Mishcon de Reya Our Ref: = JLL/HEW/HA/Alan Dershowitz Africa House Your Ref: 70 Kingsway London WC2B 6AH DX 37954 Kingsway URGENT — NOT FOR PUBLICATION -— STRICTLY PRIVATE & CONFIDENTIAL www.mishcon.com Daily Mail Northcliffe House 21 December 2018 2 Derry Street London W8 STT BY EMAIL Dear Sirs Our client: Alan Dershowitz We act for Alan Dershowitz. Our client is featured in an article entitled ‘Second woman claims billionaire Jeffrey Epstein "directed" her to have sex with lawyer Alan Dershowitz WHILE he was defending pedophile on underage prostitution charges' published on your website on 18 December 2018 at the following URL: https://www.dailymail.co.uk/news/article-6509743/Second-woman-claims- billionaire-Jeffrey-Epstein-directed-sex-lawyer-Alan-Dershowitz.html (the Article). The Article The Article contains a number of extremely serious and highly defamatory statements about our client's alleged involvement with Heading: e "Second woman claims billionaire Jeffrey Epstein ‘directed’ her to have sex with lawyer Alan Dershowitz WHILE he was defending pedophile on underage prostitution charges" Sub-heading: e "Ransome alleges that she was asked to have sex with Alan Dershowitz by Epstein" Body: e "A second woman is claiming that she was ‘directed’ to have sex with lawyer Alan Dershowitz by one of his clients, billionaire felon Jeffrey Epstein"; e "... she was told by Epstein to have sex with Dershowitz"; 51150637.2 Switchboard: London: Mishcon de Reya LLP Main Fax: New York: Mishcon de Reya New York LLP Mishcon de Reya is a limited liability partnership, registered in England and Wales (number 0C399969), authorised and regulated by the Solicitors Regulation Authority, SRA number 624547. HOUSE_OVERSIGHT_020662

Mishcon de Reya e "Dershowitz would have been defending Epstein at the time of the alleged sexual encounter, having been hired to work on the case in 2005 when a number of underage girls began coming forward and telling police they were paid to have sex." e "This makes the second woman to allege that she had sex with Dershowitz at the behest of Epstein." These allegations mean and would be understood to mean that: e Mr Epstein directed] to have sex with our client; e Our client had encouraged Mr Epstein to direct in this way; e Ms Ransome alleged that our client had sex with her; e Our client did in fact have sex wit e Our client was in some way involved in Mr Epstein's soliciting of women for prostitution; « Our client was in some way involved in Mr Epstein's soliciting of children for prostitution; « Our client's behaviour was improper and in breach of his professional obligations and the law; and e Our client is a sexual predator and/or a paedophile. The facts Our client did not have sex with PF Indeed, our client has never met or previously heard of f has been unwilling to make any claims about our client outside the courtroom (we assume for privilege reasons). Our client has never been in any way involved in Mr Epstein's alleged soliciting of women or children for prostitution. Our client is not a sexual predator or a paedophile. We are instructed that: e The allegations made by MM form part of a wider campaign against our client by MMB lawyer, David Boies, against whom our client has filed a complaint with the Florida bar. ¢ [ERE is 2 known fantasist. Amongst other claims, she has claimed to have sex tapes of the US President, Donald Trump, as well as Hillary Clinton, Bill Clinton, and other prominent figures. She has also accused our client of having acted for her in the past — a claim which is easily disprovable by court records. 51150637.2 2 HOUSE_OVERSIGHT_020663

Mishcon de Reya All of the above information was in the public domain at the time you published the Article. Your conduct Your conduct has been disgraceful. You published the Article without making any effort to seek our client's comment. Further, you took the story from an article in The New York Daily News, yet chose to ignore our client's position contained therein. You also deliberately embellished upon the story in The New York Daily News: nowhere in that article does it state either that claimed that she had sex with our client, or that she did have sex with him. In fact, quite the opposite, it states as follows: "Nowhere in the court case or the transcript does Ransome or anyone else allege that had sex with Dershowitz — or that she was directed to." It is staggering that a news organisation as well-resourced and with such a good reputation as yours has conducted itself in this way. Serious harm Given the gravity of the Allegations — which include imputations of seriously improper and/or unlawful behaviour — as well as the nature and extent of publication, there is no question that serious harm has been, and will continue to be, caused to our client's reputation. The serious harm you have caused to our client's reputation is not only causing him (and his family) great anguish, it is likely to cause significant damage to his ability to earn in the future. He will hold you fully liable for this. Immediate action required In view of the above, our client requires you to immediately do the following: I. Remove the Article from your website. 2. Publish an apology, the terms of which to be agreed. 3 Remove any associated links to the Article within your website. 4. Undertake not to repeat the Allegations. 5. Undertake to pay our client significant damages, the quantum of which to be agreed. 6. Undertake to pay our client his legal costs. Please may we hear from you within 24 hours. In the meantime, all our client's rights are reserved. 51150637.2 3 HOUSE_OVERSIGHT_020664

Mishcon de Reya Yours faithfully JAulrcon Le flesa ae 2 Mishcon de Reya LLP Direct Tel: Direct Fax: Email: 51150637.2 4 HOUSE_OVERSIGHT_020665