From: GMAX

From: GMAX To: J Jep <jeevacation(tcgmail.com> Subject: FW: Draft Responses Date: Sat, 05 Mar 2011 12:59:32 +0000 Attachments: The Sunday_Times_-_Daniel_Foggo_- _ AK _comments_-_05_03_11.DOC; The Mail on Sunday_Times_-_Anne Witheridge_- AK comments_-_04_03_11.DOC _ _ _ _ _ Inline-Images: image.gif I am out of time — this has to go now and it is what is going.. Forwarded Message From: Philip Barden Date: Sat, 5 Mar 2011 07:50:32 -0500 To: NY Max Cc: James Dunn Subject: Draft Responses >, Kevin Maxwell I have now received Alan Kilkenny's input and I have brought together two final versions. One for the Mail on Sunday and the other for the Sunday Times. There is a fine line to be drawn here as what we are trying to achieve is to limit reputational damage. Given that these allegations are in Court papers and within the public domain, even before this morning's article in the Daily Mail it is inevitable that the papers will run this story tomorrow. What we want to achieve is a balanced article that makes it clear that the allegations are denied, there is doubt as to their genuineness, i.e. Rothstein and to make it relatively complex. The one point Alan is very clear on is that if we overtly threaten litigation if they publish, that is only more likely to make them harden their stance as they are going to publish anyway. I would therefore suggest we send the attached subject to Ghislaine's sign off asap. I am on my mobile. Kind regards, Phili. Barden Partner Devonshires Website: www.devonshires.com chttplAwww.devonshires.come> 30 Finsbury Circus, London, EC2M 7DT This email is intended for the addressee named within only. It may contain legally privileged or confidential nformabon. If you are not the named individual you should not read this email and if you do so. you must not under any circumstances make use of the information therein. If you have read this email and it is not addressed to you. please notify ITtildevanshires.co.uk and confirm that 4 has been deleted from your system and no copies made. This Firm is regulated by the Solicitors Regulation Authonty under registration number 0049857. This Firm does not accept service by electronic mail or facsimile. A list of partners. together with further legal statements. is available upon request or at www.devonshires.co.uktterms-and-conditionvlegal-notices.html Devonshires Solicitors. 30 Finsbury Circus. London EC2M 7DT tel .44 (0)20 7628 7576 fax +44 (0)20 7256 7318 We have a complaints procedure. a copy of which is available on request. If you are not satisfied with our handling of your complaint. you can ask the Legal Ombudsman to consider the complaint. The Legal Ombudsman can be contacted on 0300 555 0333 or can be contacted by email: encpiriestillecialombudsman.orq.uk. Normally, you will need to bring a complaint to the Legal Ombudsman within 6 months of receiving a final written response from us about your complaint You also have a right to object to a bill by applying to the court for an assessment of the bill under Pan 3 of the Solicitors Act 1974. If all or part of the bill remains unpaid. we may be entitled to charge interest. The Devonshires Foundation is proud to support Clic Sargent (reg. chanty 1107328) and The National Autistic Society (reg. charity 269425) during 2010/2011. EFTA00635352 Val Please consider the environment before printing this email. End of Forwarded Message EFTA00635353