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

10110 Email: Email: Email: Attorneys for Third-Party Respondent Daniel Zwirn COOLEY LLP By: Wiliagithesu William J. wartz William O'Brien Arastu K. Chaudhury 1114 Avenue of the Americas • ork 10036 Email: Email: Email: Attorneys for Third-Party Respondents D.B. Zwirn Partners, LLC, D.B. Zwirn & Co.

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

tations to the Third-Party Claimants. 5 EFTA00729308 Dated: New York, New York June 25, 2010 COOLEY LLP By: StX A an Levine William O'Brien Arastu K. Chaudhury 1114 Avenue of the Americas Attorneys for Third-Party Respondents D.B. Zwirn Partners, LLC (n/k/a Irvington Associates, LLC), D.B. Zwirn & Co., L

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

s list to the extent additional witnesses are identified. Dated: May 20, 2010 New York, NY COOLEY LLP By: William J. Schwartz William O'Brien Arastu K. Chaudhury 2 EFTA00665946 1114 Avenue of the Americas York 10036 Email: Email: Email: Attorneys for Third-Party Respondents D.B. Zwirn Partners. LLC,