Epstein Secrets

n-privileged or, if privileged, is relevant to the business of managing the Funds and the Managed Accounts. I cannot be certain, but I suspect that Schulte is the legal counsel in respect of which those attorney client privileges are claimed by DBZCO under the Information Sharing Agreement It is my und

in Privileged Communications between DBZCO and Legal Counsel or May Constitute Attorney Work Product The Buyer Enters into Guaranty Agreements with David Lee, Lawrence Cutler and Other DBZCO Employees Providing Transition Services, Pursuant to Which Guaranty Agreements the Buyer Guarantees Salary, Bonus

. 8 EFTA00613915 By June 2006, Messrs. Cutler and Proshan reported back to Mr. Zwim. They recommended that DBZ retain Schulte Roth & Zabel LLP ("Schulte") to investigate the management-fee and airplane issues, determine what had occurred, and provide legal advice on potential disclosure and employme

been approved by Schulte in the calls he made to investors. 9 EFTA00613916 Mr. Gruss resigned on the verge of being fired in early October 2006. David Lee was appointed to replace him as DBZ's Acting CFO. Mr. Zwirn informed investors of Mr. Gruss's separation from DBZ in mid-October 2006, using a scri

payment for the purchase of an airplane to be used by Mr. Zwirn for business travel. Mr. Zwirn then caused the law firm Schulte Roth & Zabel LLP ("Schulte") to undertake an investigation into what had occurred. The investigation was apparently completed in mid-September 2006. Thereafter, in early Octo

w subscription for an investment was treated as a separate "tranche," with its own cycle of rolling lock-ups. (See Exhibit Q; Exhibit R.) Mr. Zwim, David Lee (former President and acting CFO of the Fund manager) and Elise Hubsher (former head of the Marketing and Investor Relations Group for the Fund man

t.com EFTA00299206 Page 123 1 2 about it. 3 4 5 have considered to be material? 6 7 8 9 10 11 12 bells and whistles 13 time, when Schulte 14 '06 to investigate 15 16 17 18 19 20 21 22 23 24 25 Q• Epstein And the materiality being that there was a thief, which was someth

to a bunch of unreturned 8 telephone calls, basically saying don't -- don't 9 reach out for Dan Zwirn anymore, speak to somebody 10 else, call David Lee. 02:40:19 11 Q. So you believe that this e-mail was 12 sent because you wanted to talk to Dan and they 13 were trying to deflect you to David