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

nated 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 DBZ's management fees. They may have also mentioned a

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

ounting 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 by June 2006: the early payment of management fees by the

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

t with JE? f. That letter was prepared by your assistant GC, Heath Weisberg, who sent it to HB with a copy to GD, yourself, Allyson Alimansky and David Proshan? g. Insofar as you know, FTC had nothing to do with the language that Mr. Weisberg chose to use? 7. As your boss for several years and then a se