Epstein Secrets

the "oral contract" claim and Claimants' claim for a declaration of Jeepers's rights with respect to the Fund. Additionally, we understand that the Zwirn Parties contend that the extrinsic evidence is, in any event, relevant to their "exculpatory clause" defense to Jeepers's fraud and breach of fiduci

and contemporaneous e-mails concerning the Side Letter, (see, e.g., December 2004 E-mail Correspondence between Mr. Zwim and Mr. Dubin, Ex. K (Mr. Zwirn: "we're done, ftc in for $20mi1 jan 1 L.P. . . . This is the last 2 year money will 20 EFTA00614019 take from anyone of course"; Mr. Dubin: "of c

ce"; (2) a binder of exhibits cited in the memorandum; and (3) a binder of cases cited in the memorandum. Re Iectfullysubmitted, Attachments cc: Harry Susman (counsel for Financial Trust Company, Inc. and Jeepers, Inc.) John Siffert and Daniel Reynolds (counsel for Daniel B. Zwini) William Schwartz and W

) It is also important to note that similar language is used in other portions of the New Agreement for other releases—including the release of the Zwirn Parties by EFTA00306063 PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP Hon. Anthony J. Carpinello (Ret.) 4 Claimants—that was based on release la

e Zwim Parties have reconsidered their position. We look forward to mediating this final issue with you. Respectfully submitted, Enclosures cc: Harry Susman, Esq. John Siffert, Esq. Daniel Reynolds, Esq. William Schwartz, Esq. William O'Brien, Esq. Darren K. Indyke, Esq. James H.R. Windels, Esq. EF

WWW******************WW************** *le On Jun 13, 2011, at 9:59 AM, Lesley Groff wrote: > Hi Darren...can you tell me where JE is to go for the Zwirn depo tomorrow? ALso, what time is he to be there? I need to let Jojo know.= EFTA00432687

From: Darren Indyke To: Lesley Groff Subject: Re: Zwim depo tomorrow Date: Mon, 13 Jun 2011 14:02:19 +0000 Check with Harry Susman, but I believe it is at Susman Godfrey at 9AM. Check with Harry first before you tell JE. Thanks. Darren K. Indyke Darren K. Indyke, PLLC 301 Eas

W**WWW************WWW**WWW********* ** > On Jun 13, 2011, at 9:59 AM, Lesley Groff wrote: >> Hi Darren...can you tell me where JE is to go for the Zwirn depo tomorrow? ALso, what time is he to be there? I need to let Jojo know.= EFTA00432700

Subject: Re: Zwim depo tomorrow Date: Mon, 13 Jun 2011 14:54:27 +0000 ok, thanks On Jun 13, 2011, at 10:02 AM, Darren Indyke wrote: > Check with Harry Susman, but I believe it is at Susman Godfrey at 9AM. Check with Harry first before you tell JE. Thanks. > • Darren K. Indyke > Darren K. Indyke, PLLC

much!! Sent from my iPhone On Aug 24, 2011, at 12:16 PM, Harry Susman < wrote: > Jill: can you help her out. Siffert was opposing counsel in the Zwirn matter, > • Harry Susman > Susman Godfrey > l(w) (c) • Original Message > From: [mailto: > Sent: Wednesday, August 24, 2011 10:19 AM > To

From: To: Harry Susman cza> Cc: Jill McCrary cta> Subject: Re: Jeffrey Epstein Date: Wed, 24 Aug 2011 16:22:13 +0000 I got it!! It is taken care of. Thx so much!! Sent