Epstein Secrets

DECKELBAUM JAMES M DUBIN ALICE SIELISLE EATON ANDREW J EHRLICH enyTootc2:3 12GEN MARL; ALCONE ANDRE

the "oral contract" claim and Claimants' claim for a declaration of Jeepers's rights with respect to the Fund. Additionally, we understand that the Zwirn Parties contend that the extrinsic evidence is, in any event, relevant to their "exculpatory clause" defense to Jeepers's fraud and breach of fiduci

and contemporaneous e-mails concerning the Side Letter, (see, e.g., December 2004 E-mail Correspondence between Mr. Zwim and Mr. Dubin, Ex. K (Mr. Zwirn: "we're done, ftc in for $20mi1 jan 1 L.P. . . . This is the last 2 year money will 20 EFTA00614019 take from anyone of course"; Mr. Dubin: "of c

FERT & WOHL LLP By: II ert Daniel E. Reynolds Andrew S. Lee 500 Fifth Avenue ailig York 10110 Email

were invalid and set forth the schedule of eligible withdrawal dates for FTC's investments. FTC did not respond to the letter by claiming that Mr. Zwirn had promised to honor FTC's demand for $80 million. 17 EFTA00613924 FTC subsequently submitted a request for complete withdrawal on February 13,

Zwinz & Co., L.P., DBZ GP, LLC, and Zwirn Holdings, LLC EFTA00613904 Table of Contents Preliminary Statement 1 Statement of Facts 2 A. Mr. Zwirn's Personal Background 2 B. DBZ Background 2 I. DBZ's Investment Strategy 3 2. Mr. Zwirn's Role at DBZ 3 3. Mr. Dubin's Involvement with D

Epstein and Ghislaing orniwatch _Pjn6roJaall Maxwell for their ownt use and for use by several others, Perversion of Justice, The Miami including Prince Andrew[411 and retired Harvard Law Herald, November 29, 2018. M4 professor Alan Dershowitz. -2-1 Giuffre also claimed Epstein, Maxwell and others had physic

by alleged victim Virginia Roberts against Prince Andrew had no bearing on the lawsuit by alleged yictims

deem his investment after he was informed of accounting irregularities in the fundiN By this time, his investment had grown to $140 million. The DB. Zwirn fund refused to redeem the investment Hedge funds that invest in illiquid securities typically have years-long "lockups" on their capital for all i

TER G RICCIARDI WALTER RIEMAN RICHARD A. ROSEN ANDREW N ROSENBERG PETER J. ROTVAINSELIG IJEFFREY D t

) It is also important to note that similar language is used in other portions of the New Agreement for other releases—including the release of the Zwirn Parties by EFTA00306063 PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP Hon. Anthony J. Carpinello (Ret.) 4 Claimants—that was based on release la

T & WOHL LLP By: John S e Daniel E. Reynolds Andrew S. Lee 500 Fifth Avenue New York, New York 1011

ations concerning their withdrawal requests, and never documented the promise in any of their communications with any Third-Party Respondent. Also, Zwirn's disclosures to investors were neither misrepresentations, misleading nor negligent. FIRST AFFIRMATIVE DEFENSE 3. Epstein communicated to the Fun

r addressed to the CEO of Telstra Head Office, Mr Andrew Penn, Melbourne, Victoria from the Norwood Post

edeem his investment after he was informed of accounting irregularities in the fund.k°1 By this time, his investment had grown to $14O million. The Zwirn fund refused to redeem the investment. Hedge funds that invest in illiquid securities ically have years-long "lockups" on their capital for all in

. SIFFERT, ESQ. 9 DANIEL E. REYNOLDS, ESQ. 10 ANDREW S. LEE, ESQ. 11 12 ALSO PRESENT: 13 RICK NOB

ments in the fund. 9 Q. And did you discuss what the lockup 10 would be for those increases? 09:19:07 11 A. I don't recall. 12 Q. Did Mr. Zwirn tell you that the lockup 13 for those -- did Mr. Dubin tell you that the 14 lockup for any subsequent investment would be on 15 the same calend