P) evonshires solicitors The Editor Our Ref: PTBICLWA4219254 The News of the World 7 March 2011 NOT FOR PUBLICATION Dear Sir Ghislaine Maxwell We represent Ghislaine Maxwell. Our client is appalled and outraged AND SCHOCKED by the highly defamatory allegations published by you on Sunday 6 March 2011. Our client received no advance notification that you intended to publish and so had no opportunity to defend herself OR TO BE ABLE TO TELL YOU THAT THE ALEGATIONS WERE WITHOUT ANY MERIT, BASLEESS AND WRONG. The articles contain numerous untrue and defamatory statements. It would seem that in the feeding frenzy to attack Prince Andrew our clients rights were totally disregarded. You have stated that our client has engaged in procuring underage girls to have sex with Jeffrey Epstein. For the avoidance of doubt that is accusing our client of having engaged in very serious criminal misconduct. You have labelled our client as a child abuser. These are extremely serious AND DAMAGING allegations for you to have published and it is extraordinary that you have done so without any advance notice to our client. You say in your article that: "Legal paperwork, held by lawyers in West Palm Beach acting for some of the 14 girls who have lodged suits against 58 year old Epstein, also names Prince Andrew's close friend, Ghislaine Maxwell, daughter of disgraced publishing tycoon Robert Maxwell as well as Epstein's social fixer, as a child abuser." Our client has absolutely no knowledge whatsoever of these papers or the allegations to which you refer. Accordingly and so our client may defend herself and in accordance with the overriding objective of the Civil Procedure Rules, we require you to immediately provide us with copies of all the documents on which you rely in support of the allegations you have made. In particular "the legal paperwork" to which you refer. We demand this by way of advance disclosure. Please provide this by 4pm today given the gra