HOUSE_OVERSIGHT_020664.jpg

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