Epstein Secrets

irn explained that FTC's investments were subject to two-year rolling lock-ups. Mr. Zwim then informed Mr. Dubin by email that he had spoken to Mr. Beller about "the facts of lock-ups." Mr. Zwim and Mr. Lee, then DBZ's Acting CFO, obtained and reviewed redemption schedules from DBZ's Investor Relation

aw all of FTC's investments during these conversations; in fact, he did not. II EFTA00613918 H. FTC's Liquidation Demand On November 13, 2006, Harry Beller, an accountant at FTC, called Mr. Zwim. They discussed when FTC's investments could be redeemed. Mr. Zwirn explained that FTC's investments were su

ee. He delegated management of the back office and day-to-day operations to other senior officers who were experienced in those areas, including Mr. Gruss. The financing sources included cash on the funds' balance sheets; interest and principal received from existing loans; proceeds from sales of asse

exhibits and meeting with front-office professionals to discuss available opportunities. Mr. Zwim met regularly with DBZ's Chief Financial Officer, Perry Gruss, and other members of the treasury group to discuss the financing of potential investments. Mr. Zwim adjusted the size and timing of investments bas

equent correspondence to the Fund. Jeepers's current version of events also relies upon inconsistent and unreliable testimony from Mr. Epstein, Mr. Beller, and Mr. Dubin. At his deposition, Mr. Epstein testified both that he expected to be paid "immediately" after making his request and that he expect

d above, e-mails from the same day the of the November 13, 2006 fax clearly indicate that the Fund explained the lock-up schedule to Mr. Epstein and Harry Beller, Mr. Epstein's accountant, who sent the withdrawal request. (See Exhibit J at HCMARB_00000049; Exhibit K at HCMARB_00000052.) Jeepers has offered n

stigation was apparently completed in mid-September 2006. Thereafter, in early October 2006, the Fund parted ways with its Chief Financial Officer, Perry Gruss. Mr. Zwim, using a script Schulte had approved, immediately called investors (including Mr. Epstein) to inform them of Mr. Gruss's departure (though

ial Officer, Perry Gruss. Mr. Zwim, using a script Schulte had approved, immediately called investors (including Mr. Epstein) to inform them of Mr. Gruss's departure (though he did not tell them the specific nature of the two accounting improprieties). Very shortly thereafter, a third accounting impr

e Fund on the March 31, 2007 withdrawal date. 26. After FTC submitted its notice of withdrawal, and well before the November 30, 2006 cutoff date, Harry Beller, an FTC representative, spoke with David Lee, D.B. Zwim's new CFO. During that conversation, Mr. Lee informed Mr. Beller that D.B. Zwim would not ho

0, 2006 cutoff date, Harry Beller, an FTC representative, spoke with David Lee, D.B. Zwim's new CFO. During that conversation, Mr. Lee informed Mr. Beller that D.B. Zwim would not honor the notice of withdrawal because, according to Mr. Lee, FTC had no withdrawal rights at that time. Mr. Lee informed

Daniel Zwim, the Managing Principal of D.B. Zwim. Mr. Zwim informed Mr. Epstein that D.B. Zwirn was terminating the Fund's chief financial officer, Perry Gruss, but stated that there was "nothing wrong" at the Fund. When Mr. Epstein asked for a more detailed explanation, Mr. Zwim indicated that the CFO had

Mr. Zwirn that he wanted to withdraw all of FTC's money from the Fund. 19. In October 2006, D.B. Zwim officially announced the resignation of Mr. Gruss as CFO of the Fund. D.B. Zwim, however, continued to conceal the reasons for Mr. Gruss's departure. In its 2006 Third Quarter Investor Commentary,

I've read it. 03:08:28 16 Q. Do you recognize it? 17 A. No, sir. 18 Q. Did you sign it? 19 A. It appears so. 20 Q. Could that be Mr. Beller signing for 03:08:37 21 you? 22 A. It could be. 23 Q. If you signed it, would you have read 24 it? 25 A. Not necessarily. 03:08:47 VE

hs. 25 Q. Who was present? 03:14:49 VERITEXT REPORTING COMPANY www.veritext.com EFTA00299294 Page 211 1 Epstein 2 A. I believe just Mr. Gruss and me. 3 Q. Who set up the meeting? 4 A. I did. 5 Q. How? 03:15:05 6 A. I called him. 7 Q. And asked if he would meet with you? 8

ate a bunch of 18 conversations, it was all the fact that Dan Zwirn 19 was a crook. 20 Q. Did you ever have a conversation with 03:14:36 21 Perry Gruss? 22 A. Yes. 23 Q. When was that? 24 A. In the past two months. 25 Q. Who was present? 03:14:49 VERITEXT REPORTING COMPANY www.veritext

s well as our best guess of when the witnesses will be called: Dan Zwirn--Friday, July 22 Jeffrey Epstein--Monday, July 25 Perry Gruss--Monday-PM Harry Beller--Tuesday, July 26 Glenn Dubin--Tuesday Darren Indyke--Wednesday, July 27 Dan Stachman (rebuttal expert, subject to motion in limine)--Wednesday H

s "real" witness list as well as our best guess of when the witnesses will be called: Dan Zwirn--Friday, July 22 Jeffrey Epstein--Monday, July 25 Perry Gruss--Monday-PM Harry Beller--Tuesday, July 26 Glenn Dubin--Tuesday Darren Indyke--Wednesday, July 27 Dan Stachman (rebuttal expert, subject to motion

ister)/ to what happened on November 13. Here's what the evidence will show. Mr. Epstein was clearly agitated , he wanted to get his money out. Mr. Beller is instructed to make a written demand on the Fund. Dan Zwirn claims that in response, he talked to Beller and explained to him that FTC had no rig

is. The evidence will show that Jeffrey Epstein clearly wanted to get his money out of the Fund in November 2006. When Mr. Epstein heard about Mr. Gruss's departure, he immediately was suspicious and demanded to withdraw his entire capital account. Mr. Zwirn's reluctance to provide details and insi

ank which Jeffrey's withdrawal would precipitate. • November 13, 2006 email from Zwirn to Dubin advising that Zwirn spoke as calmly as possible to Harry Beller about lock-up facts and stating that it would be very good for you to call Jeffrey. • November 13, 2006 email from Zwirn to Dubin that Dubin shoul

volving oversight of sub-advisor DB Zwirn beginning in the Fall 2006." • September 24, 2006 Zwirn calls Jeffrey to advise that he is going to fire Gruss but it is not for material reasons. Jeffrey advises that he wants to redeem FTC's entire investment. • Sepetember 30, 2006. Gruss is fired. • O

y. 3 Q. Did you know at or about the time that 4 it went out that it had actually been sent? 5 A. No. 02:05:27 6 Q. Is that something Mr. Beller would have 7 told you: We made the redemption request? 8 A. I would have said, after the telephone 9 call with Dan and Glenn: Make sure I get

126 1 Epstein 2 A. Yes. 3 Q. He lied to you about the airplane? 4 A. He lied that the things that he 5 represented were the reasons that Gruss were fired 11:45:55 6 were strictly immaterial. He said the phrase that 7 it was immaterial was a lie. 8 Q. Anything else you recall him using