Epstein Secrets

were invalid and set forth the schedule of eligible withdrawal dates for FTC's investments. FTC did not respond to the letter by claiming that Mr. Zwirn had promised to honor FTC's demand for $80 million. 17 EFTA00613924 FTC subsequently submitted a request for complete withdrawal on February 13,

Zwinz & Co., L.P., DBZ GP, LLC, and Zwirn Holdings, LLC EFTA00613904 Table of Contents Preliminary Statement 1 Statement of Facts 2 A. Mr. Zwirn's Personal Background 2 B. DBZ Background 2 I. DBZ's Investment Strategy 3 2. Mr. Zwirn's Role at DBZ 3 3. Mr. Dubin's Involvement with D

Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counter-Claimants and Third-Party Claimants v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LW, Counter-Respondent and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO., L.

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

Respondent § Case No. and FINANCIAL TRUST COMPANY, INC. and § JEEPERS, INC., Counter-Claimants and Third-Party Claimants § v. § Arbitrator: D.B. ZWIRN SPECIAL OPPORTUNITIES § FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO.

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

C., Respondent § Case No. 1425006537 and FINANCIAL TRUST COMPANY, INC. and § JEEPERS, INC., Counterclaimants and Third-Party Claimants § v. D.B. ZWIRN SPECIAL OPPORTUNITIES § FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO.

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

, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counterclaimants and Third-Party Claimants v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO., L

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

, Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counterclaimants and Third-Party Claimants v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, Counter-Respondent and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO., L

ich no response is required. 7. Admit the allegations of Paragraph 7. 2 EFTA00731280 8. Deny the allegations of Paragraph 8, except admit that Zwirn lives in New York, New York, and at times was referred to as the "Managing Partner" of the Company; and aver that Zwirn was the managing member of

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X PERRY A. GRUSS, Plaintiff, v. DANIEL B. ZWIRN, D.B. ZWIRN & CO., L.P. and D.B. ZWIRN PARTNERS, LLC, Defendants. X 09 cv 6441 (DC) ECF CASE ANSWER AND COUNTERCLAIMS OF DEFENDANTS D.B. ZWIRN & CO., L.P. AND D.B. ZWIRN PARTNERS, L

first deposed- (principal of leepers, Inc.) Daniel B. Zwim (individually and principal of D.B. Zwirn Special Opportunities Fund, L.P. and related Zwirn entities) Glenn Dubin Harry Beller David Lee (non-party witnesses) -second deposed- -third deposed- 3. The dates contained in Scheduling order

Claimants v. JEEPERS, INC., Respondent and FINANCIAL TRUST COMPANY, INC. and JEEPERS, INC., Counter-Claimants and Third-Party Claimants v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a/ FORTRESS VALUE RECOVERY FUND 1 LLC, Counter-Respondent and D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & Co.,

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

JAMS ARBITRATION IN THE MATTER OF FINANCIAL TRUST COMPANY, INC., JEEPERS, INC., v. D.B. ZWIRN SPECIAL OPPORTUNITIES FUND, L.P. k/n/a FORTRESS VALUE RECOVERY FUND I LLC, D.B. ZWIRN PARTNERS, LLC, D.B. ZWIRN & CO., L.P. ZWIRN HOLDINGS, LLC,