Epstein Secrets

no reasonable basis or need to explore its discredited theory through a deposition of Mr. Gruss. By way of background, Mr. Gruss was the CFO of the Zwirn entities. He effectively was terminated by DBZ on October 4, 2006, shortly after an internal investigation by Schulte Roth & Zabel LLP ("Schulte Ro

stoppel for the Fund's failure to honor Mr. Zwim's alleged promise and subsequent written redemption requests; • fraudulent inducement because Mr. Zwirn did not intend to honor his alleged promise when it was made on November 13, 2006; and • breach of fiduciary duty and negligent misrepresentation

Fortress VRF I LLC and Fortress Value Recovery Fund I LLC v. Jeepers, Inc. JAMS Ref. No. 1425006537 Dear Judge Carpinello: Third-Party Respondents Daniel B. Zwim, D.B. Zwim & Co. L.P. ("DBZ"), DBZ GP, and Zwirn Holdings, LLC submit this letter in response to Third-Party Claimants Financial Trust Company, Inc

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

k, New York 10018 Re: Fortress VRF I LLC and Fortress Value Recovery Fund 1 LLC v. Jeepers, Inc. JAMS Ref. No. 1425006537 Dear Judge Carpinello: Daniel B. Zwim submits this letter in advance of our scheduled mediation session with Your Honor on November 2. The only remaining issue regarding the settlement

cited each of Mr. Epstein's investments with the Zwirn fund, as well as the commissions and the other terms in respect thereof. For example, at Mr. Zwirn's request, Mr. Dubin requested that Mr. Epstein pay a 2% management fee to the Zwim fund, rather than Mr. Epstein's offer of 1.3%. In addition, aft

duction and various telephone calls trying to resolve disputes. 4. Glenn Dubin negotiated and solicited each of Mr. Epstein's investments with the Zwirn fund, as well as the commissions and the other terms in respect thereof. For example, at Mr. Zwirn's request, Mr. Dubin requested that Mr. Epstein p

y, Inc. invested hundreds of millions of dollars with Highbridge as an investment manager with its many sub-advisors from 2001 to the present. 2. Daniel B. Zwim had been one of those sub-advisors beginning in 2002 and, according to the Securities and Exchange Commission, remained a sub-advisor through at le

first deposed- (principal of leepers, Inc.) Daniel B. Zwim (individually and principal of D.B. Zwirn Special Opportunities Fund, L.P. and related Zwirn entities) Glenn Dubin Harry Beller David Lee (non-party witnesses) -second deposed- -third deposed- 3. The dates contained in Scheduling order

l for the parties have agreed that depositions will occur in the following order: Jeffrey E. Epstein -first deposed- (principal of leepers, Inc.) Daniel B. Zwim (individually and principal of D.B. Zwirn Special Opportunities Fund, L.P. and related Zwirn entities) Glenn Dubin Harry Beller David Lee (no