52. 64. While I was, DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 I remember this day so clearly, we were staying in a house and, after visiting Steve Irwin's Crocodile Zoo in the morning, we had gone out on to the beach in front of the house in the afternoon. 124. her brother, Harry, for example. Over the years, Harry and I came to have a slightly difficult relationship, I ended up feeling quite suspicious of him, which was awkward as I was the godfather to one of his children. DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 I was being made to look irresponsible or reckless. DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 The article is marked both as an 'Exclusive' and a 'Picture Exclusive', as it carries two photographs of me, and the well-known television personality Caroline Flack, together on a street in Fulham, London. 10. 94. 154. 104. Every relationship has its challenges, but they're private just clearly not for us. Capitol Inquiries, and Benji Pell. Article published by The Mirror entitled "Harry's cocaine ecstasy and GHB parties" by Jane Kerr & Jeff Edwards dated 14 January 2002 I believe it doesn't matter whether you're a public figure at this point. The duke is suing the publisher of the Sun, News . As stated, Chelsy and I were not widely discussing our relationship. 78. 151. I understand that it is not my function to argue the case, either generally or on particular points, or to take the court through the documents in the case. It was upsetting to be questioning someone who played such an important role in my adolescence, and I felt as though I knew I could trust him but on the nose' information appearing in print, that only he knew about, convinced us otherwise. 152. A target had been placed on my head and I was withdrawn. It was also true that I was finding the media intrusion particularly difficult, or as the Defendant's journalists put it - "sensitive" - because of the heightened attention due to reports surrounding my A-Levels and the employment tribunal hearing of my former teacher. 185. The article contains a quote from a spokesperson, allegedly on my behalf, which states that I had already spoken to my father "but any conversation will remain private". Marked as an 'exclusive', it reveals that Chelsy would take a year out from her studies to be able to spend more time in England, as I was just about to enrol at Sandhurst. DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 198. If we had met at a friend's apartment, it would have been someone we trusted implicitly, so I don't believe anyone would have provided any details to the Defendant's journalists, either here or in Ireland. I have been advised that David Rowe was freelance when he wrote this and was paid 100 for the story. i. This article, which appeared on page 10 of the Daily Mirror, contains details of the role of Parade Commander I was given at the CCF tattoo, which was held at Eton on 27 May 2003 (not on the 29th May as reported by the Defendant). 16 hours ago Comments Prince Harry arrives at High Court for battle with MGN over phone hacking Giving evidence in his ongoing case against the Daily Mirror 's publisher at London's High Court. By this stage, Chelsy was already extremely guarded about our relationship and our circle of friends who we trusted with information about us had shrank considerably. Reading these articles with the benefit of hindsight, I realise how brazen they were about the information they had managed to get. Article published by The Mirror entitled "Plot to steal Harry DNA" by Harry Arnold dated 16 December 2002 Prince Harry referred to Prince William, 40, in the witness statement by his current title, following the death of Queen Elizabeth and King Charles' accession to the throne, as heir: "HRH The . 119. I remember this incident so clearly, I was pickpocketed. My solicitors have shown me an invoice for the agency, BDI, dated 9 November 2007 with the subject "Project Harry". 133. 34. I walked into the Arrivals Hall with a baseball cap on and immediately spotted five separate paparazzi sitting on benches with cameras in bags, their hands inside rucksacks and everyone else looking at me - I remember that someone was videoing me with one of those tiny little cameras between their legs. There really was no respite from the press intrusion. 57 "BORED HARRY IN POLO JAUNT." I believe these show that MGN were using unlawful means of gathering information about me for this article. There was a call made from someone at MGN to Jamie on 21 July 2006, which seems suspicious. 106. 115. For obvious reasons, any plans for me and my regiment were intended to be highly confidential, so no coverage of this was welcome. 52. The level of detail regarding our phone communications is shocking and so blatant. We did speak about it over the phone, but I promised her that I hadn't had a lap dance and stayed with the three other cadets that had girlfriends. 40. There is also a payment to Rob Palmer for 500 entitled 'Harry booze bungles'. I suspected I was targeted, nothing about it felt opportunistic. This was handled by a tight, small team internally, so it is not clear to me where the defendant's journalists could possibly have obtained these quotes from. Chelsy had no interest in being involved in public life, she found the press intrusion as difficult as I did, and it was the main, DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 by Susie Boniface dated 2 December 2007 Prince Harry, the Duke of Sussex, arrives at the Royal Courts of Justice in London on Tuesday. 179. "He wholeheartedly believes that our country owes a huge debt of gratitude to the rich . Article published by The Mirror entitled "Snap..Harry breaks thumb like William; Exclusive" by Jane Kerr dated 11 November 2000 140. - My security and I simply couldn't know whether they were reaching for a camera or drawing some kind of weapon. It seems to me the Defendant was either trying to create a story, or they had got the wrong end of the stick. The article also states that Chelsy and I were to reunite in Mozambique, which is described in the article as a make-or-break holiday. 58. 41. My solicitors have shown me two Contribution Payment Requests to Frank Thorne which seem likely to relate to this article. DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 It included a comment from a 'friend' that the final straw for her was me signing up to a helicopter pilot training course, as it would leave so little time for a serious relationship. DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 It reported I had been banned from seeing Chelsy, who was in Cape Town. 175. They admit people were doing it but deny the victims' claims. It was suffocating, in the airport you're just trapped and all that after a long flight. I now understand that Dean Rousewell is well-known in this litigation as having used unlawful information gathering techniques himself, and also a habitual commissioner of private investigators, including JJ Services and Commercial & Legal Services. Article published by Sunday Mirror entitled "Hooray Harry's dumped" by Zoe Griffin & Nick Owens dated 11 November 2007 DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 My solicitors have shown me a private investigator invoice from Newsreel UK for 500. Posted. I think it's quite ironic for the Defendant's journalists to be remarking on how difficult I was finding this period, when articles like this, and the conduct of the press, including the Defendant's journalists, contributed to that feeling. The whole narrative of the article seems designed to make me look bad. She was fearful of what was actually happening to her and now I know that I was the same. 36. I really did want those close to me to know I wanted to get back, I wanted my family to understand how important was for me to serve again. as is Natalie Pinkham, a sports television presenter and a close friend of mine. 44. The article is accurate in that it reports I was taken back to Clarence House, then on to see a doctor. In a witness statement released as he gave . At the time, Mark Dyer, was like a mentor to me and we discussed a lot of options for my future career, as I really valued his opinion and, DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 197. This article, which was published on page 9 of the Daily Mirror and written by lan Miller, reports that my brother and I would not be attending the gala pageant to celebrate the 100th birthday our great grandmother, the late Queen Mother. 196. I. Article published by The Mirror entitled "Harry is ready to quit Oz" by Jane Kerr dated 27 September 2003 134. I fully accept and agree with the fact that journalists and the media own the public square, in as much as, if you are in a position of responsibility and or are funded by the taxpayer, the media should have the power to be able to investigate anyone, anytime, for pretty much anything. At the time, when I was 18 years old and had lost my mother just six years earlier, stories such as this felt very damaging and very real to me. This article, marked as an 'exclusive' and published on page 39 of the Sunday Mirror, revealed an injury that I had sustained to my back while playing polo, which had forced me to stop playing rugby. It revealed that we had "several tense meetings" the week before, and that she decided to call it a day. They became instant targets - a common theme for all my friends and girlfriends. I believe this trial witness statement complies with Practice Direction 57AC and paragraphs 18.1 and 18.2 of Practice Direction 32, and that it has been prepared in accordance with the Statement of Best Practice contained in the Appendix to Practice Direction 57AC. It is true that I was asked to be a godfather, but again, I'm not sure where these comments would have come from. 13. Article published by Sunday Mirror entitled "Harry met Chelsy" dated 18 November 2007 - no byline 128. Most small clubs and bars didn't have back entrances, and if they did, the paparazzi would find out and cover them too. 53. The article reports that Chelsy had "let rip in a string of phone calls" and includes a comment from a 'highly placed source' that she had gone "berserk, had slammed the phone down because she was too angry, and then called back to scream at me for half an hour. As I have said previously, details of my travel plans, including dates I would be flying, were not released by the Palace for security reasons, yet the specific date I would return to Britain was published days in advance. Jamie Lowther-Pinkerton, my former private secretary. UK. The most interesting part of this article for me is the line that I was staying inside watching videos" instead of working outside to avoid the camera crews. Again, I'm not sure where the Defendant's journalist would have got this information from. The Palace did make an announcement regarding his appointment and the article itself reports that we helped choose him for the role and that we got on well with him, which we did. I was angry. Harry, 38, is suing the publisher, attempting to prove that reporters for the Daily Mirror, Sunday Mirror and Sunday People titles were linked to methods including phone hacking, so-called "blagging" or gaining information by deception, and use of private investigators, between 1996 and 2010. The first, a payment to Gerard Cousens for 150 with the description 'Prince Harry in Argentina' dated 25 November 2004. 57. 156. Prince Harry witness statement: Key extracts. The timing of the article was also horrible. This is another article that contributes to the narrative set by the Defendant's journalists that I was irresponsible in some way, and that all my family were somehow desperately trying to find ways to keep me in check. Again, how would they have known this? 60. 82. 98. Along with what I understand about the activities of Jane Kerr, I understand that her co-author, Chris Hughes was a regular commissioner of private investigators including Jonathan Stafford, Searchline, and Severnside. 71. I don't believe my father was widely discussing his views with anyone outside of the family. 180. 172. In his role as my father's, DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 You become a victim of their system. I really cannot understand how the Defendant's journalists obtained such specific details for this article, however given what I know about Dean Rousewell's activities, I find it very suspicious. If this is the case, how did they know? I've always heard people refer to my mother as paranoid, but she wasn't. My solicitors have shown me a number of Contribution Payment Requests that appear to relate to this article in the days leading it up to it. We, naturally, spoke about all types of personal matters, including all aspects of our relationship and this was often through voicemail. I am at a complete loss as to how these details were obtained. I note that there isn't a witness statement from either Dean Rousewell, who is bylined in ten of the fifty selected articles, or from any of the other 31 journalists who are bylined in those articles. Date: 24 February 2023. 65. cope". k. Paddy Haverson, my father's former Communications Secretary. 147. My private information would have been present on voicemails left on his landline phone by other members of my family or the Royal Household. DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 Article published by The Mirror entitled "Back together" by Fiona Cummins dated 20 November 2007 While I can't recall the specific details of the state of our relationship at this time, it's highly unlikely I told anyone the details of the way I was trying to patch things up with Chelsy, it's hardly flattering to be contacting someone so much it could be described as "pestering" them. It is obvious they were doing everything in their power to glean my private information while I was starting a serious relationship. 40. 21. The description for the payment reads 'Harry Afghan tour blocked" which clearly relates to this article. Signed:. Prince Harry has accused the tabloid press of casting him in the role of a "thicko" and a "cheat", in his case against Mirror Group Newspapers (MGN). Had she not been in a relationship with me, she would never have had to endure such a horrific experience at the hands of MGN's journalists. To me, it seems like the Palace were approached with information about a possible fallout from the decision for us to miss the event, which they then responded to. Sept. 12, 2022, 5:07 AM PDT / Source: TODAY By Ariana Brockington and Drew Weisholtz Prince Harry is grieving the loss of his grandmother Queen Elizabeth II following news of her death at age. There was often up to 15 men waiting outside with huge cameras. Article published by The People entitled Harry..Don't be a hero" by Dean Rousewell dated 4 March 2007 My brother and I stopped talking to him for a while as we just couldn't understand how stories about us meeting privately with him ended up in the papers, or how photographers would end up outside his apartment. I am satisfied that the purpose and proper content of trial witness statements, and proper practice in relation to their preparation, including the witness confirmation required by paragraph 4.1 of Practice Direction 57AC, have been discussed with and explained to Prince Harry, Duke of Sussex. Prince Harry gave evidence on Tuesday at the High Court in London in his lawsuit against the publisher of British tabloid the Daily Mirror, which he accuses of phone-hacking and other unlawful acts. I am aware that my brother was also a victim of phone hacking and unlawful information gathering. 178. 97 "HARRY IN SPACE" The Mirror, 24 July 2006, Stephen Moyes 47. Article published by Sunday Mirror entitled "Harry - I'm going to join army" by Rupert Hamer dated 5 January 2003 p. Caroline Flack, the late television presenter, was a friend of mine. Again, this now seems like the Defendant's journalists were digging around for more private information to publish. People have died as a result, and people will continue to kill themselves by suicide when they can't see any other way out. Although my solicitors have advised me that it would not be appropriate for me to provide a running commentary on each and every documents disclosed by Defendant in this statement, I have had the opportunity to review them and would like to say that I'm shocked and appalled at the sheer volume of payments made by MGN titles to private investigators (who are known in this litigation to have used voicemail interception and other unlawful information gathering techniques to obtain private information about their targets) for private information about me and my Associates over a ten year period (from 1999, when I was still very much a minor, to 2009). 64. To prepare this witness statement, I have been through each of the articles highlighted with my solicitors on a series of video calls in January and February 2023. I came to expect to be followed and papped by someone hiding in a bush somewhere. I do not believe that the Palace put this information out freely, I think they responded to information that was put to them. DocuSign Envelope ID: 0C88E148-B05A-4AD5-A805-D34312B765E4 Article published by The Mirror entitled "3am: What a way to Harry on" by Clemmie Moodie & Danielle Lawler dated 26 March 2009 28. Given how little there really is to the story, it is mind boggling the amount of enquiries and payments MGN had made. 155. "Harry met Chelsy" Sunday Mirror, 18 November 2007, No byline As mentioned above, there had been extensive coverage of the party after the photographs were leaked. I had already decided that I wanted to spend time assisting with aid projects in Africa, as my mother had done. Communications Secretary, he would have been the first to know if something newsworthy about my brother and/or I had occurred good or bad and would, in all likelihood, been the one to have known the most about it. 31. This shows me that MGN were digging around my associates to unlawfully gather my private information. MGN's Amended Defence and Schedule to Amended Defence dated 23 November 2022 What strikes me about this article is the quote from the 'royal aide' regarding my plans to get a "proper job" in the rest of my gap year before I joined Sandhurst. What's clear to me is that the Defendant's journalists knew far more than they put into the public domain and didn't want to reveal too much of their hand for fear of exposing the unlawful ways they were really obtaining this kind of personal and private information. 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