First witness statement of: Thomas Markle

Filed on behalf of: Defendant

Statement date: 3 December 2020

IN THE HIGH COURT OF JUSTICE Claim no. IL-2019-000110

BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES
INTELLECTUAL PROPERTY LIST (ChD)
BETWEEN

HRH THE DUCHESS OF SUSSEX

Claimant

and

ASSOCIATED NEWSPAPERS LIMITED

Defendant

FIRST WITNESS STATEMENT OF THOMAS MARKLE

I, Thomas Markle, of 5419 Hollywood Blvd Ste C, Los Angeles WILL SAY AS FOLLOWS:

1. I am the Claimant's father. I am making this statement at the request of the Defendant, which
has asked me to explain my reasons for wanting the Defendant's newspaper to publish
extracts from my daughter Meg's August 2018 letter to me.

The article in People magazine, February 2019

2. When I read the article "The Truth About Meghan" in People magazine I was shocked by
what it said about me. It was a total lie. It misrepresented the tone and content of the letter
Meg had written me in August 2018. I quickly decided I wanted to correct that
misrepresentation.

3. It seemed to me that the article had either been expressly authorised by Meg or she had at
the very least known about and approved of its publication. I believed (and still believe) that
 Meghan wanted her account of the letter to be published. The sources for the article were
said to be Meg's "best friends". It seemed to me she must have used these friends to pass
information to the press, information that she wanted published, including information about
the letter she had obviously told them she had written. I did not think her friends would have
disclosed information about the letter unless she had asked them to. The article also referred
to my letter back to Meg, which only she would have known about.

4. The article quoted a longtime friend of Meg talking about the letter. She was quoted as
saying: "After the wedding she wrote him a letter. She's like, "Dad, I'm so heartbroken. I love
you. I have one father. Please stop victimizing me through the media so we can repair our
relationship." This suggested to people that Meg had reached out to me with the letter, saying
in the letter that she loved me and that she wanted to repair our relationship.

5. That suggestion was false. The letter was not an attempt at a reconciliation. It was a criticism
of me. The letter didn't say she loved me. It did not even ask how I was. It showed no
concern about the fact I had suffered a heart attack and asked no questions about my health.
It actually signalled the end of our relationship, not a reconciliation.

6. The People magazine article also misrepresented my reply to the letter. It said I had replied
to Meg's letter by requesting a photo opportunity: "He writes her a really long letter in return,
and he closes it by requesting a photo op with her. And she feels like, "That's the opposite
of what I'm saying. I'm telling you I don't want to communicate through the media, and you're
asking me to communicate through the media. Did you hear anything I said?". That implied
I wanted a photo for publicity reasons. That was not the case – as my reply to her letter had
made clear. I had suggested a photo of Meg and me together as I thought a photo showing
we were in a harmonious relationship would make the press back off.

7. The People article also accused me (and my other daughter Samantha) of "mistruths":
"Painful 'Mistruths' Meghan's half sister Samantha has spoken critically of her to the U.K.
tabloids, accusing her of being difficult, while her dad, Thomas, has said she shut him out –
claims her friends say are patently false". It was wrong for People magazine to say I had lied
about Meg shutting me out – she had shut me out, as the letter from her showed.

8. The People article contained other inaccuracies about me. First, it suggested I was to blame
for the end of the relationship as I had ignored her: "It's almost like they're ships passing. He
knows how to get in touch with her. Her telephone number hasn't changed. He's never
called; he's never texted. It's super-painful, because Meg was always so dutiful. I think she
will always feel genuinely devastated by what he's done. And at the same time, because
 she's a daughter, she has a lot of sympathy for him". That was false. I had repeatedly tried
to reach her after the wedding but I couldn't find a way of getting her to talk to me.

9. Second, a former colleague of Meg's was quoted by People magazine saying "Meghan has
been a rock for everyone in her family. It's a real shame that it's being painted in this other
light that is just absolutely false. She [took care of her father] with such incredible generosity.
The fact that this could be flipped around, that she was acting out or not caring for him, is
preposterous". That was wrong and unfair. It made it sound as though Meg had been
supporting me, which was untrue.

My dealings with the Mail on Sunday

10. Until I read the article in People magazine I had never intended to talk publicly about Meg's
letter to me. The content of that article caused me to change my mind. It was only by
publishing the text of the letter that I could properly set the record straight and show that what
People magazine had published was false and unfair. The article had given an inaccurate
picture of the contents of the letter and my reply and had vilified me by making out that I was
dishonest, exploitative, publicity-seeking, uncaring and cold-hearted, leaving a loyal and
dutiful daughter devastated. I had to defend myself against that attack.

11. Although I was approached by other journalists for comment after the article in People
magazine was published, I decided to reach out to Caroline Graham of the Mail on Sunday
to say that I wanted to get the truth out there. I never asked for and I never received any
payment for the article.

12. It was important to me in setting the record straight about me and about the tone and content
of the letter that Caroline should not just describe what Meg had written but that she should
actually quote from and reproduce parts of the letter. If the public didn't see the letter and
read what it said in its own words, I did not think anyone would believe me. At that time, there
were articles saying I was a liar, including that I had lied about my heart attack, even on TV,
and there were people saying I didn’t go to Meg's first wedding when I did. The text of the
letter proves that what was said in People magazine about the letter was wrong. It “dissolves”
what was said about me in that article. Readers had to see the letter for themselves – then
they would know they were getting the truth.

13. The Mail on Sunday respected my wish to publish extracts from the letter as it was telling my
story and it was up to me to say which parts of the letter needed to be published for me to
tell that story. I was therefore shown all of the extracts and I approved publication of those
extracts. I could have said no if they had wanted to publish parts of the letter which I didn't