Epstein Secrets

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

UE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., Respondent § Case No. 1425006537 and FINANCIAL TRUST COMPANY, INC. and § JEEPERS, INC., Counterclaimants and Third-Party Claimants § v. D.B. ZWIRN SPECIAL OPPORTUNITIES § FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and

y 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 Trust Company, Inc. and Jeepers, Inc. 1205876v1/011585 19 EFTA00722327 Timestamp: 8/16/2010 5:38 PM COT P

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

RF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counterclaimants and Third-Party Claimants v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B.

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-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc. EFTA00791898 JAMS ARBITRATION IN THE MATTER OF FORTRESS VRF I LLC and

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

RF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counterclaimants and Third-Party Claimants v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B.

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

RF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counterclaimants and Third-Party Claimants v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B.