Epstein Secrets

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

of this Settlement Agreement (a "Settlement Agreement Dispute"), the Parties agree to resolve such Dispute through binding arbitration before Judge Carpinello, to be administered II EFTA00298491 CONFIDENTIAL by the JAMS office in New York, New York pursuant to the JAMS Comprehensive Arbitration Rules

y 21, 2010, to which the Zwirn Parties and Claimants each filed a separate Response dated June 25, 2010 in an arbitration proceeding before the Hon. Anthony J. Carpinello (Ret.) at the New York, New York office of JAMS, reference number 1425006537 (the "Arbitration"); WHEREAS, the Parties subsequently agreed to the t

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

C 20006-1047 TELEPHONE (2021 2.23-7300 500 DELAWARE AVENUE. SUITE ZOO POST OFFICE BOX 32 WILMINGTON. DE 1900-0092 TELEPHONE (302) 035.4410 Hon. Anthony J. Carpinello (Ret.) Arbitrator, JAMS 620 Eighth Avenue, 34th Floor New York, NY 10019 (TEW. AR W. AABBOTT ALLAN J. BERTH. ATKINS W Eitn Y i ifi U lan .AN

. WLAZLO JJyUL KAYE N. YOSHINO TONG YU t TRAC RT EY A. CONE ROBE OMSK). JR. VRF I LLC v. Jeepers, Inc., JAMS Ref. No. 1425006537 Dear Judge Carpinello: On behalf of Claimants Fortress VRF I LLC ("VRF I LLC") and Fortress Value Recovery Fund I LLC (the "Fund") (and together with VRF I LLC, "Claiman

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

A00727326 Avenue, 34th Floor, New York, New York and to 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 fo