Epstein Secrets

1 r.wmE ROSIN TARNIFSKY MONICA K. THURMOND NAV/ T94 NL II RG PISA MARIA," YULE MW&ISICE G. WEE BEL A. TvZicrifee. STEVEN J. WILLIAMS WOOD A LAWRENCE & .. WITDORCMIC MARK S. WLAZLO JJyUL KAYE N. YOSHINO TONG YU t TRAC RT EY A. CONE ROBE OMSK). JR. VRF I LLC v. Jeepers, Inc., JAMS Ref. No. 14

E BEL A. TvZicrifee. STEVEN J. WILLIAMS WOOD A LAWRENCE & .. WITDORCMIC MARK S. WLAZLO JJyUL KAYE N. Y

im brought against them in which certain of the allegations in such a claim were somewhat similar to those asserted by Mr. Epstein (or his company, Jeepers, Inc.) in the Arbitration. Claimants believe the proposed release language for the New Agreement quoted above accurately captures the agreement parties r

IR Taw:KY al31 J.L. 7:1^.4- LIZA 14..YLLAzmucite LAWRENCE G. WE Sygoora v Waco.. JR. ETH A. WILKINSON ST

and Fortress Value Recovery Fund I LLC (together, "Claimants"), we write to seek an order compelling Respondents Financial Trust Company, Inc. and Jeepers, Inc. (together, "Jeepers/FTC") to produce certain documents in response to our First Set of Document Requests, dated August 17, 2010. The requested docu

nting Improprieties and Response In Spring 2006, Lawrence Cutler, DBZ's Chief Compliance Officer, and David

ether, the "Zwim Respondents") submit this pre-hearing brief in opposition to the claims by Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc. (together, "FTC"). Preliminary Statement At no time did Daniel Zwim promise Jeffrey Epstein that FTC could immediately withdraw $80 million of its

DANIEL J TOAL MARK A liNDWIERG LIZA M. vcLA u LAWRENCE 0. WE THIOOORE V WENS. JR. Wet WILKINSON . 4

and Fortress Value Recovery Fund I LLC (together, "Claimants"), we write to seek an order compelling Respondents Financial Trust Company, Inc. and Jeepers, Inc. (together, "Jeepers/FTC") to produce certain documents in response to our First Set of Document Requests, dated August 17, 2010. The requested docu