Epstein Secrets

epresentatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on its behalf. 5. "You" and "Your means Glenn Dubin and any representative, agent or anyone else acting on your behalf. 6. "Third-Party Claim" means Jeepers, Inc.'s Response and Financial Trust Com

ty Respondents. SUBPOENA DUCES TECUM To: Glenn Dubin Highbridge Capital Management 9 West 57th Stree

ense include terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communications between You on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communications between You on the one hand, and any of

fficers, employees, representatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on its behalf. 5. "Glenn Dubin" means Glenn Dubin and any representative, agent or anyone else acting on his behalf. 6. "Third-Party Claim" means Jeepers, Inc.'s Response and Fi

and anyone else acting on its behalf. 5. "Glenn Dubin" means Glenn Dubin and any representative, agent

clude terms in the present tense. DOCUMENT REQUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

fficers, employees, representatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on its behalf. 5. "Glenn Dubin" means Glenn Dubin and any representative, agent or anyone else acting on his behalf. 6. "Third-Party Claim" means Jeepers, Inc.'s Response and Fi

and anyone else acting on its behalf. 5. "Glenn Dubin" means Glenn Dubin and any representative, agent

clude terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

2 Highbridge objects to the definition of "Glenn Dubin" as vague, overbroad, and unduly burdensome, par

ce the information requested in Instruction 2. SPECIFIC RESPONSES AND OBJECTIONS Request No.1: All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. Highbridge objects to the definition of "

tion 2. SPECIFIC RESPONSES AND OBJECTIONS Request No.1: All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. Highbridge objects to the definition of "All" and "each" as vague, 6 EFTA01592057 R

LLC, D.B. ZWIRN & CO, L.P., DBZ GP, LLC, ZWIRN HOLDINGS, LLC, and DANIEL ZWIRN, Third-Party Respondents. RESPONSES AND OBJECTIONS OF NON-PARTY GLENN DUBIN TO THE SUBPOENA DUCES TECUM DATED NOVEMBER 9,2010 Non-party Glenn Dubin ("Dubin") hereby objects and Third-Party Respondents' subpoena dated Novem

rd-Party Respondents. RESPONSES AND OBJECTIONS OF NON-PARTY GLENN DUBIN TO THE SUBPOENA DUCES TECUM DATED NOVEMBER 9,2010 Non-party Glenn Dubin ("Dubin") hereby objects and Third-Party Respondents' subpoena dated November 9 Dubin makes this response without in any way waiving any all potential o

Instruction 2. SPECIFIC RESPONSES AND OBJECTIONS Request No.1: All documents concerning any communication between You on the one hand, and any of the Zwirn Parties on the other, concerning any of the ThirdParty Claimants. Response to Request No.1: Dubin objects to this Request on the grounds that it is overl

documents relating to the Fund or Third-Party Claimants' investments in the Fund. Request No. 2: All documents concerning any communication between Glenn Dubin on the one hand, and any of the Third-Party Claimants on the other, concerning any of the Zwirn Parties, the Claimants or the Fund. Response to Req

ments concerning any communication between Glenn Dubin on the one hand, and any of the Third-Party Claim

ll documents concerning any communication between Glenn Dubin on the one hand, and any of the Third-Party Claimants on the other, concerning any of the Zwirn Parties, the Claimants or the Fund. Response to Request No. 2: Highbridge objects to this Request on the grounds that it is overly broad, unduly burdensom

hich was incorporated into the record at the Arbitration hearing, you agreed that: "The Epstein Parties will also provide full, general releases to Glenn Dubin and the Zwirn Parties, including standard language as to affiliates and other persons (except as to any claims for breach of this Settlement Agreem

uld be raised in the Arbitration (notwithstanding the fact that the term sheet says that the Epstein Parties will provide full, general releases to Dubin). First Windels and then Condren advised that Dubin, Highbridge, JPM wanted a much broader general release consistent with what they understood to b

have at any time acted, or purported to act on behalf of any of the foregoing (the "Dubin Released Parties," except that, for the sake of clarity, the Zwirn Parties and any individuals or entities that are directly or indirectly controlled by one or more of the Zwirn Parties, shall not be considered Dubin Relea

e Zwirn Parties, and this version incorporates some, but not all, of their proposed changes. We have not yet received comments from counsel for Mr. Dubin. EFTA00429181 If you have any comments or wish to discuss, please let us know. Best, Hannah Hannah Sholl I Associate Paul, Weiss, Rifkind, Wha

reement and a blackline comparing this version to the initial version we circulated on August 5. We reviewed the comments provided by Mr. Indyke and the Zwirn Parties, and this version incorporates some, but not all, of their proposed changes. We have not yet received comments from counsel for Mr. Dubin. EFTA004