Hearing transcripts

29 January 2008 - Afternoon session

21 (2.00 pm)
22 (Jury present)
23 LORD JUSTICE SCOTT BAKER: Yes, Mr Mansfield.
24 MR MANSFIELD: I was asking you just before lunch, on
25 a reflective basis, whether, as far as you can now

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1 consider and assess, any errors made by your team on the
2 night. So far the only error you have been prepared to
3 concede concerns staffing levels. You have had time
4 over lunch. Are there any other errors?
5 A. No, sir.
6 Q. You must have thought about this quite a lot -- in other
7 words, before today --
8 A. Yes, sir.
9 Q. -- as to whether you could have done anything
10 differently.
11 A. Yes, sir.
12 Q. When I say "you", I mean you as a team, because that's
13 how you were working.
14 A. Yes, sir.
15 Q. I am going to suggest there are a number, but I am going
16 to concentrate on two of the most important errors that
17 night. Neither of these two that I am going to suggest
18 to you have anything to do with staffing levels; do you
19 follow?
20 A. (Witness nods)
21 Q. Absolutely down to your team. Seatbelts. It's
22 perfectly plain that neither of the principals at the
23 scene of the crash had seatbelts on; you know that?
24 A. Yes.
25 Q. This is quite important, isn't it?

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1 A. Yes.
2 Q. It's part of the security responsibility as bodyguards
3 that you have, isn't it?
4 A. Absolutely.
5 Q. I will take Princess Diana first of all. There is
6 absolutely no evidence to suggest that she was in the
7 habit of not wearing a safety belt, in fact quite the
8 reverse, that she normally did, and that drivers who
9 went with her in London and elsewhere, and who acted as
10 bodyguards and so forth, insisted on her wearing safety
11 belts and there is no suggestion she didn't. Right?
12 A. I couldn't comment.
13 Q. You see, at the very least -- at the very least --
14 although you weren't in the car, there was
15 a responsibility by your colleague to ensure that
16 Princess Diana did have her safety belt on before they
17 moved off from the rear of the hotel; do you agree?
18 A. I know Trevor, I have known him of old, and he is a very
19 professional guy, and what he will have done is ensured
20 that he mentioned the seatbelts to Dodi and the
21 Princess. Without a shadow of a doubt, Trevor will have
22 mentioned that, but he can't physically grab the
23 Princess of Wales and put a seatbelt on her.
24 Q. No, no, please understand, no-one has suggested that
25 Princess Diana ever refused to wear one. Really what

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1 I want to get at here is that neither of you really paid
2 sufficient attention to the important details that day.
3 Nothing to do with staffing; to do with your
4 responsibilities. You understand the question?
5 A. As far as I am aware, the responsibility of the BG in
6 the vehicle with the principals is to remind them to put
7 the seatbelt on.
8 Q. Well, it looks as though -- because if she were
9 reminded, her habit was in fact to wear them, so it
10 looks as though she wasn't reminded; do you follow?
11 A. Yes, but I think the Princess of Wales had travelled in
12 enough cars to know that when you get into a vehicle,
13 you put a seatbelt on.
14 Q. Of course.
15 A. So to say that Trevor was in any way remiss in his
16 duties, you would have to ask Trevor. But I know Trevor
17 of old, he is a very professional guy and he will have
18 asked the Princess and Dodi to put their seatbelts on.
19 Q. He can't explain this part of it, you see. It may have
20 something to do with his memory and I accept that part
21 of it. All I am saying to you is neither of them were,
22 and there isn't any evidence that Dodi ever refused to
23 put on a safety belt. It is part of your
24 responsibility, you agree, to ensure that your
25 principals are kept in a safe environment?

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1 A. Yes, and I am sure that Trevor will have reminded the
2 Princess and Dodi to put their belts on.
3 Q. So they both, as it were, you think, must have refused
4 to do it?
5 A. I couldn't comment on that because I wasn't in the
6 vehicle.
7 Q. I see. I want to move forward from the seatbelt issue,
8 except this: when you went from the airport, Le Bourget,
9 was everybody wearing seatbelts?
10 A. Everybody was in my vehicle, yes.
11 Q. What about the other one?
12 A. I couldn't comment on the other vehicle.
13 Q. When, of course, you left the rear of the Ritz to go to
14 the apartment, was everybody wearing seatbelts?
15 A. In my vehicle they were, yes.
16 Q. But you don't know about the other vehicle?
17 A. No, I wasn't in that vehicle.
18 Q. Of course, when you left the apartment to go back,
19 eventually ending up at the Ritz, were you all wearing
20 seatbelts?
21 A. As far as I am aware we were, yes.
22 Q. You didn't have anybody in the lead vehicle to remind
23 someone to wear a seatbelt, did you?
24 A. Yes, we had the Ritz driver.
25 Q. Philippe Dourneau?

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1 A. I don't know his name.
2 Q. You don't know. But of course there is an even more
3 important issue than the wearing of seatbelts and that
4 is obtaining authority or clearance for a palpably
5 terrible decoy plan; do you agree?
6 A. I am sorry, what was the question?
7 Q. Yes. The other matter which I am going to put to you,
8 which is far more serious, is obtaining clearance for
9 a plan that you say you regarded as "terrible". I am
10 using your words. Right?
11 A. (Witness nods)
12 Q. Because I think you agree you didn't get clearance, did
13 you?
14 A. Clearance for which plan? For Dodi's plan?
15 Q. Well, I will come to whose plan it was. You didn't get
16 clearance for the plan that Henri Paul should drive
17 another car from the rear and that the other two
18 vehicles that you had used earlier on in the day should
19 be used as decoys, that plan?
20 A. Clearance from whom?
21 Q. I am sorry, if you are going to -- you did regard it as
22 terrible, did you?
23 A. It wasn't a very good plan, no.
24 Q. That's the word you have used in the past, a "terrible
25 plan".

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1 A. I don't understand the question.
2 Q. Don't you? I am going to suggest this is the most
3 crucial part of the day. According to you -- and we
4 will come to who actually presented this plan to you in
5 a moment -- the most crucial part of the day, you are
6 presented with a plan that -- whether you used the word
7 "terrible" -- that was a word you have used, isn't it,
8 "terrible plan"?
9 A. I would imagine so, yes.
10 Q. Right. A terrible plan is presented to you. Your
11 obligations are in fact to Mohamed Al Fayed, aren't
12 they?
13 A. Our obligations were to the Princess and Dodi that
14 night.
15 Q. Ultimately, for the security, Mohamed Al Fayed?
16 A. Mr Fayed wasn't there.
17 Q. There is a telephone, isn't there?
18 A. Trevor and I made the decision to speak and remonstrate
19 with Dodi when we got the opportunity, which you saw us
20 do on there.
21 Q. We will come to what you said over the many years. Now,
22 do you agree that you did not get clearance, in other
23 words authority or whatever, from the ops room, let
24 alone anyone else, name Handley-Greaves, John Macnamara,
25 Mohamed Al Fayed -- you didn't get authority or

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1 clearance from them for this plan, did you?
2 A. When we spoke to Dodi, he told us that the plan had been
3 okayed by Mr Fayed.
4 Q. I am so sorry. Just answer the question and we will be
5 much quicker.
6 LORD JUSTICE SCOTT BAKER: I think the witness is answering
7 the question.
8 MR MANSFIELD: I appreciate what you are going to say, which
9 is "They told me it had been cleared".
10 A. That's right.
11 Q. Yes. I will come to that. The first thing is: do you
12 agree that you didn't get clearance from the ops room?
13 Whatever you are being told and whoever it's by, you
14 didn't get clearance from the ops room for this, did
15 you?
16 A. Well, no, because it wasn't an ops room decision to
17 make.
18 Q. That's the first stage. You didn't get clearance. I am
19 now going to suggest to you that not only did you not
20 get clearance from the ops room or Mohamed Al Fayed or
21 anybody else, you didn't -- or neither did Kes (sic) --
22 actually telephone through what the plan was, even
23 though you thought, you say, it had been authorised;
24 correct?
25 A. We heard from Dodi that the plan had been authorised by

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1 Mr Fayed.
2 Q. You didn't telephone through --
3 A. I personally never telephoned, no.
4 Q. No we have your telephone records --
5 LORD JUSTICE SCOTT BAKER: Would there have been any point
6 if it had been authorised by the boss?
7 A. No, sir. In that situation, if I may, because Mr Fayed
8 is so hands-on with every aspect of his organisation,
9 many people take the boss's name -- sorry, Mr Fayed's
10 name -- in vain, and because of that, once Dodi had said
11 to me, "Its okay, it's been okayed by MF, it's been
12 okayed by my father", that really closed the door on any
13 further discussion.
14 MR MANSFIELD: We will come to it.
15 I am going to suggest to you that whatever you are
16 being told, because you knew that Mohamed's name was
17 taken in vain, it's part of the instructions that you
18 are given when you do this job to make sure that his
19 name is not taken in vain, particularly by those
20 offspring who have bodyguards. That was well known to
21 you, wasn't it?
22 A. I wouldn't call him "offspring". Mr --
23 LORD JUSTICE SCOTT BAKER: What age was Dodi?
24 A. He was 42, sir.
25 MR MANSFIELD: That's if, of course, the whole of this plan

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1 had in fact come from Dodi.
2 A. Sir, the situation I found myself in with Trevor was if
3 we would have called Mr Fayed that night, essentially
4 what we were saying to him, "I'm sorry to bother you at
5 such a late hour, sir, but is your son lying to me?"
6 Q. No, no --
7 A. Well, it is.
8 Q. I want to put to you this situation: you wouldn't have
9 allowed a drunk driver. That you have made very clear.
10 A. Absolutely not.
11 Q. Right. And here we have an insecure plan, if I may put
12 it that way, according to your recollection; is that
13 right?
14 A. Yes, sir.
15 Q. An insecure plan. You have no problem about your
16 contact with Mohamed Al Fayed. You worked for him. You
17 have already said that.
18 A. Yes, sir.
19 Q. This isn't a question of ringing up and saying "Dodi's
20 lying" -- if it all came from Dodi, of course -- is it?
21 It's a question of saying, at the very least to the ops
22 control, "I don't like this plan, but on the other hand,
23 as I understand it, it's been authorised and we are
24 leaving now". Did you do that?
25 A. No, sir.

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1 Q. Why not?
2 A. Because it had been okayed by Mr Fayed.
3 Q. No, please understand, we have moved on just slightly.
4 So if you thought it had been okayed by
5 Mohamed Al Fayed -- and I want to make it clear to you
6 that none of this had been authorised by
7 Mohamed Al Fayed -- do you follow -- none of it. I want
8 to make it clear that if he had known what was going on
9 or the ops room had known what was going on, it would
10 have been countermanded. Do you follow? That is why
11 I am putting these questions to you.
12 A. I follow that -- I follow what you are saying. I can
13 see where you are going, but I disagree with what you
14 are saying.
15 Q. You may do.
16 A. I do.
17 Q. You have a very, very poor memory of who actually told
18 you about any plan, don't you?
19 A. Dodi -- sorry, Henri Paul initially told us about the
20 plan.
21 Q. That is what you say now. Yes, because I have had the
22 CCTV --
23 A. -- the CCTV to look at.
24 Q. Yes, you have had the benefit of looking at the CCTV and
25 I have not objected.

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1 A. If it wasn't to jog my memory, why was I given the CCTV?
2 Q. Well, I will refrain from commenting. You see, if you
3 had not seen that CCTV last night, you would have been
4 coming here giving a quite different story, wouldn't
5 you?
6 A. No, sir.
7 Q. Oh?
8 A. The key points always remain the same. In any statement
9 I have ever given, the key points always remain the
10 same.
11 Q. They always remain the same? Well, I am going to ask
12 you that question, I am afraid it will take a little
13 time, but I will ask you the question again about key
14 points always remaining the same. The key point here,
15 because of what you are just saying about the authority
16 to do this, is who actually told you about the plan;
17 yes?
18 A. Yes.
19 Q. You realise that is key, isn't it?
20 A. It is one of the key points, yes.
21 Q. About which really you couldn't be wrong, according to
22 you?
23 A. I could be mistaken at what time I was told, but the --
24 in essence I was told by Henri Paul and then it was
25 confirmed by Dodi.

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1 Q. But that, of course, isn't what you have always said, is
2 it?
3 A. As far as I am aware it is, yes, sir.
4 Q. Is it?
5 A. As far as I am aware.
6 Q. Do you even have a memory of what you have said at
7 various times? Do you?
8 A. Usually, sir, yes.
9 Q. Sorry?
10 A. Usually, yes.
11 Q. Do you think you have always said that the plan was in
12 fact spelt out by Henri Paul and then confirmed by Dodi?
13 Is that what you have always said?
14 A. It's not what I have always said, no.
15 Q. No.
16 A. I have had lapses in memory I think --
17 Q. Oh, have you? You do recognise how serious this is,
18 don't you?
19 A. Absolutely, yes.
20 Q. I am dealing with the kernel of what happened that
21 night --
22 A. Yes.
23 Q. -- and your responsibility that night.
24 A. Yes.
25 Q. Because I am going to suggest to you that what you

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1 allowed to happen here -- and I will go through it with
2 you -- is you allowed Henri Paul to take the crucial
3 decisions, didn't you?
4 A. No, sir.
5 Q. Well, just for the moment, I am going to ask you to look
6 at the statement that you have there dated
7 15th February 2005. This is a statement which you have
8 told us today and you told the police in 2005 you were
9 making when purposefully not looking at your earlier
10 statement so you could tell the truth; all right?
11 A. Yes, sir.
12 Q. Do you know what this statement says about who told you
13 about the plan, the details of the plan?
14 A. No, sir.
15 Q. So you don't even remember what's in this statement that
16 you must have read, what, last night?
17 A. Yes, I was reading it last night.
18 Q. You were reading it last night. You have come here to
19 tell the truth, haven't you?
20 A. Yes, sir.
21 Q. It's one thing to say, "Look, it's a long time ago,
22 I really can't remember"; you follow that?
23 A. I understand that.
24 Q. And I am giving you every opportunity. If you really
25 want to say you can't remember and it's all a haze,

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1 please say so.
2 A. No, I am trying to get to the bottom of it.
3 Q. I will ask, therefore -- in view of that answer, there
4 are some pretty clear explanations as to how this comes
5 about.
6 A. Yes.
7 Q. If you look at page 9, and I think so that the jury may
8 follow, could we have [INQ0007113 - read out in court] please? Could we
9 have the paragraphs highlighted that come after your
10 observations about Henri Paul:
11 "The first I knew of the plan ..."
12 Do you see that?
13 A. Yes.
14 Q. I am going to read that, now it is highlighted, so the
15 jury may follow:
16 "The first I knew of the plan to leave was about
17 15 minutes before departure."
18 You were asked about that this morning:
19 "Dodi popped his head out and said that the two of
20 them -- Dodi and the Princess -- were to go in another
21 car from the rear of the hotel with just a driver. Then
22 he went back into the suite. This plan was a bad idea.
23 Trevor and I spoke to each other and decided we would
24 say to Dodi to go from the front of the hotel."
25 Note the next bit:

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1 "Trevor knocked at the door and said this, and Dodi
2 said to us, 'It's been okayed by MF, it's been okayed by
3 my father', those were his exact words. I have no
4 knowledge of any phone calls between Dodi and
5 Mohamed Al Fayed."
6 A. Yes.
7 Q. Then you deal with Mohamed Al Fayed's name in vain and
8 so on, "couldn't go and check" -- well, I am going to
9 ask you about that:
10 "Trevor said to Dodi 'You need a back-up
11 vehicle'..." and so on.
12 In fact, the only mention -- perhaps I will read the
13 rest of it so you can see:
14 "... but Dodi said 'no'. We said to him, 'Look, you
15 must have someone with you' and then he said okay, but
16 told us that as there was only one car, only one of us
17 could go. Dodi told us that he wanted our two vehicles
18 to remain at the front and that he would use another
19 vehicle to go from the rear. Dodi said that one of us
20 was to go to the front and indicate that they'd be out
21 in five minutes. Trevor was very frustrated about
22 Dodi's plan for the departure from the hotel. I would
23 emphasise that it was Dodi's plan. He said he was going
24 to have it out with him. We talked it out between us
25 and Trevor calmed down. Trevor remained totally

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1 professional, he was just frustrated at the lack of
2 information and the disregard of his advice. I said to
3 him that I'd go in the car instead, but Trevor said 'No,
4 I've said I'll go so I will go'."
5 Where is Henri Paul?
6 A. He wasn't there at that time. All I can say is that has
7 probably been a lapse in memory because of the time that
8 had gone on.
9 Q. I am sorry, a key point you said minutes ago -- key
10 points. You agree, first of all, that this version in
11 2005 has absolutely no mention of Henri Paul providing
12 you with the details, does it?
13 A. No.
14 Q. How is it, therefore, if you have come here to tell the
15 truth and it's not a memory problem which was suggested
16 to you at the start -- it's not a memory problem -- how
17 is it that Henri Paul gets written out and Dodi gets
18 written in?
19 A. That was the memory at the time. However, now I have
20 had the luxury of looking at the DVD --
21 Q. The luxury?
22 A. That's right -- I've had the luxury of looking at the
23 DVD, it's jogged my memory and it's a more current
24 statement.
25 Q. I am going to suggest to you that you will say whatever

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1 you think is convenient, particularly if it doesn't
2 involve any responsibility by you for what happened on
3 that night -- any responsibility.
4 A. No, that's not the case, sir, no.
5 Q. I am going to suggest to you that if this was a plan
6 that you thought had been authorised, even if you
7 thought that, you had a very easy way of dealing with
8 it. I will come to that. That's that version on
9 page 9.
10 Of course you have also been asked about the very
11 first statement you made, because that was the last one,
12 and I am concentrating on what happened outside the
13 suite. In 1997 on 2nd September -- can we have this --
14 there have also been some questions asked on this.
15 Page 5, please. Could we have on screen [INQ0001728 - read out in court].
16 As you will have observed on the previous one, there
17 is no CCTV of Trevor knocking on the door or any of
18 that, is there?
19 A. No.
20 Q. So somehow or another you have left out Henri Paul and
21 suggested that Trevor had made an attempt to follow it
22 up with Dodi.
23 A. Yes, I was mistaken.
24 Q. Mistaken. Now, on this page, could we have from "Trevor
25 and I ..."

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1 Now, I want to ask you whether you remember even
2 what you said this morning about Henri Paul.
3 A. Yes.
4 Q. Do you remember what you said this morning about
5 Henri Paul when you first met him that day?
6 A. Yes, someone introduced us and said "This is Henri Paul,
7 he is the 2IC and works for the Ritz".
8 Q. Even on that detail, do you see what you have written?
9 "Trevor and I ran into Henri Paul several times.
10 I did not know his name and thought he was just
11 a chauffeur."
12 A. I did not know his name at the start and I thought he
13 was a chauffeur at the start. Then, when I first met
14 Henri Paul, I did not know his name, I thought he was
15 a chauffeur because he was driving a vehicle, and then
16 Trev said to me, "No, he is the 2IC", which is the
17 second in command, "of the Ritz security".
18 Q. Right. There is nothing here in this statement or in
19 the other statement, in fact, that you suggest you were
20 introduced to him by name as second in charge of
21 security, is there? But that's, you say, what you
22 remember?
23 A. That's what I remembered at the time, yes. When I first
24 met Henri Paul, because he was driving a vehicle,
25 I thought he was a chauffeur. I did not know his name.

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1 That's when Trevor said, "No, this is Henri. He is the
2 2IC of the Ritz".
3 Q. If I may pause there, dealing with who was planning what
4 that day -- that's the 30th -- whose plan was it, if
5 a "plan" is the right word, "arrangement", to arrive
6 at the Ritz when you first got there on the 30th after
7 the airport? Do you follow? The first arrival?
8 A. Mm.
9 Q. Do you remember where you arrived?
10 A. No, I don't.
11 Q. Front or back?
12 A. I don't remember.
13 Q. You arrived at the rear with the two vehicles; all
14 right?
15 A. Okay.
16 Q. So do I take it that certainly wasn't an arrangement you
17 had come to?
18 A. No.
19 Q. So you had nothing to do with the planning of the
20 arrival. When you left later to go off to the apartment
21 and then on for something to eat, you left from the
22 rear, didn't you?
23 A. I don't recall where we left from.
24 Q. You don't recall. So once again, whoever is involved in
25 that plan, it wasn't you?

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1 A. I don't recall who did it.
2 Q. If you were concerned in security arrangements and you
3 were doing the arranging, you would certainly remember,
4 wouldn't you?
5 A. If I did it last week or last month, yes. However, it
6 was over 10 years ago, so, no, I don't remember.
7 Q. You have been asked many, many times over today about
8 these events, haven't you? So it is not as though you
9 are being asked for the very first time, is it?
10 A. And I still can't remember.
11 Q. You still can't remember. When you got back to the Ritz
12 that night, when there was a problem at the front door,
13 the arrangement to arrive at the front door wasn't
14 yours, was it?
15 A. It was the chauffeur's, I believe.
16 Q. Quite. So you weren't involved in that either?
17 A. I don't believe there is a back door to the apartment.
18 Q. No, so sorry, I mean back at the Ritz. I am leaving out
19 the apartment for the moment. When you got back to
20 the Ritz and arrived at the front of the Ritz --
21 A. I suppose --
22 Q. Because the photographers got in and all the rest of it.
23 A. We didn't know where we were going at the time. If we
24 didn't know where we were going, how could we arrange
25 a plan to get there?

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1 Q. Because you weren't even in the lead vehicle to know
2 where you were going, were you?
3 A. If we had been told where we were going, we could have
4 arranged a plan, but we weren't.
5 Q. Let us pause for a moment. Sometimes if a couple are on
6 holiday, they might not always have everything in mind,
7 might they?
8 A. No, but it was no ordinary couple. They should have
9 kept us informed.
10 Q. Did you know that in fact a member of the Ritz staff had
11 in fact gone to the restaurant in advance?
12 A. No.
13 Q. You didn't know about that?
14 A. No.
15 Q. So far, up to the arrival back at the Ritz, none of the
16 arrangements for travel and arrival at the Ritz had been
17 made or participated in by you; correct?
18 A. That's right.
19 Q. That's right. I want to suggest to you that's how it
20 went on. You weren't actually involved in the planning,
21 were you?
22 A. No, that's absolutely right.
23 Q. Right. So on this, just going back to this page, if you
24 glance further down, you sit outside the suite -- do you
25 see this? You have seen this a bit earlier today.

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1 A. Yes, sir.
2 Q. "Henri Paul came twice, the first time to ask us if
3 everything was all right, the second time to say that
4 everything had been arranged with Dodi."
5 So you do mention Henri Paul in this first
6 statement, but you don't suggest that he spelt out any
7 kind of plan, do you?
8 A. No.
9 Q. Why not?
10 A. I don't know.
11 Q. Well, I would like you to think, because if this
12 statement, being your earliest recollection and
13 therefore likely to be truthful and accurate, I ask you
14 how it is that you have managed to, again, include
15 Henri Paul but not in the role that you now have to give
16 him now you have seen the CCTV; do you follow?
17 A. I don't know, sir, but you really can't argue with the
18 CCTV.
19 Q. No, no, no, I know you can't. I know you can't. I am
20 suggesting that is not my problem, but your problem,
21 isn't it, because you now have to explain what comes
22 afterwards in this statement, because you then say:
23 "At around 23.15, just after Henri Paul called by
24 for the second time, Mr Dodi ..."
25 I am sorry I am going to have to go through the

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1 detail of this. It has been read, but there are some
2 questions I want to ask you.
3 "... opened the door of his suite to ask me how many
4 paparazzi were there."
5 We appreciate that he doesn't appear to have done
6 that, opened the door, until gone midnight.
7 A. Mm.
8 Q. So of course you can be wrong by times, but on the CCTV
9 he doesn't open the door until minutes before they are
10 due to leave, which wasn't your recollection, was it?
11 A. No. So there was a lapse in my memory again.
12 Q. Another lapse in your memory. What I want to suggest
13 that Dodi was doing was merely opening the door and
14 saying "We are about to leave" because that's the next
15 thing that happens.
16 A. No, that's not the case, sir. We had a conversation --
17 we both got up and had a conversation with Dodi.
18 Q. What you then say is, at the earlier time, that he
19 opened the door to ask you how many paparazzi.
20 "I told him, after checking, that there were at
21 least 30 or so ...
22 "Mr Dodi told me that we would be leaving the hotel
23 in the next few minutes using the plan he'd devised,
24 which consisted of using another Mercedes and another
25 chauffeur. I thought he was talking about Francois, but

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1 if the paparazzi saw him move, they would have realised
2 what was going on. Mr Dodi told me that it was
3 Henri Paul.
4 "As I did not know Henri Paul prior to that day, it
5 did not come as any surprise ..."
6 Because at this stage, of course, you realised he
7 was second in charge of security, did you?
8 A. Yes.
9 Q. "Mr Dodi explained the plan, which consisted of leaving
10 the hotel via the rear and making the paparazzi think
11 they would be leaving from the front. It was arranged
12 they would go straight back to the apartment off the
13 Champs Elysees.
14 "It was perfectly normal for Trevor to accompany the
15 couple as he was Mr Dodi's personal bodyguard."
16 A. Yes, sir.
17 Q. Then you see these following paragraphs and then I have
18 a number of questions:
19 "We pointed out to Mr Dodi that it was not sensible
20 just to take one bodyguard, but he said in response that
21 the car was too small. What is more, his plan consisted
22 of making the paparazzi think that we would be leaving
23 from the front by sending me to signal to the usual two
24 chauffeurs, who, incidentally, were still parked in
25 front of the Ritz, Philippe in the Mercedes and Francois

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1 in the Range Rover, to get ready. Getting one of them
2 to leave would have attracted the attention of the
3 paparazzi. Mr Dodi wanted to make a discreet departure,
4 as we were sure that the paparazzi would approach the
5 Princess and her companion again as they had done during
6 the course of the day. At that moment they were
7 particularly thick on the ground, and then there were
8 bystanders joining them as well.
9 "In contrast to Mr Dodi's obvious anger ..."
10 You deal with laughing and joking and so on.
11 Right, a number of questions. You have already
12 conceded that the time is an error, the fact that it's
13 Dodi and not Henri Paul, at that hour, if that's
14 a possible time, giving the details, but there is a bit
15 more. One point has already been made to you. There is
16 no suggestion in this plan that he didn't want
17 a bodyguard with him, is there?
18 A. When we originally heard about the plan from Henri Paul,
19 it was going to be that there was no BGs involved at
20 all.
21 Q. Or are you trying to say that it was Dodi saying there
22 should only be one? This morning you said --
23 A. No, no, it was -- Trevor negotiated and we reached
24 a compromise with Mr Dodi.
25 Q. With Henri Paul in the sense that Henri Paul tells you

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1 and then you negotiate with Dodi?
2 A. Yes.
3 Q. You see, this morning you couldn't really recall why
4 this account doesn't have any mention of, as it were,
5 Dodi saying there would only in fact be one; all right?
6 A. Yes.
7 Q. Because, of course, in the statement we have just seen
8 in 2005, the suggestion that is being made is, of
9 course, by Dodi that they would leave without
10 a bodyguard from the rear. That's what you are saying
11 in 2005. Now, which is it?
12 A. Well, I deliberately didn't go through any of my
13 previous statements because I wanted to give the memory
14 as I had it in 2005.
15 Q. Which is it, that Dodi told you "We don't want to go
16 with a bodyguard" or Henri Paul told you and you
17 negotiated?
18 A. No, Henri Paul told us the plan originally. We
19 remonstrated with Dodi about the plan and then we
20 reached a compromise with Dodi to take one BG.
21 Q. That you are saying having seen the CCTV?
22 A. Yes, sir.
23 Q. Right. But there is something else missing in this
24 account that you give originally, isn't there?
25 Something else. I have been through it again and I am

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1 sorry to take time to do it because I do not want you to
2 feel caught out, trapped, taken short or whatever.
3 There is a key feature missing from this first version
4 that came, you said, from Dodi in 1997. What's missing?
5 A. I don't know.
6 Q. What's the key point that meant you didn't go and get
7 clearance, according to you, and as the learned Coroner
8 is observing, you would not need to go if you had been
9 told that it has been cleared?
10 A. When Dodi mentioned his father's name, that was -- for
11 us it was a done deal.
12 Q. Absolutely. Very clear in your memory, that, is it?
13 A. Yes.
14 Q. Where is it in the statement?
15 A. I don't think it is in the statement.
16 Q. No. It's not in there, is it? The key element that you
17 had got, as it were, from Dodi that his father,
18 Mr Mohamed or however -- what did he call him?
19 A. "MF".
20 Q. Those were his exact words --
21 A. Yes, sir.
22 Q. Where is that exact memory and those exact words in your
23 very first version?
24 A. Well, maybe I didn't recall it at the time.
25 Q. But I thought you said earlier today that you do recall

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1 all the central key points.
2 A. This statement was given only a couple of days after the
3 accident.
4 Q. And in it you have already said today that because it's
5 given, so I just remind you, on 2nd September, it's
6 likely to have the freshest and clearest memory, isn't
7 it?
8 A. No, as you said earlier on, there has been so much
9 information given to me, now I can give a fuller account
10 of what happened.
11 Q. No, no, we only want what actually happened, not
12 a fuller account on the basis of what you have read,
13 what you have seen or even necessarily the CCTV. We
14 just want it from you.
15 A. That's why I thought we were here, so that we can use
16 every asset available to us so that we can get to the
17 truth of the matter.
18 Q. The truth is not as you first put it to the French
19 judge; agreed?
20 A. No, the main bones of everything have always been the
21 truth, as I have always said.
22 Q. The main bones that Henri Paul spelt the plan out, that
23 it involved saying to you "Don't bother to get clearance
24 because MAF has done it" just isn't there, is it?
25 A. No, but that's what happened. I can only tell you as

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1 I can see it today, as I can see the truth, and I have
2 always said that Dodi was -- used the words, "It's okay,
3 it's been okayed by MF, it's been okayed by my father",
4 and at that time any negotiation with him was closed.
5 Q. Or was it Henri Paul who said that?
6 A. No, that's what Dodi said.
7 Q. You are quite sure --
8 A. Absolutely.
9 Q. -- that it wasn't Henri Paul who said "got clearance
10 from MF"?
11 A. It was Dodi, when we were speaking to Dodi at about
12 midnight.
13 Q. So the only reason it is said in the first statement is
14 you have just forgotten one of the key points?
15 A. I just probably missed out because I was tired or I was
16 just in awe of what was going on. It was only a couple
17 of days after the accident.
18 Q. Right. So there is a version in 1997, there is another
19 version in 2005, but in between, of course, you
20 participated in a book, didn't you?
21 A. Yes.
22 Q. Right, and you gave several interviews for that book?
23 A. Yes.
24 Q. Have you read the book recently?
25 A. Not recently, no.

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1 Q. Do you remember what is in the book about this part of
2 it all?
3 A. No.
4 Q. Because I am going to suggest that what is in the book
5 must have come from you, because Mr Rees, who has given
6 evidence recently, doesn't have a memory of parts of
7 what went on, and certainly before he saw the CCTV,
8 interestingly, he thought it was all Dodi, but now
9 accepts it was Henri Paul, but he has no memory of the
10 Henri Paul -- do you follow? That's what he said.
11 A. Yes.
12 Q. So if there was a memory when the book was published
13 in 2000, I am suggesting it has to come from you unless
14 there is some other source. Do you follow?
15 A. Yes.
16 Q. Right. Could we have on screen, please, page 82?
17 That's in the softback. I don't know whether it's the
18 same in the hardback. Sir, do you have a copy of this?
19 LORD JUSTICE SCOTT BAKER: I have, but I do not have it in
20 court.
21 MR MANSFIELD: There is an unmarked copy here. (Handed)
22 LORD JUSTICE SCOTT BAKER: Thank you.
23 MR MANSFIELD: We are putting it on screen because I want to
24 take you through this version. It starts on page 82
25 with a time:

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1 "At 11.07 ..."
2 Could we have that up on screen? Would you like the
3 book or are you happy with the screen?
4 A. No, it's fine.
5 Q. Right:
6 "At 11.07 ..."
7 In fact it's out by about a minute, but that is
8 pretty precise. Where did that time come from?
9 A. I don't know, sir.
10 Q. Was it from you?
11 A. No.
12 Q. Had you, at that stage, had access to any information
13 about the CCTV?
14 A. The CCTV? No.
15 Q. Yes, about timings.
16 A. No.
17 Q. French dossier?
18 A. No.
19 Q. " ... both bodyguards arrived upstairs and sat outside
20 the Imperial Suite, waiting for word. The two cars were
21 out front, with Jean-Francois Musa, a director of Etoile
22 Limousine and Philippe Dourneau awaiting orders. Trevor
23 and Kes did not know what was happening next. Nor did
24 they know that, while they had been eating, Dodi had
25 made a phone call that would change their lives."

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1 Where did that come from?
2 A. No idea.
3 Q. Did you see this before it went out?
4 A. No.
5 Q. You see, you didn't know that he had made a phone call
6 and neither did Rees, let alone what's contained in the
7 next bit.
8 "He had called the hotel's night manager,
9 Thierry Rocher, to report the paparazzi mess at the door
10 and, hearing that Henri Paul had returned, asked Rocher
11 to tell Paul that they would need a third car for him
12 and the Princess at the back of the hotel."
13 Do you know any of that?
14 A. No.
15 Q. So that doesn't come from you and it doesn't come from
16 Rees.
17 A. No.
18 Q. As I will have to go through with you slightly later,
19 Thierry Rocher had been told something at a much earlier
20 stage, but it wasn't a phone call. Do you follow?
21 I will come back to it:
22 "The two cars they had used that day would stay at
23 the front, in the Place Vendome, as a diversion.
24 "As Trevor and Kes waited outside the suite,
25 Henri Paul came by several times, up and down the

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1 stairs, and seemed very busy chatting with hotel staff.
2 Photographers report that he was agitated and sociable
3 to an unusual degree as he moved around the entrances.
4 He had seemed a bit of a showman the few times Trevor
5 had seen him; it was nothing new.
6 "20 minutes before midnight ..."
7 Where did that time come from?
8 A. I don't know, sir.
9 Q. Not from you?
10 A. I never wrote the book.
11 Q. Did you give an interview about this at all?
12 A. I gave a number of interviews to the --
13 Q. Did you -- because you have agreed, and I put it to you,
14 Mr Rees can't have remembered what's coming up now
15 because until he gave evidence, he had no recollection
16 of Henri Paul saying anything.
17 Now:
18 "20 minutes before midnight, Henri Paul turned up at
19 the door of the suite, still stinking of cigars, Kes
20 noted, and told them, 'The plan's been changed. We'll
21 be leaving from the back of the hotel, with just one
22 car. He wants me to drive'."
23 Is that what you told the authors?
24 A. I don't recall.
25 Q. "'The two other cars will leave from the front, to

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1 divert the paparazzi. Dodi doesn't want a bodyguard'."
2 So that comes from Henri Paul at this stage; is that
3 what you told the author?
4 A. I don't know.
5 Q. Or writer?
6 A. I don't know.
7 Q. You don't know.
8 "They would be leaving in half an hour. This was
9 a terrible plan. Henri Paul was a security man, not
10 a chauffeur."
11 That's the point you are making there. Well, at
12 least that's the point the book is making. Did you make
13 that point?
14 A. Not that I recall, no.
15 Q. "They needed a two-car convoy and a bodyguard. Trevor
16 shot back to Henri Paul, 'No fucking chance is he
17 leaving without a bodyguard, no way in a million years
18 it's going to be without me. I'll be coming with you if
19 we go with this'."
20 Did you say that?
21 A. No.
22 Q. You see, it's not a version that accords with what you
23 are saying now.
24 A. We had conversations with Henri Paul, but I am not --
25 I can't remember what we said to him.

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1 Q. Can't you? Well, if you can't remember what you said to
2 him, how is it you are now able to say today what you
3 said to him?
4 A. Because of the assistance with the DVD.
5 Q. But the DVD doesn't tell you what was said, does it?
6 A. No, but it jogs the memory to what happened on certain
7 occasions.
8 Q. I am so sorry, it jogs the memory so that your previous
9 accounts, at least to the French authorities and then
10 the British authorities, that the plan came from Dodi is
11 wrong. In the first place it came from Henri Paul, you
12 are now saying. But now you are saying you can't
13 remember what was said to Henri Paul, or can you?
14 A. At what time?
15 Q. Well, any time.
16 A. Well, we -- when we spoke to Henri Paul, we said, "This
17 is a non-starter" and all Henri Paul said was, "Well,
18 it's from Dodi".
19 Q. You see, I asked you very carefully, minutes ago,
20 whether, in fact, the question of going without
21 a bodyguard was raised by Henri Paul and you negotiated
22 it and so forth. Do you follow?
23 A. That is right, yes.
24 Q. Well, it was raised by Henri Paul, no bodyguard, was it?
25 A. Not to me. But that's Trevor talking, not me.

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1 Q. But you are there, are you?
2 A. I don't know, but that's Trevor talking, not me. You
3 would have to ask Trevor.
4 Q. I see.
5 "The bodyguards announced that they would have to
6 report this to London."
7 That's what you thought, is that right, what it says
8 there?
9 A. Well I never made any phone calls to London.
10 Q. No, I know you didn't. What it says is that the
11 bodyguards announced that they would have to report this
12 to London; do you see that?
13 A. Yes.
14 Q. Did you?
15 A. Did I?
16 Q. First of all, did you tell the writer that that was
17 announced?
18 A. I never told that to the writer, no.
19 Q. You didn't. You see, I am just going to pause for
20 a moment because when you came to make the statement to
21 the police here in 2005, you were asked about the book,
22 weren't you?
23 A. Yes, sir.
24 Q. You said:
25 "There are some inaccuracies and some things are

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1 taken out of context, but on the whole the book is
2 fairly accurate."
3 A. Fairly accurate, yes.
4 Q. So far this version in here that we have been through
5 doesn't really accord with your recollection, does it?
6 A. Some of it is -- as I have said, there are inaccuracies.
7 Q. This is quite important, this part of it, because of the
8 question of getting clearance; do you follow? It is
9 claimed in here, a book with which you co-operated, that
10 "The bodyguards announced that they would have to report
11 this to London, only the second time in the trip they'd
12 felt ops should be told about a bad plan of Dodi's".
13 Right?
14 A. (Witness nods)
15 Q. Now, the truth: did you announce it or not?
16 A. I don't recall announcing the plan -- the -- that to
17 Dodi -- sorry, to Henri Paul, no.
18 Q. Because if in fact all of this is true, that Henri Paul
19 is saying it has been cleared, that is the obvious thing
20 you would have to do, isn't it, report it to London?
21 A. I don't see why, no.
22 Q. Don't you? Right, we will just go on. It's the next
23 part particularly. You see I have asked you about this
24 very carefully. You have so far said that the okaying
25 came via Dodi saying his father had okayed it.

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1 A. That's correct, yes.
2 Q. Just look at what it says here:
3 "But Henri Paul confirmed. 'It has been okayed by
4 Mr Mohamed'. Kes is sure of this, the phrase
5 'Mr Mohamed' standing out from the ubiquitous 'the boss'
6 of the lads".
7 A. That's right. Henri Paul uses the words "Mr Mohamed";
8 Dodi used the words, "It's okay by MF, it's okay by my
9 father".
10 Q. I asked you very carefully where this had come from.
11 You said Dodi. Here -- is this what you told the
12 writer, that in fact it's coming from Henri Paul?
13 A. I think what I have mistaken there is when he was
14 talking to us about the plan initially. Initially when
15 we said, "This is a crap plan", I assume he would have
16 said, "It's been okayed by Mr Mohamed". I don't recall
17 him saying that, but if I said that there, then that's
18 what I would have remembered at that time.
19 Q. You see, you do now follow, don't you, that these
20 versions that you are giving of what happened are
21 different, aren't they?
22 A. They are certainly different, but it's still the truth.
23 Q. Still different on key points about --
24 A. It's still the truth.
25 Q. Which is the truth? Which of these versions is the

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1 truth?
2 A. The wording is slightly different on a number of them,
3 I agree, but the truth of the matter is that once the
4 boss's name had been mentioned by Dodi, it closed the
5 door on any possible sort of argument to the plan.
6 Q. I would like to go back, if I may -- well, I will
7 continue with the rest of the book on page 83:
8 "He had heard the second in command of security
9 at the Ritz say this plan had been okayed by Fayed. But
10 he knew that employees often took Fayed's name in vain,
11 since there was no way to check without causing
12 offence -- or worse. And the plan was still a hopeless
13 one."
14 Then at the bottom of that page you deal with,
15 minutes later, Dodi popping his head out. Do you see?
16 A. Yes, it says that he popped his head out and confirmed
17 it all, and that's when we had the conversation with
18 Dodi.
19 Q. That is a fairly full description in the book of
20 Henri Paul explaining the plan and saying it's been
21 okayed. Now we go back to page 9 of your statement made
22 to the British police. Could we have that back up on
23 screen [INQ0007113 - read out in court]? May we have the paragraph now:
24 "When we were waiting outside the suite ..."
25 Do you see that?

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1 A. Yes.
2 Q. "When we were waiting outside the suite, Henri Paul did
3 come up just before we left. Again he wasn't drunk.
4 There was no slurring of his words and when he walked up
5 the corridor he wasn't falling around. He was quite
6 tactile -- he would touch your arm when he was talking
7 to you -- and he stood very close to me. I don't smoke
8 and neither does Trevor and I was close enough to smell
9 cigars on him but not drink. He was off to one side and
10 I don't remember him having any input into the
11 arrangements."
12 A. Yes.
13 Q. That's a very odd memory, isn't it?
14 A. What I meant by that was I don't remember him speaking
15 to Dodi about it. He received his instructions from
16 Dodi when he wasn't with us.
17 Q. You see, please don't make extraordinary, if I may put
18 it to you, assumptions about anything. Do you say that
19 Henri Paul spoke to Dodi about all this?
20 A. Well, I assume he was taking it by a phone call.
21 Q. Do you? Why do you assume that?
22 A. Because he wasn't with us. As I say there, I don't
23 remember him making any input into the arrangements.
24 Q. You see, the real point about this observation is not
25 just that you don't mention Henri Paul; you do mention

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1 Henri Paul, but in fact you mention him by saying he
2 doesn't seem to have any input into the arrangements in
3 the sense of telling you anything or whatever; do you
4 see?
5 A. That's just the words that I used on the day.
6 Q. What do these words mean, these words on the day in
7 2005?
8 A. It means he didn't speak to Dodi in front of us. There
9 was no input in front of us.
10 Q. Well, that would have been easier to put --
11 A. Those are the words I used on the day. I don't know why
12 I used those words, but --
13 Q. I suggest it's because Henri Paul is floating in and out
14 over the years, and finally, when you see the CCTV, you
15 have the luxury overnight -- the words you have used --
16 of pinning your latest account -- because you have to
17 now; there is no way round the CCTV -- to Henri Paul.
18 A. No, that's not the case.
19 Q. Because that's the process, isn't it?
20 A. No, that's not the case at all. If anything the CCTV
21 has been very helpful.
22 Q. Yes, I suggest it certainly has, and I want to deal with
23 you, if I may, in relation to the order of events and
24 see if you can help a little bit.
25 A. Okay.

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1 Q. The easiest way of doing this is in fact to have the
2 timeline in front of you. Do you have it?
3 A. Sure.
4 Q. So we can put the statements to one side for a moment.
5 I will try and do it without necessarily having to show
6 sequences all over again because you saw it and the jury
7 has seen it already.
8 I will do it chronologically and ask you questions
9 as we go through. Could you turn to page 2 of the
10 timeline? The jury have it in their divider numbered 3
11 at item number 6. I am, for the moment, going to
12 concentrate on the period of the evening when Henri Paul
13 and you are back at the Ritz. Of course, Princess Diana
14 and so forth are there.
15 There comes a point, and you will see it there --
16 I will use the times on the left-hand side because it's
17 easier to follow -- at 22.03.16 where you return to the
18 stairs, they having entered the suite. Right?
19 A. (Witness nods)
20 Q. If I go too fast, please tell me. At 23.03.52 we are
21 back downstairs and you go into the bar at that point.
22 I am just going to ask you this: you knew by this stage,
23 did you not, when you go to the bar, having been told to
24 have a meal, that in fact there was no-one outside the
25 suite; you knew that by then, didn't you?

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1 A. Yes, sir.
2 Q. Were you happy about that situation?
3 A. Well, we had --Ritz security were in the place and the
4 couple were in a locked room, so we thought that was
5 adequate.
6 Q. Yes, of course. But were you happy about it?
7 A. No, I would have been happier if we had had more members
8 of the team on the ground, but we had to deal with what
9 we had.
10 Q. There were plenty of people in the Ritz. The question
11 I want to put to you is: did you ever approach the night
12 security, Mr Rocher, and say, "Look, we are both being
13 given permission to have something to eat in the bar or
14 something to eat, I think someone should be outside the
15 suite, just one person, while we are having it"? Did
16 you do that?
17 A. We spoke to -- well, I don't know who we spoke to, I am
18 afraid I don't know the names, but we asked the Ritz
19 staff to keep an eye on the corridor for us, yes.
20 Q. Did you ask Mr Rocher -- because he has given
21 evidence -- did you ask him to ensure that there was
22 someone sitting outside the suite?
23 A. I don't know who Mr Rocher is.
24 Q. All right. Did you ask any member of the Ritz staff,
25 senior, junior or whatever, "I think there should be

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1 someone up there"?
2 A. The words we used were "Keep an eye on the suite for
3 us".
4 Q. Who did you ask?
5 A. I don't know.
6 Q. Or did you really not think about it?
7 A. No, we asked a member of the Ritz staff.
8 Q. Right. When you went over to Repossi's in the
9 afternoon, did you do the same?
10 A. No. That was already being taken care of by the Ritz
11 staff.
12 Q. Did you ask, in the afternoon, while you popped across
13 to Repossi's, the Ritz staff whether a member of staff
14 could sit outside the suite while you were out there
15 since Princess Diana was in there on her own?
16 A. We didn't ask because they were already being covered by
17 Ritz staff.
18 Q. So you didn't ask?
19 A. No.
20 Q. And you know there wasn't anybody sitting outside?
21 A. I wasn't aware of that because I was across the road.
22 Q. No, no, but when you came back?
23 A. I don't recall.
24 Q. Just passing on, you go down to the bar at this time,
25 and Henri Paul, as it says, having been called back to

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1 the hotel, enters the foyer and so forth. At 22.09, one
2 and a half minutes after Henri Paul enters the bar,
3 Rees-Jones leaves, or Mr Rees leaves, and he is outside.
4 There are a couple of questions. First of all, can you
5 help with what he could have been talking about for
6 10 minutes on his mobile?
7 A. No idea.
8 Q. Did he tell you, "I have got a very long call to make to
9 the ops"?
10 A. I don't recall.
11 Q. Because it wouldn't need 10 minutes, would it, just to
12 explain that you are at the Ritz?
13 A. I don't know, but the phone records will show who he was
14 talking to.
15 Q. We will come to phone records. We don't have his, but
16 we have yours.
17 A. Yes.
18 Q. In addition to that, what then appears to happen is that
19 Henri Paul is with you, isn't he?
20 A. Yes.
21 Q. It's approximately 15 minutes that he is with you,
22 22.09, as we see there. I am using the left-hand side.
23 A. Yes.
24 Q. You have not got it on this, I don't think. Let me just
25 check. No. The time when he, as it were, leaves the

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1 bar is 22.25, so approximately -- and you can write it
2 in on that sheet if you want, on the third sheet --
3 22.25, Henri Paul leaves the bar. So he is with you for
4 about 15 minutes. You knew he was second in-chief, you
5 say, by then, for security?
6 A. Yes.
7 Q. Now, did you say to him, "Look, I am a little unhappy
8 about what's going on because I really don't know what's
9 going on here"? Did you say that?
10 A. I believe we mentioned in small talk that we weren't
11 getting enough information from the principals, yes.
12 Q. You didn't even know whether they were going to leave
13 the hotel?
14 A. No, we hadn't heard anything like that.
15 Q. So you were having a discussion with Henri Paul at that
16 stage?
17 A. It was small talk because my attention was fixed towards
18 the entrance.
19 Q. Did he say where he had been?
20 A. No.
21 Q. Because the position is -- you may now be aware --
22 between 7, approximately, and 10 that evening, his
23 movements are very difficult to track as to where he
24 was.
25 A. Yes.

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1 Q. He didn't give you any clue about him having come back
2 to the hotel?
3 A. Not that I recall, no.
4 Q. In fact you assumed he had been on duty all the time?
5 A. Yes.
6 Q. Right. We will just turn over the page because there
7 are one or two other matters I just want to insert so
8 you have the picture.
9 Now, at about 22.30 -- again it's not on here but it
10 will be relevant to the third page -- there is no
11 issue -- in fact it's 22.25, the time I have already
12 mentioned, from about that time he is not in the bar,
13 Rees-Jones has re-entered, but Henri Paul leaves and he
14 speaks to the night security manager called Rocher, all
15 right? Can you bear in mind --
16 A. Sure, yes.
17 Q. We are now halfway down the third page. He, Henri Paul,
18 leaves, you don't know very much about what's going on,
19 you say, and Henri Paul hasn't said much to you; all
20 right?
21 A. No.
22 Q. We know this because Mr Rocher, the night manager -- and
23 I will not show you the CCTV -- meets Henri Paul in the
24 hotel, once he has left the bar, and tells him that
25 a third car will be required from the rear of the hotel;

145

1 all right?
2 A. (Witness nods).
3 Q. So nothing about a decoy plan and nothing about who is
4 going to drive the car; do you follow?
5 A. Yes.
6 Q. We know, in fact, so that you have the picture about
7 when he comes back to the bar, that Henri Paul having
8 had that information -- and so it's clear, there is no
9 occasion henceforward that Henri Paul, having got that
10 information, goes back up to the suite to talk to Dodi.
11 I think we can deal with that compendiously. Do you
12 agree he never did?
13 A. No.
14 Q. No. So he in fact goes outside, that's Henri Paul --
15 A. Yes.
16 Q. -- you are still in the bar; Rees-Jones is back. He
17 goes outside, into Place Vendome, what -- the jury can
18 follow it on their other master schedule --
19 A. Yes.
20 Q. -- becomes what's called the "first visit to
21 Place Vendome", all right? He is out there for
22 something like nine minutes, eight of which are out of
23 view. Now did he tell you what he was going to do?
24 A. No.
25 Q. Right. He comes, as it were, back into the bar at --

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1 and again I am afraid not all the times are on here, but
2 it's so you can slot them in -- he is back in the bar by
3 about 22.43 -- 22.11 at night, if it's easier to follow,
4 all right? He is back in the bar. So he is been out of
5 the bar all that time.
6 A. Yes.
7 Q. He comes back into the bar and he is then in the bar
8 with you until eight minutes past 11, approximately.
9 You will see that is written in there halfway through.
10 Do you see that entry?
11 A. Yes.
12 Q. In that period of time, he is back in -- am I going too
13 fast?
14 A. No.
15 Q. -- he is back in at 22.11, so it's roughly half an hour.
16 In that half an hour, does he say anything to you about
17 the need for a third car, let alone that he is going to
18 drive, at the back?
19 A. Not that I recall, no.
20 Q. Because your evidence today is you didn't know about
21 this until later.
22 A. I don't know what time he told us, but I have recognised
23 from the DVD, we were in the foyer and that's where --
24 I remember Trevor and I were together and that's when he
25 was telling us. As I said earlier, there were two

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1 occasions when he could have been telling us. I don't
2 recognise which one it was.
3 Q. I appreciate that's what you now say. So we can, as it
4 were, shoot forward a little bit; namely, you are
5 leaving the bar at eight minutes past, approximately,
6 11, to go back upstairs, and of course by the time you
7 get back up there, once again it's perfectly clear that
8 nobody has been sitting outside the suite.
9 A. That's correct.
10 Q. You are then outside the suite and Henri Paul comes for
11 his first occasion, which is on page 4 of this timeline
12 at the top -- this is the first occasion. I think you
13 are saying this is one occasion when he could have told
14 you about this plan.
15 A. It's one of the occasions, yes.
16 Q. I am going to put to you that up until the time that
17 he -- if this is one possible occasion, and
18 interestingly quarter past 11 was precisely the time
19 that you put in your very first statement; do you
20 recall? We have been through it today.
21 A. Yes.
22 Q. So if this was the time, firstly Henri Paul has not
23 spoken to Dodi by going to the suite -- we know that.
24 A. (Witness nods)
25 Q. -- and there is no evidence that he has called in any

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1 other way, in other words used an internal telephone,
2 because his movements are covered pretty well. All
3 right?
4 A. Yes.
5 Q. So what he is telling you, if it's at 23.15, about the
6 detail -- for example, he is going to do the driving,
7 there is going to be decoy out the front and it's been
8 authorised by MAF -- I suggest at that point it can't
9 have come from Dodi; do you follow?
10 A. I don't know where it came from.
11 Q. No. You see, I know it may be convenient to assume all
12 sorts of things, but when we get down to tracing the
13 CCTV, you see the problem here. Of course, I appreciate
14 you are saying there could be another occasion, and
15 that's the occasion that comes further down on page 4;
16 the occasion where he stands in front of them. Do you
17 see that? Do you think it could be that occasion?
18 A. Possibly.
19 Q. Possibly that occasion, all right. That's 23.28.
20 Possibly that one. He is called away to speak on the
21 telephone; do you see that? It's at 23.29, half past 11
22 now.
23 A. Yes.
24 Q. Do you know who he spoke to at that point? It's not
25 written in there, but --

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1 A. No.
2 Q. -- we have evidence about who he spoke to.
3 A. No.
4 Q. He spoke to Mr Roulet, who is more senior to Mr Rocher,
5 who had telephoned in, asking to speak to him.
6 Did Henri Paul ever tell you that he had spoken to
7 Mr Roulet?
8 A. Not that I recall, no.
9 Q. Mr Roulet, when asked about this -- because I asked him
10 the question:
11 "Did Henri Paul tell you [Mr Roulet] about this
12 third car plan and that he [Henri Paul] was going to do
13 the driving when in fact he was not a chauffeur?"
14 Mr Roulet said that no, he didn't and he should
15 have. So you didn't know anything about that phone call
16 that he took downstairs?
17 A. No.
18 Q. He comes back up, as we will see. Next page, page 5,
19 Henri Paul returns to the Imperial Suite and there is
20 a longer conversation with Henri Paul, isn't there?
21 A. Yes.
22 Q. Let us stand back for a moment and be realistic, now we
23 have seen the CCTV. 99 per cent of all the discussions
24 about the plan were with Henri Paul, weren't they?
25 A. Yes, but the pivotal one where we spoke to Dodi was the

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1 one where it was sealed.
2 Q. Do you agree, looking at the CCTV, that 99 per cent of
3 the discussions were with Henri Paul?
4 A. Most of the discussion was with Henri Paul, yes, that's
5 correct.
6 Q. I will suggest to you that the pivotal thing was what
7 you were choosing to believe from Henri Paul, wasn't it?
8 A. I had no reason not to believe.
9 Q. All right. Do you think now, looking back on this, that
10 the one thing you should have done, since you weren't
11 employed by Henri Paul, was, in fact, just to do a mild
12 check with ops before you start walking any routes? Do
13 you follow?
14 A. With hindsight I should have done a check.
15 Q. Yes, you agree. Thank you. I want to put to you that
16 it doesn't take hindsight for somebody of your
17 experience, which is why I began with your experience,
18 to realise the need for that, does it?
19 A. At the time -- we were making decisions at the time from
20 the information that we were given at the time.
21 Q. I appreciate, but you are trained to work under
22 pressure, aren't you?
23 A. Yes.
24 Q. Especially in the military?
25 A. (Witness nods)

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1 Q. You don't get the luxury or convenience of plenty of
2 time, on the one hand, on the other; you have to take
3 quick decisions and learn to take them so that security
4 comes first?
5 A. That's correct.
6 Q. Right. Now I think you will agree, if we just glance
7 down this page -- I am now on page 5. I hope you are on
8 the same page -- after the discussion which is
9 approximately three minutes long at 23.36 with
10 Henri Paul outside the suite, you then go, may I put it,
11 walk-about; you go to the front, and then in
12 particular -- it's not on this, but you walk -- you have
13 been already reminded -- you do what's called, on the
14 other timeline we have, "Walking the final route".
15 That's what you do, isn't it?
16 A. Yes.
17 Q. Yet you still haven't spoken to Dodi, have you?
18 A. We were waiting until we got an opportunity to speak to
19 Dodi.
20 Q. Oh no. You see, you, at any stage -- if this was being
21 put up by Henri Paul in the way you describe now, the
22 obvious thing, unless your mind wasn't on the job, you
23 just knock on the door, as you claimed in one of the
24 statements, and say, "May I have a quick word with
25 Dodi?" You could have done that, couldn't you?

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1 A. The reason why we didn't do that is we didn't want to
2 force an issue with Dodi until he was agreeing to come
3 out because, you know, we didn't want to embarrass him
4 in front of the Princess.
5 Q. It's a bit late in the day to wait until he comes out,
6 isn't it?
7 A. That's why we were trying to do it late in the day, so
8 that we would get a --
9 Q. Late in the day?
10 A. -- so that we would get a quick decision from him and
11 change the plan.
12 Q. That's not the way it's handled properly, is it? If
13 there is a plan you don't approve of, unless you are
14 just going along with it, you take it up with the
15 principal and not with Henri Paul. You say to
16 Henri Paul, "Never mind Mohamed, I just want to check
17 with Dodi that he is happy with this". It is perfectly
18 straightforward, isn't it?
19 A. We spoke to Dodi when he came out.
20 LORD JUSTICE SCOTT BAKER: Mr Mansfield, we have been round
21 and round and round this and I think the issues are
22 pretty clear.
23 MR MANSFIELD: Whether they are clear to the witness I am
24 not sure. May I just continue with the point because
25 I have not asked this before and it is why I have gone

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1 through the chronology carefully.
2 You never attempted to approach Dodi, did you?
3 A. We approached Dodi as soon as he -- as the opportunity
4 arose and we spoke to Dodi.
5 Q. I will suggest, on the cameras we see, that you had
6 plenty of time when you were just sitting outside the
7 suite, didn't you?
8 A. Yes, but we didn't want to intrude on Dodi when he was
9 having an evening with the Princess --
10 Q. That's your explanation. Page 5, you do the walk-about
11 of the rear, and I have not asked you this before: when
12 you are walking down the back, as we can see on the CCTV
13 with Mr Rocher, did you know who he was?
14 A. No. I thought he was a member of the Ritz security.
15 Q. He is the very man, I suggest to you, that you could
16 have said -- you have not checked with central ops, you
17 haven't checked with Dodi -- do you say to him, "Look,
18 this whole business of walking to the rear is really not
19 very satisfactory"?
20 A. I don't recall what conversation I had with Mr Rocher.
21 Q. So it's not a situation where you recall having any
22 conversation with him about not using the rear?
23 LORD JUSTICE SCOTT BAKER: We are getting to the point,
24 Mr Mansfield, where we ought to have a break.
25 MR MANSFIELD: Certainly. I will break it now.

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1 LORD JUSTICE SCOTT BAKER: I may have misunderstood the
2 position, but in one of your earlier questions this
3 afternoon, you appeared to insinuate that Mr Wingfield
4 should not have been looking at the DVD overnight.
5 MR MANSFIELD: No.
6 LORD JUSTICE SCOTT BAKER: That wasn't the position?
7 MR MANSFIELD: No. I think I made my point earlier that he
8 was quite entitled to look at it. I have never objected
9 to that. On the last occasion we had no idea the
10 witness had seen it, so I am -- that is not an objection
11 I am making.
12 LORD JUSTICE SCOTT BAKER: Because the position was made
13 perfectly clear --
14 MR MANSFIELD: Yes, yes, I have not made any objection.
15 LORD JUSTICE SCOTT BAKER: Quarter of an hour.
16 (3.15 pm)
17 (A short break)
18 (3.30 pm)
19 (Jury present)
20 LORD JUSTICE SCOTT BAKER: Yes, Mr Mansfield.
21 MR MANSFIELD: Thank you.
22 If you turn to the last section that I want to deal
23 with with you, page 6 of the timeline, we can see there,
24 earlier up the page, that you finish, as it were, the
25 walk-through and then, at 23.50, in other words

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1 10 minutes to midnight, do you see it says that you and
2 Rees-Jones ascend the staircase to the Imperial Suite
3 followed by Henri Paul?
4 Question: did you, at that stage, know when anyone
5 was going to leave?
6 A. Not as far as I recall, sir, no.
7 Q. Again -- I put the point throughout -- even up to then,
8 Henri Paul still hasn't spoken to Dodi at the suite; all
9 right? Just going on, 23.50, Imperial Suite, foyer
10 camera. You walk down the corridor from the top of the
11 stairs, in the direction of room 103, before returning
12 to your seat. I will take it up from 23.50.33, as it is
13 in the left-hand corner. Could we just see the
14 section -- this is the only one I want to show you --
15 between there and the door opening and the section we
16 have already seen? It's a slightly longer section.
17 Could we see that section, 23.51? Thank you.
18 (CCTV footage shown)
19 Thank you very much. I am sorry to have asked you
20 to watch that, and the jury and the learned Coroner, but
21 there are some rather obvious points I want to make to
22 you and see what your reaction is to it. That's
23 a substantial length of time, isn't it? Really it's
24 about 10 minutes --
25 A. Mm.

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1 Q. -- having done the walk-through, that you are both
2 sitting there and Henri Paul is with you?
3 A. (Witness nods).
4 Q. First question: what was going on?
5 A. We were waiting for Dodi to come out so that we could --
6 Q. When was he going to come out?
7 A. When he came out.
8 Q. You are really saying that you sat there for 10 minutes
9 not knowing when he was going to come out?
10 A. Yes. A lot of the job involved a lot of sitting around
11 in corridors, and basically you react when the principal
12 sees fit to come out rather than any specific timings.
13 Q. Of course, during this ten-minute interval, I think you
14 agree, no attempt made to liaise with Dodi by you, is
15 there?
16 A. No. We knew that when he eventually came out, we would
17 be able to speak to him.
18 Q. But of course the minutes are ticking by -- if it had
19 been another hour -- it would be far too late to change
20 anything, the later you leave it; do you agree?
21 A. No.
22 Q. I am so sorry. The later you leave it, if you are going
23 to try to change somebody's mind, the more difficult it
24 is because the plans are all in place; do you follow?
25 A. No, I disagree.

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1 Q. Oh, you thought you could change it?
2 A. Mm.
3 Q. Did you tell Henri Paul, "I think I can change this"?
4 A. I don't know what we said to Henri Paul.
5 Q. I would like you to think about it. 10 minutes sitting
6 there, did you say to Henri Paul, "Look, I don't like
7 this, I am not having it, I am going to ask Dodi to
8 change it"? Did you?
9 A. I believe we had said to Henri Paul that we were going
10 to try and change Dodi's mind. I don't know when I said
11 it to him and I don't know what I was saying to him
12 there; I don't know what I was saying to Trevor there.
13 Q. We don't have that in any of your versions. Is that
14 something you have just thought of having sat through
15 10 minutes of inaction?
16 A. No, sir, no.
17 Q. Why have you not mentioned that before?
18 A. I don't know.
19 Q. Right. Moving on to the end of the 10 minutes, of
20 course you don't -- and I think you accept you don't --
21 in that 10 minutes, make any contact with central ops,
22 do you?
23 A. No.
24 Q. So then they do come out. In fact I didn't go through
25 it, but you will see, if you turn over the page to

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1 page 7, the Princess and Dodi come out about six minutes
2 after the short conversation that you had.
3 A. Yes.
4 Q. So they are just on the point of leaving when he pops
5 his head out of the door; do you agree?
6 A. Yes.
7 Q. So he must have said to you, "We are just about to go",
8 mustn't he?
9 A. I assume so, yes.
10 Q. I would like you to think about this in relation to what
11 you say now happened. What did Dodi say when he popped
12 his head out of the door six minutes before he was due
13 to leave?
14 A. Do you mean at midnight on the transcript?
15 Q. Yes. It's the only time you talked to him.
16 A. He said "Everything's set" or something like that, and
17 we said, "Well, no, this is not good".
18 Q. Did he tell you, "We are about to go"?
19 A. I don't recall.
20 Q. Because that's the most obvious thing, isn't it?
21 A. The only words I recall are the ones I have mentioned
22 earlier. Everything else I don't recall. I am not
23 going to make it up.
24 Q. Well I suggest you have come very close to it in your
25 different versions.

159

1 A. No, I disagree.
2 Q. Can you give any explanation for all these different
3 versions?
4 A. Memory lapses.
5 Q. Somebody listening to all this could be forgiven for
6 thinking that perhaps it's worse than that; that you
7 might just be making it up to protect your own back?
8 A. No, that's not the case at all.
9 Q. What you said earlier on -- this was put to you about
10 that short conversation, 28 seconds at midnight,
11 roughly, with Dodi -- my learned friend put to you:
12 "It's rather a lot of information to be, as it were,
13 contained within 28 seconds."
14 Do you remember that question?
15 A. Yes.
16 Q. Do you remember what you said?
17 A. It was a condensed sort of quick conversation that we
18 had with Dodi.
19 Q. This is what you said. These are your words and I will
20 ask you to explain them:
21 "The bare bones of the conversation that we had with
22 Dodi -- perhaps I fleshed them out with information for
23 the French Inquiry in as much as I made a couple of
24 assumptions ..."
25 Do you remember saying that?

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1 A. I may have said "assumptions", yes, but --
2 Q. Did you flesh out a conversation?
3 A. I didn't say anything that was untrue, no.
4 Q. Did you flesh out a conversation?
5 A. I may have done. That's what I said earlier on.
6 Q. We want to, as it were, get to the truth. What have you
7 fleshed out in this conversation that didn't actually
8 take place? In other words there was a conversation but
9 not as full as you are claiming. Now, what is it you
10 fleshed out?
11 A. No, I have put some of the conversation that we had with
12 the Princess and Dodi after they came out of the
13 Imperial Suite with Dodi's -- I have put them both
14 together. It's a memory lapse.
15 Q. What's the couple of assumptions?
16 A. I don't recall.
17 Q. That's what you said this morning.
18 A. I said I may have done.
19 Q. I will read you again what you said:
20 "The bare bones of the conversation that we had with
21 Dodi -- perhaps I fleshed them out with information for
22 the French Inquiry in as much as I made a couple of
23 assumptions ..."
24 A. Trying to illustrate to the French Inquiry what was
25 going on.

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1 Q. Yes, in other words making suggestions about the nature
2 of the conversation when you didn't have a memory of the
3 conversation; correct?
4 A. Some of that is correct, yes.
5 Q. Which bit of it is correct?
6 A. The only bit that I can state categorically of what Dodi
7 said to me is that, as I have said earlier on, it was
8 Mr Fayed who okayed his plan.
9 Q. We have been through it. You have said at different
10 times that it was Henri Paul who said it and you are now
11 saying it is Dodi that said it.
12 That's the only bit of the conversation. So is the
13 jury to understand, therefore, that all the rest of it
14 you really can't remember? The arguments and all the
15 rest of it, just an assumption that you would have
16 argued?
17 A. No, we did force our case with Dodi.
18 Q. Do you remember it?
19 A. Yes.
20 Q. You do?
21 A. (Witness nods).
22 Q. So that's not fleshed out?
23 A. No.
24 Q. So what is fleshed out? What were the assumptions that
25 were going through your mind this morning when faced by

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1 Mr Burnett's question, "rather a lot of information
2 contained within the 28 seconds"?
3 A. I think the only possible explanation is that, with --
4 because this statement was so close to the accident,
5 I had just lumped all the information together and
6 I have put it all together --
7 Q. What's the information you have lumped together that
8 actually wasn't said?
9 A. It was -- for example, our big fear was that we were --
10 the couple were going to be moving on to a different
11 location.
12 Q. Did you know at that time where they were going?
13 A. We asked the Princess and Dodi when they came out and
14 they said "Straight back to the apartments". It was the
15 Princess that said that, not Dodi.
16 Q. Yes, the Princess, when they come out. So your position
17 is: I didn't know when they were going to come out of
18 the suite. When they did come out of the suite, they
19 didn't say they were about to leave -- sorry, when Dodi
20 popped his head out, they didn't say they were about to
21 leave -- and at that point that he stuck his head out of
22 the door, you didn't even know where he was going?
23 A. That's correct.
24 Q. Now, when in fact you are standing, as we see -- and
25 I am not asking for it to be played, but you can follow

163

1 it on the timeline if you turn over the page -- you see
2 at the top in fact they exit the suite itself at 00.06.
3 Do you have that?
4 A. Yes, sir.
5 Q. Top of page 7. They are met by you, and Rees-Jones is
6 at the top of the stairs. Did you know then you were
7 about to leave?
8 A. It was obvious that we were about to leave. They were
9 coming out.
10 Q. The question that then arises: one of you, that is
11 either you or Trevor Rees-Jones, has the obligation to
12 notify central ops that you are leaving; correct?
13 A. Correct.
14 Q. Looking at the phone records, it's certainly not you, is
15 it?
16 A. No. That's because I was with the Princess and Dodi
17 while Trevor walked round to the front, so I assume
18 Trevor made the call.
19 Q. As has been shown to you, we have a summary of what is
20 handwritten in the log, but I want to go beyond that.
21 I want to suggest to you clearly that nobody, neither of
22 you, rang central ops at any stage after they had come
23 out of the suite at about six minutes past midnight to
24 let anyone know they were leaving.
25 A. No, that's not the case. If I was with Dodi and the

164

1 Princess, stood talking to them, then anybody that
2 wasn't directly with them would have been away from us
3 and making a phone call, and because there were only two
4 of us that would have been Trevor.
5 Q. That would have been, ought to have been, Trevor?
6 A. It will have been Trevor. Trevor would have made the
7 call if you check his records.
8 Q. Well, we can't and you know that. We haven't got the
9 records for his phone. We have a log in relation to the
10 central ops, but I am going beyond that, people who were
11 in the central ops. Did you know those people,
12 Mr Quaife and others?
13 A. Yes.
14 Q. They are responsible people?
15 A. Excellent operators.
16 Q. They are not going to say, "Well, they did ring up but
17 we didn't bother to write it down", are they?
18 A. No. They would have made it in the log.
19 Q. Yes. I make it clear to you that there was no call from
20 either of you. You agree you didn't. Did you, at any
21 time, just check with Trevor, "You have told central
22 ops", because you didn't like this plan, "You have
23 told" --
24 A. Yes, it would be standard practice if you were going --
25 to say, "Have you told the other end?" or "Have you told

165

1 ops?", and that is just to remind each other and that's
2 certainly what I would have done.
3 Q. Just going on again from that position -- and I am not
4 following through because obviously you go out the front
5 and they go out the back.
6 A. Yes, sir.
7 Q. -- there comes a time after the crash when you go to
8 meet Mohamed Al Fayed who has come across, has he not?
9 A. Yes, sir.
10 Q. I just want to ask you to deal with one thing that he
11 said almost immediately, which of course may have
12 shocked you, but something he said on arrival when you
13 met him, coming to see his son. Do you remember what he
14 said?
15 A. When the aircraft landed, I was at Le Bourget with the
16 vehicles waiting to pick him up. He debussed from the
17 aircraft with Rock Higgins and Dick Honeybell and he
18 walked across to me. As he was walking across the pan,
19 a chap gave me a phone -- I believe it was
20 Claude Roulet, but I can't be 100 per cent certain --
21 and he said "This is for you". It was a chap on the
22 phone, and he said -- I believe he was from the British
23 Consulate, but, to be quite honest, I wasn't taking any
24 names or anything like that -- and he said, "I am afraid
25 I have got some bad news for you. The Princess of Wales

166

1 is dead". I don't recall the time.
2 Q. No, it's all right.
3 A. Then literally I passed the phone back to Claude --
4 I believe it was Claude Roulet, but as I say, I can't be
5 certain -- the boss came across and he was flanked by
6 the two guys, and I said to him, "I am sorry for your
7 loss, sir", and I kind of put my hand on his shoulder,
8 just trying to -- because you could see that the boss
9 was very rattled, and I was just trying to just give him
10 some comfort, basically, and then I took him to the
11 waiting vehicle, made sure he got into the vehicle.
12 I got into the vehicle in the front seat with the driver
13 and the other two BGs got into the -- sorry, as we were
14 walking across, I then said, "I am afraid I have got
15 some more bad news for you, sir. I am afraid the
16 Princess of Wales is dead". At that time we believed
17 that all four occupants of the car were dead.
18 I got the boss into the vehicle and we set off for
19 either the morgue or the hospital -- I am not quite
20 certain which one we went to first -- and as we were
21 moving off, the boss exploded, making a couple of
22 allegations.
23 Q. In view of what has been said about various things,
24 I want you to just say what it is he said at that very
25 early stage.

167

1 A. He said something like, "I hope the British Government
2 and Prince Philip are happy now", and at first I thought
3 I had misheard him, so I turned round in my belt and
4 said, "Sorry, sir, what was that?", and he said, "I hope
5 the British Government are happy now", and I said, you
6 know -- he said, "I hope the British Government are
7 happy now. They have caused this", and I said, "That's
8 not the case, sir. No-one would have wished this".
9 Then he sort of slumped back in his seat, I turned round
10 and we continued with the journey.
11 Q. I think you mentioned that he also mentioned, in the
12 same breath, the Duke of Edinburgh.
13 A. Yes, sir.
14 Q. So you knew from that stage that in these tragic
15 circumstances that was his reaction and belief at that
16 point?
17 A. No, sir. I think it was -- what I thought at the time
18 was it was just an explosion of grief.
19 Q. Of course. But not just an explosion; it was couched in
20 particular terms?
21 A. You would have to ask Mr Fayed. I believe it was just
22 grief.
23 Q. All right. That's your recollection of what he said.
24 Can I just move forward? In the days that came
25 thereafter, do you agree that you were prepared and came

168

1 back from holiday in Ireland to appear in various
2 programmes, did you not?
3 A. At the boss's request, yes.
4 Q. You were happy to do it, weren't you? You never
5 objected --
6 A. No, I wasn't happy to do it, no. I objected to
7 Paul Handley-Greaves and he got back to me and he just
8 said, "Look, this is from the boss. Can you do it for
9 him? Can you find it in your heart to do it?" Those
10 were his words. And I said, "Okay, I will do it".
11 Q. The context I want to put to you is clear: no-one told
12 you what to say on the programmes, did they?
13 A. No.
14 Q. No. What, as you call him, "the boss" wanted from the
15 beginning was you being prepared to tell whoever wanted
16 to know the truth about your memory of events on the
17 night. That's all he wanted, wasn't it?
18 A. Yes.
19 Q. Thank you. As we move on to a later stage, that is
20 1998 -- you talked about the incident in the tent and
21 all the rest of it -- in fact, just before that, you had
22 had a meeting in Harrods with the person -- I can give
23 you the name if it will help -- who was producing the
24 television programme about which you mentioned today,
25 didn't you?

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1 A. Yes.
2 Q. At the meeting you never indicated, did you, to that
3 producer for that programme, when you first saw him,
4 that you didn't want to participate, did you?
5 A. I wasn't particularly keen, however I was sat there, you
6 know, in the middle of Harrods under pressure to --
7 I felt like I was under pressure to perform for these
8 people and that's the truth of it.
9 Q. There was no-one in the room other than the producer,
10 was there?
11 A. No, but the chap would obviously report back anything
12 I said to the boss.
13 Q. Right. Once again, nobody had said to you what you had
14 to say, let alone anybody saying, "We want you to lie
15 and come up with a particular version"?
16 A. No, because at that time there was a number of
17 conspiracy theories being promoted, that was when I was
18 taking the view that because I didn't agree with the
19 conspiracy theories at all, if I appeared in anything
20 that was supporting that, I would be seen to be
21 supporting it, which I don't support.
22 Q. I understand a reaction you may have. But do you agree
23 that nobody, even at that stage, said that you had to go
24 on this programme and agree with anything, did they?
25 A. No.

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1 Q. Thank you. Therefore -- and I am not suggesting you
2 didn't have a meeting with Mohamed Al Fayed -- he was
3 really upset about the fact that you having performed in
4 September and appeared on television and given your
5 version -- he was upset that you weren't prepared to go
6 and give your version again; that's all.
7 A. That's not the way I saw it.
8 Q. That's not the way you saw it?
9 A. No.
10 Q. Because I think you will agree, will you not, that
11 Mohamed Al Fayed has been deeply affected by the events
12 that happened on that day, as a number of others have?
13 A. Many people have, yes.
14 MR MANSFIELD: Finally this, and, sir, may I do it in this
15 way, as I did with the other witness, although at a
16 slightly later stage.
17 On Mohamed Al Fayed's behalf, I am not pursuing the
18 suggestions that were made in the letter that have
19 already been described. The reasons for not doing that
20 I have already expressed in relation to the earlier
21 witness, and as I have already explained to you, sir,
22 and I do so again to the jury, the beliefs that
23 Mohamed Al Fayed had based on materials that were coming
24 forth is a matter which he will describe himself in the
25 witness box and it will be a matter, at that stage, for

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1 him to, as it were, explain why those beliefs arose at
2 that time. I am not suggesting to this witness that in
3 fact he has been paid to turn against Mohamed Al Fayed.
4 LORD JUSTICE SCOTT BAKER: Mr Keen?
5 MR KEEN: I have no questions for this witness, sir.
6 LORD JUSTICE SCOTT BAKER: Mr Croxford?
7 Questions from MR CROXFORD
8 MR CROXFORD: I want to ask you questions on behalf of
9 the Ritz Hotel. So there is no mystery, just let me
10 tell you the general topic. I am going to ask you
11 a series of questions about the activities of the
12 paparazzi from your arrival in Paris and how they
13 affected your work. I will try and keep away from
14 jargon. I am going to try and avoid calling you a "BG"
15 and so forth.
16 Keeping away from jargon, I would just like to begin
17 by asking you about your working relationship as it
18 happens on this trip with Mr Rees-Jones, but I emphasise
19 "as it happens".
20 You and he, on this trip first to the South of
21 France and then to Paris, were working very much as
22 a team, weren't you?
23 A. Yes, sir.
24 Q. That is something which both your training in the
25 Marines, was it --

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1 A. Yes.
2 Q. -- and then your training and working pattern when
3 working for Mr Al Fayed had dinned into you, wasn't it,
4 work as a team?
5 A. Yes.
6 Q. One of the significant aspects of working as a team was
7 that team members looked out for one another?
8 A. Yes.
9 Q. I don't know whether you call him your "oppo" or "mate"
10 or whatever it was, that sort of language, no doubt, but
11 you and Trevor Rees -- Rees-Jones as he then was --
12 would have regarded one another as oppos and you would
13 hopefully look out for one another?
14 A. That's correct.
15 Q. You would be concerned for one another to know that if
16 support was needed, you knew early on and were able to
17 provide such support?
18 A. Yes, that's correct.
19 Q. Taking it very swiftly, whilst you have been in the
20 South of France, the brigade of paparazzi had been
21 a persistent feature in your life down there in dealing
22 with your principals; is that right?
23 A. Yes.
24 Q. They had been intrusive at almost all times when they
25 were on duty?

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1 A. Yes.
2 Q. And even when you couldn't see them being on duty, you
3 feared that they were there or thereabouts, hiding,
4 ready to take their snaps?
5 A. There was always a possibility.
6 Q. They had been a troublesome presence; is that fair?
7 A. I wouldn't say "troublesome". They were a presence,
8 definitely, but not troublesome.
9 Q. They were a feature of your life with which you had to
10 cope all the time when you were on duty just in case
11 they interfered?
12 A. If we were with the Princess, yes.
13 Q. Once you got to Le Bourget, I want to take this very
14 quickly --
15 A. Sure.
16 Q. -- you told the French police of a description of the
17 journey back from Le Bourget into Central Paris; do you
18 remember that?
19 A. Yes.
20 Q. I want to ask you one or two questions about it. The
21 paparazzi were following you in, I think, two cars in
22 particular and a number of motorcycles?
23 A. Yes.
24 Q. One of those cars, the black Peugeot 205, was
25 particularly prominent, wasn't it?

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1 A. I don't recall a black Peugeot. The only vehicle
2 I recall was either a silver or a white-coloured Shogun.
3 Q. A grey metallic Shogun or Pajero, I think you called it
4 at the time.
5 A. Yes.
6 Q. And the driver of that, I think you suggested, appeared
7 to be driving, just keeping up, but otherwise not
8 getting in the way?
9 A. Yes. He wasn't sort of in our face and trying to get in
10 the bubble. He was just -- sorry, in between the two
11 vehicles. He was just keeping pace, as you put it.
12 Q. If you want to see it, then of course you can. Others
13 in the room have heard this before. Sir, it's in the
14 2nd September statement. I am picking up from page 2.
15 You will be very familiar with it.
16 You said this:
17 "Upon our arrival I noticed a black Peugeot 205 and
18 numerous motorcycles."
19 That would be right?
20 A. If that's what I said at the time, yes.
21 Q. Then you said:
22 "... throughout the entire journey, the paparazzi's
23 vehicles embarked on a series of dangerous manoeuvres in
24 order to get photos. Indeed the 205 that I have
25 mentioned [this is the bit I really want to ask you

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1 about] overtook us very quickly on the right and then
2 very suddenly cut in in front of the Mercedes in which
3 Mr Dodi and the Princess were travelling, braking very
4 hard as it did so."
5 Now I have jogged your memory, do you remember that
6 incident?
7 A. Vaguely.
8 Q. The object being to slow the Mercedes and the
9 Range Rover down and let the paparazzi on the
10 motorcycles take their photographs?
11 A. Yes.
12 Q. As you described it then, putting it better than I did
13 just now, "This manoeuvre enabled the motorcycles
14 following us to get very close to the Mercedes on both
15 sides and to get some pictures".
16 A. Yes.
17 Q. This was right too, wasn't it?
18 "Meanwhile they [that's the motorcycles] were
19 constantly trying to squeeze between the Mercedes and
20 the Range Rover."
21 A. So it appeared at the time.
22 Q. You gestured to them -- I don't think I need ask you to
23 repeat the gesture -- to stop these manoeuvres because
24 you thought they were too dangerous.
25 A. It was nothing obscene, sir. It was more of a ...

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1 Q. "Back off"?
2 A. Yes.
3 Q. As far as you could see, they nodded in acquiescence or
4 agreement, but having nodded, within a very short period
5 of time they simply resumed what I think you, at the
6 time, described as "their shenanigans"; they weren't
7 very reliable in your persuading them to back off?
8 A. No.
9 Q. Taken overall, you said this to the French police and
10 I want to see if this was a good description of your
11 journey:
12 "I can't tell you at what precise speed we were
13 travelling on the journey between Le Bourget and
14 Neuilly, but it felt appropriate and reasonable and we
15 observed the stopping distances between ourselves and
16 other vehicles."
17 A. Yes.
18 Q. "We did not overtake anyone on the autoroute and the
19 Pajero driver, who was following us, was driving in a
20 very relaxed manner, not like someone driving at speed."
21 A. I don't recall very much of that journey so I can't say
22 "yes" or "no", but there was nothing particularly that
23 sticks in my mind about the journey.
24 Q. Nothing out of the ordinary apart from the incidents of
25 the sort I have just described with the paparazzi and

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1 the Peugeot; is that right?
2 A. Yes.
3 Q. Thank you. On that journey, you presumably were keeping
4 in contact with your oppo, Trevor Rees?
5 A. Yes.
6 Q. For that purpose each of you had, I think, a Motorola
7 walkie-talkie -- is that right?
8 A. Yes.
9 Q. -- used essentially when you were in close proximity to
10 one another to communicate privately?
11 A. Yes.
12 Q. If necessary, you had mobile phones with which you could
13 speak to one another?
14 A. That's right.
15 Q. It was important that you and he communicated during the
16 journey because that was part of your routine, first of
17 all?
18 A. That is right, yes.
19 Q. Also because there came a time when the two vehicles
20 separated and each of you needed to know what was
21 expected of the other?
22 A. That's right.
23 Q. So you would have spoken then to discuss it?
24 A. Yes.
25 Q. Presumably, when he got to Villa Windsor, he would have

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1 told you "I am at Villa Windsor"?
2 A. The Motorola wouldn't have had that range, so I believe
3 he would have used his mobile phone.
4 Q. So he would have told you, "Well, we are at Villa
5 Windsor, where are you?", and you presumably, when you
6 got to the apartment at Rue Arsene Houssaye, would have
7 done something similar to him?
8 A. Yes.
9 Q. Keeping in touch with one another?
10 A. Yes.
11 Q. On that journey, using it as an illustration for
12 a moment, you were travelling in the back-up vehicle?
13 A. That's correct.
14 Q. Having a back-up vehicle is part of, first of all, as we
15 have heard, the ordinary incident of the job you were
16 doing at the time in close protection?
17 A. Yes.
18 Q. And it has what might accurately -- perhaps
19 euphemistically -- be described as a very useful
20 tactical role, doesn't it, a back-up vehicle?
21 A. Yeah. Two vehicles is good. Three or four would be
22 better.
23 Q. But particularly in urban areas?
24 A. Yes.
25 Q. You probably haven't heard of this, but Mr Sansum has

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1 told the jury about the use of a back-up vehicle in
2 a narrow street to open the doors and stop a following
3 tail of paparazzi and others getting through.
4 A. Yes.
5 Q. That sort of thing would be a very useful illustration?
6 A. It would be, yes.
7 Q. I think at one stage you went so far as to describe to
8 the Metropolitan Police about having no counter-attack
9 vehicle. Would that be a --
10 A. Yes, that's just a vehicle that -- for example, if you
11 were in a four-car move, your SAP would be your security
12 advance party vehicle. Then you have two vehicles, the
13 principals' vehicle, the back-up car, and either one or
14 two other vehicles, one in the tail and one perhaps on
15 the side, either on a parallel road or driving next to
16 you, which would be used as essentially a blocking
17 vehicle.
18 Q. I need not trouble about that. Let us concentrate on
19 back-up. The absence of a back-up vehicle, particularly
20 in an urban area, made your role as a close protection
21 officer more difficult?
22 A. Yes.
23 Q. And it would have made the role later on -- when
24 Trevor Rees was off without a back-up vehicle, his role
25 more difficult?

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1 A. Yes.
2 Q. And you would have realised that?
3 A. Yes.
4 Q. And you would have been concerned about that inhibition
5 on your oppo?
6 A. Yes.
7 Q. This is right, isn't it, that what you -- I will use the
8 word "suffered" -- suffered when you came out of
9 Le Bourget throughout that first day, a Saturday, in
10 Paris, with the paparazzi, was a continuation of what
11 you had seen in recent weeks, namely intense paparazzi
12 interest in the movements in particular of the Princess?
13 A. Yes.
14 Q. Taking it very swiftly, you have said something about
15 an altercation that took place later on in the day after
16 you had been to Villa Windsor, after you had made the
17 first visit to the Ritz. When you got back to the
18 apartment block at Rue Arsene Houssaye, there was
19 an altercation?
20 A. A small one, yes.
21 Q. I do not want to go into the great detail of it, but so
22 far as you could judge, the paparazzi were very forward
23 in trying to get their pictures?
24 A. They were quite close to the Princess of Wales, which
25 made us quite uncomfortable.

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1 Q. Pressing in?
2 A. Yes.
3 Q. And as Mr Burnett asked you this morning, there were at
4 least two of the paparazzi present then who were very
5 aggressive?
6 A. Yes.
7 Q. I just want to make sure I understood rightly. One of
8 the tactics they were employing, not necessarily the two
9 aggressive, but the paparazzi people, was to spit at
10 you; is that right?
11 A. That's correct.
12 Q. They were doing that at Rue Arsene Houssaye in the hope,
13 you thought, of getting some reaction?
14 A. That's correct.
15 Q. When, later on, the couple came out from the apartment
16 to go on the journey in the evening, once again the
17 paparazzi pressed forward to get their photographs?
18 A. Not as close as they had done in the afternoon because
19 we had been out earlier on and we had spoken to them and
20 calmed the situation down and said, "Look, you are going
21 to get a better picture if you cut us a bit of slack",
22 and they seemed to agree with us, and we didn't have the
23 problems that we had had when they came out.
24 Q. They didn't push right up close, pushing lenses in
25 faces?

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1 A. It's a question of the proximity. It's intrusive and
2 it's literally in people's faces, and that is what we
3 asked -- we just asked them to appreciate the -- you
4 know, to afford the Princess a little bit of, you know,
5 privacy.
6 Q. As you told Mr Mansfield this morning, on that journey,
7 after you had left the apartment, there was quite a bit
8 of press activity, wasn't there?
9 A. When we got to the Ritz, yes.
10 Q. On the journey, there was quite a bit of press activity?
11 A. Not as much as it was on the afternoon's move.
12 A little, but not as much -- nowhere near as much as the
13 afternoon's move.
14 Q. Was this not right, what you told the French magistrate
15 on 2nd September 1997, just two days later? If you want
16 to see it, of course you can. It's page 4. I do not
17 ask for it to be brought up on the screen. The last but
18 one paragraph:
19 "At around 21.30 hours we left the apartment for
20 the Ritz. The paparazzi took some pictures as we left
21 but they were less insistent. On the way we were
22 followed constantly by 15 or so paparazzi."
23 A. That's correct.
24 Q. 15 is quite a --
25 A. Oh, it's nowhere near as many as there were there in the

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1 afternoon, and they did afford us the distances that we
2 had asked, so it was nowhere near as intrusive as it had
3 been.
4 Q. You see, on those narrow streets in Central Paris,
5 15 paparazzi pursuing you must have had some effect.
6 A. Not particularly, no.
7 Q. Mr Dourneau seems to have thought that they were coming
8 from all angles, all over the place; some were
9 recce'ing, travelling in front of the vehicle. Do you
10 remember that?
11 A. No, it was nowhere near as bad as the afternoon's move.
12 Q. Of course, on that occasion, you and Mr Rees-Jones were
13 travelling in the same vehicle, weren't you?
14 A. Yes.
15 Q. And you had to be kept in contact with Mr Dourneau by
16 telephone as to where he was planning to go?
17 A. And we spoke to our driver as well and said, "Where are
18 we going?", and he said, "This looks like the Ritz
19 route". So that's when we informed our superiors that
20 it looks like it, that it looks like they intend
21 the Ritz, rather than -- intend the Ritz.
22 Q. Was this one of the features that, if you had not got
23 used to, you had at least to deal with over this period
24 of lo