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ee. He delegated management of the back office and day-to-day operations to other senior officers who were experienced in those areas, including Mr. Gruss. The financing sources included cash on the funds' balance sheets; interest and principal received from existing loans; proceeds from sales of asse
exhibits and meeting with front-office professionals to discuss available opportunities. Mr. Zwim met regularly with DBZ's Chief Financial Officer, Perry Gruss, and other members of the treasury group to discuss the financing of potential investments. Mr. Zwim adjusted the size and timing of investments bas
orth above, an award should be entered for the Zwirn Respondents. Dated: July 11, 2011 New York, New York LANKLER SIFFERT & WOHL LLP By: II ert Daniel E. Reynolds Andrew S. Lee 500 Fifth Avenue ailig York 10110 Email: Email: Email: Attorneys for Third-Party Respondent Daniel Zwirn COOLEY LLP By: Wiliag
in Paragraph 152. 21. Deny the allegations in Paragraph 153, but aver on information and belief that DBZCO's Chief Financial Officer at the time, Perry Gruss, was responsible for improyei ly causing Fund and Managed Account assets to be used to finance the purchase of the airplane, without Plaintiff's kn
g other relief as this Court may deem just and proper. Dated: New York, New York January 29, 2009 LANKLE S1FFERT & WOHL LLP By: Johfi S. Siffi Daniel E. Reynolds Andrew S. Lee 500 Fifth Avenue New York, New York 10110 (212) 921-8399 (212) 764-3701 (fax) Attorneys for Plaintiff and Counterclaim Defendant
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
onfidentiality Agreement 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
Entities connected to both Perry Gruss and Daniel E. Reynolds

Jeffrey Epstein
PERSON
Glenn Dubin
PERSONZwirn
PERSON
Financial Trust Company
ORGANIZATIONWilliam O'Brien
PERSON
United States
LOCATIONAnthony J. Carpinello
PERSON
Prince Andrew
PERSONDANIEL ZWIRN
PERSONDarren Indyke
PERSONZWIRN HOLDINGS
ORGANIZATIONJeepers, Inc.
ORGANIZATIOND.B. ZWIRN & CO.
ORGANIZATION
JPMorgan Chase
ORGANIZATIONDavid Lee
PERSOND.B. ZWIRN
PERSONAndrew S. Lee
PERSONJohn S. Siffert
PERSON
Highbridge Capital Management
ORGANIZATIONCounter-Claimants
ORGANIZATION