Mm.

I understand.

We respond by defending ourselves in relation to that.

But he's used that to accuse our group of phone hacking, which is -- I'm sorry, but it is a very serious thing to do.

I'm sorry, but you're asking me to comment on a statement which was issued by my group, not by me.

You know, this is -- what you're talking about is whether he was wilfully blind to the facts, if that's what we're saying, or whether he was reckless as to the truth. I think that to make a very serious allegation against us on something as thin as ...

But I don't think he said that. His evidence wasn't that there was that sort of detail in his voicemail messages.

I don't think that that's a reasonable inference. If you look at the detail in the piece, it's not the sort of detail that you would have got from a voicemail interception. There is detail in there which has come from a source and that to me ...

Yes.

I would want to check rather than say something which may be inaccurate.

I think he had denied knowing a plummy-voiced woman. I'll have to dig out the correspondence to check.

No, but any --

I think in correspondence, which I haven't checked recently before giving evidence today, it was denied that he knew a plummy-voiced woman of that description.

Well, what is odd about this is that in the original claim brought against the Mail on Sunday, which was settled with the agreement of the statement in open court, Mr Grant or his solicitors denied that there was any plummy-voiced woman, and said the story was entirely false.

Yes. Yes.

This is what my statement also says.

I don't know. I don't know any more detail about the source.

No.

And the title. He said it was the Daily Mail.

Yes.

Yes.

I don't think that is right.

What I'm simply trying to do is put the facts before the Inquiry that we have got from our journalists.

But Mr Grant's evidence was, I think, admitted by him to be speculation when he gave evidence, wasn't it?

Yes.

This section of my witness statement dealing with Mr Grant's evidence is simply saying that on our evidence, his evidence contains a number of significant inaccuracies, and that is the purpose of these paragraphs, to say what in our view those inaccuracies are, based upon the facts from our ...

Yes, that's right.

Yes.

There have been a number of discussions between our legal team and the journalists in relation to these facts. But I'm happy to provide further information on this, if that would assist.

By the managing editors and by Mr Todd in connection with the preparation of this witness statement.

This is the information I've been provided.

Well, because he may not have had it personally, but the evidence was that this is a number she famously keeps private, and this is simply saying it's not a number that is kept private, it's one that is well-known, but Mr Todd himself obviously didn't have ...

I don't, but I can ask.

Yes, but equally, if Mr Grant had put some of this to us earlier, we could have explained the circumstances to him.

-- I think that the anger about the allegations relates to the issue of phone hacking. This part of the statement is dealing with an issue he's raised while giving evidence and is simply designed to set out what our position is on it.

But if this is designed, though, to address what we've said about the mendacious smears --

It's a piece of logic, yes.

But this is our answer, saying -- explaining that that is not the basis of our knowledge.

No, but he might have known that she'd registered into the hospital under the name of Sophie Hong.

The Westminster Register Office?

Which information?

Yes, Mr Grant's evidence.

Well, our evidence is that our reporter was instructed by the news editor to keep a distance from the house to observe what happened and when Mr Grant appealed to the media to leave, she conveyed that to the news editor, who instructed her to leave, which she did and ...

Yes.

This was after the confirmation of the birth, yes.

I don't agree that there's a presumption, no. But in any event, this statement sets out that we withdrew -- as you know from Mr Silva's evidence this morning, we withdrew our photographer and we didn't continue to pursue her.

No, this is a serious point. Article 10 hasn't featured much in the discussions --

Actually, she also has her rights of freedom of expression. She has her right to talk if she wishes to do so.

Yes.

Well, he could do. He was, after all, the father of the child. He could easily have spoken to the media and said, "Please, she doesn't wish to say anything, neither do I".