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

RTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., Respondent § Case No. and FINANCIAL TRUST COMPANY, INC. and § JEEPERS, INC., Counter-Claimants and Third-Party Claimants § v. § Arbitrator: D.B. ZWIRN SPECIAL OPPORTUNITIES § FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, Counter-R

of Facts 2 A. Mr. Zwirn's Personal Background 2 B. DBZ Background 2 I. DBZ's Investment Strategy 3 2. Mr. Zwirn's Role at DBZ 3 3. Mr. Dubin's Involvement with DBZ 4 4. DBZ's Lock-Ups 4 C. Mr. Epstein's Relationship with Mr. Dubin 6 D. FTC's Investments in the Fund 7 E. Account

ers. In 2000, Michael Dell's investment firm hired Mr. Zwim to start and serve as the portfolio manager of its Special Opportunities Group. In 2001, Glenn Dubin, the co-founder of Highbridge Capital Management ("Highbridge"), recruited Mr. Zwim to serve as a managing director and the senior portfolio manage

RF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counter-Claimants and Third-Party Claimants v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LW, Counter-Respondent and D.B.

nd no reason why Mr. Zwirn would have entertained such an agreement. According to Mr. Epstein, in phone calls with Mr. Zwirn and, separately, with Glenn Dubin, the source of Mr. Epstein's original introduction to Mr. Zwirn and a co- owner of the Fund's General Partner through an entity called Dubin & Swieca

all the money he had in the Fund. These communications allegedly culminated in a November 13 conference call among Mr. Epstein, Mr. Zwirn, and Mr. Dubin, in which Mr. Zwirn, worried that a complete withdrawal by Mr. Epstein would precipitate a "run on the bank," allegedly promised Mr. Epstein that t

RF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counter-Claimants and Third-Party Claimants v. FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO., LP, DBZ

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

RF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counter-Claimants and Third-Party Claimants v. FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO., LP, DBZ

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 "

RECOVERY FUND I LLC, Claimants, - against - JEEPERS, INC., Respondent. Ref. No.: 1425006537 FINANCIAL TRUST COMPANY, INC., and JEEPERS, INC., Counter-Claimants and Third-Party Claimants, - againstFORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent, and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO, L.P

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

UE RECOVERY FUND I LLC, Claimants, - againstJEEPERS, INC., Respondent. Ref. No.: 1425006537 FINANCIAL TRUST COMPANY, INC , and JEEPERS, INC., Counter-Claimants and Third-Party Claimants, - against - FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent, and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO, L

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 responds as follows to Third-Party Responden

ty 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 responds as follows to Third-Party Respondents' subpoena dated November 9, 2010 (the "Subpoena"). Dubin makes this response wi

UE RECOVERY FUND I LLC, Claimants, -against- JEEPERS, INC., Respondent. Ref. No.: 1425006537 FINANCIAL TRUST COMPANY, INC., and JEEPERS, INC., Counter-Claimants and Third-Party Claimants, - against - FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent, and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO, L

incipal of leepers, Inc.) Daniel B. Zwim (individually and principal of D.B. Zwirn Special Opportunities Fund, L.P. and related Zwirn entities) Glenn Dubin Harry Beller David Lee (non-party witnesses) -second deposed- -third deposed- 3. The dates contained in Scheduling order No. I regarding Exchange

s Fund, L.P. and related Zwirn entities) Glenn Dubin Harry Beller David Lee (non-party witnesses)

RF 1 LLC and FORTRESS VALUE RECOVERY FUND 1 LLC, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counter-Claimants and Third-Party Claimants v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a/ FORTRESS VALUE RECOVERY FUND 1 LLC, Counter-Respondent and D.B

uld only "take it or leave it," Mr. Epstein had significant bargaining power in his dealings with the Fund. (See, e.g., E-mail from Mr. Zwim to Mr. Dubin, Ex. I ("We have done back flips for Jeffrey [Epstein] and, as a large, early and important investor, will continue to do so at his convenience.").

F I LLC and. FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counter-Claimants and Third-Party Claimants v. FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO., LP, DBZ