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21/06/95 - 1st Affidavit of Debra Angela
King
This is the 1st Affidavit of Debra Angela King sworn on behalf
of the Defendant on 21st June 1995
IN THE HIGH COURT OF JUSTICE
CHANCERY DIVISION BETWEEN:
(1) MICHELLE TAYLOR
(2) LISA BUCK (nee TAYLOR)
Plaintiffs
and
PATRICK BERNARD O'MAHONEY
(aka BERNARD PATRICK O'MAHONEY, PATRICK LAWSON and BERNARD
KING)
Defendant
AFFIDAVIT OF DEBRA ANGELA KING
I, DEBRA ANGELA KING, of Basildon, Essex, MAKE OATH AND SAY
AS FOLLOWS:
1.
I am the Defendant's common-law wife. I make this Affidavit
from my own knowledge unless otherwise indicated. I have read
the two Affidavits sworn by Michelle Taylor, the Affidavit
of Ray Buck and the Affidavit of Ann Taylor and I make this
Affidavit in response to certain of the allegations raised
that concern me.
2.
Bernard and I have lived together as man and wife for more
than 10 years, and have two children. We have never married.
The only break in the continuity of our relationship in all
that time was for the period June/July 1993 to November 1993.
This was as a result of my having become completely fed up
with the amount of time that Bernard was spending with the
Plaintiffs in this action and working on their appeal.
I thought he was neglecting me and our children. We had had
a major row a few years before over the amount of time he
was spending on fundraising for the James Fallon charity.
After an argument, Bernard moved out. I now know that approximately
a week later he moved into the flat occupied by the Plaintiffs,
and had an affair with Michelle Taylor.
3.
I do not know anything about a woman called "Donna"
or a girl in Battersea. Paragraphs 22 and 23 of Michelle Taylor's
Affidavit are a complete fabrication so far as they concern
me.
4.
It has been alleged that I told Michelle Taylor that the Defendant
received £50 for the use of an excerpt of the letter
in the article which appeared in the News of the World on
26th July 1992. I have no recollection of this conversation,
and as far as I know the allegation is untrue.
5.
I have been asked to set out the details of the telephone
harassment that I have suffered on and off since June 1993.
I first received a call from Michelle Taylor in June 1993.
It was in the early hours of the morning. She asked me if
Bernard was with me. I said that he wasn't in. At the time
I knew he was working at a nightclub. She put the phone down.
In the period June 1993- October 1993 I received 3-4 similar
calls, the caller identifying herself as Michelle each time.
On the last occasion I told her not to ring again in no uncertain
terms. Paragraphs 21-23 of Michelle Taylor's Affidavit are
wrong. Bernard came back to live with me in October 1993.
He told me he would have nothing further to do with the Taylors
and we started to patch things up.
After about two weeks, I then received another call at approximately
9 am on a Tuesday morning. The caller announced herself as
"Sharon" but I recognised the voice as Michelle's.
I said "I know its you Michelle, I told you not to call
any more". She denied she was Michelle to begin with,
then admitted it and said "I've got to talk to you".
She wanted to know if Bernard had moved back in with me.
She went into detail about how they had had an affair for
three months. She made a point of going into where they had
been on my son's birthday. I was very upset and angry. While
the call was taking place, Bernard was downstairs. He was
unaware that I was talking to Michelle. After the call ended
I went downstairs and told Bernard who had been on the phone
and what she said. I threw him out.
6. Over the course of the next few days Michelle called many
many times. On one occasion she claimed she had had a lengthy
conversation with my three year old daughter, which I didn't
like at all. She asked me deeply searching personal questions.
She asked me to meet her - she put it that we should go out
for a drink together one night and said she wanted to meet
my children.
During the same period I received several calls from Bernard,
who was telling me not to listen to Michelle. I told Bernard
I was going to meet Michelle and find out the truth. He told
me not to meet her under any circumstances. He put the phone
down and came straight round to my house. He called Michelle.
I cannot remember the exact words, but he yelled at her.
He was really angry. He was swearing. He kept saying "Keep
out of my life". He told her to keep away from me and
the kids. He said she had ruined his life. He said he wanted
nothing to do with her and she should keep away. That was
the last time I spoke to Michelle.
7.
However almost straight away I started to receive anonymous
telephone calls at all times of the day and night. As soon
as I answered, the telephone was put down at the other end.
I knew it must be Michelle. I did not have her telephone number
but found a piece of the campaign notepaper and called the
campaign number, which was Ann Taylor's house.
I told Ann Taylor to tell Michelle if she wanted to speak
to me to call me, but don't call my house and put the phone
down. I said I knew Michelle was calling my house to see if
Bernard answered the phone. I said "you can tell her
that he's gone". She queried what I meant by "gone".
I said "he's out of my life, he's gone, she won't find
him here". I don't recall saying anything about any News
of the World article.
8.
After a period of about two weeks I accepted Bernard back
and again we began to patch things up on the understanding
that we would never mention the Taylors. They were a bit of
a sore point to say the least. We have been together ever
since.
9.
Over the course of the next 6-8 months the calls continued,
on an irregular basis. Sometimes I would get one a week, sometimes
one a fortnight. Sometimes they would be more than one in
the night, then nothing for a few days. However the campaign
stepped up dramatically in the Summer of 1994.
They were being received about five times a week. I remember
this was about the time Bernard was asked by the Metropolitan
Police to make a statement concerning the assistance he had
rendered to the Plaintiffs in gathering and analysing evidence
prior to the Court of Appeal hearing. The coincidence in timing
prompted us to suspect that the anonymous calls were coming
from or at the instigation of the Plaintiffs. However, we
had no proof of this.
10.
During this period calls were coming in the early hours of
the morning and disturbing the children who were getting very
upset. Typically calls were received at about 3.30 am on weekdays
and 4.30-4.40 am on Fridays and Saturdays. It was always on
the nights that the Velvet Underground, the club where Ray
Buck then worked, was open. I was very frightened. I couldn't
sleep, and suffered an outbreak of psorriasis.
I telephoned British Telecom Nuisance Calls and spoke to a
Mr Dennis Copenhall. He explained the options available to
me for dealing with nuisance calls. These included changing
the number, having calls intercepted, and having a trace put
on them. He explained that a trace could only be used if an
official complaint had been made to the police and the police
had given permission for a trace to be used.
I wanted to find out who was making the calls, because it
was clear to me that the timing of each call, and the fact
that frequently the caller would sit on the line for between
5 and, on one occasion, 20 minutes saying nothing, was intended
to frighten me. I wanted to find out who was trying to frighten
me to this extent. I went to the police station to make a
complaint. I saw that the form for making the complaint said
that if the calls were traced, the police would prosecute.
I was frightened what might happen if they did prosecute,
so I left it. The calls went on for another four weeks or
so. I simply couldn't stand it any more. I called Dennis Coppenhall
again and he advised me to go to the police, which I did this
time. Within two days the trace was put on. I was told all
the calls were being traced to call boxes, which meant there
would be nothing the police or BT could do.
However, at about this time the 1471 facility was introduced.
We used the 1471 facility to get the numbers of the call boxes
from where the calls were being made. Once we had received
the telephone numbers, Bernard and I rang them, sometimes
over a period of several days, until someone answered. When
the telephone was answered, the person who answered was asked
to tell us where the call box was located.
Some people laughed and put the phone down, but eventually
by these means we established that all the calls were being
made at various call boxes between St Giles Circus, South
Bank University, New Kent Road and Peckham. We knew that Ray
Buck, the Second Plaintiffs husband, worked at the Velvet
Underground nightclub in St Giles Circus.
I could only conclude that he was making the calls, which
was borne out by the timing of the calls: they would have
coincided with him making his way home from his work as a
doorman in the early hours of the morning. We still had to
prove it though.
11.
After about 4-6 weeks, BT said they were going to withdraw
the trace, in another couple of weeks since it had only thrown
up call boxes. Fearing it was going to come to nothing, Bernard
called Ann Taylor to get a message to the Plaintiffs that
we knew the calls were coming from Ray Buck, and to warn them
that if this harassment, which by then I was finding unbearable,
did not stop, we would have no alternative but to take matters
furthers, (by which we meant get proof and go to the police).
It is fair to say that neither of us wanted to do this: all
we wanted to do was stop the calls. I am informed by Bernard
and verily believe that he told Ann Taylor that we knew the
calls were coming from the Plaintiffs, and asked her to intervene.
I was not a party to any of the subsequent conversations which
are referred to in Bernard's Second Affidavit.
12.
BT said they would not put video surveillance is so many call
boxes, so Bernard called Catford Police Station and asked
them if he could carry out his own video surveillance. He
was told it was the only way that sufficient evidence would
be collected for a prosecution. We arranged for my mother
to stay over and look after the two children. It was arranged
that when a call was received, she would press '1' to activate
the trace which would log the time of the call and where it
came from.
At the same time, we planned to follow Ray Buck to video him
making the call. The video would have a date and time on it
and, we anticipated we would then match up this information
with the date and time that the trace showed, in order to
link the two. This would prove that Ray Buck was making the
calls. The first time, on 29th December 1994 Bernard went
alone.
I am told by him, and verily believe, that he followed Ray
Buck from the club, but when Ray Buck pulled over, having
seen Bernard, Bernard drove on and drove home. The second
time, on 30th December, I went with Bernard to hold the video
camera while he drove. Ray Buck saw us and sped off and turned
into Devonshire Road.
He disappeared. We drove up and down Devonshire Road looking
into the turnings off that road to see where he had gone but
could not see his car. I now know, but didn't know at the
time, that Ray Buck lived in Devonshire Road. The following
day Ann Taylor telephoned. She spoke to Bernard and asked
why he was following Ray. Bernard told her about the calls
and the videoing. The calls then stopped. We haven't had one
since.
13.
Bernard contacted the police and gave them the map of the
route, the call numbers and everything. The police agreed
to interview Lisa and Ray. On 24th February 1995 I was informed
by PC Hayes and Inspector Reeve of Basildon Police Station
that when they interviewed Ray and Lisa, Ray made a full admission
and Lisa admitted making one call, and they are now being
prosecuted.
14.
Ray Buck has made a counter allegation that we were harassing
him, but this is not true and no charges have been brought.
15.
I have read the Affidavit sworn by Gary Jones on 13th June
1995 and confirm that the statements made in paragraph 5 of
that Affidavit concerning the circumstances in which the story
was published are true.
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