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hat they represented the interest of all investors, Claimants could have tried to bring claims against Mr. Zwim on the other investors' behalf; Mr. Zwirn did not intend to release Claimants from their indemnification obligations with respect to such claims. Second, the Zwim Parties and Claimants (and
reement. Claimants' letter followed. Claimants' proposed language is far broader than the Settlement Terms. For example, Claimants propose that the Zwirn Parties release Claimants from all claims "that could have been asserted in the arbitration." This language is not contained in the Settlement Terms
hat our proposed language be adopted, or that in the alternative, Your Honor adopt the language in the Settlement Terms. Respectfully, Ce-Otthee> John S. Siffert cc: Allan Arffa, Esq. (by email) Chet Lipton, Esq. (by email) EFTA00308107
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
t class mail, this day of Brad S. Karp Allan Arffa Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019 John S. Siffert Lankier Siffert & Wohl LLP 500 Fifth Avenue, 33rd Floor New York, NY 10110 1043197v1/011585 20 , on: Alan Levine Cooley LLP The Grace Build
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
is 17th day of August, on: Brad S. Karp Allan Arffa Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019 John S. Siffert Lankier Siffert & Wohl LLP 500 Fifth Avenue, 33rd Floor New York, NY 10110 Alan Levine Cooley LLP The Grace Building 1114 Avenue of the Americ
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
10036 iii 479-6000 Counsel for Third-Party Respondents D.B. Zwirn Partners, LLC, D.B. Zwirn & Co., L.P., DBZ GP, LLC, and Zwirn Holdings, LLC John S. Siffert, Esq. Daniel E. Reynolds, Esq. Lankier Siffert & Wohl, LLP 500 Fifth Avenue, 33rd Floor New York, New York 10110 212 921-8399 Counsel for Third
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
k 10036 (212) 479-6000 Counsel for Third-Party Respondents D.B. Zwirn Partners, LW, D.B. Zwirn & Ca, L.P., DBZ GP, LW, and Zwirn Holdings, LLC John S. Siffert, Esq. Daniel E. Reynolds, Esq. Lankier Siffert & Wohl, LLP 500 Fifth Avenue, 33rd Floor New York, New York 10110 (212) 921-8399 Counsel for Thi
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
New York, NY 10036-7798 4. All notices to Daniel Zwim with respect to this Settlement Agreement shall be sent to Daniel Zwim at and in care of: John S. Siffert Lankier Siffert & Wohl LLP 500 Fifth Ave, 33rd Floor New York, NY 10110 5. All notices to shall be sent to at and in care of: with respect to
Entities connected to both Zwirn and John S. Siffert

Jeffrey Epstein
PERSON
Glenn Dubin
PERSON
Financial Trust Company
ORGANIZATION
United States
LOCATIONAnthony J. Carpinello
PERSONPerry Gruss
PERSONZWIRN HOLDINGS
ORGANIZATIONDANIEL ZWIRN
PERSONDarren Indyke
PERSONJeepers, Inc.
ORGANIZATION
Stephen Hawking
PERSON
Jes Staley
PERSONWilliam O'Brien
PERSON
JPMorgan Chase
ORGANIZATION
Alan Dershowitz
PERSOND.B. Zwirn
ORGANIZATIOND.B. ZWIRN & CO.
ORGANIZATIONStephen D. Susman
PERSOND.B. ZWIRN
PERSONWeiss
PERSON