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CLAIMS OF DEFENDANTS D.B. ZWIRN & CO., L.P. AND D.B. ZWIRN PARTNERS, LLC JURY TRIAL DEMANDED Defendants D.B. Zwim & Co., L.P. (the "Company") and D.B. Zwim Partners, LLC ("DBZLLC"), by their attorneys Cooley Godward ICronish LLP, answer the Complaint and Jury Demand herein as follows: I. Aver that in 2006, de
uss had obligations to the Company and DBZLLC in addition to those set forth in the unexecuted Supplementary Agreement among D.B. Zwim & Co., L.P., D.B. Zwim Partners, LLC and Perry Gruss (the "Supplementary Agreement"). 58. Deny the allegations of Paragraph 58, except admit that Gruss was a partner in the Comp
Managed Funds were properly financed, and that Gruss held himself out to be qualified to perform these functions. 4 EFTA00731282 20. Admit that Harold Kahn ("Kahn") was hired in April 2005 to serve as the Company's Chief Operating Officer; and otherwise deny the allegations of Paragraph 20, except aver
of document, subject matter, number of pages, and the basis of the claim of privilege asserted. DEFINITIONS I. "Zwim Entities" means Daniel Zwim, D.B. Zwim Partners, LLC, D.B. Zwim & Co., L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their respective members, managers, general partners, limited pa
oyees, representatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on their behalf. 3. "You" means Harold Kahn. 4. Rules of construction: "All" and "each" shall be construed as all and each; "and" and "of shall be construed either disjunctively or conjuncti
of document, subject matter, number of pages, and the basis of the claim of privilege asserted. DEFINITIONS I. "Zwim Entities" means Daniel Zwim, D.B. Zwim Partners, LLC, D.B. Zwim & Co., L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their respective members, managers, general partners, limited pa
oyees, representatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on their behalf. 3. "You" means Harold Kahn. 4. Rules of construction: "All" and "each" shall be construed as all and each; "and" and "of shall be construed either disjunctively or conjuncti
Entities connected to both D.B. Zwim Partners and Harold Kahn

Richard Kahn
PERSONZWIRN HOLDINGS
ORGANIZATIONAnthony J. Carpinello
PERSON
Financial Trust Company
ORGANIZATIOND.B. ZWIRN & CO.
ORGANIZATIONDANIEL ZWIRN
PERSON
Jeffrey Epstein
PERSOND.B. ZWIRN
PERSONJeepers, Inc.
ORGANIZATION
Houston
LOCATION
Stephen Hawking
PERSONHarry P. Susman
PERSONthe Judicial Arbitration and Mediation Service
ORGANIZATIONCounterclaimants
ORGANIZATIONSusman Godfrey
PERSONSUSMAN GODFREY L.L.P.
ORGANIZATIONLouisiana Street
ORGANIZATIONStephen D. Susman
PERSONSUSMAN GODFREY
ORGANIZATIONSeth Ard
PERSON