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

ubscription agreement and to execute the Fund's LPA. Each time, it was "admitted" as a limited partner in the Fund. Section 9.1 of the LPA states: Complete Withdrawals of Capital Account. Complete withdrawals of a Limited Partner's Capital Account may be made as of the last Business Day of the calendar quarter ending at least two y

("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

wo years. Article IX, Section 9.1 of the LPA thus describes the process for making a complete withdrawal of a limited partner's "Capital Account": Complete Withdrawals of Capital Account. Complete withdrawals of a Limited Partner's Capital Account may be made as of the last Business Day of the calendar quarter ending at least two y

ank you. EFTA00621796 Financial Trust Company Epstein & Co.) Initial Inv. Oats Liquidity Redemption Date Fund Account Investment Value LP Financial Trust Company. Inc. 127,451,286.27 as of 09/30/06 4/1/2002 2 year roiling 6/30/2008 Subscription S 10,000.000 9/1/2002 2 year rolling 9/30/2008 Additiona

ner in excess of its ratable share, the Partnership shall reimburse such party for such expenses. Article IX. WITHDRAWAL BY LIMITED PARTNERS 9.1. Complete Withdrawals of Capital Account. Complete withdrawals of a Limited Partner's Capital Account may be made as of the last Business Day of the calendar quarter ending at least two ye