Epstein Secrets

evin Naftalis & Frankel LLP Marshall H. Fishman Stephen M. Sinaiko Gabrielle L. Gould 1177 Avenue of th

or the requests. 31. Claimants shall be deemed a "Customer" for purposes of production of documents and information referenced in portions of the Guide that are relevant to this arbitration. - 6 - KU 2748586.1 EFTA00724441 32. Unless otherwise specified in a particular document request, this R

Respectfully submitted, SUSMAN GODFREY L.L.P. Stephen D. Susman 654 Madison Avenue, 5th Floor New Yor

objection, FTC will produce responsive documents. 58. To the extent not called for by the preceding requests or by the applicable portions of the Guide, all documents concerning (a) the Funds, (b) the Fund Managers, (c) Evan Kerr, (d) Heather Malloy, (e) Ira Zicherman, (0 any other Bear Steams Fund,

of Science, Essential Writings of Henri Poincare’ Stephen Jay Gould, Modern Library, Random House, N.Y. 200

he work of the 13" HOUSE_OVERSIGHT_013504 Century proponent of a school of Jewish ecstatic mysticism, Abraham Abulafia, whose interpretation of the Guide and his own Commentary on the Secrets taught that the human mind, if transformed into a “state of active intellect,” could become one with Spirit, re