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

osts of this proceeding. 1043197v1/011585 18 EFTA00722267 Dated: New York, New York May 2010 Respectfully 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 Stre

ng to settle the dispute for $140 million plus $35 million in prejudgment interest. To help you evaluate our claims, I have enclosed an affidavit of Glenn Dubin. Second, to avoid the need for Epstein to file litigation immediately, we propose that the parties enter into a tolling agreement. I have taken the

our claims, I have enclosed an affidavit of Glenn Dubin. Second, to avoid the need for Epstein to file l

o later than May 3, 2010. With regard to our settlement demand, please give me your response by no later than May 15, 2010. Thank you. Sincerely, Stephen D. Susman Enclosures cc: Jeffrey Epstein I037032vI/011585 EFTA00722244 Brad Karp Alan Levine John S. Siffert April 23, 2010 Page 3 bcc: Darren Indy

e cost of litigation. To help you evaluate our claims, I EFTA00722240 Brad Karp Paul Weiss April 22, 2010 Page 2 have enclosed an affidavit of Glenn Dubin. This affidavit should be treated as confidential under the terms of our March 26, 2010 letter agreement. We are willing to entertain further negot

2010 Page 2 have enclosed an affidavit of Glenn Dubin. This affidavit should be treated as confidential

limited liability partnership 5TH FLOOR 6S4 MADISON AVENUE NEW YORK, NEW YORK 10065-8404 Suite sop woo LOuiSiana Street Houston Texas oo2.5o95 Stephen D. Susman Direct Dia April 22, 2010 FAX Suite 5100 gel Main Street Dallas Texas 202- Suite 950 ism Avenue of the Stars Los Mg California 67.60ag Di

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

cations between the Firm and any public relations firm. Dated: New York, New York August 17, 2010 Respectfully submitted, 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.

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

s designed to harass Respondents and/or third-parties. Dated: New York, New York September 2010 Respectfully submitted, SUSMAN 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

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

produce responsive documents, if any, that may exist. Dated: New York, New York September 2010 Respectfully submitted, 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

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

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 560 Lexington Ave, 15th Floor New York, New York 10022 Telephone: (212) 336-8330 Fax: (2 E-mail: E-mail: Attorneys for Respondent Co

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

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 Ave, 15th Floor New York, New York 10022 Telephone: (212) 336-8330 Fax: (212) 336-8340 E-mail: E-mail: Attorneys for R

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

with the attorneys' fees and costs of this proceeding. Dated: New York, New York February 2010 Respectfully submitted, SUSMAN GODFREY L.L.P. Stephen D. Susman 654 Madison Avenue, 5th Floor New York, New York 10065-8440 Telephone: (212) 336-8330 Fax: (212) 336-8340 E-mail: [email protected] Har

ng to settle the dispute for $140 million plus $35 million in prejudgment interest. To help you evaluate our claims, I have enclosed an affidavit of Glenn Dubin. Second, to avoid the need for Epstein to file litigation immediately, we propose that the parties enter into a tolling agreement. I have taken the

our claims, I have enclosed an affidavit of Glenn Dubin. Second, to avoid the need for Epstein to file l

o later than May 3, 2010. With regard to our settlement demand, please give me your response by no later than May 15, 2010. Thank you. Sincerely, Stephen D. Susman Enclosures cc: Jeffrey Epstein I037032vI/011585 EFTA00587245 Brad Karp Alan Levine John S. Siffert April 23, 2010 Page 3 bcc: Darren Indy