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

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 19 EFTA00300221 PROO

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

phen 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 Claimants Financial Tr

individual subscribed on or after the date of Claimants' purchase of any limited partnership interest or other ownership interest in the Funds: (a) Jeffrey Epstein, (b) Harry Beller, (c) Darren Indyke, and (d) Lesley Groff. Response: FTC objects because this request seeks information that is not calculated to

lead to the discovery of relevant information and is overly burdensome. Subject to the forgoing, FTC will produce documents sufficient to show Mr. Epstein's educational and employment history to the extent such documents are readily available to FTC. 24. Documents sufficient to show Claimants' (a) ov

ete educational and employment background of (a) Jeffrey Epstein, (b) Harry Beller, (c) Darren Indyke, and

g, FTC will produce documents sufficient to show Mr. Epstein's educational and employment history to the exten

ue, 5th Floor New York, New York 10065-8440 Tele hone: Fax: E-mail: 19 997243v11011543 EFTA00731198 Harry P. Susman SUSMAN GODFREY . 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: (713) 651-9366 Fax: (713) 654-6666 E-mail: Attorneys for Claimants Financial Trust Company, In

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

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] Attorneys for Claimants F

ctors, representatives, agents, officers, consultants, attorneys, predecessors, successors or affiliates of Financial Trust Company, Inc., including Jeffrey Epstein. 6. The term "Jeepers" means Jeepers, Inc. The term includes past and/or present employees, directors, representatives, agents, officers, consulta

Company, Inc. or Jeepers, Inc., including Jeffrey Epstein. 5. The term "FTC" means Financial Trust Compan

l Trust Company, Inc. or Jeepers, Inc., including Jeffrey Epstein. 5. The term "FTC" means Financial Trus

h Ard 654 Madison Avenue, 5th Floor New York, New York 10065-8440 Telephone: Fax: E-mail: E-mail: Harry P. Susman SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002-5096 Telephone: Fax: E-mai : Attorneys for Respondent Counterclaimants and Third-Party Claimants Financial Tru

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

rd 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-Claimants Financial Trust C

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

o. 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 Counterclaimants and Third-

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

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