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

. The only remaining issue regarding the settlement of the above-referenced matter concerns the scope of the release to be given by Daniel Zwim and the Zwirn Entities to the Claimants. The settlement read into the record at our last meeting with Your Honor provides that: "The Zwim Parties, on the one hand, and t

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

Suite 5100 1000 Louisiana Houston, TX 77002-5096 3. All notices to 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

LLC, D.B. ZWIRN & CO., L.P., DBZ GP, LLC, ZWIRN HOLDINGS, LLC, DANIEL ZWIRN, and Third-Party Respondents Case No. 1425006537 Arbitrator: Hon. Anthony J. Carpinello Respondents' Response to the First Set Of Document Requests By Third-Party Respondents Zwirn Entities Respondents Financial Trust Company, Inc. an

d without waiving the forgoing objection, Respondents will produce responsive documents, if any, that may exist. 3. All communications with any of the Zwirn Entities. Response: Respondents object because this request is overly broad, vague, unduly burdensome, designed to harass Respondents and/or third parties,

LLC, D.B. ZWIRN & CO., L.P., DBZ GP, LLC, ZWIRN HOLDINGS, LLC, DANIEL ZWIRN, and Third-Party Respondents Case No. 1425006537 Arbitrator: Hon. Anthony J. Carpinello SUBPOENA DUCES TECUM To: JP Morgan Chase & Co. JP Morgan Asset Management Highbridge Capital Corporatoin NOTICE IS HEREBY GIVEN that pursuant t

d in Epstein's Claim. 8. All documents concerning the repayment of advances made from the Highbridge Managed Account to other funds controlled by the Zwirn Entities, including without limitation any documentation of such advances, any promissory notes, documentation of whether such funds were repaid, and any di