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

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-Respondent and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO.

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

C., Respondent § Case No. 1425006537 and FINANCIAL TRUST COMPANY, INC. and § JEEPERS, INC., Counterclaimants and Third-Party Claimants § v. D.B. ZWIRN SPECIAL OPPORTUNITIES § FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO.

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

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

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

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

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

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

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

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. 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)

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. ZWIRN PARTNERS, LLC, D.B. ZWIRN & Co.,

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

JAMS ARBITRATION IN THE MATTER OF FINANCIAL TRUST COMPANY, INC., JEEPERS, INC., v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO., L.P. ZWIRN HOLDINGS, LLC,