Epstein Secrets

) 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

t in advance exactly what new third-party claims could be brought against the Zwim Parties, how the pre-Arbitration agreements between the Fund and the Zwirn Parties might (or might not) apply to such claims, and how the currently proposed release language might (or might not) apply to such claims. Therefore, the

ns of the Zwim Fund, after Zwim spun off his business from DSAM (then known as Highbridgc Capital Management, LLC), 1 helped introduce investors to Zwirn, invested my personal and family foundation assets with Zwirn, and my firm allocated assets of Highbridgc Capital Corporation ("I-TCC") to an accou

clude terms in the present tense. DOCUMENT REQUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

my personal and family foundation assets with Zwim, and my firm allocated assets of iiighbridge Capital Corporation ("HCC) to an account managed by Zwirn's company which was also the investment manager of the Zwim Fund. 3. One of the early investors that I introduced to Zwim was Jeffrey Epstein ("E

clude terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

ation. Without limiting the foregoing, Highbridge shall not produce any documents exchanged by the parties in connection with the matter entitled Zwirn v. Corbin Capital Partners, L.P. et al., Index No. 08/603382. Objections to Definitions 1. Highbridge objects to the Definitions to the extent th

tion 2. SPECIFIC RESPONSES AND OBJECTIONS Request No.1: All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. Highbridge objects to the definition of "All" and "each" as vague, 6 EFTA01592057 R

Parties had, now has or will ever have against the Released Parties, which constitute, concern or otherwise relate to: (a) (b) (c) C. By the Zwirn Parties any matter or thing from the beginning of time to the date of this Settlement Agreement relating to any of the Investments or the Fund; a

arties now manage or formerly managed, and any fund or account now or formerly managed by Claimant Fortress VRF I LLC or its affiliates; and (2) the Zwirn Parties and each of their past, present and future parents, subsidiaries and other affiliates, each of the predecessors, successors, heirs and assigns of e