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

d to the breach of contract claims against D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC ((the) "Fund"), [and] D.B. Zwim Partners, LLC, D.B. Zwim & Co. L.P., DBZ GP LLC, Zwirn Holdings LLC, and Daniel Zwirn [together, the "Zwim Parties")." (Financial Trust Company, Inc.'s and

. 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

, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on their behalf. 2. "Zwim Parties" means Daniel Zwim, D.B. Zwim Partners, LLC, D.B. Zwim & Co, L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their members, employees, representatives, agents, predecessors,

. 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

agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on their behalf. 2. "Zwirn Parties" means Daniel Zwirn, D.B. Zwim Partners, LLC, D.B. Zwirn & Co, L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their members, employees, representatives, agents, predecessors,

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

"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. Zwim & Co., L.P., DBZ GP, LLC and Zwim Holdings, LLC (collectively, the "Zwim Entities") and Daniel Zwim (together with the Zwim Entitie

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

CLAIMS OF DEFENDANTS D.B. ZWIRN & CO., L.P. AND D.B. ZWIRN PARTNERS, LLC JURY TRIAL DEMANDED Defendants D.B. Zwim & Co., L.P. (the "Company") and D.B. Zwim Partners, LLC ("DBZLLC"), by their attorneys Cooley Godward ICronish LLP, answer the Complaint and Jury Demand herein as follows: I. Aver that in 2006, de

uss had obligations to the Company and DBZLLC in addition to those set forth in the unexecuted Supplementary Agreement among D.B. Zwim & Co., L.P., D.B. Zwim Partners, LLC and Perry Gruss (the "Supplementary Agreement"). 58. Deny the allegations of Paragraph 58, except admit that Gruss was a partner in the Comp