KB-2022-003316 - [2025] EWHC 1716 (KB)

Search for (to the extent not done already), disclose and produce for inspection all documents evidencing the information provided at or in advance of or following (i) the meeting in or around early April 2016 that was arranged between him and Dr Evan Harris and Mr Graham Johnson; and (ii) the meetings referred to at §22(a)(i) and §22(b)(ii) of the Reply in relation to his alleged Personal Watershed Moment.

Search for (to the extent not done already), disclose and produce for inspection all documents that explain, evidence or refer to the “Mailbusiness” referred to in the email from Dr Harris to the Fifth Claimant dated 3 March 2016 in connection with the meeting arranged in or around early April 2016.

Disclose and produce for inspection the witness statement he provided to the Leveson Inquiry quoted from in the Byline Investigates article entitled “Phone hacker emailed Mail on Sunday executive ChrisAnderson with updates during complex eavesdropping operation onSimon Hughes MP”, written by Mr Johnson and published on 28 July 2020, or any other document containing the quoted words, or any other document in which the Fifth Claimant and/or HJK raised their suspicions, during the Leveson Inquiry, that journalists engaged by the Defendant had been involved in unlawful information gathering or that formed the basis of those suspicions.

Disclose and produce for inspection the further and better particulars provided by Mr Thomson to the Leveson Inquiry of a paragraph in his witness statement that read: “It is clear that from the evidence that hasbeen disclosed and/or the evidence that I have obtained in the phonehacking litigation, this activity was not confined to one newspaper orone newspaper group but common industry practice. Paul McMullanadmitted as much in his meeting with Hugh Grant, which was the subjectto matter of an article a copy of which is exhibited at Tab 6 of MT1”.

Disclose and produce for inspection documents evidencing who he followed on his social media accounts and when he followed them in the period from January 2011 to October 2016.