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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
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK IN THE MATTER OF FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC
. 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
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants, v. JEEPERS, INC. Respondents,
. 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
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants, v. JEEPERS, INC. Respondents,
. 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
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants, v. JEEPERS, INC. Respondents,
Inc.'s ("Jeepers") (together, "Third-Party Claimants") Statement of Counterclaim and Third-Party Claim. 2. Among other things, Zwim never promised Jeffrey Epstein ("Epstein") that the Fund would honor a withdrawal request for $80 million, or any withdrawal request that was not made in accordance with the cont
(together, "Third-Party Claimants") Statement of Counterclaim and Third-Party Claim. 2. Among other things, Zwim never promised Jeffrey Epstein ("Epstein") that the Fund would honor a withdrawal request for $80 million, or any withdrawal request that was not made in accordance with the contractual re
aim. 2. Among other things, Zwim never promised Jeffrey Epstein ("Epstein") that the Fund would honor a
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants, v. JEEPERS, INC. Respondents,
esignations. Claimants may call the following witnesses during arbitration to offer evidence in support of their claims and defenses: Daniel Zwim; Jeffrey Epstein; David Lee; Doug Cardoni; Elise Hubsher; Brad Flood; Allyson Alimansky; and Heath Weisberg. Henry Bregstein of Katten Muchin Rosenman LLP may
their claims and defenses: Daniel Zwim; Jeffrey Epstein; David Lee; Doug Cardoni; Elise Hubsher; Brad
port of their claims and defenses: Daniel Zwim; Jeffrey Epstein; David Lee; Doug Cardoni; Elise Hubshe
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK IN THE MATTER OF FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. Reference No
pport of their claims and defenses: Daniel Zwim Jeffrey Epstein David Lee Doug Cardoni Elise Hubsher
Respondents may call the following witnesses during the arbitration hearing to offer evidence in support of their claims and defenses: Daniel Zwim Jeffrey Epstein David Lee Doug Cardoni Elise Hubsher Brad Flood Allyson Alimansky Third-Party Respondents reserve the right not to call the above witnesses. Th
their claims and defenses: Daniel Zwim Jeffrey Epstein David Lee Doug Cardoni Elise Hubsher Brad Flo
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK IN THE MATTER OF FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. Reference No
esignations. Claimants may call the following witnesses during arbitration to offer evidence in support of their claims and defenses: Daniel Zwim; Jeffrey Epstein; David Lee; Doug Cardoni; Elise Hubsher; Brad Flood; Allyson Alimansky; and Heath Weisberg. Henry Bregstein of Katten Muchin Rosenman LLP may
their claims and defenses: Daniel Zwim; Jeffrey Epstein; David Lee; Doug Cardoni; Elise Hubsher; Brad
port of their claims and defenses: Daniel Zwim; Jeffrey Epstein; David Lee; Doug Cardoni; Elise Hubshe
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK IN THE MATTER OF FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. Reference No
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
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants, - againstJEEPERS, INC., Respond
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
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants, - against - JEEPERS, INC., Respo
Entities connected to both Jeffrey Epstein and JUDICIAL ARBITRATION

Prince Andrew
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Glenn Dubin
PERSON
Jes Staley
PERSON
Stephen Hawking
PERSON
Financial Trust Company
ORGANIZATION
Houston
LOCATIONZwirn
PERSONJeepers, Inc.
ORGANIZATIONHighbridge
ORGANIZATIONWEISS
ORGANIZATIONZWIRN HOLDINGS
ORGANIZATIONDANIEL ZWIRN
PERSONAnthony J. Carpinello
PERSON
Highbridge Capital Management
ORGANIZATIOND.B. Zwim
PERSONDavid Lee
PERSONStephen D. Susman
PERSONSeth Ard
PERSON