Catherine Zeta Jones' statement

Text of the witness statement of Catherine Zeta Jones submitted to the high court

Tuesday February 11, 2003

I, Catherine Zeta Jones will say as follows:

1. I am the Second Claimant in this action and the wife of the First Claimant. I am a film actress.

Introduction

2. I was born in Swansea on 25 September 1969. My father is Welsh and my mother is of Irish/Welsh descent. I come from a large and very closely-knit family.

3. I started performing on stage at dancing school when I was very young. Amongst other productions, I appeared in a production of the musical, Annie when I was 11 and when I was 13 I appeared in Bugsy Malone. I left Dumbarton House School in Swansea, when I was nearly 16 to do a nine month national tour with a musical. I was then offered a part in 42nd Street running in London's West End in which I appeared for approximately 18 months. I made my first film Scheherazade in 1990. The following year I appeared in the television series The Darling Buds of May in which I played Mariette Larkin. This was followed by a number of other small budget films and I then worked in the United States on a number of television mini series including one called Titanic. My movie career took off when I was spotted by Stephen Spielberg who asked me to appear in The Mask of Zorro in 1996. This launched my movie career in the United States. Since then I have appeared in a number of major films including Entrapment and, with my husband, in Traffic.

Early Media Intrusion

4. I first became aware of the intrusiveness of the media in 1991 when I worked on The Darling Buds of May. After only one episode of that series had been broadcast, I became a recognisable celebrity and for the first time in my life people approached me in the street to ask me for my autograph. Initially I was delighted, not realising how intrusive such attention would become. However, this recognition soon began to cause me increasing distress as I realised that whatever I was doing off screen was considered far more important than what I was doing on screen. I was a 21-year-old girl trying to live a normal life in London. Very quickly it felt as if every aspect of my private and personal life was becoming the subject of media interest. I regularly found details of my private life in the tabloids and on occasions had to face a barrage of photographers and journalists outside my house. During one "siege" I remember that for several days a neighbour kindly shopped for groceries for me so that I did not have to face the journalists. Unfortunately, at that time I did not rebuff a number of falsehoods that were published about me which have, as a result, been recycled in various media ever since. At that stage of my career I did not feel able to challenge the press, nor did I have the resources to get proper advice and help in dealing with the press.

5. Much of the publicity that I received was extremely personal and negative such that, when a film in which I was acting did not succeed, it was referred to by the tabloids as "Zeta's flop" or something similar. For instance, Christopher Columbus: the Discovery starred, amongst other, Marlon Brando, Tom Sellick (sic) and Rachel Ward but it was still "Catherine's flop". At that time, Britain had a relatively small film industry, and this tabloid coverage tainted me in the eyes of the small group of people who were responsible for making serious decisions about film making in this country. It became clear to me that those people would not take me seriously.

6. As my career progressed, my personal life rapidly became the subject of tabloid gossip, rumour and speculation. This was something that I did not encourage and, throughout my career, I have tried to keep the media at a distance as far as is possible, given the business I am in. It is usual under my performance contracts for there to be a clause obliging me to promote the particular film or television series. However, over and above those press events which I am contractually obliged to attend I rarely give personal interviews to the press. This does not of course prevent articles being published which are written as if I have made personal revelations to the journalist concerned, when all that I have done is provide some innocuous response to a journalist's questions about my private life. I have, however, been fortunate in that, unlike some other women in the public eye, none of my ex-boyfriends has over sold his story to the newspapers.

7. In addition to the general upset and the damage to my career that media intrusion was causing me, a number of incidents made me concerned for my safety. For example, I remember late one night as I walked the short distance from a taxi to my home, a photographer jumped out of the doorway next to mine where he had been waiting for me and started snapping photographs of me, terrifying me out of my wits. On another occasion, I actually swerved my car into a lamppost trying to escape from a paparazzo. At that time I did not have the money to finance the measures needed to keep the press at bay. Now I am able to afford the security systems necessary to offer at least some protection and privacy for me and members of my immediate family.

8. I eventually decided that I needed to have a new start and I moved to the United States in 1996. My bad experience with the British tabloid press was part of the reason why I decided to make the move.

Press attention since meeting Michael Douglas.

9. I first met Michael Douglas at the Deauville Film Festival in September 1998. For several months our relationship did not get into the public eye. Finally, however, articles began to appear about us. While we were on holiday in Majorca photographs were taken by long lens cameras of Michael and me on a boat we had hired for three days. They showed us embracing. It was an intimate moment which the tabloid press had no compunction about publishing.

10. In December 1999 I became pregnant with Michael's child, shortly after which Michael came home with me to Wales for Christmas and met my family. At that time Michael asked my father for my hand in marriage and he consented. After Christmas we flew back to Aspen, Colorado for the Millennium celebrations at which time both of us were feeling extremely sick with the flu. Despite this we decided to go out and to celebrate the Millennium at a private party. Michael proposed that night and I agreed to marry him. It was typical of the press attention we attracted that, as a result of the announcement of our engagement, photographs of Michael and me at the party became valuable and a number of photographs taken of us before he proposed to me that evening found their way to the press.

11. Late in January 2000, some seven or eight weeks into my pregnancy, I was told that the Sun had discovered that I was pregnant and was going to publish the story. As I was so early in my pregnancy I had not had all the necessary medical tests and naturally had not yet told even my close family. My pregnancy was, I thought, a close guarded secret. As a result of that telephone call, I immediately had to telephone my mother and other members of my close family to tell them about the pregnancy and that it was going to be published in the Sun the following day. It was extremely upsetting to me that I was forced to announce my pregnancy to people before I was ready to do so. As this was my first child, I particularly wanted to have every possible test before announcing the news to my family.

12. This information about my pregnancy was so private and I was so upset at the fact that it had been leaked that Michael and I instructed a private investigator to track down the source. It turned out to be a paparazzo who had been obtaining information from an assistant in my then lawyer's office.

13. As soon as my pregnancy had become public knowledge, the press attention increased dramatically and became very difficult for me to cope with. When I left my apartment I was regularly followed by a caravan of people documenting my every move and taking photographs of me. There was considerable press coverage about my pregnancy. It was particularly upsetting when the press followed me to my doctor and to the hospital where I was due to give birth. I found the hounding of the press very, very stressful.

14. Over the last few years, and particularly since my pregnancy, I have become increasingly concerned about photographs of Michael and me (and more recently of Dylan) at private moments finding their way into the media. It is the photographs and records of the personal things that upset me the most. I do not want the world to know I am having a baby before I have told my family. If I am having a disagreement with a loved one, I do not want the world to know about it. If I go to the doctor, I do not want the world to know that I have been to the doctor or why I have been there.

15. Both Michael and I are used to being accompanied by security people. We usually have a driver and we frequently have a bodyguard when we go abroad. In addition our cars and our homes have full security features. Whilst these measures prevent intrusion into our homes, it is impossible to prevent photographers following us all over the world, taking photographs of us wherever they can and selling those photographs for very considerable sums of money. Michael and I tend to think of the paparazzi as game hunters who view us as their game which they have to stalk and hunt down. The photographs they take of us are their trophies. The amount of money that an independent photographer can make by taking and selling photographs of us is enormous. It is for that reason that such photographers go to the extraordinary lengths they do to take these photographs. For example, Michael and I were told that the photographs published in the British press of me lying semi-naked on top of Michael on the boat off Majorca were sold for something in the region of £250,000. Not only do I resent the fact that our family privacy is being invaded in this way and that we are forced to take ever more sophisticated and expensive steps to protect our private lives, but I also object to the fact that someone is making that amount of money from this despicable behaviour.

16. There is a related issue. Both Michael and I are in the business of "name and likeness". Any photographs of us that are published are important to us, not just personally but professionally as well. People go to see movies specifically because either Michael or I are in them and they have expectations, amongst other things, of the way we will look. Those expectations are created to a significant degree by the images they see of us in the media. Directors take into account the public's perception of actors and actresses when casting for films. The hard reality of the film industry is that preserving my image, particularly as a woman, is vital to my career. I had a lesson in Britain of the way in which poor publicity can stunt your career prospects. I have always been determined not to allow this to happen to me in the United States where I do virtually all my work. For this reason, there is a clause in every performance contract I sign giving me full photo approval. This means that no still photographs of the movie may be published or distributed without my prior consent. This is not a right that all actors manage to obtain and is only granted to those with sufficient "star" power. It is a right that I have had to work hard to obtain and I work hard to enforce and control it. I spend a great deal of time sifting through the hundreds of photographs that are taken of me during a film shoot and selecting those which I know will benefit my career.

17. As part of the measures I take to preserve the integrity of my name and likeness, I employ people to surf the internet and to read magazines and newspapers to search for infringing uses and to take action to stop them. This is a constant battle. My image is used to sell products all over the world with which I have no connection whatsoever. The unauthorised use of my image for commercial gain infuriates and upsets me and not just when, as does happen, it appears on pornography websites. I feel exploited. I view it as theft: people steal my image to make money for themselves. It is not, however, just a business issue. I see it as my personal right as an individual to choose how my image may be used. I am, however, perfectly happy for photographs of me to be exploited to the full when they are being used for a good cause, such as those taken of me with Luciano Pavarotti that were taken at an event to raise money for war orphans in Afghanistan. Also, whilst I do not relish being photographed when I am out shopping or with my family in public places. I realise that it is not possible to prevent such photographs being taken of me.

Photographs of Dylan in OK!

18. As a result of the intensive press interest in my pregnancy I realised that the press attention surrounding the birth of our child would be enormous and would be very difficult to deal with. Michael and I decided that we had to be pro-active in managing the media interest, otherwise it would be unbearable. We eventually concluded that the best course of action would be to arrange for a photographer of our choice to take photos of us and of the baby and to provide those photographs to a magazine who would then syndicate them to magazines of our choosing. We hoped that by providing some photographs of our child we could appease the public appetite for information about him or her and that this would in turn reduce the bounty on the baby's head as regards illicitly taken photographs.

19. Allen Burry had discussions with OK! and we eventually decided that OK! should publish the photographs of the baby. It was clear from Allen's reports of his discussions with Martin Townsend, the editor of OK! that they were very sensitive to our concerns. In particular, they were happy with our request that we use our own photographer and that we retain control over which photographs could be published and over the content of the text. The sum paid by OK! for the photographs of Dylan was paid into a charitable trust fund of which Dylan will be the sole trustee when he comes of age.

20. The photographer that I selected to take the photographs of Dylan was Daniela Federici. I had worked with Dani before and knew her to have a sensitive eye. I also wanted to have a female photographer to record the very early days in the life of my first child.

21. Given the intense media interest in my pregnancy we took a number of measures to prevent journalists snatching photographs of me and the baby in hospital. For instance, Dylan and I were wheeled from the delivery room back to my room covered by a sheet. A bodyguard was posted at the door of my room. Even so, I was told that journalists had tricked their way into the hospital by pretending to be members of my family. When Michael collected Dylan and me from the hospital he was allowed to park our car in the doctors' parking lot which had a special key. It later became apparent, however, when the photographs were published in Hello!, that photographers had found out where our car was parked as they snatched photographs of us leaving the hospital. One week after Dylan was born I was driving in Los Angeles with Dylan and his nanny in the back of the car. The car behind bumped into us. Under Californian law, I had to get out of the car and exchange insurance details with the oth! er driver. It turned out that the car behind was driven by photographers from a British tabloid newspaper which had deliberately hit us. They immediately jumped out of their car and took photographs of me looking furious at the side of the road. They then published them in an article about me being consumed by road rage. This incident made me very angry.

Plans for the Wedding

22. Shortly after Michael and I became engaged, Michael had asked me what type of wedding I wanted to have. We both knew the kind of media attention that our wedding would create, and knowing this, and fearful of the way in which media attention could ruin our wedding, I even suggested to Michael that we should marry in a register office. He said that as he had been married once before that would be fine for him but that he wanted me to have the wedding of my dreams as it was my first, and hopefully my only, wedding. Having turned it over in my head I decided that he was right. I did not want to be forced to have my wedding in secret. I had always wanted my wedding to be a very special day and it was extremely important to me that my family (in particular) should be there to share such an important day with me. In addition, I was lucky enough to have the money to be able to afford the wedding of my dreams and to be able to share that wedding with my family and friends by inviting them to that wedding.

23. Both Michael and I have particularly large and extended families. So large that, for reasons of space, we ultimately had to limit the number of family members that we could invite and were forced to be extremely clinical about our invitation decisions such as making decisions on the basis of a generational proximity. I know that this decision upset a number of family members both on my side and on Michael's. However, despite our being selective, there were over 120 direct family members at the wedding. If we had each invited our entire family that figure would easily have been doubled.

24. We started planning the wedding in February 2000. I wanted a home-spun and intimate occasion that everyone attending would find magical and special. I wanted it to be glamorous as I wanted to give my family and childhood friends the party of a lifetime, but I also wanted it to be a warm and relaxed occasion where all the guests, with their widely differing experiences and backgrounds would feel comfortable. We thought about having the wedding in a number of places including Bermuda, Majorca and Los Angeles. Eventually we decided that the wedding should be held in New York. For a couple whose friends and relatives are spread from the west coast of the US to Wales, New York is a central and convenient location. Also, many of my family in Wales had never been to the United States. I wanted to give them the opportunity to come over and visit me in the country, which had come to mean a great deal to me. Los Angeles was an option, but would have been a very long way for my family to travel especially for those who could only come for a weekend. I love New York and I thought that if the wedding was going to be in the United States then it should be in the Big Apple.

The New York Plaza

25. Once we had set our minds on New York, The Plaza was the natural choice. It was big enough to cope with a wedding of this size and scale and had a proven track record for hosting large events, which required security measures. I wanted to hold the wedding somewhere where members of my family would be able to stay and which would be a wonderful introduction to New York. I also wanted to have the wedding somewhere that I could sleep the night before the wedding so that my arrival at the wedding would not be turned into a media circus.

The Guest List

26. Preparing the guest list was the next major task. Michael started with his Christmas card list and then narrowed it down to his Christmas gift list. I simply prepared a list of everybody that I would want to come to my wedding and then narrowed it down. For both of us the most important guests were our family. In addition to my family, there were a number of other people whom it was very important that I invite to the wedding. For example, I very much wanted the Headmaster of my old school, Dumbarton House, to attend. I also invited a number of childhood friends such as Helen Jones, Julie Walker, and Peter Howard who ran the local amateur dramatics society with me in Swansea, and also Hazel Johnson, my first dance teacher, who I have known since I was four. Friends from my days on the London stage were also invited, including girls with whom I had acted in 42nd Street in London, as well as various other acting colleagues and business associates. It was also important to me that my parents could invite to the wedding some of their own friends whose children's weddings they had previously attended. Nearly everybody at the wedding was personally known to me except for certain members of Michael's family and one or two spouses whom I did not know. For example, I asked my driver, Lenny, to bring his wife even though I had never met her, simply because I had heard so much about her from him. I know that Hello! has said that the wedding guests included celebrities, politicians and other prominent people. That is true. However, the reason that these people were invited to our wedding was that they were either friends (for obvious reasons, many of our friends in the movie business are celebrities) or family or close associates (such as Kofi Annan and his wife with whom we have become close as a result of Michael's position as a United Nations Messenger of Peace). We certainly did not intend our wedding to be a celebrity event.

27. I asked Simone Martel to act as the event planner for the wedding. She had been involved in arranging a joint birthday party for Michael and me the previous September. Michael and I were born on the same day, 25 September. I liaised regularly with Simone and Allen Burry and with my assistant, Julianne Berkovitz, about the plans for the wedding. Like nearly every other bride I was very nervous about the wedding plans and was determined to be involved at every stage of that planning. In addition to my general involvement there were some areas that were particularly important for me including the dress, the photography arrangements and the dicor.

The Dress

28. I originally asked for sketches for the dress from a number of designers including Donatella Versace, Karl Lagerfeld and Richard Tyler of Dolce & Gabbana as well as from Christian Lacroix whose design I ultimately chose. I was looking for the design that best met my vision of what I wanted my dress to look like. Everyone who worked on the dress kept the design confidential. Because of my pregnancy and the birth of Dylan my body was constantly changing over the period leading up to the wedding. The final fitting was made only three days before the wedding. For the final 24 hours before the wedding one of my friends sat with the dress and my wedding jewels in a locked hotel room in order to protect them both from the press and generally. Michael did not see the dress until the day of the wedding.

The Official Photographers

29. Choosing the photographers was also something that was particularly important to me. I wanted the photographs to reflect the atmosphere of the wedding and I wanted to be certain that the chosen photographers would achieve that goal. Because of the world that I move in I come into contact with a lot of photographers and have strong feelings about their styles. Before selecting our photographers I looked at the photography books of about six or seven photographers. In addition, a number of other photographer friends had asked me if they could take the photographs at the wedding. In the end the photographer whom I chose to take the formal photographs was Michael O'Neill who had taken the photos for Zorro and whom I trusted. The reportage photographer whom I selected was Terry de Roy Gruber, a very famous wedding photographer. Before selecting Terry de Roy Gruber we met to discuss what I wanted his photographs to capture. It was clear from his portfolio of photographs and from our meeting that I would enjoy working with him and that he would inject into the photographs the fun and life that I wanted them to convey.

30. Looking at the photographs that we have and as they appear in OK! I am delighted with the photographers we chose. The photographs of the party give a real feeling of the atmosphere of the wedding which was intimate, warm, fun and relaxed. The formal photographs of Michael and me with our families are exactly as I had wanted them to be. The photographs as ultimately published in OK! are only a fraction of the photographs we have and which we will use to make up our private wedding book. The same photographs that were provided to OK! will eventually be given to members of my family and friends who attended the wedding. However, I was so upset by what Hello! did that, save for one exception, I have not felt able to send any wedding photographs out, even to my mother, until our action against Hello! has been resolved. The exception was a photograph of my grandmother, Nanna Fair, with Kirk Douglas. She was absolutely thrilled to meet him and I wanted to let her have that memento when she was ill in hospital.

31. It was very important to us that our guests could feel totally relaxed at the wedding. The photographers were briefed not to take photographs of certain people who were at the wedding and whom I thought would not welcome being photographed. These included, for instance, Meg Ryan and Russell Crowe who were dating at that time but whose relationship was not public knowledge.

32. We decided not to have a video of the wedding for several reasons. In the first place video recordings have a tendency to find their way on to the Internet. Also videos tend to be more intrusive than cameras and tend to stop people from relaxing. It was very important to us that the photographers should not be intrusive and that our guests should feel at ease.

The Dinner on Friday, 17 November 2000

33. As our extended families had not met each other prior to the wedding, we specifically arranged a dinner the night before the wedding at the Russian Tea Room in New York. The main aim of this dinner was for our families and other old friends to get to know each other a little before the wedding. It also meant that the photographers (and also Martin Townsend, then the Editor of OK!) could get to identify who were members of my family and could also get a feel of the fun family atmosphere which we hoped the wedding would have. For that reason Terry de Roy Gruber came to the Russian Tea Room to take photographs and I went around the room with him pointing out all of the people who were particularly important to me but who would not have been known to him as they were not celebrities. I pointed out to him and to his assistants those family members whom I particularly wanted photographs of at the wedding. As we had specifically requested that nobody bring cameras to the wedding I asked the photographers to take photographs of my family and friends that I could then give to them so that they would have memories of the occasion.

Security Measures to Protect Privacy

34. One of our major concerns from the outset was to ensure that media intrusion would not wreck our wedding. We wanted to enjoy our wedding without having to worry about the press. We knew that this would mean that very strict security would be required to protect us from media intrusion, but given our experience of the lengths to which the media would go to get pictures of us there was no other option for us. The defendants claim in their defence that the security measures were put in place to protect the commercial value of our agreement with OK! which I refer to later in this statement. That is untrue. The purpose of the security measures (which were arranged by us, without the help of OK!) was to prevent access by the media so that we could fully enjoy our wedding day. It was very important to both of us that we could be ourselves and enjoy ourselves with our families and friends in an intimate and private setting without worrying who was watching. The security measures were under discussion long before we decided to enter into an agreement with OK!.

35. The first invitation we sent to our guests said simply that the guest was invited to the wedding of Michael and Catherine in New York. For security reasons the invitation did not say where the wedding was due to be held or give any other details. However, certain other information was enclosed with the invitation including a request that no gifts be given to us and that if guests insisted on giving presents they should be in the form of a donation to the charitable fund to be run by Dylan when he comes of age. Another information sheet informed guests who were able to attend that further details would follow closer to the date.

36. After these invitations had been printed, but before they had been sent out, The New York Post published an article on 14 September disclosing that the wedding was to be held at The Plaza. We decided to send the invitations out in their original form anyway. As soon as we received a reply we sent out a notice to each person who had accepted the invitation informing him or her that the wedding would be held at The Plaza. We also sent with it a notice requesting that no photography or video equipment be brought to the wedding by our guests. I understand that Hello! has suggested that our request to guests not to bring cameras or video equipment to the wedding was not intended to bind our guests. That is untrue. It was clear from the context of the invitation that this was a direct instruction to our guests, albeit one that was expressed in polite and friendly language. Our close friends and family know how paranoid we have been forced to become over the issue of intrusive an unwelcome photography in recent years. Even without such a notice the vast majority of our friends and family would not have dreamed of bringing a camera to our wedding because they know of our privacy concerns. The notice accompanying the invitation was, for many of our guests, no more than a reminder of what they knew to be a binding rule concerning private events with me or Michael. In addition, it was made quite clear by the security procedures at the wedding itself that no photographic equipment was allowed at the wedding.

37. Although I was not personally involved in the details of the security arrangements they were an important feature of the planning for the wedding. A number of different security measures were used to ensure that only those guests who had specifically been invited could attend the wedding or the pre-wedding reception at the Russian Tea Room. For many of our celebrity guests these types of security arrangements were accepted as the norm. However, for our non-celebrity friends and, in particular for my family, these arrangements were entirely new to them and had to be explained very clearly. I remember that I had to warn my mother to tell all of the family that they absolutely must not forget their invitations without which they simply would not be able to get into the wedding. Fortunately, everybody remembered their invitation and nobody was refused access to the wedding.

Press covering of the preparations

38. In the run up to our wedding on Saturday, 18 November 2000 neither Michael nor I issued any information to the media concerning our wedding. The rumour mill, however, continued unabated. In the 11 months between our engagement and our marriage there was enormous coverage of our wedding plans, in particular in the English tabloid media. The vast majority of this coverage was entirely fictitious and included baseless statements as to where and when we were to be married as well as entirely speculative details of our guest list. An example of this is the article which appeared in The Mail on Sunday in March 2000 revealing, apparently authoritatively, that we were intending to hold the wedding at Skibo Castle. In fact this was nonsense. Michael and I had never even thought about holding the wedding at Skibo. I also remember one incident when Big Breakfast did a live broadcast from Swansea, complete with cardboard cut-outs of Michael and me stating that we were going to have our wedding in Swansea.

Inevitably, when it was discovered that this was not the case newspaper articles appeared stating that we had 'snubbed Swansea'. Many of the pre-wedding references in the press, as well as being mistaken, also were very upsetting and offensive to us. Perhaps the most offensive media article was published shortly before the wedding when one of the papers published a story stating that I hated Michael's brother, Eric, and that I was not going to invite him to the wedding because of his drug problem. He actually saw that article and telephoned me to ask me if it was true. Of course it was nonsense.

Decision to Grant Exclusive Rights to Photographs to OK!

39. When considering how to deal with the inevitable media interest in our wedding we ultimately decided to go down the same route that we had chosen in respect of Dylan's birth. We decided that, with a view to reducing the media frenzy for photographs of the wedding and protecting our wedding day from the inevitable media intrusion, we would reach an agreement with a magazine which we would allow to publish a limited number of our wedding photographs. We hoped that once the rest of the media found out that we had entered into such an arrangement they would be less interested in trying to infiltrate our wedding. This would leave us and our guests free do enjoy the day without worrying about the media. Both Michael and I also accept that as celebrities we have an obligation not to ignore those people who make us celebrities, the people who pay money to watch our movies. One of the reasons that we decided to reach a deal with a magazine was to make contact with our fans and to avoid the accusation that we had shunned them or were too aloof. We wanted to do so in a context where the choice was ours as to what was and was not published about our wedding, not left to a media free-for-all.

40. We appreciated that it would be impossible to obtain prior approval for photographs or text published in an American magazine. American publications are not prepared to grant prior approval. This was something that was essential for us. Both Hello! and OK! are in any event in many stores in the USA because there is no real equivalent over there. Having had a good experience with Martin Townsend and OK! over the photographs of Dylan, I was quite keen to work with OK! again in relation to the wedding. The negotiation of the deal was left up to Allen Burry who was fully aware of our requirements in terms of privacy, security and control over the photographs and text. Much of the basis for the agreement was the trust that Michael and I had in Martin Townsend personally, whom we liked, and in OK! because of our previous good experience of working with them.

41. In addition to our concerns about the photography, it was very important to both Michael and me that the wedding was reported in a fair and accurate way. I did not want to read articles full of nonsense such as those which had appeared in the run-up to the wedding. I also wanted to make sure that all references to my family members were accurate. For example, a number of other media organisations have previously, and continue to, repeatedly mix up my two grandmothers and to misspell their names. This may not seem an important issue to the people writing the articles, but it is very important to both me and to my family, especially to my grandmothers. These are not people who are used to being, or have volunteered to be, in the public eye. My grandmother Nanna Fair has since died and one article reporting her death used a photograph of my other grandmother, Nanna Zeta. Nanna Zeta was very upset by this.

42. It was also very important to me that the selection of photographs that were published showed the wedding to be the family occasion that it was going to be and not a celebrity event full of film stars in dark glasses. If the choice of photographs was left to the magazine it might have decided to focus on photographs of celebrities whereas I wanted it to be clear from the coverage how much my family means to me and how important a part my family played at the wedding.

43. Another key feature of the arrangement with OK! was that we retained legal control of the photographs. This was important to us because we wanted to be in a position to prevent the use of our wedding photographs by people hoping to cash in on the commercial value of our names and likenesses. As I have already mentioned, it is a constant battle to prevent this from happening.

44. As I have already mentioned, we did not confirm any details of the wedding to the media at large and made no press statements about our plans. OK! was provided with some information by Allen Burry for the edition that was going out to news stands on 17/18 November, the weekend of the wedding itself. Michael and I gave the interview to Michael Townsend for the wedding issue of OK! on the evening of 16 November.

45. The media needed no encouragement from us, however, in its coverage of the wedding, most of which was speculative. Inaccuracies in the press coverage included the following statements, that we had invited Steven Spielberg, Sir Michael Caine, Sharon Stone, Bill and Hillary Clinton, Brad Pitt and Jennifer Aniston to the wedding; that I had flown 30 friends over from Swansea; that after the wedding Michael and I were planning to rush back to work in Hollywood; that the wedding dress was designed by David Emmanuel; that Michael had asked his son, Cameron, to bury the hatchet after years of family strife in order to be best man; that Dylan had been carried down the aisle by Anne Douglas as opposed to Diana Darrid, Michael's mother; that Michael had bough me a £1 million yacht for a wedding present and that we had exchanged our vows in the Presidential Suite.

HELLO! AND THE UNAUTHORISED PHOTOGRAPHS

46. On Sunday, 19 November 2000 (the day after the wedding) Michael and I returned to our apartment in New York. We had decided not to have a real honeymoon but rather to spend some time on our own with Dylan. We were both absolutely delighted at the way the wedding had gone. It was exactly the wedding I wanted --a homely wedding notwithstanding the fact that it was on a large scale. We had managed to have a private wedding for our family and friends without suffering the intrusion of the media into our special day. We spent the first day of our 'honeymoon' reminiscing about what a wonderful time we and our guests had had.

47. However, all of this was quickly spoilt. On the following morning Martin Townsend telephoned Allen Burry whose office was in our apartment. Allen put us on to the speakerphone and Martin told us that they had discovered that unauthorised and pirated photographs of the wedding were due to be published in Hello! Michael and I were devastated. It was an appalling and very upsetting shock to discover that our wedding had been invaded in that way. Our peace and happiness evaporated. I felt violated and that something precious had been stolen from me. Our distress and anger at what Hello! did to us continues to this day.

48. I was extremely nervous as to the type of photographs Hello! might have and how Michael and I and our guests would be portrayed. I thought that they might have had photographs that could embarrass my guests. I did not want my guests to open a copy of Hello! and feel as violated as we felt that afternoon. In addition, there were many private moments of the wedding from which the official photographers had been excluded, including my time alone with Michael after we had signed the wedding register and of me crying during the ceremony. I had no idea whether Hello! had photographs of those very intimate moments, and until the photographs were actually published in Hello! I had no idea of what they would look like and who might be embarrassed or offended by them.

49. It was awful for me to have to think about this so soon after our beautiful wedding. I was suddenly thrown from the quiet, peace and joy of our time alone to anger and feelings of betrayal of what Hello! had done. It seemed to us that Hello! was publishing the photographs to spite us for not allowing them to cover the wedding. Hello! knew full well from their discussions with Allen Burry how much we wanted our wedding to be free from concerns about the media. They knew that by publishing the photographs they were causing us the distress we had tried so hard to avoid. We were determined that Hello! should not get away with, and profit from its terrible behaviour. We wanted to assist OK! who had been so co-operative and completely trustworthy and we also wanted to ensure that at least some of the official photographs of our wedding were published as soon as possible to offset the damaging effect of whatever Hello! was going to publish. We spent hours and hours sitting on the floor going through the photographs (which would in other circumstances have been a wonderful experience) in a mad rush in order to approve them so that OK! could publish the official photographs before Hello! published its unauthorised and pirated photographs.

50. I remember sitting on the phone crying about the way that our memories of the wedding which had seemed so wonderful had suddenly soured. Both Michael and I found ourselves racking our brains to think which of our guests could possibly have betrayed us in this way. Names were discussed and suspicions were aroused about many people. At the time I just felt sickened, as did Michael.

51. Although I did not attend the court hearings in London, when Michael and I with OK! tried to prevent the publication of the stolen photographs, I understand from our lawyers that our distress at the prospect of their publication was made clear at those hearings. Hello!'s decision to go ahead and publish the photographs after the injunction was lifted, knowing full well how upset this would make us, seems even more unforgivable to me.

Issue 639 of Hello!

52. The following weekend I was in New York with Michael when we first saw issue 639 of Hello! which contained the illicit photographs of our wedding at pages 87-91 of that issue. Allen Burry brought a copy up to the apartment to show it to us. Not surprisingly, seeing the photographs were exactly the sort that I did not want to see. They were poor quality, sleazy, unflattering and looked like they had been stolen, as indeed they had. They also contained images of several private moments which Michael and I would never have agreed to getting published to the outside world. The whole point of the security arrangements and our agreement with OK! was to allow us the freedom at our wedding of not having to worry about our public image and to be completely relaxed and natural.

53. I have the following specific comments about the Hello! photographs:

53.1 The main cover photograph, which is repeated on page 89, shows me looking as if I am about to stab Michael with the cake knife. It was a light-hearted, faintly ridiculous, moment which we did not want or expect to appear on newstands around the world.

53.2 The photographs at the top of page 87 shows my father walking me down the aisle. This, for me, was an incredibly important moment in the ceremony made ludicrous by the appalling quality of the photograph. In the first place the photograph is so blurred that the people in it are barely recognisable. Secondly, the only part of my father that can be seen is his arm. My wedding was specifically meant to be, and was, a real family event, but the stolen Hello! photographs show no decent pictures of my family.

53.3 The photograph at the top of page 88 shows Michael feeding me a piece of cake. This was another light-hearted, intimate, incident which shows how relaxed we felt. The moment is private and would have remained so but for Hello!'s publication of the photographs.

53.4 The photograph of me at the bottom of page 88 shows me eating more cake. Again it is poor quality and clearly has the look of a snatched photograph.

53.5 The photograph on page 90 is an awful paparazzi shot of a very private moment of Michael and I kissing. That is precisely the type of photograph that I would not have wanted to be published, especially with the caption "the new Mr and Mrs Douglas share a lingering kiss as the party continues".

53.6 On page 90 is a deeply unflattering photograph of me dancing with respected journalist Ed Bradley. The photograph makes me look large. From a professional point of view this is an example of a photograph that I would never have allowed to be published. It was extremely important for my career that I regain my figure after giving birth to Dylan. I had put a lot of work in at the gym (which I loathe going to). It is all too easy for the film industry to conclude that an actress is past her best. On a personal note, as any bride would, I wanted to look my best on my wedding day. This photograph would not have been included in my wedding album. Finally, the caption to that photograph states "The vivacious bride took to the dance floor but not, at any time, with her groom." That is false, extremely offensive and very hurtful. In fact I danced with Michael for most of the time throughout the evening. The other part of the same caption which refers to Michael giving "his lovely young bride" a £1 million yacht is also complete nonsense. He did not give me a yacht and it makes it sound as if my relationship with Michael revolves around material things.

54. There were a number of inaccuracies in the text of Hello!'s article about the wedding. Hello! said Michael and I spent the night in the Astor Suite of the Waldorf Hotel. We did not in fact spend any time in the Astor Suite.

Hello! referred to my grandmother, Zeta, having had a hip and eye operation. In fact she has had neither. She had had a knee operation. Hello! stated that members of my family flew over by private jet. That was untrue. Hello! reported that Sir Sean Connery, Sir Michael Caine and Jeff Bridges attended the wedding. In fact, Sean was invited but could not come. Neither Sir Michael Caine nor Jeff Bridges were invited to the wedding. Hello! reported that Dylan was carried down the aisle by my mother when in fact it was Michael's mother. Hello! recycled the rumour that we have considered getting married in Clyne Chapel in Wales. This was untrue. As mentioned above, it was also reported that Michael gave me a £1 million yacht as a wedding gift. That, too, was untrue. Finally, again as mentioned above, Hello! said I did not dance with Michael at the wedding. Again, this is untrue and carries a very hurtful insinuation.

55. I have already said we felt that Hello!'s coverage of the wedding was spiteful. It was introduced by an article entitled "When Michael met Catherine. The Romance that convinced them he should take a second try at marriage". The article consisted of photographs of Michael and his first wife, Diandra, side by side with photographs of Michael and me with very pointed captions such as "the same chairs that Diandra loved to relax in were soon being used by Catherine once her involvement with Michael was well out in the open". This just increased my upset at what Hello! had done.

56. The publication of the unauthorised photographs in The Sun, under the headline "Catherine Eater-Jones" added insult to injury. The sleazy looking photographs with the silly caption turned the intimate moments into something ridiculous and made Michael and me objects of fun for The Sun readers. Any bride would be distraught by that sort of humiliation. It was cruel. The Daily Mail also published Hello!'s stolen photographs in its issues dated 24 and 25 November 2000.

57. Once the Hello! photographs had become public, our family and many of our friends were very sensitive as to how we and our wedding day had been violated by Hello!

58. I understand that Hello! has suggested that our wedding was a commercial venture and that the purpose of the deal with OK! Was to make money. As I have already said, the purpose of our arrangement with OK! Was entirely different. The money was not the important aspect of the deal. I appreciate that to most people £1 million is a very large sum of money. However, it was the sum offered by both OK! and Hello! which indicates the value of such photographs to the media. We did not negotiate over the sum. What was more important to us was ensuring that our wedding was not spoilt by media intrusion and that we could choose what was published about our wedding.

59. I also understand that Hello! has suggested that we used the occasion of our wedding to boost our careers as professional actors. Without wishing to seem immodest, the suggestion that two well-known actors with various professional awards between them would use their wedding day to boost their professional careers is patently ludicrous and frankly offensive. It was the very last thing on our minds. Hello!'s subsequent publication of other photographs.

60. Since Hello! published the unauthorised photographs of the wedding it has published features about Michael and me (and Dylan) which strongly suggest to its readers that we have agreed to being interviewed by Hello! and being photographed for the feature. This is totally false, as neither of us would want for obvious reasons to be associated in any way with Hello! In its issue 694 dated 1 January 2002 it published an article purporting to show "how motherhood has only added to (my) beauty". In fact the photographs were taken a year before Dylan was born. The accompanying text suggests to the reader that I had given an interview to Hello! In fact nothing could be further form the truth. I still feel very angry and upset about Hello!'s publication of the intruder's stolen photographs of the wedding and the way in which it destroyed the peace of the period after our wedding. I have no intention of giving Hello! an interview. I also feel that such articles make me look wholly hypocritical and unprincipled to anyone who knows that we are suing Hello! The same applies to the feature in issue 715 of 25 May 2002 about our visit to the South of France, the main purpose of which was to support a charity event organised by one of our friends. To the casual reader it may appear that we have co-operated with Hello! over the feature, but we did not. Another feature published in issue 700 dated 12 February 2002 with photographs of Michael, Dylan and me gives the same impression. We did not co-operate with Hello!

61. I feel that Hello! Is deliberately taunting me. The last feature is a case in point. It reused a photograph of Dylan and me on a beach whilst we were all on holiday in Mauritius. We had already complained to Hello! About the publication of this photograph and others which appeared in issue 679, September 11, 2001. They had been taken without our consent whilst we were on a private holiday. Hello! republished the photograph in its issue 700 in full knowledge of our distress and upset about the original publication.

62. Another example of Hello! apparently deliberately targeting me was its inclusion of the Ernest Jones advertisement using a photograph of me in issue 691, 4 December 2001. As I have already explained I am not prepared to allow my likeness to be used without my authorisation. I had not authorised its use by Ernest Jones. In any event, Hello! apparently had a choice as to the photograph used for the advertisement and it chose one of me. The same issue also contained a feature about the contributions our wedding guests had given to the charitable fund that Michael and I have set up for Dylan to administer for the benefit of others when he grows up.

63. In its issue 698, Hello! used a photograph of me taken by Mario Testino in an article about an exhibition of his photographs at the National Portrait Gallery in London. It was a photograph originally published in Vanity Fair. When Mario Testino asked whether I would consent to it appearing in the exhibition I agreed. Then Hello! wrote to my agent, Cece Yorke, asking for permission to use another photograph in a feature about the exhibition and permission was refused. They went ahead with the publication of the photograph in question for which they had not requested, nor did they have, permission to publish.

64. In its issue 737 dated 29 October 2002, Hello! carried a feature of my second pregnancy entitled "CATHERINE How She's Putting a New Baby Before Her Career". In addition to being full of factual inaccuracies, the article makes gratuitous and offensive comments on the inevitable increase in my weight during pregnancy and casts doubt on the future of my career.

65. Hello!'s publication of these features about me and my family since the publication of the wedding photographs rubs salt in the wound as far as I am concerned and makes Hello!'s conduct even worse to my mind.