t in advance exactly what new third-party claims could be brought against the Zwim Parties, how the pre-Arbitration agreements between the Fund and the Zwirn Parties might (or might not) apply to such claims, and how the currently proposed release language might (or might not) apply to such claims. Therefore, the

reement and a blackline comparing this version to the initial version we circulated on August 5. We reviewed the comments provided by Mr. Indyke and the Zwirn Parties, and this version incorporates some, but not all, of their proposed changes. We have not yet received comments from counsel for Mr. Dubin. EFTA004

ense include terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communications between You on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communications between You on the one hand, and any of

clude terms in the present tense. DOCUMENT REQUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

clude terms in the present tense. DOCUMENT REOUESTS 1. All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. 2. All documents concerning any communication between Glenn Dubin on the one hand, and

arties now manage or formerly managed, and any fund or account now or formerly managed by Claimant Fortress VRF I LLC or its affiliates; and (2) the Zwirn Parties and each of their past, present and future parents, subsidiaries and other affiliates, each of the predecessors, successors, heirs and assigns of e

have at any time acted, or purported to act on behalf of any of the foregoing (the "Dubin Released Parties," except that, for the sake of clarity, the Zwirn Parties and any individuals or entities that are directly or indirectly controlled by one or more of the Zwirn Parties, shall not be considered Dubin Relea

ll documents concerning any communication between Glenn Dubin on the one hand, and any of the Third-Party Claimants on the other, concerning any of the Zwirn Parties, the Claimants or the Fund. Response to Request No. 2: Highbridge objects to this Request on the grounds that it is overly broad, unduly burdensom

Instruction 2. SPECIFIC RESPONSES AND OBJECTIONS Request No.1: All documents concerning any communication between You on the one hand, and any of the Zwirn Parties on the other, concerning any of the ThirdParty Claimants. Response to Request No.1: Dubin objects to this Request on the grounds that it is overl

tion 2. SPECIFIC RESPONSES AND OBJECTIONS Request No.1: All documents concerning any communication between Glenn Dubin on the one hand, and any of the Zwirn Parties on the other, concerning any of the Third-Party Claimants. Highbridge objects to the definition of "All" and "each" as vague, 6 EFTA01592057 R