Epstein Secrets

e course of the settlement negotiations and for wrongfully inducing Jeepers to enter into the Agreement. However, it is clear that no claim against Schulte Roth could be pursued absent termination, as they are released under the terms of paragraph 6. 4 EFTA00731204 Attorney Work Product Privileged and C

.4 2. Potential Claims Against Glenn Dubin and Highbridge Capital You have also asked us to examine what claims, if any, Jeepers might have against Glenn Dubin and/or Highbridge based upon representations made by Dubin that Jeepers should not withdraw its complete investment from the Fund. A threshold quest

f the claims Jeepers might have against the Fund. Section Two of this memorandum addresses any claims that Jeepers might have against Glenn Dubin ("Dubin") or Highbridge Capital ("Highbridge"), including the extent to which Dubin or Highbridge are covered by the terms of the Settlement Agreement and

, Perry Gruss, sometime 5 in the future. 03:16:18 6 That Mr. Kahn had showed up on most of 7 the e-mail with respect to the airplane which 8 Schulte Roth had been -- I believe it was, Schulte 9 Roth had been called in in May of '06, my best 10 recollection, sir, to deal with the issues of the 03:1

Page 201 1 Epstein 2 you? 3 A. Correct. 4 Q. And the reason that you are telling 5 Mr. Dubin that you want out is because you can't 02:50:10 6 get a firm answer on this issue; isn't that 7 correct? That's what the e-mail says; correct?

r one from you to 4 Mr. Dubin. 5 Do you recall these? 03:23:22 6 A. I see them now. 7 Q. You see the bottom e-mail, Jeffrey 8 Epstein to Glenn Dubin Sunday, December 6, 2009, 9 2:05? 10 A. Yes, sir. 03:23:32 11 Q. Do you recall sending that? 12 A. I sent it. 13 Q. Do you recall send

non-material accounting irregularities. Zwirn claims it was on advice of counsel. JEE speaks to Dubin, Zwirn and Zwirn's counsel (Harry Davis from Schulte Roth) about lie and JEE again demands to redeem FTC's entire investment in the Fund. At this time, it is explained that Zwirn is trying to avoid a run o

l Memorandum of the Fund. On page 14,"Although HCM (Highbridge Capital Management, LLC) is a Member of the Trading Manager, neither HCM nor Messrs. Dubin or Swieca have any authority or discretion over the operations or investments of the Trading Manager, the Fund, or the Non-U.S. Fund. Mr. Ziwrn ha

tations made to me by Zwirn caused me to send an additional notice in February 2007 demanding redemption of my entire investment • In March 2007, Schulte Roth informed me that both my November 2006 and February 2007 redemption requests were denied. As I have stated previously, Schulte Roth claimed that my

wirn and Co. • In September 2004, Highbridge sold most of its interests to J.P. Morgan. Though its is Kirklands' understanding that, in substance, Dubin and Sweica continued to receive its portion of the management and incentive fees I paid to Zwirn and then passed on to you and henry in the form of

tations made to me by Zwirn caused me to send an additional notice in February 2007 demanding redemption of my entire investment • In March 2007, Schulte Roth informed me that both my November 2006 and February 2007 redemption requests were denied. As I have stated previously, Schulte Roth claimed that my

wirn and Co. • In September 2004, Highbridge sold most of its interests to J.P. Morgan. Though its is Kirklands' understanding that, in substance, Dubin and Sweica continued to receive its portion of the management and incentive fees I paid to Zwirn and then passed on to you and henry in the form of