Epstein Secrets

H II EX r ALAN S. HAITI' SLAVA HAN ;MEAN ERA 12 E. HA EA lc I. HERITcm IR H. II V Ir n i MAN . HU I TON LIM MTH J. WI N frinIZAKtr'S L JOHN C. KENNEDY 1101 AA,Iflet ID IN may Tong am Fortress VRF I v. Jeepers, Inc., JAMS No. 1425006537 Dear Mr. Susman: ALAN W KORNSERG DANIEL J KRA.MER PX1P4tNt

I TON LIM MTH J. WI N frinIZAKtr'S L JOHN C. KENNEDY 1101 AA,Iflet ID IN may Tong am Fortress VRF I

E NEW YORK, NEW YORK IN THE MATTER OF FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counter-Claimants and Third-Party Claimants v. FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B. ZWIRN PART

335 Letter to Tallah Woykowski from Investor 2/8/2007 VRF 00001394 336 Email to Elise Hubsher and Alisa Butchkowski from Dan Zwirn, attaching Financial Trust spreadsheet 2/14/2007 DBZCO_FTC 0002140 — 0002141 3 EFTA00614027 Exhibit Descri tion Date Bates 337 E-mail i from Seth Lebowitz re Jeepe

NN CENTER PLAZA SUITE 200 1600 JOHN FITZGERALD KENNEDY BOULEVARD PHILADELPHIA, PA 19103-2813 215-563-9

r the plain- tiffs to amend their pleadings. I. FACTUAL AND PROCEDURAL BACKGROUND In their amended complaint, Jeffrey E. Epstein ("Epsteinn and Financial Trust Company, Inc. ("Fr) (collectively "plain- tiffs") allege that Citibank, N.A. ("Citi- bank") and Citigroup, Inc. ("Citigroup"I [collectively "defendants"] misrepre

itch book" referenced in the amended complaint is the document that plaintiffs rely on is a disputed fact that precludes a Rule 12(bX6) dismissal. Financial Trust Co., 268 F.Supp.2d at 572. Nothing in any of the briefs have convinced me that the parties do not dispute which pitch book Epstein received, what disc

ed to meet Federal Rule of Civil Proce- dure 9(b)'s heightened pleading standard. I did, however, grant the plaintiffs leave to amend the complaint Financial Trust Co.' Citibank, 268 F.Supp.2d 661 (D.Vir- gin Islands 2003). H. LEGAL ANALYSIS A. Federal Rule of Civil Procedure 9(b) (1-31 In order to state a viable

Skaktte ' !"4 .111;rAN •RIAN B. ROBERT N.HER HIRS MAHNN MICHELE HIRIHMAN JOYCE S HUA DAVID S HUNTINGTON :14ER g:IA TANAj.KriPtiN BRAD S KARP JOHN C KENNEDY •NoT•cmermo TO TNE NEW YORK BAR Reference No. 1425006537: In the Matter of the Arbitration Between Fortress VRF I LLC, Claimants, and Jeepers, Inc

ON :14ER g:IA TANAj.KriPtiN BRAD S KARP JOHN C KENNEDY •NoT•cmermo TO TNE NEW YORK BAR Reference No. 1

ACCONE T. ROBERT ZOCHOWSKI. JR. Dear Judge Carpinello: Attached you should find: (1) a hard copy of Claimants' Memorandum of Law in Opposition to Financial Trust Company, Inc.'s and Jeepers, Inc.'s Motion In Limine "To Exclude Extrinsic Evidence"; (2) a binder of exhibits cited in the memorandum; and (3) a binder of cases c

HISTORY: Hacecsa v. United States. 309 F.3d 722, 2002 U.S. App. LEXIS 22192 (10th Cir. NM.. 2002) JUDGES: r 11 Rehnquist, Stevens, O'Connor. Scalia, Kennedy. Sower, Thomas, Ginsburg. Breyer. OPINION Petition for writ of certiorari to the United States Court of Appeals for the Tenth Circuit denied. I of

value proposition for any robo investor looking to invest in alternative asset investments, such as real estate,' stated Adam Bergman. President of the IRA Financial Trust Company. According to Adam Bergman. a partner with the IRA Financial Group, the costs involved in having a self-directed IRA account has been reduced drama

D. R. CRIM. P. 6(e) CONFIDENTIAL DB-SDNY-0026461 EFTA_00I74 I 44 EFTA01298709 Page 3 OFAC RESULTS RDC: 11641989 Not Alerted KC 0198325 The Financial Trust (Global Search) Company FIRCOSOFT: 31721057VVR_317210572182CompanyThe Financial Trust Company No AlertNo AlertNo AlertNo Alert BIS RESULTS: Neg

theories, including Obama birtherism, the Clinton Body Count theory, gAnon, the Global warmint hoax theory, Trump Tower wiretapping allegations, a John F. Kennedy assassination cons ira theory involving Rafael Cruz, linking talk show host Joe Scarborough to the death of a staffer,L alleged foul-play in the d

y, Trump Tower wiretapping allegations, a John F. Kennedy assassination cons ira theory involving Rafael C

ls at his New York City home, as well as helping aspiring models get work with the company jooli64 In 1996, Epstein changed the name of his firm to the Financial Trust Company and, for tax advantages, based it on the island of St. Thomas in the U.S. Virgin Islands.O21 By relocating to the US. Virgin Islands, Epstein was

best known for his successful defense of William Kennedy Smith. The prosecutors presented Epstein a choic

g to work" and "eligible for re-employment" at The Florida Science Foundation. Please be advised that the only W-2 that Mr. Epstein provided is from Financial Trust Company, Inc., which shows that Mr. Epstein was employed in the U.S. Virgin Islands at a salary of $180,785.62, not $250,000. Mr. Epstein provided to you no docu

founder of The Florida Science Foundation and Mr. Indyke is its Vice President. More importantly, Mr. Epstein is also the founder and President of the Financial Trust Company, his for-profit corporation. Mr. Indyke is Mr. Epstein's subordinate at that entity as well. One of Mr. Epstein's attorneys has suggested that Mr.

best known for his successful defense of William Kennedy Smith. The prosecutors presented Epstein a choic

g to work" and "eligible for re-employment" at The Florida Science Foundation. Please be advised that the only W-2 that Mr. Epstein provided is from Financial Trust Company, Inc., which shows that Mr. Epstein was employed in the U.S. Virgin Islands at a salary of $180,785.62, not $250,000. Mr. Epstein provided to you no docu

founder of The Florida Science Foundation and Mr. Indyke is its Vice President. More importantly, Mr. Epstein is also the founder and President of the Financial Trust Company, his for-profit corporation. Mr. Indyke is Mr. Epstein's subordinate at that entity as well. One of Mr. Epstein's attorneys has suggested that Mr.

ENN CENTER PLAZA SUITE 200 1600 JOHN FITZGERALD KENNEDY BOULEVARD PHILADELPHIA, PA 19103-2813 215-563-

damages. Plaintiffs have thus alleged enough information to survive a Rule 12(b)(6) motion on Case No. 08-80736-CV-MARRA P-000727 EFTA00228107 k Financial Trust Co. v. Citibank Civil No. 02-108 Memorandum Opinion Page 9 their fraud claims. C. The Mass .Mutual Investment Claims Although it is unclear from t

erentiate the counts between the Mass Mutual and AIG funds as defendant attempts to do. Case No. 08-80736-CV-MARRA P-000729 EFTA00228109 I .• Financial Trust Co. Inc. I. Citibank Civ. No. 2002-108 Memorandum Opinion Page 11 ENTERED this 30th day of December, 2004. FOR THE COURT: /s/ Thomas K. Moore Distri

if you need further assistance. Sincerely, Mary Kennedy Chief, Bureau of Support Services cc: File Flo

act Us Home PROGRAM SEAR(( Educators Professionals Partners Page I of 2 Education Development Member - Jeffrey E. Epstein Chairman and CEO The Financial Trust Company New York, New York Jeffrey Epstein is Chairman and CEO of the Financial Trust Company, an exclusive private trust co that provides a unique array