Epstein Secrets

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

should be entered for the Zwirn Respondents. Dated: July 11, 2011 New York, New York LANKLER SIFFERT & WOHL LLP By: II ert Daniel E. Reynolds Andrew S. Lee 500 Fifth Avenue ailig York 10110 Email: Email: Email: Attorneys for Third-Party Respondent Daniel Zwirn COOLEY LLP By: Wiliagithesu Willia

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

n/k/a Irvington GP, LLC), and Zwirn Holdings, LLC (n/k/a Irvington Holdings, LLC). LANKLER SIFFERT & WOHL LLP By: John S e Daniel E. Reynolds Andrew S. Lee 500 Fifth Avenue New York, New York 10110 Attorneys for Third-Party Respondent Daniel Zwirn 6 EFTA00729309

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

ondents D.B. Zwirn Partners. LLC, D.B. Zwirn & Co., L.P., DBZ GP, LLC, and Zwirn Holdings, LLC LANKLER IFFE HL LLP By: Jo Daniel E. Reynolds Andrew S. Lee 500 Fifth Avenue York 10110 Email: Email: Email: Attorneys for Third-Parry Respondent Daniel Zwirn 3 EFTA00665947