Epstein Secrets

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

nagers, managing members, employees, directors, representatives, agents, officers, consultants, attorneys, predecessors, successors or affiliates of D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, including without limitation the Zwirn Entities. 8. The term "Zwirn En

Inc., including Jeffrey Epstein. I205876vI/011585 2 EFTA00722310 Timestamp: 8/16/2010 5:38 PM CDT 7. The term "Fund" or "On-Shore Fund" means D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC. The term includes past and/or present general partners, managers, managi

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

of the Fund. The assignment was made retroactively effective January 1, 2006. Counterclaim and Third-Party Respondents 16. Counterclaim Respondent D.B. Zwim Special Opportunities Fund, L.P. kinia Fortress Value Recovery Fund I LLC was a limited partnership formed under the laws of the State of Delaware.

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

k, NY 10036 Suite 3800 1x01 Third Avenue Seattle, WaShingtongazoa-3000 Re: Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein vs. D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, et. al. Dear Sirs: As you are aware, I represent Jeffrey Epstein, Finan

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

rk, NY 10019 Suite 3800 12os Third Avenue Seattle,. Wa ' ton loa-3000 Re: Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein vs. D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, et. al. Dear Brad: I am writing in an effort to move our settlement dia

ave against Daniel Zwim, D.B. Zwim Special Opportunities Fund, L.P. ("Fund"), D.B. Zwirn Partners, LLC, D.B. Zwim & Co., L.P., Zwirn Holdings, LLC, Glenn Dubin, Highbridge Capital Management, Dubin & Swieca Asset Management, and any of their successors or predecessors in interest for damages arising out of

.B. Zwim & Co., L.P., Zwirn Holdings, LLC, Glenn Dubin, Highbridge Capital Management, Dubin & Swieca A

t Financial Trust Company, Inc., Jeepers, Inc., and Jeffrey Epstein ("Client" or "you") in connection with all claims you have against Daniel Zwim, D.B. Zwim Special Opportunities Fund, L.P. ("Fund"), D.B. Zwirn Partners, LLC, D.B. Zwim & Co., L.P., Zwirn Holdings, LLC, Glenn Dubin, Highbridge Capital Ma

.4 2. Potential Claims Against Glenn Dubin and Highbridge Capital You have also asked us to examine what claims, if any, Jeepers might have against Glenn Dubin and/or Highbridge based upon representations made by Dubin that Jeepers should not withdraw its complete investment from the Fund. A threshold quest

f the claims Jeepers might have against the Fund. Section Two of this memorandum addresses any claims that Jeepers might have against Glenn Dubin ("Dubin") or Highbridge Capital ("Highbridge"), including the extent to which Dubin or Highbridge are covered by the terms of the Settlement Agreement and

. Epstein CC: Darren K. Indyke FROM: Jay P. Lefkowitz, P.C. Eric F. Leon David S. Flugman DATE: August 7, 2009 RE: Potential Claims against D.B. Zwim, Glenn Dubin, and/or Highbridge Capital You have asked us to examine potential claims against D.B. Zwim, Glenn Dubin, and/or Highbridge Capital in

2010) Schedule of Contributions by FTC (Missing as of Jan. 28, 2010) Fortress Letter Dec. 3, 2009 Jeepers' Cancellation Declaration Affidavit of Glen Dubin re Zwirn (Original and Faxed Copy) Fortress VRF Advisors I LLC, Net Asset Values July— Nov. 2009 Fortress Investment Group, Form ADV Part II, Unifo

roll of Davis Polk (Missing as of Jan. 28, 2010) Dubin Memo to DKI re: Zwirn Liquidity (Missing as of Ja

11. Jeepers Inc. Transactions I. D.B. Zwim Special Opportunities Fund f/k/a/Highbridge/Zwim Special Opportunities Fund I ( ASSIGNED FROM FTC) 2. D.B. Zwim Special Opportunities Fund f/k/a/Highbridge/Zwim Special Opportunities Fund II( ASSIGNED FROM FTC) 3. DB Zwim Special Opportunities Funds Investor

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

ancial Trust Company, Inc. ("FTC") and Jeepers, Inc. ("Jeepers") (collectively, "Claimants"), submit the following statement of their claims against D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, D.B. Zwim Partners, LLC, Zwim Holdings, LLC, D.B. Zwim & Co., L.P., and

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

LLP The Grace Building 1114 Avenue of the Americas New York, NY 10036 Re: Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein vs. D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, et. al. Dear Sirs: As you are aware, I represent Jeffrey Epstein, Finan

or previously granted both parties the right to take such pre-hearing testimony of third- I57I529vI/011585 EFTA00585338 party witnesses (e.g., Mr. Dubin and Mr. Gruss), although the Zwim Parties and FTC subsequently elected to pass on the opportunity (preferring instead to call these witnesses to the

for July 22-29 in order to hear the testimony of Chris Suan, who was a former partner with Dan Zwim in the management company and general partner of D.B. Zwim Special Opportunities Fund, L.P. The parties have discussed this issue with Your Honor previously, but the issue was tabled so that the parties cou