Epstein Secrets

objection, Respondents will produce responsive documents, if any, that may exist. 9. All documents and communications concerning the assignment of Financial Trust Company, Inc. `s limited partnership interests in the Fund to Jeepers, Inc. Response: Respondents object because this request is overly broad and vague. Subject to

d without waiving the forgoing objection, Respondents will produce responsive documents, if any, that may exist. 3. All communications with any of the Zwirn Entities. Response: Respondents object because this request is overly broad, vague, unduly burdensome, designed to harass Respondents and/or third parties,

JAMS ARBITRATION IN THE MATTER OF FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counterclaimants and Third-Party Claimants v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND

d in Epstein's Claim. 8. All documents concerning the repayment of advances made from the Highbridge Managed Account to other funds controlled by the Zwirn Entities, including without limitation any documentation of such advances, any promissory notes, documentation of whether such funds were repaid, and any di

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

Suite 5100 1000 Louisiana Houston, TX 77002-5096 3. All notices to the Zwim Entities with respect to this Settlement Agreement shall be sent to the Zwirn Entities at and in care of: 12 EFTA00298492 CONFIDENTIAL William O'Brien Cooley LLP The Grace Building 1114 Avenue of the Americas New York, NY 10036