Epstein Secrets

nal issue with you. Respectfully submitted, Enclosures cc: Harry Susman, Esq. John Siffert, Esq. Daniel Reynolds, Esq. William Schwartz, Esq. William O'Brien, Esq. Darren K. Indyke, Esq. James H.R. Windels, Esq. EFTA00306065

t in advance exactly what new third-party claims could be brought against the Zwim Parties, how the pre-Arbitration agreements between the Fund and the Zwirn Parties might (or might not) apply to such claims, and how the currently proposed release language might (or might not) apply to such claims. Therefore, the

or, New York, New York, to PRODUCE DOCUMENTS as described on Exhibit A hereto. Dated: November 9 , 2010 Hon. Anthony J Arbitrator Requested by: William O'Brien, Esq. Cooley LLP 1114 Avenue of the Americas New York, New York 10036 Counsel for Third-Party Respondents D.B. Zwirn Partners, LLC, D.B. Zwirn

ense include terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communications between You on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communications between You on the one hand, and any of

BRING AND PRODUCE DOCUMENTS as described on Exhibit A hereto. Dated: November 2010 Hon. Anthony J. Carpinello (Ret.) Arbitrator Requested by: William O'Brien, Esq. Cooley LLP 1114 Avenue of the Americas New York, New York 10036 iii 479-6000 Counsel for Third-Party Respondents D.B. Zwirn Partners, LLC

clude terms in the present tense. DOCUMENT REQUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

rk, New York and to BRING AND PRODUCE DOCUMENTS as described on Exhibit A hereto. Dated: November", 2010 on. Anthony J Arbitrator Requested by: William O'Brien, Esq. Cooley LLP 1114 Avenue of the Americas New York, New York 10036 (212) 479-6000 Counsel for Third-Party Respondents D.B. Zwirn Partners, L

clude terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

message: From: "Hannah Sholl" Date: August 12, 2011 12:22:05 PM EDT To: "Darren Ind ke" < >, "Arastu Chaudhury" < Lee" < >, "Dan Reynolds" < "William O'Brien" < >, "John Siffert" 'William Schwartz" , "Andrew "James , "Jennifer A Spiegel >, "Demian A Ordway" Subject: Revised Settlement Agreement Cou

reement and a blackline comparing this version to the initial version we circulated on August 5. We reviewed the comments provided by Mr. Indyke and the Zwirn Parties, and this version incorporates some, but not all, of their proposed changes. We have not yet received comments from counsel for Mr. Dubin. EFTA004

the Zwim Entities with respect to this Settlement Agreement shall be sent to the Zwirn Entities at and in care of: 12 EFTA00298492 CONFIDENTIAL William O'Brien Cooley LLP The Grace Building 1114 Avenue of the Americas New York, NY 10036-7798 4. All notices to Daniel Zwim with respect to this Settlement

arties now manage or formerly managed, and any fund or account now or formerly managed by Claimant Fortress VRF I LLC or its affiliates; and (2) the Zwirn Parties and each of their past, present and future parents, subsidiaries and other affiliates, each of the predecessors, successors, heirs and assigns of e