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a partner in the Company and a member of DBZLLC and was the Chief Financial Officer and Chief Administrative Officer of the Company. 4. Aver that Gruss was effectively terminated from the Company and DBZLLC, resigning on the verge of being fired, on or about October 4, 2006, and otherwise deny the
tence of Paragraph 16. 17. Deny the allegations of Paragraph 17, except admit that the Fund Controllers and the Operations department reported to Gruss and worked under his supervision; that they had responsibilities concerning accounting and record-keeping; that they worked with the Funds' Adminis
individual investment accounts (the "Managed Accounts"), including HCM/Z Special Opportunities LLC ("HCM/Z"), an account managed for the benefit of Highbridge Capital Corporation. The Funds and the Managed Accounts are referred to collectively as the "Managed Funds." 114. The Company's investment strategy was unlike most h
) invested $80 million in the Zwirn Fund. 4. In early September 2006, Zwim informed me that he was firing the Fund's then-Chief Financial Officer, Perry Gruss. Zwim said that he discovered various irregularities at the Fund, including that investors' money was used to pay for an airplane that would be owne
rs that I directed to invest in the Fund was Jeffrey Epstein ("Epstein"). Epstein was both a personal friend of mine and a major client of my firm, Highbridge Capital Corporation. Between 2002 and 2005, Epstein (through an entity called Financial Trust Company, Inc.) invested $80 million in the Zwirn Fund. 4. In early Septe
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 $3 million in investor money had been u
FTA00586235 Statement of the Claim 22. In 2002, Epstein was introduced to Daniel Zwim by Glenn Dubin. Dubin and his partner Henry Swieca started Highbridge Capital Corporation, a very successful investment management firm. Epstein had a long-standing relationship with Dubin, and Highbridge provided investment advisory se
ny, Inc.) invested $80 million in the Fund. 4. In early October 2006, Zwim informed me that he was firing the Fund's then-Chief Financial Officer, Perry Gruss. Zwim said that he discovered various irregularities at the Fund, including that investors' money was used to pay for an airplane that would be owne
that I encouraged to invest in the Fund was Jeffrey Epstein ("Epstein"). Epstein was both a personal friend of mine and a major client of my firm, Highbridge Capital Corporation. Between 2002 and 2005, Epstein (through an entity called Financial Trust Company, Inc.) invested $80 million in the Fund. 4. In early October 200
Entities connected to both Perry Gruss and Highbridge Capital Corporation

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Glenn Dubin
PERSONZwirn
PERSON
Financial Trust Company
ORGANIZATIONHighbridge
ORGANIZATIOND.B. Zwirn
ORGANIZATIONHarry Beller
PERSONDarren Indyke
PERSONSchulte
PERSON
Highbridge Capital Management
ORGANIZATION
United States
LOCATIONWilliam O'Brien
PERSOND.B. ZWIRN & CO.
ORGANIZATIOND.B. Zwim
PERSONDaniel Zwim
PERSOND.B. ZWIRN
PERSON
Richard Kahn
PERSONHarry P. Susman
PERSON
Alan Dershowitz
PERSON