Epstein Secrets

im brought against them in which certain of the allegations in such a claim were somewhat similar to those asserted by Mr. Epstein (or his company, Jeepers, Inc.) in the Arbitration. Claimants believe the proposed release language for the New Agreement quoted above accurately captures the agreement parties r

nal issue with you. Respectfully submitted, Enclosures cc: Harry Susman, Esq. John Siffert, Esq. Daniel Reynolds, Esq. William Schwartz, Esq. William O'Brien, Esq. Darren K. Indyke, Esq. James H.R. Windels, Esq. EFTA00306065

nd the basis of the claim of privilege asserted. DEFINITIONS 1. "Third-Party Claimants" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepers, Inc. and includes all their directors, officers, employees, representatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyo

or, New York, New York, to PRODUCE DOCUMENTS as described on Exhibit A hereto. Dated: November 9 , 2010 Hon. Anthony J Arbitrator Requested by: William O'Brien, Esq. Cooley LLP 1114 Avenue of the Americas New York, New York 10036 Counsel for Third-Party Respondents D.B. Zwirn Partners, LLC, D.B. Zwirn

nd the basis of the claim of privilege asserted. DEFINITIONS 1. "Third-Party Claimants" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepers, Inc. and includes all their directors, officers, employees, representatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyo

BRING AND PRODUCE DOCUMENTS as described on Exhibit A hereto. Dated: November 2010 Hon. Anthony J. Carpinello (Ret.) Arbitrator Requested by: William O'Brien, Esq. Cooley LLP 1114 Avenue of the Americas New York, New York 10036 iii 479-6000 Counsel for Third-Party Respondents D.B. Zwirn Partners, LLC

nd the basis of the claim of privilege asserted. DEFINITIONS 1. "Third-Party Claimants" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepers, Inc. and includes all their directors, officers, employees, representatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyo

rk, New York and to BRING AND PRODUCE DOCUMENTS as described on Exhibit A hereto. Dated: November", 2010 on. Anthony J Arbitrator Requested by: William O'Brien, Esq. Cooley LLP 1114 Avenue of the Americas New York, New York 10036 (212) 479-6000 Counsel for Third-Party Respondents D.B. Zwirn Partners, L

ether, the "Zwim Respondents") submit this pre-hearing brief in opposition to the claims by Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc. (together, "FTC"). Preliminary Statement At no time did Daniel Zwim promise Jeffrey Epstein that FTC could immediately withdraw $80 million of its

venue ailig York 10110 Email: Email: Email: Attorneys for Third-Party Respondent Daniel Zwirn COOLEY LLP By: Wiliagithesu William J. wartz William O'Brien Arastu K. Chaudhury 1114 Avenue of the Americas • ork 10036 Email: Email: Email: Attorneys for Third-Party Respondents D.B. Zwirn Partners,

te") among: (i) Fortress VRF 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.,

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 10036-7798 4. All notices to Daniel Zwim with respect to this Settlement