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

tfully submitted, 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-Cla

the Fund and FTC—Le., the "2005 Side Agreement" described in paragraph 33 of the Demand. 7. All communications, including without limitation with Glenn Dubin, relating to Counterclaimants' efforts to withdraw money from the Fund. 8. All documents that reflect telephone calls between or among any of Zwim

26. All documents concerning payments from the Fund, any of the Zwim Entities, or Zwim to Glenn Dubin or any entity owned or controlled in part by Dubin, including without limitation Dubin & Sweica Capital Management, from 2006 to the present, including payments made in settlement of any disputes an

SUSMAN GODFREY L.L.P. Stephen D. Susman Seth Ard 654 Madison Avenue, 5th Floor New York, New York 10065-8440 Telephone: Fax: E-mail: E-mail: Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: Fax: E-mai : Attorneys for Respondent Counterclai

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

MAN GODFREY L.L.P. 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 R

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

d, SUSMAN GODFREY 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, In

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

CE DOCUMENTS as 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: Attorn

rom Entrust 8/27/2004 DBZCOPR-00541659 315 D.B. Zwirn & Co, L.P. Presentation 9/2004 DBZCO_FTC 0025303 - 0025329 316 E-mail to Dan Zwirn from Glenn Dubin re Investor Calls 11/15/2004 DBZCO_FTC 0008646 2 EFTA00614026 Exhibit Description Date Bates 317 E-mail to Dan Zwirn from Glenn Dubin re

03 - 0025329 316 E-mail to Dan Zwirn from Glenn Dubin re Investor Calls 11/15/2004 DBZCO_FTC 0008646

E 185.10) 5028.5300 12TH 1.10011. HONG 140040 CLUB BUILDING CHATER ROAD. CENTRAL HONE KONG TELEPHONE 4552) 284.0300 By E-mail and Hand Delivery Harry P. Susman, Esq. Susman Godfre LLP ALDER CASTLE 80 MOINE STREET LONDON [CAT MA. V.R. TELEPHONE 144 20) 7347 1800 fiJKOKU SEINE, BUILDING 24 UCHISADVAICHO

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

ve testimony at a 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

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

ve testimony at a 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 Se

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

man 654 Madison 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: hsusman