rm, Highbridge Capital Corporation. Between 2002 and 2005, Epstein (through an entity called Financial Trust Company, Inc.) invested $80 million in the Zwirn Fund. 4. In early September 2006, Zwim informed me that he was firing the Fund's then-Chief Financial Officer, Perry Gruss. Zwim said that he discovere

bridge Managed Account. EFTA00791902 6. All documents concerning Highbridge's knowledge during 2006 and 2007 of the accounting irregularities at the Zwirn Fund or Zwim Entities as described in Epstein's Claim. 7. All documents concerning Highbridge's disclosure to Epstein of Highbridge's knowledge of the

ment. This sort of language is conspicuously absent from the January 11, 2005 Letter Agreement between Zwirn and FTC. 18. I have been informed that the Zwirn Fund has suggested that every hedge fund must track each investment separately in order to calculate, for example, the high-water mark. This is simply no

nilla. The contractual language is clear, and the legal principles are solid. Under the terms of the 2005 Letter Agreement between FTC/Jeepers and the Zwirn Fund, FTC was entitled to withdraw its "Capital Account" on March 31, 2007, so long as it gave notice before December 1, 2006. Notice was given, after a