Epstein Secrets

PAUL, WEISS, RIFICIND, 1255 AVENUE OF THE AMERICAS NEW YORK, NEW YORK 10019-6064 TELEPHONE (212) 373-3000 LLOYD K GARRISON ('540-1001) RANDOLPH t. PAUL II 540.105110 SIMON H. RIMINI] (1050-10051

t in advance exactly what new third-party claims could be brought against the Zwim Parties, how the pre-Arbitration agreements between the Fund and the Zwirn Parties might (or might not) apply to such claims, and how the currently proposed release language might (or might not) apply to such claims. Therefore, the

bed on Exhibit A hereto. Dated: November 9 , 2010 Hon. Anthony J Arbitrator Requested by: William O'Brien, Esq. Cooley LLP 1114 Avenue of the Americas New York, New York 10036 Counsel for Third-Party Respondents D.B. Zwirn Partners, LLC, D.B. Zwirn & Co., L.P., DBZ GP, LLC, and Zwirn Holdings,

ense include terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communications between You on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communications between You on the one hand, and any of

A hereto. Dated: November 2010 Hon. Anthony J. Carpinello (Ret.) Arbitrator Requested by: William O'Brien, Esq. Cooley LLP 1114 Avenue of the Americas New York, New York 10036 iii 479-6000 Counsel for Third-Party Respondents D.B. Zwirn Partners, LLC, D.B. Zwirn & Co., L.P., DBZ GP, LLC, and Z

clude terms in the present tense. DOCUMENT REQUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

scribed on Exhibit A hereto. Dated: November", 2010 on. Anthony J Arbitrator Requested by: William O'Brien, Esq. Cooley LLP 1114 Avenue of the Americas New York, New York 10036 (212) 479-6000 Counsel for Third-Party Respondents D.B. Zwirn Partners, LW, D.B. Zwirn & Ca, L.P., DBZ GP, LW, and Zw

clude terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

ts or wish to discuss, please let us know. Best, Hannah Hannah Sholl I Associate Paul, Weiss, Rifkind, Wharton 8 Garrison LLP 1285 Avenue of the Americas I New York. NY 10019-6064 (Direct Phone) (Direct Fax) This message is intended only for the use of the Addressee and may contain information that

reement and a blackline comparing this version to the initial version we circulated on August 5. We reviewed the comments provided by Mr. Indyke and the Zwirn Parties, and this version incorporates some, but not all, of their proposed changes. We have not yet received comments from counsel for Mr. Dubin. EFTA004

th respect to this Settlement Agreement shall be sent to Claimants at and in care of: Fortress VRF I LLC Attention: Rick Noble 1345 Avenue of the Americas, 46th Floor New York, NY 10105 — and — Allan J. Arffa Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 100

arties now manage or formerly managed, and any fund or account now or formerly managed by Claimant Fortress VRF I LLC or its affiliates; and (2) the Zwirn Parties and each of their past, present and future parents, subsidiaries and other affiliates, each of the predecessors, successors, heirs and assigns of e