Epstein Secrets

eepers, Inc., Respondent ALAN W. KORNSERG DANIEL J. KRAMER 2AVID K. LAKTIONIR TIOTHIN P LAMB* MOON . Lang; DANIEL4 kgr•ELL XIAO'YLI R • LIU JEFFREY MARELL MARCO MASOTTI EDWIN S. MAYNARD DAVID W. MAYO ELIZABETH R. MCCOLM MARK I F. MENDELSOHN • SY S. MYERSON J MN E NATHAN NE NYARADY

L L REISNER WALTER G. RICCIARIM WALTER RIEMAN RICHARD A. ROI1N ANDREW N ITO NIIRG J ROTHEN•ERG JACQUELINE P RAPHAEL M RUSSO JE CCCCC D. SA EPSTEIN JEFFREY SARROSAMUELS rt KENNETH MNIMITAEIDER ROBERT •. SCHUMER JAMES H. SCHWAB ./Q14N M. SCOTT STEPHEN J. IMSHAK DAVID . MOSES •ILVERMAN

G J ROTHEN•ERG JACQUELINE P RAPHAEL M RUSSO JE CCCCC D. SA EPSTEIN JEFFREY SARROSAMUELS rt KE

amounts as the General Partner shall determine." Mr. Epstein concedes he did not read the LPA prior to investi

the doubt, therefore, its motion would need to be construed as a motion for the exclusion, in considering its claim 2 EFTA00614001 for breach of the Side Letter, of all evidence other than the LPA. Even as so interpreted, the motion should fail.' According to Jeepers, all of the evidence (other than the LPA

omise 42 B. Jeepers Has No Claim for Fraud Because Mr. Zwirn Fully Disclosed All Accounting Irregularities and Made No Misrepresentations to Mr. Epstein 43 C. Jeepers's Claim for Breach of Fiduciary Duty or Negligent Misrepresentation Against Mr. Zwirn and the Other Zwirn Parties 47 III. JEEPER

in June 2009, VRF I LLC became the managing member of the Fund. The dispute centers on whether or not Jeepers, an investment vehicle controlled by Jeffrey Epstein, complied with the rules of the Fund when it attempted to withdraw money from the Fund. Claimants have no direct financial interest in this dispute

not Jeepers, an investment vehicle controlled by Jeffrey Epstein, complied with the rules of the Fund whe

Irregularities and Made No Misrepresentations to Mr. Epstein 43 C. Jeepers's Claim for Breach of Fiduciary

eepers's "entire capital account" at the "earliest possible date" (the "February 2007 Withdrawal Demand") (Exhibit M). The letter argued that, under the Side Letter, Jeepers was entitled to withdraw its entire capital account "as of the last day of the calendar quarter 19 EFTA00613963 ending at least two yea

AGREEMENT AND GENERAL RELEASE This Settlement Agreement and General Release (this "Agreement"), dated as of February_, 2014, is made by and between Jeffrey Epstein ("Epstein"), Andr-ew—Par-kas ("Furless"}„ Island Global Yachting Facilities Ltd., a Cayman Islands exempted company ("IGYF"), and IGY-AYH St. Thoma

RAL RELEASE This Settlement Agreement and General Release (this "Agreement"), dated as of February_, 2014, is made by and between Jeffrey Epstein ("Epstein"), Andr-ew—Par-kas ("Furless"}„ Island Global Yachting Facilities Ltd., a Cayman Islands exempted company ("IGYF"), and IGY-AYH St. Thomas Holdings

ed as of February_, 2014, is made by and between Jeffrey Epstein ("Epstein"), Andr-ew—Par-kas ("Furless"}

use a slip at American Yacht Harbor Marina (the mina-at-the-"Facilityp for a vessel up to 75 feet in length on the terms and conditions set forth in the Side Letter. The-Porties-agree-that-the-right-to-use-seid-slip-shall-eontinue-fe-be-preyided unfler4he-prei4siens-ef-the4ide-Iretter-and-this-Seetien--3-shall-r