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Statement from Mr Douglas Marvin
DOUGLAS R MARVIN of 725, 12th Street, NW, Washington
D.C. 20005 WILL SAY AS FOLLOWS:
1. I am a lawyer practicing law as a partner
of Williams and Connolly in Washington D.C. I graduated from
the University of Virginia School of Law in 1972 and passed the
bar that same year. I am a member of the Bars of Virginia, Pennsylvania
and the District of Colombia as well as the Bar of the United
States Supreme Court.
2. Upon graduation from law school, I accepted
an offer from William Rehnquist, then Assistant Attorney General,
Office of Legal Counsel, United States Department of Justice (currently
Chief Justice of the United States) for appointment to the position
of attorney-advisor in his office as part of the Honors Program
at the Justice Department. Two years later, I was appointed as
counsel to the Committee of the Judiciary, United States Senate
which is responsible for all legislation dealing with civil and
criminal codes. In 1975, Edward Levi, upon his appointment and
confirmation as Attorney General, asked me to return to the Justice
Department as his Special Assistant. After serving as his Special
Assistant for approximately six months, I was appointed Counsellor
to the Attorney General of the United States, a position that
essentially serves as the chief of staff for the Office of the
Attorney General. At that time, the Department of Justice employed
over 50,000 people with the heads of all of the litigating divisions,
the United States Attorneys throughout the country as well as
law enforcement agencies such as the Federal Bureau of Investigation,
reporting to the Attorney General. In May 1977, I left the Justice
Department to join Williams and Connolly. I have practiced as
a lawyer at Williams and Connolly since then taking only a leave
of absence in 1981 to assist the then newly appointed Attorney
General, William French Smith.
3. In September 1996, I was in London working
on a commercial transaction for Harrods. During the course of
that work, I reviewed with Harrods executives the types of legal
proceedings that the Company was facing and, in that process,
learned that Mr Al-Fayed was scheduled to appear as a witness
in Mr Hamilton's case against The Guardian. Mr Stuart
Benson and I therefore met with Geraldine Proudler a partner at
Olswangs and Mr Geoffrey Robertson QC who were acting for The
Guardian, to learn more about the status of the case. Our
meeting with Ms Proudler and Mr Robertson occurred about 10 days
before the Hamilton case was scheduled to commence.
4. During the course of the meeting with Ms
Proudler and Mr Robertson, Ms Proudler told Mr Benson and me
about certain diary entries that had been produced to The Guardian
lawyers by Mr Al-Fayed, one of which referred to a woman named
Iris and indicated that Ian Greer had called asking about a sum
of £5,000 that was supposedly due. I told Ms Proudler that
the name Iris probably referred to one of the secretaries in Mr
Al-Fayed's Park Lane office and, as I was staying in a flat adjacent
to the Park Lane offices, I would ask Iris about it.
5. Subsequently, I met with Iris Bond. I
asked her about the entry and about her knowledge of Mr Hamilton
and Mr Greer in general. It became evident that Ms Bond was aware
of facts that were very relevant to the Hamilton case. I did
not show Mr Al-Fayed's witness statement to Ms Bond nor did I
show her any documents other than the diary entries. Instead,
I questioned Ms Bond about the extent of her knowledge as I would
question any witness to learn about the particular witness' recollection
of events. In response to my question about other persons who
were employed by Mr Al-Fayed during the period of time relevant
to the Hamilton case, Ms Bond identified Alison Bozek and Phillip
Bromfield.
6. I reported to Ms Proudler what I had learned
from Ms Bond and told her that there might be other witnesses
with relevant information. Ms Bozek was away on holiday at that
time and was expected back in London on Tuesday or Wednesday
the following week. I told Ms Proudler that, as I would be back
in London at that time, I would attempt to meet with her then.
7. Ms Bozek did return to London during the
mid-week and I met with her, I believe, on Wednesday 25September
about five or six days before the Hamilton trial was to begin.
I do not recall showing to Ms Bozek any documents. I certainly
did not show to her Mr Al-Fayed's witness statement. Instead,
as with Ms Bond, I asked Ms Bozek questions to ascertain the
extent of her knowledge, beginning with such general questions
as whether she had ever met with Mr Hamilton or whether she knew
who Mr Greer was.
8. After meeting with the three witnesses, I
reported to Ms Proulder what I had learned. Ms Proudler either
asked me, or I offered, to prepare witness statements. After
preparing the statements, I provided drafts of the statements
to each of them for their review. I explained to each of the witnesses
that the statements needed to be truthful in every respect and
that, once signed, the statements would be delivered to the lawyers
acting for Mr Hamilton and Mr Greer. Once each of the witnesses
advised me that they were satisfied that the statements were
truthful in every respect, I arranged for the statements to be
prepared in final form and delivered to the witnesses for signature.
9. I did not meet with any of the witnesses
in the presence of another witness. Nor did I discuss with, or
show to any of them, the contents of the statements of others.
None of the three witnesses listened to the answers given by
other witnesses.
10. Mr Al-Fayed did not attend any of the meetings
with the witnesses. I received no instructions from Mr Al-Fayed
about the contents of the witness statements. He never told me
what he thought the witnesses could, or would, say. What I learned
from the witnesses and what appeared in their witness statements,
derived entirely from the questions I asked them in order to
ascertain the extent of their knowledge.
11. The decision to meet with each of the witnesses
and to take statements from them was not instigated by Mr Al-Fayed.
Instead, that decision was made by Mr Benson and me, at the suggestion
of Ms Proudler.
12. Needless to say, Mr Hamilton's claim that
the statements from the three witnesses were fabricated is absolutely
false. Each of the witnesses simply responded to questions put
to them and were very careful in ensuring that their statements
were entirely honest and truthful. For my part, I certainly considered
each of the individuals to be honest and truthful.
13. The contents of this statement are true
to the best of my knowledge and belief.
Douglas R Marvin
22 January 1997
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