Epstein Secrets

he Company to incur substantial fees and expenses to said professionals. In addition, the Company disclosed Gruss's misconduct to the United States Securities and Exchange Commission, which commenced an investigation of the Company in March 2007 and which investigation is not completed. As a result, the Company incurred yet furt

a partner in the Company and a member of DBZLLC and was the Chief Financial Officer and Chief Administrative Officer of the Company. 4. Aver that Gruss was effectively terminated from the Company and DBZLLC, resigning on the verge of being fired, on or about October 4, 2006, and otherwise deny the

tence of Paragraph 16. 17. Deny the allegations of Paragraph 17, except admit that the Fund Controllers and the Operations department reported to Gruss and worked under his supervision; that they had responsibilities concerning accounting and record-keeping; that they worked with the Funds' Adminis

d a conference call? 03:09:43 21 A. No. No. 22 Q. The answer is no? I'm sorry. 23 A. No. 24 Q. Have you ever given testimony before 25 the Securities and Exchange Commission? 03:10:03 VERITEXT REPORTING COMPANY www.veritext.com EFTA00299290 Page 207 1 Epstein 2 A. Yes. 3 Q. Relating to what? 4 A. I think

hs. 25 Q. Who was present? 03:14:49 VERITEXT REPORTING COMPANY www.veritext.com EFTA00299294 Page 211 1 Epstein 2 A. I believe just Mr. Gruss and me. 3 Q. Who set up the meeting? 4 A. I did. 5 Q. How? 03:15:05 6 A. I called him. 7 Q. And asked if he would meet with you? 8

ate a bunch of 18 conversations, it was all the fact that Dan Zwirn 19 was a crook. 20 Q. Did you ever have a conversation with 03:14:36 21 Perry Gruss? 22 A. Yes. 23 Q. When was that? 24 A. In the past two months. 25 Q. Who was present? 03:14:49 VERITEXT REPORTING COMPANY www.veritext

erstandable goal, the Parties have agreed to a protective order. Moreover, the Fund (under prior management) produced many similar documents to the Securities and Exchange Commission without redacting any investor names, and a database of that production was given to FTC in this case without any redactions of investor names. As a

granted both parties the right to take such pre-hearing testimony of third- I57I529vI/011585 EFTA00585338 party witnesses (e.g., Mr. Dubin and Mr. Gruss), although the Zwim Parties and FTC subsequently elected to pass on the opportunity (preferring instead to call these witnesses to the Hearing itse

nts (continued) December 31, 2010 affect the value of the Fund's assets. The ultimate outcome of these mattes cannot be ascertained at this time. The Securities and Exchange Commission (the "Commission') has filed a civil complaint against Perry Gruss, the former Chief Financial Officer of the Original Manager, alleging improper t

of these mattes cannot be ascertained at this time. The Securities and Exchange Commission (the "Commission') has filed a civil complaint against Perry Gruss, the former Chief Financial Officer of the Original Manager, alleging improper transfers of client funds between 2004 and 2006. The Fund is not a pa