Epstein Secrets

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

LLC was DBZ's General Partner. Third-Party Respondent Zwim Holdings LLC was a member of DBZ GP LLC and D.B. Zwim Partners, LLC. Under Delaware law„ Zwirn Holdings LLC cannot be held liable solely on the basis of its membership in the limited liability companies. 6 Del. C. § 18-303; see also Thomas v. Hobbs, 2005 W

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

"). Third-Party Respondent DBZ GP LLC was the general partner of the Investment Manager (the "Zwirn Investment Manager GP"). Third- Party Respondent Zwirn Holdings LLC was a holding company that held interests in the 4 EFTA00613948 Zwirn Fund GP and the Zwirn Investment Manager GP. Third-Party Respondent Daniel

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.").

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")." (Financial Trust Company, Inc.'s and Jeepers Inc.'s Motion In Limine to Exclude Extrinsic Eviden