Epstein Secrets

thwart FTC's withdrawal. 1043197v1/011585 2 EFTA00722251 6. To help convince Epstein to change his mind, Zwirn sought the help of his partner, Glenn Dubin, who owned a minority interest in the Fund's general partner. Dubin had a long-standing relationship with Epstein. 7. On November 13, 2006, Zwim a

convince Epstein to change his mind, Zwirn sought the help of his partner, Glenn Dubin, who owned a minority interest in the Fund's general partner. Dubin had a long-standing relationship with Epstein. 7. On November 13, 2006, Zwim and Dubin held a telephone conference with Epstein. During that cal

SUSMAN GODFREY L.L.P. Stephen D. Susman 654 Madison Avenue, 5th Floor New York, New York 10065-8440 Tele hone: Fax: E-mail: Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: Fax: E-mail: Attorneys for Respondent Counter-Claimants and Third-Party

erning Jeffrey Epstein's involvement in J.P. Morgan's investment in Highbridge Capital Management, including but not limited to the introduction of Glenn Dubin to Jes Staley. Response: Respondents object because this request is overly broad, vague, burdensome, designed to harass Respondents and/or third p

ing but not limited to the introduction of Glenn Dubin to Jes Staley. Response: Respondents object bec

. Stephen D. Susman Seth Ard 654 Madison Avenue, 5th Floor New York, New York 10065-8440 Fax: (212) 336-8340 E-mail: E-mail: Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Fax: (713) 654-6666 E-mail: 7 EFTA00729276 Attorneys for Respondent Counter-Claim

ut waiving the forgoing objection, Respondents will produce responsive documents, if any, that may exist. Request No. 13: All documents concerning Glenn Dubin and/or Highbridge Capital Management (n/k1a Dubin & Swieca Asset Management, LLC) that relate to: (a) any investment by Epstein, Jeepers or FTC in

ca Asset Management, LLC) that relate to: (a) any investment by Epstein, Jeepers or FTC in the Fund; (b) any conversation between or among Epstein, Dubin and Daniel Zwirn relating to the Fund; (c) any effort by Epstein, Jeepers and/or FTC to withdraw any amount from the Fund; (d) the Fund; (e) the

Y L.L.P. Stephen D. Susman Seth Ard 654 Madison Avenue, 5'h Floor 8440 Fax: (212 336-8340 E-mail: E-mail: 10 EFTA00729268 Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Attorneys for Respondent Counter-Claimants Financial Trust Company, Inc. and Jeepers, Inc. 11 EFTA00729269

icers, employees, representatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on their behalf. 9. "Glenn Dubin" means Glenn Dubin and any entity owned or controlled by him, including without limitation Dubin & Swieca Asset Management, LLC. 9. "Document" mea

d anyone else acting on their behalf. 9. "Glenn Dubin" means Glenn Dubin and any entity owned or contro

described on Exhibit A hereto. Dated: , 2011 Hon. Anthony J. Carpinello (Ret.) Arbitrator Requested by: SUSMAN GODFREY L.L.P. Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: (713) 651-9366 Fax: (713) 654-6666 E-mail: Attorneys for Respondent Coun

rty Respondents. SUBPOENA AD TESTIFICANDUM To: Glenn Dubin Highbridge Capital Management 9 West 57th Stree

spondents. SUBPOENA AD TESTIFICANDUM To: Glenn Dubin Highbridge Capital Management 9 West 57th Stree

hearing relating to the above-referenced matter. Dated: June 2011 Hon. Anthony J. Carpinello (Ret.) Arbitrator Requested by: Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: (713) 651-9366 Fax: (713 654-6666 E-mail: Stephen D. Susman Seth Ard 5

rty Respondents. SUBPOENA AD TESTIFICANDUM To: Glenn Dubin Highbridge Capital Management 9 West 57th Stree

spondents. SUBPOENA AD TESTIFICANDUM To: Glenn Dubin Highbridge Capital Management 9 West 57th Stree

hearing relating to the above-referenced matter. Dated: June 2011 Hon. Anthony J. Carpinello (Ret.) Arbitrator Requested by: Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: (713) 651-9366 Fax: E-mail: Stephen D. Susman Seth Ard 560 Lexington A

pportunities Fund, L.P. ("Fund"), which was managed primarily by Daniel Zwim ("Zwim"). Epstein began making these investments based on the advice of Glenn Dubin, who helped start the Fund and owned a minority interest in the Fund's general partner. 1008645vI/011585 EFTA00586232 4. Between 2002 and 2005,

estment, and Zwim begged Epstein to refrain because such a redemption could cause a "run on the bank." 7. On November 13, 2006, Zwim, Epstein, and Dubin participated in a call. During the call, Zwim agreed that if Epstein would request a withdrawal of only $80 million, the Fund would honor the reque

Avenue, 5th Floor New York, New York 10065-8440 Telephone: (212) 336-8330 Fax: (212) 336-8340 E-mail: [email protected] Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: (713) 651-9366 Fax: (713) 654-6666 E-mail: [email protected] Att