Epstein Secrets

loor New York, New York 10018 Re: Fortress VRF I LLC and Fortress Value Recovery Fund 1 LLC v. Jeepers, Inc. JAMS Ref. No. 1425006537 Dear Judge Carpinello: Daniel B. Zwim submits this letter in advance of our scheduled mediation session with Your Honor on November 2. The only remaining issue regardin

LANKLER SIEFERT& WOHL LLP ATTORNEYS AT LAW TELEPHONE TELEFAX October 31, 2011 BY E-MAIL AND BY HAND The Honorable Anthony J. Carpinello JAMS 620 Eighth Avenue, 34'h Floor New York, New York 10018 Re: Fortress VRF I LLC and Fortress Value Recovery Fund 1 LLC v. Jeepers, Inc. JAMS

forever, irrevocably and unconditionally release and discharge: (I) except with respect to any indemnification obligations Claimants may have to the Zwim Releasors for reasonable attorneys' fees and costs incurred in connection with the Arbitration, the Claimants Released Parties from, and covenant not to sue

ny of the Zwim Releasors against any of the Claimants Released Parties that are directly related to the matters at issue in the Arbitration, none of the Zwim Releasors is releasing any Claimants Released Parties from (or agreeing not to sue any of them with respect to) any claims of any nature that any Zwim Releas

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

forever, irrevocably and unconditionally release and discharge: (1) except with respect to any indemnification obligations Claimants may have to the Zwim Releasors for reasonable attorneys' fees and costs incurred in connection with the Arbitration, the Claimants Released Parties from, and covenant not to sue

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

y forever, irrevocably and unconditionally release and discharge: (1) except with respect to any indemnification obligations Claimants may have to the Zwim Releasors for reasonable attorneys' fees and costs incurred in connection with the Arbitration, the Claimants Released Parties from, and covenant not to sue