EFTA01733881

e evonshires The Editor The Daily Mail solicitors The Editor The Mail on Sunday Our Ref: PTBICLICA4220501 7 March 2011 NOT FOR PUBLICATION Dear Sir Ghislaine Maxwell We represent Ghislaine Maxwell. Our client is appalled and outraged by the highly defamatory allegations published by you in the Daily Mail on Saturday, 5 March 2011 and today, 7 March 2011 and in yesterday's Mail on Sunday. At this stage, we are writing to both your publications with the same letter as we note that you are both drawing on material from the same journalist, Sharon Churcher and the same issue arise regarding both publications. Our client received no advance notification that you intended to publish allegations in the Daily Mail on 5 March. That article contained numerous untrue and defamatory statements. It would seem that in the feeding frenzy to attack Prince Andrew, our client's rights were totally disregarded. Whilst we did respond to the questions raised late on 4th March and in connection with the Mail on Sunday article, given the information we supplied, it is extraordinary that you continued to defame our client and you were on firm notice that they were untrue. Then again today, further untrue statements have been published. We demand that you stop publishing these allegations as you are on notice that they are untrue. It is t.mf table for example that in your press coverage you have not referred to the fact that lawyer, Brad Edwards, was the business partner of Scott Rothstein who has been convicted and sentenced to 50 years in prison for making false claims against Jeffrey Epstein. Scott Rothstein was creating false cases on which he raised investment finance — that was the ponzi fraud. So you should know that there are false cases not just claims. We note that in 2007 whilst reporting allegations made against Jeffery Epstein you made it clear that our client was not in any way implicated in those allegations. Additional) ou make no reference whatsoever to character. Are you not aware that was arrested in 2002 for theft. We do not as yet know if that led to a conviction nor if that was related to her decision to leave the United States. Lexcel 30 Finsbury Crews. Logsdon ECM 7DT Tel 020 7 628 75 78 Fax 0670 008 9390 DX 13858 Felsbury Square wifettlevonehen7s corn ot pores is open for aspeceon at otr onus Ilia Mn Saes rot oxept some by electronic mai or tinier* Ths Mn is matted try ne Sokoto's Reg' on AsOloorti EFTA_R1_00010140 EFTA01733881 You have present as being a credible and reliable source of evidence. She is neither. The information that she has given to you and apparently contained within legal proceedings is untrue. Our client has at no time engaged in any improper, let alone, unlawful conduct of the nature set out in your publications or otherwise. Our client was not aware of any improper or unlawful conduct on the part of Jeffrey Epstein. Your decision to continue to run with this story in a feeding frenzy around Prince Andrew is doing considerable damage to our client's reputation and as a consequence of that she will suffer significant financial loss and damage. We hold you fully accountable and responsible for all loss and damage our client suffers as a consequence. You are already on notice that every time you publish these untrue allegations our client's loss and damage increases. We will be drawing the Court's attention in due course, your failure to desist and if you continue to publish as you are doing, then we will ask the Court ultimately to award enhanced damages to reflect your misconduct. Whilst we have previously put these matters to you, we would once again ask you to carefully note the following: 1. Our client was not aware of any improper or unlawful conduct by Jeffery Epstein. 2. Our client has not been named as a party in any proceedings relating to Jeffrey Epstein's unlawful conduct or any other similar conduct by anyone else. 3. Further, no one has at any time even written to our client making any claims against her. If what is being alleged are the genuinely-held beliefs of third parties, the fact that these have never even been put to our client is extraordinary and should have indicated to you that they were likely to be untrue. 4. Furthermore, our client has never even been put on notice of any such claim. 5. Our client has never been contacted by any police force or other law enforcement agency in connection with any allegations made against Jeffrey Epstein. She has absolutely no connection to the criminal prosecution of Jeffrey Epstein and neither was she approached by the defence or the prosecution in that matter. 6. The only legal process that our client has ever received is a subpoena for a deposition in civil proceedings brought by against Jeffery Epstein and not our client. Our client was not required to answer the deposition as she was instructed Mr Epstein had settled the case. Our client was merely one of many people who were issued with subpoena's in that matter. 7. One of the lawyers primarily responsible for promoting allegations against Jeffrey Epstein was Scott Rothstein. In June 2010, Mr Rothstein was sentenced to 50 years imprisonment for his involvement in what is reported to have been the largest ever fraud in Florida, a US$1.2 billion ponzi scheme. He is also the primary defendant in a civil law suit based on his fraud in which the claim is US$100 billion. He is a man without any shred of credibility. He is a proven liar and someone who has sought to manipulate the law to his own advantage. It is recorded in Court papers that Mr Rothstein made and pursued false claims against Jeffrey Epstein which included promoting allegations of improper conduct of the type you describe. Page 2 4220501.1 EFTA_R1_00010141 EFTA01733882 8. Mr Rothstein directly created false cases against Mr Epstein which he then sold to investors. Further he encouraged false complaints to be made. We understand that attorney Brad Edwards was formerly Mr Rothstein's business artner. It was at the time that these false claims were being created and promoted came forward. 9. has previously made unsubstantiated allegations for sexual misconduct. On at least one other occasion, she claimed to have been sexually assaulted and the US Government declined to prosecute the case "due to the victim's lack of credibility". Accordingly we demand that you issue a full apology, a retraction and your agreement to pay damages to be assessed by 4pm this Wednesday. Failing which our will commence proceedings to clear her name of these outrageous allegations and a pre-action protocol letter will be sent later this week If it is necessary to issue process then we shall seek aggravated damages. If you publish further we shall ask the court to take that into account in assessing the quantum of damages as any such conduct will only serve to increase the loss and damage our client suffers. Yours faithfully Devonshires Page 3 4220501.1 EFTA_R1_00010142 EFTA01733883