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to Paragraph 7 of the Settlement Agreement and Release dated April 8, 2009 ("Agreement") among D.B. Zwim Special Opportunities Fund ("Fund"), L.P., Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein, Jeepers has provided Jeepers' Cancellation Declaration to the names and addresses listed in Pa
null and void and the releases, waivers, promises, covenants, and other provisions contained therein are of no effect. Cc: Alan R. Glickman, Esq. Schulte Roth & Zabel LLP 919 Third Avenue New York, NY 10022 Jeffrey Epstein President EFTA00724456
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
ime looking into the issues. 8 EFTA00613915 By June 2006, Messrs. Cutler and Proshan reported back to Mr. Zwim. They recommended that DBZ retain Schulte Roth & Zabel LLP ("Schulte") to investigate the management-fee and airplane issues, determine what had occurred, and provide legal advice on potential disclosure an
to Paragraph 7 of the Settlement Agreement and Release dated April 8, 2009 ("Agreement") among D.B. Zwim Special Opportunities Fund ("Fund"), L.P., Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein, Jcepers has provided Jeepers' Cancellation Declaration to the names and addresses listed in Pa
null and void and the releases, waivers, promises, covenants, and other provisions contained therein are of no effect. Cc: Alan R. Glickman, Esq. Schulte Roth & Zabel LLP 919 Third Avenue New York, NY 10022 Jeffrey Epstein President EFTA00591278
Entities connected to both Jeepers, Inc. and Schulte Roth & Zabel LLP

Jeffrey Epstein
PERSON
Financial Trust Company
ORGANIZATION
United States
LOCATIONDarren Indyke
PERSON
Stephen Hawking
PERSONStephen D. Susman
PERSONSUSMAN GODFREY
ORGANIZATION
Alan Dershowitz
PERSONZwirn
PERSOND.B. ZWIRN & CO.
ORGANIZATIOND.B. ZWIRN
PERSONSouthern District
LOCATION
New York
LOCATIOND.B. Zwirn Special Opportunities Fund
ORGANIZATION
Prince Andrew
PERSONWilliam O'Brien
PERSOND.B. Zwim Special Opportunities Fund
PERSON
FedEx
ORGANIZATIONDavid Lee
PERSONPerry Gruss
PERSON