Epstein Secrets

Esq. Susman Godfrey, LLP 654 Madison Avenue, 51h Floor New York, New York 10065-8440 212/336-8330 Counsel for Respondent and Counter-Claimants William O'Brien, Esq. Cooley LLP 1114 Avenue of the Americas New York, New York 10036 2 1 2/47 -6000 m r Counsel for Third Party Respondents D.B. Zwirn Partner

Order. Counsel are invited to enter into a stipulated protective order concerning the confidentiality of documents produced in this proceeding. The Arbitrator will provide assistance if required. 10. Exchange of Information. The parties shall exchange all documentary evidence they intend to offer at the

n (counsel for Financial Trust Company, Inc. and Jeepers, Inc.) John Siffert and Daniel Reynolds (counsel for Daniel B. Zwini) William Schwartz and William O'Brien (counsel for D.B. Zwim Partners, LLC; D.B. Zwim & Co., L.P.; DBZ GP, LLC; and Zwim Holdings, LLC) EFTA00613999 JUDICIAL ARBITRATION AND MEDIATION

xcluded on the breach of written contract claim because: (I) the terms of the relevant contract (again, really contracts, as Jeepers would allow the Arbitrator to consider the LPA in addition to the Side Letter) are unambiguous; (2) if those agreement(s) are in fact ambiguous, the doctrine of contra projer

(eServe User) 13. eLaw Tracking # 122456 Seth Ard (eServe User) 14. eLaw Tracking # 122457 Stephen Susman (eServe User) 15. eLaw Tracking # 122458 William O'Brien (eServe User) EFTA00622269 eServe Document Separator Sheet Powered By 000 If any of the documents are incomplete, missing, illegible or unread

sed please find our administrative information and an invoice for a retainer to cover any pre-hearing costs such as preliminary conferences with the Arbitrator, case management fee, review of motions and other documents, etc. Please mail your payment to JAMS at the PO Box number located on the bottom of th