Epstein Secrets

no reasonable basis or need to explore its discredited theory through a deposition of Mr. Gruss. By way of background, Mr. Gruss was the CFO of the Zwirn entities. He effectively was terminated by DBZ on October 4, 2006, shortly after an internal investigation by Schulte Roth & Zabel LLP ("Schulte Ro

stoppel for the Fund's failure to honor Mr. Zwim's alleged promise and subsequent written redemption requests; • fraudulent inducement because Mr. Zwirn did not intend to honor his alleged promise when it was made on November 13, 2006; and • breach of fiduciary duty and negligent misrepresentation

inello JAMS 620 Eighth Avenue, 34th Floor New York, New York 10018 TELEPHONE 12121 921.6399 TELEFAX (212) 764-3701 Re: Fortress VRF I LLC and Fortress Value Recovery Fund I LLC v. Jeepers, Inc. JAMS Ref. No. 1425006537 Dear Judge Carpinello: Third-Party Respondents Daniel B. Zwim, D.B. Zwim & Co. L.P. ("DBZ"), DBZ G

hat they represented the interest of all investors, Claimants could have tried to bring claims against Mr. Zwim on the other investors' behalf; Mr. Zwirn did not intend to release Claimants from their indemnification obligations with respect to such claims. Second, the Zwim Parties and Claimants (and

reement. Claimants' letter followed. Claimants' proposed language is far broader than the Settlement Terms. For example, Claimants propose that the Zwirn Parties release Claimants from all claims "that could have been asserted in the arbitration." This language is not contained in the Settlement Terms

FERT & WOHL LLP ATTORNEYS AT LA's': November 1, 2011 BY E-MAIL AND BY HAND The Honorable Anthony J. Carpinello JAMS Re: Fortress VRF I LLC and Fortress Value Recovery Fund I LLC v. Jeepers, Inc. JAMS Ref. No. 1425006537 Dear Judge Carpinello: Daniel B. Zwirn submits this letter in response to Claimants' letter to You

th any potential or actual investment in the Fund; or (h) any due diligence materials, summaries or notes (including background checks) related to Zwirn or any of its partners, officers or employees, including, but not limited to, Daniel Zwirn. Response; Respondents object because this request is o

06537 Arbitrator: Hon. Anthony J. Carpinello Counter-Claimants' Response to the First Set Of Document Requests By Claimants Fortress VRF I LLC And Fortress Value Recovery Fund I LLC Respondents Financial Trust Company, Inc. and Jeepers, Inc. (collectively referred to as "Respondents") hereby respond to Petitioner's First