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

ed Gibson Dunn & Crutcher LLP ("Gibson Dunn") to conduct a thorough internal investigation of all potential accounting issues. Gibson Dunn retained Deloitte & Touche as a special accountant for its investigation. The Company made appropriate disclosures and self-reported these issues to the United States Securit

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,

formerly served as Executive Vice President for Enforcement of NASD and as Chief Litigation Counsel at the SEC. Gibson Dunn, with the assistance of Deloitte & Touche, reviewed over a million documents and interviewed 23 witnesses, including Mr. Gruss on five separate occasions. Gibson Dunn made two presentations

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

nvestments. Mr. Zwim and Mr. Epstein scheduled a meeting on November 21, 2006, that was to include Mr. Dubin, Mr. Cutler, Mr. Lee, Fried Frank, and Deloitte & Touche. The main purpose of the meeting was to give Mr. Epstein comfort about the value of FTC's investments in the Fund. Mr. Epstein cancelled the meetin