Epstein Secrets

COMPANY, INC.'S AND JEEPERS, INC.'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to Scheduling Order No. 1, Financial Trust Company, Inc. and Jeepers, Inc., by their attorneys, Susman Godfrey L.L.P., hereby request that D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC

nagers, managing members, employees, directors, representatives, agents, officers, consultants, attorneys, predecessors, successors or affiliates of D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, including without limitation the Zwirn Entities. 8. The term "Zwirn En

Inc., including Jeffrey Epstein. I205876vI/011585 2 EFTA00722310 Timestamp: 8/16/2010 5:38 PM CDT 7. The term "Fund" or "On-Shore Fund" means D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC. The term includes past and/or present general partners, managers, managi

Recovery Fund I LLC, and referred to in this Statement as the "Fund"). FTC subsequently transferred the investment to its wholly-owned subsidiary, Jeepers, Inc. ("Jeepers"). Counter-Claimants will refer to this investment throughout as belonging to FTC even though ownership was transferred during the events

of the Fund. The assignment was made retroactively effective January 1, 2006. Counterclaim and Third-Party Respondents 16. Counterclaim Respondent D.B. Zwim Special Opportunities Fund, L.P. kinia Fortress Value Recovery Fund I LLC was a limited partnership formed under the laws of the State of Delaware.

L.P. k/n/a Fortress Value Recovery Fund I LLC, et. al. Dear Sirs: As you are aware, I represent Jeffrey Epstein, Financial Trust Company, Inc., and Jeepers, Inc. (collectively "Epstein") in connection with claims regarding an investment in D.B. Zwirn Special Opportunities Fund, L.P. k/n/a Fortress Value Reco

k, NY 10036 Suite 3800 1x01 Third Avenue Seattle, WaShingtongazoa-3000 Re: Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein vs. D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, et. al. Dear Sirs: As you are aware, I represent Jeffrey Epstein, Finan

. Susman Godfrey L.L.P. ("SG", "we", or "us") (which includes any successor to the partnership of SG) will represent Financial Trust Company, Inc., Jeepers, Inc., and Jeffrey Epstein ("Client" or "you") in connection with all claims you have against Daniel Zwim, D.B. Zwim Special Opportunities Fund, L.P. ("F

t Financial Trust Company, Inc., Jeepers, Inc., and Jeffrey Epstein ("Client" or "you") in connection with all claims you have against Daniel Zwim, D.B. Zwim Special Opportunities Fund, L.P. ("Fund"), D.B. Zwirn Partners, LLC, D.B. Zwim & Co., L.P., Zwirn Holdings, LLC, Glenn Dubin, Highbridge Capital Ma

se No. Arbitrators: FINANCIAL TRUST COMPANY, INC.'S AND JEEPERS INC.'S STATEMENT OF CLAIM I. Claimants Financial Trust Company, Inc. ("FTC") and Jeepers, Inc. ("Jeepers") (collectively, "Claimants"), submit the following statement of their claims against D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fo

ancial Trust Company, Inc. ("FTC") and Jeepers, Inc. ("Jeepers") (collectively, "Claimants"), submit the following statement of their claims against D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, D.B. Zwim Partners, LLC, Zwim Holdings, LLC, D.B. Zwim & Co., L.P., and

L.P. k/n/a Fortress Value Recovery Fund I LLC, et. al. Dear Sirs: As you are aware, I represent Jeffrey Epstein, Financial Trust Company, Inc., and Jeepers, Inc. (collectively "Epstein") in connection with claims regarding an investment in D.B. Zwirn Special Opportunities Fund, L.P. k/n/a Fortress Value Reco

LLP The Grace Building 1114 Avenue of the Americas New York, NY 10036 Re: Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein vs. D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, et. al. Dear Sirs: As you are aware, I represent Jeffrey Epstein, Finan