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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
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
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
"). 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
ake from anyone of course"; Mr. Dubin: "of course"), the e-mail transmittal note accompanying the Side Letter itself, (E-mail from Heath Weisberg to Harry Beller, Ex. B at I) ("Attached please find the side note relating to [FTC's] January I, 2005 investment in [the Fund]."), as well as the testimony of Fund
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
Entities connected to both Harry Beller and Zwirn Holdings LLC

Jeffrey Epstein
PERSON
JPMorgan Chase
ORGANIZATION
Financial Trust Company
ORGANIZATIONLeon Black
PERSON
Prince Andrew
PERSON
United States
LOCATION
Glenn Dubin
PERSON
Lawrence Krauss
PERSONZwirn
PERSONPerry Gruss
PERSONHighbridge
ORGANIZATIONDavid Lee
PERSONHubsher
PERSONAnthony J. Carpinello
PERSONSchulte
PERSONCounter-Claimants
ORGANIZATION
Pittsburgh
LOCATIONWilliam O'Brien
PERSONDBZ GP LLC
ORGANIZATIONDel. Ch
PERSON