Epstein Secrets

the "oral contract" claim and Claimants' claim for a declaration of Jeepers's rights with respect to the Fund. Additionally, we understand that the Zwirn Parties contend that the extrinsic evidence is, in any event, relevant to their "exculpatory clause" defense to Jeepers's fraud and breach of fiduci

and contemporaneous e-mails concerning the Side Letter, (see, e.g., December 2004 E-mail Correspondence between Mr. Zwim and Mr. Dubin, Ex. K (Mr. Zwirn: "we're done, ftc in for $20mi1 jan 1 L.P. . . . This is the last 2 year money will 20 EFTA00614019 take from anyone of course"; Mr. Dubin: "of c

's ("FTC's") (together, "Jeepers's") motion in limine "to exclude extrinsic evidence EFTA00614000 related to the breach of contract claims against D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC ((the) "Fund"), [and] D.B. Zwim Partners, LLC, D.B. Zwim & Co. L.P., DBZ GP LLC, Zwirn Holdings LLC,

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

ed hereto. EFTA00727329 8. "Settlement Agreement and Release" means the Settlement Agreement and Release reached in or about April, 2009 between D.B. Zwim Special Opportunities Fund, L.P. and the Third Party Claimants. 9. "Document" means any document including but not limited to correspondence, internal or external memoranda

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

ed hereto. EFTA00727339 8. "Settlement Agreement and Release" means the Settlement Agreement and Release reached in or about April, 2009 between D.B. Zwim Special Opportunities Fund, L.P. and the Third Party Claimants. 9. "Document" means any document including but not limited to correspondence, internal or external memoranda