Documents disclosed by the Crown Prosecution …...Email Tom Crone and Andy Coulson relaying what...

DOCUMENTS DISCLOSED BY THE CROWN PROSECUTION SERVICE

Email Tom Crone and Andy Coulson, 04/01/07 [22. D18726]

Email Tom Crone and Andy Coulson, 09/01/07 [23. D26464]

Email Tom Crone to Clive Goodman’s lawyer re: reading case papers, 03/11/06 [2. D19068]

Email Tom Crone and Andy Coulson relaying what Rebekah Brooks was told by the Police, 15/09/06 [7. D18737]

Email Tom Crone and Andy Coulson re: Tom Crone seeing defence papers, 03/11/06 [8. D18758]

Email Tom Crone and Andy Coulson re: Tom Crone not to attend Clive Goodman’s legal conference, 22/11/06 [10. D18759]

Email Tom Crone and Andy Coulson containing line “tilt Mulcaire”, 25/11/06 [11. D30636]

Email Tom Crone and Andy Coulson containing comment about Clive Goodman straying off the preferred line, 02/12/06 20. [D18757]

Email Tom Crone and Andy Coulson with draft briefing note ‐ the December 2006 Memo, 30/12/06 [21. D18768]

Colin Myler witness statement and handwritten contemporaneous note

Email Tom Crone and Andy Coulson saying whose names are included in the case papers, 10/11/06

Email Andy Coulson and Tom Crone re: ok for Tom Crone to send the December 2006 memo, 03/01/07

Pages 4‐7 AC Jury bundle regarding the December 2006 memo

2005 Agreement with Nine Consultancy (Glenn Mulcaire) containing an exclusivity clause. Signed for NOTW/NI by Neville Thurlbeck

Expenses form for Rebekah Brooks’ lunch with Clive Goodman

Various agreements for News of the World and Glenn Mulcaire – main contracts signed by Greg Miskiw and one by Neville Thurlbeck.

D\8026 _

Page 1 of 1

6 You replied on 04/01/2007 10:30. Follow up

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From: Coulson, Andy Sent: Wed 03/01/2007 16:16

To: Crone, Tom

Cc:

Subject:

Attachments: 1~1{, 1-1__

Tom - you are OK to send that memo to Les whenever you're ready-

Do we have any news on Clive's probation meeting? I emailed him today to explain that I wouldn't be meeting him but that you were keen to have a chat.

Also one other question on your memo .. you say Mufcaire started working for us in 2000 ... I thought it went back further than that?

Page I of l

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From: Crone, Tom Sent: Tue 09/01/200710:41

To: Coulson, Andy

Cc:

Subject:

Attachments:

Andy,

Clive texted to say he can't make a meet-up today (it was always subject to his confirmation). He also says he'd rather not come very far from his home area cos of " . .trying to spend as much time with daughter as possible". I'll see if I can rearrange something with him.

On the "options" briefing that Les asked for, I'll be knocking somE?tbip.,g_Jo.g~Lhe.c..Jhis_m..orn jog.recommending that, despite the concerns and th1rracKC5renforceability re a confidentiality c1iius~. we should offer a one y ear's money's'~rrce.,;oeiif"":.ffie'agreementstloulctBe·rorin'al17tfi'aW'nl:Jp' oelween the lawyers on each side (I'll get it drafted by Farrers) and the payments should be in tranches ...say quarterly. Even if Les ok's .. .it is, of course quite poss' that M says not enough.

If you have thought of anything else, I'd welcome the input.

Tom

- . -·

of l

Henri Brandman & Co.

From: Crone Tom [[email protected] .Y-i

Page l of 2 ..

Crone, Tom --··-----From: Crone, Tom

Sent: 15 September 2006 10 34

To: Coulson, Andy

Subject: Stictly Privat and confidential.

Andy,

Here's what Rebekah told me about info relayed to her by cops :

1. they are confident they have Clive and GM bang to rights on the Palace intercepts;

2. re GM: the raids on his properties produced numerous voice recordings and verbartim notes of his accesses to voicemails. From these they have a list of 100-110 "victims";

3. the only payment records they found were from News lnt, ie the NoW retainer and other invoices: they said that over the period they looked at (going way back) there seemed to be over £1 M of payments;

4. the recordings and notes demonstrate a pattern of "victims" being focused on for a given period and then being replaced by the next one who becomes flavour of the week/month;

5. they are visiting the bigger victims i.e. where there are lots iof intercepts;

6. their purpose is to insure that when GM comes up in court the full case against him is there for the court to see (rather than just the present palace charges);

7. all they are asking victims is "did you give anyone else permission to access your voicemail?" and if not "do you wish to make a formal complaint";

8. they are confident that they will get, say, 5-10 people who will give them the green light and they can then charge GM in relation to those victims....they are keen that the charges should demonstrate the scale of GM's activities...so they would feature victims from different areas of public life.. .politics, showbizz, etc;

9. In terms of NoW:

a) they suggested that they were not widening the case to include other NoW people but would do so if they got direct evidence..say, NoW journos directly accessing the voicemails (this is what did for Clive),

b) but they have got hold of NoW back numbers to 2004 and are trying to marry CG accesses to specific stories ,

c) In one case - Hugh Grant and Jemimah Khan - they seem to have a phrase from an NoW story which is identical to the tape or note of GM's access,

d) they have no recordings of NoW people speaking to GM or accessing voicemails,

e) they do have GM's phone records which show sequences of contacts with NoW before and after accesses ...obviosly they don't have the content of the calls .,.so this is at

15/09/2006

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Page 2 of 2

) st circumstantiaL

10) they are goiung to contact RW today tio see if she wishes to take it further.

-[ 5/09/2006

15/09/2006 Linklaters _ S204680-00004 20111208_0870004706

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From: Crone, Tom Sent: Fri 03/11/2006 16:11

To: Coulson, Andy

Cc:

Subject: clive

Attachments:

Andy,

After we spoke re Clive I emailed and spoke to Henri, ..... . H., after ringing him, told me Clive would only agree to let us see/have the papers on Tues. I rang Clive and suggested that it was sensible for all if I could read it all properly before Tues. conference (and you could be made aware etc). He was with someone and said he'd call back. ·

He has done so, short while ago, and says he doesn't want to "release" this paperwork to anyone cos it always leaks .. but he is happy for me to come to his house and read it. Pretty adamant about that.

Not good. I then spoke to Henri. . .who is frustrated and embarassed but can't act otherwise than under client's instructions. He and I have agreed that 1'11 get there an hour before Tues conf. so f·can read this stuff prior to the big discussion.

-··-·- ·-·· ·---£1-ive·is-eein§ ·s+milarly-difficl:llt-appai:entJy..o\ler..'.:Kelsey..shouJcLknow.this......b.u.Loatthat''...SY.ndro.me,

You might make him change his mind about us having a set of the papers ....! wouldn't bet on it.

Obviously, her

-- -Lowndes, Simon

From: Crone, Tom Sent: 22 November 2006 10:42 To: Coulson, Andy Subject: dive

Andy,

Henri rang late yest'y to inform that Clive says I shouldn't be at the 3pm conference with kelsey today. Nothing personal, he says, just that he will feel greatly inhibited if I'm there. Suspect that's right, cos he has also instructed Henri to bring along the essay I mentioned to you (which, by the way, is 5 pages,, not three).

·ust rang Clive .... he says he's "devestated" by the fact that the no. of charges .gainst him on the indictment has gone up from 8 to 15 ... and Count 2 charges him

(and Mufcaire) witrh accessing Helen Asprey between Feb and April 2005. Said he . feels he has to draw a "clear distinction" between himself and all of Mulcaire's other

- --activiti-e·s:--He-mt1st- m-ak-e~t-e+ear- tl=l-at-R·e-i~-A.Qt.tbe-gui.d.i.n.g.Jigbt_a.Ltbe NoW behind everything GM did over the years. "If I don't do that, I'm going to prison, its as simple as that."

He's happy for me to get a furr report on the conference afterwards and says he'll give it to me himself. ·

I'm just about to relay this to Henri. ....then will head

Page I of I

lawyer .. From: Crone, Tom Sent Sat 25/11/2006 14:27

To: Coulson, Andy

Cc:

Subject: confidential

Attachments:

The potential problem with the No W/you apologising to specific individuals (the 3 involved in Clive 's charges) is that it leads to the questionmwe!J, ar.fl yap g9i(!g ~o ap9l9gise to all_ (he others., for example

• ~1' • .. : · - •• .. • • • • • • • • • · ~ . ... . r . . . .. ~ ... . -.,· . . .. .. .

, /· {htf .!}~IJ;!~f !il }f{uf~~.!'.f f ~X.fr~ c/:{.a!f!.ef? !ts v4(_?,~lc/ P..,y d9:_vjJ{i:(i/i.......wmch.~oiil~/tif(fi/iifcaire in.to r~~~(ing: Also an apology to ·

the Clive 3 might prompt Clifford or Simon Hughes or the others to say "/ too dema,nd apology from NoW editor''.

I think an apology from Clive on Wedy plays well for him....but the only way we could do it is to link our apology directly to Clive's (if he makes one)....e.g.

Today in court Clive G accepted his guilt and apologised to the victims of ·- -- ·- - the-offences with·whtch he·is charg-ed. - · ·----·- - ·-·- ---·-·- - ·-· ---

As the Editor of the NewS-of- the-Wo.r-ld-1-fa.ke-u.[.ti.mate-r.esp.o.nsibiJ.i.ty_for..__ the actions of my reporters and would therefore like now to add my own sincere apologies to those people.

Clive may see your last line as highlighting the fact that he deliberately flouted your guidelines...and might fear judge would see that and hold it against him.

As the Editor of the News of the World I take ultimate responsibility for the actions of my reporters.

I would therefore like to apologise unreservedly to X for the distress that has been caused by this

case.

The activities carried out by Clive Goodman were wrong and should not have occurred.

Before this case came to light, I put in place guidelines to ensure that these methods were not

employed by any member of the paper's staff. They have been reinforced since.

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see From: Coulson, Andy Sent: Sat 02/12/2006 12:34

To: Crone, Tom

Cc:

Subject: RE:

Attachments:

will henri be present at that interview?

From: Crone, Tom

Sent: 02 December 2006 12:26

To: Coulson, Andy

Subject: RE:

~~~~~f-&~I~~hat..... Henri was with him when he had the introductory chat with the Probation man .... .Pro5a ion man ootlined stuff they'.d be talking about when they have the "2-hour meeting" ... including "what Clive regards himself as being guilty of'...

From: Coulson, Andy Sent: 02 December 2006 12:16 To: Crone, Tom Subject: RE:

what make-s you suspect that?

From: Crone, Tom

Sent: 02 December 2006 12: 15

To: Coulson, Andy

Subject: RE:

e@liy,oop-,~l~Hk~~ it is the same as Wed's statement so I think its probably ok. I plan to get him out fur lunch in the next couple of weeks (with Warren perhaps) .... ..... .I suspect that in his quiet chats with the probation man he'll stray off the preferred line.

From: Coulson, Andy Sent: 02 December 2006 12: 08 To: Crone, Tom Subject:

Tom - your view ...?

Journalist Clive Goodman pleaded guilty this week to intercepting phone calls involving members of the royal family.

News of the World Royal Editor Goodman, 49, will be sentenced at the Old Bailey in the new year,

Private investigator Glenn Mulcaire pleaded guilty to the same charge.

Both men apologised in court of Wednesday.

Mulcaire also admitted separate charges of intercepting the phone calls of five other people.

News of the World editor Andy Coulson also apologised 'unreservedly' to the royals and said that Goodman's actions

were 'entirely wrong.' =..::. ···' ·-· ~ ,,-,.,;,;_;_.~

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ends

..,AYou forwarded this message on 04/01/2007 10:21. .

Attachments can contain viruses that may harm your computer. Attachments may not display correctly.

Page 1 of 1

lawyer ea * From: Crone, Tom Sent: Sat 30/12/2006 15:36

To: Coulson, Andy

Cc:

Subject: c.S.tt~;·priVc:it~}_nd conidentia!_. ~ ~ ·~·. -.... _~

Attachmen~: Q EAS(6SB) ) _J'-< r ~

·,. ·._·'-:. . . . ( (l{ /_·;.

Andy,

I enclose a briefing note on the current Clive situati9n. It ought to go to Les (especially with the emergence of Mulca ire's employment lawyer and the thinly disguised bla8kmail threat) but you obviously need to see it first. I am off from today til.l next Thursday. On Thursday, subject to you and Les, I anticipate talking to and maybe meeting Mulcaire's man to listen to what he has to say.

Sorry to drop this on you during your week's hol. Leave it till Tues if you wish - I had to send it today cos of the days off next week.

Tom

Attachments: new year.doc (43538 Bytes)

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CONFIDENTIAL FormMGll(T)

Page 1 of4URN:Brooks

WITNESS STATEMENT

(CJ Act 1967, s.9; MC Act 1980, ss.5A(3) (a) and 5B; Criminal Procedure Rules 2005, Rule 27.1)

Statement of: MYLER COLIN

Age ifunder 18: (ifover 18 insert 'over 18') Occupation: EDITOR

This statement (consisting of3 page(s) each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully stated anything in it, which I know to be false or do not believe to be true.

Signed: C MYLER Date: 21/12/2011

Tick ifwitness evidence is visually recorded O (supply witness details on rear)

This is my second witness statement and I have been asked to make it further to my meetings

with DS GUEST on 2 September 2011 and 6 December 2011.

I am making this statement about a specific issue.· It has been made without access to any

records due to the fact that I have been denied access to my office reco.rds by News

International . Accordingly, it is true to the best ofmy memory.

I recall a meeting that I had with Neville THURLBECK , the Chief Reporter of the News of the

World ("the Newspaper"), together with Tom CRONE , the Newspaper's Legal Manager. I

believe the meeting took place in the summer of 2009, in or around July 2009. I cannot

remember who initiated or arranged the meeting or the reason given for arranging it, but the

discussion was significant.

I recall that the meeting took place on a Saturday and we met on the Magazine floor. This area

was alongside the legal department offices, which was always empty on a Saturday.

Mr THURLBECK told Mr CRONE and me that some years previously he had hacked into

David BLUNKETT 's voicemail messages. This had taken place when Mr BLUNKETT was the

Home Secretary and allegations were printed by the Newspaper about his personal life. Stories

concerning Mr BLUNKETT were published in 2004, and ultimately he resigned his position as

Signed: C MYLER Signature Witnessed by: C. Spinks

2006/07(1)

CONFIDENTIAL

CONFIDENTIAL

Form MGI 1(1)(CONT)Continuation ofStatement of. MYLER COLIN Page2of4URN: Brooks

Home Secretary. All these events had occurred before my arrival at the Newspaper in January

2007.

Mr THURLBECK added that some time following the hacking of Mr BLUNKETI's phone, he

had attended a meeting with Andy COULSON (Editor of the Newspaper from January 2003 to

January 2007), Neil WALLIS (Executive Editor of the Newspaper from mid 2007 until August

2009, and previously Deputy Editor) and Mr KUTTNER (Managing Editor of the Newspaper

until July 2009). Mr THURLBECK maintained that at that meeting he had told those persons

that he had hacked Mr BLUNKETT's phone. He. said that those present at the meeting told him

to destroy his phone and computer, and that he should work from home. Mr THURLBECK said

this meeting had taken place in Mr COULSON's office. He did not tell us when this alleged

meeting had taken place, although it must have been prior to the end of January 2007 given Mr

COULSON's presence at the meeting. I have no way of knowing whether or not Mr

THURLBECK's allegations are true.

I was shocked and astounded by Mr THURLBECK's remarks, and after the meeting I agreed

with Mr CRONE .that we needed to speak to Rebekah BROOKS about the issue as soon as

possible. In June 2009, it had been announced that Mrs BROOKS was to replace James

MURDOCH as the Chief Executive of News International with effect from September 2009.

However, Mrs BROOKS was already acting as Chief Executive during the. transition period .

before she took over that role. officially.

Following the meeting with Mr. THURLBECK, because of the importance of what had been

said, I went back to my office and asked the Deputy Editor, Jane JOHNSON , to take a note in

which I recorded what I had been told. I do not know where that note is retained or what

happened to that note. As I have already indicated, I have not been allowed access to any of my.

records.

I arranged a meeting with Mrs BROOKS.on the next day Mrs BROOKS, Mr CRONE and I

were in the office, which I believe was the following Tuesday. Mr CRONE and I saw her

together for approximately 20 minutes in the morning. We met in a room on the Executive


. 2006/07(1)

CONFIDENTIAL

http:BROOKS.on

CONFIDENTIAL

Continuation of Statement of: MYLER COLIN FormMG!l(T)(CONT) URN:Brooks Page 3 of4

floor. I recounted the comments made by Mr THURLBECK. She appeared shocked and

agitated about what I was telling her. I believe that she said this is "one question too many, six

months too late" and "I will not let this company go into meltdown". I do not know what she

meant by her first comment. She concluded our meeting by saying that we should let her think

about the issue.

Later that same day, Mrs BROOKS phoned me and asked me to meet her outside the building.

We met a short time after that and Mrs BROOKS expressed her views about how awful the

situation was. I recall that she said something along the lines of "we've got to protect Andy". I

believe that she was referring to Mr COULSON. I told her that I could understand the

significance of what she had said but that if I were asked about my knowledge, I would not lie,

She w~t away from the meeting saying that she would decide what should be done.

I considered that I had discharged my obligation to report this matter to my line manager and

expected that she would in turn report this matter higher up the chain.

Following my discussions with Mrs BROOKS, my expectation was that Mr THURLBECK

would be dismissed. I, myself, made two attempts to remove him during 2010, but for a variety

ofreasons neither attempt was successful.

After I had made clear to the Culture, Media .and Sport Select Committee my view about the

significance of the "for Neville" email in July 2009, Mr THURLBECK's position became

increasingly untenable. Together with the Managing Editor, Bill AKASS , I therefore insisted

that financial provision be made in the budget to dismiss Mr THURLBECK and also Ian .

EDMONDSON, whose own position was becoming increasingly difficult and ultimately

untenable. The details of the financial provision and when the provision was made will be

recorded in the Newspaper's financial reco.rds. Mr THURLBECK was eventually dismissed in

September 2011.


2006/07(1)

CONFIDENTIAL

CONFIDENTIAL

Continuation of Statement of: MYLER COLIN FonnMGll{T)(CONT) URN:Brooks Page4of4

Mr COULSON resigned from the Newspaper in January 2007. Mr KUTTNER had left, or was

about to leave, when the conversation with Mr THURLBECK took place. By that time it had

already been announced that Mr WALLIS would be leaving the Newspaper.

I did not discuss the issue with Mrs BROOKS again until early 2011. A dinner was held in

Wapping for the sponsors of the 2012 Olympics, the date of which can be estabjished from the

Newspaper's records. After the dinner took place, Mrs BROOKS and I spoke about how

difficult· she had found the transition from Editor of The Sun to Chief Executive of News

International. A couple ofdays later, I asked her whether she had told "the boss everything" (by

which I meant, Rupert MURDOCH). She said that she "had now". I do not know whether she

did in fact discuss the issue with him.. We have not discussed the matter again since then.

This is my best recollection of the circumstances and detail of this incident.


2006/07(1)

CONFIDENTIAL

Page i of 1

.. . ..:-~.:

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From: Crone, Tom Sent: Frl 10(11/2006 11:16

To: Coulson, Andy Cc:

Subject: RE:

Attach rn ents:

Let me discuss with Henri. By the way, in the inferests of doing everything we can for Clive... I have authorised the commissioning of a telecomms expert to go thru the pros'n evidence from their telecomms investigators to see if there are an I loopholes etc. Our guy won't be big dough .. .

From: Coulson, Andy Sent: 10 November 2006 11:12 To: Crone, Tom Subject: RE:

Fine and there is nothing els e buried away that could help/hinder? just wonder if its worth me sending someone (SKlNeil?} to Henri's for a day to read througn ...

______From: Crone'-Tom . Sent: 10 November 2006 11:11 - -- · - -- -- - -·--·-- - --------- - ----- - - -·To: Coulson, Andy Subject: RE:

6You replied on 04/01/2007 10:30. Follow up

lawyer ma ?::? ddi.

From: Coulson, Andy Sent: Wed 03/01/2007 16:16

To: Crone, Tom Cc:

Subject:

Attachments:

Tom - you are OK to send that memo to Les whenever you're ready.

Do we have any news on Clive's probation meeting? I emailed him today to explain that I wouldn't be meeting him but that you were keen to have a chat.

Also one other question on your memo .• you say Mulcaire started working for us in 2000 ..• I thought it went back further than fhat?

ANDY COULSON DEFENCE BUNDLE VOLUME 2 SUBJECT: CLIVE GOODMAN

Re: CLIVE GOODMAN

Clive Goodman is appearing for sentence on Januacy 2~h at tl1e Old Bailey. (I am anxious that those who need to know have an understanding of the possible outcomes).

Dackg:i;-ound:

1. Clive has pleaded guilty to a single count of conspiracy to inten:ept voicemail messages. The case against him is limited to the period from November 2005 to August 2006 ind to three members of the Royal Household staff. It Js not suggested he made or stood to ma.kc personal gRin from these activities.

2. His co-conspirator fs Glenn Mulc,!lire, a private Investigator, who pleaded guilty to the same charge as Clive and also to 5 other charges of intercepting the voicemails of Max Clifford, Andrew Skylet (football agent), Gordon Taylo.r (Chief Executive of the Professional Footballers Association.:.. "PFA"), Simon Hughes MP and EUe MacPherson ••• all between February and June 2006.

3, Both men pleaded guilty .at the Bailey on November 291h and were remanded for Social Inqµiry Rep orb to be prepare~ (by the Probation Service) so as to assist the Judge in sentencing. Clive had the meeting with his allocated probation officer on J' anuacy l8ia.

Possible outcomes on January 26ih:

1. In terms ofsentencing, there is a likelihood that both men will, receive prison sentences. If that is the case, Clive has a chance that his will.be suspended. Mulcsire will probably get an immediate custodial sentence. The maximum on each count is 2 years. ·

2. In terms of trying to predict fall-out from the January 26111

hearing, I.e. P.R.~ possible further police activity andpossible further legal proceedings, we need to look at what might be said in court by each of the parties (Prosecution, Clive and MuJcafre) and at a threat of civil proceedings we have received from one of the "victims".

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i) Prosecution:

The Prosecution will open tlte .hearing by summarising the case against each of the Defendants.

Their summary of CJJve's activities will be restricted to the single charge against hJm as described above.

Because of the enormous amount of evidence they seized in the raids on Mufcaire's premises., their outline of the case against hJm will paint a far hlgger picture. They are likely to say that the S extra charges are samples ofa much larger group of people whose voicemails !te accessed; that the evidence suggests only one paymaster, the News of the World; and that he has been exclusively contracted to the NoW for a number of years, his

· la~t annual contract (one of the seizures) being worth£x.

Clive:

Clive's dealings with f:lis lawyers have been marked by an intense anxiety that 1te will go to prison .as the '(fall-guy" for activities that go far beyond his guilty plea. llis lawyers have told him tliat he ea n only be sentenced for the single guilty plea and what it enmiled, but his anxiety (and possible resentment towards us) remains very strong ..

He. has told his lawyers that his commissionin.g of Mulcaire to f atercept Royal Household voicemails (i.e. his charge) was done with the knowledge and a uthorlsa tion of the Editor. (This is denied by Andy and I am certain it Js a false allegation - for III number of reasons it makes no sense at all). There is a real possibility that tWs allegation by Clive will come out at the court hearing, either as something he has told the Probation Officer for hJs report or in answer to a question asked of Ms counsel by the judge. Clive has said he will not volunteer the

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allegation but if asked direct questions (e.g. Were you doing it alone? Who else knew?) he says he will have to answer.

iii) Mulcaire:

Mulcaire's relationship with the News of the World goes back to around 2000. Through one or other of his companies, h~ has been contracted to supply ''a research and information service" on an exclusive basis (in that he can't do It for any other media outlet) since 2001.

He is 35 and married with 5 children aged 3-13.

Just before Christmas,. Greg Miskiw, former NoW news editor who is a friend of Mulcaire's rang me ''as an honest broker" to say: he is very bltter towards NoW for doing nothing to help him since the arrest; he'has ,consulted an employment lawyer and has had contact with a literary agent; as a result of the publicity the Jtaxman is after him for a "5-figure sum"; he must have mon.ey to tide bis family over for the year he tbinks this will take to sort things out; he is looking for a severance Hgreement which would contain a confidentiality clause.

The following day Mulcaire's lawyer rang me. To say he has " ...... been Instructed by Glen Mulcalre to advise h!m on his employment and/or contractual position with regard to his work for the NOTW and any claims that he· might have In light of the crlmtnal proceedfngs, of whfch' I am sure you are well aware." He is looking for a meaningful diseussion. I told him I'd need to take instructions and advice and I'd speak to him in the new year.

Ignoring the element ofillegal activity. it is not out of the questlon that although he contracts as a company and. Js clearly a freelance or consll!ltant, his legal status gives him employment rights

COPY 4-Page 17111176

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JB02047


against us. I have sent his contracts to a Farrers' employment law expert for a view.

What Mnlcaire might say (tllrough counsel) Jn court is clearly linked to the outcome of bis "employment" discussions. It Js quite likely in any event that he wlll say ail of tlle activities with whlch he is charged were conducted for the NoW. Whether he says a lot more (e.g. nnmes) or a lot Jess may depend on any tams'that"m~y take place .

.3. The PR fall-out from the J anua1:y 261h hearing is bound to be pretty awful even if neither Clive nor Mule a ire make allegations against the No W or No W individuals.

If they do make specific allegations, there is a real possibility that the police ,vlll renew their active interest .In investigating possible offences by other parties.

4. Subsequent Civil Litigation:

Seper a tcly we have been written to by the lawyers for PFA boss, Gordon Taylor, who is the subject of one of the 5 extra charges against Mulcairc (the PFA are funding

this). They say we are clearly responsible for Mulcaire's sustained 18~month exercise in illegally accessing TaylQr's phone and infringing his (and possibly his members') privacy and Data P1·otectfon Rights. On December 191h they served us with a Data Protection Notice fo provide all Jnformation a bout hlm held by us, etc, etc.

My guess Js tJ?.at there is very little of any substance to provide under this request. Nor, so far as I Mow, is there ~uch evidence.for.what they are claiming other than Mulcaio:e's contracts with us. What they are aware of is a sheet of No W headed notepaper seized by police at Mulcafre's premises which.. Js dated February 2005 and suggests that the No W wished to buy a story "about Gordon Taylor's affair". As it happens, the NoW never ran such a story.

Where this threatened civil claim is going! cannot accurately predict, but I suspect in the short term it won't go away.

COpY 4 -Page 16 of176

lli 57 40tf-77cA·45 rS...:i7 cf·W9~ 69 Ob4fa g 20l 1090U5_PfUNT000018

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AN A GREEMENT between NINE CONSULTANCY UK LTD (hereinafter called •the Consultant') o London SW10- and the NEWS OF THE WORLD (hereinafter caHed 'the CoinpanY1 of 1 Virgin ia streY,London E98 1 ~W.

IT' IS AGREED THAT:

-· ... f. In consideration of the payments set out in paragraph 7 hereunder, the Consultarit . Will' provji:fe the -Company with a research and infom,af:ion service for a period of 12 months from 1 July 2005.

2. The Consultant agrees that. during.the contracted period, he w ffl un,:fertake all research and information assignments requested by the Company.

3. The Consultant warrants that he wm conduct aft said assignments promptly, efficfentfy and with a high level of research and investigative s kill. The Consultant wm be avaUabfe to work: reasonable hours at the convenience of the Company. He will report regularly during assfgntnents and agrees to perform folfow-up requests and directfons from and generaUy

·assist the Company's representatives.

4r The Consultant wiU treat all assignments, communications, documents, payments and information passing between himself and the Company In the stric:fest confidence. This obligation wmcontinue to bfncfthe Consultant after tha expfratfon of thfs~greement.

5. During the period of this agreement. the Consurtant wlll not undertake · assignments from, work for ar provide any research or information to any other UK or Eire media outlet or freerance journalfst.

6. This agreement may be terminated by either party upon fwo months ' notice ln writing. Upon termination all future obligations hereunder except the confidentiality undertaking in paragraph 4 af;Jove shall cease.

7. The Consultant shall be paid weekly at the rate of £2019 (amounting to £104,988 for the 12-mont~ period}. · .- : · ·

SIGNED•..••....••..••.•.•......•.••••.•••.••.•.•.•••.....•••••.. ···· -·········

NINE CONSULTANCY UK LTD

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1 VIRGINIA STREET, LONDON E98 1 NW Telephone: 020 7782 1000 Fax: 020 7583 9504

THE WORLD'S L ARG EST SUNDAY SALE · www.newsoffheworld.co.uk

AN AGREEMENT between EURO RESEARCH and INFORMATION LTDi ereinafter called 'the Consultant') of , London SW10 and the NEWS OF THE WORLD (hereinaf ter caUed !foe CompanA of 1 Virginia Stree , London E981NW.

IT IS AGREED THAT:

1. In consideration of the payments set out in paragraph 7 hereunder, the Consultant will provide the Company with a research and information service for a period of 12 months from 151 September 2001 .

2. The Consultant agrees that, during the contracted period, he will undertake all research and information assignments requested by the Company.

3. The Consultant warrants that he will conduct all said assignments promptly, efficiently and with a high level of research and investigative skill. The Consultant will be available to work reasonable hours at the convenience of the Company. He will report regularly during assignments and agrees to perform follow-up requests and directions from and generally assist the Company's representatives.

4. The Consultant will treat all assignments, communications, documents, payments and information passing between himself and the Company in the strictest confidence. Th:s ohlin :1ticn wm continue to b1nd the Consultant after the expiration of this agreen1ent.

5. During the period of this agreement, the Consultant will not undertake assignments from, work for or provide any research or information to any other UK or Eire media outlet or freelance journalist.

6. This agreement may be terminated by either party upon two months' notice in writing. Upon termination all future obligations hereunder except the confidentiality undertaking in paragraph 4 above shall cease.

7. The Consultant shall be paid weekly at the rate of £1769.23 (amounting to £92,000 for the 12-month period).

('~~ SIGNEDr:i"E·wJO:·THE 0 WORL0"'... .................................... ..

Registered Office: News Group Newspapers Ltd., 1 Virginia Street, London E98 1XY

http:www.newsoffheworld.co.uk

1 VIRGINIA STREE~ LONDON E98 1 NW Telephone: 020 7782 1000 Fax: 020 7583 9504

THE WOR LD'S LARGEST SUNDAY SALE vvww.newsoftheworld.co.uk

AN AGREEMENT between EURO RESEARCH and INFORMATION LTD~ reinafter called 'the Consultant') of . London SW10 - and the NEWS OF THE WORLD (hereinafter called 'the Company') of 1 Virginia Street, London E98 1NW.

IT IS AGREED THAT:

1. In consideration of the payments set out in paragraph 7 hereunder, the Consultant will provide the Company with a research and information service for a period of 12 months from 151 September 2002.


3. The Consultant warrants that he will conduct all said assignments promptly, efficiently and with a high level of research and investigative skill . The Consultant will be available to work reasonable hours at the convenience of the Company. He will report regularly during assignments and agrees to perform follow-up requests and directions from and generally assist the Company's representatives.

4. The Consultant will treat all assignments, communications, documents, payments and information passing between himself and the Company in the strictest confidence. This obligation will continue to bind the Consultant after the expiration of this agreement.



7. The Consultant shall be paid weekly at the rate of £1769.23 (amounting to £92,000 for the 12-month period).

2

Registered Office: News Group Newspapers Ltd., 1 Virginia Street, London E98 1XY

http:vvww.newsoftheworld.co.uk

, C..;J • .JU~o~VU...> ..1. ..J· ,._

1 VIRC\INIA STREET, LONDON E98 1NW Telephone: 020 7782 1000 Fa.x: 020 7583 9504 www.newsottheworld.co.uk

23"' .July 2003

e sea London SW10.

ADDENDUM to a letter of agreement dated 1st September. 2002.

As discussed we have agreed lhat the research and assisfanca provided by Euro Research and Information Lid to \he News of the World should be extended 10 run from the Monday to Friday each week from 9arn till 5pm. In emergencies calls can bs made outside these hours including Saturdays between Sam mi 12 noon.

In return the News of the World agrees to pay Euro Research and Information Ltd an additional £250 a weeK, maKing the total weekly remuneration £2,019.

I would be grateful If you could sign as indicated below.

Yours sincerely,

r~-~ Assistant Editor News and Investigations

Ragistered Office: News Group Newspapers Ltd., 1 Virginia Street. Land.on E98 1XY Registered No. 679215 Engl~nd

3

http:www.newsottheworld.co.uk

AN AGREEMENT between NINE CONSUL TANGY UK L TD (hereinafter called 'the Consultant') of , London SW10 and the NEWS OF THE WORLD (hereinafter called 'the Company') of 1 Virginia Street, London E98 1 NW.

IT IS AGREED THAT:

1. In consideration of the payments set out in paragraph 7 hereunder, the Consultant will provide the Company with a research and information service for a period of 12 months from 1 July 2005.


3. The Consultant warrants that he will conduct all said assignments promptly, efficiently and with a high level of research and investigative skill. The Consultant will be available to work reasonable hours at the convenience of the Company. He will report regularly during assignments and agrees to perform follow-up requests and directions from and generally

·assist the Company's representatives.

4. The Consultant will treat all assignments, communications, documents, payments and information passing between himself and the Company in the strictest confidence. This obligation will continue to bind the Consultant after the expiration of this



7. The Consultant shall be paid weekly at the rate of £2019 (amounting to £104,988 for the 12-month period).

SIGNE -·· ···· ..... ..... ................... .. ........... . . .. ......... .. .... .

CNINE SULTANCY UK LTD ~ . kuLc.o;·d1..E J

~ /~y; ~%d/ SIGNeD.: ..... . ... . .. ... : .... . .. ....... ............. ..... . ....... .. .. ..... .. .. ... . .

NEWS OF THE WORLD

4

22. D1872623. D264642. D190687. D187378. D1875810. D1875911. D3063620. D1875721. D18768Myler document right order pages2528Pages 4-7 of Andrew Coulson's JuryBundle Folder No.2ID1526 - Nine Consultancy14444 ALF-75PJT-1

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