Epstein Secrets

the Zwirn entities. He effectively was terminated by DBZ on October 4, 2006, shortly after an internal investigation by Schulte Roth & Zabel LLP ("Schulte Roth") concluded that Mr. Gruss was responsible for two instances of financial misconduct. Soon after Mr. Gruss departed, additional instances of Mr. Gru

or permission to depose Perry Gruss, DBZ's former Chief Financial Officer. We submit that Jeepers has not met its burden to show good cause why Mr. Gruss's deposition should be taken, and Your Honor should deny permission to take his deposition.' In its February 14, 2011 letter, Jeepers tries to port

r in response to Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc.'s (collectively, "Jeepers") request for permission to depose Perry Gruss, DBZ's former Chief Financial Officer. We submit that Jeepers has not met its burden to show good cause why Mr. Gruss's deposition should be taken,

, 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

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

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

volving oversight of sub-advisor DB Zwirn beginning in the Fall 2006." • September 24, 2006 Zwirn calls Jeffrey to advise that he is going to fire Gruss but it is not for material reasons. Jeffrey advises that he wants to redeem FTC's entire investment. • Sepetember 30, 2006. Gruss is fired. • O

me by Zwirn caused me to send an additional notice in February 2007 demanding redemption of my entire investment EFTA00729346 • 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

paid, so that DSAM still retains an interest in the Zwirn business.] • In October 2006, Zwirn called me to alert me to the fact he had terminated Perry Gruss as CFO for reasons which Zwirn initially claimed were not material. I believe that Zwirn's counsel told you a similar story, but with more details.

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

at Dubin and Swieca still retains an interest in the Zwirn business. • In October 2006, Zwirn called me to alert me to the fact he had terminated Perry Gruss as CFO for reasons which Zwirn initially claimed were not material. I believe that Zwirn's counsel told you a similar story, but with more details.

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

at Dubin and Swieca still retains an interest in the Zwirn business. • In October 2006, Zwirn called me to alert me to the fact he had terminated Perry Gruss as CFO for reasons which Zwirn initially claimed were not material. I believe that Zwirn's counsel told you a similar story, but with more details.