Epstein Secrets

KIRKLAND & ELLIS LLP MEMORANDUM Attorney Work Product Privileged and Confidential TO: Jeffrey E. Epstein CC: Darren K. Indyke FROM: Jay P. Lefkowitz, P.C. Eric F. Leon David S. Flugman DATE: August 7, 2009 RE: Potential Claims against D.B. Zwim, Glenn Dubin, and/or H

idential TO: Jeffrey E. Epstein CC: Darren K. Indyke FROM: Jay P. Lefkowitz, P.C. Eric F. Leon Dav

d and Confidential TO: Jeffrey E. Epstein CC: Darren K. Indyke FROM: Jay P. Lefkowitz, P.C. Eric F. L

d and Confidential TO: Jeffrey E. Epstein CC: Darren K. Indyke FROM: Jay P. Lefkowitz, P.C. Eric F. Le

e course of the settlement negotiations and for wrongfully inducing Jeepers to enter into the Agreement. However, it is clear that no claim against Schulte Roth could be pursued absent termination, as they are released under the terms of paragraph 6. 4 EFTA00731204 Attorney Work Product Privileged and C

under the January 11, 2005 letter agreement only applied to complete redemptions. • March 28, 2007 telephone conversation between Mark Elovitz and Darren Indyke regarding Schulte response in which Elovitz advises that he will revisit the issue with Zwirn. Indyke sends Elovitz a confirmatory letter on that s

conversation between Mark Elovitz and Darren Indyke regarding Schulte response in which Elovitz advises that he will revisit the issue with Zwirn. Indyke sends Elovitz a confirmatory letter on that same date. • April 9, 2007 follow up letter from Indyke to Elovitz advising that Elovitz has not calle

March 27, 2007, Schulte (Mark Elovitz) letter to Darren Indyke claiming that the February 14, 2007 withd

non-material accounting irregularities. Zwirn claims it was on advice of counsel. JEE speaks to Dubin, Zwirn and Zwirn's counsel (Harry Davis from Schulte Roth) about lie and JEE again demands to redeem FTC's entire investment in the Fund. At this time, it is explained that Zwirn is trying to avoid a run o

No, sir. 20 Q. Did you tell other people in your 04:32:42 21 office about the conversation? 22 A. I would have said to either Harry or 23 Darren that Dan agreed to the $80 million, let's 24 get it done. 25 Q. Have you ever seen any piece of paper 04:32:54 VERITEXT REPORTING COMPANY www

, Perry Gruss, sometime 5 in the future. 03:16:18 6 That Mr. Kahn had showed up on most of 7 the e-mail with respect to the airplane which 8 Schulte Roth had been -- I believe it was, Schulte 9 Roth had been called in in May of '06, my best 10 recollection, sir, to deal with the issues of the 03:1