Epstein Secrets

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

nagers, managing members, employees, directors, representatives, agents, officers, consultants, attorneys, predecessors, successors or affiliates of D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, including without limitation the Zwirn Entities. 8. The term "Zwirn En

Inc., including Jeffrey Epstein. I205876vI/011585 2 EFTA00722310 Timestamp: 8/16/2010 5:38 PM CDT 7. The term "Fund" or "On-Shore Fund" means D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC. The term includes past and/or present general partners, managers, managi

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

of the Fund. The assignment was made retroactively effective January 1, 2006. Counterclaim and Third-Party Respondents 16. Counterclaim Respondent D.B. Zwim Special Opportunities Fund, L.P. kinia Fortress Value Recovery Fund I LLC was a limited partnership formed under the laws of the State of Delaware.

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

. 113. The Company primarily made investments through various funds that it managed: D.B. Zwim Special Opportunities Fund LP (the "Onshore Fund"), D.B. Zwim Special Opportunities Fund Ltd. (the "Offshore Fund"), D.B. Zwim Special Opportunities Fund II Ltd. (the "LTD II Fund"), D.B. Zwim Special Opportun

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

ancial Trust Company, Inc. ("FTC") and Jeepers, Inc. ("Jeepers") (collectively, "Claimants"), submit the following statement of their claims against D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC, D.B. Zwim Partners, LLC, Zwim Holdings, LLC, D.B. Zwim & Co., L.P., and