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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
mpany, Inc., and Jeepers, Inc. (collectively "Epstein") in connection with claims regarding an investment in D.B. Zwirn Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC. I am writing in an effort to avoid litigation by settling this dispute. I037032vI/011585 EFTA00722243 Brad Karp Alan Levine John S. Siffert
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
mpany, Inc., and Jeepers, Inc. (collectively "Epstein") in connection with claims regarding an investment in D.B. Zwirn Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC. I am writing in an effort to avoid litigation by settling this dispute. I037032vI/011585 EFTA00587244 Brad Karp Alan Levine John S. Siffert
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.").
tion in limine "to exclude extrinsic evidence EFTA00614000 related to the breach of contract claims against D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC ((the) "Fund"), [and] D.B. Zwim Partners, LLC, D.B. Zwim & Co. L.P., DBZ GP LLC, Zwirn Holdings LLC, and Daniel Zwirn [together, the "Zwim Parties"
Entities connected to both Glenn Dubin and L.P. k/n/a Fortress Value Recovery Fund I LLC

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
Stephen Hawking
PERSON
Financial Trust Company
ORGANIZATION
Dallas
LOCATIONJeepers, Inc.
ORGANIZATION
Seattle
LOCATIONWeiss
PERSOND.B. Zwirn
ORGANIZATIONStephen D. Susman
PERSON
Brad S. Karp
PERSOND.B. Zwim
PERSONJohn S. Siffert
PERSONRifkind
PERSONLankier Siffert & Wohl LLP
ORGANIZATIONAlan Levine
PERSONthe Fortress/Fund
ORGANIZATION