Epstein Secrets

O DELAWARE AVENUE. SUITE 200 POST OFFICE BOX 32 WILMINGTON. DE 111•994032 TELEPHONE 1302) 061-4410 July 21, 2011 BY HAND DELIVERY The Honorable Anthony J. Carpinello (Ret.) Arbitrator, JAMS 620 Eighth Avenue, 34th Floor New York, NY 10019 MATTHEW W A1111017 thititi t AtEri * , YNN BA JO▪ HN • RAY RAM° t.I

LLIAMS LAWRENCE I. WITDORCHIC MARK f i4WLAZLO 1.41 . MIGHINO AN E. YAREIT TO KAY N YU TRACEY A. ZACCONE T. ROBERT ZOCHOWSKI. JR. Dear Judge Carpinello: Attached you should find: (1) a hard copy of Claimants' Memorandum of Law in Opposition to Financial Trust Company, Inc.'s and Jeepers, Inc.'s Mot

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

k, New York 10110-3398 A2 SS Counsel for Third Party Respondent, Daniel Zwirn 2. Arbitrator. The parties have appointed as sole Arbitrator: Hon. Anthony J. Carpinello (Ret.) JAMS 620 Eighth Avenue, 34ih Floor New York, New York 10018 212 2704: 3. Case Manager: Michael Gonzalez, Esq. Case Manager JAMS 620

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

.B. ZWIRN & CO., LP, DBZ GP, LLC, ZWIRN HOLDINGS, LLC, and DANIEL ZWIRN, Third-Party Respondents JAMS Reference No. 1425006537 Arbitrator: Hon. Anthony J. Carpinello (Ret.) CLAIMANTS' PRE-HEARING BRIEF PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, New York 10019-6064 (212)

eemers, i.e., in category § 18-804(a)(2). Specifically, it would be entitled to a priority claim in the Fund's liquidation in the amount set by the Arbitrator and would entitle Jeepers to receive payment pro rata with all other Redeemers when assets are distributed by the Fund in connection with its windi

10:00 AM for 8 hours at 10:00 AM for 8 hours at 10:00 AM for 8 hours PLACE: JAMS 620 Eighth Ave. 34th Floor New York, NY 10018 NEUTRAL: Hon. Anthony J. Carpinello (Ret.) Enclosed please find our administrative information and an invoice for a retainer to cover any pre-hearing costs such as preliminary confere

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