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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
ents concerning: (a) any limited partnership agreement or other organizational document, or any other agreement, with respect to the Fund; (b) any Confidential Memorandum, offering document or other disclosure or subscription document relating to the Fund; (c) the November 17,2004 Supplement to the Confidential Memor
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
d normally decline substantially, resulting in a so-called "fire sale." None of this was a secret to the Funds' investors. For example, a May 2003 Confidential Memorandum circulated in connection with an offering of the Fund expressly noted that: "substantial requests for withdrawals by limited partners could induce t
To: [email protected][[email protected]]; Jeffrey [email protected]] From: Dubin, Glenn Sent: Wed 8/31/2011 7:22:27 PM Subject: FW: DZ Distributions From: McHale Stuart, Tracy [mailtcl. Sent: Wednesday, August 31, 2011 :55 PM
in the fund. The runes fees and expenses may offset the tunes trading profits. Prospective investors should review the risks described in the fund's Confidential Memorandum. This email and any attachments hereto do not constitute an offer to sell, or a solicitation of an offer to buy, any interest in any investment vehi
Entities connected to both Glenn Dubin and Confidential Memorandum

Jeffrey Epstein
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
New York
LOCATION
Samantha Power
PERSON
JPMorgan Chase
ORGANIZATION
Financial Trust Company
ORGANIZATIONZwirn
PERSON
Wilbur Ross
PERSON
United Kingdom
LOCATIONJane Doe
PERSON
Dallas
LOCATION
Michigan
LOCATION
Tokyo
LOCATION
New York State
LOCATION
Louisiana
LOCATIONthe State of New York
LOCATION
Detroit
LOCATION