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,

ld lead to a diversion from the central issues in the case. The primary issue in this case is when Jeepers was entitled to redeem its investment in the D.B. Zwirn Special Opportunities Fund (the "Fund"). Jeepers alleges that during a conversation with Mr. Zwim on November 13, 2006, Jeffrey Epstein, Jeepers' owner, asked to redeem Jeepe

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

ent to May 2005 Amendments Signed By JEE for FTC • May 2005 Amended and Restated Limited Partnership Agreement and May 2005 Offering Memorandum of the D.B. Zwirn Special Opportunities Fund, L.P. • March 2006 -a verbal demand to redeem the remaining balance of its assets in the Highbridge Managed Account. • August 23, 2006 - HCM (D

, while the Fund's outside counsel investigated the matter further. Finally, at the end of September 2006, I fired the Chief Financial Officer, Mr. Perry Gruss, for these matters, and thereafter, I began to inform investors. 12. After consulting with Dubin,in fact Dubin attended the meeting with counsel, I

this affidavit is true and correct. 2. In 2002, I, along with Highbridge Capital Mgmt, started an investment Fund that ultimately became known as the D.B. Zwirn Special Opportunities Fund, L.P. ("Fund"). The Fund was originally organized under the name Highbridge/Zwirn Special Opportunities Fund, L.P., but in 2004 the Certificate of