Thomas Sheridan, born 7 March 1964, whose domicile of citation has been specified as Paisley Road West, Glasgow, and Gail Sheridan, born 4 January 1964, whose domicile of citation has been specified as Paisley Road West, Glasgow, you are indicted at the instance of The Right Honourable Elish Angiolini, Queen's Counsel, Her Majesty's Advocate, and the charges against you are that
(1) you THOMAS SHERIDAN having raised an action of defamation in the Court of Session, Parliament House, Parliament Square, Edinburgh against News Group Newpapers Limited, 124 Portman Street, Kinning Park, Glasgow, a company incorporated under the Companies Acts, being the publisher of the News of the World newspaper, in which you alleged that on 21 November 2004 the said newspaper had published an article communicating the false idea that you had visited a "swingers club" with Anvar Begum Khan, c/o Lothian and Borders Police, Police Headquarters, Fettes Avenue, Edinburgh, and knowing that a civil jury trial had been fixed for the hearing of said action on 4 July 2006 and having on 9 November 2004 at a meeting of the Executive Committee of the Scottish Socialist Party held at 70 Stanley Street, Glasgow, attended by, among others, Colin Fox, c/o Lothian and Borders Police, Police Headquarters, Fettes Avenue, Edinburgh, admitted attending such a club and in particular Cupid's Healthclub, 13-17 Sutherland Street, Swinton, Manchester on two occasions in 1996 and 2002 and knowing that accurate minutes of the said meeting existed and had been lodged on 16 June 2006 at the said Court on behalf of the said defender and that said Colin Fox was to be called as a witness at said trial did on 18 June 2006 at the premises known as The Beanscene, 67 Holyrood Road, Edinburgh attempt to suborn said Colin Fox, to falsely depone as a witness that the minutes of said meeting were not accurate and you did thus attempt to suborn said Colin Fox to commit perjury;
Friday (2) on 21 July 2006 at the Court of Session, Parliament House, Parliament Square, Edinburgh you THOMAS SHERIDAN being affirmed as a witness in a civil jury trial of an action for defamation then proceeding there at your instance against the News Group Newspapers Limited, 124 Portman Street, Kinning Park, Glasgow as publishers of the News of the World newspaper did falsely depone: -
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a) that at a meeting of the Executive Committee of the Scottish Socialist Party held on 9 November 2004 at 70 Stanley Street, Glasgow you had not admitted you had attended Cupid's Healthclub, 13-17 Sutherland Street, Swinton, Manchester known as Cupid's on two occasions in 1996 and 2002 and that you had not admitted that you attended there with Anvar Begum Khan c/o Lothian and Borders Police, Police Headquarters, Fettes Avenue, Edinburgh;
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b) that at said meeting on 9 November 2004 Alan William McCombes and Keith Robert Baldassara, both c/o Lothian and Borders Police, Police Headquarters, Fettes Avenue, Edinburgh did not state that they had previously raised the issue with you of your visits to a sex club in Manchester and that you had admitted to them that it was true;
c) that at said meeting you denied having visited a swingers' club in Manchester;
d) that Allison Kane, Keith Robert Baldassara, Alan William McCombes, Allan Green, Colin Anthony Fox, Barbara Jane Scott, Carolyn Leckie, Catriona Mary Grant, Joanna Harvie, and Rosemary Kane all c/o Lothian and Borders Police, Police Headquarters, Fettes Avenue, Edinburgh had lied in evidence during said civil jury trial when each gave evidence that: -
they had heard you admit at said meeting on 9 November 2004 that you had visited said Cupid's in Manchester; and
they heard it being stated at said meeting on 9 November 2004 that Alan William McCombes and Keith Robert Baldassara had previously raised the issue with you of your visits to a sex club in Manchester and that you had admitted to them that it was true;
e) that you had not admitted in 2002 to said Alan William McCombes and Keith Robert Baldassara that you had attended a sex club in Manchester;
f) that you did not say at the said meeting held on 9 November 2004 that you were not prepared to resign as convener of the Scottish Socialist Party unless there was proof that you had attended a sex club in Manchester and that you did not believe that there was any evidence to prove that you were lying about not attending said club;
g) that in a pub known as the Golden Pheasant,2 Stepps Road, Kirkintilloch on or around Friday 12 May 2006 you were not given the minutes of the said meeting of 9 November 2004 to read;
h) that said Alan Green lied during his evidence in said civil jury trial that in said pub known as the Golden Pheasant on or around 12 May 2006 he had shown you the minutes of the said meeting of 9 November 2004;
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i) that there was not an event on 14 June 2002 or at any other time at the Moathouse Hotel, Congress Road, Glasgow organised by Matthew McColl, c/o Lothian and Borders Police, Police Headquarters, Fettes Avenue, Edinburgh which you attended along with Andrew McFarlane, c/o Lothian and Borders Police, Police Headquarters, Fettes Avenue, Edinburgh at which you and said Andrew McFarlane went into a bedroom with a girl and had sexual relations with said girl;
j) that Helen Todd Allison and Lily Anne Colvin both c/o Lothian and Borders Police, Police Headquarters, Fettes Road, Edinburgh lied in their evidence during said civil jury trial when each gave evidence that you were at the Moathouse hotel with said Andrew McFarlane;
k) that a conversation between you and said Keith Robert Baldassara had not taken place when said Keith Robert Baldassara had asked you about "madness" somewhere in a hotel in Glasgow and that you said to him that you did not participate, but were present at the event when a lady from Birmingham was brought in;
l) that said Keith Robert Baldassara lied in his evidence during said civil jury trial that he had asked you about "madness" somewhere in a hotel in Glasgow and that you said to him that you did not participate, but were present at the event when a lady from Birmingham was brought in;
m) that you had not attended said Cupid's in Manchester along with Andrew McFarlane, Gary Clark, Anvar Begum Khan and Katrine Trolle all c/o Lothian and Borders Police, Police Headquarters, Fettes Avenue, Edinburgh towards the end of 2001, or had ever visited a swingers' club;
n) that you had an affair with said Anvar Begum Khan in late 1992 for six months only and that you did not have a sexual relationship with her from 1994 to 2002; and
o) you never had a sexual relationship with said Katrine Trolle and had never been with her in the house occupied by you at Paisley Road West, Cardonald, Glasgow or with her at Kingennie Court, Dundee;
the truth being as you well knew, that on 9 November 2004 at the Executive Committee meeting of the Scottish Socialist Party held at 70 Stanley Street, Glasgow, you did admit to attending said Cupid's in Manchester on two occasions in 1996 and 2002 and that you had visited said club with said Anvar Begum Khan;
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that at said meeting it was stated by said Alan William McCombes and Keith Robert Baldassara that they had previously raised the issue of you attending a sex club in Manchester and that you had admitted to them that it was true;
that at said meeting you did not deny having visited a swingers' club in Manchester;
that said Allison Kane, Keith Robert Baldassara, Alan William McCombes, Allan Green, Colin Anthony Fox, Barbara Jane Scott, Carolyn Leckie, Catriona Mary Grant, Joanna Harvie and Rosemary Kane had not lied in evidence during the said trial when they each gave evidence that: -
i) they had heard you admit at said meeting on 9 November 2004 that you had visited the said Cupid's in Manchester on two occasions and
ii) they had heard it being stated that said Alan William McCombes and Keith Robert Baldassara had previously raised the issue with you of your visits to a sex club in Manchester and that you had admitted to them that it was true;
that: -
i) on 3 November 2002 in the course of a journey between Glasgow and Edinburgh you did admit to said Keith Robert Baldassara that you had attended a sex club in Manchester;
ii) on an occasion between 4 November 2002 and 31 December 2002, at the City Chambers, George Square, Glasgow, you did admit to said Alan William McCombes that you had visited a club for swingers in Manchester and
iii) on 1 November 2004 at the City Chambers, George Square, Glasgow, you did admit to said Alan William McCombes and Keith Robert Baldassara that you were the MSP referred to in the News of the World article published on 31 October 2004 and that you had attended said Cupid's in Manchester with said Anvar Begum Khan;
that you did state at the said meeting held on the 9 November 2004 that you were not prepared to resign as convener of the Scottish Socialist Party unless there was proof that you had attended the said Cupid's in Manchester and that you did not believe that there was any evidence to prove that you were lying about not attending said club;