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ton, Kevin Spacey and Chris Tucker to Africa in his private Boeing 727, to promote the former presidents anti-AIDS efforts.He was also friends with Prince Andrew, Duke of York, whom he hosted in his New York mansion in December 2010. In addition to his private island called Little St. James Island off of St.
nti-AIDS efforts.He was also friends with Prince Andrew, Duke of York, whom he hosted in his New York man
efforts.He was also friends with Prince Andrew, Duke of York, whom he hosted in his New York mansion in Decem
dents anti-AIDS efforts.He was also friends with Prince Andrew, Duke of York, whom he hosted in his New York mansion in Decem
cial Truk Company, Inc., 2 corporation organized and existing under the laws of the United States Virgin Islands ("FTC'), is the sole shareholder of Jeepers, Inc., a corporation organized and existing.under the laws of the United States Virgin islands ("Jeepers!), which has elected to be taxed as a qualified
TER G RICCIARDI WALTER RIEMAN RICHARD A. ROSEN ANDREW N ROSENBERG PETER J. ROTVAINSELIG IJEFFREY D t
im brought against them in which certain of the allegations in such a claim were somewhat similar to those asserted by Mr. Epstein (or his company, Jeepers, Inc.) in the Arbitration. Claimants believe the proposed release language for the New Agreement quoted above accurately captures the agreement parties r
ak ft nta rg ilIALIM Era URLDSTEIN DHAaren055, ANDREW G. GORDONal 821.121COV511.1Z0 P4-111 •LAN 6 SL
and Fortress Value Recovery Fund I LLC (together, "Claimants"), we write to seek an order compelling Respondents Financial Trust Company, Inc. and Jeepers, Inc. (together, "Jeepers/FTC") to produce certain documents in response to our First Set of Document Requests, dated August 17, 2010. The requested docu
FERT & WOHL LLP By: II ert Daniel E. Reynolds Andrew S. Lee 500 Fifth Avenue ailig York 10110 Email
ether, the "Zwim Respondents") submit this pre-hearing brief in opposition to the claims by 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
TER 0 RICCIARDI WALTER RICH•RDRitmAN A ROSEN ANDREW N ROSENBERG PE [A i , ROTHENGERG JACQUELINE P R
and Fortress Value Recovery Fund I LLC (together, "Claimants"), we write to seek an order compelling Respondents Financial Trust Company, Inc. and Jeepers, Inc. (together, "Jeepers/FTC") to produce certain documents in response to our First Set of Document Requests, dated August 17, 2010. The requested docu
Entities connected to both Prince Andrew and Jeepers, Inc.

Jeffrey Epstein
PERSON
Marc Rich
PERSONSouthern District
LOCATIONLeon Black
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
Richard Kahn
PERSONDarren Indyke
PERSON
Martha Stewart
PERSON
Prince Charles
PERSON
Stephen Hawking
PERSON
New York
LOCATIONMaria Farmer
PERSON
Stewart Oldfield
PERSON
Jes Staley
PERSONJane Doe
PERSON
Les Wexner
PERSON
Lawrence Krauss
PERSON
U.S. Virgin Islands
LOCATIONLarry Visoski
PERSON