Hearing transcripts

24 January 2008 - Morning session

1 Thursday, 24th January 2008
2 (10.00 am)
3 (Jury present)
4 LORD JUSTICE SCOTT BAKER: Mr Burnett, following the
5 observations that were made yesterday, I have come to
6 the conclusion that Mr Klein and Mr Cole should be
7 recalled unless anybody persuades me to the contrary,
8 and arrangements can be made for that at some convenient
9 time in the foreseeable future.
10 MR BURNETT: Certainly, sir.
11 LORD JUSTICE SCOTT BAKER: I take it nobody wants to argue
12 otherwise. Very well.
13 MR TREVOR REES (continued)
14 Questions from MR CROXFORD
15 MR CROXFORD: Mr Rees, my name is Ian Croxford. I am acting
16 for the Ritz Hotel. I will not keep you very long, but
17 I just want to ask you some more questions about
18 30th and 31st August. I will begin, if I may, by asking
19 you about the end of that, the journey from the Ritz.
20 A. Yes, sir.
21 Q. Mr Keen asked you some questions yesterday and I want to
22 pick up some of the detail and some of the consistency
23 of your recollection; all right?
24 A. Okay, sir.
25 Q. This is right, isn't it, that you have, very

1

1 understandably, at all times been very concerned, when
2 speaking about the events of that night, to be satisfied
3 that what you are describing is recollection and not
4 reconstruction?
5 A. Yes, sir.
6 Q. Obviously your task has been made much, much more
7 difficult by the fact of and the extent of your
8 injuries.
9 A. I would say so, sir, yes.
10 Q. Is this right, that in exercising caution to speak only
11 of what you think you have recalled, when you have
12 spoken about those events, you have been confident that
13 it is recollection?
14 A. They are my best recollections, sir, yes.
15 Q. Now, it's also right, isn't it, that from the very first
16 time that you were questioned -- and as Mr Keen reminded
17 you yesterday, that was when the French magistrate came
18 to your hospital bedside on 19th September of 1997 --
19 you have had some recollections which you have been able
20 to pass on to those who have asked?
21 A. Yes, sir, the recollections in the statement, sir, yes.
22 Q. I will ask you a little more about that bedside
23 interview in a few moments.
24 I wonder, first of all, if Mr Foley could bring up
25 one photograph. Sir, it's in the jury bundle, [page 62],

2

1 and I hope, Mr Rees, it's there -- yes, it is -- on the
2 screen.
3 A. Yes, sir.
4 Q. We can see you in the left-hand side of the picture;
5 yes?
6 A. Yes, sir.
7 Q. I think it's said that this photograph was taken in
8 Rue Cambon, as you were departing from the Ritz.
9 A. I accept that.
10 Q. Just assume that for the moment. It is not going to be
11 the detail of what I want to ask you about.
12 We can see from the photograph, and we know from
13 other material, that this photograph was obviously taken
14 at night.
15 A. Yes, sir.
16 Q. Here you are at night, and we can see your left hand is
17 on the sun visor; do you see that?
18 A. Yes, sir.
19 Q. It is down?
20 A. Yes, sir.
21 Q. Obviously not to deflect the sun, but having the visor
22 down would, of course, have given you access to -- is it
23 called the vanity mirror, on the inside of the visor?
24 A. Yes, sir.
25 Q. It is right, is it not, that it would have been part of

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1 the ordinary everyday stock-in-trade of your job, when
2 travelling in a car with a principal, to use the vanity
3 mirror as and when necessary to see what was going on,
4 so far as you could, behind?
5 A. That sometime happens, sir. Sometimes certain cars have
6 a second mirror fitted, but ...
7 Q. One way or the other, you would like to be able to use
8 a mirror so that you could see behind as well as in
9 front?
10 A. That happens, sir, yes.
11 Q. Would it be right to infer here that since you have got
12 the sun visor down, probably you had the mirror
13 available in order that you could watch behind?
14 A. I don't remember the photo being taken, sir, but that's
15 a possibility, yes.
16 Q. Indeed we can see -- I don't think I need trouble you
17 with it -- but so that you will have and the jury will
18 have, on the facing page, a rather more clear picture,
19 but even on 62, the one that is in front of you, we can
20 see that the Princess of Wales herself seems to be
21 turning her head to look behind.
22 A. Yes, sir.
23 Q. So looking behind, in the ordinary course -- and
24 I appreciate that you don't have recollection of this
25 particular moment -- but in the ordinary course, looking

4

1 behind and looking around would have been something that
2 you would have done when travelling in a car with
3 a principal?
4 A. Yes, sir. You would have all-round observation
5 en route, sir, yes.
6 Q. Of course. I do now want to ask you a little more about
7 that bedside interview. It was 19th September.
8 Sir, I will not ask for it to be brought up on the
9 screen unless someone wants it. Mr Rees, of course, has
10 a copy in front of him.
11 If you want to look at it, Mr Rees, do. It's
12 19th September 1997.
13 A. Yes, I have it here, sir, yes.
14 Q. Is this right, that first of all you have some
15 recollection of having been visited by the magistrate in
16 the hospital whilst you were in bed?
17 A. I remember more clearly the second interview, sir. I do
18 not have any clear memories of this first visit.
19 Q. Very well. Is this right, that whether it's the first
20 or the second visit, you don't, as you sit there today,
21 have any clear recollection -- unless you go and look at
22 the notes of the interviews or statement, you don't have
23 a clear recollection of what you actually said then?
24 A. No, sir, I have to refer to the statement, sir.
25 Q. Quite understandable. You, of course, at that stage,

5

1 were seriously ill, but happily on the mend?
2 A. Yes, sir.
3 Q. But the doctors who were treating you were satisfied
4 that you were fit to be interviewed?
5 A. They were, sir, yes.
6 Q. You were willing to be interviewed?
7 A. Yes, sir.
8 Q. You had members of your family there helping you?
9 A. The first interview especially because I was speaking
10 through a trache tube. It had to be translated to the
11 translator. So the first interview definitely was
12 a translated question and answer.
13 Q. We can see, I think, that there are some questions
14 about: will you ask him so-and-so and such and such?
15 A. Yes.
16 Q. Right. I am going to go to page 4, sir, on your copy.
17 I just want to pick up, if I may, what Mr Keen asked
18 you and then go a little further. We can see that the
19 first question at the top of page 4 -- you were asked
20 a question, the context of which was having left
21 the Ritz, and the question to you was:
22 "And after he has no recollection of anything from
23 that moment until ...", and then, "... about the journey
24 that was followed?"
25 Do you see that?

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1 A. I do, sir, yes.
2 Q. You said, because you have a recollection, "I remember
3 that we were being followed, but nothing else"?
4 A. That's correct, yes, sir.
5 Q. I will ask you a number of questions about that "being
6 followed", Mr Rees.
7 A. Yes.
8 Q. If we go down on the foot of that page, the magistrate
9 asked you, "Does he remember ..." We can see,
10 therefore, putting the questions through the third
11 party. I will put them to you, if I may:
12 "Do you remember where they were followed to and by
13 whom?"
14 Your recollection, as you said yesterday, was:
15 "There were two cars and a motorbike. I do not know
16 anything about the journey."
17 That was your recollection obviously at the time,
18 was it?
19 A. Yes, sir.
20 Q. Indeed it's substantially your recollection today, isn't
21 it, that you do have a recollection of being followed?
22 A. Yes, sir, I do.
23 Q. I will come and develop and just explore that. If you
24 turn over the page, the next question you were asked
25 was:

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1 "Can he provide any details about the cars and the
2 motorbike?
3 "Answer: I think it was a white car, a hatchback,
4 with three doors, but I don't remember anything else."
5 Now I will ask you about the colour presently, but
6 your recollection clearly then was a white car,
7 three-door hatchback?
8 A. Yes, sir.
9 Q. Substantially, whether it's white or very
10 light-coloured, you have that recollection today, do you
11 not?
12 A. Yes, sir, that's my clearest recollection.
13 Q. Yes, it's your clearest recollection. The next question
14 put to you was:
15 "So the cars were following you after departing from
16 the Ritz?
17 "Answer: Yes."
18 A. That's correct, sir, yes.
19 Q. If you just turn over the page, to your page 6, foot of
20 the page, you were asked a question as to whether you
21 remember who was closest, that is of the following
22 vehicles; "Who was closest when he saw the cars and the
23 motorbike?", and your answer was "I don't remember", but
24 then you added "It kept changing".
25 A. I see that, sir, yes.

8

1 Q. Mr Rees, from that answer, "It kept changing", obviously
2 you were doing your best at the time to give your
3 recollection?
4 A. Yes, sir.
5 Q. Clearly your recollection of "It kept changing" must
6 have meant that you had a recollection of it being a car
7 or a motorbike that was closest behind you at different
8 stages?
9 A. I would agree with that, yes, sir.
10 Q. I am grateful. Indeed, the point was confirmed because
11 the next question that was asked of you was:
12 "It kept changing during the journey?
13 "Answer: Yes."
14 Do you see that?
15 A. Yes, sir.
16 Q. Please understand, I am not going to criticise you at
17 all, I am not criticising you at all, but it's clear
18 from these answers, is it not, that you don't have, as
19 you say, a detailed recollection of the journey, but
20 this aspect of something that happened after you left
21 the Ritz you do have a recollection of?
22 A. It would seem at that time that I had that recollection,
23 sir, yes.
24 Q. You don't have it now?
25 A. I have no clear recollections of -- I have a general

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1 memory of the incidences that occurred during that time,
2 but for clear recollections I have to refer to my
3 statement, sir.
4 Q. I quite understand. It's difficult for anyone after
5 ten years, let alone in your circumstances.
6 A. Yes, sir.
7 Q. Let me press you a bit more then. On page 7, do you see
8 in the middle of the page that you were asked whether
9 you would be able to recognise the white car, and you
10 say that you don't think so. I will ask you some more
11 particular questions about that in a few minutes.
12 A. Okay, sir.
13 Q. But the next one:
14 "Was this car behind them when they left the Ritz?
15 "Answer: It crossed the road and then it followed
16 us."
17 A. Yes, sir.
18 Q. Can you help me, Mr Rees, now, about "crossed the road"?
19 I assume from the context that the road would have been
20 the road at the back of the Ritz, Rue Cambon.
21 A. Rue Cambon, yes, sir.
22 Q. When you say "It crossed the road", can you help by what
23 you meant by that at the time?
24 A. I believe the vehicle was parked on the far side of the
25 road on the far pavement, and as our vehicle drew off,

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1 it drew onto the road to follow us.
2 Q. Again let me try and understand. When you say "the far
3 pavement" -- let us take it in stages.
4 A. Far from where we exited the vehicle, the far side of
5 the road, from the point we exited the hotel.
6 Q. So it was on the other side of the road?
7 A. Correct, sir, yes.
8 Q. Just in your mind's eye for the moment, so the jury can
9 follow, once the four of you got in the car and the car
10 was facing down Rue Cambon in order to drive away --
11 A. Yes, sir.
12 Q. -- this car that was parked up on the other side of the
13 road, was it somewhere ahead of the Mercedes?
14 A. No, it was behind the Mercedes, sir.
15 Q. Right. So when you say that it followed you, you must
16 have either turned or seen in a mirror, as you went off,
17 the car pulling on to the road and pulling up behind
18 you?
19 A. I would agree with that, sir, yes.
20 Q. Right. Indeed, just to touch on your memory at that
21 time, you were then asked about other vehicles that you
22 had seen at other times in the day, weren't you?
23 A. Yes, sir, I believe so.
24 Q. We can see -- and the jury have heard about -- that you
25 referred to a four-wheel-drive jeep, which presumably

11

1 means a jeep-type vehicle rather than a particular
2 brand --
3 A. Yes, sir.
4 Q. -- and two motorbikes and a small three-door hatchback
5 that you think was dark-coloured.
6 A. That's what it says here, sir, yes.
7 Q. The jury have heard about a dark Peugeot 206 down at the
8 airport at Le Bourget when you landed.
9 In addition -- and I will pick this up again in
10 a little more detail in a moment or two -- if you turn
11 on to page 9, you were asked about an incident with
12 journalists; do you see that?
13 A. I do, yes, sir.
14 Q. The second question.
15 A. Yes.
16 Q. You gave an answer -- and I will ask you, as I say, some
17 more -- but the jury have heard, and you did then recall
18 and do now recall, that there had been a bit of
19 an altercation at Rue Arsene Houssaye when you first
20 deposited the couple there late in the afternoon; is
21 that right?
22 A. That's correct, yes, sir.
23 Q. I will come back to that, Mr Rees.
24 Then, a couple of weeks or so later, you were
25 interviewed by the French police and you made the

12

1 statement which Mr Burnett asked you about on
2 2nd October.
3 A. Yes, sir.
4 Q. I just want to ask you a couple of questions about that,
5 if I may. By all means, you open it. I would like you
6 to go, please, to the fourth page. There is pagination
7 in the top left-hand corner, as you know, Mr Rees.
8 A. I have it.
9 Q. Once again, at this stage, you were confident, were you
10 not, that you were speaking from recall and trying to
11 tell the police what you remembered?
12 A. I believe I have always done that, sir, yes.
13 Q. Here in the middle of the page, there is a paragraph
14 beginning, "When we went out ..." Could you find that?
15 A. Yes, sir, I can see it.
16 Q. You told them:
17 "When we went out via the back exit, the car had not
18 yet arrived."
19 Then you describe the principals waiting.
20 "I myself was in the street where there were two or
21 three journalists with a small white or very
22 light-coloured hatchback and possibly a scooter."
23 Then:
24 "There were not many journalists about."
25 A. Yes, sir.

13

1 Q. So you had noticed this hatchback car evidently when you
2 were waiting for the Mercedes to arrive?
3 A. That's what it says there, yes, sir.
4 Q. Whereas earlier you described it as white, you now say
5 white or very light-coloured. Again, presumably, you
6 were being cautious here because, whilst there was good
7 street lighting, it's possible that it wasn't white but
8 some colour that was near to white. Is that what you
9 were trying to say?
10 A. I would say that I couldn't definitely say that it was
11 a white-coloured car, but white or light-coloured is
12 what I would say.
13 Q. You actually said "very light-coloured"?
14 A. Yes, sir.
15 Q. And that would have been accurate?
16 A. I believe so, sir.
17 Q. On this occasion, if you turn to page 6, you were shown
18 some photographs, it appears, of a particular type of
19 car, a white Fiat Uno.
20 A. I vaguely remember that, sir.
21 Q. The position is this, isn't it, that you told the police
22 then that you had no recollection of such a car, and
23 I think you subsequently clarified things -- and I will
24 show you presently, if necessary -- but you have no
25 recollection one way or the other what make or type of

14

1 car this hatchback was; is that right?
2 A. Not exact make and model, sir, no.
3 Q. All you can say, is this right, is that it was
4 three-door, by which presumably you meant driver's door,
5 passenger door and hatchback at the back?
6 A. Yes, sir.
7 Q. And the colour I have just asked you about?
8 A. Yes, sir.
9 Q. I wonder if I could ask Mr Foley to bring up
10 INQ0019840]. It's a record of what was in the
11 Daily Mirror on 2nd March 1998. It's the first
12 teaser/trailer, it would appear, for the series of
13 articles that came.
14 I would like to ask you to focus in on the last
15 third of the page, where there is a quote:
16 "To start with I couldn't remember ..."
17 Do you see that?
18 A. I do, yes, sir.
19 Q. Just above it I ought to perhaps take:
20 "I am starting to remember more and more."
21 Do you see that?
22 A. I do, yes, sir.
23 Q. Then you went on:
24 "To start with I couldn't remember a thing and the
25 doctors weren't sure if I would ever remember. I had

15

1 amnesia. Everything was just a blank."
2 Presumably you did say that to Piers Morgan?
3 A. It would appear so, sir, yes --
4 Q. You don't dispute that you said it?
5 A. No reason to dispute that, sir, no.
6 Q. Of course, at this stage, you were receiving help from
7 a doctor or doctors to see about your amnesia, as far as
8 they could help you?
9 A. I was, sir, yes.
10 Q. If I read on, there is a statement not attributed to you
11 about seeing Henri Paul and him not appearing obviously
12 drunk. Then this:
13 "The bodyguard's memory breakthrough came last
14 Wednesday after he met his psychiatrist."
15 I want to understand that. It's not a statement
16 attributed to you, but it's right, isn't it, that
17 sometime towards the end of February or very early March
18 there had been what the journalist called
19 a "breakthrough" in that you had remembered two further
20 things?
21 A. Yes, which I have previously mentioned, sir, yes.
22 Q. I will ask you about one of those in a moment, but it
23 was only those two further things, was it?
24 A. Yes, sir.
25 Q. Forgive me just asking you this --

16

1 A. Sorry, can I just --
2 Q. Of course.
3 A. There were other things at the time, I believe, but
4 those were the only two things which were clear enough
5 to mention to the psychiatrist.
6 Q. I am grateful for that because I think you are
7 addressing the very thing that I was going to ask you.
8 For the moment, there were other things, but they were
9 not so clear; is that it?
10 A. That's what I remember at the time, sir. There were
11 other things coming that I either dreamt about or
12 thought I remembered, but the two memories or flashbacks
13 that I have mentioned were the only two that I was
14 prepared to mention to the psychiatrist.
15 Q. Because these were the two that you were satisfied were
16 reliable as recollection?
17 A. At that time, yes, sir.
18 Q. And the other things that you were remembering at that
19 stage you were uncertain about; is that right?
20 A. That's correct, yes, sir.
21 Q. But you did have the impression that you were beginning
22 to get some recall; is that right?
23 A. I wasn't sure if it was recall or dreams, sir. As
24 I said, the only two that I was happy to put my name to
25 were the two that I mentioned to the psychiatrist.

17

1 Q. Okay. I wonder next -- I would like to take you onto
2 the long article that was published on 2nd March.
3 Mr Foley, it's [INQ0019844].
4 Do you have a hard copy there, Mr Rees?
5 A. I will read it off the screen, sir.
6 Q. Whichever is easier for you, sir. This is the third
7 page on this form of print-out; do you see that?
8 A. Yes, sir, I do.
9 Q. At the top of the page, just so that we can place this,
10 there is a quote there about "nothing untoward about
11 Henri Paul's behaviour", attributed to you, and you have
12 already given evidence about that.
13 If we focus in on the middle part, just above the
14 middle of the page, "The now infamous video of
15 Diana ..." Do you see that, Mr Rees?
16 A. Yes, sir.
17 Q. I would just like that and the next eight or ten lines.
18 Then after that introduction of the "infamous video":
19 "Trevor says 'I can recall that we were being
20 followed as we headed for the apartment'."
21 So it's clear, is it not, Mr Rees, that here we are,
22 six months on, and what you had previously described to
23 the magistrate and the police you were confident enough
24 to go public with?
25 A. Yes.

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1 Q. You were being followed?
2 A. Yes, sir.
3 Q. You were confident, also, that there were two cars and
4 a motorbike. One seemed to be a white car -- I am not
5 going to hold you to colour -- a white car with a boot
6 which opened at the back and had two doors?
7 A. Yes, sir.
8 Q. Again you were confident enough of this now, as
9 recollection, to go public with it?
10 A. That was my best recollection, yes, sir.
11 Q. The next line is:
12 "The police have shown me pictures of Fiat Unos, but
13 I can't help much with that kind of detail."
14 A. That's correct, sir.
15 Q. A few days later you were attended in Paris, I think,
16 before the investigating magistrate again and were
17 interviewed on 6th March 1998.
18 A. Yes, I was, sir, yes.
19 Q. It was on this occasion, wasn't it, that you described
20 the two new memories which have been mentioned in the
21 newspaper reports, of which you were sufficiently
22 confident to describe them as memory?
23 A. I described them to the judge as memory. However I did
24 state that I wasn't 100 per cent certain at that time.
25 Q. I would like to ask you about one of those. Go to the

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1 second page of that note of interview, please.
2 Sir, if you have it, it's 6th March, page 2.
3 We can bring it up on the screen --
4 A. I have it now, sir.
5 Q. Second page, just over halfway down:
6 "Question: Could you incorporate the new memories
7 and go over the sequence of events from the departure
8 from the Ritz via the Rue Cambon?"
9 Do you see that?
10 A. I do, yes, sir.
11 Q. You begin your answer by referring back to what you said
12 already:
13 "As I have already said, I remember getting in the
14 Mercedes in Rue Cambon. As the Mercedes set off, we
15 were followed by vehicles that were waiting for us to
16 leave. I remember there was a small light-coloured
17 estate vehicle and one or two motorcycles."
18 Then this:
19 "The new memory that I have is of the traffic
20 lights, which can only be the ones at Place de la
21 Concorde in relation to the route that we took."
22 Pause there for a moment. Can I just break that
23 down? You were saying, were you, that you had a memory
24 of being stopped at traffic lights?
25 A. I did, sir, yes.

20

1 Q. But you were also explaining, were you, that you don't
2 remember that that was Place de la Concorde, but you had
3 worked out from the route that you understood that you
4 had taken that it must have been?
5 A. That's correct, sir.
6 Q. I understand. You carried on:
7 "I remember that we stopped there. At that point
8 I turned round to look out of the window behind us.
9 I then saw that a motorcycle had arrived on the
10 right-hand side of the car and had stopped ... not sure
11 about the other vehicles. I can remember this
12 motorcycle very clearly."
13 Can you remember it now, sir?
14 A. Only by reading the statement, sir.
15 Q. Right, but at that stage, ten years ago, no doubt this
16 was as firm a recollection as you thought you could then
17 come to; is that fair?
18 A. At that time, yes, sir.
19 Q. You went on to say:
20 "When our vehicle moved off, there were lots of
21 flashes ..."
22 You then said:
23 "... from photographers, I presume."
24 A. Correct, sir.
25 Q. When you say "lots of flashes", can you remember now,

21

1 are we talking about one or two or was it really quite
2 a barrage?
3 A. I can't comment on the number of flashes that I remember
4 in that memory, sir.
5 Q. You then went on to describe the other memory that had
6 come back to you and I need not ask you about that.
7 Just two other things on this area: as you told the
8 Metropolitan Police in 2004, I think it was, it's still
9 your position today, is it, that you recall
10 a light-coloured vehicle following you when you left
11 the Ritz?
12 A. Yes, sir, I do.
13 Q. I just want to ask you about one other thing on this
14 area. I don't know, did you see last weekend's
15 Sunday Telegraph?
16 A. I didn't, no, sir.
17 Q. Has it been drawn to your attention?
18 A. Somebody has mentioned it, but I have not seen the
19 article, sir.
20 Q. I just want to ask you a question and clarify the
21 position. In The Telegraph, you saw, did you, that
22 a reporter, at least, was describing an expectation of
23 telling the inquest that memories are gradually
24 returning, present tense? Do you remember reading that?
25 A. I have not read the article, sir.

22

1 Q. Just let me read it to you. Sir, if needs be, Mr Foley
2 has a copy and it can be brought up, but I don't ask for
3 it unless the witness is in difficulties or you think it
4 is sensible.
5 The reporter said:
6 "But Mr Rees, formerly Trevor Rees-Jones, is now
7 expected to tell the inquest that memories are gradually
8 returning, including one of the Princess calling
9 out ..." and so on.
10 That's the present tense. Was that accurate as of
11 today?
12 A. No, that's not accurate, sir, no.
13 Q. The only other point on this is that the reporter then
14 went on to say, missing out one sentence, sir:
15 "Friends say he is expected to recount that he
16 remembers the group leaving the Ritz and being pursued
17 by two cars and a motorcycle into the Alma Tunnel."
18 Now you have described already being pursued by two
19 cars and a motorcycle, but the different thing there is
20 friends saying about being pursued into the Alma Tunnel.
21 Was that accurate?
22 A. No, it's not accurate. I don't speak to my friends
23 about this in detail, sir, so that's not accurate at
24 all.
25 Q. Very well. I just wanted to clarify, Mr Rees. That's

23

1 all.
2 A. Yes, sir.
3 Q. I would like to ask you about, much more briefly, other
4 parts of the day. You have some recollection of the
5 earlier parts of Saturday 30th August; is that right?
6 A. That's correct, I do.
7 Q. Not only through lapse of time, but also because, no
8 doubt, the minutiae of what happened during that day
9 wasn't at the time seen by you as being particularly
10 significant, much of it no doubt didn't stick in your
11 memory?
12 A. As I said, I have general memories of the day, but not
13 specific memories of telephone calls or who I spoke to.
14 Q. Coming out of the airport at Le Bourget you were
15 followed by some paparazzi, weren't you?
16 A. Yes, we were, yes, sir.
17 Q. In particular I think you have mentioned already a small
18 dark hatchback. I will suggest it was a Peugeot 205,
19 but that may not matter. Do you remember being followed
20 by that hatchback?
21 A. Reading the statements, I believe that's what
22 I remembered at the time, yes, sir.
23 Q. I have what Mr Wingfield said in a statement about this,
24 that "the paparazzi vehicles embarked on a series of
25 dangerous manoeuvres in order to get photographs". Do

24

1 you remember that?
2 A. I don't remember the dangerous manoeuvres, no, sir.
3 Q. He has one recollection of the 205 overtaking and then
4 suddenly slowing down to try and slow the Mercedes,
5 seemingly so as to let the photographers on the
6 motorbikes get photographs. Do you recall that?
7 A. I have no memory of that, sir.
8 Q. You went on to Villa Windsor. I don't think I need to
9 ask you any questions about that. On that journey from
10 the airport and off to Villa Windsor, you were in the
11 lead front car and Mr Wingfield was in the Range Rover
12 behind; correct?
13 A. That is correct.
14 Q. And you separated, as the jury have heard, at some
15 stage.
16 A. Yes, sir, we did.
17 Q. During that journey, you and Mr Wingfield, you had
18 two-way walkie-talkie radios, did you not?
19 A. Yes, we had GSM telephones and radios to talk to each
20 other, yes.
21 Q. Presumably, again as a matter of routine, you were
22 talking to one another from time to time during the
23 course of the journey?
24 A. Yes, we would have been, sir.
25 Q. That would have been a matter of routine, wouldn't it?

25

1 A. A matter of standard procedure, yes, sir.
2 Q. I am not fortunate enough to travel in these
3 circumstances, but I assume there is no embarrassment
4 about you talking to your colleague in front of your
5 principals; it's what they expect you to be doing when
6 doing your job?
7 A. That's correct.
8 Q. Coming back to this altercation at Rue Arsene Houssaye,
9 when you arrived there, late on in the afternoon or
10 early evening, there were a lot of photographers and
11 a pretty unseemly -- I am going to say "scrum", I think
12 to a rugby player, but it's not a bad way of describing
13 it -- a pretty unseemly scrum as the pack of
14 photographers tried to press up and get their snaps of
15 the Princess and Dodi Al Fayed?
16 A. I am not sure if -- there were some of the photographers
17 that followed us. I am not sure if there were actually
18 some waiting for us there. There was a handful of
19 photographers there -- not a huge group, but there was
20 a fair number of photographers there.
21 Q. They tried to get up very close?
22 A. I seem to remember that they tried to get up close and
23 that the security guard obviously pushed one of them
24 back.
25 Q. It was a very big French man on the door, as it were; is

26

1 that right?
2 A. Yes, that's correct.
3 Q. Having got your principals in, you and Mr Wingfield came
4 down and tried to reason with the photographers; is that
5 right?
6 A. We came down and spoke to them, yes, sir.
7 Q. What you were saying to them was this, in substance,
8 wasn't it, that "Look, chaps, if you are reasonable, you
9 will get your photographs. When the principals come
10 out, you will get some photographs. Just don't press up
11 too close; don't make a nuisance"?
12 A. I think we had said to them -- I believe we might have
13 spoken to them previously on the same matter, that not
14 to take photographs while we were travelling; that they
15 would get sufficient time to take photographs as the
16 couple were moving in and out of different venues, sir.
17 Q. You were asking them also to give the couple some space,
18 hold back and use the facilities of their long lenses?
19 A. I can't remember specifically if it was to hold back,
20 but when the couple were exiting the vehicle, that there
21 was sufficient time there to take photographs without
22 causing problems while we were travelling.
23 Q. Do you recall that when the couple came out, intending
24 to go to the restaurant that evening, the press
25 photographers in fact just pressed forward again and

27

1 there was a bit of a scrum once more getting your
2 principals into the car and away?
3 A. I don't remember it being that difficult exiting the
4 apartment at that time. However, yes, there were
5 photographers there trying to take photos quite close.
6 Q. And they were getting closer than you had invited them
7 to?
8 A. As I said, I didn't find it a difficulty at that stage.
9 My main concern was whilst travelling between venues,
10 sir.
11 Q. Now you then drove off initially towards the restaurant
12 and ended up, as we all know, at the Ritz.
13 A. Yes, sir.
14 Q. During the course of that journey, presumably you and
15 Kes Wingfield again made use of your walkie-talkies or
16 mobile phones?
17 A. I believe we would have been in touch with
18 Philippe Dourneau, who was driving the couple, sir.
19 Q. Yesterday you were asked some questions about a piece of
20 film whilst you were standing in the vestibule at the
21 back of the Ritz waiting for the car to arrive and being
22 handed a house telephone -- do you remember that?
23 A. Yes, I do, sir.
24 Q. -- so that, as you explained, you could talk to
25 Mr Wingfield who was at the front of the Ritz?

28

1 A. That's correct, sir.
2 Q. As the jury now know, quite a long way away from over on
3 the Place Vendome side.
4 A. Yes, sir.
5 Q. That again would have been an ordinary part of your job,
6 wouldn't it, keeping in touch with your colleague, your
7 mate, on the task of looking after the principals?
8 A. That would be -- that's correct, yes, sir.
9 Q. Would this also be right, Mr Rees, that whilst you now
10 don't have a recollection of it from what you have
11 already told us, it would have been an ordinary part of
12 your work for you and Mr Wingfield to have been on the
13 walkie-talkies or the mobile telephones when you made
14 the journey off towards the Alma Tunnel?
15 A. I would have informed him when we left, sir, yes.
16 Q. Presumably, when you had stopped at those traffic
17 lights, if there were a lot of cars or motorbikes around
18 and so forth, that's the sort of information you would
19 have passed back to your colleague, is it not?
20 A. I would have informed him of any major delays on the
21 route, but if it wasn't causing a major delay on the
22 journey, I wouldn't have informed him, sir.
23 MR CROXFORD: Mr Rees, I am very grateful.
24 A. Thank you.
25 LORD JUSTICE SCOTT BAKER: Mr Horwell?

29

1 Questions from MR HORWELL
2 MR HORWELL: My name is Richard Horwell, Mr Rees. I appear
3 on behalf of the Commissioner of the Metropolitan
4 Police.
5 A. Good morning.
6 Q. Yesterday, certain allegations were withdrawn that had
7 been made against you and they can be summarised as
8 follows: that you were lying when you said you had no
9 recollection as to what took place; that the security
10 services had turned you against Mr Al Fayed; that the
11 security services wrote your book; and that in one way
12 or another you were in the pay of the security services.
13 Had you always regarded those allegations against you as
14 pure fantasy?
15 A. I never -- they weren't true. I had no reason to --
16 I didn't really pay attention to them, to be honest,
17 sir.
18 Q. But they were pure fantasy, weren't they?
19 A. They are completely untrue, sir.
20 Q. They are not based on any fact or evidence at all, are
21 they?
22 A. None at all, sir, no.
23 Q. Well, one day, Mr Rees, an apology may follow.
24 The photograph that you have been looking at very
25 recently, the photograph that was taken of the car as it

30

1 left the back exit of the Ritz, you have been asked
2 about what you were doing. Mr Rees, you may well simply
3 have been shielding yourself and, more importantly, the
4 Princess from photographers?
5 A. I believe it was a combination of trying to prevent the
6 flash of the photographers' cameras and, also, as the
7 other counsel mentioned, using the mirror.
8 Q. Of course we can see the Princess turning away from the
9 photographer or photographers that were in front of the
10 car.
11 A. Yes, she is looking backwards in the vehicle, sir, yes.
12 Q. Away from the photographer?
13 A. Away from where the photograph was taken, sir, yes.
14 Q. Now, you have said, Mr Rees, in various ways, that it
15 may well be that the deposition or interview by
16 Judge Stephan on 19th September of 1997 represents the
17 most accurate account of these events because it was the
18 first recorded statement that you made and that it was
19 made at a time when you had had very little opportunity
20 to be influenced by others?
21 A. I had had no opportunity at that stage to be --
22 Q. You had no opportunity?
23 A. None at all, sir, no.
24 Q. By others, I mean either acquaintances or the media.
25 There are two aspects of that account that you gave on

31

1 19th September that I want to ask you about. The first
2 is in relation to the journalists who followed you away
3 from the Ritz. You have that interview with you, don't
4 you?
5 A. I have it here, sir, yes.
6 Q. Could you turn, please, to page 7? You were asked
7 whether you could record(sic) if photographs were taken.
8 You said "I don't know".
9 "Would he be able to recognise the white car ...",
10 that you had described that had been parked in
11 Rue Cambon. You said:
12 "I don't think so. It crossed the road and then it
13 followed us."
14 What you could recollect there, Mr Rees, was that
15 this white vehicle had been parked in Rue Cambon, and
16 your inference was that the people or the person inside
17 it was waiting for this departure?
18 A. That's what I believe, sir, yes.
19 Q. And it was associated with at least one, be it
20 a motorbike or a scooter?
21 A. Yes, sir.
22 Q. And you thought they were journalists or paparazzi?
23 A. That's what I believe, sir, yes.
24 Q. That white vehicle followed you down Rue Cambon and away
25 from the Ritz?

32

1 A. I remember it following the vehicle as we drew off,
2 sir --
3 Q. And that's as far as your memory --
4 A. That's as far as my memory takes me, sir, yes.
5 Q. The second point from this very short interview is the
6 topic of Dodi and his changing the plan as to how you
7 would leave the Ritz. If you turn to page 4 -- I am
8 taking the page numbers from the top right-hand corner,
9 obviously -- you were telling Judge Stephan about events
10 at the Ritz. There you say:
11 "They had their meal. We ate ours. Dodi changed
12 the plan. The Princess, Dodi, Henri Paul and I left via
13 the rear. There were still some photographers at the
14 rear."
15 If you turn over, please, to page 5, to the bottom
16 of the page:
17 "Does he remember how Mr Paul was summoned and by
18 whom?
19 "Answer: Dodi called him so that he could drive us
20 from the back of the hotel.
21 "Question: Can he say why?
22 "Answer: No, it was Dodi who changed the plan. It
23 wasn't me."
24 Was it then, Mr Rees, your emphatic memory that
25 whatever had happened at the Ritz, it was Dodi who had

33

1 changed the plan of departure?
2 A. As I said, sir, I don't actually remember the interview
3 taking place. However, that was my best recollection at
4 that time, sir.
5 Q. You have now seen the closed circuit television film
6 from the Ritz.
7 A. Yes, sir.
8 Q. Do you remain adamant, Mr Rees, that the change of plan
9 was Dodi's idea?
10 A. Looking at the CCTV footage, sir, I accept that it was
11 communicated via Mr Paul, however I stand by the fact
12 that it came from Mr Paul via Dodi, sir.
13 Q. If we can just look for a moment at other evidence that
14 we have heard on this topic, Mr Rees, and see how it
15 fits in with the recollection that you have.
16 Thierry Rocher was the night manager at the Ritz; did
17 you know him?
18 A. I would recognise him, sir, yes.
19 Q. When he gave evidence on this topic on 4th December of
20 last year, he had this to say: he was shown CCTV footage
21 of his going to the Imperial Suite and talking to Dodi.
22 We can take the time of this visit from the video. It's
23 20 minutes past 10. He said that:
24 "Dodi asked me why it was such a mess when they
25 arrived downstairs at the hotel in Place Vendome."

34

1 Mr Rocher said that because Dodi had obviously been
2 so concerned about the circumstances in which they
3 arrived at the hotel, that Dodi told him this:
4 "Because of all that, there would be a third car,
5 and I [that's Mr Rocher] had to tell Mr Paul that there
6 would be a third car which would leave from Rue Cambon
7 at the rear of the hotel, but this information had to
8 remain confidential between Mr Paul, Mr Al Fayed and I",
9 meaning Mr Rocher, of course.
10 He was then asked this:
11 "So you were told that there would be a third car
12 leaving from the Rue Cambon and that only Mr Paul should
13 know about that?"
14 And he said:
15 "That is true."
16 He went on to say that he passed that information on
17 to Henri Paul, and he was shown some CCTV footage of his
18 speaking to Mr Paul after this visit. So that is
19 an idea and a change of plan that was expressed by Dodi
20 to Mr Rocher at 20 minutes past 10 that night, long
21 before the departure.
22 First this: do you think that it was a good idea of
23 Dodi's to keep the change of plan a secret from the two
24 bodyguards?
25 A. No, sir, I don't.

35

1 Q. I am sure the reasons for that are obvious, but can you
2 spell them out for us, please?
3 A. We were charged with the personal security of Dodi and
4 the Princess. We should have been kept fully informed
5 of any changes in the itinerary or any changes in his
6 intentions to leave the hotel, sir.
7 Q. You came to know of that change of plan through
8 Henri Paul?
9 A. That's what it would appear, sir, yes.
10 Q. He obviously had to tell you at some stage, Mr Rees.
11 Are you now as certain as you can be that you did have
12 words with Dodi about that change of plan?
13 A. Yes, sir, I am.
14 Q. Whether it took 20 seconds, 28 seconds or whatever, you
15 did raise your concerns with Dodi as to what was being
16 suggested?
17 A. Yes, sir. I believe I raised my concerns of the fact
18 that he wished to leave with no security at all, that we
19 had pushed the crowd of onlookers and photographers
20 across -- away from the front of the Ritz, and that two
21 vehicles were there and he should leave in the two
22 vehicles from the front.
23 Q. But Dodi couldn't be turned?
24 A. I believe that if I had have kept pushing that point,
25 sir, then he might revert to his original decision to

36

1 leave with no security and that was obviously not the
2 position that I would go with. So I reached the
3 workable compromise of myself leaving with the couple
4 and Kes remaining at the front of the hotel.
5 Q. I just want to read a short extract from your book in
6 relation to this episode. Do you have a copy still?
7 A. I don't, no, sir.
8 Q. I am sure one can be provided, Mr Rees. Page 83,
9 please. We have a marked copy, but it doesn't matter,
10 Mr Rees. It's only underlining. (Handed)
11 A. Thank you.
12 Q. I am told it has been given to you at the bottom of 82.
13 Let me just read from the very bottom of page 82.
14 "As Trevor and Kes waited outside the suite,
15 Henri Paul came by several times, up and down the
16 stairs, and seemed very busy chatting with hotel staff.
17 Photographers report that he was agitated and sociable
18 to an unusual degree as he moved around the entrances.
19 He'd seemed a bit of a showman the few times Trevor had
20 seen him; it was nothing new.
21 "Twenty minutes before midnight, Henri Paul turned
22 up at the door of the suite, still stinking of cigars,
23 Kes noted, and told them 'The plan's been changed.
24 We'll be leaving from the back of the hotel, with just
25 one car. He wants me to drive. The two other cars will

37

1 leave from the front to divert the paparazzi. Dodi
2 doesn't want a bodyguard'. They'd be leaving in half
3 an hour.
4 "This was a terrible plan. Henri Paul was
5 a security man, not a chauffeur. They needed a two-car
6 convoy. And a bodyguard! Trevor shot back to
7 Henri Paul, 'No f***ing chance is he leaving without
8 a bodyguard -- no way in a million years it's going to
9 be without me ... I will be coming with you if we go
10 with this'.
11 "The bodyguards announced that they'd have to report
12 this to London, only the second time in the trip they'd
13 felt ops should be told about a bad plan of Dodi's. But
14 Henri Paul confirmed, 'It's been okayed by Mr Mohamed.
15 Kes is sure of this', the phrase 'Mr Mohamed' standing
16 out from the ubiquitous 'the boss' of the lads. He had
17 heard the second-in-command of security at the Ritz say
18 this plan had been okayed by Fayed. But he knew that
19 employees often took Fayed's name in vain, since there
20 was no way to check without causing offence -- or worse.
21 And the plan was still a hopeless one.
22 "'It wasn't Henri Paul driving that bothered me',
23 says Trevor. 'He'd already driven that day -- it would
24 have been like challenging Paul Handley-Greaves about
25 driving the boss'. It was the plan itself that

38

1 disturbed."
2 You go on to say in that book that minutes later,
3 same page, 83:
4 "... Dodi popped his head out of the suite and
5 confirmed it all. They'd have a third car behind the
6 hotel, and the two in front would serve as decoys while
7 the couple escaped out the rear. Paul would be driving,
8 he told them. Trevor was forceful, 'You aren't leaving
9 without security -- I'll be coming'. The photographers
10 and the crowd had been moved back across the road. They
11 weren't close. 'It would be quite safe to leave from
12 the front', Trevor argued to Dodi. But Dodi insisted
13 that the party should leave from the back -- with one
14 car only."
15 There it is set out what is described as stage
16 whispers by you, saying forcefully, "It's not going to
17 happen. There is absolutely no way you are going
18 without any security. This was non-negotiable", and
19 then Dodi finally relented and said that you could come
20 in the car. You suggested there should be a back-up
21 car, but the book says Dodi was resolved.
22 Now that is the account of this important event in
23 your book.
24 A. Yes, sir.
25 Q. Is that a combination of both your recollection and

39

1 Kes's?
2 A. Yes, sir, a combination of the two.
3 MR MANSFIELD: Sir, I am sorry to intervene, if I may, just
4 on this. Yesterday I was very careful not to put this
5 passage because this witness said he had no recollection
6 of what was said by Henri Paul.
7 MR HORWELL: It's the witness's book. I am entitled to ask
8 him about it.
9 MR MANSFIELD: Yes, I am not suggesting that.
10 LORD JUSTICE SCOTT BAKER: I think we had better put it in
11 context.
12 MR HORWELL: Yes. That's why I asked the question that
13 I did: this is a combination of your recollection and
14 that of Kes Wingfield's?
15 A. That's correct, sir, yes.
16 Q. But does it set out as accurately as it can, Mr Rees,
17 your opposition to this plan and your raising that
18 concern and opposition with Dodi?
19 A. Yes, sir. I opposed the plan and I did raise that point
20 to Dodi, sir, yes.
21 Q. But he was adamant?
22 A. Again, I can't remember the specific conversation, sir,
23 but I stand by what's written, sir.
24 Q. You were criticised yesterday for not having done your
25 job properly. Do you accept any one of those

40

1 criticisms?
2 A. No, I don't, sir, no.
3 Q. Who had been responsible for allocating just two
4 bodyguards to Dodi and Diana throughout this period of
5 nine days?
6 A. I believe that would have come from Mr Handley-Greaves,
7 sir.
8 Q. Was two enough?
9 A. I didn't think so, sir, no. Considering the report from
10 Mr John Johnson on his previous trip, I considered we
11 needed more people for our trip.
12 Q. The concern that you had was the paparazzi and attention
13 in general; not just from them, but no doubt from
14 others; is that right?
15 A. At that stage obviously it was in the open, in the
16 media, and the attention, both paparazzi and the general
17 public, would have been a lot higher, sir.
18 Q. How many do you suggest there should have been through
19 this period of nine days?
20 A. I would have expected -- or I thought it would have been
21 good to have a four-man team, sir, the same as would
22 have been with Mr Fayed.
23 Q. Did you complain about the lack of bodyguards during
24 this period?
25 A. Again I don't remember specific telephone calls, sir,

41

1 but I do remember that I spoke to Mr Handley-Greaves at
2 one time during that trip and I believe Kes Wingfield
3 remembers other telephone calls we had.
4 Q. Should those concerns and complaints that were made have
5 been recorded in the log?
6 A. I don't believe the telephone call to Mr Handley-Greaves
7 would be recorded in the log, sir, no.
8 Q. What about a complaint to the operations room itself?
9 A. It depends on the content of the call. If it was just
10 a personal call to the man on duty, then, no, it
11 wouldn't be recorded. If it was an official telephone
12 call, then it should be recorded, sir, yes.
13 Q. Was anything done about the concerns that you and Trevor
14 raised?
15 A. We didn't get any extra security, sir, no. I believe at
16 one stage we got an extra crew member to help the crew
17 of the yacht, but we didn't get any extra security, sir,
18 no.
19 Q. I will just read three -- I think it is -- very short
20 extracts from your book, Mr Rees. The first at page 65,
21 towards the top. This is dealing with the cruise on the
22 Jonikal, top of 65:
23 "As Kes remembers it, Trevor got through to the team
24 leader at the ops room and told him 'We need more
25 blokes. We're knackered already, and now it's going to

42

1 be a longer trip'. Kes could guess by Trevor's
2 expression what he was hearing on the other end of the
3 line.
4 "This was the first of two calls for help from the
5 bodyguards, calls Fayed's team would claim had never
6 been made."
7 Then a few lines further down:
8 "Trevor was making one of his frequent calls to
9 London ops when Kes says he heard him throw in another
10 request, 'Can you give us more blokes here? The
11 paparazzi are getting worse'. With Fayed's huge
12 security staff at St Tropez and a helipad on the boat,
13 help could have been there in an hour. The answer was
14 no. This would be their last request for help."
15 Over the page, page 66, this deals with the episode
16 when Dodi went swimming from the boat without telling
17 you. It's just below halfway down page 66:
18 "The swimming episode combined with Dodi never
19 telling him anything was the last straw for Trevor. He
20 picked up his phone and, for the first and only time on
21 this trip, called Fayed's chief of personal security,
22 Paul Handley-Greaves, direct in London to complain about
23 Dodi's behaviour, hoping it would get back to the
24 boss -- in which case he was sure that Dodi would then
25 get to hear about it."

43

1 You raised concerns, you made complaints, but they
2 weren't listened to?
3 A. As I said, the content of the telephone call is Kes's
4 memory. I do believe that we would have made frequent
5 calls to London operations, and I have to accept Kes's
6 memory of the content of those telephone calls, but it
7 would seem that would be the case. I do remember
8 calling Mr Handley-Greaves during that trip, however the
9 exact content of that call again I wouldn't be able to
10 recollect.
11 Q. All right. It was suggested to you yesterday that you
12 and Kes, having been on duty by this stage, I think,
13 eight days, should have stayed outside the
14 Imperial Suite throughout.
15 A. Yes, sir.
16 Q. Criticisms were made about your going downstairs. Can
17 I just ask you this about the Ritz and security inside
18 the Ritz? Was there any policy as to what should
19 happen, whether bodyguards should stay outside rooms
20 24 hours a day or not?
21 A. When the Fayed family visited the Ritz, sir, it was
22 generally considered a reasonably secure area, and with
23 only two of us on that trip, we had a number of duties
24 to perform during that time at the Ritz. As I said to
25 Mr Mansfield, I thought there was Ritz security

44

1 personnel securing the suite as we were performing those
2 other duties.
3 Q. Dodi, of course, told you and Kes to go downstairs to
4 the bar and get something to eat?
5 A. Yes, sir.
6 Q. He obviously knew you wouldn't be outside the
7 Imperial Suite?
8 A. No, sir.
9 Q. He was content with that?
10 A. I believe so, sir, yes.
11 Q. You were criticised for not having enough control over
12 Dodi. Dodi was in his 40s, the son of Mohamed Al Fayed.
13 Were you able to exercise control over him?
14 A. To a certain extent, sir, in the private security
15 business, everything has to be done on advice and
16 co-operation of the client or principal. It's not --
17 I believe it's not possible in our industry to force
18 people to do what they don't want to do. So if someone
19 blatantly wanted to disregard your advice, then you are
20 very limited into what you could do to push that
21 through.
22 LORD JUSTICE SCOTT BAKER: What was the position about
23 seat-belts with Dodi ordinarily?
24 A. I can't remember if it was all the time, sir. Sometimes
25 he wore them and sometimes he didn't. Generally, as

45

1 I have said, if we were travelling very slowly in the
2 centre of London, I remember at times he didn't wear
3 them. However, if we were leaving London towards the
4 Hammersmith flyover, where the speed picked up,
5 seat-belts would always be worn, sir.
6 LORD JUSTICE SCOTT BAKER: Did you regard that as a matter
7 for you to deal with or a matter for Dodi to deal with?
8 It's a fairly basic requirement, a seat-belt on --
9 A. Yes, sir. I can't remember if that was part of the
10 handover, when I took the job on, the seat-belt issue,
11 sir, but at that time, as I say, that was the state of
12 affairs with Dodi, sir.
13 MR HORWELL: I have some very small points I hope I can deal
14 with quickly. Your deposition dated 2nd October 1997,
15 do you have that with you?
16 A. Yes, sir, I do.
17 Q. Thank you. If you turn to the second page, the page
18 numbers are in the left-hand margin at the top of the
19 page. I want to ask you about this. At the top of the
20 page, the deposition reads as follows:
21 "On leaving the airport, I saw a small dark-coloured
22 press car. I did not see any other cars or motorcycles.
23 As I was in the front of the Mercedes, I did not notice
24 anything in particular. I was in radio contact with
25 Wingfield and at Dodi's request the Mercedes accelerated

46

1 in order to leave the press behind. We told the
2 Range Rover to go straight to the apartment while we
3 went to the Villa Windsor."
4 Do you have a recollection of that now or not?
5 A. No, sir. Only from reading the statement, sir.
6 Q. Right, but that is what you had to say on
7 2nd October 1997 --
8 A. Yes, sir, it is.
9 Q. -- that at Dodi's request the Mercedes accelerated away
10 from the paparazzi?
11 A. That's what's in the statement, sir, yes.
12 Q. Two pages on to page 4, you are asked again about the
13 departure from the Ritz. Halfway down the page, it's
14 only a short extract:
15 "When we went out via the back exit, the car had not
16 yet arrived. Dodi and the Princess waited in the
17 corridor. They appeared very relaxed. I myself was in
18 the street where there were two or three journalists
19 with a small white or very light-coloured hatchback and
20 possibly a scooter. Actually there were not many
21 journalists about."
22 So again, Mr Rees, it was your understanding that
23 those in Rue Cambon were journalists or paparazzi?
24 A. That's what I believe, sir, yes.
25 Q. That's how they acted?

47

1 A. Yes, sir.
2 Q. Now, the book itself. There are a number of references
3 in the book to your being put under pressure. There is
4 a reference to the possibility of your changing your
5 account. I want to summarise those references. It's
6 going to be a very brief summary, Mr Rees, because what
7 is important is what you say to these various points
8 that I am going to give you the headlines of only.
9 A. Okay, sir.
10 Q. At the beginning of the book -- if you wish to follow,
11 please do so -- in the introduction, it's (xiii), you
12 are thanking the people that helped you, your lawyers in
13 particular, and you say this about halfway down:
14 "Without their tenacity and courage, many of the
15 hidden facts would never have come to light and I would
16 have faced unbelievable pressures from the press, from
17 Fayed, and from the international legal side,
18 ill-equipped to protect myself."
19 If you could turn on to page 242, please, there is
20 a reference at page 242 -- and indeed a lot of this part
21 of the book is dealing with the events leading up to and
22 following the interview with Piers Morgan.
23 A. Yes, sir.
24 Q. So we are dealing with The Mirror interview. Halfway
25 down 242, you are dealing with certain memories that

48

1 have come to you. You say this:
2 "'These memories' were something Trevor wished he
3 had kept to himself, and, frankly, wished the boss had
4 kept to himself when he had talked to The Mirror. 'I've
5 always said I was unsure of this woman's voice saying
6 "Dodi". Looking back, it can't be true, and as soon as
7 I said it, I totally regretted it'. Now, the Harrods
8 people were running with it."
9 Over to the next page, 243, the paragraph almost in
10 the middle, just above halfway:
11 "I sat down and thought, to be honest, what harm is
12 it going to do [this is the interview]? I am not sure
13 if these are true memories or not. I won't lie about
14 anything. But what harm would be done? I am not going
15 to say anything that's outrageous to upset the
16 Princess's family -- I am not saying I saw them getting
17 an engagement ring, or saw them jumping into bed
18 together, which I never would anyway. Trevor's instinct
19 said 'I don't want to do this', but I felt well by then,
20 I wanted to help the boss. I hoped it wouldn't hurt
21 anyone'."
22 Then, Mr Rees, this passage was read to you to you
23 yesterday at 262/263. These are the events that are set
24 out in your book concerning the request by Mr Klein that
25 you should sign the letter that would effectively stop

49

1 the English and the French lawyers communicating with
2 each other?
3 A. Yes, sir.
4 Q. That is a letter that Mr Klein wanted you to sign, and
5 you refused.
6 A. That is correct, sir, yes.
7 Q. You thought that that letter was going to improperly and
8 unfairly impede your interests?
9 A. I did, sir, yes.
10 Q. At 267, after that incident with Mr Klein and his letter
11 is raised, about three-quarters of the way down the
12 page, and this is relating to the views of your parents:
13 "As they heard about the fight with Franck Klein
14 over the letter at the Villa Windsor, it confirmed to
15 Jill and Ernie [that's your parents] 'that Fayed wants
16 to own Trev, lock, stock and barrel'."
17 Now those, as I have said, are mere headlines that
18 I have extracted from the book concerning what was
19 happening during this period of weeks after the crash.
20 For part of that time, of course, you were at Park Lane.
21 A. Yes, sir.
22 Q. What was going on? What did you think was happening,
23 Mr Rees, in terms of pressures on you or what was
24 expected of you?
25 A. I personally felt at that stage there was -- I felt the

50

1 pressure that -- to remember what had occurred. The
2 fact that I couldn't was frustrating myself and was
3 obviously frustrating Mr Fayed. He would -- in my
4 meetings with him, he would suggest possibilities, which
5 I would reply "Well, that's a possibility".
6 Q. What possibilities was he suggesting to you?
7 A. The one I specifically remember was a flash in the
8 tunnel which caused the accident. I would say that's
9 a possibility. I did not feel comfortable being in his
10 presence at that time. He was obviously a very upset
11 man. Also in the media, in general, there was a feeling
12 that my not remembering was due to one cause or another
13 and that was being filled by various theories. So
14 I felt under pressure to remember something at that
15 stage, sir.
16 Q. Right. You throughout have done your best to tell
17 nothing but the truth?
18 A. Throughout I believe that's what I have done, sir.
19 Q. Finally, Mr Rees, a very short topic, Karen Mackenzie.
20 A. Yes, sir.
21 Q. "If I remember, they will kill me" is what she suggests
22 you said to her. We will hear that the first public
23 statement that Miss Mackenzie made to that effect was in
24 the summer of 2003 to ABC Television, an American news
25 channel. Those words, "they will kill me" -- this is

51

1 whilst you are still at Park Lane?
2 A. I assume that's when I was back doing light duties, yes,
3 sir.
4 Q. Were you then concerned about anyone wanting to kill
5 you?
6 A. No, I wasn't, sir, no.
7 Q. Does that remark make any sense to you whatsoever?
8 A. No, sir, it doesn't.
9 Q. Can you think of any circumstances in which you would
10 then have said those words?
11 A. I can't remember that conversation and I can't see why
12 I would have made that statement, as she says, sir.
13 Q. What sort of relationship did you have with
14 Miss Mackenzie?
15 A. I had a good relationship. She was a housekeeper of
16 60 Park Lane and when I went on to work directly for
17 Dodi, we had a closer working relationship. So we had
18 a good working relationship, sir.
19 Q. Did you confide in her or not?
20 A. No. It was a working relationship.
21 MR HORWELL: Thank you, Mr Rees.
22 MR BURNETT: Sir, I have no further questions.
23 LORD JUSTICE SCOTT BAKER: Thank you very much, Mr Rees.
24 That's all we require. We are very grateful to you for
25 coming and going over these very difficult matters.

52

1 Thank you.
2 A. Thank you very much, sir.
3 MR BURNETT: Sir, the next witness is Commander Jephson.
4 LORD JUSTICE SCOTT BAKER: Yes, we will have the break and
5 then deal with his evidence.
6 (11.15 am)
7 (A short break)
8 (11.30 am)
9 (Jury present)
10 LORD JUSTICE SCOTT BAKER: I call Patrick Jephson.
11 COMMANDER PATRICK JEPHSON (sworn)
12 LORD JUSTICE SCOTT BAKER: Would you prefer to sit or stand?
13 It's entirely up to you.
14 A. May I sit?
15 Questions from MR HOUGH
16 MR HOUGH: Is your name Patrick Jephson?
17 A. Yes.
18 Q. As I have explained to you, my name is Jonathan Hough
19 and I ask questions first on behalf of the Coroner.
20 First of all I think you were private secretary to
21 the Princess of Wales between 1990 and January 1996.
22 A. That's correct.
23 Q. Since that time, I think you have written two books
24 about your time with the Princess. First of all
25 "Shadows of a Princess", published in 2000, and secondly

53

1 "Portraits of a Princess", published in 2004.
2 A. That's correct.
3 Q. The first one is the one of interest to us because that
4 deals with an account of your time there, whereas the
5 second one is more about travels with her, isn't it?
6 A. Yes.
7 Q. Just for completeness, that first book was, of course,
8 written before Mr Burrell published his note concerning
9 the fears of the Princess of Wales, the note written to
10 him by her, and also before Lord Mishcon's note of his
11 meeting with you and the Princess was made public.
12 A. Yes.
13 Q. You also, I think, gave a statement to the British
14 police in December of 2003, didn't you?
15 A. Yes.
16 Q. Do you have a copy of that statement with you?
17 A. I do, yes.
18 Q. It may help you to have it in front of you so that
19 reference can be made. I think you have also given,
20 over the years, various media interviews, including
21 recently appearing on a BBC documentary entitled
22 "Diana's Last Summer" in August of last year.
23 A. I don't remember that specific one, but it's quite
24 possible, yes.
25 Q. This question is being asked generally of witnesses:

54

1 other than your book royalties, have you ever received
2 any payment for an account relating to the Princess of
3 Wales?
4 A. When I have written on my own behalf, I have been paid
5 as a freelance journalist, yes.
6 Q. Are you expecting any payment in the future for giving
7 accounts of the Princess?
8 A. It's possible, but again I would say that the general
9 rule is that when I have written something, then, as
10 a freelance journalist, I would expect a normal fee for
11 that.
12 Q. Do you have any immediate plans to write anything or
13 produce anything?
14 A. No.
15 Q. Thank you. Dealing with your background, I think
16 between the late 1970s and 1987, you served in the
17 Royal Navy.
18 A. Yes.
19 Q. I think you reached the rank of commander; is that
20 right?
21 A. Lieutenant commander.
22 Q. Then, in late 1987, you were selected to serve as
23 an equerry for the Princess of Wales?
24 A. Yes.
25 Q. Then, in 1990, you were promoted from that position to

55

1 the post of her private secretary?
2 A. Yes, that's fair. I was asked to leave the Navy by the
3 Princess to set up her office.
4 Q. I think you describe it in your book as a promotion
5 anyway.
6 A. It certainly felt like one.
7 Q. Turning to the other end of your post, you resigned in
8 January 1996.
9 A. Yes.
10 Q. I don't propose to go into the detail of your
11 resignation, but is it fair that by late 1995 you felt
12 sidelined and that your relations with the Princess were
13 not as good as they had been?
14 A. I don't think I have used the word "sidelined", but
15 certainly the way I wanted to carry out my job had been
16 made much more difficult.
17 Q. In particular I think you were concerned about the
18 Princess having chosen to give the famous Panorama
19 interview without consulting you.
20 A. That was a factor.
21 Q. But between 1990 and 1995, is it fair to say that you
22 generally enjoyed a very close relationship with the
23 Princess as an employee?
24 A. Yes.
25 Q. Is it also fair to say that, whatever happened in

56

1 relation to your resignation, you remained and remain
2 fond of the Princess?
3 A. Certainly.
4 Q. We have heard already that your post was taken up in
5 August 1996 by Michael Gibbins?
6 A. I don't believe that he replaced me as private
7 secretary. I think his title was controller.
8 Q. But a similar post?
9 A. I don't know.
10 Q. Can we now deal with a couple of points of background in
11 relation to the Princess? This is in relation to her
12 fears and concerns in the early years of your employment
13 with her.
14 In your book you recall that from quite an early
15 stage with the Princess -- your time with the
16 Princess -- she consulted astrologers; is that right?
17 A. Yes.
18 Q. You also recall, again from an early stage, that she put
19 some faith in their predictions?
20 A. Sometimes. I would not say that it was blind faith.
21 Q. Perhaps I can hand to you a copy of some extracts from
22 your book. This has been passed to my learned friends,
23 Mr Horwell and Mr Mansfield. We have additional copies
24 for others if they want them. (Handed) We may not need
25 to go to the particular pages if you recall the events,

57

1 but in late 1989/early 1990, you say that she passed on
2 to you a prediction from a clairvoyant who had been
3 consulted by the Duchess of York to the effect that
4 Prince Charles would be killed in a helicopter accident;
5 do you recall that now?
6 A. I remember the prediction, but I couldn't put a specific
7 date to it.
8 Q. Certainly it appears in the part of your book when you
9 are dealing with 1989/1990. At the same period you say
10 that she acquired -- and I am using your word --
11 a fantasy, from a similar source, that Prince Charles
12 would not ascend to the throne and Prince Andrew would
13 be Regent. Is that something you remember?
14 A. Yes. I think the use of the word "fantasy" has to be
15 seen in context. This was generally a rather sceptical
16 account that I was giving and indeed a humorous one.
17 I think a little later on I give my response to the
18 Princess as being "Yes, ma'am, any tips for the 3.30 at
19 Kempton?" My intention, with all these things, was to
20 maintain a pretty jocular atmosphere between us because
21 I didn't think she really believed it and I certainly
22 didn't.
23 Q. I was just going to come on to that and say that, in
24 fact, in your book, you refer to her describing the
25 source of the prediction as "Fergie's witch woman".

58

1 A. Yes. It was in the nature of an entertainment between
2 us, and I was trying to gauge the degree to which she
3 actually believed what she was being told.
4 Q. Moving on, then, to June 1990 -- and this is page 82 of
5 your book -- you say that in June 1990 she told you that
6 her astrologer had told her that Prince Charles would
7 never be king and that she continued to heed her
8 astrologer's predictions, the more dire the better,
9 particularly where the Prince was concerned, and that
10 "she was rewarded with regular forecasts of helicopter
11 crashes, skiing accidents and other calamities that
12 obstinately refused to befall him", the Prince of Wales.
13 So certainly by June 1990 you were referring to her
14 believing some of the predictions?
15 A. When it suited her was my impression, and I was anxious
16 to try and reinforce her in a sense of scepticism.
17 Q. Moving on to 1993 -- this is page 287 of the book -- you
18 say that her quest for personal growth took her into
19 a range of interests, including astrology and
20 soothsaying, and that "the practitioners of these
21 disciplines fed the paranoia that never lurked far below
22 her surface". By 1993, would you describe that as
23 a fair account of their effect on her?
24 A. It seemed fair to me, and certainly I have -- by that
25 stage I thought it was a harmful effect and certainly

59

1 made my job more difficult.
2 Q. Moving on to a different topic, which is police
3 protection. I think, until late 1993, the Princess of
4 Wales had four personal protection officers, policemen.
5 A. That's right. She had four close protection officers
6 who worked on a rota and back-up security as required.
7 Q. I think in December of 1993 -- and this can be shown by
8 the records if necessary, but I don't think it's
9 controversial -- she met DAC Meynell, a senior policeman
10 responsible for her protection, and asked for her
11 protection to be removed. Do you remember that?
12 A. Vaguely, yes. I mean, rather better than vaguely, but
13 I couldn't remember word for word.
14 Q. I think there was an initial stage from the end of 1993
15 to February of 1994 when her protection was halved,
16 reduced to two PPOs; do you remember that taking place?
17 A. I don't remember the specific details. I certainly
18 remember that the process of the withdrawal of
19 protection from her took some time and may have been in
20 stages.
21 Q. Then, on 1st February 1994, I think that you had
22 a meeting with Mr Meynell and Sir Robert Fellowes.
23 A. I don't remember it precisely.
24 Q. It may help to show on screen briefly the record of that
25 meeting. It's [INQ0058850]. This is DAC Meynell

60

1 recording a meeting with yourself and
2 Sir Robert Fellowes, in which he records you saying that
3 notwithstanding the risks inherent in her actions, Her
4 Royal Highness was determined to continue her private
5 activities without the benefit of police protection.
6 Robert Fellowes asking you if you were in a position
7 to assure him, in the event of anything untoward
8 occurring to Her Royal Highness, to absolve both the
9 Commissioner and the Home Secretary from blame and
10 embarrassment which would undoubtedly arise; you saying
11 that the Princess was totally aware of the possible
12 outcome of her decision, but valued the freedom that
13 such a decision had brought about and could not be
14 persuaded to change her mind. Then Sir Robert Fellowes
15 asking you if you would be prepared to put that in
16 a note.
17 Is that an account of the meeting which accords with
18 your memory now?
19 A. Yes, it does.
20 Q. Thank you. I don't think we need it on screen any
21 longer.
22 So the reason you gave, according to that, is that
23 the Princess valued the freedom that her decision was
24 giving her?
25 A. That was my interpretation. I have to say that I was

61

1 very uneasy about her decision. I tried to persuade her
2 to keep her security, and I think we did compromise that
3 security would be provided when she undertook public
4 engagements. But it was a development I was very
5 unhappy about.
6 Q. Yes, in fact, in your book, in fairness to you,
7 page 200, you pay tribute to the personal protection
8 officers and say that they had a high degree of
9 professionalism; is that right?
10 A. I would do so again now.
11 Q. And you describe the decision to cut off police
12 protection as indicative of erratic judgment. That's
13 page 325. Is that what you still think?
14 A. Yes.
15 Q. Then, page 326, you describe it as a "bold, even
16 reckless move, the result in varying parts of a desire
17 to secure some privacy, a wish to appear different from
18 her in-laws ... and a willingness to demonstrate her
19 popularity ..."
20 A. That was my judgment, yes.
21 Q. It was your assessment of the motivation?
22 A. Yes.
23 Q. You also say this -- and you may wish to look at
24 page 326 for this -- that when her decision had been
25 taken, you expressed some concern for her safety, and

62

1 that she responded:
2 "I don't need any of that stuff, Patrick. Nobody is
3 going to hurt me."
4 Is that a conversation that you recall?
5 A. Yes, that was fairly typical of a number of things she
6 said at around that time.
7 Q. Moving on to another topic you deal with in your book --
8 this is page 253, if you want to flick a few pages back
9 in the extracts -- you write this -- sorry, to put it in
10 context, you are dealing at this stage with the
11 aftermath of the publication of Andrew Morton's book,
12 which I think was published in June of 1992.
13 A. Mm.
14 Q. You say this:
15 "She received several well-intended letters from
16 Prince Philip at this time, but appeared to register
17 only what she chose to hear as their unsympathetic
18 tone."
19 Now, just to clear one point up, this is the only
20 correspondence from the Duke of Edinburgh that you refer
21 to in your book; is that right?
22 A. I think so.
23 Q. Now, the jury has been told repeatedly about
24 correspondence to the Princess of Wales from the
25 Duke of Edinburgh running between June and October of

63

1 1992 which had a supportive tone. Is that the
2 correspondence that you are referring to in this section
3 of your book?
4 A. I think so.
5 Q. Did you actually see the correspondence?
6 A. Yes, I was shown some of it by the Princess. That's why
7 I formed the opinion that it was well intended.
8 Q. We have already heard from Rosa Monckton that the
9 Princess was sometimes upset when seeing the letters,
10 despite their tone being supportive and their intentions
11 being good. Do you recall having seen her upset in that
12 way?
13 A. Well, I think, as I have indicated here, that she
14 appeared to, I think I said register only their
15 unsympathetic bits. As I recall, they were quite
16 balanced, but it's quite possible to read the same
17 document in two different ways, and I was trying to be
18 objective in my reading of it. So I think that I was
19 surprised that she seemed to choose to read it in a --
20 read them in a less sympathetic light.
21 Q. Thank you. Moving on to another event in 1992, you no
22 doubt recall, in August of 1992, the publication of the
23 so-called "Squidgy tapes" --
24 A. Yes.
25 Q. -- the conversations between the Princess and Mr Gilbey.

64

1 Do you also recall, late 1992/early 1993, tapes being
2 published of conversations between the Prince of Wales
3 and Mrs Parker-Bowles?
4 A. Yes.
5 Q. So-called "Camillagate". Both conversations had,
6 I think, been recorded some years earlier?
7 A. Apparently.
8 Q. In your book, you describe the Princess being
9 understandably very distressed in reaction to the
10 publication of those tapes.
11 A. Yes, I don't recall the exact word I used, but she was
12 also, as she often was, quite calm under pressure.
13 Q. This is page 256. It's your description, so you may be
14 saying the same thing:
15 "She was alternately despairing, defiant or lost in
16 self-pity."
17 So that suggests a variation between defiance and
18 being rather down.
19 A. I think it was very difficult for her because I think at
20 the time she was at Balmoral with the rest of the
21 Royal Family and therefore was already feeling rather
22 isolated.
23 Q. Then at page 280 of your book, you deal with rumours
24 relating to those published tapes and you write that:
25 "Excited rumours were multiplying about the source

65

1 of both recordings, both the Squidgy tapes and the tapes
2 between the Prince of Wales and Mrs Parker-Bowles."
3 You say that the rumour that was going round was
4 that rogue elements of the security services were
5 involved and they were popular suspects with the
6 tabloids and the Princess alike.
7 A. Yes.
8 Q. So those rumours were current in the tabloids and were
9 also rumours that were finding favour with the Princess,
10 were they?
11 A. Well, she certainly didn't say anything to me that
12 suggested she dismissed the idea.
13 Q. But you go on to make clear in your book that from all
14 your dealings, you didn't believe that there was any
15 sinister plot of that kind.
16 A. I think that it's fair to say I was quite aware that her
17 communications might be monitored by the security
18 services, but the operative word there, I think, was
19 "hostile", and I would quite often say to her that she
20 must assume that her phone calls could be overheard and
21 should bear that in mind when she decided what to say.
22 I think I used the example of when I was in the
23 Navy, when landline phones were used, there was a notice
24 on them which said "This line is not secure", in other
25 words "Be careful what you say", and I advised her to

66

1 adopt a similar sort of attitude when she was using her
2 own phone.
3 Q. Was that advice that stemmed from your general
4 background or from something specific that you learnt at
5 any stage?
6 A. Nothing specific, but again it was almost in response to
7 these rumours that -- it was something that she perhaps
8 should treat as a fact of life rather than as something
9 which was necessarily hostile and aimed at her.
10 Q. But, again, that advice wasn't given on the basis of
11 anything specific you learned?
12 A. No.
13 Q. You say, in your book, that the Princess of Wales was
14 an eager early customer of digital mobile phone
15 technology because that was thought to be less
16 vulnerable to that kind of monitoring.
17 A. I think I said "the Wales Household" because it
18 certainly including the Prince of Wales' staff as well.
19 Q. So both sides of the Household were equally keen on the
20 new technology?
21 A. That was the impression I had, yes.
22 Q. These inquests have heard evidence that the Princess of
23 Wales had her apartment swept for listening devices in
24 both 1993 and 1994. Were you aware of those sweeping
25 exercises?

67

1 A. I became aware of them, although I wasn't officially
2 notified.
3 Q. Were you aware at the time or some time later?
4 A. I think there were a number of occasions when it took
5 place, and I think by the time of the last occasion
6 I was aware of it, yes.
7 Q. Just so you are filled in, Mr Wharfe gave evidence that
8 a firm posing as a carpet-cleaners came to perform
9 a sweep in May 1993, and Mr Harding has given evidence
10 that he performed four sweeps in mid-1994.
11 A. I never met Mr Harding. I wasn't officially aware of
12 these visits, although, as I say, I was aware through,
13 I suppose, unofficial sources.
14 Q. Mr Harding also gave evidence that at one point he found
15 a kind of signal which might have been either from
16 a listening device or from a radio or an innocent item
17 of electrical equipment. Were you aware of that finding
18 he had made?
19 A. No.
20 Q. Moving on, then, to late 1995. Now we know that the
21 Panorama interview was broadcast on 20th November 1995,
22 and we also know that you weren't consulted in advance
23 of that.
24 A. I was made aware of it by the Princess about a week
25 before the broadcast.

68

1 Q. But you weren't consulted about whether she should do
2 the interview?
3 A. Specifically not.
4 Q. Because this time is the time that we are dealing with
5 your meeting with Lord Mishcon. It's probably important
6 to look at the Princess's mood around this time, late
7 1995. You deal with this at page 371 of your book,
8 which again you may want to look at. You say this:
9 "Such was the pressure she herself was under, the
10 Princess's moods could swing from small-voiced
11 vulnerability to icy hostility in the space of a single
12 phone call.
13 "On top of this, her paranoia had reached new
14 heights. She saw plots everywhere, was obsessed with
15 the thought that she was being bugged and honestly told
16 me that her car's brake lines had been cut. Looking me
17 straight in the eye, she even said that somebody had
18 tried to 'take a pot' at her with a gun in Hyde Park.
19 Needless to say, I had all these accusations checked
20 out, but the truth was as I had known all along: such
21 threats were all in her imagination."
22 That section of your book comes at a time that you
23 are dealing with events in late 1995. Is this a fair or
24 only a one-sided summary of her mood at that time?
25 A. It's a fair description of what I perceived at the time

69

1 and what I felt at the time. In isolation it perhaps
2 looks rather uncharitable, but my intentions are
3 anything but uncharitable towards her. But I was
4 confused, certainly, and as the paragraph opens, "Such
5 was the pressure she herself was under ...", I felt this
6 was the result of the very difficult and painful
7 position she found herself in.
8 Therefore, even as she was telling me these things,
9 I was aware that she had many good excuses for having
10 a rather defensive attitude to what was happening to
11 her. I suppose my frustration was that I didn't believe
12 these were true, but I wanted to know why she was saying
13 these things, and because, as I think I had said
14 earlier, she seemed unduly open to suggestions which
15 I thought were misleading or mischievous, then I was
16 dismayed that time and energy were being spent dealing
17 with what I was pretty sure were rumours instead of some
18 of the practical things that might have been done to
19 improve her situation.
20 Q. Now you refer to a few specific points there. You refer
21 to her telling you honestly that her car's brake lines
22 had been cut. The jury have heard from Rita Rogers, the
23 medium, that she told the Princess that her brakes had
24 been tempered with. Did the Princess ever cite
25 Mrs Rogers as the source of that comment?

70

1 A. No. I had great difficulty identifying who the source
2 was. I mean my main concern was to see, first of all,
3 if these allegations were true, and if they weren't,
4 then where they were coming from.
5 Q. Also in late 1995, is this right, that the Princess of
6 Wales was preoccupied with ideas about
7 Tiggy Legge-Bourke?
8 A. Yes, she was.
9 Q. Did she think at that stage that Miss Legge-Bourke was
10 having an affair with Prince Charles?
11 A. She never said as much to me specifically, but I think
12 in December that year she told me that she believed
13 Miss Legge-Bourke was pregnant.
14 Q. You refer in your book -- and we need not go into the
15 detail of this -- to a remark made by the Princess of
16 Wales to Miss Legge-Bourke at a Christmas party in
17 December 1995.
18 A. Yes.
19 Q. Was that in that general context?
20 A. Yes.
21 Q. Another point that you have mentioned, as I say, is
22 concerns about the car. I think you also specifically
23 recall the Princess of Wales, in late 1995, having
24 concerns first of all about tracking or homing devices
25 having been placed on her car, and secondly, as we have

71

1 heard, the brakes. Those are points you make in your
2 witness statement, I think.
3 A. Yes.
4 Q. You told officers from Operation Paget -- and this is
5 recorded in a message -- that you had the chauffeur,
6 Steve Davies, check the car both for tracking or homing
7 devices and also for any tampering with brakes. Do you
8 remember asking him to do that?
9 A. Yes, I do. This again was trying to establish how much
10 weight I should place on the Princess's assertions that
11 her brakes were cut and that her car had a homing device
12 in it.
13 Q. You say that after Mr Davies had made those checks, he
14 told you that there was no problem of any kind.
15 A. Yes, I mean, it didn't seem out of the question to me
16 that there might be a homing device in her car. I mean,
17 that seemed like -- it's quite normal now for cars to
18 have tracking devices. It didn't seem to me to be
19 necessarily, in itself, sinister that her car might have
20 a tracking device in it.
21 Q. You say again, in the message recorded by the Paget
22 officers, that the Princess of Wales, when you had
23 reported that nothing had been found, found that to be
24 inconclusive.
25 A. That seems likely. I don't remember it exactly.

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1 Q. Do you remember what her reaction was when you told her
2 that nothing had been found?
3 A. Yes, inconclusive, yes.
4 Q. I have to put to you out of fairness that Mr Davies has
5 given evidence and he believes he didn't make any such
6 checks at your request. Could you be referring to
7 somebody else other than Mr Davies or is he just wrong
8 about that?
9 A. Well, I didn't make a record of it, but my memory is
10 quite clear that I did ask him if there had been
11 a problem with the brakes or if he had been aware of any
12 tampering with them. But it wasn't -- it was not
13 something I made an official issue out of. It was
14 really, I suppose, me trying to confirm the likelihood
15 in my own mind that no such tampering had taken place.
16 So it doesn't altogether surprise me that he might not
17 remember it. My own memory of it is clear, but not very
18 detailed.
19 Q. Moving on now to an event the jury have heard about
20 a number of times, your meeting with Lord Mishcon along
21 with the Princess. Perhaps you can have on screen the
22 note made by Lord Mishcon [INQ0006335]. Mr Foley is
23 ahead of me again. I think this is the first time you
24 are seeing the full text of the note; is that right?
25 A. Yes.

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1 Q. It is fair that you have the opportunity to read it.
2 I will not read it again because it has been read into
3 evidence a number of times. (Pause)
4 A. Yes.
5 Q. Have you had the chance to look at that?
6 You will see there Lord Mishcon recording that in
7 this meeting, on 31st October 1995, the Princess
8 expressed the views or beliefs that, first, the Queen
9 would be abdicating in April 1996; secondly, that
10 efforts would be made to get rid of her or to injure her
11 in a staged car accident; thirdly, that both she and
12 Mrs Parker-Bowles would be put aside; and finally, that
13 Miss Legge-Bourke had been operated on for an abortion,
14 and she, the Princess, would shortly be in receipt of
15 a certificate. Dealing with that aspect of the meeting,
16 is the note accurate about what the Princess said?
17 A. I don't remember exactly, but I wouldn't dispute it.
18 Q. Do you have a recollection of any of those things being
19 said by the Princess during that meeting?
20 A. Yes.
21 Q. Do any particularly stand out as something you remember?
22 A. No.
23 Q. The note goes on to say that Lord Mishcon told the
24 Princess that if she really believed her life or being
25 was threatened, security measures, including those

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1 relating to her car, must be increased, but he frankly
2 could not believe that what he was hearing was credible.
3 Do you remember Lord Mishcon making suggestions about
4 security measures?
5 A. I don't remember that, but I do remember him saying to
6 me afterwards that these were serious allegations.
7 Q. He then refers to asking for a private word with you
8 apart from the Princess. Does that stick in your mind
9 at all?
10 A. Yes. I remember that better than the meeting.
11 Q. He records you as saying that you "half-believed in the
12 accuracy of what the Princess had said as to the risks
13 to her safety". Pausing there, did you say that?
14 A. Quite possibly.
15 Q. Secondly, did you half or entirely believe that there
16 was a serious threat to the Princess's safety at all?
17 A. I think that should be interpreted as an expression of
18 my own uncertainty. Although, as I think I have said in
19 my statement, I did not think that there was any truth
20 in the allegations, I was very concerned that they were
21 being made at all, so not so much the content, but the
22 fact that she was saying these things.
23 It concerned me for two reasons: one was that it is
24 suggested that she was attaching more and more belief in
25 what she was being told by others who I didn't know, and

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1 that, by attaching such importance to these allegations,
2 she was playing into the hands of her critics in what
3 you might call the "Royal Establishment", who were at
4 that time, I knew, quite prepared to suggest that she
5 was mentally fragile or in some way a liability to the
6 Royal Family.
7 So I assumed that what the Princess had said to
8 Lord Mishcon was a privileged matter. This was
9 something she was saying to her solicitor and he was
10 obliged to take it at face value. My concern was to
11 remain objective as my job entailed giving the Princess
12 the best advice I could. To me that meant not believing
13 everything she was told or that she told me necessarily,
14 but that I should weigh it alongside other information
15 that I had.
16 Now because I did not have any other information at
17 that stage to confirm what she was saying one way or the
18 other, it seemed to me quite logical and sensible to say
19 to Lord Mishcon that I half-believed it. I knew neither
20 one way nor the other.
21 Q. Can I put it to you, the way you put it in your
22 statement. You say this, it's towards the end of page 1
23 of your statement:
24 "I should explain that in the circumstances, though
25 I thought it highly unlikely that they [that is the

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1 concerns of the Princess] were well-founded, I was
2 anxious not to dismiss these claims outright. The
3 Princess had made similar claims to me in the recent
4 past without any evidence being found. There were no
5 reliable witnesses. Nevertheless, I knew that an open
6 expression of disbelief might discourage her from
7 sharing similar fears in the future. I felt it best to
8 try to elicit the source of her information in order to
9 decide what credence it deserved. However, in the time
10 available I was not able to establish the source with
11 any certainty and even wondered if one existed at all.
12 Knowing her as I did, I was fairly confident that her
13 reactions were not those of someone who actually feared
14 for her life."
15 Are those paragraphs an accurate expression of what
16 you were thinking?
17 A. Yes.
18 Q. Going through them: the Princess had made similar claims
19 to you in the recent past without any evidence being
20 found; is that a reference to what you were saying in
21 relation to brakes being tampered with and so on?
22 A. Yes, and I think also her belief that her apartments
23 were bugged.
24 Q. Then when you say there were no reliable witnesses, is
25 that an indication that there were no reliable witnesses

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1 to support, as far as you were aware, the concerns that
2 she was expressing?
3 A. Yes.
4 Q. Then you go on to say that you felt an open expression
5 of disbelief might prevent her from sharing concerns in
6 the future.
7 A. I used the word "fears" and I think that's worth
8 stressing.
9 Q. I have been using the word "concerns" because that's the
10 word that appears in your statement, but I am happy if
11 you would prefer to use "fears".
12 A. Yes, on the bottom line of the first page.
13 Q. Yes, yes. I was using "concerns" because it appears
14 further up where you refer to having half-believed her
15 concerns. I doesn't matter --
16 A. I used the word "fears" deliberately there because --
17 I mean, I would say again, my concern was why she was
18 feeling like this. It was because she was afraid, and
19 I was frustrated because I didn't know the source of her
20 fears.
21 Q. But, as far as you know and from what you had checked
22 out, you weren't aware of any reliable evidence to
23 support those fears?
24 A. Correct.
25 Q. After the meeting, were you able to find any reliable

78

1 evidence or any sources for those fears?
2 A. No.
3 Q. After the meeting, as far as you were aware -- and we
4 know you were only in post for another month or two --
5 were any additional security measures taken by or for
6 the Princess?
7 A. Not that I was aware of.
8 Q. One final brief topic: in your book you say that you
9 received a number of personal missives from the Princess
10 over the years, and you say that most of them were
11 signed off "With love from Diana"; is that right?
12 A. Do I say "most"? I mean several of them were, but in
13 the course of my working duties, I, on a daily basis,
14 exchanged sometimes dozens of notes with the Princess.
15 It would be very unusual for them to be signed off "with
16 love". It did happen occasionally when she was
17 particularly appreciative of something I had done.
18 Q. I am referring to page 259 of your book, where you say:
19 "As with most of her missives, this one came 'with
20 love from Diana'."
21 A. I am sorry, by "missive" there, I meant letter or note
22 rather than office memorandum.
23 Q. Personal notes?
24 A. Yes.
25 Q. You also say, again in relation to these personal notes,

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1 that "her style was sometimes over-flowery, effusive".
2 A. Yes, and that was a good reflection of her character.
3 Q. You also say that over the years the Princess gave you
4 a number of sets of cufflinks as gifts.
5 A. Yes.
6 Q. You say elsewhere in your book that cufflinks were
7 a gift that she often gave.
8 A. Yes. There was a distinction. There were cufflinks
9 that carried -- that were her cipher, which were
10 official gifts similar to the kind given by many members
11 of the Royal Family. The ones she gave me were ones she
12 had chosen.
13 Q. Of course we have heard about cufflinks which were said
14 to have been owned by her father, which she said had
15 been owned by her father, and that would be a still more
16 distinctive gift; is that right?
17 A. I would think so, yes.
18 MR HOUGH: Thank you very much. Those are my questions.
19 LORD JUSTICE SCOTT BAKER: Mr Mansfield?
20 Questions from MR MANSFIELD
21 MR MANSFIELD: Yes, good morning, Commander. I am
22 Michael Mansfield. I represent Mohamed Al Fayed.
23 A. Mr Mansfield.
24 Q. I have a number of questions for you. Starting first of
25 all with this: whatever else one says reflecting on

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1 Princess Diana, she was not mentally unstable, was she?
2 A. No.
3 Q. You appreciate that was one of the allegations being
4 made against her by forces that were hostile to her,
5 wasn't it?
6 A. I was aware of it at the time and I have since become
7 more aware of it.
8 Q. Yes. So she would not be paranoic about believing that
9 there were people who were saying that about her, would
10 she? That's what they were saying?
11 A. She would not be a paranoic. I am certainly concerned
12 about what is, I think, a medical term -- and
13 I am concerned to see it again in my own book -- where
14 I refer to "paranoia", which I think is a medical
15 diagnosis which I would question. Paranoid behaviour
16 I did see, and it was, so far as I was aware,
17 justifiable.
18 Q. Yes, I will come to that. So she was perfectly
19 justified in believing, because they were saying it,
20 that the forces ranged against her thought she was
21 mentally unstable because they were saying that. So she
22 was perfectly justified in thinking that those forces
23 thought that because they said it?
24 A. Yes.
25 Q. Right. Now, in addition to that, of course she had

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1 a number of people -- you were one of them -- for
2 a period up to 1996, as you have described, upon whom
3 she could trust for reliable advice and reliable
4 perspectives; correct?
5 A. I hope so.
6 Q. Yes. I want to deal with the observation you have made
7 today: "I was quite aware that her communications might
8 be monitored by the security services". Those are the
9 words you have used today, all right? Just dealing with
10 this aspect, first of all that was something you
11 communicated to her; correct?
12 A. Yes.
13 Q. You are not prone to fantasy?
14 A. I don't think so.
15 Q. I am sorry, these are rather obvious questions, but you
16 may understand the purport of them.