Epstein Secrets

vent of a third-party claim brought against them in which certain of the allegations in such a claim were somewhat similar to those asserted by Mr. Epstein (or his company, Jeepers, Inc.) in the Arbitration. Claimants believe the proposed release language for the New Agreement quoted above accurately c

INSELIG IJEFFREY D tArr I?. SAF KU° ERSTIIN JEFFREY B. SAMUEL0 DALE M. SARRO TERRY E. daRIMER KENN

claim were somewhat similar to those asserted by Mr. Epstein (or his company, Jeepers, Inc.) in the Arbitratio

t in advance exactly what new third-party claims could be brought against the Zwim Parties, how the pre-Arbitration agreements between the Fund and the Zwirn Parties might (or might not) apply to such claims, and how the currently proposed release language might (or might not) apply to such claims. Therefore, the

. 6. All documents concerning any request by any of the Third Party Claimants to withdraw any amounts from the Fund. 7. All documents concerning Jeffrey Epstein's involvement in J.P. Morgan's investment in Highbridge Capital Management, including but not limited to Your introduction to Jes Staley. 8. All do

ITIONS 1. "Third-Party Claimants" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepers, Inc.

. DEFINITIONS 1. "Third-Party Claimants" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepe

ense include terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communications between You on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communications between You on the one hand, and any of

. 6. All documents concerning any request by any of the Third-Party Claimants to withdraw any amounts from the Fund. 7. All documents 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

m's company which was also the investment manager of the Zwim Fund. 3. One of the early investors that I introduced to Zwim was Jeffrey Epstein ("Epstein"). Epstein was both a pssonal friend of mine and a long-time investor in TICC. My understanding is that beginning in 2002 Epstein invested assets in

. DEFINITIONS 1. "Third-Party Claimants" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepe

clude terms in the present tense. DOCUMENT REQUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

. 6. All documents concerning any request by any of the Third-Party Claimants to withdraw any amounts from the Fund. 7. All documents 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

n's company which was also the investment manager of the Zwim Fund. 3. One of the early investors that I introduced to Zwim was Jeffrey Epstein ("Epstein"). Epstein was both a personal friend of mine and a long-time investor in HCC. My understanding is that beginning in 2002 Epstein invested assets in

. DEFINITIONS 1. "Third-Party Claimants" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepe

clude terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

the "Effective Date") among: (i) Fortress VRF I LLC ("VRF I LLC") and Fortress Value Recovery Fund I LLC (the "Fund") (together, "Claimants"); (ii) Jeffrey Epstein, Jeepers, Inc. ("Jeepers") and Financial Trust Company, Inc. ("FTC") (collectively, the "Epstein Parties"); (iii) D.B. Zwim Partners, LLC, D.B. Zwi

"Withdrawal Requests"); WHEREAS, the Zwim Entities and the Fund denied that the 2006 and 2007 demands were proper requests for withdrawal, and the Epstein Parties disagreed with that position; WHEREAS, withdrawals from the Fund were suspended, and, since February 2008, the Fund has been engaged in the

I LLC (the "Fund") (together, "Claimants"); (ii) Jeffrey Epstein, Jeepers, Inc. ("Jeepers") and Financial

arties now manage or formerly managed, and any fund or account now or formerly managed by Claimant Fortress VRF I LLC or its affiliates; and (2) the Zwirn Parties and each of their past, present and future parents, subsidiaries and other affiliates, each of the predecessors, successors, heirs and assigns of e

VE RELEASE LANGUAGE is as follows: OPERATIVE RELEASE LANGUAGE "Except as provided in Paragraph E of this Part III of the Settlement Agreement, the Epstein Parties[I HAVE DEFINED THIS TERM FOR YOU BELOW JEFFREY], on behalf of themselves and, to the fullest extent permitted by law, each of the Epstein R

NGUAGE "Except as provided in Paragraph E of this Part III of the Settlement Agreement, the Epstein Parties[I HAVE DEFINED THIS TERM FOR YOU BELOW JEFFREY], on behalf of themselves and, to the fullest extent permitted by law, each of the Epstein Released Parties [I HAVE DEFINED THIS TERM FOR YOU BELOW

f the "Epstein Parties" and the "Epstein Released Parties" as used in the OPERATIVE RELEASE LANGUAGE above is as follows: The Epstein Parties means Jeffrey Epstein, Jeepers, Inc. and Financial Trust Company, Inc. The Epstein Released Parties means "the Epstein Parties and each of their past, present and futur

have at any time acted, or purported to act on behalf of any of the foregoing (the "Dubin Released Parties," except that, for the sake of clarity, the Zwirn Parties and any individuals or entities that are directly or indirectly controlled by one or more of the Zwirn Parties, shall not be considered Dubin Relea

ctions and these objections, Dubin will undertake a reasonable search for and produce responsive documents. Request No.7: All documents concerning Jeffrey Epstein's involvement in J.P. Morgan's investment in Highbridge Capital Management, including but not limited to Your introduction to Jes Staley. 8 EFTA01

. Request No.7: All documents concerning Jeffrey Epstein's involvement in J.P. Morgan's investment in Hig

ocuments. Request No.7: All documents concerning Jeffrey Epstein's involvement in J.P. Morgan's investmen

Instruction 2. SPECIFIC RESPONSES AND OBJECTIONS Request No.1: All documents concerning any communication between You on the one hand, and any of the Zwirn Parties on the other, concerning any of the ThirdParty Claimants. Response to Request No.1: Dubin objects to this Request on the grounds that it is overl

ocuments. Request No.7: All documents concerning Jeffrey Epstein's involvement in J.P. Morgan's investmen

s and these objections, Highbridge will undertake a reasonable search for and produce responsive documents. Request No.7: All documents 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 Stal

. Request No.7: All documents concerning Jeffrey Epstein's involvement in J.P. Morgan's investment in Hig

tion 2. SPECIFIC RESPONSES AND OBJECTIONS Request No.1: All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. Highbridge objects to the definition of "All" and "each" as vague, 6 EFTA01592057 R