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s agent Glenn Dubin, to reduce his demand for a total withdrawal of $133 million to only $80 million. But the money was never paid. Mr Dubin and Mr Epstein are in lock step with regard the details of these conversations . However Dan Zwirn, the general partner, of the fund had just been notified of gro
efore FTC made its demand. This is an attempt to turn it into a classic swearing match. But it has no relevance to the $80 million contract claim. Jeffrey Epstein clearly spoke to Dan Zwirn and Glenn Dubin, only Dan Zwirn disputes this, before making the $80 million demand and promises were made; however, th
tial because if word got out to the press and the market, there could very well be a run on the bank. And the incentives for GD to make DZ satisfy JE were even greater: in addition to 18 years of personal and family friendship, GD was responsible for each of JE's contributions to the Fund and in
no relevance to the $80 million contract claim. Jeffrey Epstein clearly spoke to Dan Zwirn and Glenn Dub
his money out of the Fund in November 2006. When Mr. Epstein heard about Mr. Gruss's departure, he immediatel
nilla. The contractual language is clear, and the legal principles are solid. Under the terms of the 2005 Letter Agreement between FTC/Jeepers and the Zwirn Fund, FTC was entitled to withdraw its "Capital Account" on March 31, 2007, so long as it gave notice before December 1, 2006. Notice was given, after a
to a managed account and Zwim would consult with me about various issues. 3. One of the first investors that I directed to invest in the Fund was Jeffrey Epstein ("Epstein"). Epstein was both a personal friend of mine and a major client of my firm, Highbridge Capital Corporation. Between 2002 and 2005, Epste
the dispute. During these discussions with Epstein, Zwim did not dispute that Epstein had the right to withdrawal all of his money. I assumed that Epsteins withdrawal would be accomplished quickly. I my self have never encountered a provision that only allowed total withdrawals as opposed to partial wi
vestors that I directed to invest in the Fund was Jeffrey Epstein ("Epstein"). Epstein was both a personal
rm, Highbridge Capital Corporation. Between 2002 and 2005, Epstein (through an entity called Financial Trust Company, Inc.) invested $80 million in the Zwirn Fund. 4. In early September 2006, Zwim informed me that he was firing the Fund's then-Chief Financial Officer, Perry Gruss. Zwim said that he discovere
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
bridge Managed Account. EFTA00791902 6. All documents concerning Highbridge's knowledge during 2006 and 2007 of the accounting irregularities at the Zwirn Fund or Zwim Entities as described in Epstein's Claim. 7. All documents concerning Highbridge's disclosure to Epstein of Highbridge's knowledge of the
the contract language governs the procedures surrounding withdrawal requests. 13. The language in the January 11, 2005 letter from Daniel Zwirn to Jeffrey Epstein states: In accordance with section 9.1 of the Amended and Restated Limited Partnership Agreement, dated as of May 1, 2003 (as amended to the dote h
uary 11, 2005 letter from Daniel Zwirn to Jeffrey Epstein states: In accordance with section 9.1 of the Am
the January 11, 2005 letter from Daniel Zwirn to Jeffrey Epstein states: In accordance with section 9.1 o
ment. This sort of language is conspicuously absent from the January 11, 2005 Letter Agreement between Zwirn and FTC. 18. I have been informed that the Zwirn Fund has suggested that every hedge fund must track each investment separately in order to calculate, for example, the high-water mark. This is simply no
Entities connected to both Jeffrey Epstein and the Zwirn Fund