Epstein Secrets

disclosure of the Fund's financial and accounting irregularities. FTC was one of the Fund's largest and oldest investors. Over the next few months, Zwirn, the Fund and its management employed a combination of misrepresentations and contrived legal arguments to thwart FTC's withdrawal. 1043197v1/01158

e attorneys' fees and costs of this proceeding. 1043197v1/011585 18 EFTA00722267 Dated: New York, New York May 2010 Respectfully submitted, SUSMAN GODFREY L.L.P. Stephen D. Susman 654 Madison Avenue, 5th Floor New York, New York 10065-8440 Tele hone: Fax: E-mail: Harry P. Susman SUSMAN GODFREY L

sfer of FTC's interest in the Fund to Jeepers, including without limitation any correspondence between or among any Counterclaimants and any of the Zwirn entities and/or Glenn Dubin regarding the transfer and drafts of any agreements relating to such transfer. 12. Copies of each version of the subsc

ount. 77. All communications between the Firm and any public relations firm. Dated: New York, New York August 17, 2010 Respectfully submitted, SUSMAN GODFREY L.L.P. Stephen D. Susman Seth Ard 654 Madison Avenue, 5th Floor New York, New York 10065-8440 Telephone: Fax: E-mail: E-mail: Harry P. Susma

responsive documents, if any, that may exist. 7. All documents and communications concerning the allegation in ¶ 59 of the Third-Party Claim that "Zwirn was well-aware in October 2006 of the improprieties detailed in the March 2007 report." 3 EFTA00729272 Response: Respondents object because thi

evant information and is designed to harass Respondents and/or third-parties. Dated: New York, New York September 2010 Respectfully submitted, SUSMAN GODFREY L.L.P. Stephen D. Susman Seth Ard 654 Madison Avenue, 5th Floor New York, New York 10065-8440 Fax: (212) 336-8340 E-mail: E-mail: Harry P. Su

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

ction, Respondents will produce responsive documents, if any, that may exist. Dated: New York, New York September 2010 Respectfully submitted, SUSMAN GODFREY L.L.P. Stephen D. Susman Seth Ard 654 Madison Avenue, 5'h Floor 8440 Fax: (212 336-8340 E-mail: E-mail: 10 EFTA00729268 Harry P. Susman S

would request a withdrawal of only $80 million, the Fund would honor the request. Dubin will corroborate Epstein's version of events. 8. Based on Zwirn's promise and his characterization of the events at the Fund, FTC made a request for an $80 million withdrawal on November 13, 2006. 9. After wait

plus interest, together with the attorneys' fees and costs of this proceeding. Dated: New York, New York February 2010 Respectfully submitted, SUSMAN GODFREY L.L.P. Stephen D. Susman 654 Madison Avenue, 5th Floor New York, New York 10065-8440 Telephone: (212) 336-8330 Fax: (212) 336-8340 E-mail: ssus

ments in the fund. 9 Q. And did you discuss what the lockup 10 would be for those increases? 09:19:07 11 A. I don't recall. 12 Q. Did Mr. Zwirn tell you that the lockup 13 for those -- did Mr. Dubin tell you that the 14 lockup for any subsequent investment would be on 15 the same calend

neys for Claimants 6 1285 Avenue of the Americas 7 New York, New York 10019-6064 8 BY: ALLAN J. ARFFA, ESQ. 9 HANNAH S. SHOLL, ESQ. 10 11 SUSMAN GODFREY 12 Attorneys for JEEPERS, 13 Financial Trust Company, and Witness 14 560 Lexington Avenue, 15th Floor 15 New York, New York 10022 16 BY: S