Your full name, please?

Very well. Thank you very much.

It does deal with it and it's about the Criminal Procedure and Investigation Act, which is a macro point.

The macro point is one that probably will fall better into module two, or part two of the first module, namely the police and press, but may I mention this very briefly now, because I think there may have been a misunderstanding with the submission that I made last time --

I'm very grateful for that indication.

We are quite content with that limitation on it, with the rider that we've indicated, that if we were to be descending into any detail at all, and it seemed to us difficult if Mr Hurst was to be making a statement to the Inquiry, that he would avoid ...

As far as we can see, the only way in which he would become involved is by making the sort of claims that he has made in his pleadings in that case against a number of individuals, including my client, but also including News International. There are five defendants in ...

The reason that we raise it is simply because in your judgment at paragraph 32, you said in the concluding paragraph that you did not anticipate that you would be considering the specific behaviour of the individuals, not least because of the pending police investigation and possible prosecutions. That you ...

I appreciate that, although it might bear possibly on the point that has just been raised by Mr Sherborne, whose client doesn't (inaudible) and who is the claimant in the case that is presently being brought before this court in the civil division.

Sir, I appreciate that that has been debated this morning, because Mr Shepherd(?), my instructing solicitor sitting beside me, has kept we abreast of some of the developments, albeit in short form.

We had, I think, two points to make, one macro, to use the in vogue expression, and one ...

I think it almost certainly touches on it only tangentially, because what we would wish to suggest to you today was because of the position in relation to one of Mr Sherborne's clients, we ought to be a core participant, if that core participant was going to be addressing ...

I say that, because we received a reply, as I understand it, acknowledging the letter, but without any comment upon its content.

We've put nothing further in writing, but we did submit a letter to you, dated 22 September, which I trust made its way to you.

I hope that the solicitor for the Inquiry has passed on the information that I was delayed in another court this morning so I have only just arrived but I have been kept abreast of what has been --

My Lord, I would. Richard Christie, appearing on behalf of Mr Jonathan Rees. You will remember that we appeared before you some while ago.

No, my Lord, I understand. As I say our principal concern, even allowing for what your Lordship has said, if you are going to be exploring illegal and unethical behaviour, given the allegations that have been made, and you are also going to be exploring the ethical extent to which ...

My understanding is that he was the subject of that but I may be misinformed.

My Lord, with respect, as I understood it, I thought that was something you would be wanting to enquire about, namely the press and the public. Potentially, under the regulatory scheme that we have at the moment, an individual accused could be held responsible but the press are not responsible --

We accept that proposition.

There is one other aspect of it, of course, which we respectfully submit is particularly important to his case, namely that his case -- and I use that in its widest sense -- has featured on Panorama and on the Radio 4 Report and in a large number ...

Yes.

Well, we appreciate that.

Well, I suppose we don't know, we simply don't know what is going to be raised. But what you have raised this morning is the prospect of illegal and unethical behaviour --

My Lord, because we respectfully submit that it is likely, looking at 5.2(c), that there may well be suggestion that implicates him or makes significant criticism of him, and therefore we respectfully submit that it would be right that he be a core participant.

-- that our client would be well served as a core participant at that stage.

Richard Christie, appearing on behalf of William Jonathan Rees, who is the only private investigator on the list that is before your Lordship today.

The position so far as we are concerned, looking at the information that was provided to us this morning, is that it seems to us, certainly ...