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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
t class mail, this day of Brad S. Karp Allan Arffa Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019 John S. Siffert Lankier Siffert & Wohl LLP 500 Fifth Avenue, 33rd Floor New York, NY 10110 1043197v1/011585 20 , on: Alan Levine Cooley LLP The Grace Build
he Americas New York, NY 10036 Suite 3800 1x01 Third Avenue Seattle, WaShingtongazoa-3000 Re: Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein vs. D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, et. al. Dear Sirs: As you are aware, I represent Jeffrey
very Fund I LLC, et. al. Dear Sirs: As you are aware, I represent Jeffrey Epstein, Financial Trust Company, Inc., and Jeepers, Inc. (collectively "Epstein") in connection with claims regarding an investment in D.B. Zwirn Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC. I am wr
Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein vs. D.B. Zwim Special Opportunities Fund
NT PURPOSES ONLY Via E-mail & First Class Mail Brad S. Karp Paul, Weiss, Rifkind, Wharton & LLP 1285 Avenue of the Americas New York, NY 10019 John S. Siffert Lankier Siffert & Wohl LLP 500 Fifth Avenue, 33rd Floor New York, NY 10110 Alan Levine Garrison Cooley LLP The Grace Building 1114 Avenue of t
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
is 17th day of August, on: Brad S. Karp Allan Arffa Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019 John S. Siffert Lankier Siffert & Wohl LLP 500 Fifth Avenue, 33rd Floor New York, NY 10110 Alan Levine Cooley LLP The Grace Building 1114 Avenue of the Americ
. 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
York, New York 10036 Counsel for Third-Party Respondents D.B. Zwirn Partners, LLC, D.B. Zwirn & Co., L.P., DBZ GP, LLC, and Zwirn Holdings, LLC John S. Siffert, Esq. Daniel E. Reynolds, Esq. Lankier Siffert & Wohl, LLP 500 Fifth Avenue, 33rd Floor w ork 10110 Counsel for Third-Party Respondent Daniel Z
. 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
10036 iii 479-6000 Counsel for Third-Party Respondents D.B. Zwirn Partners, LLC, D.B. Zwirn & Co., L.P., DBZ GP, LLC, and Zwirn Holdings, LLC John S. Siffert, Esq. Daniel E. Reynolds, Esq. Lankier Siffert & Wohl, LLP 500 Fifth Avenue, 33rd Floor New York, New York 10110 212 921-8399 Counsel for Third
. 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
k 10036 (212) 479-6000 Counsel for Third-Party Respondents D.B. Zwirn Partners, LW, D.B. Zwirn & Ca, L.P., DBZ GP, LW, and Zwirn Holdings, LLC John S. Siffert, Esq. Daniel E. Reynolds, Esq. Lankier Siffert & Wohl, LLP 500 Fifth Avenue, 33rd Floor New York, New York 10110 (212) 921-8399 Counsel for Thi
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
New York, NY 10036-7798 4. All notices to Daniel Zwim with respect to this Settlement Agreement shall be sent to Daniel Zwim at and in care of: John S. Siffert Lankier Siffert & Wohl LLP 500 Fifth Ave, 33rd Floor New York, NY 10110 5. All notices to shall be sent to at and in care of: with respect to
ine Garrison Cooley LLP The Grace Building 1114 Avenue of the Americas New York, NY 10036 Re: Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein vs. D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, et. al. Dear Sirs: As you are aware, I represent Jeffrey
very Fund I LLC, et. al. Dear Sirs: As you are aware, I represent Jeffrey Epstein, Financial Trust Company, Inc., and Jeepers, Inc. (collectively "Epstein") in connection with claims regarding an investment in D.B. Zwirn Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC. I am wr
Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein vs. D.B. Zwim Special Opportunities Fund
NT PURPOSES ONLY Via E-mail & First Class Mail Brad S. Karp Paul, Weiss, Rifkind, Wharton & LLP 1285 Avenue of the Americas New York, NY 10019 John S. Siffert Lankier Siffert & Wohl LLP 500 Fifth Avenue, 33rd Floor New York, NY 10110 Alan Levine Garrison Cooley LLP The Grace Building 1114 Avenue of t
simply not true. On July 25, 2011, Mr. Zwim believed that he was releasing Claimants only from claims related to those that had been brought by Mr. Epstein in the Arbitration, and not any potential claim for fraud or breach of fiduciary duty brought by a Fund investor other than Mr. Epstein. Claimants a
claims related to those that had been brought by Mr. Epstein in the Arbitration, and not any potential claim f
hat our proposed language be adopted, or that in the alternative, Your Honor adopt the language in the Settlement Terms. Respectfully, Ce-Otthee> John S. Siffert cc: Allan Arffa, Esq. (by email) Chet Lipton, Esq. (by email) EFTA00308107
Entities connected to both Jeffrey Epstein and John S. Siffert
Darren Indyke
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Glenn Dubin
PERSON
Jes Staley
PERSON
Stephen Hawking
PERSON
Seattle
LOCATION
Financial Trust Company
ORGANIZATIONWeiss
PERSON
Brad S. Karp
PERSONWharton & Garrison LLP
ORGANIZATIONRifkind
PERSON
Dallas
LOCATION
Houston
LOCATIONZwirn
PERSONJeepers, Inc.
ORGANIZATIONPerry Gruss
PERSOND.B. Zwirn
ORGANIZATIONAnthony J. Carpinello
PERSON