Epstein Secrets

ACCONE T. ROBERT ZOCHOWSKI. JR. Dear Judge Carpinello: Attached you should find: (1) a hard copy of Claimants' Memorandum of Law in Opposition to Financial Trust Company, Inc.'s and Jeepers, Inc.'s Motion In Limine "To Exclude Extrinsic Evidence"; (2) a binder of exhibits cited in the memorandum; and (3) a binder of cases c

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

N NEW YORK, NEW YORK 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., Counter-Claimants and Third-Party Claimants v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FU

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

("Addt'l Jan 1 $20mm FTC is subject to 2 yr lock not 3 yr"); see also Exhibit F at HCMARB_00000155 ("Attached please find the side note relating to Financial Trust Company, Inc.'s January 1, 2005 investment in D.B. Zwim Special Opportunities Fund, LP") (emphasis added).) There are two additional problems with Jeepers's curren

"). 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