Epstein Secrets

rest, exceed $45 million. Introduction 2. At all times relevant to the claims stated herein, Claimant FTC was a corporation owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful investor. At all times relevant to the claims stated herein, Claimant COUQ was a private foundation managed by

million. Introduction 2. At all times relevant to the claims stated herein, Claimant FTC was a corporation owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful investor. At all times relevant to the claims stated herein, Claimant COUQ was a private foundation managed by Epstein.

imant FTC was a corporation owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful inv

ld by both the High-Grade and Enhanced Funds. Had Mr. Epstein been made aware of the true nature of what was t

09 Respectfully submitted, SUS EY L.L.P. ep en D. Susman 654 Madison Avenue, 5th Floor New York, New York 10065-8440 E-mail: Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 E-mail: Attorneys for Claimants Financial Trust Company, Inc. C.O.U.Q. Foundation

tners, LLC, D.B. Zwim & Co., L.P., DBZ GP, LLC, Zwim Holdings, LLC, and Daniel Zwirn. Introduction 3. Over a three-year period beginning in 2002, Jeffrey Epstein ("Epstein"), through a firm he owned and managed named Financial Trust Company, Inc. ("FTC"), made an $80 million investment in D.B. Zwim Special O

Zwim & Co., L.P., DBZ GP, LLC, Zwim Holdings, LLC, and Daniel Zwirn. Introduction 3. Over a three-year period beginning in 2002, Jeffrey Epstein ("Epstein"), through a firm he owned and managed named Financial Trust Company, Inc. ("FTC"), made an $80 million investment in D.B. Zwim Special Opportuniti

3. Over a three-year period beginning in 2002, Jeffrey Epstein ("Epstein"), through a firm he owned and

Fund, The 2005 Letter Agreement did not provide Mr. Epstein with any such right as of March 31, 2007, becaus

SUSMAN GODFREY L.L.P. Stephen D. Susman 654 Madison Avenue, 5th Floor New York, New York 10065-8440 Tele hone: Fax: E-mail: Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: Fax: E-mail: Attorneys for Respondent Counter-Claimants and Third-Party

o., L.P., and Daniel Zwim. Introduction 2. At all times relevant to the claims stated herein, Claimants FTC and Jeepers were owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful investor. 3. Starting in 2002, Epstein (through FTC) began investing in D.B. Zwim Special Opportunities Fund

el Zwim. Introduction 2. At all times relevant to the claims stated herein, Claimants FTC and Jeepers were owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful investor. 3. Starting in 2002, Epstein (through FTC) began investing in D.B. Zwim Special Opportunities Fund, L.P. ("F

imants FTC and Jeepers were owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful inv

Fund, The 2005 Letter Agreement did not provide Mr. Epstein with any such right as of March 31, 2007, becaus

Avenue, 5th Floor New York, New York 10065-8440 Telephone: (212) 336-8330 Fax: (212) 336-8340 E-mail: [email protected] Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: (713) 651-9366 Fax: (713) 654-6666 E-mail: [email protected] Att

ing the forgoing objection, Respondents will produce responsive documents, if any, that may exist. 19. All documents and communications concerning Jeffrey Epstein's involvement in J.P. Morgan's investment in Highbridge Capital Management, including but not limited to the introduction of Glenn Dubin to Jes Stale

l documents and communications concerning Jeffrey Epstein's involvement in J.P. Morgan's investment in Hig

19. All documents and communications concerning Jeffrey Epstein's involvement in J.P. Morgan's investmen

. Stephen D. Susman Seth Ard 654 Madison Avenue, 5th Floor New York, New York 10065-8440 Fax: (212) 336-8340 E-mail: E-mail: Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Fax: (713) 654-6666 E-mail: 7 EFTA00729276 Attorneys for Respondent Counter-Claim

date, authors, recipients, type of document, subject matter, number of pages, and the basis of the claim of privilege asserted. DEFINITIONS 1. "Epstein" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepers, Inc. and includes all their directors, officers, employees, representatives, agen

recipients, type of document, subject matter, number of pages, and the basis of the claim of privilege asserted. DEFINITIONS 1. "Epstein" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepers, Inc. and includes all their directors, officers, employees, representatives, agents, parents, subsidiari

ilege asserted. DEFINITIONS 1. "Epstein" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeeper

described on Exhibit A hereto. Dated: , 2011 Hon. Anthony J. Carpinello (Ret.) Arbitrator Requested by: SUSMAN GODFREY L.L.P. Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: (713) 651-9366 Fax: (713) 654-6666 E-mail: Attorneys for Respondent Coun

sponds to the individual requests as follows: Documents Requested Request No.1: 2 EFTA00729260 All documents concerning any investments made by Epstein, Jeepers or FTC in the Fund, including, but not limited to, all documents concerning: (a) any decision to make, retain or liquidate such investment

Y L.L.P. Stephen D. Susman Seth Ard 654 Madison Avenue, 5'h Floor 8440 Fax: (212 336-8340 E-mail: E-mail: 10 EFTA00729268 Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Attorneys for Respondent Counter-Claimants Financial Trust Company, Inc. and Jeepers, Inc. 11 EFTA00729269

ibble, Jr. Joseph S. Grinstein Bryce T. Barceb Jeffrey David SUSMAN GODFREY L.L.P. 1000 Louisiana, Sui

n 500 E Street, S.W., Suite 401 Washington, D.C. 20436 Via E-mail: For Respondent Aliphcom D/B/A Jawbone and Bodymedia, Inc. Kalpana Srinivasan SUSMAN GODFREY L.L.P. 1901 Avenue of the Stars, Suite 950 Los Angeles, California 90067-6029 Telephone: (310) 789-3100 Facsimile: (310) 789-3150 Via E-mail: 9 - i -.I