I have spoken to Mr Jay and we don't make an application to be core participants for Module 3.

Yes.

Yes.

No, sir, although it is also fair to say that the timetable is subject to rapid change. I've made the point about Mr Tickner's statement arriving yesterday afternoon. I now gather from Mr Garnham, which I didn't know, that there may be a yet further witness to ...

Sir, in my submission, that would be an obvious first step. Obviously that's without prejudice to the larger arguments that Mr Garnham has advanced.

Yes. The potential implications of the statement are being considered and investigated as I speak.

The statement, as I hope was clear from what Mr Garnham said, came as a complete surprise certainly to me yesterday afternoon. It is not, I should make absolutely clear, served as part of the MPA/MOPC's section 21 notices response. We hope in the three statements we have ...

Sir, before you hear the evidence, may I make a couple of points, because of course Mr Tickner was an employee of my clients.

-- which have been welcomed by the MOPC and before that the MPA, and in relation to which responsive work is already being undertaken.

But for present purposes, it suffices to say, I hope, that the MOPC recognises the importance of a positive culture at the top of the Met, established ...

Yes. Can I just say two final things?

As you'd expect, the responses from the MOPC to your notices will also contain comments and responses to both the Filkin and the HMIC reports --

I know you've also served a section 21 notice on the general body, the Association of Police Authorities, and it may be that their more general perspective will be very useful.

Yes. Of course our statements, our response to your notices, will deal with these matters.

Yes.

Yes.

Yes.

Sir, under the 2011 Act, the Mayor is committed to appoint a Deputy Mayor for policing and crime and the Mayor has nominated a former chair of the authority, the MPA, Mr Malthouse, to that position and to head up the MOPC for all day-to-day purposes. So there's continuity ...

In relation to the MPA finally, may I sum up the experience, if I can put it that way, over some 11 years as follows: first, by reminding you that at the beginning of the process in 2000, the Met had no experience of rigorous oversight, and I've no ...

Sir, I do that because, of course, in relation to the key events with which you're concerned in this module, it was the MPA which was in place at all material times. But so far as lesson-learning, so far as recommendations coming out of this Inquiry are concerned, it ...

We move from what Mr Jay described in his opening as internal governance to external governance of the MPS.

The MOPC is the statutory body responsible under the provisions of the Police Reform and Social Responsibility Act of last year for securing the maintenance of an efficient and effective police ...

They are indeed, sir.

Sir, I appear, as you know, for a joint (inaudible) the Metropolitan Police Authority and the Mayor's Office for Policing and Crime.

Yes.

It may be useful to have a short opening setting out our role, that's all.

May I come back to you when I've had a chance to take some instructions on that? Because we are newcomers and this is a new area for the Inquiry.

May I reserve my position on that? You appreciate we came today not quite knowing whether we would have core participant status.

Would you designate Eversheds as the legal representative?

Thank you very much.

Sir, are you intending to rule on my application?

Yes, we will certainly do that.

Yes. Can I deal with that in this way: the short answer, I'm afraid, is no. There is a national body, on which there's representation from the Metropolitan area. It's called the Association of Police Authorities, but I don't speak for them. It may be that ...

Sir, we have set out our application on behalf of the MPA and now the Mayor's office for policing crime in writing, we've done so as succinctly as we possibly could in three and a half pages and said that if you needed to hear further submissions or ...

Thank you.

Sir, all I can say is: I am ready to apply now but I can see that that is not what you want. All I am then saying is, if it is to be later, then let it not be too late, ie so as to prejudice --

Thank you, sir.

The second point, and it is a quick point, again, made in Eversheds' email of 30 September, but I don't think it is something that anybody has mentioned so far and it may be we have simply misread the document, but it relates to paragraphs 15 ...

The second point --

Sir, can I just touch on two specific points on the protocols. The first is to repeat the offer we made in correspondence, that if we can assist the Inquiry legal team with the technical issues on the document management system, we are very ready to do that, as indeed ...

Yes. Sir, that's the concern. As I say, in the intervening period, however long it is, our concern is to ensure that anything that might affect our interests is shared with us, so that we can make our own contribution. Now, I am not asking, exactly the same way ...

Yes. Sir, I have one or two specific points to make on that, if I may. May I just come back to this point about the timing of any application for CP status for module 2, because we were slightly disturbed to be told by one of your legal team ...

Yes. Also you have said, as I understood it, that there would be openings at the beginnings of modules and closings at the end, so that the difficulty my clients have is this: at the moment they are outside the pail. They are told, however, that their bit or the ...

It is simple fairness, and what we would say, going forward, is again very simple. If there is something which will or might affect our interests then, given that the Inquiry is plainly on notice of our position, we ought to be told about it and involved in it.

So ...

Indeed.

Yes. Our position is that we are in a distinct situation from Mrs Brooks from Trinity Mirror. I now know for example that we were given the attachments to the note that Mr Chawla was not, but the point we are relying on is exactly the same: fairness. In my ...

Yes.

Thank you.

Thank you very much.

Sir, so far as today and the first stage, module 1, part 1, is concerned, may I simply say this: we have listened very carefully to what your Lordship has said, in particular about there not being a bright line between core participant status and the position of those who ...

As a matter of fact, sir, we also expect to seek that status for part 2 as and when it arrives.

Yes.

In due course the regulator of the Metropolitan Police will, we believe, have a genuine interest in part 2, the relationship between the press and the police. If one looks at the terms of reference in part 1, there are essentially regulatory issues there, and I expect us to make ...

Sir, I represent the Metropolitan Police Authority. My name is Phillips, I am instructed by Eversheds. The Authority is the regulator of the Metropolitan Police Service, it's a statutory body and it exists to ensure that there is an effective, efficient and accountable police service in London.

Now, sir ...