Mighcon de Reya

Mighcon de Reya Our Ref: JLUHEW/HA/AJan Dershowia Africa House Your Re 70 Kingsway London WC28 6AH DX 37954 Kingsway URGENT — NOT FOR PUBLICATION — STRICTLY PRIVATE & CONFIDENTIAL www.mishcon.com Daily Mail Northcliffe House 2 Derry Street London W8 5TT Dear Sirs Our client: Alan Dershowitz We act for Alan Dershowitz. 21 December 2018 BY EMAIL Our client is featured in an article entitled 'Second woman claims billionaire Jeffrey Epstein "directed" her to have sex with lawyer Alan Dershowitz WHILE he was defending pedophile on underage prostitution charges' published on your website on 18 December 2018 at the following URL hupsiliwviw,dcally_maitccktulilne_wsfarticle-6_50974_3/S_eco_nd-v_voillan-claims- b iunaire-Jeffrey-Epstein-directed-sex-lawyer-Alan-Dershowitz.html (the Article). The Article The Article contains a number of extreme) serious and highly defamatory statements about our client's alleged involvement wit Heading: • "Second woman claims billionaire Jeffrey Epstein 'directed' her to have sex with lawyer Alan Dershowitz WHILE he was defending pedophile on underage prostitution charges" Sub-heading: alleges that she was asked to hove sex with Alan Dershowitz by Epstein" Body: • "A second woman is claiming that she was 'directed' to have sex with lawyer Alan Dershowitz by one of his clients, billionaire felon Jeffrey Epstein"; • "... she was told by Epstein to have sex with Dershowitz"; 51150637.2 Mishcon de Reya is a limited liability partnership. registered in England and Wales (number OC399969). authorised and regulated by the Solicitors Switchboard: +44 (0)20 3321 7000 London: Mishcon de Reya LLP Regulation Authority. SRA number Main Fax: +44 (0)20 7404 5982 New York: Mishcon de Reya New York UP 624547. EFTA00794015 Mthhcon de Reya • "Dershowitz would hove been defending Epstein at the time of the alleged sexual encounter, having been hired to work on the case in 2005 when a number of underage girls began coming forward and telling police they were paid to hove sex." • "This makes behest of Epstein." the second woman to allege that she had sex with Dershowitz at the These allegations mean and would be understood to mean that: • Mr Epstein directed Ms to have sex with our client; • Our client had encouraged Mr Epstein to direct Ms • Ms alleged that our client had sex with her; • Our client did in fact have sex with Ms in this way; • Our client was in some way involved in Mr Epstein's soliciting of women for prostitution; • Our client was in some way involved in Mr Epstein's soliciting of children for prostitution; • Our client's behaviour was improper and in breach of his professional obligations and the law; and • Our client is a sexual predator and/or a paedophile. The facts Our client did not have sex with Ms Indeed, our client has never met or previously heard of Ms Ms has been unwilling to make any claims about our client outside the courtroom (we assume for privilege reasons). Our client has never been in any way involved in Mr Epstein's alleged soliciting of women or children for prostitution. Our client is not a sexual predator or a paedophile. We are instructed that • The allegations made b Ms form part of a wider campaign against our client by Ms lawyer, David Boies, against whom our client has filed a complaint with the Florida bar. • Ms is a known fantasist_ Amongst other claims, she has claimed to have sex tapes of the US President, Donald Trump, as well as Hillary Clinton, Bill Clinton, and other prominent figures. She has also accused our client of having acted for her in the past — a claim which is easily disprovable by court records. 51150637.2 2 EFTA00794016 Macon de Reya All of the above information was in the public domain at the time you published the Article. Your conduct Your conduct has been disgraceful. You published the Article without making any effort to seek our client's comment. Further, you took the story from an article in The New York Daily News, yet chose to ignore our client's position contained therein. You also deliberately embellished upon the story in The New York Doily News: nowhere in that article does it state either that Ms claimed that she had sex with our client, or that she did have sex with him. In faa.lie the opposite, it states as follows: "Nowhere in the court case or the transcript does or onyone else allege that had sex with Dershowitz — or that she was directed to." It is staggering that a news organisation as well-resourced and with such a good reputation as yours has conducted itself in this way. Serious harm Given the gravity of the Allegations — which include imputations of seriously improper and/or unlawful behaviour — as well as the nature and extent of publication, there is no question that serious harm has been, and will continue to be, caused to our client's reputation. The serious harm you have caused to our client's reputation is not only causing him (and his family) great anguish, it is likely to cause significant damage to his ability to earn in the future. He will hold you fully liable for this. Immediate action required In view of the above, our client requires you to immediately do the following: I. Remove the Article from your website. 2. Publish an apology, the terms of which to be agreed. 3. Remove any associated links to the Article within your website. 4. Undertake not to repeat the Allegations. 5. Undertake to pay our client significant damages, the quantum of which to be agreed. 6. Undertake to pay our client his legal costs. Please may we hear from you within 24 hours In the meantime, all our client's rights are reserved. 51150637.2 3 EFTA00794017 Miiiheon de Reya Yours faithfully /AAA& ca.e.cru 'et._ L_Lis Mishcon de Reya LLP Direct Tel: +44 (0)20 3321 7132 Direct Fax: +44 (0)20 3761 1846 Email: [email protected] 51150637.2 4 EFTA00794018