13 (2.00 pm) 14 MS PATRY HOSKINS: Good afternoon, sir. The only witness 15 this afternoon is Mr Derek Webb. 16 LORD JUSTICE LEVESON: Certainly. 17 MR DEREK WEBB (sworn) 18 Questions by MS PATRY HOSKINS 19 MS PATRY HOSKINS: Mr Webb, if you would sit down and make 20 yourself comfortable. Do you have a bundle in front of 21 you with a number of tabs? 22 A. Yes, I have. 23 Q. First of all, could you state your full name to the 24 Inquiry, please? 25 A. Yes, Derek Frank Webb. 95 1 Q. You've provided us with a witness statement to the 2 Inquiry. For the technician, it's 515506. You've 3 signed it at the end. We can see that. Can you confirm 4 that the contents of it are true to the best of your 5 knowledge and belief? 6 A. That is correct. 7 Q. Can I say this before I ask you any questions: your 8 exhibits to your statement contain the names of a large 9 number of people that you placed under surveillance 10 whilst you worked for News of the World. It is really 11 important, Mr Webb, that you don't mention any of their 12 names when you answer my questions. On some occasions, 13 I will refer to a person by name, and then it's fine for 14 you to answer my questions, but for legal reasons, 15 I'd rather you didn't mention any individual by name 16 unless I have. 17 A. I agree. 18 Q. Do you understand? 19 A. Yes. 20 Q. I'm going to start, please, by asking you about your 21 career and your background. This is set out at 22 paragraph 1 of your statement, which you can open. It 23 should be behind tab 2, in fact. Do you see that? You 24 explain that you worked for many years in the police 25 force, that you were a detective with the Hertfordshire 96 1 constabulary and you retired after 30 years' service; is 2 that correct? 3 A. That's correct. 4 Q. You tell us there that you retired from the police force 5 on 12 November. You don't tell us which year that was? 6 A. That is 12 November 19 -- sorry, 2003. 7 Q. 2003. You tell us that during your years with the 8 police force, you were mainly a detective constable, but 9 for a period of over 15 years you were attached to 10 various squads where you were engaged in the 11 investigation of serious crime, specifically conducting 12 surveillance on major criminals. 13 A. That is correct. 14 Q. For this work, you say that you've been trained to 15 a very high level of competency and you'd completed 16 several specialist surveillance courses? 17 A. That is correct. 18 Q. Would you say, then, that you were someone who had 19 a specialist knowledge of surveillance techniques? 20 A. Yes. 21 Q. This was one of your specialisms? 22 A. Yes. 23 Q. Let me ask you this: you worked in the police force for 24 almost all of your professional life. I know you went 25 on to work for News of the World and I'll ask you about 97 1 that in a moment, but prior to working for the 2 News of the World, had you ever worked as a journalist? 3 A. No. 4 Q. Had you ever worked as a freelance journalist? 5 A. No. 6 Q. Had you published any stories in newspapers in any 7 capacity? 8 A. No. 9 Q. So your only specialism, am I right, was being a police 10 officer? 11 A. That is correct. 12 Q. And one who specialised, amongst other things, in 13 surveillance? 14 A. That is correct. 15 Q. Okay. You then tell us that you went on to undertake 16 surveillance for News of the World, spanning a period of 17 over eight years, from 17 December 2003 until the 18 newspaper closed in July 2011; yes? With a break in the 19 middle of about 15 or 16 months? 20 A. That's correct. 21 Q. Which I'll come back to. Is that all correct? 22 A. Yes. 23 Q. The break, you tell us, was between 20 November 2007 and 24 20 March 2009. 25 A. That's correct. 98 1 Q. You'll have to accept the dates from me unless they're 2 within your personal knowledge. I just want to 3 understand the eras of the News of the World that you 4 were working in. Between 2003 and January 2007, 5 Mr Coulson was editor? 6 A. Yes. 7 Q. Did you know that? 8 A. Yes. 9 Q. Good. Mr Myler became editor at the end of January 2007 10 and you were still there because you didn't have your 11 break until November 2007? 12 A. That is correct. 13 Q. Then from 2009 to 2011, Mr Myler was the editor? 14 A. That is correct. 15 Q. So those are the editors that you worked under, if I can 16 put it that way. 17 A. Yes. 18 Q. You tell us also in general terms that during this time, 19 the period spanning eight years, you placed 20 approximately 150 different people under surveillance on 21 instruction from the News of the World; is that correct? 22 A. That is correct. 23 Q. Okay. Let me take your time at News of the World 24 chronologically, if I can. Let's start back at 2003 25 when you first came to be instructed to do work for 99 1 News of the World. I want to the understand how you 2 came to work for News of the World. You set this out at 3 paragraph 3 of your statement in some detail, and you 4 explain that while you were still employed by 5 Hertfordshire constabulary and working as a detective in 6 the CID department at Watford police station, you were 7 instructed by your supervisor to execute a warrant on 8 an address where a man was allegedly making section 1 9 firearms. Your brief, you say, contained the fact that 10 the intelligence had originated from Neville Thurlbeck, 11 a reporter for News of the World. 12 A. That is correct. 13 Q. Do you remember that? 14 A. Yes, I do. 15 Q. And that the story of the arrest was going to appear in 16 the Sunday edition the newspaper. You were additionally 17 told that Mr Thurlbeck had worked undercover on the 18 case. Do you remember that? 19 A. Yes. 20 Q. You say following the arrest you met with Thurlbeck on 21 several occasions regarding the preparation of the case 22 papers. What I want you to do is tell me in your own 23 words the conversations you had about what your 24 intentions for the future were. 25 A. Yes, just had a conversation with Neville Thurlbeck. 100 1 He'd asked me what I'd been doing in the police force 2 and I told him, and told him that I specialised in 3 undercover as well as surveillance, but mainly 4 surveillance, and I told him when I was going to retire 5 and he actually said, "Well, look me up when you retire. 6 We might have some work for you in relation to the 7 surveillance side." 8 Q. You don't give us a date for this conversation. 9 A. No, I don't. This went over probably a period of about 10 six months while I was doing the -- preparing the case 11 papers and whatever. So it would have been -- I don't 12 have the exact date for that. 13 Q. That's fine? 14 A. It's sometime at the back end of 1999/2000, somewhere 15 around about that particular period, but I can't be 16 certain on the dates. 17 Q. All right. You told us earlier that you retired on 18 12 November 2003? 19 A. 3. 20 Q. So presumably then you made contact with him when you 21 retired; is that correct? 22 A. That's correct. 23 Q. How did you do that? 24 A. I contacted -- he left me his card, and I contacted him. 25 He was one of several persons I contacted, not from 101 1 News of the World but contacts I'd made through setting 2 up my own business, that I was going to set up my own 3 business. 4 Q. Can you recall what he said to you when you did make 5 contact with him? 6 A. Yes, I do. He says, "We have got work for you", and he 7 says, "If you bear with us for a week or so, or a few 8 weeks, I'll get a back to you on that with some work for 9 you", which he did. 10 Q. Did he ask you to enter into a written contract with 11 News of the World at that stage? 12 A. No. 13 Q. You explain to us that when you began to work for 14 News of the World, you operated under the company name 15 of Silent Shadow Services? 16 A. That is correct. 17 Q. Was that a company that you had set up for the purpose? 18 A. I set it up only by name. It wasn't set up through 19 Companies House or anything like that at that stage. 20 I was going to, and everything was going to be set up as 21 a proper business, but having had the phone call from 22 Mr Thurlbeck and started work, it developed from there, 23 so it only went under a company name for the sole 24 purpose of the invoice that I sent in to 25 News of the World. 102 1 Q. I understand. So that was the name that appeared on 2 your invoices? 3 A. That's right. 4 Q. It's the name you traded under? 5 A. Yes. 6 Q. For the purposes of the work you were doing? 7 A. Yes, and for tax purposes as well. 8 Q. Did you have a private investigator's licence at this 9 time? 10 A. I did get a private investigator's licence, and it 11 wasn't straight away. I applied for that through 12 a company, and I filled in a number of forms, giving 13 details and everything, police service and whatever, and 14 I got a private investigator's licence. 15 Q. Was that a requirement of News of the World? 16 A. No. 17 Q. Was that something that you yourself -- 18 A. That's something I done. 19 LORD JUSTICE LEVESON: Did it give you any advantage? 20 A. It was only that if I was doing surveillance and I got 21 stopped by the police, I would have some sort of 22 authority in relation to doing private investigations 23 licence, in case people phoned up on suspicion there was 24 somebody in the street acting suspiciously. 25 LORD JUSTICE LEVESON: So it was not so much as giving you 103 1 authority to at least provide some evidential support 2 for what you told the police officer? 3 A. Yes, that's it. 4 LORD JUSTICE LEVESON: Yes. 5 MS PATRY HOSKINS: So you've told us you got a PI licence, 6 you set up this company, you started work for 7 News of the World. No written contract. 8 If you look behind tab 11, please, you will see 9 a document that you have prepared, "Working schedule 10 from December 2003 to December 2004". Do you see that? 11 A. Yes, I do. 12 Q. Technician, it's 51548 on the screen. December 2003 13 to December 2004. As I said before, please don't 14 mention any names. There are names on this. Please 15 don't mention any. 16 A. No. 17 Q. We can see your work took off quite quickly. If we look 18 at the range of dates, you start December 2003. 19 Wednesday 17 December to the 19th, you were put on a job 20 in London. You're then called upon again, number 2, 21 30 December. Then 6 January, 7 January, 11 January, 22 22 January. I don't want to read through every single 23 date, but it's obvious they got you to work quickly. 24 Would that be a fair assessment? 25 A. That is correct. 104 1 LORD JUSTICE LEVESON: It probably needs a bit more picking 2 out, doesn't it? What's a shift? 3 A. A shift is eight hours. 4 LORD JUSTICE LEVESON: Thank you. 5 MS PATRY HOSKINS: Yes. The invoice only states three 6 shifts, so a shift was -- 7 A. A shift was 8 hours. A shift and a half was 12 hours, 8 and there was always a grey area in between which 9 I didn't get paid for. 10 Q. What do you mean by a grey area in between? 11 A. A lot of times, they asked me to do 8 o'clock to 4, so 12 the shift would finish at 4 and there was something 13 happening and the surveillance was continuing, or the 14 news desk would say, "Can you stay on for another couple 15 of hours", and I'd stay on for 6 o'clock, but I could 16 only book for the eight hours, the one shift, until the 17 shift and a half arrived at 12 hours. And then again -- 18 so there was another grey area between 13, 14 and 15, 19 until 16 appeared for the two shifts. 20 Q. I understand. 21 LORD JUSTICE LEVESON: So your shifts were rounded down? 22 A. Yes. 23 LORD JUSTICE LEVESON: All right. I understand that. 24 MS PATRY HOSKINS: If we look at the final page of this 25 particular exhibit, you'll see that between the 105 1 period December 2003 and December 2004, you worked 2 a total of 207 shifts, totalling 1,656 hours worked. 3 Grey area never paid: 99 hours. 4 A. Correct. 5 Q. I mention that for the purpose of the judge. You 6 assessed that to be a total of 12 days with no pay at 7 all. Total hours away from home: 101 hours, 30 minutes, 8 for which no additional payment for working away was 9 authorised. 10 A. That is correct. 11 Q. And you explain just under the heading to that section: 12 "Between 17 December 2003 and 22 December 2004, 13 I worked 42 weeks as outlined." 14 A. That is correct. 15 Q. Would it be fair to say that you felt that you were 16 working for News of the World right from the outset 17 pretty much full-time? 18 A. Yes, employed by them, yes. 19 Q. Now, no names, but if we cast our eye over the three 20 pages of that exhibit, we can see the types of jobs that 21 you were put on from the start. Unfortunately those who 22 only have redacted versions won't, but can you agree 23 with me, please, Mr Webb, that it's a combination of -- 24 LORD JUSTICE LEVESON: I have a version where they're greyed 25 out. 106 1 MS PATRY HOSKINS: Mr Webb has a version -- 2 A. These are not greyed out. 3 LORD JUSTICE LEVESON: I think it might be better if he 4 sees -- I mean, can you read the names? 5 A. Yes, I can. 6 LORD JUSTICE LEVESON: That's fair enough. I don't want you 7 to say the names, as Ms Patry Hoskins has said. 8 MS PATRY HOSKINS: Just for your information, there are 9 three different versions: the version he has that is 10 unredacted, the version you have where you can still 11 read the names, and the version which, I'm delighted to 12 say, is on the screen, where there are no names. That 13 was deliberate. 14 LORD JUSTICE LEVESON: Yes. 15 MS PATRY HOSKINS: We can agree, can't we, it's 16 a combination of politicians, celebrities and sports 17 stars in the main? 18 A. In the main, yes. 19 Q. I'll come back to the breakdown of exactly the type of 20 people you were placing under surveillance a bit later, 21 if I can. 22 Now, I want to ask you about how you would be 23 instructed, so how a job would come in, how you would 24 find out about it. You handed to the Inquiry yesterday 25 an email which should look like this. 107 1 Sir, we just handed it to you now. 2 LORD JUSTICE LEVESON: Yes, I've seen it. 3 MS PATRY HOSKINS: It's heavily redacted, for obvious 4 reasons, but it appears to be an email to you from 5 someone at the News of the World? 6 A. That is correct. 7 Q. Giving you the job: 8 "Hi mate, the story is this: X is having an affair 9 with a woman called Y. She is the wife of X's best 10 mate. They live at [an address] ... I don't have 11 pictures of her husband. I have pictures of her." 12 Then it gives you a short email from a researcher 13 and says: 14 "All the best and call if needed." 15 A. That's correct. 16 Q. Now, am I right in saying that this is an email 17 instruction to you to carry out a job? 18 A. Yes. 19 Q. This one is dated 6 May 2011, but can you tell us 20 whether it is representative of the type of instruction 21 that you would get to carry out a job? 22 A. Yes. The instructions would be -- I'd normally get 23 a phone call from someone from the news desk. 24 Q. Yes. 25 A. Or from journalists that might have been elsewhere but 108 1 he was connected to the news desk and he'd been asked by 2 the news desk to give me a call. They would instruct me 3 on a job and say, "Could you go to this location and 4 follow X, Y and Z?" They'd give me the address. Not all 5 the time they would follow it up with an email. On 6 occasions, they would follow it up with an email with 7 other details. If there was no other email to forward 8 out, I'd just be getting the details of the address and 9 that would be it. So I'd write the address down and 10 head there. 11 Q. Okay. So to summarise, over the course of the years, 12 you would receive instructions by phone call, text 13 message, email? 14 A. Yes. 15 Q. Any other means? 16 A. No, they were the main -- 17 Q. But in terms of the instructions that you received by 18 email, is this email fairly typical of the type of email 19 that you would receive? 20 A. Yes, it is. 21 Q. I want to pick you up on one thing. You said the call 22 or the message would come through from the news desk. 23 Was it always the news desk? 24 A. It was always -- the news desk was the hub of 25 everything, and that was where all the information came 109 1 from, but I would get calls from different journalists. 2 So it wouldn't be from a journalist that might be at the 3 news desk at that particular point, he might be 4 somewhere else in the country, but he might have been 5 asked by the news desk to give me a call. But he would 6 always refer: "We have had a tip", or: "The news desk 7 want you to do this particular job." 8 Q. So your understanding was the instructions pretty much 9 always came from or through the news desk? 10 A. Yes. 11 Q. Can I ask you this: did you ever receive an instruction 12 which contained within it the transcript of a text 13 message or a phone conversation or a voicemail message? 14 A. No. 15 Q. So that's 2003. I've taken you through how you were 16 instructed and the types of jobs that you did. We know 17 that you then worked until November 2007 before you had 18 this break. Can I move on to 2007? Remember we 19 discussed the periods when the different editors worked? 20 By the time that Colin Myler was appointed editor at the 21 end of January 2007, you'd been working for 22 News of the World for about three years? 23 A. That is correct. 24 Q. What I want to understand is: did you know there had 25 been a change of editor at News of the World? 110 1 A. I was aware. 2 Q. At that time, you were aware? 3 A. I was aware, yes. 4 Q. Did you notice, in terms of the work that you were 5 given, any difference after Mr Coulson left and Mr Myler 6 started? In terms of the work you were given or the 7 types of assignments you were given, how regularly you 8 were instructed, anything like that? Was there any 9 appreciable difference between Mr Coulson's reign and 10 Mr Myler's reign? 11 A. No, no. 12 Q. Did you suddenly, for example, get fewer types of 13 certain assignments, fewer celebrity assignments, or was 14 the language used by journalists any different when they 15 were instructing you? 16 A. No, no. The journalists would change. There would be 17 journalists come in and journalists go out and go to 18 other newspapers. 19 Q. So journalists came and went? 20 A. That's right. 21 Q. But no appreciable difference in the type of work you 22 were given? 23 A. No, it was the same type of work. 24 Q. Any change in the tips that you were given? 25 A. No. 111 1 Q. You may not know this, but Mr Myler sent a letter to all 2 staff on 7 February 2007 referring to the use of private 3 investigators. Were you aware of that letter? 4 A. No, I wasn't. 5 Q. Did any of the staff instructing you ever refer to that 6 letter? 7 A. No. 8 Q. Did you receive a copy of the PCC code at this time? 9 A. No. 10 Q. We're talking early 2007. 11 A. No. 12 Q. Were you ever given a copy of the PCC code? 13 A. No. 14 Q. Still on 2007, please, I need to ask you about something 15 Mr Crone said in evidence to this Inquiry. Did you hear 16 or watch Mr Crone's evidence to this Inquiry at all? 17 A. No, not all. Not all of it. 18 Q. Okay, I'm going to read out relevant parts. For your 19 note, sir, and for the note of those who were here, it's 20 the 13 December transcript, it's behind tab 20 in your 21 bundle, and it's pages 42 to 43. It might be behind 20 22 in your bundle, but it doesn't matter because I'm going 23 to read it out. 24 I'm going to start on page 41 of the transcript. 25 LORD JUSTICE LEVESON: 41, line ...? 112 1 MS PATRY HOSKINS: Right at the bottom, line 23. 2 LORD JUSTICE LEVESON: Thank you. 3 MS PATRY HOSKINS: Mr Jay is asking Mr Crone some questions 4 and I'm going to read them out to you because you don't 5 have it in front of you and you may not have seen this 6 particular part. Mr Jay is asking Mr Crone about 7 something that he has said already: 8 "After the arrest and conviction of Clive Goodman, 9 a new editor, Colin Myler, came to the News of the World 10 and introduced a number of measures to tighten controls 11 and procedures in order to eliminate illegal or 12 unethical practices." 13 Now, he then refers, on page 42, first to a number 14 of others things and at the top of page 43, Mr Jay 15 continues on in the statement of Mr Crone: 16 "I'm aware that all editorial staff were written to, 17 cash payments were virtually eliminated, a fresh 18 programme and training days were initiated and the use 19 of private detectives was forbidden." 20 Then Mr Jay goes on to ask him about cash payment, 21 which doesn't concern us and I'm going to ignore. At 22 the bottom of page 44, Mr Jay comes back to the issue of 23 private detectives and says this at line 17: 24 "The use of private detectives was forbidden. Was 25 that really the case?" 113 1 Mr Crone answers: 2 "Well, as I understand, that was the case. I mean, 3 I didn't issue the edict. It came from Mr Myler, 4 I believe, or from the managing editor via originally 5 from Mr Myler. 6 "Question: I think my question was more: were 7 private detectives used after 2007? 8 "Answer: Not to my knowledge, no." 9 So we'll pause there. Can I be absolutely clear: 10 you were clearly operating as a private investigator for 11 News of the World during almost all of 2007, weren't 12 you, until November 2007? 13 A. Yes. 14 Q. At no stage were you told, were you: "Stop working"? 15 A. No. 16 Q. Did they suspend your services during that period? 17 A. No. 18 Q. Or say anything to you that might have caused you to 19 believe that they were worrying about the use of your 20 services? 21 A. No. 22 Q. I've already asked you about whether things changed 23 in January or February 2007. Prior to your arrest, 24 which I'm going to come onto in a moment, were you aware 25 of any steps taken by the News of the World to regulate 114 1 your activity or the activity of other private 2 investigators? 3 A. I didn't know about any other private investigators. 4 Q. I'll come back to that, I promise. 5 You then stopped working for the News of the World 6 in November 2007, so what I want to do is ask you about 7 that. I want to ascertain whether your departure from 8 News of the World in November 2007 had anything to do 9 with Mr Crone's belief that Mr Myler may have banned or 10 forbidden the use of private investigators, or indeed 11 anything to do with Mr Myler's clean-up operation at the 12 News of the World. 13 Can I take you back to your witness statement, 14 please, which is behind tab 2. 15 A. Yes. 16 Q. Can we look, please, at paragraph 2 of your statement. 17 You indicate there the dates that, for a period of 15 18 months between 2000 and 2009, the News of the World 19 didn't employ your services. Can you just tell the 20 Inquiry in your own words what happened that led to that 21 departure in November 2007? 22 A. I was arrested -- I was arrested with a serving police 23 officer on the strength of a voicemail message, and 24 having been arrested, there was no strength in the 25 voicemail message, but I was subsequently interviewed by 115 1 the professional standards at Thames Valley, and having 2 gone through a all my paperwork, they charged me with 3 five offences of aiding and abetting misconduct in 4 public office. One of the charges related to an email 5 connected with News of the World. 6 Q. Right. Okay. What I want to understand is what 7 happened. When News of the World found out about 8 this -- it doesn't matter how they found out. What 9 happened when they found out about this? 10 A. They told me I can continue working until and unless 11 charges are brought against me. If charges are brought 12 against me, then they will have to terminate my 13 employment. 14 Q. And were charges brought against you? 15 A. Yes, they were. 16 Q. There are documents, Mr Webb, behind tabs 3 and 4 which 17 are confidential documents. They include 18 a confidentiality agreement between you and 19 News of the World, so I'm not going to ask you about 20 them in any detail and they haven't been disclosed to 21 the core participants for that very reason. But what 22 I want to know is this: what's your understanding of why 23 News of the World terminated the use of your services at 24 this time? 25 A. I think it's because obviously I was arrested and 116 1 charged with the offences outlined, that they felt that 2 I couldn't be involved in the News International 3 procedures in relation to that, and so the compromise 4 agreement was basically for me not to disclose any 5 information that I'd done for News of the World. 6 Q. You'd probably better stop there and not say anything 7 more about the compromise agreement. Right. Did they 8 speak to you about what the position would be if the 9 charges were either dropped or you were acquitted? 10 A. Yes. 11 Q. Did they ever discuss that with you? 12 A. Yes, they did. 13 Q. What did they say about that? 14 A. They said if the charges are dropped or I'm acquitted, 15 then to contact the News of the World and they will 16 reemploy me. 17 Q. To the best of your knowledge and understanding, did the 18 fact that they terminated your services have anything to 19 do with the fact that you were a private investigator or 20 was it solely on the basis that you had been charged 21 with criminal offences? 22 A. Solely the charges. 23 Q. You tell us in your witness statement, paragraph 7, that 24 Mr Crone and Mr Kuttner arranged the compromise 25 agreement. 117 1 A. That is correct. 2 Q. It's important: how do you know that? 3 A. I went into the News of the World building and met up 4 with them, and we sat -- 5 Q. When you say "them", do you mean Mr Kuttner and 6 Mr Crone? 7 A. Yes. 8 Q. Was Mr Crone present at this meeting? 9 A. Mr Crone was there as well, and there was another lady 10 there, yes. 11 Q. Sorry, I spoke over you. Are you absolutely sure that 12 Mr Crone was at the meeting? 13 A. I'm certain as can be. 14 Q. What happened then in respect of the criminal charges? 15 A. They advised me that because I'd been charged, that 16 I wasn't allowed to work for the News of the World, and 17 I am entitled to go and work for any other newspaper. 18 Q. Pausing there, leaving aside News of the World, what 19 happened in respect of the criminal charges that had 20 been brought against you? 21 A. Um ... 22 Q. Did they proceed? 23 A. No, they -- it went to legal -- I was on bail for 18 24 months. It went to legal arguments and it was -- the 25 judge at that particular time -- it was never proceeded 118 1 with. It was dropped. 2 Q. It was dropped, okay. You tell us that you then went 3 back to work for News of the World again? 4 A. That is correct. 5 Q. Who made the approach this time, you or them? 6 A. I phoned up. I phoned up Neville Thurlbeck and told him 7 the result of what had taken place but I wanted some 8 time out until Christmas and that was it, and he told me 9 to contact him early in the new year. 10 Q. So I presume you did contact him? 11 A. I contacted him in the early part of the new year, 12 I think it was either first or second week in January of 13 that -- 2009, and he told me that there's been a little 14 bit of a hiccup, we need you to actually terminate your 15 private investigator's licence and that the bosses 16 require you to get -- join the NUJ. 17 Q. Right. So two things. You had to relinquish your 18 licence? 19 A. In fact, can I just say that -- I say "relinquish my 20 licence". I'd actually let it drop throughout -- when 21 I was -- the previous year when I was actually on bail. 22 So it had actually dropped from the system anyway. 23 Q. But did Mr Thurlbeck know that? 24 A. No. 25 Q. Okay. So am I right in saying he said two things had to 119 1 happen before you came back: you had to relinquish or no 2 longer have a licence? 3 A. Three things. 4 Q. Okay, I'll tell you the two and then you can tell me the 5 third. Secondly, had you to get an NUJ card. And 6 thirdly? 7 A. Yes. Thirdly, I had to change my email address. 8 Q. Right. Which was at the time? 9 A. I'd changed it from Silent Shadow Services to Shadow 10 Watch. So it was Shadow Watch, and I needed to change 11 it -- they wanted it changed from Shadow Watch. 12 Q. Right. To what? 13 A. To Derek Webb Media. 14 Q. So no reference to shadow? 15 A. [redacted] 16 Q. Sorry, I didn't mean for you to have to tell me the 17 exact address. 18 A. I thought you asked for that. 19 Q. Sorry. I understand. 20 Three things, then. What I want to know is this: 21 can you tell me what your understanding was of why 22 News of the World were asking you to do these three 23 things? What did Mr Thurlbeck say to you? 24 A. He told me it's in relation to the Clive Goodman affair, 25 in relation to that matter, that because of the use of 120 1 private investigators, ie Glenn Mulcaire, that they 2 didn't want to be tied up with private investigators. 3 Q. Can you remember any of the exact words in the 4 conversation or is it too long ago? 5 A. It's too long ago, but they were basically the words. 6 It was definitely to do with Clive Goodman that I was 7 told to -- that that was the reason. 8 Q. All right. Why did you agree to do these things? 9 A. For employment. 10 Q. You've already told us that you had no experience of 11 being a journalist, but yet you were being asked to 12 obtain an NUJ card. First of all, what was the process? 13 How did you obtain an NUJ card? 14 A. I contacted another journalist who I knew that didn't 15 work for News of the World and that person signed and 16 got a counter-signature and I sent the form off and it 17 was approved and that was it. 18 Q. You got your NUJ card through the post? 19 A. That's right, and it referred to me -- because I'd put 20 it down as a researcher. 21 LORD JUSTICE LEVESON: Hang on. Did you have to provide any 22 details of qualification to get an NUJ card? 23 A. Nothing. I just basically went through the details that 24 were on the form that I was a police officer -- 25 LORD JUSTICE LEVESON: What sort of details? 121 1 A. It was just basic details about whether I had got any 2 experience in various things, various matters, and 3 I couldn't put any -- that I'd got any experience, but 4 it was accepted. 5 LORD JUSTICE LEVESON: Because you hadn't? 6 A. I hadn't. 7 LORD JUSTICE LEVESON: Yes. All right. 8 MS PATRY HOSKINS: Right. What I want to understand is 9 whether things changed. After you complied with their 10 wishes, gave up the licence, got the NUJ card and 11 changed the email address, did anything change in terms 12 of the work that you were undertaking, the assignments 13 you were given? 14 A. No. 15 Q. And so on? Did you suddenly become a journalist? 16 A. No. 17 Q. If someone had asked you at the time what you did, what 18 would you have said? 19 A. Freelance researcher-cum-journalist. 20 Q. What were you doing in your own mind, Mr Webb? 21 A. Surveillance. 22 Q. Let me ask you these questions: did you ever write any 23 articles for the paper post-2009? 24 A. No. 25 Q. Did you have any bylines published? 122 1 A. No. 2 Q. Did anything change at all from the time you'd been 3 a private investigator from 2003 to 2007? 4 A. Nothing. 5 Q. Did the News of the World give you a copy of the PCC 6 code then? 7 A. No. 8 Q. Did they give you any training on the code? 9 A. No. 10 Q. Were you paid in a different way? 11 A. The same amount. 12 Q. Were your tips any different? 13 A. The same -- when you say the tips, what do you mean? 14 Q. The tips that you were given which would then lead to an 15 assignment. 16 A. Yes -- no, exactly the same. 17 Q. Did they ever discuss with you the public interest in 18 obtaining the information that you were obtaining? 19 A. No. 20 LORD JUSTICE LEVESON: But I rather gather from what you 21 were saying before that most of the time you were just 22 going there to look and report. You weren't given any 23 information? 24 A. I was given certain bits of information in relation that 25 A was having an affair with B or to do with drugs or to 123 1 do with an addiction, so it was very limited sort of 2 information, but given all the details of the people. 3 MS PATRY HOSKINS: Did you even ever know exactly which 4 story it was that you were working on? 5 A. Oh yes, yes. 6 Q. Mr Myler said this in evidence to the Inquiry. I'll 7 read it back to you: 8 "Getting an NUJ card made Mr Webb more aware of his 9 responsibilities whilst working for the 10 News of the World." 11 Is that right? Did it? 12 A. It's a very difficult question. It's a very difficult 13 question to actually answer. 14 Q. Try and answer it, if that's possible. 15 A. I don't think there was any -- there was no difference. 16 I didn't feel different. 17 Q. Perhaps we can agree on the one change that did happen, 18 apart from the change to your email address. You 19 started billing them as Derek Webb, freelance journalist 20 and not as Silent Shadow? 21 A. That is correct. 22 Q. So in terms of the paper trail, you weren't identifying 23 yourself as a private investigator? 24 A. That's right. 25 Q. Nor referring to yourself as Silent Shadow? 124 1 A. Mm. 2 Q. We can see that, can't we, from tab 5? 3 A. Yes. 4 Q. Just for the sake of completeness, right at the back of 5 tab 5, we can see the invoices that you were submitting 6 after this time. 51529 onwards. 7 A. That is correct. 8 Q. You're now headed as freelance journalist -- 9 A. That is correct. 10 Q. -- on your billing. 11 You'll have no knowledge of what I'm about to refer 12 to, but you can take it from me that Mr Kuttner sent an 13 email to, amongst other, Colin Myler and Tom Crone on 14 29 July 2009 which referred to you as Derek Webb, Silent 15 Shadow. Now, the date is important. 29 July 2009. It 16 doesn't matter why that was, but it's right to say, 17 wasn't it, that by July 2009 that company had stopped 18 trading completely? You didn't refer to yourself as 19 Silent Shadow any more? 20 A. That company went out of business on the date of my 21 arrest, when the police took possession of everything. 22 Q. Thank you. I'm going to ask you some general questions 23 now about -- 24 LORD JUSTICE LEVESON: Just before we move from the invoice. 25 They don't identify who you are supposed to be watching; 125 1 they merely identify where you were? 2 A. They asked me to do that. In the initial stages in 3 2003, I did in fact put the name of the person. There 4 is a number of invoices that refer to this. But they 5 asked me to change, and the reason why they asked me to 6 change, to put a name or anything different, is so that 7 the invoice, when it goes through their finance 8 department, wouldn't identify who I was following and it 9 wouldn't be common knowledge. 10 MS PATRY HOSKINS: Is that what they told you, Mr Webb? 11 A. That's what they told me. 12 Q. Can I ask you some general questions about your 13 employment? Were you aware of any other private 14 investigators employed by News of the World? 15 A. I wasn't aware of them. I'd heard rumours. 16 Q. From? 17 A. From photographers that said that other people are 18 working -- other private investigators are working. 19 Q. Can you give us a time period for that? 20 A. The time period was mainly between 2003 and 2007. 21 Q. All right. After 2009, were you aware of any private 22 investigators working for the News of the World? 23 A. No. 24 Q. Apart from you? 25 A. No. 126 1 Q. You tell us in your statement that a very large number 2 of journalists at News of the World instructed you over 3 the course of your time there? 4 A. That is correct. 5 Q. They're all in the statement. I'm not going to read 6 them out, but out of fairness to something Mr Myler said 7 in evidence yesterday, he never personally instructed 8 you, did he? 9 A. No. 10 Q. I'm coming on to ask you about payment now. How were 11 you paid by News of the World? 12 A. I sent my invoice in. 13 Q. Yes. 14 A. And then what they would do is they would raise their 15 own invoice, of which there is copies in the file. 16 Q. Yes. 17 A. And they would send those invoices out to me. In the 18 initial stages, it was all done by -- sent through the 19 post, but obviously in the last six months, it's been 20 done electronically. But they would send those out and 21 within a couple of days the money would be in my bank. 22 Q. If you turn to paragraph 8 of your statement -- so 23 that's back behind tab 2 -- you explain this and you say 24 on page 51509, halfway down the page -- this is the 25 point that Lord Justice Leveson was referring to 127 1 a moment ago: 2 "In the early days, I would title my invoice with 3 the name of the subject of the surveillance but this 4 changed in order that the identity of the subject was 5 not disclosed to the staff within the accounts 6 department. I cannot remember who gave me this 7 instruction but from that point forward, I identified 8 each invoice simply by location." 9 When you say "in the early days", when did this 10 change? 11 A. This changed by 2004, within a matter of several jobs. 12 Q. Were you always paid in this way? Were you ever paid in 13 cash? 14 A. No, always paid this way. 15 Q. I want to ask you now a bit more about the scope and the 16 quality of the work that you were instructed to do. 17 You've explained to us that you would get instructions 18 in different ways: by phone, by email, by text message. 19 To what extent would you be given specific information 20 about the people that you were going to place under 21 surveillance? 22 Let me give you an example. To what extent were you 23 told something like: "We think X is having an affair. 24 Could you please go up to Y address and place that 25 person under surveillance with a view to finding out 128 1 whether that's true"? How often was the tip a specific 2 one with specific pieces of information? 3 A. Yes, there was always specific information. There was 4 never a fishing expedition. 5 Q. Right. That's my question. 6 LORD JUSTICE LEVESON: That depends how you define "fishing 7 expedition", doesn't it? 8 A. I presume that is correct, because obviously if I'm 9 given information that A is having an affair with B, 10 that could be classed as a fishing expedition to find 11 out whether that is correct. 12 LORD JUSTICE LEVESON: Exactly. 13 A. But it wasn't a fishing expedition that they instructed 14 me and said, "Could you go and have a look at A and see 15 whether anything's happening with A and whether they're 16 having an affair"; it was always that they were having 17 an affair and they would always say a little bit extra, 18 that: "We think they're having an affair with B." 19 LORD JUSTICE LEVESON: But the answer to that is, isn't it, 20 to be accurate, you're not fishing. Whether they are, 21 you can't say? 22 A. That is probably correct. 23 MS PATRY HOSKINS: Let me put it another way: did you ever 24 get an instruction that said, "Follow X about for 25 a while, see if you can find anything out"? 129 1 A. No. 2 Q. Were the instructions ever vague -- 3 A. No, they weren't -- 4 Q. -- in terms of what you were trying to achieve? 5 A. No, they were not vague, but obviously you would -- you 6 might have to chase things by going to A to get to B. 7 Q. Can you explain that? 8 A. I'll explain that. That you'd have to follow A, 9 although A wasn't the person that the job is interested 10 in, because they're interested in B and C, but you'd 11 have to follow A to find out where A is going to to meet 12 up with B and then follow on from B. I know that sounds 13 awkward in relation to certain jobs. Not all jobs, but 14 there were some jobs where it was -- specifically where 15 they asked me to go and follow a mother, where the -- to 16 hope that she meets up with the son, to then carry on 17 with the son. 18 Q. I understand. So you were asked to place under 19 surveillance people who might be connected to a famous 20 person, for example? 21 A. That's right. 22 Q. So that they would then maybe lead to you that famous 23 person? 24 A. That's right. 25 Q. I understand. Some of the periods of surveillance were 130 1 quite lengthy? 2 A. Yes. 3 Q. On some occasions you were there for a very short time, 4 on one occasion, and other times up to two weeks I have 5 seen in some cases. 6 A. That's correct. 7 Q. Is that correct? 8 A. Yes. 9 Q. Typically, would it be a matter of a few days or 10 a longer period? 11 A. Well, it varied. It depended upon whether the person 12 was actually on the move or where they were going or 13 whether they were -- on occasions, people would go on 14 holiday in the UK and they would send me and say, "Keep 15 an eye on them on holiday", so I'd be away for a week, 16 two weeks, or whatever. They would say to me, "Follow 17 A", and I might follow A that starts off in Kent and we 18 don't know where the person's going -- when I say "we", 19 I mean referring to the news desk -- but the person 20 would then end up -- I would end up in Liverpool later 21 that day. So it would transpire is that they wouldn't 22 knock the job on the head when I'm up in Liverpool, 23 although it might be a job that they'd only given 24 a couple of days, but things might develop on that job. 25 But equally, there's jobs you go on where you're sitting 131 1 there for a week and nothing happens, where in your own 2 mind you're thinking: "This is not going to happen", but 3 you continue because just in case it does. 4 Q. Mr Thurlbeck said that there were occasions which he 5 found very frustrating where you would be on the job for 6 a couple of days and you wouldn't really have had 7 a chance to find out the information you were being 8 tasked to found out, and then you'd have to be pulled 9 off the job because someone else on the news desk might 10 need your services for something else. Was that 11 accurate? 12 A. It's very frustrating when you know something is 13 definitely happening. What I mean by that is you know 14 someone's using a phone -- when I say "using", I'm 15 seeing them, observing them using a phone and they're 16 obviously speaking to someone. They've come out their 17 house and wandered around the side of their house to use 18 a mobile phone, which could be considered suspicious in 19 relation to me, because obviously I'd be thinking 20 there's something more than meets the eye to this. 21 You'd relay that back, that information, but because of 22 the budget restraints on certain jobs -- certain jobs 23 would get a certain amount of budget and others would 24 get more priority with budgets. So that -- and there 25 might be a more important job. So you'd be taken off 132 1 and put on another job, thinking you might go back to 2 that job but a lots of times you didn't go back to that 3 same job. 4 Q. So he was right to say that there would be occasions 5 where you'd start a job and never get to finish it 6 because you'd be pulled off it and put on something 7 else? 8 A. Mm. 9 Q. I want to ask you about the type of the work that you 10 carried out for News of the World. I'm going to do that 11 by reference to the work schedules you've put in. You 12 said right at the outset that you placed about 150 13 people under surveillance over the eight-year period. 14 Let me ask you this: in terms of how you did it, I'm 15 assuming -- and I'd like you to correct me if I'm 16 wrong -- that it was all surveillance from public 17 places. You didn't try to infiltrate people's homes or 18 private places anything? 19 A. No. They instructed me that from the very outset. 20 Q. What did they say to you about that? 21 A. They said that I do not go on private land, any private 22 property, do not go hunting through rubbish bins and do 23 not take pictures of -- photographs of children or 24 follow children connected to families. So if the child 25 walks up the road, don't follow the child. 133 1 Q. And they told you this from the outset? 2 A. This was from the outset. 3 Q. From 2003 onwards? 4 A. Yes, this was from the very outset. 5 Q. Thank you. We've done here a bit of an analysis of the 6 work schedules. I actually counted 197 people over the 7 schedules that I've seen, but that's because some people 8 appear twice. Again, I don't want any reference to 9 names, but it's clear to me from that analysis that I've 10 done that you mainly followed celebrities, politicians, 11 sportsmen or people with a connection to a celebrity. 12 Would that accord with your recollection? 13 A. Yes, that's correct. 14 Q. And in fact, if you counted sportsmen and families of 15 celebrities as celebrities and put them all in the same 16 category, it's overwhelming. That's overwhelmingly the 17 job that you were given to do, following celebrities? 18 A. Yes. 19 Q. If you were trying to give me a percentage of the time 20 you spent on celebrities as opposed to anyone else, what 21 percentage figure would you put on it? 22 A. I would say celebrities -- but you have to put 23 celebrities with MPs. 24 Q. Okay. 25 A. So I would say 85 per cent. 134 1 Q. Including MPs? 2 A. Yes, including MPs. So MPs and celebrities, 3 85 per cent. 4 Q. All right. And the other 15 per cent? What were they 5 made up of? 6 A. Yes, they were made up of drugs offences, addictions, or 7 crime. 8 Q. All right. So people who were not well-known, but who 9 were connected to those areas? 10 A. Connected to them areas, and obviously lawyers as well. 11 LORD JUSTICE LEVESON: I'm not so sure about "obviously". 12 Does that link them with drug dealers? 13 MS PATRY HOSKINS: Let me ask you no you about the type of 14 instructions that you were given in relation to those 15 people. I have looked through the names and the sorts 16 of tips you were given. Most of these instructions were 17 tips about sexual relationships, affairs, intimate 18 relationships. That's correct, isn't it? 19 A. Yes. 20 Q. Given that you've told us that this was all public 21 surveillance, in the sense that you didn't go into 22 private homes or onto private property, how often was 23 this about uncovering crime, so uncovering drug dealing 24 or corruption or something else? 25 A. That comes into the other 15 per cent. 135 1 Q. That comes into the other 15 per cent. Okay. What 2 about people who were accused or suspected of 3 fraternising with criminals? Did that form any part of 4 the surveillance you undertook? 5 A. No. 6 Q. None at all? Okay. Bearing that in mind, I'd like to 7 go back to -- I'm going to read you parts of 8 Mr Thurlbeck's evidence. Did you watch or -- 9 A. No. 10 Q. -- listen to Mr Thurlbeck's evidence? 11 Sir, you'll find a transcript of his evidence behind 12 tab 18. 13 LORD JUSTICE LEVESON: Thank you. 14 MS PATRY HOSKINS: For everyone else, it's the transcript 15 from 12 December 2011, and we're starting at page 28, 16 please. You don't have to turn this up. It is in your 17 bundle, but I will read it out. 18 He's asked at the bottom of page 26 about the use of 19 private investigators and he says this, top of page 27: 20 "Can I ask you about Mr Derek Webb? [This is Mr Jay 21 speaking] What was your involvement, if any, with him?" 22 And he says: 23 "He would be employed to observe people, report back 24 to journalists on activities that we might be 25 investigating for the paper. He would compile a report, 136 1 a journalist would then act on that report and 2 investigate further with him or alone." 3 Pausing there, that's right, isn't it? 4 A. That's correct. 5 Q. "The question was what was your involvement with him and 6 the answer was he would be employed? 7 "Answer: Yes. 8 "Question: I think the question was more directed 9 to you. Did you employ him? 10 "Answer: I did, yes." 11 That's right, isn't it? 12 A. Yes. 13 Q. Mr Thurlbeck was one of the people who regularly 14 instructed you? 15 A. Yes. 16 Q. "Do you remember approximately when you first started 17 engaging him? 18 "Answer: I think it was at the beginning of 19 2002/2003, something like that. I'm not the quite 20 sure." 21 Q. Well, we know when it was. 22 "Can you remember approximately how many assignments 23 you gave him?" 24 He says: 25 "Dozens. I can't put a number of it, but several 137 1 dozen, I would think." 2 A. I couldn't put a number on it either. 3 Q. "Can you assist us with the type of assignments in 4 general terms?" 5 He says: 6 "Yes, we would -- the newspapers for decades had 7 been involved in observing human behaviour and reporting 8 on it. Derek Webb was especially good at observing, and 9 he would observe and he would compile evidence of all 10 sorts of activities, illegal or otherwise, and he would 11 come back to us and we would act upon whatever he was 12 reporting on." 13 So far so good? 14 A. Yes. 15 Q. "Were your primary surveillance targets politicians and 16 celebrities? 17 "Answer: I would say they formed a large 18 percentage, yes." 19 A. Yes. 20 Q. You have told us it was 85 per cent celebrities and 21 politicians? 22 A. Yes. 23 Q. So you'd agree with him there. 24 " In relation to celebrities -- take them first -- 25 were the assignments in the main directed to finding out 138 1 about their private lives?" 2 And he says this: 3 "Only if their private life came into conflict with 4 their public life." 5 I'm not going to ask you to comment on that. It's 6 not a matter for you. 7 "That wasn't the question. Did the assignments in 8 the main relate to their private lives? 9 "Answer: Yes. 10 "Question: In other words -- 11 "Answer: Their activities. 12 "Question: -- their intimate relationships? 13 "Answer: Not always. 14 "Question: But usually, is that right? 15 "Answer: I wouldn't say 'usually'. Sometimes it 16 could be their intimate relationships or sometimes it 17 could be drug-taking or sometimes it would be maybe 18 fraternising with undesirables, but it was right across 19 the spectrum." 20 You've told us, I think, that surveillance of people 21 who were accused or suspected of fraternising with 22 undesirables or criminals -- 23 A. Unless you're classing A meeting B, if they're having 24 a relationship, that is classing -- unless they are 25 classing that as undesirables. 139 1 Q. You weren't specifically asked to place anyone under 2 surveillance for the sole reason that they were 3 fraternising with someone undesirable such as 4 a criminal; is that right? 5 A. No, that's right. 6 Q. Okay. 7 A. Not that I can remember, anyway. 8 Q. What about drug taking? 9 A. Yes, the drug taking, that's -- that did come into play. 10 Q. Within the 15 per cent? 11 A. That's within the 15 per cent. 12 Q. And within that 15 per cent, how many cases did you 13 investigate or how many people did you place under 14 surveillance for the purpose of that topic? 15 A. I think there was only two or three. 16 Q. All right. I think I can pause there with 17 Mr Thurlbeck's evidence. 18 I said that I would come back to placing certain 19 persons under surveillance for longer periods. We've 20 seen -- I'll turn it up if you would like, but on some 21 occasions you kept certain public figures under 22 surveillance for a period of up to two weeks. 23 A. That is correct. 24 Q. Without naming any names, give us an example of what you 25 would be doing for two weeks. 140 1 A. I would actually be following them, whether it be on 2 foot or whether it be in a car, and solely watching them 3 day in, day out. 4 Q. All with the purpose of trying to establish the 5 information that you'd been given? 6 A. Yes. So on a day, you don't know whether you're going 7 to be on the move the whole of the day or part of a day. 8 If you were following an MP and an MP would go into the 9 House of Commons, then it would be very difficult. He 10 might be there all day before they come out. So it's 11 very, very difficult to analyse exactly how long you'd 12 do the surveillance for because obviously you might be 13 called off at 5 o'clock -- they'd say, "No, knock it on 14 the head" -- or carry on, going into the evening when 15 they come out. So it's very, very difficult. It 16 depends if the person is actually on the move or where 17 they're going. 18 Q. Okay. In respect of one job you were given -- I think 19 I can say this -- you kept the wife of a famous 20 footballer under surveillance for a month? 21 A. Yes. 22 Q. What did that entail? 23 A. A lot of hard work. 24 Q. I'm sure that's right. 25 A. She went everywhere. 141 1 Q. All right. I won't ask you anything more about the 2 specifics of that job. 3 I am coming on to ask you about some specific 4 examples of some of the investigations you were asked to 5 undertake. The first relates to Mr Watson MP. It's 6 very important I'm not going to ask you about what you 7 found out, if anything, about Mr Watson, but I do want 8 to understand: were you given specific instructions to 9 place Mr Watson under surveillance? 10 A. Yes, I was. 11 Q. Were you given a specific instruction as to what you 12 were to find out about Mr Watson? 13 A. Yes. 14 Q. So was it a fishing expedition in any sense? 15 A. No. 16 Q. Were you told who he was or what his role was in public 17 life? 18 A. Yes, I was. I was aware. 19 Q. Were you aware that he sat on a Select Committee? 20 A. No, not at that particular time when I carried out the 21 surveillance. 22 Q. All right, I'm going to park it there. I'm going to 23 turn on now, please, to the surveillance of Ms Harris 24 and a gentleman called Mr Mark Lewis, if I can. You 25 deal with this in your witness statement, so if we turn 142 1 back to that. You were asked about this at 2 paragraph 11, 51510. You explain at the third 3 paragraph, under the heading 11, that were asked on two 4 separate occasions to follow two solicitors. Do you see 5 that? 6 A. That is correct. 7 Q. Can I ask you -- 8 A. Can I actually say on the first occasion I was asked to 9 follow one solicitor to see whether he'd meet up with 10 the other solicitor. 11 Q. Let's start right at the at the beginning. Who 12 instructed you on this particular job? Can you 13 remember? 14 A. I can't remember. It came from the news desk. I was on 15 a job in Surrey and I was asked -- the person who gave 16 me the job in Surrey said, "You have been knocked on the 17 head on that. Can you make your way to Manchester? The 18 news desk want you to do another job in Manchester." So 19 I made my way to Manchester -- 20 Q. At that stage, did you know anything being why you were 21 going to Manchester? 22 A. No, I didn't know anything about the job and 23 I remember -- I vaguely remember texting the journalist 24 that was dealing with the Surrey job and said to him -- 25 because I was not far off of Manchester and it was 143 1 getting late in the day, and I said, "I've not had any 2 instructions", and then I understand -- I can't be 3 100 per cent on this, whether it came through from 4 somebody from the news desk or whether it came through 5 on a text. I've got the vaguest feeling that it came 6 through a start-off on a text: "Can you go to this 7 address?" 8 Q. Right. 9 A. So I headed for that address. 10 Q. At that stage, that's all you knew, an address? 11 A. Yes, and then when I arrived at that address, I was 12 instructed -- I had a phone call from the news desk 13 saying, "We want you to place this solicitor under 14 observations, but can you start tomorrow?" So because 15 it was late in the day -- on that first day. 16 Q. Can you recall the names of anyone that you spoke to on 17 that day on the news desk? 18 A. I can't remember -- because the trouble is a lot of the 19 people from the news desk I don't know in person, so 20 it's names. So I can't put a name to a face. Some of 21 them I can do, but others I can't. It's only over 22 a period of time. I cannot remember precisely who gave 23 me that information at that particular time, that first 24 initial details. 25 Q. Okay. So you were told to place the person, the man who 144 1 lived at that address, under surveillance; is that 2 correct? 3 A. A person, yes. 4 Q. Were you given a reason why? What were you trying to 5 find out? 6 A. Yes, that he was having an affair with another person. 7 Q. Okay. I don't want you to say anything else. I don't 8 know if you were told anything else, but I don't want 9 you to say anything else, please. 10 Now, you said that you were called off that night. 11 Did you undertake that surveillance the next day? 12 A. I carried on that night for actually a little while and 13 watched, just to get the feeling of where I could sit, 14 where the locations are for the following day. 15 Q. And then what happened the next day? 16 A. The following day I -- from my memory -- and I know that 17 no male appeared from that address, and I can't remember 18 whether it was -- what time of the day, but I contacted 19 the news desk and said, "There's no male here at the 20 address." And somebody from the news desk said, "Can 21 you describe the woman?" and I said, "She's got dark 22 hair." So they said, "Can you follow her to see -- can 23 you follow her and take a picture of her?" So 24 I followed her and took a picture of her. 25 Q. All right. At that stage, had you been given the name 145 1 of the man that you were supposed to be finding? 2 A. I'd been given a name of a man, yes. 3 Q. Let's not mention it. Was it Mark Lewis? 4 A. No. 5 Q. Right. How did you obtain photographic evidence of the 6 woman that you had described to the news desk? 7 A. I followed her into a garden centre and then I had my 8 video bag and I had it on. So I was zooming in here, 9 there and everywhere. 10 Q. How long did you survey her for? How long did this 11 period of surveillance take place? 12 A. I can't honestly say. 13 Q. Okay. 14 A. I followed her all day, obviously, but I can't honestly 15 say how long the video took. The video was just 16 a picture. 17 Q. What did you do with the footage that you had obtained? 18 A. I was told that it would be collected from my hotel that 19 night. 20 Q. So did you prepare it for collection? 21 A. I put it in an envelope and -- 22 Q. With a note? 23 A. I've only seen the note very recently. 24 Q. Sir, it should have been -- I think everybody has been 25 given a copy. Do you have a copy in front of you? 146 1 A. Yes, I have. I only saw this on 5 November via someone 2 else. 3 Q. First of all, let's start with the basics. Is this your 4 handwriting? 5 A. Yes, it is. 6 Q. Is this a note that you prepared? 7 A. Yes. 8 Q. If you cast your eye over it, it's addressed to Ian. 9 Who would that be? 10 A. That would be Ian Edmondson. 11 Q. I'm going to read it for the benefit of those who don't 12 have it in front of them: 13 "The video is a bit up and down in the beginning. 14 Then there is close up shots of her. She kept moving 15 around, as you can see. You may think it's finished at 16 one stage but let it run. Its total is about five to 17 six minutes. Any questions need answering, call me. 18 Phone on all time except a few hours during wedding on 19 Tuesday, 12 to 4-ish. I am back on first flight Monday, 20 week 12 April if you need me to go back up there. 21 Cheers, Derek." 22 Is that note self-explanatory? 23 A. That is. 24 Q. Is there anything that's you want to say about it? 25 A. No. 147 1 Q. Was this the note that you sent down with video 2 footage -- 3 A. That's is it. 4 Q. -- to Mr Edmondson? Was it collected from your hotel as 5 planned? 6 A. Yes, it was. 7 Q. Did you stay in Manchester that evening? 8 A. Yes, I did. 9 Q. Did you speak with either Mr Edmondson or someone else 10 from the news desk the next day? 11 A. I was told by someone from the news desk to stand down, 12 it's not the woman. 13 Q. You were told to stand down, that it was not the right 14 woman? 15 A. That it was not the woman in question. 16 Q. Did you prepare any note or report as a result of that 17 short period of investigation? 18 A. I believe not. I would have known -- I didn't have 19 a laptop up there and I wouldn't have prepared a note -- 20 unless I prepared a note inside with this saying that -- 21 the name and address of the garden centre, but I can't 22 remember 100 per cent. But that would have only been 23 that. 24 Q. Were you ever instructed to go back up to Manchester and 25 carry on this particular assignment? 148 1 A. Yes. 2 Q. When was that? 3 A. I was contacted on the 10th -- and I know it was the 4 10th -- 5 Q. The 10th of ...? 6 A. 10 April. I know it was the 10th because I printed out 7 copies of two photographs and I was told to go up there 8 on the 12th and I would have had a phone call from the 9 news desk on the 10th because they're printed out on 10 10 April. 11 Q. What were these photographs that you printed out? 12 A. The photographs were two photographs. It was one of the 13 original male that I was told to follow. 14 Q. Pause there. Not Mark Lewis? 15 A. Not Mark Lewis. 16 Q. And the other person? 17 A. The other person -- do you want me to name this person? 18 Q. Yes. 19 A. Charlotte -- Charlotte Lewis. No, sorry -- yes. 20 Q. And what were you asked to do on the 10th? 21 A. I was asked to follow these solicitors around to see 22 where they'd meet up, and I wasn't given instructions on 23 how I wanted to do it. They basically said, "We will 24 leave it to you to go on whichever solicitor's office 25 you want to go on." 149 1 Q. Were you given details then of their particular 2 solicitors offices that they worked at? 3 A. Yes, I was, and reason why -- because I was given that 4 on the Saturday. That's the reason why I printed out, 5 knowing full well there would be numerous people going 6 in and out of the solicitors' offices. That's why 7 I printed them out on the 10th, where I never printed 8 them out on the 1st because I'm going to a specific 9 address. 10 Q. So when did the job commence? When did you start the 11 surveillance again? 12 A. On the 12th I started. 13 Q. How many days did that particular job last? 14 A. It lasted till the Friday, from the Monday to the 15 Friday. 16 Q. Did you ever catch sight of either Ms Harris or the 17 other gentleman? 18 A. No. 19 Q. Did you obtain any video footage of either of them? 20 A. No. 21 Q. Why did you stop the job on the Friday? 22 A. I was informed by the news desk that they'd found out 23 that they were in London. 24 Q. Were you ever asked to place them under surveillance 25 again? 150 1 A. No. 2 Q. Did you produce any report or log of that particular 3 week of surveillance? 4 A. No. 5 Q. Did you ever deal, in connection with this surveillance, 6 with a gentleman called Julian Pike? 7 A. No. 8 Q. I'm going to ask you now, finally, please, about the 9 time when the News of the World closed, obviously, 10 in July 2011. Presumably you then stopped receiving 11 instructions when it closed? 12 A. Yes. 13 Q. Can I ask you this? Why did you decide to speak out 14 publicly about the work that you had undertaken for 15 them? 16 A. It's -- during the three months after the closure, I was 17 in communication with News of the World, 18 News International, because I was aware that other 19 freelance people up and down the country had received 20 loyalty payments for the three months and everyone 21 I spoke to had had these payments, except me. So 22 I contacted the News International team and informed 23 them and they said to me I hadn't worked enough days for 24 them. So I thought, well, this is strange that they 25 were distancing themselves from me, so I compiled the 151 1 schedule solely for that, not for this. This schedule 2 was compiled solely to show them how many days I'd 3 worked and obviously the grey areas and everything like 4 this. Sent them in, and they advised me to take the 5 schedules to the police, which I thought was very 6 strange, because what I was trying to do was get loyalty 7 payments from them, rather than going to the police. 8 I was then told -- the next thing is that I was -- 9 then had communication with a particular journalist, who 10 told me that there was going to be certain things 11 published in the paper, that I had done the surveillance 12 and the surveillance logs and various other things in 13 relation to the solicitors which we'd mentioned, knowing 14 full well I hadn't. I was going to be connected to that 15 and linked in that way. 16 I was then -- this was on -- I believe it was 17 4 November. It was before the 5th. On 5 November, 18 I was then informed by Newsnight and they showed me the 19 document which we referred to, which is my note to 20 Ian Edmondson. 21 Q. Yes? 22 A. Together with some other documentation that put me into 23 a job which was all to do with surveillance of the two 24 solicitors in question. 25 I was then aware of all of this information, coupled 152 1 with what News International were saying. So they were 2 distancing themselves from me and I thought: "I'm being 3 linked in here to something I'm not involved in", and 4 I was not involved in it in any shape or form. 5 So I had an option to either speak up or to let the 6 media take its toll in relation to accusing me of all 7 sorts of things that I hadn't done. So that is the 8 reason why I spoke out, and this was solely that reason. 9 This was not to do with loyalty payments, as what was 10 published in every paper. 11 Q. I was going to say: some might say that you hold 12 a grudge against News of the World -- 13 A. I've git no grudge. 14 Q. -- because of the fact they didn't give you any loyalty 15 payment. Would that be right? 16 A. I've got no grudge against them. I was just trying to 17 get loyalty payments, which everyone else had, to keep 18 me tied over for three months for work until I found 19 other work. 20 Q. I understand. Perhaps I can ask you it this way: has 21 anyone at News International ever identified to you any 22 part of your statement or anything that you said that 23 might simply be untruthful or incorrect? 24 A. No, they haven't. 25 MS PATRY HOSKINS: Sir, those are my questions for Mr Webb. 153 1 Thank you very much indeed. 2 Thank you, Mr Webb. There may be some more 3 questions. 4 LORD JUSTICE LEVESON: No. Oh, yes? 5 MR SHERBORNE: Sir, I have two questions, if I may. I've 6 mentioned them to Ms Patry Hoskins and she said she 7 wasn't intending to deal with those matters, for reasons 8 which -- 9 LORD JUSTICE LEVESON: On what topic? 10 MR SHERBORNE: One relates to one of the core participants 11 and the other relates to the surveillance of the two 12 lawyers. 13 LORD JUSTICE LEVESON: All right. 14 MR SHERBORNE: I'm grateful. 15 Questions by MR SHERBORNE 16 MR SHERBORNE: Mr Webb, you say, perfectly fairly, in your 17 witness statement that the schedule of targets that you 18 were asked to carry out surveillance on by the 19 News of the World that you've reconstructed is 20 incomplete. Is that right? 21 A. The schedule has got a few gaps in. 22 Q. Yes. I think we all understand why, but I just wanted 23 to check that it's not a complete list of all the people 24 you were asked to carry out surveillance on? 25 A. If I can say that the dates are precisely the dates. 154 1 There's no other dates to be added in there. 2 Q. I understand. 3 A. It's only a gap of where I can't remember the name of 4 the person or I haven't got the invoice, because certain 5 other ones -- my diaries are still held by the Thames 6 Valley police in relation to 2006 and I've never had 7 them returned, so there's gaps where I can't identify 8 them with the invoices. 9 MR SHERBORNE: I understand. Obviously I don't have the 10 list of names, in the sense I don't have the unredacted 11 list, but can I ask you this -- and I just want a "yes" 12 or "no" at this stage: were you ever asked by the 13 News of the World to carry out surveillance on my 14 client, the core participant Sienna Miller, or Jude Law 15 between 2003 and 2005? 16 A. On one occasion. 17 Q. You were. 18 A. I think it was one day. 19 Q. I'm not going to ask you anything more. I just wanted 20 to -- 21 A. But I was pulled off immediately. 22 Q. Thank you, Mr Webb. 23 A. It's very important to emphasise that, because there was 24 a reason why I was pulled off immediately. 25 Q. I'm not going to ask you that reason, for reasons which 155 1 I'm sure are obvious. That's all I wanted to ask you, 2 Mr Webb. Thank you. 3 Then finally this, Mr Webb. You said you were asked 4 not to follow children. We now know from the police 5 that -- I understand at the time that you weren't 6 meaning to, but we now know that you did film Mr Lewis's 7 14-year-old daughter. Mr Lewis is at the back of the 8 court here. Is there anything you would like to say to 9 him as a result? 10 A. All I can say is that it's most important -- because in 11 his statement to the Leveson Inquiry, he actually said 12 that the police had spoke to him on the 4th and that 13 they showed him a video. They showed him a video and 14 they said there's documentation that relates to me in 15 relation to that. I have never been shown a copy of 16 this video, so I'm assuming that we're talking -- if 17 we're talking about the same video. 18 MR SHERBORNE: As I understand it, we're talking about the 19 video that you referred to in this document. 20 A. But I've not seen that video to confirm that we are 21 talking about the same person. 22 Q. So you're saying, Mr Webb, that as far as you're aware, 23 you don't know whether the person you filmed was 24 Mr Lewis's 14-year-old daughter or not? 25 A. Exactly. 156 1 MR SHERBORNE: Thank you, Mr Webb. 2 LORD JUSTICE LEVESON: Thank you very much indeed, Mr Webb. 3 MS PATRY HOSKINS: Sir, Mr Webb was our only witness this 4 afternoon. I don't know if there's any other matter 5 that needs to be dealt with. 6 MR SHERBORNE: Sir, yes. If we've completed today's 7 evidence, there are a few matters I need to raise. 8 LORD JUSTICE LEVESON: Yes. I would like -- we'll let 9 Mr Webb go.