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after the Fund self-reported the issues in 2006. At the conclusion of its investigation, the SEC elected not to charge Mr. Zwirn or any of the other Zwirn Parties with any wrongdoing, but charged Mr. Gruss with aiding and abetting violations of the Investment Advisers Act for knowingly misusing his au
COUNTERCLAIMS 42 A. Jeepers Has No Claim for Promissory Estoppel Because There Was No Promise 42 B. Jeepers Has No Claim for Fraud Because Mr. Zwirn Fully Disclosed All Accounting Irregularities and Made No Misrepresentations to Mr. Epstein 43 C. Jeepers's Claim for Breach of Fiduciary Duty o
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK IN THE MATTER OF FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants v. JEEPERS, INC
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
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants, v. JEEPERS, INC. Respondents,
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
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants, v. JEEPERS, INC. Respondents,
ations concerning their withdrawal requests, and never documented the promise in any of their communications with any Third-Party Respondent. Also, Zwirn's disclosures to investors were neither misrepresentations, misleading nor negligent. FIRST AFFIRMATIVE DEFENSE 3. Epstein communicated to the Fun
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants, v. JEEPERS, INC. Respondents,
ation. Without limiting the foregoing, Highbridge shall not produce any documents exchanged by the parties in connection with the matter entitled Zwirn v. Corbin Capital Partners, L.P. et al., Index No. 08/603382. Objections to Definitions 1. Highbridge objects to the Definitions to the extent th
JUDICIAL ARBITRATION AND MEDIATION SERVICE NEW YORK, NEW YORK FORTRESS VRF I LLC and FORTRESS VALUE RECOVERY FUND I LLC, Claimants, - against - JEEPERS, INC., Respo
Entities connected to both Zwirn and JUDICIAL ARBITRATION

Jeffrey Epstein
PERSON
Glenn Dubin
PERSON
Financial Trust Company
ORGANIZATIONHighbridge
ORGANIZATIONDANIEL ZWIRN
PERSONZWIRN HOLDINGS
ORGANIZATIONAnthony J. Carpinello
PERSON
United States
LOCATION
Jes Staley
PERSON
JPMorgan Chase
ORGANIZATIONJeepers, Inc.
ORGANIZATIONThird-Party Respondents
ORGANIZATIONCounter-Claimants
ORGANIZATIONWilliam O'Brien
PERSON
Stephen Hawking
PERSOND.B. ZWIRN & CO.
ORGANIZATIONDavid Lee
PERSOND.B. ZWIRN
PERSONthe Zwirn Parties
LOCATION
Highbridge Capital Management
ORGANIZATION