Andrew Edward Coulson, you are indicted at the instance of Her Majesty’s Advocate and the charge against you is that
On 9 and 10 December 2010 at the High Court of Judiciary Glasgow you Andrew Edward Coulson, having been sworn as a witness at the trial of Thomas Sheridan you did falsely depose:-
(a) that prior to the arrest on 8 August 2006 of Glenn Mulcaire, then working as a private investigator and contracted to the News of the World and Clive Goodman, then a journalist at the News of the World
i you did not know that Clive Goodman was involved in the unlawful interception of communications in the course of their transmission by a public telecommunications system, commonly known as “phone-hacking
ii You did not know that Clive Goodman and Glenn Mulcaire were engaged together in “phone-hacking”
iii You did not know that payments were made to Glenn Mulcaire by Clive Goodman
iv You did not have ant email exchanges with Clive Goodman in relation to Glenn Mulcaire
v You did not know, or know of Glenn Mulcaire
vi You had not heard Glenn Mulcaire’s name
vii You did not know of Glenn Mulcaire’s “illegal activities
viii You did not know Glenn Mulcaire was employed by the News of the World
and
ix You did not know that Nine Consultancy was Glenn Mulcaire
and
(B) That while you were employed as editor of the News of the World you had no knowledge of payments being made to corrupt police officers by staff at the News of the World.
The Truth being, as you well knew
(A) That between 10 Oct 2005 and 8 August 2006
i You knew that Clive Goodman was involved in “phone-hacking”
ii You knew that Clive Goodman and Glenn Mulcaire were engaged together in the unlawful interception of communication in the course of their transmission by a public telecommunication system, commonly known as “phone-hacking”
iii You knew that payments were made to Glenn Mulcaire by Clive Goodman, namely payments of £500 per week until February 2006 followed by payments amounting to £4800
iv You had email exchanged with Clive Goodman in relation to Glenn Mulcaire, referred to in said emails as “Matey”
V You knew, or knew of Glenn Mulcaire
vi You had heard Glenn Mulcaire’s name
vii You knew of Glenn Mulcaire’s illegal activities in so far as they related to the unlawful interception of communication in the course of their transmission by a public telecommunication system, commonly known as”phone-hacking”
viii You knew Glenn Mulcaire was employed by the News of the World newspaper
ix You knew that Nine Consultancy was Glenn Mulcaire in respect that you knew Nine Consultancy was the business name under which Glenn Mulcaire operated.
and
(C) That between 1 December 2002 and 26 Jan 2007 you understood that payments had been made to corrupt police officers by Clive Goodman in particular a payment of £750 in or around December 2002, a payment of £1000 in January 2003 and a payment of £1000 in or around June 2005. All said payments made to procure a “green book” or other similar directories containing information including telephone numbers relating to the Royal Family and their members of staff.