Epstein Secrets

ule.) Because there was no possibility of withdrawing earlier if disclosure occurred earlier, Mr. Zwirn's alleged delay caused no damage. See In re J.P. Morgan Chase & Co. Shareholder Litig., 906 A.2d 808, 827 n.61 (Del. Ch. 2005) (to prove common law fraud, "[the] plaintiff must have suffered substantial damage, not

3 A.2d 818 (Del. 1992) 50 Dittrick v. Chalfant, 948 A.2d 400 (Del. Ch. 2007) 30, 31 Hillman v. Hillman, 910 A.2d 262 (Del. Ch. 2006) 48 In re J. P. Morgan Chase & Co. Shareholder Litig., 906 A.2d 808 (Del. Ch. 2005) 46 In re Mesa Ltd. P'ship Preferred Unitholders Litig., 91 Civ. 12243, 1991 WL 262669 (Del. Ch.

7 Statement of Facts The Parties Claimants are related entities. Claimant VRF I LLC, the current managing member of the Fund, is an affiliate of Fortress Investment Group LLC ("Fortress"), a leading global alternative asset manager that raises, invests and manages private equity funds, credit funds, hedge funds and t

and commercial bank. In 2006, he was recognized as the Capital Markets CIO of the Year by Bankers Magazine. From 1992-2001, Mr. Torgovnik was with JP Morgan in a variety of technology roles within their Fixed Income Derivatives business, including Global Head of Fixed Income Derivatives Technology and F

s Commission, The Center, 99 Queens Road Central, Central Hong Kong, Tel. +852 3965 3222. • Millennium Capital Management (Singapore) Pte. Ltd. ("MCM Singapore"), a wholly-owned subsidiary of Millennium International Management, which is licensed by the Monetary Authority of Singapore, 80 Raffles Place, UO

and Investor Relations Department with a primary focus on building and developing new and current investor relationships. Mr. Novogratz worked at Fortress Investment Group for almost six years before joining the General Partner, most recently as Managing Director and Head of Capital Formation International in London.

be) are not obtained from such operation; or d. a designated person22. The Master Partnership, Millennium Management, the Investment Manager and MCM Singapore reserve the right to request such information as any of the Master Partnership, Millennium Management, the Investment Manager and MCM Singapore (as

g and Investor Relations Department with a primary focus on building and developing new and current investor relationships. Mr. Novogratz worked at Fortress Investment Group for almost six years before joining the General Partner, most recently as Managing Director and Head of Capital Formation International in London.

be) are not obtained from such operation; or d. a designated person22. The Master Partnership, Millennium Management, the Investment Manager and MCM Singapore reserve the right to request such information as any of the Master Partnership, Millennium Management, the Investment Manager and MCM Singapore (as

g and Investor Relations Department with a primary focus on building and developing new and current investor relationships. Mr. Novogratz worked at Fortress Investment Group for almost six years before joining the General Partner, most recently as Managing Director and Head of Capital Formation International in London.