Epstein Secrets

r. Zwim or the Zwim Entities by someone not a party to the Arbitration if those claims related to matters at issue in the Arbitration; and (2) Mr. Zwirn and the Zwim Entities were not releasing Fortress from obligations under any pre-existing agreement between the Zwim Entities and the Claimants exce

cc: Allan Arffa, Esq. (by email) Chet Lipton, Esq. (by email) EFTA00308248 Release language proposed by Lankier Siffert & Wohl LLP A. By the Zwirn Parties Except as provided in Paragraph E of this Part III of the Settlement Agreement, the Zwim Parties, on behalf of themselves and, to the fulle

. The only remaining issue regarding the settlement of the above-referenced matter concerns the scope of the release to be given by Daniel Zwim and the Zwirn Entities to the Claimants. The settlement read into the record at our last meeting with Your Honor provides that: "The Zwim Parties, on the one hand, and t

responsive documents, if any, that may exist. 7. All documents and communications concerning the allegation in ¶ 59 of the Third-Party Claim that "Zwirn was well-aware in October 2006 of the improprieties detailed in the March 2007 report." 3 EFTA00729272 Response: Respondents object because thi

d without waiving the forgoing objection, Respondents will produce responsive documents, if any, that may exist. 3. All communications with any of the Zwirn Entities. Response: Respondents object because this request is overly broad, vague, unduly burdensome, designed to harass Respondents and/or third parties,

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

Suite 5100 1000 Louisiana Houston, TX 77002-5096 3. All notices to the Zwim Entities with respect to this Settlement Agreement shall be sent to the Zwirn Entities at and in care of: 12 EFTA00298492 CONFIDENTIAL William O'Brien Cooley LLP The Grace Building 1114 Avenue of the Americas New York, NY 10036