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

R KELLEY D. PARKER ROBERT P PARKEID MARC I. L1aRLMUTTER MARK • MERANTZ VALERIE E. RADWANER CARL L REISNER WALTER G. RICCIARIM WALTER RIEMAN RICHARD A. ROI1N ANDREW N ITO NIIRG J ROTHEN•ERG JACQUELINE P RAPHAEL M RUSSO JE CCCCC D. SA EPSTEIN JEFFREY SARROSAMUELS rt KENNETH MNIMITAEIDER RO

kinds of investments the fund made; 3 correct? 4 A. Correct. 5 Q. Prior to October 2006 -- 11:48:45 6 A. Yes. 7 Q. -- you had met Mr. Zwirn once; correct? 8 A. Yes. 9 Q. And you had never spoken to him on the 10 phone; correct? 11:48:56 11 A. To the best -- 12 Q. That you re

03:38 6 Q. And he told you it was managed by Dan 7 Zwirn? 8 A. I doubt it. 9 Q. What did he tell you about Dan Zwirn? 10 A. He said the Zwirn fund was a fund that 11:03:44 11 I should put some money in. 12 Q. Did he tell you why? 13 A. They were going to be doing PIPE 14 investme

REPORTING COMPANY www.veritext.com EFTA00299205 Page 122 1 Epstein 2 negligence and a fiduciary obligation of Perry 3 Gruss, Dan Zwirn, Mr. Kahn, whoever I'm 4 unfamiliar with his first name -- that no one made 5 disclosure to me at any relevant time so that each 11:41:21 6 one had brea

all. 10 Q. Up to February 14th -- up to February 03:06:39 11 14th, 2007, other than the conversations that 12 you've testified about with Mr. Zwirn, do you 13 recall any other conversations with him? 14 A. Through the date -- there was some 15 conversation, I believe, with respect to Georg

eritext.com EFTA00299289 Page 206 1 Epstein 2 Q. Do you know who prepared it? 3 A. No. 4 Q. Did you have any conversations with Dan 5 Zwirn after this letter was sent? 03:09:03 6 A. Not that I recall. With regard to the 7 investments? 8 Q. With regard to the investments. 9 A.

3 that the -- he thought that the SEC might file an 4 investigation against him, Perry Gruss, sometime 5 in the future. 03:16:18 6 That Mr. Kahn had showed up on most of 7 the e-mail with respect to the airplane which 8 Schulte Roth had been -- I believe it was, Schulte 9 Roth had been c

ny, do you know that? 12 MR. GOLDBERGER: Form. 13 THE WITNESS: No. 14 BY MR. EDWARDS: 15 Q. Have you ever heard of a corporation, of 16 DB Zwirn or something like that? 17 A. No. 18 Q. Doesn't ring a bell? 19 A. No. 20 Q. Okay. Other than the couple trips or two 21 trips to New Y

Q. Did she also schedule appointments for 23 these young females to come to Jeffrey Epstein's 24 house? 25 MR. GOLDBERGER: Form. Rich Kahn. Richard Kahn. And how do you spell the last name? K-a-h-n. And where is he located? New York office. What does he do? I guess he was involved with the accou

in's 24 house? 25 MR. GOLDBERGER: Form. Rich Kahn. Richard Kahn. And how do you spell the last nam

R-LLP EFTA00727164 II. Detailed chronology A. Pre-closing events • Spring 2005: Dan Zwirn's travel became increasingly frequent and global • Zwirn began considering purchase of private plane. See Tab 1-2 • 8/5/05 — 9/14/05: O'Hara paid pre-closing costs from management company account, subje

nd down payment for letter of credit • Confirmed: SRZ conclusions • Gruss knew about and approved use of LP and HCM/Z money • Mixed evidence on Kahn's knowledge Subject to Confidentiality Agreement of 11/14/2006 GIBSON, DUNN SiCRCTCHER-LLP EFTA00727164 II. Detailed chronology A. Pre-closing

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

were properly financed, and that Gruss held himself out to be qualified to perform these functions. 4 EFTA00731282 20. Admit that Harold Kahn ("Kahn") was hired in April 2005 to serve as the Company's Chief Operating Officer; and otherwise deny the allegations of Paragraph 20, except aver that G