EFTA01733898

e evonshires solicitors Daniel Foggo Our Ref: PTBICLICA4218704 The Sunday Times 5 March 2011 Dear Daniel Ghislaine Maxwell I have received an email from you to Brett Jaffe. I represent Ghislaine Maxwell. The allegations to which you refer are all entirely untrue and without any factual basis. Ghislaine Maxwell was not required to answer the subpoena served upon her and has not failed to give a deposition. I have seen the article in today's Daily Mail and I would wish you to know that Ms Maxwell will be issuing proceedings against the Daily Mail absent receipt of a full retraction and apology on suitable terms. The allegations made by against Ghislaine Maxwell (as at points 1 — 14 of your email) are all entirely baseless, utterly false and without merit. Ghislaine Maxwell has never been contacted by any police force or other law enforcement agency in connection with any allegations made against Jeffrey Epstein. She has absolutely no connection to the criminal prosecution of Jeffrey Epstein and was neither approached by the defence or prosecution in that matter. Ghislaine Maxwell has not been named as a party in any proceedings relating to Jeffrey Epstein. Further, no one has at any time even written to Ghislaine Maxwell making any claims against her. It is quite extraordinary that if what is saying is her genuine held belief, that she did not add Ghislaine Maxwell as a party to any claim or even write to Ghislaine Maxwell putting her on notice of any such claim. The only legal process that Ghislaine Maxwell has ever received is a subpoena which was served on her and which she was not required to answer. One of the lawyers primarily responsible for promoting allegations against Jeffrey Epstein was Scott Rothstein. In June 2010, Mr Rothstein was sentenced to 50 years imprisonment for his involvement Lexcel 30 rmsbury Crews. Logsdon ECM 7DT Tel 020 7 628 7578 Fat 0670 008 9390 DX 13858 nnsbury Souse awetelevoneheneo corn A 1st ot pores a open ter aspecoon a as oases TNt Mn Oats rot oxeye some r6 electronic mai or escort The Mn is matted b/ ea Royston &Short/ EFTA_R1_00010510 EFTA01733898 in what is reported to have been the largest ever fraud in Florida, a US$1.2 billion ponzi scheme. He is also the primary defendant in a civil law suit based on his fraud in which the claim is US$100 billion. He is a man without any shred of credibility. He is a proven liar and someone who has sought to manipulate the law to his own advantage. He is reported as being connected with the making of false claims in relation to Jeffrey Epstein. has previously made unsubstantiated allegations for sexual misconduct. On at least one other occasion, she claimed to have been sexually assaulted and the government declined to prosecute the case "due to the victim's lack of credibility. [She also has criminal convictions for offences of dishonesty] allegations are nothing other than an attempt to seek additional financial windfall by generating publicity and thereby seeking a degree of fame. Ghislaine Maxwell will be commencing proceedings against the Daily Mail in connection with the article they have published today unless a full retraction and apology are tendered on acceptable terms. You will obviously appreciate the substantial damage that Ghislaine Maxwell will suffer from the publication of allegations of this nature. If you choose to publish any material you should ensure that you make it clear at the outset of the article and in its heading that the allegations made by are vehemently denied and that action is going to be taken against the Daily Mail. Yours sincerely Philip Barden Partner Page 2 EFTA_R1_00010511 EFTA01733899