Epstein Secrets

LLC, D.B. ZWIRN & CO, L.P., DBZ GP, LLC, ZWIRN HOLDINGS, LLC, and DANIEL ZWIRN, Third-Party Respondents. RESPONSES AND OBJECTIONS OF NON-PARTY GLENN DUBIN TO THE SUBPOENA DUCES TECUM DATED NOVEMBER 9,2010 Non-party Glenn Dubin ("Dubin") hereby objects and Third-Party Respondents' subpoena dated Novem

rd-Party Respondents. RESPONSES AND OBJECTIONS OF NON-PARTY GLENN DUBIN TO THE SUBPOENA DUCES TECUM DATED NOVEMBER 9,2010 Non-party Glenn Dubin ("Dubin") hereby objects and Third-Party Respondents' subpoena dated November 9 Dubin makes this response without in any way waiving any all potential o

3382. Objections to Definitions 1 Dubin objects to the Definitions to the extent that they purport to impose obligations on Dubin not required by the New York Civil Practice Law and Rules, the Federal Rules of Civil Procedure, the JAMS Comprehensive Arbitration Rules and Procedures, or any other applicable statute, rule o

AMS Comprehensive Arbitration Rules and Procedures, or any other applicable statute, rule or case law. 2. Highbridge objects to the definition of "Glenn Dubin" as vague, overbroad, and unduly burdensome, particularly insofar as it includes "any representative, agent or anyone else acting on his behalf" 5

. Highbridge objects to the definition of "Glenn Dubin" as vague, overbroad, and unduly burdensome, par

tions to Definitions I. Highbridge objects to the Definitions to the extent that they purport to impose obligations on Flighbridge not required by the New York Civil Practice Law and Rules, the Federal Rules of Civil Procedure, the JAMS Comprehensive Arbitration Rules and Procedures, or any other applicable statute, rule or

2. Dubin objects to the Subpoena to the extent that it calls for the production of information that is not "material" within the scope of 9 U.S.C. § 7, relev

tion, the definitions, instructions, and documents and things demanded) to the extent that it purports to impose obligations on him not required by the New York Civil Practice Law and Rules, the Federal Rules of Civil Procedure, the JAMS Comprehensive Arbitration Rules and Procedures, or any other applicable statute, rule or

4. Dubin objects to the definition of "Document" as vague, overbroad and unduly burdensome. 5. Dubin objects to the definition of "Person" on the ground th

nstructions 1. Dubin objects to each of the Instructions to the extent that they purport to impose any obligations that exceed the requirements of the New York Civil Practice Law and Rules, the Federal Rules of Civil Procedure, the JAMS Comprehensive Arbitration Rules and Procedures, or any other applicable statute, rule or