From: jeffrey E. <jeevacation@gmail.com>
Sent: Monday, January 5, 2015 9:15 PM
To: G Maxwell
Subject: Re:

Dear Sir,

Our client: Ghislaine Maxwell

Matter:

We have previously written to=20 you recording our client's denial of allegations made by and calling into question the accuracy of reporting.

As a publication regulated by=20 the Independent Press Standards Organisation, you must uphold the Editor's Code of Practice. You will be familiar with this and=in particular:

• All members of the press have a duty to =aintain the highest professional standards.

	- It is essential that the agreed code be =onoured not only to the letter, but in the full spirit.

• It is a responsibility of editors and publishers to apply the Code to editorial material in both printed and online versions of publications. They should take care to ensure it i= observed rigorously.

• The press must take care not to publish =naccurate, misleading or distorted information.

• A significant inaccuracy, misleading statement or distortion once recognised must be corrected, promptly and with due prominence, and where appropriate, an apology published.

Contrary to the above, you have=20 run a number of articles which accuse our client of having engaged in procuring minors for prostitution, which is obviously a most serious accusation and so requires detailed investigation prior to publication.

The articles date back to March=20 2011 and remain online via your website even though they contain contradictory accounts, from which it is evident that you knew that material you have published and which denigrates our client, is inaccurate, misleading or distorted.

The stories you have run are based upon information provided to you by <u>It would=20</u> appear that you have taken no effective steps to check the information provided or to investigate

On 7 March 2011 you first published alle=ations under the heading "Epstein's Girl Friday 'fixer =99: dead tycoon's daughter Ghislaine Maxwell and the girl sh= hired for paedophile stable".

• On 4 April 2014 you published basically the same allegations again under the heading 'The bombshell court=20 document that claims Prince Andrew knew about billionaire friend's =buse of underage girls".

More recently on 4 January 2015 you published a "world exclusive" under the heading "Th= first full account of the masseuse at the centre of the explosive Prince Andrew 'sex s=ave' drama... but is she telling the truth?"

It should have been readily apparent to you from the content of your article on 4 January 2015 that | is not telling the truth.

Your stated sources for the article on 4 January 2015 are “the court documents Ms  lodge= in Florida last week” and “we spoke to Ms  twice, the I=st time just 12 months ago”. The other occasion was obviously prior to publication on 7 March 2011.

There is a glaring inconsistency, which you have ignored, between the versions of events you put forward in your article dated 7 March 2011and what you now say is "the most complete story yet".

The central allegation made by=20 in your article published on 7 March 2011 is that she was recruited by our client who the same day, took her to Mr Epstein =99s mansion, where she met and then had sex with Mr Epstein whilst our client was present. Our client emphatically denies that this ever happened.

We wrote to you following publication of these allegations in 2011 and 2014 and you stood by them.<=p>

It now emerges that this is not=20████████' case at all. Rather, that it was somebody e=se, who is unnamed, and
not our client who is alleged to have led █████ to Mr Epstein's bedroom and who was then present whilst Ms █████'
claims to have had sex with Mr Epstein.<=p>

This is an entirely different=20 version of events. It cannot, or should not, have escaped your notice=20 that the story you published this Sunday was so materially different from the allegations previously published that both versions of events cannot be reconciled. As both versions are=20 based on interviews with MsM, , she has clearly lied. You should=20 have reported this prominently, and drawn the conclusion that her testimony is unreliable.

Further, you should have conducted a professional investigation, in which you would have spoken to, amongst others, her family and you would then have learnt that her father states that Ms:  told him she met the Queen when she came to London. You could have checked that with Buckingham Palace and would have found it to be untrue. This shows Ms=20:  makes up stories.

Further, you ought to have established that | was employed in a burger bar which is wholly inconsistent with her sex slave account. We understand that Ms=20 left America shortly after her then employer reported that she had stolen money.

We have previously drawn to you= attention that Brad Edwards the lawyer fiiing these claims was the p=rtner of Scott Rothstein who was sentence to 50 years in prison for in par= selling fake epstein sex settlement cases. in part for forging a ju=ges signature,

As you know, Brad Edwards, ██████ █████' current counsel was Rothsteins partner.

Despite the fact that Rothstein=20 was convicted of serious criminal offences of fraud relating to his conduct in generating false claims, that is a matter that you have ignored within your reporting. Any balanced journalism would have looked at the circumstances of the origin of the claim, have investigated its voracity and then taken a view as to whether or not it was accurate before reporting it.

Your reporting has failed to address the material inaccuracies in | account and =ou have used Ms MI obviously false allegations to denigrate our=20 client, who as Robert Maxwell's daughter YOU VIEWED AS an easy target.

Ms claims are =antasy fuelled including the suggestion that she had sex with a famous prime minister. You have not challenged her to name this person as you shou=d have done, as this is yet another fantasy.

It should be apparent to you that Scott Rothstein'S FIRM ORIGINALLY GOT get together=20 to make FALSE AND DEFAMATORY false claims. Had these been properly investigated you would have reported them as such, if you reported them at all.

FURTHER AS YOU ARE FULLY AWARE =ON OF HER CLAIMS HAVE BEEN TAKEN UNDER OATH AND THEREFORE NOT TESTED TO AN= STANDARD OF PROBITY

The above calls for an apology =o our client, RETRACTIONS IN PRINT and a detailed explanation.

Yours faithfully

On Mon, Jan 5, 2015 at 4:=8 PM, G Maxwell <GMaxl@ellmax.com <mailto:GMaxl@ellmax.com» wrote:

Draft Letter to the Editor of the Mail on Sunday

Dear Sir,<=p>

Our client: Ghislaine Maxwell

Matter:

We have previously written to y=u recording our client’s denial of allegations made by calling into question the accuracy of reporting.



Ro=erts and

As a publication regulated by t=e Independent Press Standards Organisation, you must uphold the Editor =80 s Code of Practice. You will be familiar with this and in parti=ular:

• All members of the press have a duty to =aintain the highest professional standards.

- It is essential that the agreed code be =onoured not only to the letter, but in the full spirit.

• It is a responsibility of editors and pu=lishers to apply the Code to editorial material in both printed and online=versions of publications. They should take care to ensure it is obse=ved rigorously.

	• The press must take care not to publish =naccurate, misleading or distorted information.

• A significant inaccuracy, misleading starement or distortion once recognised must be corrected, promptly and with d=e prominence, and where appropriate, an apology published.c/=pan>

Contrary to the above, you have=run a number of articles which accuse our client of having engaged in proc=ring minors for prostitution, which is obviously a most serious accusation=and so requires detailed investigation prior to publication.

The articles date back to March=2011and remain online via your website even though they contain contradic=ory accounts, from which it is evident that you knew that material you hav= published and which denigrates our client, is inaccurate, misleading or distorted.

The stories you have run are ba=ed upon information provided to you by . <u>It</u> would ap=ear that you have taken no effective steps to check the information provid=d or to investigate

• On 7 March 2011 you first published alle=ations under the heading "Epstein's Girl Friday If=xer: dead tycoon's daughter Ghislaine Maxwell and t=e girl she hired for paedophile stable".

- On 4 April 2014 you published basically =he same allegations again under the heading "The bombshell court d=cument that claims Prince Andrew knew about billionaire friend's a=use of underage girls".

• More recently on 4 January 2015 you publ=shed a "world exclusive" under the heading "The fi=st full account of the masseuse at the centre of the explosive Prince Andr=w 'sex slave' drama... but is she telling the truth?"



It should have been readily app=rent to you from the content of your article on 4 January 2015 that is not telling the truth.



Your stated sources for the article on 4 January 2015 are "the court documents Ms  lodged in Florida last week" and "we spoke to Ms  twice, the last time just 12 months ago". The other occasion was obviously prior to publication on 7 March 2011.

There is a glaring inconsistenc=, which you have ignored, between the versions of events you put forward i= your article dated 7 March 2011and what you now say is "the most=complete story yet".

The central allegation made by = in your article published on 7 March 2011is that she was =ecruited by our client who the same day, took her to Mr Epstein's =ansion, where she met and then had sex with Mr Epstein whilst our client was present. Our client emphatically de=ies that this ever happened.

We wrote to you following publi=ation of these allegations in 2011 and 2014 and you stood by them.<=>

It now emerges that this is not case at all. Rather, that it was somebody =Ise, who is unnamed, and not our client who is alleged to have led Virgini= to Mr Epstein's bedroom and who was then present whilst Ms claims to have had sex with Mr Epstein.<=>

This is an entirely different v=rsion of events. It cannot, or should not, have escaped your notice =hat the story you published this Sunday was so materially different from t=e allegations previously published that both versions of events cannot be reconciled. As both versions are b=sed on interviews with Ms M, she has clearly lied. You should =ave reported this prominently, and drawn the conclusion that her testimony=is unreliable.

Further, you should have conduc=ed a professional investigation, in which you would have spoken to, amongs= others, her family and you would then have learnt that her father states =hat Ms  told him she met the Queen when she came to London. You could have checked that with Buck=ingham Palace and would have found it to be untrue. This shows Ms Rob=rts makes up stories.

Further, you ought to have esta=lished that | was employed in a burger bar which is wholly =nconsistent with her sex slave account. We understand that Ms Robert= left America shortly after her then employer reported that she had stolen money.

We have previously drawn to you= attention that | was one of the complainants THAT SURFACED=CONTEMPORANOUSLY AND MAY HAVE BEEN generated by Scott Rothstein who was ja=led for a substantial period for his part in a Ponzi fraud scheme, which related to encouraging investors to fu=d litigation against Epstein in respect of which Rothstein produced false =laimants.

As you know, Brad Edwards, ██████████' current advisor worked for Rothstein.</=pan>

Despite the fact that Rothstein=was convicted of serious criminal offences of fraud relating to his conduc= in generating false claims, that is a matter that you have ignored within=your reporting. Any balanced journalism would have looked at the circumstances of the origin of the claim, have in=estigated its voracity and then taken a view as to whether or not it was a=curate before reporting it.

Your reporting has failed to ad=ress the material inaccuracies in account and yo= have used Ms obviously false allegations to denigrate ou= client, who as Robert Maxwell's daughter YOU VIEWED AS an easy target.

Ms  claims are =antasy fuelled including the suggestion that she had sex with a famous pri=e minister. You have not challenged her to name this person as you s=ould have done, as this is yet another fantasy.

It should be apparent to you th=t Ms:  and Scott Rothstein'S FIRM ORIGINALLY GOT get t=gether to make HER FALSE AND DEFAMATORY DEPOSITION false claims. Had=these been properly investigated you would have reported them as such, if you reported them at all.

FURTHER AS YOU ARE FULLY AWARE =ON OF HER CLAIMS HAVE BEEN TAKEN UNDER OATH AND THEREFORE NOT TESTED TO AN= STANDARD OF PROBITY

The above calls for an apology =o our client, RETRACTIONS IN PRINT and a detailed explanation.</=>

THE TERRA=AR PROJECT <http://theterramarproject.org/>
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From: J Jep
Date: Monday, January 5, 2015 at 15=45 PM
To: gmax
Subject: <no subject>

call now

please note

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Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com <mailto:jeevacation@gmail.com> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved

please =ote

The information contained in this communication is confiden=ial, may be attorney-client privileged, may constitute inside informati=n, and is intended only for the use of the addressee. It is the propert= of JEE Unauthorized use, disclosure or copying of this communica=ion or any part thereof is strictly prohibited and may be unlawful. If =ou have received this communication in error, please notify us immediat=ly by return e-mail or by e-mail to jeevacation@gmail.com <mailto:jeevacation@gmail=com> , and destroy this comm=nication and all copies thereof, including all attachments. copyright -=11 rights reserved