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

ubscription agreement and to execute the Fund's LPA. Each time, it was "admitted" as a limited partner in the Fund. Section 9.1 of the LPA states: Complete Withdrawals of Capital Account. Complete withdrawals of a Limited Partner's Capital Account may be made as of the last Business Day of the calendar quarter ending at least two y

omise 42 B. Jeepers Has No Claim for Fraud Because Mr. Zwirn Fully Disclosed All Accounting Irregularities and Made No Misrepresentations to Mr. Epstein 43 C. Jeepers's Claim for Breach of Fiduciary Duty or Negligent Misrepresentation Against Mr. Zwirn and the Other Zwirn Parties 47 III. JEEPER

in June 2009, VRF I LLC became the managing member of the Fund. The dispute centers on whether or not Jeepers, an investment vehicle controlled by Jeffrey Epstein, complied with the rules of the Fund when it attempted to withdraw money from the Fund. Claimants have no direct financial interest in this dispute

not Jeepers, an investment vehicle controlled by Jeffrey Epstein, complied with the rules of the Fund whe

Irregularities and Made No Misrepresentations to Mr. Epstein 43 C. Jeepers's Claim for Breach of Fiduciary

wo years. Article IX, Section 9.1 of the LPA thus describes the process for making a complete withdrawal of a limited partner's "Capital Account": Complete Withdrawals of Capital Account. Complete withdrawals of a Limited Partner's Capital Account may be made as of the last Business Day of the calendar quarter ending at least two y

W: Fina AM This is what I sent to you. We had also sent to Harry Beller and reviewed with him in excruciating detail. We will resend to Harry and Jeffrey and go through it again in as much detail as they would like. This e-mail message is intended only for the named recipient(s) above. It may contain

ank you. EFTA00621796 Financial Trust Company Epstein & Co.) Initial Inv. Oats Liquidity Redemption

ner in excess of its ratable share, the Partnership shall reimburse such party for such expenses. Article IX. WITHDRAWAL BY LIMITED PARTNERS 9.1. Complete Withdrawals of Capital Account. Complete withdrawals of a Limited Partner's Capital Account may be made as of the last Business Day of the calendar quarter ending at least two ye