CLAIMS OF DEFENDANTS D.B. ZWIRN & CO., L.P. AND D.B. ZWIRN PARTNERS, LLC JURY TRIAL DEMANDED Defendants D.B. Zwim & Co., L.P. (the "Company") and D.B. Zwim Partners, LLC ("DBZLLC"), by their attorneys Cooley Godward ICronish LLP, answer the Complaint and Jury Demand herein as follows: I. Aver that in 2006, de

uss had obligations to the Company and DBZLLC in addition to those set forth in the unexecuted Supplementary Agreement among D.B. Zwim & Co., L.P., D.B. Zwim Partners, LLC and Perry Gruss (the "Supplementary Agreement"). 58. Deny the allegations of Paragraph 58, except admit that Gruss was a partner in the Comp

agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on their behalf. 2. "Zwirn Parties" means Daniel Zwirn, D.B. Zwim Partners, LLC, D.B. Zwirn & Co, L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their members, employees, representatives, agents, predecessors,

"Claimants"); (ii) Jeffrey Epstein, Jeepers, Inc. ("Jeepers") and Financial Trust Company, Inc. ("FTC") (collectively, the "Epstein Parties"); (iii) D.B. Zwim Partners, LLC, D.B. Zwim & Co., L.P., DBZ GP, LLC and Zwim Holdings, LLC (collectively, the "Zwim Entities") and Daniel Zwim (together with the Zwim Entitie

of document, subject matter, number of pages, and the basis of the claim of privilege asserted. DEFINITIONS 1. "Zwim Entities" means Daniel Zwim, D.B. Zwim Partners, LLC, D.B. Zwim & Co., L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their respective members, managers, general partners, limited pa

d to the breach of contract claims against D.B. Zwim Special Opportunities Fund, L.P. k/n/a Fortress Value Recovery Fund I LLC ((the) "Fund"), [and] D.B. Zwim Partners, LLC, D.B. Zwim & Co. L.P., DBZ GP LLC, Zwirn Holdings LLC, and Daniel Zwirn [together, the "Zwim Parties")." (Financial Trust Company, Inc.'s and

of document, subject matter, number of pages, and the basis of the claim of privilege asserted. DEFINITIONS I. "Zwim Entities" means Daniel Zwim, D.B. Zwim Partners, LLC, D.B. Zwim & Co., L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their respective members, managers, general partners, limited pa

, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on their behalf. 2. "Zwim Parties" means Daniel Zwim, D.B. Zwim Partners, LLC, D.B. Zwim & Co, L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their members, employees, representatives, agents, predecessors,

of document, subject matter, number of pages, and the basis of the claim of privilege asserted. DEFINITIONS I. "Zwim Entities" means Daniel Zwim, D.B. Zwim Partners, LLC, D.B. Zwim & Co., L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their respective members, managers, general partners, limited pa