Epstein Secrets

on of Perry Gruss. 1205876v1/011585 13 EFTA00722321 Timestamp: 8/16/2010 5:38 PM CDT 38. All communications among Counterclaim Respondents and Gruss concerning Gruss's termination or the subsequent litigation filed by Gruss against Zwim, including any pleadings or discovery instruments or docume

l documents concerning any review or investigation of the Fund's operations, finances, or accounting prompted by or occurring after the departure of Perry Gruss from involvement with the Fund or any of the Zwim Entities. 36. All witness statements taken in connection with any internal review or investigat

that a true and correct copy of the foregoing instrument has been served by email and first class mail, this 17th day of August, on: Brad S. Karp Allan Arffa Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019 John S. Siffert Lankier Siffert & Wohl LLP 500 Fift

or permission to depose Perry Gruss, DBZ's former Chief Financial Officer. We submit that Jeepers has not met its burden to show good cause why Mr. Gruss's deposition should be taken, and Your Honor should deny permission to take his deposition.' In its February 14, 2011 letter, Jeepers tries to port

r in response to Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc.'s (collectively, "Jeepers") request for permission to depose Perry Gruss, DBZ's former Chief Financial Officer. We submit that Jeepers has not met its burden to show good cause why Mr. Gruss's deposition should be taken,

quest for a subpoena for Mr. Gruss's deposition testimony should be denied. Res dully/ kS Jo S. i ert Enclosures cc: Stephen D. Susman, Esq. Allan Arffa, Esq. William O'Brien, Esq. William Schwartz, Esq. EFTA00696667

s "real" witness list as well as our best guess of when the witnesses will be called: Dan Zwirn--Friday, July 22 Jeffrey Epstein--Monday, July 25 Perry Gruss--Monday-PM Harry Beller--Tuesday, July 26 Glenn Dubin--Tuesday Darren Indyke--Wednesday, July 27 Dan Stachman (rebuttal expert, subject to motion

From: "Harty Susman" < =c ,• To: A "Allan Arffa" "Arastu Chaudhury" ,'Dan Reynolds" "Jennifer Spiegel" "William O'Brien" "Andrew Lee" , "Brad Karp" , "Hannah Sholl" , John Siffert" "Willia

m contacted Epstein. The two had not spoken about anything of substance since 2002. Zwim informed Epstein that the Fund's Chief Financial Officer, Perry Gruss, had been terminated over an accounting transaction that was "nonmaterial." Zwim specifically mentioned that more than $3 million in investor money

is is to certify that a true and correct copy of the foregoing instrument has been served by email and first class mail, this day of Brad S. Karp Allan Arffa Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019 John S. Siffert Lankier Siffert & Wohl LLP 500 Fift

Re: Fortress VRF I LLC et al. v. Jeepers, Inc., JAMS Ref. No. 1425006537 I have enclosed a copy of the transcript of Daniel Zwim's deposition in the Gruss matter, bates-stamped DZ_FTC 000754 - DZ_FTC 000872. As agreed between and among the parties, the enclosed materials will be treated as confidenti

has not been fully executed. If that is not your understanding, please let me know as soon as possible. Very truly yours, Daniel E. Reynolds cc: Allan Arffa, Esq. William O'Brien, Esq. EFTA00629533

granted both parties the right to take such pre-hearing testimony of third- I57I529vI/011585 EFTA00585338 party witnesses (e.g., Mr. Dubin and Mr. Gruss), although the Zwim Parties and FTC subsequently elected to pass on the opportunity (preferring instead to call these witnesses to the Hearing itse

Honorable Anthony J. Carpinello June 3, 2011 Page 3 Thank you for considering these matters. Sincerely, Stephen D. Susman cc: William O'Brien Allan Arffa John S. Siffert 1571529v1/011585 EFTA00585340