Epstein Secrets

tanding, based on subsequent conversations with Epstein, that after this conversation, Epstein made a written request for that partial redemption of Financial Trust Company, Inc.'s capital account in the Zwim Fund and that Zwirn refused to honor this request. Glenn Dubin Sworn to before me this 3 bile ay of February, 2010.

Subsequently, I participated in a three-way call with both Zwim and Epstein. During this call, Epstein demanded from. Zwim the withdrawal of all of Financial Trust EFTA00727333 Company, Inc.'s capital account in the Zwirn Fund. Epstein said he wanted to redeem all of Financial Trust Company, Inc.'s 140 plus

clude terms in the present tense. DOCUMENT REQUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

. 4. All documents concerning the alleged conversations described in 6, 7 and 8 of the Affidavit. 5. All documents concerning the assignment of Financial Trust Company, Inc.'s limited partnership interests in the Fund to Jeepers, Inc. 6. All documents concerning any request by any of the Third-Party Claimants to withdra

Subsequently, I participated in a three-way call with both Zwirn and Epstein. During this call, Epstein demanded from Zwirn the withdrawal of all or Financial Trust EFTA00727343 Company, Inc.'s capital account in the Zwim Fund. Epstein said he wanted to redeem all of Financial Trust Company, Inc.'s 140 plus m

clude terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

4. All documents concerning the alleged conversations described in ¶¶ 6, 7 and 8 of the Affidavit. 5. All documents concerning the assignment of Financial Trust Company, Inc.'s limited partnership interests in the Fund to Jeepers, Inc. 6. All documents concerning any request by any of the Third Party Claimants to withdra

ense include terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communications between You on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communications between You on the one hand, and any of

bjections, Dubin will undertake a reasonable search for and produce responsive documents. Request No.5: All documents concerning the assignment of Financial Trust Company, Inc.'s limited partnership interests in the Fund to Jeepers, Inc. Response to Request No.5: Dubin objects to this Request on the grounds that it is overly

Instruction 2. SPECIFIC RESPONSES AND OBJECTIONS Request No.1: All documents concerning any communication between You on the one hand, and any of the Zwirn Parties on the other, concerning any of the ThirdParty Claimants. Response to Request No.1: Dubin objects to this Request on the grounds that it is overl

ions, Highbridge will undertake a reasonable search for and produce responsive documents. Request No.5: All documents concerning the assignment of Financial Trust Company, Inc.'s limited partnership interests in the Fund to Jeepers, Inc. Response to Request No.5: Highbridge objects to this Request on the grounds that it is o

tion 2. SPECIFIC RESPONSES AND OBJECTIONS Request No.1: All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. Highbridge objects to the definition of "All" and "each" as vague, 6 EFTA01592057 R

stein Released Parties" as used in the OPERATIVE RELEASE LANGUAGE above is as follows: The Epstein Parties means Jeffrey Epstein, Jeepers, Inc. and Financial Trust Company, Inc. The Epstein Released Parties means "the Epstein Parties and each of their past, present and future parents, subsidiaries and other affiliates, each

have at any time acted, or purported to act on behalf of any of the foregoing (the "Dubin Released Parties," except that, for the sake of clarity, the Zwirn Parties and any individuals or entities that are directly or indirectly controlled by one or more of the Zwirn Parties, shall not be considered Dubin Relea

I LLC ("VRF I LLC") and Fortress Value Recovery Fund I LLC (the "Fund") (together, "Claimants"); (ii) Jeffrey Epstein, Jeepers, Inc. ("Jeepers") and Financial Trust Company, Inc. ("FTC") (collectively, the "Epstein Parties"); (iii) D.B. Zwim Partners, LLC, D.B. Zwim & Co., L.P., DBZ GP, LLC and Zwim Holdings, LLC (collectivel

arties now manage or formerly managed, and any fund or account now or formerly managed by Claimant Fortress VRF I LLC or its affiliates; and (2) the Zwirn Parties and each of their past, present and future parents, subsidiaries and other affiliates, each of the predecessors, successors, heirs and assigns of e