted national newspapers with regard to
20 selling stories relating to my private life."
21 Well, that is true, isn't it?
22 A. Everything that -- it is only until now, by you reading
23 the statement that Mr Burrell has stated, that
24 the majority of what he said in there are lies.
25 Q. He is accurate about that, isn't he?

90

1 A. He is accurate about me going to the newspaper, yes, but
2 for the wrong reasons.
3 Q. I do not want to go all over that again, Mr Faux. You
4 would have accepted money from the newspaper, you have
5 told us, for selling your story?
6 A. Yes.
7 Q. You were interviewed by the police on the 12th March of
8 last year. And you described the burning incident in
9 this way:
10 "Some time after the Burrell trial, Burrell decided
11 he had to dispose of the property. I saw him going to
12 and from his house with bin bags full of paperwork that
13 he was taking into the garden to burn and he was making
14 sure it was all thoroughly burned."
15 A. That is correct.
16 Q. Do you accept that you said that?
17 A. Yes.
18 Q. You did tell the police last year that he was taking
19 the bin bags from his house?
20 A. No, I did not.
21 Q. That is what I have just read to you, Mr Faux?
22 A. You said that he was running to and fro from the house
23 next door which I have already explained, he went to and
24 fro from the house next door but he came back with
25 the one bin liner.

91

1 Q. This is what I suggest you said last year.
2 A. Is that the statement, can I look at that?
3 Q. That is message 1111 which I hope you have, Mr Faux. Do
4 you?
5 A. It is what, sorry?
6 Q. You will see message 1111 on the top left-hand corner.
7 Do you have it?
8 A. No.
9 Q. Then you should have it, I do not know if anyone has
10 a spare.
11 Do you have that?
12 A. Sorry, I did have that. Sorry.
13 Q. It is the second page, Mr Faux.
14 A. Yes five lines down from the top, MF, that is you:
15 "I saw him going to and from his house with bin bags
16 full of paperwork that he was taking into the garden to
17 burn."
18 "His house", Mr Faux.
19 A. It does state that, but that is not what I said.
20 Q. I suggest that if 2007, all that you have said about
21 this incident is that Burrell was taking property from
22 his house to burn.
23 Did you also tell the police that --
24 MR MANSFIELD: Sir, I wonder if -- my attention has been
25 drawn -- I think it is important. The handwritten

92

1 original note does not quite say that.
2 LORD JUSTICE SCOTT BAKER: Yes.
3 MR MANSFIELD: We were provided with these. Mr Croxford
4 very kindly drew my attention to this paragraph. Sir,
5 do you have the handwritten?
6 LORD JUSTICE SCOTT BAKER: Yes, I do. Yes.
7 MR MANSFIELD: It is on the first page, under the date,
8 12th March:
9 "Question: How were you made aware it was next
10 door?"
11 "Answer: He told me, neighbour next door who lives
12 alone to the left above the shop saw him running out
13 with bin liners burning paperwork."
14 That is what it says in the notes. It is not quite
15 the same as what is in the typed version.
16 LORD JUSTICE SCOTT BAKER: Yes.
17 MR HORWELL: You will understand, Mr Faux, that the typed
18 version is a much fuller record of what it was that you
19 said.
20 A. That is not quite right though, sir, to be fair. It is
21 not right.
22 Q. You say it is not right?
23 A. Yes.
24 Q. Did you advise Burrell that he should bury
25 the jewellery?

93

1 A. I did not advise him. It was a terminology at the time
2 of being with him in the hysteria of how he is, I said
3 to him: "You must do something with it, you cannot keep
4 it, bury it." That was just a terminology, I did not
5 mean it literally.
6 Q. Then, earlier this month, had you a meeting with
7 Stuart Benson and John Macnamara?
8 A. Yes.
9 Q. Where was that meeting?
10 A. At Harrods.
11 Q. And what happened on that occasion?
12 A. What happened? We discussed this investigation.
13 Q. Were you shown any documents at this meeting?
14 A. No.
15 Q. Any documents with a particular typeface on it?
16 A. No.
17 Q. Not just at this meeting, Mr Faux, were you told about
18 the importance of a particular typeface?
19 A. Not the importance, no.
20 Q. Or relevance? What discussions has anyone had with you
21 about a particular typeface, Mr Faux?
22 A. I was asked whether or not the documents, what sort of
23 documents I had seen during the course of the burning
24 and I had mentioned that they were handwritten and
25 it was typed. And then the question was asked whether

94

1 or not, what do you define as typed or what do you
2 define as written, would you be able to recognise
3 the handwritten again, do you know what sort of typeface
4 it was? And it was reference to an old typewriter.
5 Q. Were you shown any documents then or at any time,
6 Mr Faux?
7 A. No.
8 Q. Do you know the relevance of an old-fashioned
9 typewriter?
10 A. Not really, no.
11 Q. You say, "Not really": do you know the relevance of
12 an old-fashioned typewriter?
13 A. No.
14 Q. Why did you say, "Not really"?
15 A. Because I am not too sure of what the question is, of
16 whether or not I have relevance to --
17 Q. Well, the relevance of an old-fashioned typewriter or an
18 old-fashioned typeface that has anything to do with this
19 at all?
20 A. Yes.
21 Q. And what is that?
22 A. It is to do with the monarchy and reference to whether
23 or not somebody there was using an old typewriter.
24 Q. And where did you get this information from?
25 A. From the gentleman who -- during the course of their

95

1 investigation.
2 Q. And which gentleman was this?
3 A. The gentleman that I met at Harrods.
4 Q. And which gentleman was this, Mr Faux?
5 A. I cannot remember the names, I am sorry.
6 Q. You have told us Benson and Macnamara.
7 A. Benson and Macnamara.
8 Q. What did they tell you of the relevance of an
9 old-fashioned typewriter and typeface?
10 A. They told me that the documents that may well have
11 the relevance of why it was important have reference to
12 whether it was a typewriter or not was because the Duke
13 of Wellington or somebody was sending documents,
14 I presume. I do not know.
15 Q. What else did they tell you?
16 A. That was it, nothing else?
17 Q. And nothing was shown to you?
18 A. No.
19 LORD JUSTICE SCOTT BAKER: It is regrettable, Mr Horwell,
20 that one of the interested person's solicitors should
21 see fit to interview a witness when his client plainly
22 has an interest and the appropriate course would have
23 been to refer my office to the existence of this
24 information.
25 But there we are.

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1 MR HORWELL: Sir, yes. I agree.
2 So, the position is this, Mr Faux, I suggest.
3 The police in 2000, you simply reported the burning of
4 property, I suggest coming from Burrell's house,
5 paperwork is the only description you gave. And that
6 now we have you describing Burrell taking a bag from
7 Maddy's flat next door which contained documents, some
8 of which were written by an old typewriter, showing an
9 old typewriter face.
10 A. I would define as being an old typewriter.
11 Q. I would suggest that your account has changed since that
12 that you gave in 2007.
13 A. I disagree.
14 Q. You know perfectly well the importance of that change,
15 don't you?
16 A. Now I do, yes.
17 Q. You knew when you met Benson and Macnamara --
18 A. No. I did not.
19 Q. -- of the importance of that change, didn't you?
20 A. No.
21 Q. And I will ask you again: are you intending at some
22 stage in the future to sell your story to a newspaper if
23 you can get around the confidentiality agreement?
24 A. No, that was not my intention and never has been.
25 Q. You are never, ever, ever going to approach any

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1 newspaper or media outlet after today; is that right?
2 A. I am not going to approach anybody, no.
3 Q. And if they approach you?
4 A. I would give it some thought.
5 MR HORWELL: Thank you.
6 LORD JUSTICE SCOTT BAKER: Mr Hilliard?
7 Further questions from MR HILLIARD
8 MR HILLIARD: I just wanted to make sure that I have
9 understood. Mr Horwell asked you if you knew
10 the relevance of an old-fashioned typewriter. Do you
11 remember at first you said "Not really", then he asked
12 you the question again, "What did you mean by that" and
13 you said no, you did not.
14 In fact, if I understood you right, you had been
15 told at the meeting what the relevance was?
16 A. Yes.
17 MR HILLIARD: All right. Thank you very much.
18 LORD JUSTICE SCOTT BAKER: Thank you, Mr Faux, that will be
19 all, we are grateful to you for coming.
20 MR MANSFIELD: Sir, I may I raise one matter? It does not
21 involve the witness.
22 LORD JUSTICE SCOTT BAKER: Yes.
23 MR MANSFIELD: It is considering one of the areas that has
24 been of interest throughout plainly has been tracking
25 certain documents. I think you are aware of

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1 the documents to which I refer.
2 In view of the fact that the police a year ago had
3 information from this witness about the storage of
4 materials, I would ask that if it has not been done
5 already and I am not asking why it has not, that these
6 matters, before it is too late, are inquired into
7 further.
8 LORD JUSTICE SCOTT BAKER: Mr Horwell, can you help?
9 MR HORWELL: Excuse me for one moment.
10 The question I am sure is concerned with Maddy and
11 has Maddy ever been asked. The answer to that I am told
12 is no. And plainly we would invite you to ask your
13 officers now to make that inquiry.
14 LORD JUSTICE SCOTT BAKER: Yes, but it is going to have to
15 be done pretty quickly.
16 MR HORWELL: I appreciate that, and it will be.
17 LORD JUSTICE SCOTT BAKER: Thank you.
18 MR BURNETT: Sir, there is a short statement from
19 Martin Smith which deals with searches conducted by
20 Lady Sarah McCorquodale following questions asked of her
21 in evidence here.
22 It is dated Friday 14th. I am bound to say I cannot
23 remember whether you gave Rule 37 notification in
24 respect of it.
25 LORD JUSTICE SCOTT BAKER: I am very happy to do it now.

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1 MR BURNETT: It is plainly uncontroversial. I think Rule 37
2 notification was given by email, but it needs to be
3 stated publicly.
4 LORD JUSTICE SCOTT BAKER: It will be stated publicly now.
5 I am not sure if I also covered, I think I did, cover
6 the statement relating to the Fulham Leisure Holdings.
7 MR BURNETT: We will come to that at some stage later, sir.
8 LORD JUSTICE SCOTT BAKER: Thank you. But I mentioned about
9 rule 37.
10 MR BURNETT: I am aware there have been some email responses
11 suggesting that there is no controversy about
12 the statement I am about to read.
13 Statement of MR MARTIN SMITH (read)
14 MR BURNETT: This is a statement of Martin Smith. As
15 I indicated, sir, it is dated 14th March 2008 and he
16 says this:
17 "I, Martin Smith, solicitor to the inquests, make
18 the following statement:
19 "On 28th January 2008, when giving her evidence,
20 Lady Sarah McCorquodale agreed to go to Althorp House to
21 conduct a search there for documentation referred to in
22 questioning by Mr Mansfield.
23 "After she gave her evidence, I spoke to Lady Sarah
24 about arrangements for her to conduct the search in
25 question.

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1 "On 31st January 2008, I received an electronic
2 message from Lady Sarah on the inquest's secure
3 electronic document management system, Lextranet. In
4 this message, Lady Sarah stated as follows:
5 "'Afternoon, Martin. I have just returned from
6 Althorp. I have searched 50 boxes of correspondence and
7 have found no letters or any form of correspondence from
8 the Duke of Edinburgh apart from a condolence letter
9 following the death of my father in 1992. I have an
10 inventory of the correspondence held at Althorp which
11 I will bring to court on Monday. Please could you
12 acknowledge receipt of this email.
13 "'Best wishes, Sarah.'
14 "On 4th February 2008, Lady Sarah handed me
15 a document entitled 'Papers From Althorp'. This
16 comprised the inventory of the Princess of Wales'
17 correspondence held at Althorp to which Lady Sarah had
18 referred in her electronic message.
19 "I subsequently showed this document to the Coroner
20 who was satisfied that it contained no reference to
21 correspondence from the Duke of Edinburgh.
22 "On receipt of this inventory, I spoke to Lady Sarah
23 about one document listed on it. This document was
24 entitled 'Dossier: Mohamed Al Fayed. One boxed set of
25 literature'.

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1 "Lady Sarah told me that this comprised material in
2 the public domain about Mr Al Fayed which was not
3 complimentary to him. It had been sent to her late
4 sister by Mr Tiny Rowland following their acrimonious
5 and public disputes.
6 "On 22nd February 2008, I sent an electronic message
7 on the Lextranet system to Lady Sarah. In my message
8 I referred to correspondence from Lewis Silkin dated
9 19th February 2008 containing a request for the Coroner
10 to obtain a personal diary and notes said to have been
11 kept by the Princess of Wales.
12 "I referred Lady Sarah to the evidence of Simone
13 Simmons and Paul Burrell which was relied upon by
14 Lewis Silkin in their request. I also asked her to
15 confirm whether her late sister kept a personal diary of
16 the sort described in evidence by Miss Simmons and
17 whether the estate possessed any notes of the sort
18 described by Mr Burrell in his evidence which bore any
19 relevance to the issues being canvassed in these
20 inquests.
21 "On the same date, I received a reply from
22 Lady Sarah as follows:
23 "'Afternoon, Martin. Thank you for your email. To
24 my knowledge, my sister never [the word "never" is in
25 capitals, sir] kept a diary of the sort described by

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1 Ms Simmons. The only diary was the appointments diary
2 which you now have. I further confirm that the estate
3 has no additional notes of the sort described by
4 Paul Burrell in his evidence which bears any relevance
5 to the issues being qualified in these inquests. Again,
6 nothing of this type was found by me during my extensive
7 search at Althorp on 31st January 2008 and there is
8 nowhere else that these alleged notes could be stored.
9 "'I hope this gives you the information required by
10 Lewis Silkin. Best wishes, Sarah'.
11 "I believed facts stated in this statement are
12 true."
13 Sir, that completes the statement of Mr Smith.
14 Sir, we are due to start again by videolink at half
15 past one and so, now might be the a convenient moment,
16 rather than trying to cram something else in.
17 LORD JUSTICE SCOTT BAKER: Half past one, members of the
18 jury.
19 (12.23 pm)
20 (The short adjournment)
21
22
23
24
25

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