EFTA01110775.pdf

I JOHNSONS PT/BC/ME00010021 14 March 2011 Telegraph Media Group Ltd. Ill Buckingham Palace Road London SW1W ODT Johnson& Law Firm FAO: The Editor, The Daily Telegraph London Offices 21 Arlington Street London SWIA Cc: Arthur Wynn Davies, Legal Manager — Arthur.wynn-dayics a telearanh.co.uk Belfast Office Johnson House 50/56 Wellington Place Belfast DTI 6GF Dear Sirs. DX 405 Belfast I We have been consulted by Jeffrey Epstein in relation to your grossly iI inaccurate and persistent references to him being a "paedophile", in Dublin Office particular in your editions of 7 ih and 10th March under the headlines 4 Harbourmaster Place "Duchess of York admits Duke arranged for convicted paedophile IFSC Dublin 1 Jeffrey Epstein to pay off her debts" and "The Duke, his paedophile Ireland guest, and the most unusual use of an RAF base" respectively, and on DX 112018 Talbot Street. Dublin your website. Our client is not, as your headline article alleges, a convicted paedophile. Panama Although he has been convicted of soliciting prostitutes, and procuring a Paul Tweed LIP • Michael McKee person under 18 for prostitution, he has served his time for that offence. As Ken Chambers a matter of record, but without seeking to justify the offence, the girls in David Craig David Holley question were not pre-pubescent. Selena Kenns John McMahon Furthermore, the false and distorted terminology used by you to describe our Consultants client in your vitriolic attack on his character is simply not true on any John Marshall David Rogers interpretation of the word "paedophile". He has not been convicted nor been accused of being a paedophile (a pejorative that has a very specific medical Solution George Suahan definition), apart from by certain elements of the tabloid press in their recent Sarah Loughran reports on his friendship with Prince Andrew. Our client however should be Muon McClung Carl Rooney entitled to expect more accurate and credible reporting from a respected Gareth Liddy broadsheet such as the Daily Telegraph, which is supposed to have Jennifer Greenfield James gad significantly higher standards than the sensationalised and exaggerated John Kerr reporting of the tabloids. Kathy Mathews Brun Connolly Alex Trimble Our client is entitled, at the very least, to the publication of a categoric RhYs Jones Deaglan Lundy clarification and apology, in terms to be first agreed with us, as a matter of Mark Kernaghan some urgency. We would therefore be grateful to receive your proposals in Laura Cunningham this regard, while our client continues to reserve all his rights in relation to, • hal INned a. otbn d hut Weed LLP n also ItrOWted JLt a /pew tffltA in particular, what would be a totally justified Complaint to the PCC, ont.:Isar, In.Lr %Life fu r of Cahlania WOINV.jOhlaSOMIIJW.COM .4 do Soknon Itetulation AIW010111) ruIO 5RA ID 341150 Paul Pam; LLP SPA ID 545975 EFTA01110775 together with appropriate redress in relation to your defamatory allegations and malicious falsehoods. We look forward to hearing from you by return. Yours faithfully, JOHNSONS EFTA01110776