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r. Zwim or the Zwim Entities by someone not a party to the Arbitration if those claims related to matters at issue in the Arbitration; and (2) Mr. Zwirn and the Zwim Entities were not releasing Fortress from obligations under any pre-existing agreement between the Zwim Entities and the Claimants exce
cc: Allan Arffa, Esq. (by email) Chet Lipton, Esq. (by email) EFTA00308248 Release language proposed by Lankier Siffert & Wohl LLP A. By the Zwirn Parties Except as provided in Paragraph E of this Part III of the Settlement Agreement, the Zwim Parties, on behalf of themselves and, to the fulle
forever, irrevocably and unconditionally release and discharge: (I) except with respect to any indemnification obligations Claimants may have to the Zwim Releasors for reasonable attorneys' fees and costs incurred in connection with the Arbitration, the Claimants Released Parties from, and covenant not to sue
ny of the Zwim Releasors against any of the Claimants Released Parties that are directly related to the matters at issue in the Arbitration, none of the Zwim Releasors is releasing any Claimants Released Parties from (or agreeing not to sue any of them with respect to) any claims of any nature that any Zwim Releas
) 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
y forever, irrevocably and unconditionally release and discharge: (1) except with respect to any indemnification obligations Claimants may have to the Zwim Releasors for reasonable attorneys' fees and costs incurred in connection with the Arbitration, the Claimants Released Parties from, and covenant not to sue
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
forever, irrevocably and unconditionally release and discharge: (1) except with respect to any indemnification obligations Claimants may have to the Zwim Releasors for reasonable attorneys' fees and costs incurred in connection with the Arbitration, the Claimants Released Parties from, and covenant not to sue
Entities connected to both Zwirn and the Zwim Releasors

Jeffrey Epstein
PERSONAnthony J. Carpinello
PERSON
United States
LOCATIONDarren Indyke
PERSONJeepers, Inc.
ORGANIZATIONWilliam O'Brien
PERSONthe Zwirn Parties
LOCATIONLankier Siffert & Wohl LLP
ORGANIZATIONthe Claimants Released Parties
ORGANIZATIONthe Zwirn Entities
ORGANIZATIONJames H.R. Windels
PERSON