Epstein Secrets

. 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

pportunities Fund, L.P. ("Fund"), D.B. Zwirn Partners, LLC, D.B. Zwim & Co., L.P., Zwirn Holdings, LLC, Glenn Dubin, Highbridge Capital Management, Dubin & Swieca Asset Management, and any of their successors or predecessors in interest for damages arising out of your investments in the Fund (all such claims are collectively

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

. Each of µhe facts and statements herein is true and correct 2. Starting in 2002, an entity that I both owned and controlled, currently known as Dubin & Swieca Asset Management, LLC ("DSAM"), owned interests in the general partner and in the investment manager of D.B. Zwim Special Opportunities Fund, L.P. (the "Zwim Fund")

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

Each of the facts and statements herein is true and correct. 2. Starting in 2002, an entity that I both owned and controlled, currently known as Dubin & Swieca Asset Management, LLC ("DSAM"), owned interests in the general parmer and in the investment manager of D.B. Zwim Special Opportunities Fund, L.P. (the "Zwim Fund").

First Set Of Document Requests By Claimants Fortress VRF I LLC And Fortress Value Recovery Fund I LLC Respondents Financial Trust Company, Inc. and Jeepers, Inc. (collectively referred to as "Respondents") hereby respond to Petitioner's First Set of Documents Requests as follows: OBJECTIONS TO DEFINITIONS AN

ce responsive documents, if any, that may exist. Request No. 13: All documents concerning Glenn Dubin and/or Highbridge Capital Management (n/k1a Dubin & Swieca Asset Management, LLC) that relate to: (a) any investment by Epstein, Jeepers or FTC in the Fund; (b) any conversation between or among Epstein, Dubin and Daniel Zw