Epstein Secrets

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

CLAIMS OF DEFENDANTS D.B. ZWIRN & CO., L.P. AND D.B. ZWIRN PARTNERS, LLC JURY TRIAL DEMANDED Defendants D.B. Zwim & Co., L.P. (the "Company") and D.B. Zwim Partners, LLC ("DBZLLC"), by their attorneys Cooley Godward ICronish LLP, answer the Complaint and Jury Demand herein as follows: I. Aver that in 2006, de

uss had obligations to the Company and DBZLLC in addition to those set forth in the unexecuted Supplementary Agreement among D.B. Zwim & Co., L.P., D.B. Zwim Partners, LLC and Perry Gruss (the "Supplementary Agreement"). 58. Deny the allegations of Paragraph 58, except admit that Gruss was a partner in the Comp

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

d 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, and Daniel Zwirn [together, the "Zwim Parties")." (Financial Trust Company, Inc.'s and

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

agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on their behalf. 2. "Zwirn Parties" means Daniel Zwirn, D.B. Zwim Partners, LLC, D.B. Zwirn & Co, L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their members, employees, representatives, agents, predecessors,

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

"Claimants"); (ii) Jeffrey Epstein, Jeepers, Inc. ("Jeepers") and Financial Trust Company, Inc. ("FTC") (collectively, the "Epstein Parties"); (iii) D.B. Zwim Partners, LLC, D.B. Zwim & Co., L.P., DBZ GP, LLC and Zwim Holdings, LLC (collectively, the "Zwim Entities") and Daniel Zwim (together with the Zwim Entitie