e evonshires The Editor The Sun solicitors Our Ref: PTBICLICA4220542 7 March 2011 NOT FOR PUBLICATION Dear Sir Ghislaine Maxwell We represent Ghislaine Maxwell and are writing to you regarding the highly defamatory allegations published by you on 7 March 2011 in the Trevor Kavanagh. In this article, Trevor Kavanagh seeks to attack the UK libel laws by implying that newspapers have to say there is not a shred of evidence against either Prince Andrew or our client, Ghislaine Maxwell when by implication there clearly is. Mr Kavanagh says that our client "allegedly helped supply ex-boyfriend Epstein with underage "sex slaves—. Mr Kavanagh then says, 'there is no suggestion that Ghislaine is a disgusting procuress'. These are highly defamatory comments. Mr Kavanagh may care to reflect upon the fact that the libel laws exist to protect people from having untrue and defamatory allegations made against them in the media. Responsible journalism involves the proper investigation of claims that are then put to individuals who have an opportunity to at least respond before there is publication. None of that has happened in relation to this story. We would ask you to 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 Lexcel 30 rmsbury Dews. Laskin ECM 7DT Tel 020 7 628 7578 Fax 0670 008 9390 DX 13858 nnsbury Spume wonv.devonehen7s com A 1st ot pores is open