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Ms. Rowena Collins-RiceSecretary to the Leveson Inquiryc/o the Royal Courts of JusticeThe StrandLondon WC2A 2LL

30 August, 2011

Sent by email and post.

Dear Ms. Collins-Rice

RE: PIERS MORGAN AS EXPERT WITNESS / CORE PARTICIPANT

According to Rule Five of the Inquiries Rules (2006) core participants of an inquiry must have:

“...played, or may have played, a direct and significant role in relation to the matters towhich the inquiry relates;

(b)the person has a significant interest in an important aspect of the matters towhich the inquiry relates; or

(c)the person may be subject to explicit or significant criticism during the inquiry proceedings or in the report, or in any interim report.”

Given that Piers Morgan is a former employee of the Sun and editor of the the News of the World and the Mirror , his expertise in ways of the tabloids will surely be of interest to the Leveson Inquiry.He has spoken widely and knowledgeably on the subject of phone-hacking and we believe he canpersonally provide evidence that renders him appropriate for core participant status.

By way of example consider Morgan's evidence to Parliament’s Culture Media and Sport SelectCommittee in 2003:

“I think, the working practices of a daily tabloid newspaper, of actually what goes on,you need to understand… in my view, there is very little difference now between theway the tabloids operate and the broadsheet newspapers.”

The inquiry would without doubt benefit from more information as to what exactly these“tactics” entailed. While phone-hacking was rife across Fleet Street Morgan told Parliament:

“I have never known standards to be higher than they are today, particularly inrelation to how we deal with ordinary people. I have never known it better.”

F : 070 9201 2337 E : [email protected]

A campaign advocating political transparency and openness.

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Yet data from “Operation Motorman” reveals that the Mirror Group paid private investigators some£442,878.73 to illegally procure personal data like tax records, DVLA records, medical and phonerecords. Sixty-five invoices for criminal transactions can be traced back directly to Piers Morgan’sDaily Mirror during his time as editor. This is at a time when he told the CMS committee he shouldbe “congratulated” for cleaning up the paper and operating the Press Complaints Commission’sCode of Practice “effectively and seriously” .

The inquiry would benefit from hearing exactly how this contradiction arose and it is not just the“Operation Motorman” data that leads to questions arising about the Mirror under Piers Morgan.

Not only has he spoken about both the theory and the practice of phone-hacking but former employees have lifted the lid. “Many of the Daily Mirror’s stories would come from hacking into acelebrity’s voicemail,” James Hipwell said of his time at the Mirror between 1998 and his sackingin early 2000. Morgan was editor from 1995 to 2004. Hipwell also said:

“ I used to see it going on around me all the time when I worked at the Daily Mirror. I sat right next to the show business desk and there were some show biz reporters who did it asa matter of course, as a basic part of their working day. One of their bosses would wander up and instruct a reporter to `trawl the usual suspects’, which meant going through thevoice messages of celebrities and celebrity PR agents. For everyone to pretend that this issome isolated activity found only at the News of the World is ridiculous, it’s just a lie.”

During a June 2009 appearance on ‘Desert Island Discs’ on Radio Four with Kirsty Young, Morganwas asked directly about phone-hacking

KY: And what about this nice middle class boy who would have to be dealing with I meanessentially people who rake through people’s bins for a living…

PM: Well I…

KY: People who tap peoples phones , people who take secret photographs…

PM: I know but…

KY: …who do all that very nasty down in the gutter stuff, how did you feel about that?

PM: Well to be honest lets put that in to perspective as well, not a lot of that went on. A lot of it was done…

KY: Really?

PM: A lot of it was done by third parties, rather than the staff themselves, that’s not todefend it, because obviously you were running the results of their work. I’m quite happy tobe parked in the corner of tabloid beast and to have to sit here and defend all the things I used to get up to and I make no pretence about the stuff we used to do. I simply say the net of people doing it was very wide and a certainly encompassed the high and the low end of the supposed newspaper market.

Just six months ago Morgan told GQ magazine:

F : 070 9201 2337 E : [email protected]

A campaign advocating political transparency and openness.

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“It was pretty well-known that if you didn’t change your pin code when you were acelebrity who bought a new phone, then reporters could ring your mobile, tap in astandard factory setting number and hear your messages. That is not, to me, asserious as planting a bug in someone’s house, which is what some people seem tothink was going on.

…loads of newspaper journalists were doing it. Clive Goodman, the NOTW reporter,

has been made the scapegoat for a very widespread practice… Not defending him, just expressing sympathy for someone who has been made a scapegoat.

…they used to do it to me. And no, I didn’t like it. But with new technology comes new temptation and new issues.”

In a diary entry from 2001 Morgan wrote knowingly:

“Apparently if you don’t change the standard security code that every phone comes with,then anyone can call your number and, if you don’t answer, tap in the standard four digit code to hear all your messages. I’ll change mine just in case, but it makes me wonder how many public figures and celebrities are aware of this little trick.”

Whilst in volume three of his diaries Morgan wrote in 2009:

“...it was the Daily Mirror, under my editorship, which exposed Sven’s fling with UlrikaJonsson after learning of a similar message left by the then England manager on her

phone”

Promoting that same book he wrote in the Daily Mail, in relation to Heather Mills and PaulMcCartney, that

“at one stage I was played a tape of a message Paul had left for Heather on her mobile phone.”

The inquiry must surely want to know how the tape which he heard was acquired.

His career alone makes Morgan a valuable source for any inquiry into media standards, but as youcan see he also has specialist knowledge of phone-hacking, easily making him worthy of coreparticipant status as an expert witness.

Yours sincerely,

Harry ColeThe Sunlight [email protected]

F : 070 9201 2337 E : [email protected]

A campaign advocating political transparency and openness.