First witness statement of: E Verity

Filed on behalf of: Defendant

Statement date: 4 December 2020
Exhibit EV1

IN THE HIGH COURT OF JUSTICE CLAIM NO: IL-2019-000110

BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES

INTELLECTUAL PROPERTY LIST (ChD)

BETWEEN

HRH THE DUCHESS OF SUSSEX

Claimant

and

ASSOCIATED NEWSPAPERS LIMITED

Defendant

FIRST WITNESS STATEMENT OF EDWARD VERITY

I, Edward Verity, Editor of The Mail on Sunday, Northcliffe House, 2 Derry Street, London, W8
5TT, WILL SAY AS FOLLOWS:

1. I am the Editor of The Mail on Sunday and was Editor at the time of publication of the February
2019 articles which have given rise to these proceedings. Before I became Editor of The Mail
on Sunday I had worked for the Defendant in a variety of editorial roles for almost 30 years.
 Editorial considerations about the 10 February 2019 articles

2. The Mail on Sunday publishes regular stories about the royal family, reflecting our readers'
interest in royal affairs. All members of the royal family enjoy immense wealth and privilege and
cost the British taxpayer a significant amount of money. It seems to me that there is a
legitimate public interest in the behaviour of members of the royal family and their suitability to
enjoy those enormous privileges. In addition, there is a proper public interest in the conduct of
the royal family as a family, in respect of their relationships with each other. Royal weddings,
for example, are major national events, as are royal births. There had been a massive amount
of public interest in the wedding of the Duke of Sussex to the Claimant in May 2018 and in
common with many other newspapers we had provided extensive coverage of the wedding and
had published many stories about the couple themselves. One of the particular features of the
story of the wedding was the non-attendance of the Claimant’s father – a matter about which I
recall the palace issued a public statement. There had been much public speculation as to the
reasons for that and the nature of the Claimant’s relationship with her father.

3. In early February 2019 People magazine published a feature about the Claimant based on
information provided by five of her friends. That feature was trailed on the front page of the
magazine, which was emblazoned with the headline “The Truth About Meghan”. The feature
was a flattering portrayal of the Claimant, said to be based on information from “a loyal circle of
close friends”. The closeness of the relationships was highlighted by reference to the fact that
those friends had visited the Claimant in England (it is not clear if separately or together). The
information in the article included an account from a “longtime friend” as to events leading up to
the breakdown of the Claimant’s relationship with her father, including the events leading up
the wedding and his non-attendance at the wedding, and their communications after the
wedding. It included a description of the contents of the letter she had written him (the subject-
matter of this claim) and of the letter he had written to her in response, and the Claimant's
reaction to that response.

4. The People magazine articles were major news events and were reported in news media all
over the world. The Defendant covered it in Mail Online, and it was also picked up by many
other national media outlets. It was a major news story that the Duchess of Sussex, a member
of the royal family, had, as it appeared, used close friends and confidantes to promote a highly
flattering image of herself in an American media outlet, and that those friends had given
information of quite a personal nature about the Claimant (and the Claimant’s father) to that

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 outlet, including information as to the Claimant’s lifestyle and relationships. Of particular
significance was the information revealed as to the Claimant’s relationship and
communications with her father, because People magazine set out for the first time an account
of events from the Claimant's perspective leading to the Claimant’s father not attending the
wedding and the subsequent breakdown of their relationship.

5. After publication of the article in People magazine our Los Angeles-based reporter Caroline
Graham was in touch with the Claimant's father (whom she already knew) and discussed with
him what had been published in People magazine. It emerged that he considered the events
described in the People article leading to the breakdown of his relationship with the Claimant,
including their correspondence after the wedding, had been very seriously misrepresented.
One aspect of this misrepresentation was that the description of the contents of the Claimant’s
letter to him (“Dad, I’m so heartbroken. I love you. I have one father. Please stop victimising me
through the media so we can repair our relationship”) was false; the letter had not sought to
repair their relationship (a fact which I am told that the Claimant has now admitted in this
claim), and that could be seen from the text of the letter itself. Another aspect was that Mr
Markle’s letter to his daughter was also misrepresented; he had not asked for a “photo op” as
the People article stated. The events leading up to the wedding were also described entirely
from the Claimant’s point of view and in a way that Mr Markle believed was very unfair to him.

6. For all these reasons, Mr Markle wanted Caroline to help him to set the record straight about
what had actually happened. In order to tell Caroline his story he provided her with a copy of
the letter the Claimant had sent him ("the Letter"). He did not want the whole Letter published
because he thought it made his daughter look terrible, but he wanted to show people that what
they might have read in People magazine was inaccurate and unfair to him. He also provided
information as to the various ways in which the People article, and the Claimant’s letter to him,
in his view contained false information.

7. I was satisfied that there were good reasons to publish the story that Caroline produced for us.
It seemed clear to me from the Letter that its tone and contents had been misrepresented by
People magazine in a way that was unfair to Tom and was partial to the Claimant and which
therefore distorted the truth about what the Claimant had written to her father. I read the Letter
as a rather legalistic kind of "J'Accuse" – which was not how it was portrayed in People
magazine. It therefore seemed to me that what Tom was saying was credible, and that he was
entitled to correct the record and it was right to give him an opportunity to do so.

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8. We also felt that there were other good reasons to report this story. The People article was a
major news story about a prominent member of the British royal family that we needed to cover
properly. The information we had from Tom called into question the Claimant’s conduct and
behaviour and, in the light of her royal status, it was important that those issues were brought
to light. We also felt it was newsworthy and important that – as it appeared to us at the time
and still does, despite the Claimant’s denials – the Claimant had used the media, that is People
magazine, to promote a particular, very positive, loving and caring image of herself that she
wanted in the media. There were serious questions around the appropriateness of “Meghan’s
media fightback”, as the first heading to the first article in the Mail on Sunday put it.

9. Having decided to publish the story, I was very clear in my own mind that it was absolutely vital
to quote from the Claimant’s Letter. It was clear that the People article had set out an
inaccurate description of the contents of the Letter. The summary of the message of the Letter
as set out in paragraph 5 above was very misleading about the tone and content of the Letter.
It would have been very poor journalism merely to give a further description of what was in the
Letter and doing so would not have emphatically established the inaccuracy of what had been
published in People magazine. I felt that giving readers extracts in print for them to read for
themselves was a much fairer representation than trying to summarise the contents for them.
Readers can make their own minds up by reading the extracts themselves. If you summarise
things there is a danger that the summary might be partial or slanted. The fairest and indeed
the only effective way to let readers understand exactly what the Claimant was saying to her
father was to publish and show the actual words from the Letter.

10. Furthermore, if we had published the information by summarising the contents – rather than
publishing extracts from the Letter – readers might find the points made in the story as to the
inaccurate and unfair description of the Letter in People much less credible. Readers are very
sceptical. They might have thought that we had misdescribed the Letter or even that we had
actually not seen it. You go out of your way as a journalist to prove to your readers that what
you are saying is real and true. The reason to quote directly from the Letter and to reproduce
excerpts of the Letter showing the Claimant's handwriting is that it shows people this is the real
thing. Also, Tom had not received the best press up to that point and a story simply reporting
what he had said about the Letter, without quoting it, would not have had credibility.

11. My discussions with colleagues about the story included consideration of how the Letter itself
was to be presented in the published article, what bits to include and what bits to leave out.
We included what we believed was the minimum necessary in order to establish the accuracy
and credibility of our story. There are bits we deliberately left out. They were tangential to the

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 point the Claimant's father was trying to make in correcting the record, and in some cases there
were other good reasons for omitting them. For example, there was a bit about the Claimant's
grandmother which would have disclosed personal information about her that we self-
censored. Another example was some wording that referred to the specifics of Tom’s medical
issues that we cut out of a sentence. But we went through the Letter and took the bits that we
thought best represented its overall point and tone, and also the bits which Tom told us were
wrong. My deputy, Tristan Davies, was responsible for putting it on the page, i.e. deciding how
the finished story would look. Our overall aim was to give a fair and accurate representation of
the Letter but without reproducing more than was necessary to achieve accuracy and fairness.
In relation to the parts of the Letter we quoted, we set out (under each quotation) exactly why
Tom disputed what the Claimant had said in the Letter, so that readers would understand the
rival accounts.

12. I decided that Tom should have sign-off on how much and what we included. It was a story he
wanted to tell and we wanted to make sure he was happy with it. Also, we want what we
publish to be right. If someone is very close to a story, it often seems (and seemed in this case)
sensible and right to get them to look at it before publication to check that it is all accurate and
fair. Tom approved the extracts that we had chosen.

13. The articles relied upon by the Claimant presented the same overall story but approached the
story from different angles. In the hard copy newspaper, they were presented together over two
spreads (i.e. over four pages), although on the website each part could be accessed
independently. This approach of presenting the same story in different ways is common
practice.

14. While this was a unique story, it is certainly not unique for the Mail on Sunday and other
newspapers to publish extracts from letters and other documents as part of their
reporting. This is often done for good editorial reasons, so readers can see the source material
and decide for themselves whether they are being given the truth about a particular situation or
relationship. This really matters where the story is high profile or likely to be controversial. A
recent example in the Mail on Sunday is the reproduction of material from diplomatic cables
sent by the then British Ambassador to Washington, Sir Kim Darroch. We published a story
(exhibited hereto as EV1) about how Sir Kim had reported back to London on Donald Trump
and his Presidency. This story used extensive extracts from the diplomatic cables themselves,
and was also illustrated with images of the material. This conveyed the astonishingly frank and
sometimes very colourful terms in which Sir Kim briefed politicians in London on the Trump
Administration. Without such material the reader would have been deprived of an essential

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 element of the story, which lent it undeniable truth and plausibility. In this case, since the point
of publishing certain extracts from the Letter was not just to convey what was in the Letter, but
rather to correct a misleading description in a previous report as to its tone and content, it was
even more important that readers were shown extracts demonstrating that such description
was false.

Information provided to me about matters in dispute in these proceedings

15. I have recently had a meeting with a senior member of the royal household ("the source"). The
meeting took place in person less than three months ago. I had met the source on a previous
occasion. The source had direct knowledge of the matters they1 told me about and which are
set out below. I have absolutely no reason to think the source was being anything other than
completely truthful. They were fully aware of the matters in dispute in these proceedings and
how important they were to me and the company I work for. This was not gossip or tittle-tattle:
it was what I considered to be high-grade information from a serious individual in a position of
authority and responsibility who knew the implications of what they were telling me.

16. The information the source gave me included the following:

16.1. There were several drafts of the Letter (as defined above).

16.2. Jason Knauf, a member of the Kensington Palace communications team, worked on
those drafts with the Claimant.

16.3. A lot of the tweaking of the drafts was done by electronic means of communication.

16.4. Sara Latham, who worked as a communications professional for the Claimant and her
husband, assisted the authors of Finding Freedom by performing a role that was
essentially fact-checking, to make sure the authors got nothing wrong.

16.5. A woman called Keleigh at Sunshine Sachs was responsible for making calls to 'open
doors' to the authors of Finding Freedom.

16.6. The source believes that Omid Scobie was given a copy of the Claimant’s letter and
that was going to ‘one of the big reveals’ in the Book.

1 I refer to the source in the plural so as not to reveal their gender.

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