e evonshires The Editor The Daily Mail solicitors The Editor The Mail on Sunday Our Ref: PTBICLICA4220501 7 March 2011 NOT FOR PUBLICATION Dear Sir Ghislaine Maxwell We represent Ghislaine Maxwell.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 w