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e evonshires solicitors
The Editor Our Ref: PTEALCL1014220554
The Daily Telegraph
The Editor
The Sunday Telegraph
7 March 2011 NOT FOR PUBLICATION
Dear Sir
Ghislaine Maxwell
We represent Ghislaine Maxwell.
In reporting a story relating to Prince Andrew on 6 March 2011 in the Sunday Telegraph you
reported that our client is accused "in court papers of introducing young women to Epstein at
his Florida mansion". You qualified that by saying "although she has never been arrested
nor charged with any offence".
In fact, it goes far wider than that. Our client has riorbeieliesu
ith bject of any claim and the
only claim she was aware of was a claim made by
You refer to allegations that have been promoted by and her attorney who
we believe is Brad Edwards. Mr Edwards is the former business partner of Scot Rothstein
who is currently serving 50 years having created false claims and cases against Jeffery
Epstein.
You have further reported the allegations against our client on the Daily Telegraph on
Saturday 50 and Monday 70 March. Within those reports are various untrue and defamatory
statements.
We demand that you cease publishing such untrue material about our client and 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.
30 Finsbury Circus. London EC2M 7DT
TN 020 7 628 7576 Fax 0870 608 9390 DX 33856 Finsbury Square
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EFTA01158468
4. Furthermore, our client has never even been put on notice of any such claim
5. Our client 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 neither
was she approached by the defence or the prosecution in that matter.
6. The only legal process that our client h • is a subpoena for a
deposition in civil proceedings brought by against Jeffery Epstein
and not our client. Our client was not require o answer e deposition as she was
instructed Mr Epstein had settled the case. Our client was merely one of many people
who were issued with subpoena's in that matter.
7. 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 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. It is recorded in Court papers that Mr
Rothstein made and pursued false claims against Jeffrey Epstein which included
promoting allegations of improper conduct of the type you describe.
8. Mr Rothstein directly created false cases against Mr Epstein which he then sold to
investors. Further he encouraged false complaints to be made. We understand that
attorney Brad Edwards was formerly Mr Rothstein's business
ar.ne was a the time that these false claims were being created and promoted
came forward.
9. as summonsed to court for Theft in 2002. We do not know if that is
related to her leaving the United States.
10 has previously made unsubstantiated allegations for sexual
misconduct. On at least one other occasion, she claimed to have been sexually
assaulted and the US Government declined to prosecute the case "due to the victim's
lack of credibility".
Accordingly we demand an apology, retraction and agreement to pay damages by 4pm this
Wednesday 91h March.
Absent which our client will take action to clear her name.
Yours faithfully
Devonshires
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