Firstly, it was clear to them that -- they say the caption was "Relatives of victims leaving the Hotel Des Vignes". As I have explained, that was a hotel specifically for victims who had died. They, to my mind, knew that the photograph was of a young relative of a victim. On its face, it is clearly a grieving young child at that hotel, so clearly must have been a relative of a victim.
My understanding from Edward is that the Facebook photograph they took of Sebastian -- the cropping that is referred to in the Associated letter was actually cropping out Helena. It was a photograph of the two of them.
The -- and the photograph itself, the other photograph, the Helena photograph, has Edward in it. I don't know how that cropping took place, but obviously Edward is with Helena with his hand on her head. So he would have been in that photograph as well, and I don't know how -- but certainly the Facebook photograph that appeared on the Mail Online of Sebastian, Edward has told me that was just Sebastian and Helena, and Helena was cropped out of that photograph.
Just moving on through the letter, they say they didn't identify Helena but obviously they did name her in the article and they say unaware of who the subject was. As I have said -- I have made some comments on that.
They talk about reliance on EPA. That is the first I had heard about the picture agency. We have referred to some of the provisions of the code that I had quoted in the PCC letter about my understanding that the newspaper should take responsibility for the pictures they published. They said "EPA inform us". It is not clear to me whether that is informing them now or whether they made any inquiries at the time of EPA as to the circumstances in which this photograph was taken.
And they say that they were told it was someone standing in a public place on the other side of the road from the hotel. I can't say any more than what Edward has told me, as summarised in my statement, about where the individuals were and the circumstances in which that photograph was taken, and certainly Edward's evidence is that it was on hotel property and there were steps taken to shield the families of the victims from the photographers.
They then say that they had no reason to believe the photograph had not been taken in a public place or that relatives did not wish to be observed and photographed, to which I would -- you know, the photographs speak for themselves and I find it surprising that they make that assertion.
They then say -- the letter makes no reference to the photograph being published on the Mail Online. They say:
"If the Lewis Silkin letter had alerted us that the photograph on Mail Online was of Helena, it would have been immediately removed."
I mean, the letter was written with speed, a general letter to a number of media editors, as was necessitated by the circumstances. I would say that they could have inquired -- I did put in the letter my mobile number and my email address on the letter and said, "If there were any questions about the letter, then please get in touch with me", as indeed the Telegraph did, as I have summarised in my statement.