Macon de Reya Our Ref: JUJHEVV/HAFAlan Dershowitz Africa House Your Ref: 70 Kingsway London WC2B 6AH DX 37954 Kingsway URGENT — NOT FOR PUBLICATION — STRICTLY PRIVATE & CONFIDENTIAL www.mishcon.com Martin Clarke Publisher MailOnline Northcliffe House 2 Derry Street London W8 5TT Dear Sir Our client: Alan Dershowitz Letter of Claim We write further to previous correspondence in this matter. 4 January 2019 BY EMAIL In the absence of a satisfactory reply to our letters, we have been instructed by our client to send you (in your capacity as Publisher of MailOnline) a formal letter of claim in accordance with the Pre-Action Protocol for Defamation. For the avoidance of doubt, the article that forms the subject of our client's complaint is the one published on MailOnline on 18 December 2018 headed "Second woman claims billionaire Jeffrey Epstein 'directed' her to hove sex with lawyer Alan Dershowitz WHILE he was defending pedophile on underage prostitution charge" (url: , y II I CO I 65097.13 SLE ,in-; I is-Dill .L-JJ' Ly-EistL IVJj'L -A IT- DL LL ). We attach a copy of the article for ease of reference (omitting the 'under- the-line' comments). Despite our detailed initial complaint of 21 December, which requested that the article be removed immediately from the MailOnline website, and our follow-up letters of 22 and 29 December, the article remains online to this day. In the light of this, we start by observing that your newspaper's lackadaisical and dismissive response to our client's complaint stands in stark contrast to the seriousness with which he takes this matter. Indeed, we cannot overstate — and you should not underestimate — how seriously he takes it. Both he and we are staggered at the indifference you have shown thus far. 51241084.3 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