Epstein Secrets

is to certify that a true and correct copy of the foregoing instrument has been served by email and first class mail, this 17th day of August, on: Brad S. Karp Allan Arffa Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019 John S. Siffert Lankier Siffert & Wohl

on of Perry Gruss. 1205876v1/011585 13 EFTA00722321 Timestamp: 8/16/2010 5:38 PM CDT 38. All communications among Counterclaim Respondents and Gruss concerning Gruss's termination or the subsequent litigation filed by Gruss against Zwim, including any pleadings or discovery instruments or docume

l documents concerning any review or investigation of the Fund's operations, finances, or accounting prompted by or occurring after the departure of Perry Gruss from involvement with the Fund or any of the Zwim Entities. 36. All witness statements taken in connection with any internal review or investigat

From: "Harty Susman" < =c ,• To: A "Allan Arffa" "Arastu Chaudhury" ,'Dan Reynolds" "Jennifer Spiegel" "William O'Brien" "Andrew Lee" , "Brad Karp" , "Hannah Sholl" , John Siffert" "William Schwartz" Cc: "Steve Susman"<MIMMr>, "Seth Ard" <=1 1==>, "Bill Dunseth" Subject: FTC/Jeepers vs. Z

s "real" witness list as well as our best guess of when the witnesses will be called: Dan Zwirn--Friday, July 22 Jeffrey Epstein--Monday, July 25 Perry Gruss--Monday-PM Harry Beller--Tuesday, July 26 Glenn Dubin--Tuesday Darren Indyke--Wednesday, July 27 Dan Stachman (rebuttal expert, subject to motion

OF SERVICE This is to certify that a true and correct copy of the foregoing instrument has been served by email and first class mail, this day of Brad S. Karp Allan Arffa Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019 John S. Siffert Lankier Siffert & Wohl

m contacted Epstein. The two had not spoken about anything of substance since 2002. Zwim informed Epstein that the Fund's Chief Financial Officer, Perry Gruss, had been terminated over an accounting transaction that was "nonmaterial." Zwim specifically mentioned that more than $3 million in investor money