Epstein Secrets

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,

pated in certain financial impropriety at DBZ in 2004 and 2005, and failed to disclose that to Jeepers. On the February 8, 2011 conference call, Mr. Susman noted, in support of this fraud theory against Mr. Zwirn, that the Securities and Exchange Commission ("SEC") has conducted a four-year investigati

hs. 25 Q. Who was present? 03:14:49 VERITEXT REPORTING COMPANY www.veritext.com EFTA00299294 Page 211 1 Epstein 2 A. I believe just Mr. Gruss and me. 3 Q. Who set up the meeting? 4 A. I did. 5 Q. How? 03:15:05 6 A. I called him. 7 Q. And asked if he would meet with you? 8

ate a bunch of 18 conversations, it was all the fact that Dan Zwirn 19 was a crook. 20 Q. Did you ever have a conversation with 03:14:36 21 Perry Gruss? 22 A. Yes. 23 Q. When was that? 24 A. In the past two months. 25 Q. Who was present? 03:14:49 VERITEXT REPORTING COMPANY www.veritext

that? 12 A. I sent it. 13 Q. Do you recall sending that? 14 A. No, not really. 15 Q. It's cc'd to Mr. Glenn Dubin and 03:23:40 16 Mr. Susman; is that correct? 17 A. Yes. 18 Q. Does this refresh your recollection 19 that you in fact asked Mr. Dubin to meet with 20 Perry Gruss and

126 1 Epstein 2 A. Yes. 3 Q. He lied to you about the airplane? 4 A. He lied that the things that he 5 represented were the reasons that Gruss were fired 11:45:55 6 were strictly immaterial. He said the phrase that 7 it was immaterial was a lie. 8 Q. Anything else you recall him using

at to be sometime 02:13:00 11 around March? 12 A. It meant basically sell keep my 13 position -- yes, I'm sorry, yes. 14 MR. SCHWARTZ: Mr. Susman, you are 15 nodding and shaking your head at different 02:13:13 16 times depending on what's going on. I don't 17 know whether Mr. Epstein see