1

             2   (2.00 pm)

             3   LORD JUSTICE LEVESON:  Yes, Mr Jay.

             4   MR JAY:  Sir, this afternoon's witness is Mr Coulson,

             5       please.

             6   LORD JUSTICE LEVESON:  Thank you.

             7                 MR ANDREW EDWARD COULSON (sworn)

             8                       Questions by MR JAY

             9   MR JAY:  Your full name, please, Mr Coulson.

            10   A.  Andrew Edward Coulson.

            11   Q.  I ask you to turn up your witness statement, which is

            12       dated 1 May of this year.  If you look at the last

            13       paragraph and underneath it you'll see a signature which

            14       is yours, with a date and a statement of truth.  The

            15       statement of truth is given within the constraints

            16       imposed on you by the ongoing police investigation and

            17       lack of access to documents; is that right?

            18   A.  Yes.

            19   Q.  I'll first of all attempt a short timeline of your

            20       career.  You started working as a journalist in 1989; is

            21       that correct?

            22   A.  Yes.

            23   Q.  Between 1994 and 1998, you edited the Bizarre column at

            24       the Sun; is that right?

            25   A.  Yes.


                                             1






             1   Q.  The year 2000, you were deputy editor of the News of the

             2       World under Rebekah Wade as she then was; is that

             3       correct?

             4   A.  Yes.

             5   Q.  January 2003 you were appointed editor of the News of

             6       the World.  On 26 January 2007, you resigned.  Around

             7       June 2007 -- we'll come to the exact date when you give

             8       your evidence -- you were appointed Director of

             9       Communications to the Conservative Party; is that right?

            10   A.  Yes.

            11   Q.  You started work, I think, on 9 July 2007, and after the

            12       last General Election, I think on 12 May 2010, you were

            13       appointed Director of Communications at Downing Street;

            14       is that correct?

            15   A.  Yes.

            16   Q.  And you resigned as Director of Communications on

            17       26 January 2011.

            18           Can I ask you this general question first of all,

            19       Mr Coulson: there are reports about that you have been

            20       keeping a personal diary in the style of

            21       Mr Alastair Campbell, which might, as it were, be

            22       a contemporaneous record of relevant events,

            23       particularly between July 2007 and January 2011.  Is

            24       that correct or not?

            25   A.  No.


                                             2






             1   Q.  So in terms of how your witness statement has been

             2       prepared, you've had to rely on your memory,

             3       self-evidently.  Are there any other documents that

             4       you've had access to which might have assisted?

             5   A.  There were some notes that I would take as I -- you

             6       know, in the course of my work, both from opposition and

             7       government.

             8   Q.  So these are manuscript or computer records, are they?

             9   A.  No, they're notebooks.

            10   Q.  Notebooks.  And have you had access to those notebooks

            11       when you have prepared your statement or not?

            12   A.  Yes.

            13   Q.  You have been arrested in connection with

            14       Operation Weeting and Operation Elveden, so I will not

            15       be asking questions which bear on those matters, do you

            16       understand?

            17           Can I ask you some background questions?  It's clear

            18       from your statement that you were, perhaps still are,

            19       close friends with Rebekah Brooks; is that right?

            20   A.  Yes.  We haven't spoken for a while for obvious reasons.

            21   Q.  Can I ask you about the frequency of your interaction,

            22       particularly after July 2007.  About how often would you

            23       speak to her?

            24   A.  It would depend.  I think I've scheduled the sort of

            25       meetings that we had, social meetings that we had, but


                                             3






             1       we would talk now and then.  I wouldn't say even that we

             2       spoke every week.  There were times when we didn't speak

             3       for quite some time, but it was -- I'd say that we spoke

             4       over that period of time regularly, I think is the word

             5       I'd use.

             6   Q.  Did you communicate by text message with her?

             7   A.  Occasionally.

             8   Q.  By email?

             9   A.  Occasionally.

            10   Q.  And then obviously by mobile phone; is that right?

            11   A.  Yes.

            12   Q.  Would it be fair to say that you knew what each other's

            13       respective political standpoints were?

            14   A.  Well, she knew I worked for the Conservatives, so that

            15       was pretty clear.  As to her political allegiances, you

            16       know, the -- in terms of her period of editorship at the

            17       Sun, she was supportive of the Labour Party, and

            18       obviously she was chief executive when the Sun then

            19       changed its allegiance to the Conservative Party.  As to

            20       her personal views, her personal beliefs, how she voted,

            21       I have no idea.

            22   Q.  Do you have any insight into her personal political

            23       beliefs or not?

            24   A.  No, not beyond the odd conversation that we'd had, but

            25       I guess the question is, if I might be so bold, how did


                                             4






             1       she vote, I have no idea.

             2   Q.  Was she someone who you felt was close to certain

             3       politicians?

             4   A.  Yes, I think through the course of her work she was

             5       close to politicians, yes.

             6   Q.  We'll come to that in a moment.  When you took over as

             7       editor of the News of the World in 2003, which aspects

             8       of the culture there, if any, did you want to change?

             9   A.  I don't remember wanting to change any of the cultural

            10       aspects.  The main change I instigated on becoming

            11       editor was a cosmetic one.  I wanted to redesign the

            12       paper.

            13   Q.  You've worked at both papers, the Sun and the News of

            14       the World.  Are there any differences in the culture at

            15       those two papers or not, in your view?

            16   A.  In so much as one is a daily paper, so the pace of the

            17       paper is very different, the atmosphere is different to

            18       a degree, certainly on certain days of the week.  If you

            19       try to find a comparison between the News of the World

            20       mood, if you like, and the mood of the Sun, it's on

            21       a Saturday obviously because that's the day you're

            22       producing the newspaper.

            23   Q.  Moving to, please, your dealings with Mr Rupert Murdoch

            24       as editor, so we're looking now at the period 2003-2007.

            25       About how often would you speak with him, do you think?


                                             5






             1   A.  I can't put a number on it, but he would call usually on

             2       a Saturday night.  Sometimes it would be, you know,

             3       maybe a couple of times in a month, sometimes you might

             4       go a couple of months without hearing from him.  So it

             5       was -- I think I would describe that as irregular, and

             6       almost always -- in fact, I think always a sort of

             7       Saturday night phone call.  Aside from the, you know,

             8       occasional News International meetings when he was in

             9       London or when I would go to New York along with all the

            10       other editors for the sort of budget discussions.

            11   Q.  In terms of the content of the paper, what in particular

            12       was he interested in?

            13   A.  In terms of the specific content, I don't remember any

            14       conversations with him initially about a particular part

            15       of the paper.  We did talk about the sports pages.  The

            16       company had made a big investment in expanding the size

            17       of the sports pages, sports coverage in the News of the

            18       World, and that was a fundamentally important part of

            19       the sort of commercial mix of the paper, so we -- I'm

            20       sure we discussed that.  And we discussed politics

            21       generally and he would give me his view on whatever was

            22       sort of in the news at the time, maybe.

            23   Q.  We know Mr Murdoch was interested in football because he

            24       tried to buy Manchester United, we know that didn't

            25       succeed, but wasn't he interested in things such as


                                             6






             1       scoops and front pages?

             2   A.  In those conversations I might tell him, if we had

             3       a good story, what we were planning to run that night,

             4       but not always, by any measure.

             5   Q.  Wasn't he interested in stories which might impact on

             6       the commercial success, the circulation figures of the

             7       newspaper?

             8   A.  Well, insofar as -- I mean, sport is a good example.  In

             9       terms of driving sale of the News of the World, the

            10       sport was crucial.  And it also had a massive impact on

            11       the sort of physical production of the paper, so that

            12       was a -- I certainly remember having that conversation.

            13       News International invested in some very expensive

            14       presses during my time as editor, and I had real

            15       concerns that those presses, although very successful in

            16       some regards, would impact on the production of the

            17       paper, particularly the sports coverage.  You wouldn't

            18       get the right team's coverage into the right area, for

            19       example.  I certainly remember discussing that.

            20   Q.  You're bringing the conversation around to quite neutral

            21       topics such at sport.  Did he ask you questions directly

            22       about circulation figures?

            23   A.  He may well have done, yes.

            24   Q.  And during these sporadic telephone calls, him usually

            25       phoning from New York, presumably, on a Saturday, did he


                                             7






             1       tend to ask you, "How's the circulation going"?

             2   A.  Not always, no.

             3   Q.  But often?

             4   A.  I certainly remember occasions when he did, but it

             5       wasn't the -- I wouldn't want to characterise it as the

             6       main purpose of the call, because quite often he

             7       wouldn't even mention it.

             8   Q.  But both you and he were aware of the sort of factors

             9       which might impinge on the circulation figures of the

            10       paper; is that correct?

            11   A.  Yes.  My job as editor was to -- was absolutely to

            12       produce a successful newspaper.

            13   Q.  When you said you discussed the political issues of the

            14       day, were these quite general discussions about topical

            15       issues such as Europe, the European referendum or

            16       whatever it might be?

            17   A.  Yes.  I mean, Europe wasn't as big an issue for the News

            18       of the World as perhaps it was for a daily paper like

            19       the Sun, but yes.

            20   Q.  Did you discuss the politicians of the day and how well

            21       they were doing in your eyes?

            22   A.  On occasions, yes.

            23   Q.  Did you have a sense that he wanted to find out how

            24       political opinion in this country was moving?

            25   A.  I don't recall a sort of specific conversation in that


                                             8






             1       way.

             2   Q.  But in general, Mr Coulson, I'm not asking you to

             3       identify a moment or a particular conversation, but in

             4       general did you have any sense of that?

             5   A.  I might well in the course of a conversation offer

             6       a view, normally related to a particular issue rather

             7       than the sort of longer term picture.

             8   Q.  During this period, 2003, 2007, were you particularly

             9       interested in politics or not?

            10   A.  Yes.

            11   Q.  And although your paper may not have adopted this

            12       position, your own personal position throughout has been

            13       pro-Conservative, hasn't it?

            14   A.  Well, we supported Labour under my editorship at News of

            15       the World.

            16   Q.  I'm talking about your own personal --

            17   A.  How I voted?

            18   Q.  I'm not seeking to be so personal as to ask you how did

            19       you vote, I just want to seek your general perspective

            20       on things.  Generally speaking Conservative?

            21   A.  Sure, one tends to vote in line with your personal

            22       feelings, but yes, I think that's fair to say.

            23   Q.  Do you feel it was part of your job as editor, perhaps

            24       in any event, to assess the political mood of the

            25       country and in particular how the country was likely to


                                             9






             1       vote in the next General Election?

             2   A.  I think my job as editor was to -- as best I could, to

             3       establish where the News of the World readership was in

             4       terms of politics and certain issues.

             5   LORD JUSTICE LEVESON:  To lead or to follow?

             6   A.  No, I think to try and reflect, sir.

             7   LORD JUSTICE LEVESON:  So in that sense, to follow?

             8   A.  Yes, I think there's more follow than lead, I would say.

             9       There were some issues that as an editor you would want

            10       to champion, and therefore I think probably aim to lead

            11       opinion, but I think generally speaking, a successful

            12       newspaper is one that's in tune with its readership.

            13   LORD JUSTICE LEVESON:  So there are some things you can't

            14       get them to do, but there are some things you could get

            15       them to do if the cause is right?

            16   A.  Them as in politicians or the readers?

            17   LORD JUSTICE LEVESON:  No, them as in readers.

            18   A.  No, I don't think you can get readers to do anything

            19       other than try to buy the paper.

            20   LORD JUSTICE LEVESON:  All right, all right.  You have to

            21       have an understanding of where they are so that when you

            22       decide that you do want to promote a particular cause to

            23       go into leadership mode that it is sufficiently in tune

            24       with where you know they are that it doesn't cause you

            25       trouble.


                                            10






             1   A.  Yes, you want the two to be aligned as much as you

             2       possibly can.

             3   LORD JUSTICE LEVESON:  That's what I was trying to get at.

             4   MR JAY:  Of course, the exercise tends to be rather

             5       unscientific because you have a very large readership,

             6       over 3 million people are buying the paper, and

             7       obviously a whole range of opinion within that

             8       readership; is that right?

             9   A.  That's right.

            10   Q.  Do you take opinion polls, even on a rudimentary basis,

            11       of what your readership was likely to vote?

            12   A.  Pretty rudimentary.  There was some market research that

            13       I'd occasionally get access to.

            14   Q.  Would you describe your relationship with Mr Murdoch as

            15       being warm or something different?

            16   A.  I was an employee and we had a -- I thoroughly enjoyed

            17       my time working for him, and in the sort of interactions

            18       I had with him, yes, he was warm and supportive.

            19   Q.  So warm towards you and vice versa, is that it?

            20   A.  I wasn't particularly close to him in that regard,

            21       I wouldn't want to overstate it.  He was supportive to

            22       me as an editor and I enjoyed working in his company.

            23   Q.  There are rumours that you turned down the editorship of

            24       the Daily Mirror upon the resignation of Mr Morgan.  If

            25       you did, that might reflect on your loyalty to


                                            11






             1       Mr Murdoch, but did you?

             2   A.  There were conversations, yes, towards the possibility

             3       of me becoming the editor of the Daily Mirror, and

             4       I chose not to do so.

             5   Q.  Okay.  The one General Election which came in your

             6       watch, as it were, was the 2005 election.

             7   A.  Yes.

             8   Q.  You say in paragraph 40 of your statement:

             9           "In the end [you] decided to continue the paper's

            10       support of Tony Blair."

            11           Why "in the end"?

            12   A.  Well, it was a sort of long process, really.  I had

            13       a range of meetings in the sort of lead-up to the

            14       election, a conference, an outsider conference and

            15       I over time, together with my team at the News of the

            16       World, decided in the end that we would continue to

            17       support Tony Blair.

            18   Q.  Did you believe that he would probably win that

            19       election?

            20   A.  Well, it wasn't the key factor in the decision.  The key

            21       factor in the decision was -- as I touched on earlier,

            22       was I felt that News of the World's readers' best

            23       interests would be best served by Tony Blair.  But, you

            24       know, if you read the leader at the time, I think I --

            25       I think it was -- I don't think it was wildly


                                            12






             1       enthusiastic.  But I think on balance we felt that that

             2       was the best way to go.

             3   Q.  You say you reflected the mood of the country I suppose;

             4       is that right?

             5   A.  Possibly, yes.

             6   Q.  Did you take advice about who might win that election?

             7   A.  No.

             8   Q.  From your political editor, for example?

             9   A.  Oh, sorry.  In terms of advice, I mean we had a -- some

            10       pretty detailed conversations about it, and that would

            11       certainly have involved the political staff.  I was keen

            12       also to involve members of staff who didn't work in

            13       politics, who didn't understand Westminster, who weren't

            14       immersed in that world, people who worked in different

            15       departments on the magazine and in features, and what

            16       have you.

            17   Q.  Did you have discussions with Rebekah Wade about it?

            18   A.  No, I don't think so.  In terms of the editorship of the

            19       Sun, and the editorship of the News of the World, they

            20       are separate -- or they were separate papers, and there

            21       was a sort of clear line drawn between the two.  There's

            22       a rivalry, actually, or there was a rivalry between the

            23       two.  And so I wouldn't have had a -- I certainly don't

            24       remember any conversations with Rebekah about that

            25       issue.


                                            13






             1   Q.  So the Sun's endorsement of the Labour Party would have

             2       been a surprise to you then, would it?

             3   A.  I don't know if it was a surprise.  I certainly didn't

             4       play any part in that decision-making.

             5   Q.  Did you have any discussions with Mr Rupert Murdoch

             6       about it?

             7   A.  About the Sun's endorsement?

             8   Q.  No, the News of the World's endorsement.

             9   A.  I don't believe I did, no.  I may have had

            10       a conversation with him after the event, possibly.

            11       I don't know.  I don't remember, anyway.

            12   Q.  Wouldn't you, though, have wanted to find out whether

            13       what you were doing was contrary to his viewpoint?

            14   A.  No.  I didn't have a conversation with him, I don't

            15       remember one, I don't think it happened, about the 2005

            16       election.  I followed my own path with it and I don't

            17       feel, you know, sitting here now, that I was pushed or

            18       encouraged or certainly told to go a certain way.

            19       I remember the process quite well and I was determined

            20       that we would spend a reasonable amount of time with

            21       politicians from both parties and then we would make up

            22       our own minds.

            23   Q.  I move forward to October 2005, Conservative Party

            24       conference.  There were five candidates standing for the

            25       leadership.  You'll recall that, Mr Coulson?


                                            14






             1   A.  Yes.

             2   Q.  You tell us in paragraph 33 of your statement that you

             3       met Mr David Cameron there at a dinner hosted by

             4       Mr Les Hinton, do you recall?

             5   A.  Yes.

             6   Q.  Was he soon your preferred candidate for the leadership?

             7   A.  Certainly not at that stage.  I've taken the time to

             8       look back at some News of the World editions of around

             9       that period, and I don't think that the News of the

            10       World ever explicitly supported Mr Cameron in the

            11       leadership.  I don't think we explicitly supported

            12       anyone.  But we did employ at that stage William Hague

            13       as a columnist and I think that Mr Hague expressed

            14       a preference, before of course he then went to go and

            15       work with him.

            16   Q.  From your own personal perspective, was he your

            17       preferred candidate for the leadership?

            18   A.  Not that I recall.  I don't think I formed a -- at that

            19       stage a clear view.  I found a leader, actually, as

            20       I was looking at this issue.  I found a leader from the

            21       News of the World where we suggested that it was his to

            22       win, and I think -- I haven't found anything to the

            23       contrary -- I think that's as far as it went, so there

            24       was a -- we certainly weren't against him, put it that

            25       way.


                                            15






             1   Q.  Between December 2005 and January 2007, was the News of

             2       the World slowly moving towards supporting the

             3       Conservative Party at the next election?

             4   A.  I don't think so.  I mean, it was the News of the World

             5       under my editorship that came up with the headline "Hug

             6       a hoodie", and I don't think that was especially helpful

             7       to Mr Cameron, so I don't think that that's the case.

             8   Q.  In paragraph 34 of your statement you talk about the

             9       agenda for your meetings with politicians at around this

            10       time.  You make it clear:

            11           "At no point in any of these conversations was the

            12       potential support of the News of the World ... discussed

            13       and nor indeed were any commercial issues."

            14           And by "commercial issues" you presumably mean the

            15       direct business or commercial interests of News

            16       International, do you?

            17   A.  Yes.

            18   Q.  Did you discuss issues which would nonetheless impact on

            19       the interests of the press more generally such as

            20       conditional fee agreements, appropriate sentencing for

            21       breaches of the Data Protection Act, those sort of

            22       issues?

            23   A.  I don't -- I don't recall doing so, no.

            24   Q.  Human Rights Act, was that a frequent topic of

            25       conversation?


                                            16






             1   A.  That may have come up in conversation.  Yes, that's

             2       possible.

             3   Q.  In the context of the Human Rights Act, were you in the

             4       camp that freedom of the press was to take precedence

             5       over privacy of individuals?

             6   A.  I'm certainly a believer in the freedom of the press,

             7       yes.

             8   Q.  So if there were conversations about the Human Rights

             9       Act, it's clear what your position would have been

            10       during the course of those conversations, isn't it?

            11   A.  Well, I'm certainly a believer in the freedom of the

            12       press.  That much is true.

            13   Q.  In this same period, December 2005 to January 2007, as

            14       regards your dealings with politicians, would it be fair

            15       to say that it was a clear subtext of your dealings with

            16       senior politicians of all three main parties that they

            17       were keen to know whether the News of the World would

            18       support them?

            19   A.  No.  The sort of explicit issue of "will you support us"

            20       has never been asked -- was never asked of me during

            21       that time directly, no.

            22   Q.  Clear subtext.  That's the way I put it, Mr Coulson.

            23   A.  Well, I think that they -- politicians from both sides

            24       in those conversations were seeking to get their message

            25       across and hope that it would be received by us in


                                            17






             1       a positive light.

             2   Q.  Usually in human interactions one knows what the other

             3       person wants out of one.  It's not rocket science, is

             4       it?  This was the clear subtext of your conversations

             5       with politicians, wasn't it?

             6   A.  The agenda for me was to work out in the course of

             7       a conversation whether or not the party or the -- the

             8       politician or the party he represented would best serve

             9       the interests of News of the World readers, and I had

            10       some ideas as to what kind of constituted that.

            11   Q.  Do you think the politicians you spoke to knew that you

            12       were a Conservative Party supporter?

            13   A.  I don't know.

            14   Q.  You refer to a conversation with Mr Brown in 2006,

            15       Labour Conference Manchester, do you see that?

            16       Paragraph 36.

            17   A.  Yes.

            18   Q.  If it was at the Labour Conference in Manchester that

            19       year, we knew, because it was announced, that Mr Blair

            20       would be leaving within the year and therefore in all

            21       probability Mr Brown would be the next Prime Minister.

            22       Are you with me?

            23   A.  I think that was a given, yes.

            24   Q.  You say:

            25           "I remember that meeting well because Mr Brown told


                                            18






             1       me he had it on very good authority that Rupert Murdoch

             2       would appoint me as editor of the Sun when Rebekah was

             3       promoted."

             4           Do you see that?

             5   A.  Yes.

             6   Q.  So he was effectively telling you that it was already

             7       Rupert Murdoch's decision, one, that Rebekah Wade would

             8       be promoted and that, two, you would be in line to be

             9       the next editor of the Sun?

            10   A.  That's what he was saying, yes.

            11   Q.  Why did you take that with a large pinch of salt, as you

            12       say?

            13   A.  Because I didn't frankly believe that Rupert Murdoch

            14       would have had that conversation with him.

            15   Q.  But why not?  He was close to Mr Brown, wasn't he?

            16   A.  My understanding of how News International worked in

            17       terms of appointments of editors is that he would not

            18       have involved a conversation either at that stage, by

            19       the way, because it was some time after that that

            20       Rebekah was promoted, quite some time after that, and

            21       also I just didn't believe it.  I just got -- I came

            22       away believing that this was an attempt by Mr Brown to

            23       sort of impress on me his closeness to Mr Murdoch.  And

            24       quite frankly, I didn't believe it.

            25   Q.  It was certainly an attempt by Mr Brown to impress on


                                            19






             1       you his proximity to Mr Murdoch, that's clear, and that

             2       was the strong message he was transmitting to you, but

             3       his two predictions were right, though, weren't they?

             4   A.  His two predictions were right?  Well, I didn't become

             5       the editor of the Sun.  I would say as predictions go it

             6       was pretty hopeless.

             7   Q.  If certain events hadn't intruded then you might have

             8       become, but Rebekah was promoted, wasn't she?

             9   A.  She was some time later, yes.

            10   Q.  You refer then to Mr Osborne.  You say you met with him

            11       in 2005 -- this is paragraph 37.

            12   A.  Yes.

            13   Q.  Did you get on well with Mr Osborne?

            14   A.  I got on fine.  We didn't spend a lot of tim together,

            15       but I remember having a cup of coffee with him at that

            16       conference.

            17   Q.  You deal in paragraph 38 specifically with a story which

            18       was published in the News of the World in October 2005.

            19   A.  Yes.

            20   Q.  You were asked to deal with that in your witness

            21       statement and you have done.  Can we just understand the

            22       context.  Was the Sunday Mirror also going to publish

            23       the same story?

            24   A.  Yes.  I'm not sure at what point I was aware the

            25       Sunday Mirror were going to publish the story.  They did


                                            20






             1       publish the same story, though, yes.

             2   Q.  On the same Sunday?

             3   A.  Yes.

             4   Q.  And you could anticipate that the Sunday Mirror's

             5       position would be quite hostile to Mr Osborne, couldn't

             6       you?

             7   A.  Well, I didn't know that -- I'm not sure that I knew

             8       they were publishing it, so I hadn't really given that

             9       any thought, but I think it's a given that the

            10       Sunday Mirror is a more left-leaning newspaper and so as

            11       a consequence may have been more critical of Mr Osborne.

            12   Q.  But you knew that the Sunday Mirror had the story, you

            13       knew logically they could only publish it on a Sunday.

            14       In the event, they published it on the same Sunday as

            15       the News of the World.  It was all pointing to the same

            16       date, wasn't it?

            17   A.  I'm not sure that I did know -- at what point I knew

            18       that the Sunday Mirror had the story.

            19   Q.  The story, stripped down to its bare essentials, was

            20       capable of being harmful to the interests of Mr Osborne

            21       self-evidently, wasn't it?

            22   A.  It certainly wasn't helpful.

            23   Q.  Your editorial slant on the story was favourable,

            24       though, to Mr Osborne, wasn't it?  If you look at what

            25       you said, it's under your tab 3, our page 02395.  We're


                                            21






             1       on now 18 October 2005.  The story itself is splashed

             2       over three pages and contains all sorts of detail

             3       I don't think it's necessary for us to go into now, but

             4       of course it's there if anybody want to read it.  But

             5       you were effectively saying that Mr Osborne should be

             6       given another chance, weren't you?

             7   A.  I think the leader was saying that "Here's the

             8       information, here's what he says about it, make up your

             9       own minds".  I think if I were to try and distill the

            10       message of the leader, "Tories' fate is in your hands",

            11       that's how I would distill it.  But Mr Jay, I would say

            12       this: that's the leader column of the News of the World

            13       and as much as I would love to say that the leaders that

            14       I wrote were the most read part of the News of the

            15       World, I think I can safely say that they weren't.  The

            16       front page, "Top Tory, coke and the hooker" I don't

            17       think in any way can be described as career enhancing

            18       for George Osbourne and the idea that we somehow or

            19       other went easy on him I think is ridiculous when you

            20       look at the paper.

            21   Q.  Did you personally write this editorial?

            22   A.  I think I would have contributed to it.  I don't know if

            23       I actually wrote it.  Quite often the process is that

            24       I would have a conversation with another member of staff

            25       and they would write it and then I would edit it or


                                            22






             1       offer a view on it.  Sometimes I would write them

             2       myself.

             3   Q.  Whether there's any underlying evidential basis to the

             4       story is not the purpose of my questions.  You do say in

             5       about the fifth line of the editorial:

             6           "Shadow Chancellor George Osborne was a young man

             7       when he found himself caught up in this murky world."

             8           Do you see that?

             9   A.  Yes.

            10   Q.  Then you say a bit later on:

            11           "Last week we said that the Tory leadership is

            12       Cameron's for the taking.  Nothing published since then

            13       has made us change our mind."

            14           And of course Mr Osborne was going to be

            15       Mr Cameron's number two effectively as Shadow Chancellor

            16       and then, in the events which happened, Chancellor of

            17       the Exchequer, wasn't he?

            18   A.  Yes.

            19   Q.  So this was putting a favourable gloss on quite a murky

            20       world, wasn't it?

            21   A.  It was a view.  It was the paper's view.  And

            22       Mr Osborne -- again, I am not -- I agree, I don't think

            23       we should necessarily go into the detail of the story,

            24       but Mr Osborne was not admitting to anything.  These

            25       were the claims of someone who was a friend of a friend,


                                            23






             1       as I seem to remember, so that was the view formed.

             2       I think probably as a result of a discussion with my

             3       team, that's where we ended up.

             4           And I think it also -- I've taken the time to look

             5       at the Sunday Mirror's leader.  Their leader does not

             6       call for Mr Osborne to be fired.  It stops well short of

             7       that.  I think it's fair to say that it's a bit more

             8       critical, as you'd possibly expect, but it certainly

             9       doesn't suggest that it would be the end of his

            10       political career by any measure.

            11   Q.  Wasn't this a classic example, let me put it in these

            12       terms.  The News of the World couldn't resist the scoop.

            13       It was, after all, in the eyes of the News of the World

            14       a great story, so we're going to publish it for what it

            15       is, but then let's gloss it in the editorial and put

            16       perhaps the most favourable interpretation that could be

            17       put on the story.  Is that fair or not?

            18   A.  I don't think it is and I just think if you're looking

            19       for an example of the News of the World being helpful to

            20       the Conservative Party, this is, with the greatest of

            21       respect, a pretty poor example.  What matters here is

            22       what's on the front page and what the headline is on

            23       pages 4 and 5.

            24           As I look at this front page now, I'm reminded that,

            25       had we not had a DVD promotion that day, this story


                                            24






             1       would have been twice the size, and that's -- you know,

             2       that's all I can say.  Compare that to the leader

             3       column.  I just don't think that holds.

             4   Q.  Would you have buried the story altogether if you knew

             5       the Mirror were not going to splash it?

             6   A.  No.  Certainly not.

             7   Q.  Yes, the free DVD was all about Little Britain.  That

             8       takes up half the front page.  We can see the other

             9       half.  It's a standard News of the World splash, isn't

            10       it?

            11   A.  I don't think it's standard, necessarily, but it was

            12       a News of the World story.  It was also a Sunday Mirror

            13       story and I think I'm right in saying that other

            14       newspapers followed it subsequently.  It still gets

            15       a reasonable amount of coverage in the Guardian.

            16   Q.  I think I've taken that point as far as it can go,

            17       Mr Coulson.  January 2007, you resign.  Were there any

            18       discussions with Mr Hinton before your resignation?

            19   A.  Well, there was the conversation about my resignation,

            20       yes.

            21   Q.  Did you have any discussions with Mr Murdoch before you

            22       resigned or not?

            23   A.  No.

            24   Q.  You've included your severance agreement, which is under

            25       AEC1, described as a compromise agreement.  The


                                            25






             1       narrative starts at page 02379.  We can see it's dated

             2       26 February 2007.  Do you see that, Mr Coulson?

             3   A.  Yes.

             4   Q.  Which I think is exactly a month after you resigned; is

             5       that right?

             6   A.  Yes.  I resigned two weeks before I actually left.  So

             7       I resigned -- that conversation that I mentioned with

             8       Les Hinton took place two weeks before I actually left

             9       the building.

            10   Q.  So you weren't resigning on the basis that you would

            11       walk away from any contractual benefits you might

            12       attain, you were resigning on the basis that you would

            13       leave consensually, is that fair?

            14   A.  Yes.  Well, it was my decision.  There wasn't a sort of

            15       negotiation or a discussion about whether or not I would

            16       or I wouldn't.  I went to see Les Hinton and I was very

            17       clear that I was going to resign, and then I did so.

            18   Q.  Under clause 3, 02380, you received both payment in lieu

            19       of the employer's contractual notice period and

            20       compensation for termination of employment, so there are

            21       two separate tranches, aren't there?

            22   A.  Yes.

            23   Q.  The last tranche is going to be paid in November 2007.

            24       From your own experience, was that standard practice or

            25       not in severance agreements of this sort?


                                            26






             1   A.  Well, I'd never resigned before, so I don't know whether

             2       or not this is the format that was followed, personally.

             3       I'm told that the sort of separating out of payments in

             4       this way is a reasonably standard practice, but I'm not

             5       an employment lawyer so I can't be certain of that.

             6   Q.  There's reference in the agreement, if you look at

             7       clause 4.2, 02381, it's quite a complicated clause but

             8       it effectively means that the restricted stock units

             9       which were going to vest in you in August 2007 would

            10       continue to vest in you notwithstanding your

            11       resignation, do you see that?

            12   A.  Yes.

            13   Q.  As at that stage, did you also have stock in News

            14       International as opposed to News Corporation?

            15   A.  I had shares in News International, which I think I sold

            16       before I left the company, before I resigned, and there

            17       may have been some shares I had around this time that

            18       I sold immediately on leaving.

            19   Q.  Can I be clear, apart from the restricted stock units

            20       which were going to vest in you in August 2007, were

            21       there any other shares or stocks either in News

            22       International or in News Corporation, say, by May 2007,

            23       in your possession?

            24   A.  I don't believe so, no.  No.

            25   Q.  In clause 4.6 there is the provision that the employer


                                            27






             1       will pay any reasonable professional costs and expenses

             2       properly incurred by you in relation to certain matters.

             3       That clause, I think, is subject to litigation in the

             4       Court of Appeal, isn't it?

             5   A.  That's right.

             6   Q.  The last clause, under clause 7.1(b), this is 02382, you

             7       agreed that in consideration of a small payment you

             8       will:

             9           "... not make or cause to be made, directly or

            10       indirectly, any statement or comment to any person

            11       (including, without limitation, to the press or any

            12       other media) which might injure, damage or impugn the

            13       good name, reputation or character of the employer, any

            14       of its newspapers and/or any associated company

            15       (including any of its or their directors, officers,

            16       employees or shareholders)."

            17           Has that provision in any way impacted on the

            18       evidence you're giving us?

            19   A.  No.

            20   Q.  Do you know what it means?

            21   A.  I think so, yes.

            22   Q.  Okay.  When you resigned as editor of the News of the

            23       World, did you receive any commiserations from Mr Blair?

            24   A.  Yes, sometimes later, yes.

            25   Q.  Mr Brown?


                                            28






             1   A.  Yes.

             2   Q.  Mr Cameron?

             3   A.  I don't remember doing so, no.

             4   Q.  You were approached by Mr Osborne in March 2007.  This

             5       is paragraph 29 of your statement.  Our page 02412.

             6       Paragraph 29, Mr Coulson.

             7   A.  Thank you.

             8   Q.  You met for a drink and he asked you in effect whether

             9       you would be interested in joining the team.  It goes

            10       without saying that Mr Osborne knew that your natural

            11       sympathies were with the Conservative Party?

            12   A.  I don't know, you'd have to ask Mr Osborne what his

            13       thinking was, but certainly he approached me with the

            14       view that I could be a positive asset rather than

            15       a negative one, I'm sure.

            16   Q.  I think it's pretty obvious that he did know, otherwise

            17       he would have gone to someone else, wouldn't he?

            18   A.  Well, in any event, he was correct.

            19   Q.  At that stage did you know if anybody else was in the

            20       running for the job?

            21   A.  No.

            22   Q.  At any later stage, did you know whether anybody else

            23       was in the running for the job?

            24   A.  No.  At a later stage, after I'd started working for the

            25       Conservatives, I was told that there had been another


                                            29






             1       journalist, a BBC journalist, who had been -- had had

             2       a discussion, I think with Mr Cameron, quite some time

             3       before I was considered for the job, and for whatever

             4       reason that didn't work out.

             5   Q.  So this is the journalist whose name has come up in this

             6       context, isn't it?

             7   A.  Guto Harri, yes.

             8   Q.  What did Mr Osborne say that you could offer the

             9       Conservative Party?

            10   A.  The conversation really was more around my views of how

            11       the party should organise its communications in advance

            12       of a General Election.  Of course, we had no idea at

            13       that stage when the election might be.  And so I gave my

            14       views.

            15   Q.  What did you tell him?

            16   A.  I told him that my view of communications was that it

            17       needed to be first and foremost professional, that we

            18       needed to have good relationships with as many media

            19       representatives as possible right across the spectrum,

            20       and I also told him in that conversation and again later

            21       in a conversation with Mr Cameron that my firm belief

            22       was that television would play a crucial part in any

            23       General Election campaign.  My view was more so than it

            24       had done previously.

            25   Q.  You had no political experience, did you?


                                            30






             1   A.  No.

             2   Q.  You'd never been a political editor of any newspaper,

             3       had you?

             4   A.  No.

             5   Q.  Didn't Mr Osborne at least indicate what he thought or

             6       the Conservative Party thought you might bring to the

             7       table?

             8   A.  I think I was the editor of a national newspaper.  I'd

             9       been in newspapers for a long time.  I had managed

            10       a team, motivated a team.  I'd kind of, you know, had

            11       a hand in running a business, I suppose, in terms of the

            12       commercial aspects of the newspaper.  As I say, not

            13       forensically, that was the managing editor's job, but

            14       I had oversight of it.  So I'm sure those were

            15       considerations.

            16   Q.  But all those considerations would demonstrate, as I'm

            17       sure was the case, that you were a good editor, but

            18       that's not what we're talking about here.  We're talking

            19       about you being Director of Communications for the

            20       Conservative Party in Opposition.  What qualities did he

            21       say, if any, you might bring to the table?

            22   A.  I don't know.  I don't want to be obstructive, but

            23       I think that's going to be a question for Mr Osborne.

            24       I didn't -- the conversation was not, "Andy, here's why

            25       we think you're going to be great".  I don't recall it


                                            31






             1       that way at all.  The conversation was very much, "What

             2       do you think we need to do to get elected?"

             3   Q.  It was in part an interview, but at what point did he

             4       say, "Are you interested in this job"?

             5   A.  In truth it didn't feel like an interview at all.

             6       I think it was clear from the off that they were

             7       interested in hiring me.

             8   Q.  Exactly.

             9   A.  And he said that they were going to make changes to the

            10       professional set-up and that -- and that he would like

            11       me to meet Mr Cameron.

            12   Q.  So he'd already identified you as the man the

            13       Conservative Party wanted, hadn't he?

            14   A.  Well, I don't think he would have called me unless I was

            15       at the very least on the list.  And I had no idea at

            16       that point --

            17   Q.  This might have been an interview, it might have been

            18       "Let's see what Mr Coulson's like, let's ask him a few

            19       questions and we'll go away and think about it".  It

            20       doesn't appear to have been like that though,

            21       Mr Coulson, does it?

            22   A.  We'd met a couple of times previously.  Look I don't

            23       know what was in George Osborne's mind --

            24   LORD JUSTICE LEVESON:  Let's forget anything about

            25       Mr Osborne.  Let's think about you.  You're a newspaper


                                            32






             1       man.  You're used to selling ideas, selling stories.

             2       Did you not see this conversation as selling yourself?

             3       That's what most people do in interviews, isn't it?

             4   A.  Well, I wasn't going into it as an interview.  Actually

             5       I went into it, sir, with a degree of reluctance.  So

             6       I wasn't really thinking about politics until I got the

             7       call.

             8   LORD JUSTICE LEVESON:  Once you met him and it was

             9       abundantly clear what they were talking about, how did

            10       you put your view across to them that actually it might

            11       be a good idea for them to offer you a job?  Or maybe

            12       you didn't?

            13   A.  In the way I that I described, I gave an outline in the

            14       conversation with Mr Osborne as to what I felt from my

            15       experience in the media the party needed to do to give

            16       itself the best chance to be elected.  That conversation

            17       touched on the print media, of course, because that's my

            18       experience, but I remember very well saying to

            19       Mr Osborne and later to Mr Cameron that television is

            20       going to be hugely important.  By the way, hardly

            21       a stunning observation, but one that I was very clear in

            22       my mind and I was already thinking at that stage about

            23       the possibility of TV debates as well.

            24   MR JAY:  Did it not occur to you, you say you became more

            25       intrigued as the conversation went on, and presumably


                                            33






             1       you went away to think about it.  Did it not occur to

             2       you: "Why are they asking me to do this job"?

             3   A.  Possibly it did.  But once that first conversation was

             4       under way, Mr Osborne said, "I want you to meet with --

             5       talk to and meet with Mr Cameron", and then the process

             6       sort of went on from there.

             7   Q.  But you're entering terrain which is rather different

             8       from 17, 18 years of career.  Career in journalism, you

             9       end up as an editor of the largest circulation newspaper

            10       in the United Kingdom, in the English-speaking world,

            11       and now you're asked to do something completely

            12       different.  Doesn't it pass through your mind: "Why are

            13       they asking me to do this"?

            14   A.  Well, something completely different.  I'd been the

            15       editor of a national newspaper for a number of years.

            16       That involved politics, as we've discussed.  And beyond

            17       the sort of stories that you've alighted on, Mr Jay.

            18       You know, I was dealing in issues.  I ran campaigns.

            19       I was -- I hope, at least aimed to be -- in tune with

            20       the readership of a newspaper that is vast -- or was

            21       vast.  And I think those things, I'm sure, were

            22       attractive.

            23           If I can add, the route from journalism to politics,

            24       you know, I was hardly the pioneer.  There had been

            25       several people through the history of politics who had


                                            34






             1       gone from newspapers into politics.

             2   Q.  Yes.  Mr Alastair Campbell, of course, had been

             3       political editor of the Daily Mirror, I believe, and

             4       then became Director of Communications.  That may or may

             5       not have been a more natural pathway, but you didn't

             6       enjoy that previous sort of career, did you?

             7   A.  No, but one might argue that an editor of a newspaper

             8       going into politics is as appropriate.

             9   Q.  What about your connections to News International?  Did

            10       Mr Osborne mention those?

            11   A.  I don't remember that being a specific conversation at

            12       that point, no.

            13   Q.  Thinking about it --

            14   A.  There may well have been a conversation about, you know,

            15       the fact that I worked on the News of the World and

            16       maybe we discussed some individuals in that regard.

            17       I don't really remember, but I'm sure that the

            18       conversation would have touched on my previous employers

            19       in some way.

            20   Q.  It was the elephant in the room, wasn't it?

            21   A.  Not really, no.

            22   Q.  You were close to Mrs Brooks -- or Ms Wade as she then

            23       was, weren't you?

            24   A.  We were friends, yes.

            25   Q.  You had, you've told us, a warm relationship with


                                            35






             1       Mr Murdoch.

             2   A.  As an editor and employer, yes.  It didn't go beyond

             3       that.

             4   Q.  Mr Osborne, the Conservative Party knew all of that,

             5       didn't they?

             6   A.  I'm sure, yes.

             7   Q.  You also, if I can put it sort of empathetically,

             8       understood the viewpoint of the sort of floating voter

             9       which would be particularly interesting to the

            10       Conservative Party?

            11   A.  That may have been a consideration, yes.

            12   Q.  But all these considerations were ones which certainly

            13       passed through your mind, didn't they?

            14   A.  They may well have done and they may well have done for

            15       Mr Osborne.

            16   Q.  They did, didn't they?

            17   A.  I can't tell you what Mr Osborne was thinking.  In terms

            18       of my thinking, I, as I say, went into the meeting,

            19       I didn't see it as an interview.  It was a meeting with

            20       George Osborne, and my initial reaction to it was

            21       frankly slightly reluctant but I was intrigued and I had

            22       further conversations and then over time decided that,

            23       yes, this is something that I wanted to do.

            24   Q.  Okay.  There were further conversations, as paragraph 30

            25       of your statement makes clear.  I just want to ask you


                                            36






             1       this simple question: did either Francis Maude or

             2       Ed Llewellyn raise the issue of the Goodman/Mulcaire

             3       case with you?

             4   A.  I don't remember but it's possible.

             5   Q.  You say at the end of paragraph 30 that towards the end

             6       of May 2007 they, that's the conversations, were

             7       restarted and after further conversations with

             8       Mr Cameron and others you were offered the job of

             9       Director of Communications and Planning.

            10           Can I just understand the timing in the context of

            11       the last question I asked you?  Were you offered the job

            12       after the conversation which might have taken place with

            13       Mr Maude and Mr Llewellyn?  Can you remember that?

            14   A.  I think the conversation with Mr Cameron in May was --

            15       I considered in my mind to be the confirmation that

            16       I was taking the job.  It may well be in those

            17       conversations leading to that that the process of my

            18       joining -- you know, perhaps even an offer letter,

            19       I can't remember, or the terms were discussed in

            20       advance, but in my mind, that conversation when I was on

            21       holiday in Cornwall was the sort of confirmation.

            22   Q.  You say in paragraph 31 of your statement -- this is the

            23       conversation you've just been referring to:

            24           "He [that's Mr Cameron] also asked me about the

            25       Clive Goodman case."


                                            37






             1           Can you remember the gist of your answer?

             2   A.  I was able to repeat what I'd said publicly, that I knew

             3       nothing about the Clive Goodman and Glenn Mulcaire case

             4       in terms of what they did.

             5   Q.  Did the formal job offer follow that conversation on the

             6       mobile phone with you in Cornwall and Mr Cameron

             7       wherever he was?

             8   A.  In terms of paperwork, in terms of the offer letter and

             9       when it was a contract signed, I can't remember the

            10       exact timing.  I think it was afterwards.

            11   Q.  Can I ask you about the timing of your conversations

            12       with Rebekah Wade as she was, paragraph 32 of your

            13       statement.

            14   A.  Yes.

            15   Q.  You say:

            16           "At some point I told her and other close friends

            17       [you were] in discussion with the Conservatives."

            18           Might that have been in May or earlier?

            19   A.  I can't remember the timing but I know I told my --

            20       a close group of friends, small number of friends, and

            21       I'm sure that Rebekah was among them, that I was going

            22       to take this job.

            23   Q.  What was her reaction?

            24   A.  I think she would have congratulated me.

            25   Q.  Was she pleased or not, do you think?


                                            38






             1   A.  I think so, yes.  I certainly don't remember her saying

             2       otherwise.

             3   Q.  Do you know whether she had any influence or otherwise

             4       over you getting the job?

             5   A.  Not that I can recall, no.

             6   Q.  Were there any conversations with her at any stage which

             7       you had with her which might have indicated that she had

             8       an influence over you getting the job?

             9   A.  No, not that I can remember.

            10   LORD JUSTICE LEVESON:  Could I just go back?  You say that

            11       you met Mr Cameron and there isn't a trap or a trick in

            12       the question I'm asking, I'm just keen to understand it.

            13       You didn't appreciate when you started to chat to

            14       Mr Osborne that this was an interview, but by the time

            15       you were going to meet Mr Cameron, you knew exactly what

            16       was happening?

            17   A.  Yes.

            18   LORD JUSTICE LEVESON:  I'm going back to the question

            19       I asked before: did you formulate in your mind and did

            20       you have to explain what it was that you were bringing

            21       to, if you like, the party?  What skills you actually

            22       could bring to the party?  Did you sell yourself to him?

            23   A.  I'm sure I tried to talk in the most favourable light

            24       for myself, without sitting there and being an appalling

            25       bighead.  I'm sure I tried to -- in the conversation


                                            39






             1       I would have tried to impress on him that I could do

             2       a good job, yes.

             3   LORD JUSTICE LEVESON:  What I'm keen to understand is what

             4       it was that you were able to point to in your history

             5       makeup, and I understand the problem about boasting,

             6       being bigheaded, I understand that, but to demonstrate

             7       that actually this could be a sensible move for them?

             8       What was it?

             9   A.  Well, I think it's my broad experience and my experience

            10       went across from 1998 when I stopped working as

            11       a showbusiness reporter, I was involved across the paper

            12       in all manner of -- both the Sun and the News of the

            13       World, and indeed I'd worked for nine months on the

            14       Internet launching a whole series of websites.  So I may

            15       well have mentioned that, and I think through the

            16       conversation they may well have been -- I wasn't

            17       necessarily aware of it, but they may well have been

            18       trying to tease out whether or not I was the right man

            19       for the job and that conversation may well have gone to

            20       my background and where I grew up and those kind of

            21       things.  That's more than possible.

            22   MR JAY:  Paragraph 42 now, please, Mr Coulson.  You say:

            23           "Whilst my News International background may have

            24       been considered useful by the Conservatives when

            25       considering me for the post, it was not specifically


                                            40






             1       discussed as being an advantage."

             2           So that's your best recollection, is it?

             3   A.  It is my best recollection, and as I think I've put in

             4       my statement, I do remember explaining that my News

             5       International background -- this was not suggested by

             6       either Mr Osborne or Mr Cameron, this was introduced

             7       into the conversation by me -- that my News

             8       International background should not therefore be seen as

             9       some sort of, you know, a guarantee of the support of

            10       either of those papers.

            11   Q.  Plainly it couldn't be a guarantee, but it might be

            12       a factor, mightn't it?

            13   A.  Well, my experience might help in terms of connecting

            14       with News of the World readers and connecting with Sun

            15       readers, yes.

            16   Q.  And also your personal connections, they would help,

            17       wouldn't they?

            18   A.  Well, they wouldn't hurt, but I don't take the view

            19       that -- and I certainly didn't ever express the view

            20       that they would, as I say, guarantee any kind of

            21       support.

            22   Q.  I'm not talking about you expressing a view, nor am

            23       I talking about guarantee.  What I'm saying is that your

            24       personal connections would help, wouldn't they?

            25   A.  They would, and my personal connections went well beyond


                                            41






             1       News International.

             2   Q.  Was it your assessment that at about this time

             3       Mrs Brooks was becoming a very influential figure?

             4   A.  I would say she was pretty influential before that.

             5   Q.  Okay.  An even more influential figure?

             6   A.  Quite possibly.  I don't know where she was in terms of

             7       her career precisely at that moment.

             8   Q.  She was still editor of the Sun, wasn't she?

             9   A.  Still editor of the Sun.

            10   Q.  Her star was in the ascendant, wasn't it?

            11   A.  I wasn't there any more, but I think that's fair to say,

            12       yes.

            13   Q.  Politicians were very keen to get close to her, weren't

            14       they?

            15   A.  I think that is fair to say, that they wanted to get

            16       their message across to the Sun, I'm sure.  Politicians

            17       from all parties.

            18   Q.  But in order --

            19   A.  The two main parties.

            20   Q.  In order to get your message across to the Sun, the best

            21       lightning rod was Mrs Brooks, wasn't she?

            22   A.  I think if you're a politician, you have the opportunity

            23       to talk to an editor, you will take it and you'll

            24       attempt to sell yourself and your party in the best

            25       possible light.


                                            42






             1   Q.  She of course was then and no doubt still is a very

             2       powerful personality.  Is that your assessment?

             3   A.  She's a strong personality.

             4   Q.  Very powerful personality?

             5   A.  I think I'd say strong personality.  I don't know about

             6       power.

             7   Q.  Vis-a-vis the News of the World, you explained to

             8       Mr Cameron -- I'm sure he understood this anyway -- that

             9       you wouldn't get an easy ride from that paper because

            10       Mr Myler, the then editor, was more sympathetic to the

            11       Labour Party, is that the gist of it?

            12   A.  Yes.  I don't want to overstate this, but I never worked

            13       with Mr Myler so I couldn't say with any degree of

            14       certainty, but certainly from what I knew of him, and

            15       I knew him sort of briefly, he worked for another

            16       Rupert Murdoch paper in New York and we would see each

            17       other occasionally at conferences, but his background

            18       was with Mirror Group and my understanding through

            19       mutual friends and through conversations with him was

            20       that he was more likely to be left-leaning.  I don't

            21       want to suggest that that would necessarily impact on

            22       the decisions he was making, but that was my sense.

            23   Q.  So in early discussions with Mr Cameron, where you were

            24       discussing likely support of different newspapers for

            25       the Conservative Party, the message you were getting


                                            43






             1       across to him was that the News of the World certainly

             2       wasn't in the bag because Mr Myler was not onside, is

             3       that fair?

             4   A.  I'm not sure I used those words, but I think that was

             5       the sort of essence, yes.

             6   Q.  The premise of the conversation was that Mr Cameron was

             7       interested to know how the News of the World might go at

             8       the next election in terms of the support it offered; is

             9       that right?

            10   A.  Well, with regard to this conversation, as I said

            11       earlier, I think this is a conversation that

            12       I instigated.  I'm not sure that David Cameron ever said

            13       to me, "Have we got the News of the World in the bag,

            14       Andy?"  I think this is a conversation that

            15       I introduced.

            16   Q.  And the reason why you introduced it is that you felt

            17       that Mr Cameron might benefit from your insights?

            18       Correct?

            19   A.  No, the conversation went further and we discussed other

            20       newspapers as well.

            21   Q.  Certainly.  It's not just the News of the World, it's

            22       the Sun, because as you say, also in paragraph 42:

            23           "I told David Cameron, in one of our first

            24       discussions, that he should not" -- sorry, that's the

            25       News of the World.


                                            44






             1           "Mr Cameron knew Rebekah Brooks and I were friends,

             2       but again I made clear, and he understood, that this did

             3       not mean that the Sun would endorse us."

             4           So again the premise of the conversation was, or the

             5       interest from Mr Cameron perhaps for you was: how would

             6       you the Sun go in the next election?

             7   A.  Yes, but as I say, I started that conversation.

             8   Q.  The Sun in particular was of interest to Mr Cameron,

             9       wasn't it?

            10   A.  Yes.

            11   Q.  Why do you think that was?

            12   A.  Its circulation.

            13   Q.  Not just circulation.  It contains a significant number

            14       of so-called floating voters, doesn't it?

            15   A.  Within its circulation, yes.  Sorry.

            16   Q.  So in terms of the most important newspaper, if you had

            17       to identify one, whose support a political party might

            18       wish to attain, the Sun would always be top of the tree,

            19       wouldn't it?

            20   A.  If you wanted to look at it in terms of circulation,

            21       yes, because it has the biggest circulation, but I took

            22       a view that there were a number of other newspapers that

            23       we needed to work hard to gain the support of and

            24       circulation wasn't -- I didn't -- I didn't look at my

            25       working day and analyse it based on circulation.  I put


                                            45






             1       a lot of effort into trying to secure the support of the

             2       Sun.  I did exactly same to the Daily Mail.  I put a lot

             3       of time and work into the Daily Telegraph and other

             4       newspapers too.

             5   Q.  I'm not sure I was suggesting that you would lavish all

             6       your efforts on the Sun to the extent you would ignore

             7       all the others.  All I was suggesting was that the Sun

             8       was the most important.  Are we in agreement or not?

             9   A.  In terms of circulation, yes.

            10   Q.  In terms of influence on the floating voter?

            11   A.  I don't know.  I'm not sure I necessarily buy the theory

            12       that a newspaper's endorsement will influence its

            13       readers directly in that way.

            14   Q.  Do you think politicians buy into that theory?

            15   A.  I think that is a theory that is becoming less and less

            16       popular amongst politicians.

            17   Q.  Yes, but in the times we're talking about, the run-up to

            18       the 2010 election, is it a theory do you think the

            19       politicians were still buying into?

            20   A.  I think that we wanted the support of the Sun.  We

            21       wanted the support of as many newspapers as we possibly

            22       could, and we didn't know when the election was going to

            23       be, and so work had to be put into that.

            24           Can I just make a point that I touched on earlier?

            25       Newspapers were not the only focus, by any measure, of


                                            46






             1       our communications.  Television was fundamentally

             2       important and we were clear that television was

             3       fundamentally important to us from the off.

             4   LORD JUSTICE LEVESON:  That's as a mechanism for

             5       communication.

             6   A.  Yes.

             7   LORD JUSTICE LEVESON:  Television was going to be bound to

             8       have to be impartial.

             9   A.  Yes, but --

            10   LORD JUSTICE LEVESON:  Whereas newspapers don't have that

            11       limitation.

            12   A.  No, sure, and there are -- you know, the conversations

            13       that you have with a newspaper are different to the

            14       conversations that you'd have with the BBC, for example,

            15       but in terms of planning a strategy, you know, and the

            16       people that you wanted to try and have good

            17       relationships with, the people that you would spend your

            18       time talking to, where you would try and explain and

            19       give the best possible light to your policies,

            20       television was crucial for that.  As crucial, I would

            21       say, as newspapers, and in fact as we got closer to the

            22       General Election I would say even more so.

            23   MR JAY:  Planning your strategy in relation to the print

            24       media -- put the broadcast media to one side -- were

            25       there not two key elements to this?  First of all, you


                                            47






             1       had to do your best to secure the support of the Sun in

             2       due course, are we agreed?

             3   A.  That was certainly an aim.

             4   Q.  In order to secure the support of the Sun, the best way

             5       in, as it were, the best entree, was Rebekah Brooks, are

             6       we also agreed?

             7   A.  Whilst Rebekah was editor of the Sun?

             8   Q.  Yes.

             9   A.  I wouldn't describe it in that way.  I was keen actually

            10       that we had good relationships throughout -- as much as

            11       we could throughout the paper.  Same goes for -- if

            12       I can keep adding this -- for other newspapers.  It is

            13       not -- newspapers don't work that way.  You know, you

            14       can't rely on a call to an editor to guarantee anything,

            15       and nor should you.  What you were attempting to do was

            16       build a series of relationships where when you had

            17       something positive to say you would give yourself the

            18       best possible chance of getting the best possible

            19       coverage, and so it was actually a range of

            20       relationships throughout all the newspapers.

            21   Q.  Certainly.  You would not wish to ignore any particular

            22       newspaper, even those you felt were, as it were, lost

            23       causes.  You even mention the Guardian, don't you, at

            24       one point in your evidence?

            25   A.  That's right.  I think the party had very good


                                            48






             1       relationships with the Guardian.  I think I probably

             2       wouldn't include the Daily Mirror, in truth, or the

             3       Sunday Mirror.  I doesn't put an awful lot of effort

             4       into either of those papers, although we met and we

             5       talked, actually.  But yes, I -- and more importantly

             6       David Cameron -- took the view that we had to talk to as

             7       many people as possible.  The Tories had a -- the party

             8       had an electoral mountain to climb, it was of historic

             9       proportions.  So we wanted to touch as many readerships

            10       as we possibly could and get our message across as far

            11       and wide as we could.

            12   Q.  Did you advise Mr Cameron that it was essential that he

            13       became as close as he could to Mrs Brooks?

            14   A.  No.

            15   Q.  Or did he work that out anyway?

            16   A.  There was a family connection.  She was a constituent.

            17       Charlie Brooks is a constituent of his, so they live

            18       relatively close to his constituency home, but there

            19       was, I think, a fairly long-established family

            20       connection, and I think that was the genesis of it.

            21   Q.  May I ask you about two perceptions.  I think we covered

            22       one of them, namely whether influential papers have

            23       a hand in the outcome of elections and you've given your

            24       evidence on that.  What about this second perception,

            25       that there's an implied trade-off for support.  It might


                                            49






             1       not be the furnishing of direct commercial favours, it

             2       might well be the dissemination of a more favourable

             3       climate on issues and policies relevant to the media.

             4       Do you think there's any validity in that, at least on

             5       the level of perception?

             6   A.  I don't, really.  I think that there's -- in the course

             7       of a -- in the course of the election campaign there are

             8       issues that a whole range of newspapers would consider

             9       to be important to them and where our policies

            10       overlapped with those newspapers' campaigns or aims,

            11       I would seek to maximise that.  But then once in

            12       government, you get on with the business of governing

            13       and obviously politicians set out to keep their

            14       promises, so if you've in the course of those campaigns

            15       given certain promises, you do your best to keep them.

            16       Of course, we ended up with a Coalition government that

            17       made that a more complex process, but --

            18   Q.  The Prime Minister said in July 2011 words to the effect

            19       that "We all got too close to News International".  You

            20       probably recall that, Mr Coulson, don't you?

            21   A.  Yes.

            22   Q.  Is that a view he expressed to you before July 2011, in

            23       particular before you left, which I think was in January

            24       2011?

            25   A.  No, I don't remember him doing so.


                                            50






             1   Q.  You said in your statement words the effect you almost

             2       had to persuade him to meet with journalists because it

             3       was so important, but you think he probably would have

             4       preferred to be doing other work or enjoying a night at

             5       home with his family.  This is paragraph 78.  Did he

             6       ever express disgruntlement to you that he had to spend

             7       so much time with journalists and editors as part and

             8       parcel of the job, as it were?

             9   A.  Frequently.

            10   Q.  Was it ever in the context not merely is this

            11       subtracting from my quality time with my family, but

            12       there's a deeper problem here, the perception of getting

            13       too close to one newspaper group or perhaps more than

            14       one newspaper group?  Were there discussions in that

            15       sort of frank way?

            16   A.  Not that I recall, no.

            17   Q.  It follows then that you must have been surprised when

            18       he said publicly in July 2011, "We all got too close to

            19       News International"; is that right?

            20   A.  I don't know if I was surprised.  I mean, it came after

            21       a chain of events.  I don't know what his thinking was

            22       behind it.  I wasn't there.

            23   Q.  But ignoring what his thinking was, just asking you what

            24       your thinking is or was, do you feel that politicians

            25       got too close to News International or not?


                                            51






             1   A.  I look at it from the perspective of whether or not

             2       there was improper conversations or a deal done, which

             3       I think is all part of this sort of grand conspiracy

             4       that sort of sits over this idea, and I never, as I've

             5       said clearly in my statement, I never saw

             6       a conversation, was party to a conversation that to my

             7       mind was inappropriate in that way.

             8   Q.  Can I suggest, Mr Coulson, try not to look at this too

             9       literally.  You remember when Mr Murdoch gave his

            10       evidence he denied many, many times there were no

            11       express deals, but we're not talking about inappropriate

            12       conversations necessarily or express trade-offs.  We're

            13       talking about something a little bit more subtle.  Don't

            14       you agree that there is at least the valid basis for the

            15       perception that this closeness is unhealthy?

            16   A.  The word "unhealthy" I think sort of implies

            17       impropriety, and I'm not sure I agree with that.  As

            18       I sit here now, I've been out of politics for quite some

            19       time, I think things are going to change, I think things

            20       have already changed, and I think actually that process

            21       may even have begun while I was there.  We were the

            22       first government ever to be transparent with the

            23       meetings that we were having with the media, so maybe

            24       that process had already started to kind of enter into

            25       people's minds.


                                            52






             1   Q.  I think the transparency wasn't introduced until July

             2       2011, but we'll be hearing evidence about that in due

             3       course.

             4   A.  I'm not sure that's right, Mr Jay, with respect.

             5       I think that we made public some special adviser

             6       meetings with the media while I was still there.

             7   Q.  Okay.

             8   A.  So that was in -- that was in 2010.

             9   Q.  Can I ask you, please, to go back in your statement now

            10       to paragraph 45, which is page 02415?

            11   LORD JUSTICE LEVESON:  Mr Jay, at some stage we ought to

            12       have a break.

            13   MR JAY:  Yes, let's break now.

            14   LORD JUSTICE LEVESON:  Let's do that.  We'll give Mr Coulson

            15       a few minutes and the shorthand writer a few minutes.

            16       Thank you.

            17   (3.14 pm)

            18                         (A short break)

            19   (3.24 pm)

            20   MR JAY:  Mr Coulson, we're on paragraph 45 of your witness

            21       statement, the RSUs, which we saw in your compromise

            22       agreement.

            23   A.  Yes.

            24   Q.  Going to vest in August 2007, and indeed they did

            25       presumably vest on that occasion, didn't they?


                                            53






             1   A.  Yes.

             2   Q.  Is this right, Mr Coulson, that when you took up your

             3       job I think in June or July 2007, you had no shares or

             4       stocks either in News International or News Corporation,

             5       but then in August 2007 these restricted stock units

             6       vested in you?

             7   A.  No, I think there's a first tranche of restricted stock

             8       units that were granted to me before I left

             9       News International that had already vested and then

            10       a second set that were the subject of this compromise

            11       agreement then vested in August.

            12   Q.  Do you know the approximate value of these stocks?

            13   A.  I didn't throughout any time in opposition or in

            14       government, but in preparation for today I've checked

            15       and yes, their gross value is around £40,000.  What

            16       deductions would come from that, I'm not clear.

            17   Q.  And are these RSUs saleable on the open market or not?

            18   A.  I think so.

            19   LORD JUSTICE LEVESON:  Once they've vested?

            20   A.  Yes.

            21   MR JAY:  Why do you think you overlooked them?

            22   A.  This is by way of explanation, not excuse.  My job in

            23       opposition was a busy one.  My job in government was

            24       busier still, and I didn't take the time to pay close

            25       attention to my own circumstances in this regard, and


                                            54






             1       I should have done.

             2   Q.  The more important question might be this: did you

             3       discuss their existence with anybody in the Conservative

             4       Party or then in government?

             5   A.  No.

             6   Q.  Did you discuss their existence with any civil servant?

             7   A.  No.

             8   Q.  Paragraph 48 you deal with your vetting status.  Do you

             9       happen to know what your vetting status was?

            10   A.  I do now.  I didn't then.

            11   Q.  What is it or was it?

            12   A.  SC, I believe.

            13   Q.  And that means?

            14   A.  I think it means security check.

            15   Q.  So it's at least a step short of DV, which is developed

            16       vetting?

            17   A.  Yes.

            18   Q.  Which is the standard vetting, I think, for someone in

            19       your position; is that correct?

            20   A.  I don't know that that's the case, no.

            21   Q.  Did you have any unsupervised access to information

            22       designated top secret or above?

            23   A.  I may have done, yes.

            24   Q.  Did you ever attend meetings of the National Security

            25       Council?


                                            55






             1   A.  Yes.  My understanding, Mr Jay, if I can, is that the SC

             2       level allows occasional access to top secret paperwork

             3       and also participation in sensitive meetings as well.

             4       I believe that's right.

             5   Q.  Okay.  I'm not quite sure I understand what you're

             6       saying in paragraph 48 in relation to an incident at

             7       Midlands Airport in the autumn of 2010.

             8   A.  Yes.

             9   Q.  Are you saying that someone thought that your vetting

            10       status was inadequate?

            11   A.  Effectively, yes.  I think that there was a meeting that

            12       involved a discussion about the communications around

            13       that issue or incident and the view was formed that

            14       I should have been in the meeting but to be in that

            15       meeting I would -- my vetting status would need to be

            16       changed.  I don't know what stage that process had got,

            17       because obviously events overtook and I left in January.

            18   Q.  To be fair to you, these were all matters which it was

            19       for government to sort out, not for you?

            20   A.  Yes.

            21   Q.  After publication of the piece in the Guardian in July

            22       2009, were any further assurances sought by Mr Cameron

            23       or anyone else on his behalf in relation to the

            24       Goodman/Mulcaire matter?

            25   A.  Not that I recall.


                                            56






             1   Q.  Between July 2009 and May 2010, if I can get your

             2       bearings now, do you recall having discussions with

             3       Mr Myler or anyone else at the News of the World as to

             4       who they would support at the next election?

             5   A.  I don't recall a specific conversation about the

             6       likelihood of endorsement, but we certainly would have

             7       had conversations with Mr Myler I think around

             8       conference time and, as I say, with other newspapers,

             9       and the aim from our perspective certainly was to try

            10       and secure their endorsement.

            11   Q.  The means of securing their endorsement, were those

            12       means primarily through Mr Myler or through other people

            13       as well?

            14   A.  As I said earlier, for me it was about a broad range of

            15       relationships, you know, making sure that we maximise

            16       the opportunities to get our message across as

            17       effectively as we could.

            18   Q.  I'm talking about News of the World now.

            19   A.  Oh, I'm sorry.  With the News of the World specifically

            20       we had a relationship with the political editor, I knew

            21       one of their columnists quite well because I'd hired him

            22       onto the paper, and I would talk to him -- not, if you

            23       read his columns, that it got me particularly far -- and

            24       others kind of on the paper.  So we certainly tried to

            25       have good relationships.


                                            57






             1   Q.  In relation to the Sun you pick this up at paragraph 88,

             2       page 02423.  You say:

             3           "I would talk to Rebekah from time to time, when she

             4       was both editor of the Sun and later chief executive of

             5       News International."

             6           That of course was in the summer of 2009.

             7           "Most of these conversations were social although we

             8       would on occasions talk about politics."

             9           And you've self-evidently pursued a pro-Conservative

            10       and later pro-government line.  Of course that was your

            11       job, wasn't it?

            12   A.  Yes.

            13   Q.  You knew her very well.  When did you sense that she was

            14       going to deliver this major prize?

            15   A.  I'm not sure that I looked at it as her gift, as you put

            16       it, to deliver.  And I certainly don't remember a moment

            17       at which I thought, you know: great, that's the

            18       endorsement secured.  I wasn't certain of that fact --

            19       actually, I took the view that I wouldn't be certain of

            20       it until I saw it in the paper, but obviously there was

            21       the conversation between Mr Cameron and James Murdoch,

            22       in which we were told that they would be supporting us.

            23   Q.  That was on 9 September 2009.  You say in paragraph 99,

            24       however, 02426, you say:

            25           "As we approached conference season [that's 2009]


                                            58






             1       the paper's coverage became less positive for Labour."

             2           So that's something that you would have been

             3       tracking, wouldn't you?

             4   A.  Yes, I would have been paying attention to it, yes.

             5   Q.  And you were aware, of course, that Mr Cameron was as it

             6       were becoming closer to the Murdochs, you presumably

             7       knew about the trip to Santorini in 2008, didn't you?

             8   A.  I did.

             9   Q.  Was that something you had a hand in organising?

            10   A.  I may have been involved in the logistics, but I wasn't

            11       heavily involved and nor did I go.

            12   Q.  No.  But the fact of his going was something which must

            13       have pleased you in many ways; is that right,

            14       Mr Coulson?

            15   A.  I certainly would have taken the view that it was better

            16       to have the conversation than not have the conversation.

            17       I didn't form a view that it was in any way a sort of

            18       key moment.

            19   Q.  I'm not sure we're looking for key or fulcral moments

            20       which are going to cause immediate tectonic shifts.

            21       We're looking at a slow change in approach and in

            22       affiliations, but it's one moment along the slide, isn't

            23       it, away from Labour and towards the Conservatives,

            24       would you agree?

            25   A.  We would certainly have hoped so.  We would have hoped


                                            59






             1       that it was an opportunity and it was an opportunity

             2       for -- I don't know what was said, I wasn't there, but

             3       insofar as my view of that meeting, I would have seen it

             4       as an opportunity for David Cameron to put himself and

             5       the party in the best possible light, but I don't know

             6       what happened in the meeting.  I don't think we

             7       discussed it afterwards.  I think he just told me that

             8       it went quite well.  He went on holiday immediately

             9       afterwards and that was that.

            10   Q.  You knew from past experience that it would take some

            11       time to secure the Sun's support since it would come at

            12       the right tactical moment from the Sun's perspective in

            13       relation to the timing of the next election, didn't you?

            14   A.  I didn't know that, no.  I didn't get involved in the

            15       Sun's decision on the timing and frankly, had I done,

            16       I would have wanted it to come as a positive endorsement

            17       of the Conservatives in our conference.

            18   Q.  I'm not sure that was quite the question.  Maybe

            19       I phrased the question badly.  You knew that it would

            20       take time to secure's the Sun's support, didn't you?

            21   A.  It did take time.

            22   Q.  You knew that it would from past experience, didn't you?

            23   A.  Yes, I certainly saw it as a long process, but remember,

            24       during my time working for Conservatives, there were ups

            25       and downs, to say the least, and so did I have a plan


                                            60






             1       that went to that date in Gordon Brown's conference?

             2       No, I didn't, because there were periods where we didn't

             3       know when the election was going to be.  So through 2007

             4       and 2008, the Sun remained at times sort of doggedly

             5       supportive of Gordon Brown.  So in that regard it was

             6       certainly clear to me that it was going to be a long

             7       process.

             8   Q.  But didn't you know that it was also the Sun's strategy

             9       or likely to be their strategy to deliver this major

            10       prize at the appropriate time from its perspective,

            11       which would be as close to the next election as

            12       possible?

            13   A.  I'm not sure when I knew that they were going to do it

            14       on that day --

            15   Q.  I'm not talking about the particular day.

            16   A.  Sorry.

            17   Q.  I'm talking more generally.  I'm talking about what the

            18       Sun said --

            19   A.  Would it be a big moment for the Sun if they switched to

            20       the Tories?  I think that's fair to say.  Although

            21       I would add, if I can, that in terms of shocks, when you

            22       look at the political history of the Sun, the far bigger

            23       shock was them bagging Tony Blair.  Actually returning

            24       to the Conservatives in a way you could argue was less

            25       of a shock.


                                            61






             1   Q.  You say in paragraph 99:

             2           "I'm sure I discussed it [that's the coverage

             3       becoming less positive for Labour] with Rebekah and with

             4       Dominic Mohan."

             5           So we're now into the summer of 2009, aren't we?

             6   A.  Yes.

             7   Q.  Were there frequent discussions with those two about

             8       this issue?

             9   A.  I don't think I'd describe them as frequent, no.

            10   Q.  Was Rebekah taking the lead or Dominic Mohan?

            11   A.  I think I had conversations with both of them.

            12       I wouldn't describe one as taking the lead.  Dominic was

            13       the editor of the paper and in terms of my attempts to

            14       make sure that the coverage for the Conservative Party,

            15       coverage of the headlines, what was going into the

            16       paper, that's the editor's job, and so I would have had

            17       those conversations with him, and indeed other members

            18       of his staff.

            19   Q.  You knew the ultimate decision was going to be made by

            20       Mr Murdoch heavily advised by Rebekah Brooks, didn't

            21       you?

            22   A.  I think I would have taken the view that it would be

            23       done -- James Murdoch was now -- had now taken a senior

            24       role at News International.  I think I probably would

            25       have taken the view that it was going to be


                                            62






             1       a combination of views, but obviously Rupert Murdoch

             2       would play a part in that.

             3   Q.  Okay.  Three people then.  We'll have Rupert Murdoch,

             4       James Murdoch and Rebekah Brooks, but they're the three

             5       key players here, aren't they?

             6   A.  I wasn't party to the conversation so I don't know if

             7       anyone else was involved, but I certainly think it's

             8       fair to say that the three of them would have been

             9       involved and I suspect Dominic would too.

            10   Q.  But you knew this organisation very well, Mr Coulson.

            11       You knew how they operated.  You were hired in part

            12       because you understood them.  Surely you knew that the

            13       way in ultimately to Mr Murdoch was through his son and

            14       Rebekah Brooks.  That was the dynamic, wasn't it?

            15   A.  The way in to what?

            16   Q.  To getting the support of the Sun for the Conservative

            17       Party.

            18   A.  I think it was certainly an important sort of line of

            19       communication for me, yes.

            20   Q.  The truth is, with respect to him, that Mr Mohan was

            21       going to do as he was told, wasn't he?

            22   A.  I don't accept that and I don't think I'm in a position

            23       to say because I wasn't there.  So I don't know what

            24       part Dominic played in those conversations.

            25   Q.  You've worked with Mr Mohan over the years.  We've


                                            63






             1       watched him give evidence.  If you want a powerful

             2       personality, if I may say so, let's look at

             3       Rebekah Brooks, but we're not going to find one with

             4       Mr Mohan, are we?  You know that.

             5   A.  I'm not here to give a character assessment on Dominic

             6       Mohan.  I have no idea what part he played in the

             7       conversation.

             8   Q.  Oh all right.

             9   A.  You seem to have a fairly disparaging view of

            10       ex-showbusiness reporters, Mr Jay.

            11   Q.  I'm not talking disparaging.  I'm talking about strength

            12       of personality, because strength of personality may be

            13       part of the picture here?

            14   A.  I don't know.  I'm not suggesting for a second that

            15       conversations with Rebekah were not in any way

            16       influential.  Yes, I accept that.  I also considered my

            17       conversations with Dominic, I hope, to have some impact.

            18       I didn't have any conversations with James Murdoch,

            19       beyond a brief conversation I had with him which I've

            20       detailed in my statement when we met briefly for

            21       a drink.  I certainly didn't have a regular line of

            22       communication into him at all.

            23   LORD JUSTICE LEVESON:  Have you had the opportunity,

            24       Mr Coulson, to watch or read what Mr Rupert Murdoch said

            25       on the subject of political support, both in relation to


                                            64






             1       the Sun and the News of the World?

             2   A.  I've looked at some of it, sir.  I can't say I have an

             3       encyclopaedic recollection of it.

             4   LORD JUSTICE LEVESON:  Well, that would be a phenomenal feat

             5       of memory.  But I'll be corrected if I'm wrong, but in

             6       relation to the News of the World, he said that actually

             7       the paper that was close to his heart was the Sun and he

             8       was really identifying that the Sun's political line was

             9       something with which he was involved.  Might even be

            10       deeply involved.  I'm not using his words, I'm using my

            11       recollection.  Whereas he wasn't quite so interested in

            12       the News of the World and he said some observations

            13       about that and his lack of interest in that.  Did you

            14       see that particular part of his evidence?

            15   A.  Yes, I did.

            16   LORD JUSTICE LEVESON:  What I'm interested to know is

            17       whether that surprised you or surprises you now or

            18       whether it fits in with what you experienced at the

            19       time.

            20   A.  No, I hope I haven't given inadvertently, if I have, the

            21       wrong expression here.  I'm not for a second suggesting

            22       that Rupert Murdoch wasn't a fundamental part of the

            23       decision-making process.  I'm not suggesting that at

            24       all.  What I am saying is that from the point of view of

            25       my interaction, yes, I spoke to Rebekah, yes, I spoke to


                                            65






             1       Dominic, and I didn't have those -- to use the example

             2       of Dominic, I didn't have those conversations in the

             3       belief that they didn't matter.  I believe that they did

             4       matter, and I -- but I wasn't party to that -- a meeting

             5       or the discussions that took place at News International

             6       that led to the decision.  I don't know who was

             7       involved.  I'm sure that Rupert Murdoch was and I'm sure

             8       that Rupert Murdoch took a very clear view.

             9   LORD JUSTICE LEVESON:  Yes.  And would you agree with this,

            10       that if Mr Murdoch expressed a very clear view, it would

            11       require a remarkably robust editor to say, "Well, thank

            12       you very much, Mr Murdoch, I'm very interested in that,

            13       I'm actually going 180 degrees in the other direction"?

            14   A.  It would be a bold move, yes.

            15   LORD JUSTICE LEVESON:  All right.

            16   MR JAY:  After the meeting Mr Cameron, Mr James Murdoch,

            17       9 September 2009 at the George, Mr Cameron must have

            18       been pretty happy, wasn't he?

            19   A.  We had a brief conversation on the phone and, yes,

            20       I think it was positive news.

            21   Q.  Very positive news, wasn't it?

            22   A.  It was positive news, but my view was instinctively

            23       cautious and I said, "Let's wait and see when it happens

            24       and how it happens".

            25   Q.  Instinctively cautious about everything, Mr Coulson.


                                            66






             1       Unless Mr James Murdoch was going to go back on his

             2       word, this was in the bank now, wasn't it?

             3   A.  Well, you know, I didn't want to -- in my mind, I wasn't

             4       going to see it as an absolute until I'd seen the paper.

             5   Q.  Did you have no idea at all when the news would break?

             6   A.  I'm not sure when I knew precisely when it would break.

             7       I certainly didn't play a part in that decision-making,

             8       but I can't recall whether or not it was kind of in the

             9       ether once the Labour conference had started, it may

            10       have been.  It may even have been that I had

            11       a conversation and was told that it was likely or not.

            12       I do remember being at home and seeing the television,

            13       Sky News showing the front page, and that was the moment

            14       when I felt, because the paper was there, it's happened.

            15           But as I say in my statement, I'm not for a second

            16       suggesting it was a negative.  Of course it wasn't.  It

            17       was a serious positive for us.  But in truth, at the

            18       risk of sounding ungrateful, I thought that it was -- it

            19       was not the front page that I would have -- if I'd had

            20       half the influence that people think I had over the Sun,

            21       it was not the front page that I would have wanted.  Nor

            22       was the timing.

            23   Q.  Rebekah Brooks was busy phoning everybody else, she was

            24       trying to get hold of Gordon Brown that evening and

            25       failed and spoke to Lord Mandelson.  I'm sure she was


                                            67






             1       trying to get hold of you as well, wasn't she?

             2   A.  I can't remember if we had a conversation that night.

             3       I do think I had a conversation with Dominic, and

             4       I think it came after I'd soon the front page on the

             5       television.  That's my recollection.  I can't recall if

             6       I had a conversation with Rebekah that night.  We

             7       certainly I think would have spoken the next day if not

             8       that night.

             9   Q.  Didn't you take any delight in the fact, knowing that

            10       the front page itself was more anti-Labour than

            11       pro-Conservative, that its timing was rather delicious,

            12       namely it went online pretty soon after Gordon Brown's

            13       leadership speech at that conference?

            14   A.  It had some impact for the Sun newspaper, but my

            15       interests were more selfish.  I was more interested in

            16       the impact on the Conservative Party and I remember very

            17       well searching for the pro-Cameron headline in this

            18       edition and I think it was in a sub-deck somewhere.  So

            19       I'm not trying to suggest that I was disappointed.

            20       I wasn't disappointed, of course it was a plus that they

            21       were moving to the Conservatives, but I would have

            22       preferred them to have done it in a different way.  And

            23       at a different time.

            24   Q.  What, nearer to the election?

            25   A.  No, I'd have liked for them to have done it during our


                                            68






             1       conference.

             2   Q.  We know there was a certain amount of anger in the

             3       Labour Party at this turn of events.  Does that surprise

             4       you?

             5   A.  No.

             6   Q.  And the converse would also be the case.  There would be

             7       satisfaction if not jubilation in the Conservative

             8       Party?

             9   A.  I certainly wouldn't describe it as jubilation, but it

            10       was -- it wasn't a bad day in the office.

            11   Q.  No.  Did you not feel in any way, Mr Coulson, without

            12       belittling everything else that you were doing -- and

            13       you've told us that you were doing a lot -- that you had

            14       secured the major prize, what you'd been employed in

            15       May/June 2007 to secure?

            16   A.  No, I didn't feel that way at all.

            17   Q.  Can I ask you, please, about some of the meetings which

            18       you have provided details of to us?  AEC3, which is

            19       going to be tab 4 in that bundle.  They're a list of

            20       your media meetings in opposition, our page 02397.  We

            21       can see looking generally at this list that you're

            22       seeing everybody, really, including representatives of

            23       the broadcast media.  Would you agree?

            24   A.  Yes.

            25   Q.  On New Year's Eve 2008, there's a party at the Brooks'


                                            69






             1       farm; is that right?

             2   A.  We stayed at -- with Rebekah and Charlie Brooks for New

             3       Year's Eve, yes.

             4   Q.  And there was the wedding in June 2009 and then on

             5       30 September 2009 there was dinner.  That was the date,

             6       I think, that the Sun headline, "Labour's lost it", came

             7       out.  Do you recall that?

             8   A.  Yes.

             9   Q.  And that's at the Osbournes', we can see; is that right?

            10   A.  Yes.

            11   Q.  And you've listed everybody who was there, have you?

            12   A.  I believe so, yes.

            13   Q.  I suppose the mood might not have been universally

            14       favourable because we can see who else was there, but

            15       I don't know, I can't speak for Sir Harold Evans, what

            16       he was saying, but apart from him perhaps everybody else

            17       was pretty happy presumably?

            18   A.  Yes, I imagine so.

            19   Q.  What we don't see on this list inevitably is all the

            20       telephone calls you might have had with people on your

            21       mobile or whatever; is that right?

            22   A.  Yes.  As I look at the guest list of this dinner,

            23       I don't want to set a hare running here but that's my

            24       recollection of who was there.  I don't think anyone

            25       else was invited.  That's something you might want to


                                            70






             1       double-check with others who were there.  I'm pretty

             2       sure I'm right about that.

             3   Q.  If you turn over the page to 02399, we see 5 November

             4       2009, coffee at the City Inn with Fred Michel of

             5       News International.

             6   A.  Yes.

             7   Q.  "General politics discussion".  Can you remember

             8       anything more about that?

             9   A.  I think it was the first time I met him.  So I think it

            10       was literally a hello.

            11   Q.  What did you understand his role to be?

            12   A.  The corporate affairs guy for News International.

            13   Q.  But with what raft of responsibilities?

            14   A.  That brief -- that broad, rather.  I didn't know whether

            15       or not he had a specific brief.  Didn't occur to me that

            16       he did.  He was the new corporate affairs executive in

            17       News International that went right across the company.

            18   Q.  Of course including News Corporation for this purpose;

            19       is that right?

            20   A.  I don't know what his -- I didn't know then what his or

            21       now frankly what his News Corp -- specific News Corp

            22       role was.  In any event, I viewed him as a News

            23       International not a News Corp person.

            24   Q.  But you understood that he was the European lobbyist, to

            25       put it in the vernacular, for the commercial interests


                                            71






             1       of News International, News Corp, didn't you?

             2   A.  I'm not sure that I did.  I saw him as a corporate

             3       affairs executive.  I didn't know -- I know that he had

             4       a background in European politics, that's what led to

             5       the -- his hand in the Aznar meeting.  I knew obviously

             6       he was French and he spent a lot of time involved in

             7       European politics, as I understand it, but beyond that

             8       no, I didn't have any real view or information about his

             9       role.

            10   Q.  But what do you understand by the term corporate affairs

            11       executive?

            12   A.  From my experience it was logistics.  Conference, for

            13       example, he might have a hand in organising any News

            14       International function.  He would be involved on sort of

            15       broader issues for News International.  That's how

            16       I would understand.  Not involved in editorial.

            17   Q.  Certainly not, but it's all rather vague, Mr Coulson.

            18       He was a pretty high-powered executive, wasn't he?

            19   A.  Well, when I met him here, I didn't give any thought to

            20       him being especially high-powered.  I didn't know -- it

            21       was a new set-up at News International after I'd left.

            22       James Murdoch was there, there were lots of people there

            23       that I didn't know and who I'd never met, so I didn't

            24       know precisely where he fitted into the hierarchy.  Nor

            25       did I ask, I don't think.


                                            72






             1   Q.  Did you know whether he was someone who had frequent

             2       contact with government ministers or their advisers?

             3   A.  Well, I knew that as a corporate affairs person he was

             4       likely to sort of take on a role along those lines.

             5       Beyond that, no.

             6   Q.  And with what end or to what end was he taking up that

             7       role?

             8   A.  I don't -- I don't know.  I certainly didn't have any

             9       conversations with him that were specific to News

            10       International's aims.

            11   Q.  Apart from this one conversation you see noted here,

            12       were there other conversations with him?

            13   A.  I've looked at my itineraries in -- well, first of all,

            14       let's take it chronologically.  As I touched on earlier,

            15       he had a hand in the organising of a lunch between

            16       David Cameron and the former Spanish Prime Minister.

            17   Q.  Yes.

            18   A.  I don't recall whether or not he attended that lunch.

            19       And then later in my itineraries, I've noticed another

            20       meeting with him, but it had a line put through it.

            21       I don't remember it so I'm assuming that got cancelled.

            22       However, once in government I do recall talking to him,

            23       albeit very briefly, I think in my office.  I can't find

            24       a formal record of this meeting and it could well be

            25       that he was seeing someone else or was in the building


                                            73






             1       with another meeting and popped in, but in any event

             2       that was a brief conversation, as I recall it.

             3   Q.  Before June 2010, did he discuss with you News

             4       Corporation's intention to seek to acquire the remaining

             5       publicly owned shares in BSkyB?

             6   A.  I don't recall any conversation along those lines, no.

             7   Q.  Are you saying there wasn't such a conversation or are

             8       you saying that you don't recall one?

             9   A.  I'm saying that I don't recall one.

            10   Q.  When the bid was announced, was it a surprise to you or

            11       not?

            12   A.  I'm not sure I knew about it in advance.  I would want

            13       to go back and look at the business press in advance of

            14       it.  I don't whether or not -- where the commentary was,

            15       whether or not it had been flagged in the papers, where

            16       the sort of level of speculation was about it.  I seem

            17       to remember that there was a fair amount of commentary

            18       in advance.  I might be wrong about that.  That's my

            19       recollection.

            20   Q.  Not something Mrs Brooks discussed with you, was it?

            21   A.  No, I don't remember any conversations with Rebekah

            22       about it.

            23   Q.  Going back to Mr Michel, it's paragraph 95 of your

            24       statement, 02425.  You say you met with him on a few

            25       occasions for coffee including one occasion possibly at


                                            74






             1       Number 10.  Do you see that?

             2   A.  Yes.

             3   Q.  What was he doing there on that occasion, do you

             4       remember?

             5   A.  I'm sorry, Mr Jay, are you referring to my reference to

             6       the possible meeting at Number 10?

             7   Q.  Yes.

             8   A.  As I explained earlier, that's the meeting I'm referring

             9       to where --

            10   Q.  This is a lunch, is it?

            11   A.  Which is why I'm putting -- I'm sorry, are we talking

            12       about the Aznar lunch or the possibility of a meeting in

            13       Number 10?

            14   Q.  I was seeking to clarify which we were talking about.

            15   A.  I'm sorry.  The possibility of the coffee at Number 10

            16       is the meeting that I discussed, that I explained,

            17       obviously badly, previously.  The Aznar lunch was in

            18       opposition and was at some time prior to that in 2009.

            19   Q.  At that point, was Mr Aznar involved with News

            20       Corporation?

            21   A.  I believe he was, yes.

            22   Q.  Was he on the board of News Corporation?

            23   A.  I believe that's right, yes.

            24   Q.  You say you can't recall but it's possible that

            25       Mr Michel attended that lunch?


                                            75






             1   A.  Yes.

             2   Q.  That's your best recollection, you're not sure?

             3   A.  Yes.

             4   Q.  Were the affairs of News Corporation discussed at that

             5       lunch?

             6   A.  No.  Not as far as I remember.

             7   Q.  Can you remember what the discussion was about?

             8   A.  The discussion was about Spanish politics and British

             9       politics.  The lunch took place in the -- I believe it

            10       took place in the House of Commons and it was a -- the

            11       first time they'd met, I think I'm right in saying, and

            12       it was a political conversation.

            13   Q.  But it was a lunch that Mr Michel organised, it's not

            14       one that you organised; is that right?

            15   A.  He certainly played a part in it is my recollection,

            16       and -- in terms of the logistics of the lunch.

            17   Q.  Okay.  You go to Downing Street in May 2010.  I've been

            18       asked to put to you this question, Mr Coulson: your

            19       salary was cut to £140,000 a year, wasn't it?

            20   A.  Yes.

            21   Q.  Did you explore whether it was possible for private

            22       donors to top up your salary?

            23   A.  No.

            24   Q.  I think it's implicit in that answer that your salary

            25       was not topped up by private donors?


                                            76






             1   A.  Not by private donors, no.  As I say in my statement,

             2       there was a notice payment paid to me as part of my

             3       Conservative contract.

             4   Q.  I understand, yes.  You've told us about the BSkyB bid.

             5       Did you know what Mr Cable's attitude was to the bid

             6       before it became clear on 21 December 2010?

             7   A.  I don't believe so, no.

             8   Q.  You don't believe so or --

             9   A.  I don't have a specific memory of -- I certainly didn't

            10       talk to him about it and if it had been reported that

            11       he'd taken a particular view, and that's possible,

            12       I suppose, I can't remember the exact chronology, then

            13       through that route, yes I may have been aware, but

            14       I wasn't involved in the BSkyB bid.  Save for my

            15       communications role.

            16   Q.  And of course there was a political storm of sorts on

            17       21 December 2010 and you were naturally involved in that

            18       since it impacted on your role; that's right, isn't it?

            19   A.  Yes.

            20   Q.  Did you speak to Mr Hunt that day?

            21   A.  I don't recall doing so.

            22   Q.  Did you speak to Mr Hunt about the bid at any stage?

            23   A.  I don't recall any conversations with Mr Hunt about

            24       BSkyB.

            25   LORD JUSTICE LEVESON:  Was there ever any conversation with


                                            77






             1       any politician that sought, whether sensibly or not, to

             2       gain the benefit of your experience of having worked for

             3       News International for the purpose of considering this

             4       bid?

             5   A.  Not that I remember, sir, no.

             6   MR JAY:  I've been asked to put this general point to you,

             7       going back to when you were editor of the News of the

             8       World: had the News of the World ever plugged Sky TV

             9       programmes?

            10   A.  My experience of that issue is that when there was

            11       a promotion, Sky paid a price for it.  You know,

            12       literally.  I mean it was bought as promotional space.

            13       That was the main sort of crossover between Sky and the

            14       paper.

            15   Q.  And they paid the same commercial rate as everybody

            16       else, did they?

            17   A.  I don't know.

            18   Q.  Not given a favourable rate?

            19   A.  I don't know.  I didn't get involved in that.

            20   Q.  Can we look at AEC4, which is your list of media

            21       meetings in government.

            22   A.  Which tab is that?

            23   Q.  In your bundle it's tab 5.

            24   A.  Thank you.

            25   Q.  We can see from that that when the Coalition government


                                            78






             1       is instituted, Mr Cameron invites most of the important

             2       players, editors, BBC political editors, et cetera, to

             3       Downing Street over the next month or six weeks; that's

             4       clear, isn't it?

             5   A.  Yes.

             6   Q.  I think Mr Rupert Murdoch didn't happen to be the first,

             7       he appears to be the second on this list.  Mr Murdoch

             8       mentioned that you were there.  Not quite sure why or in

             9       what context.  Could you help us with that?

            10   A.  I wasn't in the meeting, but I did see him prior to the

            11       meeting and very briefly before the meeting and again

            12       very briefly after the meeting, but I wasn't in the

            13       meeting itself.

            14   Q.  There's a lot of fascination about people going in

            15       through the back door of Downing Street.  Are you able

            16       to enlighten us with that at all or is it a complete red

            17       herring?

            18   A.  No, I think he did come through the back door, as

            19       I think Mr Murdoch may have told you.  I think that's

            20       how it happened under previous administrations and

            21       I suspect it kind of happened automatically, I think.

            22   LORD JUSTICE LEVESON:  Would that be so for all these

            23       people?  There's a list of back door people and front

            24       door people, except those who stand outside the front

            25       door and talk from it?


                                            79






             1   A.  I don't know which door these other people came through,

             2       sir, to be honest.

             3   LORD JUSTICE LEVESON:  All right, all right.  I have to keep

             4       myself entertained, Mr Coulson.

             5   MR JAY:  Enlighten us on this.  There may be absolutely

             6       nothing in this point.  Is there a system where some

             7       people come in one way and other people come in through

             8       the front or not?

             9   A.  I don't think so.  I know there were some parties where

            10       guests would arrive through the back because there's

            11       a car park through the back so it's a bit easier.  In

            12       terms of Mr Dacre's meeting, for example, I have no idea

            13       which door he came through.  Had he asked to come

            14       through the back door either for reasons of his own or

            15       because he wanted to park his car there, I'm sure that

            16       would have happened.

            17   Q.  In government was it ever part of your role or practice

            18       to brief against particular individuals, as has been

            19       alleged by, or against some of your predecessors?

            20   A.  No.  My job was to -- I would certainly brief in terms

            21       of politics, but in terms of people's private lives, no,

            22       I don't recall ever doing so.

            23   Q.  I think I'm using the word "brief" in the sort of sense

            24       that's quite widely understood, it's a slightly

            25       disparaging context, but one can think of various


                                            80






             1       synonyms for "brief" but I think you know what I mean?

             2   A.  In my conversations with journalists I certainly

             3       wouldn't hide my political views, obviously.  That was

             4       the purpose of the conversation.  But no, I don't

             5       believe I did that.

             6   Q.  In terms of your discharging your responsibilities, your

             7       role only is to play with an entirely straight bat,

             8       disseminate government policy, inform, make people --

             9       ensure they understand what government is up to, but

            10       never seek to spin from time to time, to influence, to

            11       cajole, to brief or indulge in any of those sort of

            12       slightly murkier activities?  Do I have it right?

            13   A.  Well, define "brief".  I mean, I thought the question --

            14       apologies if I misunderstood -- I thought the question

            15       was did I brief against people on a personal basis.

            16       I don't believe I did.  But -- beyond their politics.

            17       But did I have strong views and would I express those

            18       views in conversations with journalists about

            19       Gordon Brown or Labour politicians, Labour policy,

            20       individuals concerned and the stance they were taking?

            21       I think I probably would in the same way that I sought

            22       to give or articulate as positive a picture possible for

            23       the Conservatives, but I don't believe that I did so

            24       inappropriately.

            25   Q.  As an observer of political life in this country over


                                            81






             1       the last 20 years, do you think the sort of things I've

             2       been describing, without reference to you of course, are

             3       an issue which needs consideration or not?

             4   A.  In terms of negative briefing?

             5   Q.  Mm.

             6   A.  I think that moment came to a head with the Damian

             7       McBride affair, of course when we were in opposition,

             8       which resulted in some very personal stories, stories

             9       which by the way were published in News International

            10       papers, as well as other papers.

            11   Q.  Okay.  Can I ask you, please, about paragraph 53 of your

            12       statement.  You say in the second sentence that you "got

            13       involved in policy only in relation to its likely impact

            14       on the media".  Do you see that?

            15   A.  Yes.

            16   Q.  Do you feel at any stage it might have been an excessive

            17       interest in how policy would play out in the media

            18       rather than in its intrinsic merits?

            19   A.  Possibly.  And if anyone was kind of thinking in those

            20       terms, I guess it would have been me as the person

            21       responsible for communications.

            22   Q.  Is this a problem which is a significant one or one

            23       which is overplayed, in your view?

            24   A.  I don't think it's -- I don't think that it's

            25       necessarily a significant problem.  I think that


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             1       political parties have to, with the modern media, fight

             2       hard to get their message across, and also there's a --

             3       you know, there is a personality aspect in politics that

             4       has probably increased over the years.  And that

             5       therefore requires -- certainly required for me a lot of

             6       attention, and you sought to make sure that an authentic

             7       view of in particular David Cameron was being sort of

             8       expressed through the media.  That would require a lot

             9       of work.

            10   Q.  You left Downing Street in January 2011 in circumstances

            11       we're not going to discuss, but can I ask you this

            12       simple question: did you discuss your departure with

            13       Rebekah Brooks or anyone else in News International?

            14   A.  If I did, it was after I had resigned.  I'm confident of

            15       that.  You know, I've tried to remember the exact chain

            16       of events.  As you can possibly appreciate, it was

            17       a fairly difficult period and I can't be absolutely

            18       sure, but I think that -- I don't think I had -- I told

            19       anyone I was resigning until after I'd told the

            20       Prime Minister.

            21   Q.  You were asked to deal with the case of Mr Driscoll, who

            22       secured a substantial sum by way of compensation from an

            23       employment tribunal.  Are you with me?

            24   A.  Yes.

            25   Q.  The hearing was after you left News International.  The


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             1       hearing I think was in 2008.  Were any arrangements made

             2       or were you asked to give evidence on behalf of News

             3       International, or the formal respondent was actually NGN

             4       Limited, which is News Group Limited?

             5   A.  No, I wasn't, which is a matter of considerable regret.

             6   Q.  Did you have any awareness that the case was going on as

             7       it was going on, before its outcome was announced?

             8   A.  I'm not sure that I knew about it in advance, but

             9       obviously it attracted some media attention once it got

            10       under way.  I don't think I knew about it in advance of

            11       that.  I certainly don't have any recollection of

            12       knowing about it in advance.

            13   Q.  And when the media attention arose, did you think: I can

            14       give evidence here?

            15   A.  No, I was working for the Conservatives at that point

            16       and I took the view -- and I've thought about this

            17       since, you know, was it the right decision?  I don't

            18       know.  I took the view that it would only make it worse

            19       if I then tried to intervene.  I certainly didn't have

            20       the view that I could sort of impose myself on the

            21       hearing at any juncture and I'm not sure that at what

            22       point the damaging -- what I considered to be the sort

            23       of damaging comments in the judgment were made.  I think

            24       it's probable that the damaging comments came, obviously

            25       because it was the judgment, at the conclusion of the


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             1       hearing, so by then it was too late anyway.

             2   LORD JUSTICE LEVESON:  You, of course, appreciate that it's

             3       for the parties to the litigation to decide who they

             4       want to ask to give evidence but nobody ever came to

             5       you?

             6   A.  Yes, sir, that's right.  I may be wrong about this, but

             7       my understanding is that the tribunal themselves do have

             8       a process by which they could have asked to talk to me.

             9   LORD JUSTICE LEVESON:  But it's quite difficult to see why

            10       a tribunal should do that in the context of adversarial

            11       litigation.  In an inquisitorial system such as the

            12       Inquiry, that's controlled by the Inquiry, in that

            13       context me.  But in the normal form of litigation, the

            14       parties decide who they call and it would be quite wrong

            15       for the judge to decide of his own volition to do so

            16       absent very special circumstances.  Anyway, but

            17       presumably you'd left records behind of your dealings

            18       with Mr Driscoll which were accessible?

            19   A.  Yes.  I think that some of those records formed part of

            20       the case.  If I can make this point, I've asked News

            21       International to furnish me with all the background to

            22       this case in terms of witness statements, in terms of my

            23       own involvement and anything else, and they've not been

            24       able to do so because I'm an ex-employee.  So all

            25       I have -- and the questions that presumably you're going


                                            85






             1       to ask me -- all I have to work on is the judgment

             2       itself and the precis and the extracts of my own emails

             3       and letters.

             4   MR JAY:  Which were referred to in the tribunal's decision,

             5       which is under tab 11 of the bundle.  The decision is

             6       quite intricate, as you're aware, but you've presumably

             7       had a chance to study it.

             8   A.  I have.

             9   Q.  There was a complaint first of all by the Arsenal

            10       Football Club in relation to a piece News of the World

            11       wrote about one of its footballers.

            12   A.  Yes.

            13   Q.  That culminated in disciplinary proceedings in October

            14       2005 and a warning.  If you look at paragraph 104, which

            15       is page 021349, Mr Kuttner, who I think was the managing

            16       editor then, was he?

            17   A.  Yes.

            18   Q.  Wrote to you by email dated 9 November 2005, so the

            19       tribunal had that.  The contents of what he wrote are

            20       telling.

            21           "He stated that the situation was not black and

            22       white enough to dismiss Matt Driscoll.  He went on to

            23       state 'of course we could still fire him: and pay the

            24       going rate for that.  Mike Dunn [he's the man who

            25       carried out the disciplinary hearing] tells me Driscoll


                                            86






             1       can't be got shot off?'  The decision to give the

             2       claimant a first warning, although the outcome of

             3       a disciplinary hearing chaired by Mr Dunn, was made by

             4       Mr Kuttner, with the agreement of the editor,

             5       Mr Coulson."

             6           Is that as far as you're concerned accurate?

             7   A.  It's accurate in terms of what you're reading.  It's not

             8       accurate in terms of the sort of wider framework of the

             9       judgment because those words "can't be got shot of",

            10       misspelt here, were directly attributed to me, which is

            11       wrong.  They are clearly a report of Mike Dunn's words

            12       via Mr Kuttner.

            13   Q.  But isn't that what this says, Mr Coulson?  Doesn't it

            14       say in the fourth line "Mr Dunn tells me Driscoll can't

            15       be shot ..." I think there's some mistake, it should be

            16       "got shot of", not "got shot off".

            17   A.  "Got shot of", yes.  Sorry, my point which may be off

            18       your question, in which case apologies, is that the

            19       "can't be got shot of" seems to form a fundamental part

            20       of the judgment as coming from me, as being my words,

            21       and they're not my words.

            22   Q.  I'm not sure that error is made by the tribunal.

            23       I think all they say is the words come from Mr Dunn, but

            24       the decision to give the claimant a warning was made by

            25       Mr Kuttner with your agreement.  Is that correct?


                                            87






             1   A.  The judgment, I think, says that it was a pretext for my

             2       desire to "gets shot of" the claimant.  I never said

             3       that.

             4   Q.  Okay.  Paragraph 105:

             5           "The claimant felt it was highly unfair for Mr Dunn

             6       to have issued him with a warning.  He wrote a letter,

             7       10 November 2005, to that effect and copied it to

             8       Mr Coulson.  He informed him that although he could not

             9       accept the criticisms made of them because he believed

            10       them to be unfounded, in the interests of harmony he

            11       decided not to appeal.

            12           "Mr Coulson responded to Mr Driscoll's letter.  The

            13       contents of his response are also very telling.  He

            14       stated:

            15           "'I also disagree with the adjudication.  In my view

            16       your actions on this matter merited dismissal.'"

            17           Is that what you said?

            18   A.  Yes.  If I can add again briefly that I'd like to have

            19       seen the full letter before I was asked to respond to

            20       this.  And I've not seen the full letter.  All I have to

            21       work on is the judgment.  And on the basis that --

            22       I don't wish to go on about this, but on the basis that

            23       the judgment couldn't even get my quote right, I am

            24       therefore not particularly willing to accept their

            25       interpretation of it.


                                            88






             1   Q.  I think we've already established that what you believe

             2       is attributed to you in paragraph 104 is not because it

             3       comes from Mr Dunn.  Do you see that?

             4   A.  I'm referring to the judgment, the later judgment.

             5   Q.  What they're doing, the tribunal, in paragraph 106 is

             6       setting out a direct citation from something you've said

             7       which might appear to be somewhat hostile and then to

             8       paraphrase what else your letter said:

             9           "He went on to state [that's you going on to state]

            10       that his performance would be monitored closely and that

            11       if it did not improve or if there was any repeat of any

            12       of the failings, further disciplinary action may be

            13       invoked against him.  He offered no words of

            14       encouragement.  In the context of Mr Coulson being the

            15       editor of the paper, this was a bullying remark."

            16           The simple question is: that's a fair point, isn't

            17       it?

            18   A.  No, I don't accept that.  It was a reaction to a letter

            19       that he had sent to Mike Dunn and copied to me.  I was

            20       irritated by it, I will accept, and I will also accept

            21       that my response was perhaps intemperate, but I do not

            22       accept that it equated to bullying, and in any event,

            23       following on from this letter, Matt Driscoll went on to

            24       kind of continue in his work in a very kind of positive

            25       way.  I think that's documented.  I think that Mike Dunn


                                            89






             1       wrote to him shortly afterwards with a message that was

             2       basically "upwards and onwards" and that was -- that was

             3       supported.  I was happy to support Mike Dunn in that

             4       process.

             5   Q.  But the tribunal found that wasn't so, that this was the

             6       start of a downward path, but I think what is most

             7       material is that whereas in formal terms all that

             8       Mr Driscoll received was a warning, you were saying,

             9       well, he should have been sacked.  That's true, isn't

            10       it?

            11   A.  My view was that the issues that led to the tribunal

            12       were serious, and should be taken seriously, and yes,

            13       I expressed the view that in my view he perhaps should

            14       have lost his job over it, but that didn't happen and

            15       I accepted the decision of the tribunal and there was no

            16       grudge.  I did not at that point, as the tribunal find,

            17       decide that that was the end of Mr Driscoll's career at

            18       the News of the World.  I think that both the tribunal

            19       and Mr Driscoll kind of picked different moments as to

            20       when they claim I decided this.  In another part of

            21       I think Mr Driscoll's evidence he says that it started

            22       with the story about the Arsenal shirt.  Now, if I was

            23       making decisions about News of the World staff and their

            24       future on the basis of a failure to stand up a tip or

            25       a story being lost to another newspaper, three-quarters


                                            90






             1       of the staff would have been on disciplinaries.  That's

             2       the nature of -- it's part of the cut and thrust of

             3       Sunday newspapers.  And in any event, it was a story

             4       about whether or not Arsenal would be wearing purple

             5       shirts.  It wasn't an exclusive about who was the next

             6       manager of England, for example.

             7   Q.  Later in 2006, paragraph 130, do you see that?

             8   A.  Yes.

             9   Q.  "Mr Wallis [that's a witness we've heard here] reported

            10       to Mr Coulson.  Mr Coulson's response is instructive.

            11       He stated by email to Mr Wallis dated 19 July 2006 he

            12       wanted him out as quickly and cheaply as possible."

            13           Do you remember that email?

            14   A.  Inasmuch as I've been reminded of it both through this

            15       tribunal and before.  Again I've asked for all the

            16       emails.  So I don't know what the exact context of it

            17       was, I don't know what came before or followed

            18       afterwards.

            19   Q.  I think all the tribunal are saying is there was a bit

            20       of a pattern here, if you follow me, certainly if you

            21       marry up the November 2005 email with the 2006 email

            22       it's consistent.  You want this man out and reasonably

            23       you're bullying him.  That's the truth, isn't it?

            24   A.  No, it's not the truth.  The first point to make is that

            25       in between times it was clear that I'd supported Mr Dunn


                                            91






             1       in actually trying to get Mr Driscoll's relationship

             2       with the News of the World back on track.

             3           The other point I would make is that at some time,

             4       many months, several months before I sent this email,

             5       Mr Driscoll himself had instigated severance

             6       negotiations with the paper.  So my recollection is that

             7       this email, "want him out as quickly and cheaply as

             8       possible", is absolutely in relation to that process.

             9   Q.  Okay.  So you disagree with the tribunal's clear

            10       findings; is that right?

            11   A.  Yes, I do.

            12   Q.  I think that's as far as I can really take that issue,

            13       Mr Coulson.  Those all the questions I had for you.  Was

            14       there anything you particularly wanted to say that we

            15       might have left out?

            16   A.  Can I make one point in relation to the theory that

            17       there was some kind of deal between News Corp or News

            18       International and the Conservative Party over the issue

            19       with BSkyB?  Can I just make one very straightforward

            20       point?

            21           If there was a deal, and if there was a conspiracy,

            22       as people seem to be suggesting, why was Vince Cable

            23       given the job?  It is in the Prime Minister's gift to

            24       decide who -- of course there was the complex nature of

            25       the Coalition, but it was the Prime Minister's gift to


                                            92






             1       decide who held which brief in his Cabinet, so if there

             2       was this theory, if there was this conspiracy running

             3       that David Cameron was going to somehow or other return

             4       the favour to News International, why on earth did he

             5       give it to -- and I would choose my words carefully --

             6       a combative member of the Liberal Democrat Party?

             7   Q.  Of course, Mr Cable was already the business secretary

             8       in May 2010, was he not?  The BSkyB bid would fall

             9       within his province and that wasn't announced until June

            10       2010.

            11   A.  No, but the conspiracy, I think, suggests that this was

            12       a deal that was done some time before.

            13   LORD JUSTICE LEVESON:  All right.  Well, it's an advocacy

            14       point rather than a factual point.

            15           Can I ask a very different question?  You probably

            16       as much if not more than anyone else have doubtless

            17       reflected on the issue which is at the core of this

            18       particular part of the Inquiry, which was, of course,

            19       set up by the Prime Minister in July last year.  And the

            20       issue is whether the relationship between the press and

            21       the politicians has become either close or no longer

            22       entirely conducive to good government, whichever way you

            23       want to put it.

            24           Now, whether this happened many years ago, whether

            25       it's a consequence of the involvement of those who've


                                            93






             1       been very heavily concerned with newspapers into the

             2       heart of communications in government, one could debate,

             3       but I would like your view on whether that relationship

             4       has become too close so that it gets in the way and how

             5       that should be addressed, if you have a view on it.

             6   A.  Well, the Prime Minister himself has said that he

             7       accepts that it got too cosy, and I'm not minded to

             8       disagree with him.  I think that it's perfectly clear

             9       now, as a result of this process, that the relationships

            10       with the media have got in the way of the message, let's

            11       put it that way.  I think that is abundantly clear.

            12       What you do about it, I think, is much more difficult

            13       because I would hate to think that -- I'm not suggesting

            14       that this is on your mind, sir, but I would hate to

            15       think that any barriers would be erected, more barriers

            16       would be erected between politics or politicians --

            17       politics more importantly, and the press.

            18           You only have to look at the turnout at last week's

            19       local elections which was low, to say the least.  People

            20       are disengaging with politics.  If you make it more

            21       difficult for the media to report on politics, if you

            22       make it more difficult for journalists to understand

            23       what it is you're trying to do, that's going to get an

            24       awful lot worse.

            25           Some people may say that that turnout is because of


                                            94






             1       this Inquiry or because of people's general reaction of

             2       what's been reported over the last months.  I'm not sure

             3       I buy that theory.  I come from the perspective of

             4       someone who's worked on both sides of the fence and

             5       I just sincerely hope, sir, with respect that the result

             6       of this part of the Inquiry does not, as I say, erect

             7       yet more barriers between what is already a pretty

             8       difficult process.

             9   LORD JUSTICE LEVESON:  If you'd heard what I said earlier

            10       today, you would know that I am very keen on ensuring

            11       that politicians have a mechanism to identify what their

            12       policies are and to seek to engage the public in them,

            13       and that journalists have the ability and responsibility

            14       to hold politicians and others, in which number I've

            15       always included the judiciary, to account for what they

            16       do.  The question is how to ensure that that happens in

            17       an open, transparent and appropriate way.

            18           It may be you don't have an answer, but if from your

            19       experience working both sides of the fence you do have

            20       a view -- it's not going to bind me, so you don't need

            21       to worry about it -- I'd be interested to hear it.  If

            22       not, then not.

            23   A.  It is incredibly difficult.  I mean, one point that

            24       troubles me in evidence, if I can say, that's come out

            25       throughout this Inquiry, is the idea that a friendship


                                            95






             1       is always based on some ulterior motive.  People are

             2       friends, people talk to each other and that's certainly

             3       true of the overlap between politics and the press.

             4   LORD JUSTICE LEVESON:  I'm not so sure that's fair, because

             5       equally I have said not once but many times that

             6       politicians are entitled to be friends with people,

             7       journalists are entitled to be friends with people.  The

             8       question is to differentiate and to be clear about the

             9       difference between social relationships and any form of

            10       business.

            11   A.  Yes, I have to say I think that what's happened over the

            12       course of the last couple of years, perhaps over the

            13       course of the last year or so, I think is going to solve

            14       that problem for you.  I think the possibility now of

            15       politicians not being transparent about their dealings

            16       with the media, I think the events that have come to

            17       pass will go a long way to dealing with that.

            18   LORD JUSTICE LEVESON:  Well, if I could be assured that the

            19       very fact of the last seven months had achieved the

            20       purpose so that I could go back to productive judicial

            21       work, I might be quite pleased with that, but that's

            22       a bit of a big leap, isn't it?

            23   A.  I wouldn't be so bold as to suggest that, sir.

            24   LORD JUSTICE LEVESON:  No, all right.  All right.

            25   MR DAVIES:  Could I just say while Mr Coulson is there that


                                            96






             1       I think what he may have had in mind is paragraph 107 of

             2       the tribunal's decision in the Driscoll case because

             3       they do there say it was a pretext for Mr Coulson's

             4       desire to "get shot of the claimant".

             5   LORD JUSTICE LEVESON:  I'm sure that's right, but

             6       Mr Rhodri Davies, as you know and I know, sometimes

             7       judgments don't always spell out all the dots.  I take

             8       the point, though.

             9           Mr Coulson, thank you very much indeed.

            10   A.  Thank you, sir.

            11   LORD JUSTICE LEVESON:  I understand why this has not been an

            12       easy process, but there it is.  It's been important.

            13       Thank you very much.

            14


            17

            18

            19

            20

            21

            22

            23

            24

            25


                                            99