Epstein Secrets

nvestment in the D.B. Zwirn Special Opportunities Fund (the "Fund"). Jeepers alleges that during a conversation with Mr. Zwim on November 13, 2006, Jeffrey Epstein, Jeepers' owner, asked to redeem Jeepers' entire investment (worth approximately $135 million at that time). Jeepers alleges that Mr. Zwim promised

ner, asked to redeem Jeepers' entire investment (worth approximately $135 million at that time). Jeepers alleges that Mr. Zwim promised that if Mr. Epstein sought to redeem only $80 million of Jeepers' investment, that request would be honored quickly.2 We contend that Mr. Epstein's allegations arc a r

conversation with Mr. Zwim on November 13, 2006, Jeffrey Epstein, Jeepers' owner, asked to redeem Jeepers

. Jeepers alleges that Mr. Zwim promised that if Mr. Epstein sought to redeem only $80 million of Jeepers' in

formerly served as Executive Vice President for Enforcement of NASD and as Chief Litigation Counsel at the SEC. Gibson Dunn, with the assistance of Deloitte & Touche, reviewed over a million documents and interviewed 23 witnesses, including Mr. Gruss on five separate occasions. Gibson Dunn made two presentations

kground 2 I. DBZ's Investment Strategy 3 2. Mr. Zwirn's Role at DBZ 3 3. Mr. Dubin's Involvement with DBZ 4 4. DBZ's Lock-Ups 4 C. Mr. Epstein's Relationship with Mr. Dubin 6 D. FTC's Investments in the Fund 7 E. Accounting Improprieties at DBZ 8 F. DBZ's Discovery of Accounting Imp

Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc. (together, "FTC"). Preliminary Statement At no time did Daniel Zwim promise Jeffrey Epstein that FTC could immediately withdraw $80 million of its investments in DBZ's Fund. Mr. Epstein's claim that Mr. Zwim made such a promise is a newly

ary Statement At no time did Daniel Zwim promise Jeffrey Epstein that FTC could immediately withdraw $80

volvement with DBZ 4 4. DBZ's Lock-Ups 4 C. Mr. Epstein's Relationship with Mr. Dubin 6 D. FTC's Inves

nvestments. Mr. Zwim and Mr. Epstein scheduled a meeting on November 21, 2006, that was to include Mr. Dubin, Mr. Cutler, Mr. Lee, Fried Frank, and Deloitte & Touche. The main purpose of the meeting was to give Mr. Epstein comfort about the value of FTC's investments in the Fund. Mr. Epstein cancelled the meetin

Suite 920 Sherman Oaks, CA 91403 Vincent S. Green, Esq. Nemecek & Cole 15260 Ventura Boulevard Suite 920 Sherman Oaks, CA 91403 VIA U.S. MAIL Jeffrey Epstein 9 E. 71st Street New York, NY 10021 6795 North Palm A Floor, Fresno C 7 telephone. facsando: ;menet littplivnyw.adr.orst @nit\ Arcyta 341 )

0 Sherman Oaks, CA 91403 VIA U.S. MAIL Jeffrey Epstein 9 E. 71st Street New York, NY 10021 6795 North

Suite 920 Sherman Oaks, CA 91403 VIA U.S. MAIL Jeffrey Epstein 9 E. 71st Street New York, NY 10021 67

Court, 1975-80; Attorney, Private Practice, 1971-75; Deputy California Attorney General, 1969-71; Certified Public Accountant, Haskins & Sells (now Deloitte & Touche), 1964-69. Experience Since 1987, Senior Litigator at Jones Day concentrating in appeals and complex commercial litigation in federal and state co

NO.: 09-CV-80591-MARRAJJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE NO. 101'

9 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARRAJJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE NO. 101'S RESPONSE TO DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT AS MODIFIED BY DEFENDANT'S

ever been allowed is misplaced; this case involved only a single violation of a predicate statute. Moreover, Defendant's reliance on its own Doe vs. Epstein line of cases is, at a minimum, premature. Accordingly, in the instant case, not only was it proper for Plaintiff to plead multiple counts in the

a "very high burden" on a defendant to show that a "plaintiff cannot conceivably prove any set of facts that would entitle him to relief." Beck v. Deloitte & Touche et aL, 144 F.3d 732, 735-36 (11th Cir. 1998); accord N.J. Inc. v. Nw. Bell Tel. Co., 492 U.S. 229, 249-50 (1989). The FAC satisfies the aforementi

From: "Jeffrey E." <jeevacation(rgmail.com> To: Richard Kahn Subjec

From: "Jeffrey E." <jeevacation(rgmail.com> To: Richard Kahn Su

sessed their effectiveness on a quarterly basis in connection with the requirements of the Sarbanes-Oxley Act. PRIOR POSITIONS: Senior Accountant, Deloitte & Touche, LLP — Audited publicly traded investment banks and private equity firms. Senior Accountant, Rothstein, Kass & Co., M.— Audited various hedge funds

on October 5, 2009 and by Federal Express upon: Jeffrey L. Liddle, Esq. Liddle & Robinson, LLP 800 Thir

ed Gibson Dunn & Crutcher LLP ("Gibson Dunn") to conduct a thorough internal investigation of all potential accounting issues. Gibson Dunn retained Deloitte & Touche as a special accountant for its investigation. The Company made appropriate disclosures and self-reported these issues to the United States Securit

From: Richard Kahn < Sent: Friday, May 29, 2015 3:56 PM To: jeffrey E. Subject: resume from Russell Attachments: JB.docx; Untitled attachment 00152.htm attached is a resume from Russell please =dvise thank you Rich

terly basis in connection with the requirements =f the Sarbanes-Oxley Act. 4 EFTA_R1_02120868 EFTA02710275 PRIOR POSITIONS: Senior =ccountant, Deloitte & Touche, LLP — Audited publicly traded =nvestment banks and private equity firms. Senior =ccountant, Rothstein, Kass & Co., P.C. — Audited various =edge fun