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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
em, in effect, that the investigation had been terminated as to them. F. DBZ's Discovery of Accounting Improprieties and Response In Spring 2006, Lawrence Cutler, DBZ's Chief Compliance Officer, and David Proshan, DBZ's General Counsel, informed Mr. Zwirn of a potential accounting irregularity relating to DB
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
dicates that, in the spring of 2006, various potential accounting improprieties were discovered at the Fund. According to the deposition testimony, Lawrence Cutler, the Fund's Chief Compliance Officer, and David Proshan, the Fund's General Counsel, informed Mr. Zwirn of two potential accounting irregularities
sold to JPMC? 1 EFTA00624864 Timestamp: 7/212011 5:39:28 PM EST 2. GD was the point person at all time with regard to how the Fund dealt with JE? (198) a. He was JE's contact person or point person with the Fund? (201) b. He gave you directions as to who would call JE? (202) c. He would
11/13 $80m request? So the 2/14 demand by HB was simply a reiteration of the earlier request? 4) You assure GD that "we have done back flips for Jeffrey, and as a large, early and important investor, will continue to do so? c. Within 3 hours of your telling HB that he has absolutely no contractual
imate demise of the DB Zwirn SOFs- 15 EFTA00624878 Timestamp: 7/212011 5:39:28 PM EST a. In March of 2006, David Proshan, your Gen Counsel, and Lawrence Cutler, your chief compliance officer, came to you and told you that Tim Wong, a controller hired in Dec. 05 to conduct an internal audit of the manageme
Entities connected to both Jeffrey Epstein and Lawrence Cutler
Leon Black
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Lawrence Krauss
PERSON
Glenn Dubin
PERSONHarry Beller
PERSON
Financial Trust Company
ORGANIZATIONZwirn
PERSONPerry Gruss
PERSONHighbridge
ORGANIZATIONGibson Dunn
ORGANIZATION
Cutler
PERSONSchulte
PERSONAnthony J. Carpinello
PERSONDavid Lee
PERSONHubsher
PERSONCounter-Claimants
ORGANIZATIONHarry Davis
PERSONElise Hubsher
PERSONDavid Proshan
PERSON