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.

d normally decline substantially, resulting in a so-called "fire sale." None of this was a secret to the Funds' investors. For example, a May 2003 Confidential Memorandum circulated in connection with an offering of the Fund expressly noted that: "substantial requests for withdrawals by limited partners could induce t

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

elaware limited liability company. As discussed under "Certain Legal and Regulatory Matters Relating to the Master Partnership" in Part Two of this Confidential Memorandum, Millennium Management is the commodity pool operator and commodity trading advisor of Millennium USA and the Master Partnership and has general re

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

elaware limited liability company. As discussed under "Certain Legal and Regulatory Matters Relating to the Master Partnership" in Part Two of this Confidential Memorandum, Millennium Management is the commodity pool operator and commodity trading advisor of Millennium USA and the Master Partnership and has general re