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

UE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., 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

y P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: Fax: E-mai : Attorneys for Respondent Counterclaimants and Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc. 1205876v1/011585 19 EFTA00722327 Timestamp: 8/16/2010 5:38 PM COT P

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

RF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, 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.

L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: (713) 651-9366 Fax: (713) 654-6666 E-mail: Attorneys for Respondent Counterclaimants and Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc. EFTA00791898 JAMS ARBITRATION IN THE MATTER OF FORTRESS VRF I LLC and

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

RF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, 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.

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

RF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, 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.

rty Respondents. SUBPOENA AD TESTIFICANDUM To: Glenn Dubin Highbridge Capital Management 9 West 57th Stree

spondents. SUBPOENA AD TESTIFICANDUM To: Glenn Dubin Highbridge Capital Management 9 West 57th Stree

an Seth Ard 560 Lexington Ave, 15th Floor New York, New York 10022 Telephone: (212) 336-8330 Fax: (2 E-mail: E-mail: Attorneys for Respondent Counterclaimants and Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc. EFTA00585949

rty Respondents. SUBPOENA AD TESTIFICANDUM To: Glenn Dubin Highbridge Capital Management 9 West 57th Stree

spondents. SUBPOENA AD TESTIFICANDUM To: Glenn Dubin Highbridge Capital Management 9 West 57th Stree

560 Lexington Ave, 15th Floor New York, New York 10022 Telephone: (212) 336-8330 Fax: (212) 336-8340 E-mail: E-mail: Attorneys for Respondent Counterclaimants and Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc. EFTA00585951