Epstein Secrets

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

coolev.com Email: [email protected] Email: msleeper@,coolev.com Email: kkrajeck(a,coolev.com Attorneys for Defendants D.B. Zwirn & Co., LP. and D.B. Zwirn 'Farmers, LLC EFTA00731324 CERTIFICATE OF SERVICE I certify that the foregoing Answer and Counterclaims of Defendants D.B. Zwim & Co., L.P. and

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

15 NO. DESCRIPTION PAGE 16 17 Exhibit 1, letter 33 18 Exhibit 2, memorandum dated 9/17/04 49 19 from Zwirn to limited partners of 20 D.B. Zwirn special opportunities fund 21 Exhibit 3, invoice from FTC to Resnick 97 22 Exhibit 4, draft consulting agreement 98 23 with fax cover sheet

volving oversight of sub-advisor DB Zwirn beginning in the Fall 2006." • September 24, 2006 Zwirn calls Jeffrey to advise that he is going to fire Gruss but it is not for material reasons. Jeffrey advises that he wants to redeem FTC's entire investment. • Sepetember 30, 2006. Gruss is fired. • O

, HCM is to be allocated 46% of the Incentive Fees and Management Fees collected by Highbridge Zwirn Partners, LLC (which later changed its name to D.B. Zwirn Partners, LLC - the General Partner of the Fund), D.B. Zwirn & Co., L.P. (the Fund's Trading Manager) and DB Zwirn GP, LLC (the General Partner of

paid, so that DSAM still retains an interest in the Zwirn business.] • In October 2006, Zwirn called me to alert me to the fact he had terminated Perry Gruss as CFO for reasons which Zwirn initially claimed were not material. I believe that Zwirn's counsel told you a similar story, but with more details.

hbridge, who employed Dan Zwirn as a manager. I also invested an additional $20 MM at the beginning of 2005. • In March 2004, Zwirn spun off into D.B. Zwirn and Co. • In September 2004, Highbridge sold most of its interests to J.P. Morgan. However, it is Kirkland's understanding that, in substance, DSA

at Dubin and Swieca still retains an interest in the Zwirn business. • In October 2006, Zwirn called me to alert me to the fact he had terminated Perry Gruss as CFO for reasons which Zwirn initially claimed were not material. I believe that Zwirn's counsel told you a similar story, but with more details.

hbridge, who employed Dan Zwirn as a manager. I also invested an additional $20 MM at the beginning of 2005. • In March 2004, Zwirn spun off into D.B. Zwirn and Co. • In September 2004, Highbridge sold most of its interests to J.P. Morgan. Though its is Kirklands' understanding that, in substance, Dubi

of these mattes cannot be ascertained at this time. The Securities and Exchange Commission (the "Commission') has filed a civil complaint against Perry Gruss, the former Chief Financial Officer of the Original Manager, alleging improper transfers of client funds between 2004 and 2006. The Fund is not a pa

formerly known as the D.B. Zwirn Special Opportunities Fund (TE), L.P., and Fortress Value Recovery Fund API LLC ("AP Fund"), formally known as the D.B. Zwirn Asia/Pacific Special Opportunities Fund, L.P. In March 2008, the Original Manager of the Fund began implementing an orderly disposition of the Fund

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

Jeffrey Epstein, provides financial consulting services to third-parties, and FTC also invests its own funds. FTC made the following investments in D.B. Zwirn Special Opportunities Fund, L.P.: • $10 million investment on April 4, 2002; • $10 million investment on September 1, 2002; • $30 million inve

at Dubin and Swieca still retains an interest in the Zwirn business. • In October 2006, Zwirn called me to alert me to the fact he had terminated Perry Gruss as CFO for reasons which Zwirn initially claimed were not material. I believe that Zwirn's counsel told you a similar story, but with more details.

hbridge, who employed Dan Zwirn as a manager. I also invested an additional $20 MM at the beginning of 2005. • In March 2004, Zwirn spun off into D.B. Zwirn and Co. • In September 2004, Highbridge sold most of its interests to J.P. Morgan. Though its is Kirklands' understanding that, in substance, Dubi

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

Fund from 9 Financial Trust Company to JEEPERS? 10 A. Yes, sir. 02:16:54 11 Q. What was the purpose of that, sir? 12 A. I -- it was to -- D.B. Zwirn had a New 13 York-sourced income that was -- showing New 14 York-sourced income. As my business is a Virgin 15 Islands entity, I wanted to be e