Epstein Secrets

ing the forgoing objection, Respondents will produce responsive documents, if any, that may exist. 19. All documents and communications 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

l documents and communications concerning Jeffrey Epstein's involvement in J.P. Morgan's investment in Hig

19. All documents and communications concerning Jeffrey Epstein's involvement in J.P. Morgan's investmen

d without waiving the forgoing objection, Respondents will produce responsive documents, if any, that may exist. 3. All communications with any of the Zwirn Entities. Response: Respondents object because this request is overly broad, vague, unduly burdensome, designed to harass Respondents and/or third parties,

date, authors, recipients, type of document, subject matter, number of pages, and the basis of the claim of privilege asserted. DEFINITIONS 1. "Epstein" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepers, Inc. and includes all their directors, officers, employees, representatives, agen

recipients, type of document, subject matter, number of pages, and the basis of the claim of privilege asserted. DEFINITIONS 1. "Epstein" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepers, Inc. and includes all their directors, officers, employees, representatives, agents, parents, subsidiari

ilege asserted. DEFINITIONS 1. "Epstein" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeeper

d in Epstein's Claim. 8. All documents concerning the repayment of advances made from the Highbridge Managed Account to other funds controlled by the Zwirn Entities, including without limitation any documentation of such advances, any promissory notes, documentation of whether such funds were repaid, and any di

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

Suite 5100 1000 Louisiana Houston, TX 77002-5096 3. All notices to the Zwim Entities with respect to this Settlement Agreement shall be sent to the Zwirn Entities at and in care of: 12 EFTA00298492 CONFIDENTIAL William O'Brien Cooley LLP The Grace Building 1114 Avenue of the Americas New York, NY 10036