Epstein Secrets

acting Brian and engaging in sexual conversations after learning Brian was fifteen. After extensive breaks in their communications, it was usually Blazck who reestablished the intemet relationship. The jury instructions included the is- sues of entrapment and predisposition to commit the crime charge

to bring in association with or connection with." Morales Trans World Airlines, 504 U.S. 374, 383, 112 S. . 2031, 119 L.Ed.2d 157 (1992) (quoting Black's Law Dictionary 1128 (5th ed.1979)) (construing "relating to" in a different statutory context). We have construed "relarg to" language broadly in

, 112 S. . 2031, 119 L.Ed.2d 157 (1992) (quoting Black's Law Dictionary 1128 (5th ed.1979)) (construing

org/newshounbb/europe/jan-june99/berger_5-27.html), NewsHour with Jim Lehrer, PBS, May 27, 1999, Retrieved: May 27, 2006 12. A Schurr, Stephen, "DB Zwirn hires Clinton aide" (http://www.stonebridge- intemational.com/press/news010.html), Financial Times, March 15, 2006 13. A "Sandy Berger Quits Kerry

5 688.745 5 836.497 INVESTMENTS AP TECHNOLOGV(LEON BLACK) 250.030 250.000 A P SHL INVESTOR 1 030.000

8.745 5 836.497 INVESTMENTS AP TECHNOLOGV(LEON BLACK) 250.030 250.000 A P SHL INVESTOR 1 030.000

Zwirns Interest in Corbin. JEE will rercieve all distributions unto $2 million and the remaining distributions will be divided 50/50 between JEE and Zwirn 76.000,000 70,000,000 5,000,003 1,000,000 The June 30,2011 valuations(prior to the settlement) valued DBZ at 18,688,906 (May valuation) + 44,850,

5 688.745 5 836.497 INVESTMENTS AP TECHNOLOGV(LEON BLACK) 250.030 250.000 A P SHL INVESTOR 1 030.000

8.745 5 836.497 INVESTMENTS AP TECHNOLOGV(LEON BLACK) 250.030 250.000 A P SHL INVESTOR 1 030.000

Zwirns Interest in Corbin. JEE will rercieve all distributions unto $2 million and the remaining distributions will be divided 50/50 between JEE and Zwirn 76.000,000 70,000,000 5,000,003 1,000,000 The June 30,2011 valuations(prior to the settlement) valued DBZ at 18,688,906 (May valuation) + 44,850,

in this sense. See Sun-Times Media Grp., Inc. v. Black, 954 A.2d 380, 398 (Del. Ch. 2008) (course of pe

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

P, 624 A.2d 1199, 1208 n.16 (Del. 1993) (quoting Black's Law Dictionary 337 (5th ed. 1983)). FTC cannot

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

Del. Ch. 1988) 49 Sun-Times Media Grp., Inc. v. Black, 954 A.2d 380 (Del. Ch. 2008) 31, 33 United Re

after the Fund self-reported the issues in 2006. At the conclusion of its investigation, the SEC elected not to charge Mr. Zwirn or any of the other Zwirn Parties with any wrongdoing, but charged Mr. Gruss with aiding and abetting violations of the Investment Advisers Act for knowingly misusing his au

COUNTERCLAIMS 42 A. Jeepers Has No Claim for Promissory Estoppel Because There Was No Promise 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 o

Wall Street veterans, including Mr. Staley, who is now chief executive of the British bank Barclays. Mr. Epstein provided personal tax services to Leon D. Black, whose Apollo Global Management is one of the world's largest private-equity firms. He discussed a major investment idea with and entrusted millions

ey, he laid some of the early groundwork for JPMorgan to make a major acquisition — one that would vault Mr. Staley's career to a higher plane. Mr. Black, Mr. Dubin and Mr. Staley were not Mr. Epstein's biggest business relationships: That distinction belongs to Leslie H. Wexner, the billionaire found

Trust, according to court papers. At its peak, the investment was worth $140 million. Mr. Dubin and Mr. Epstein parted professional ways after Mr. Zwirn's fund shut down and Mr. Epstein sued, according to a person close to Mr. Dubin. The two men, however, continued to socialize, with Mr. Epstein join

6.106,511 5944.731 INVESTMENTS AP TECHAOLOGY(LEON BLACK) 250.000 250,000 A P SHL NVESTOR 1.030.003 1

06,511 5944.731 INVESTMENTS AP TECHAOLOGY(LEON BLACK) 250.000 250,000 A P SHL NVESTOR 1.030.003 1

Zwirns interest in Corbin. JEE will rercieve all distributions upto $2 million and the remaining distributions will be divided 50/50 between JEE and Zwirn 70.000.000 5.000,000 1.000.000 76.000.000 the June 30,2011 valuations(prior to the settlement) valued 082 at 18.688.906 (May valuation) • 44,850

d 137,097.35 -102,779.88 34,317.47 _____ Roy Black 7/31/09 7,155.00 -25,558.42 -18,403.42 8/31/

Epstein Outstanding Legal Invoices as of 12-15-09 Total Outstanding For the period ending Invoice Paid Amount Kirkland & Ellis 2/28/09 - DB Zwirn 8,155.70 0.00 8,155.70 6/30/09 - DB Zwirn 4,115.00 0.00 4,115.00 6/30109 - jane doe 101 litigation 26,334.66 0.00 26,334.66 6/30109 - doj

d 137,097.35 -102,779.88 34,317.47 _____ Roy Black 7/31/09 7,155.00 -25,558.42 -18,403.42 8/31/

15-09 Total Outstanding For the period ending Invoice Paid Amount Kirkland & Ellis 2/28109 - DB Zwirn 8,155.70 0.00 8,155.70 5/31109 - DB Zwirn 1,628.79 1.00 1,629.79 6/30/09 - DB Zwirn 4,115.00 0.00 4,115.00 6/30109 - jane doe 101 litigation 26,334.66 0.00 26,334.66 6/30109 - doj