laims and defenses: Daniel Zwim; Jeffrey Epstein; David Lee; Doug Cardoni; Elise Hubsher; Brad Flood; Allyson Alimansky; and Heath Weisberg. Henry Bregstein of Katten Muchin Rosenman LLP may testify as an expert on the practices relating to restrictions on investment withdrawals (and the reasons for suc

laims and defenses: Daniel Zwim; Jeffrey Epstein; David Lee; Doug Cardoni; Elise Hubsher; Brad Flood; Allyson Alimansky; and Heath Weisberg. Henry Bregstein of Katten Muchin Rosenman LLP may testify as an expert on the practices relating to restrictions on investment withdrawals (and the reasons for suc

ting to such a lock-up, the investor gains the potential for the higher returns presented by illiquid investments. (See Exhibit X, Expert Report of Henry Bregstein, at 4-8.) Table 3 illustrates this point. If an investor invests $10 million on May I, 2002 (as Jeepers did) under a rolling two-year lock-up sched

370 Letter to David Lee from Jeffrey Epstein re Settlement Agreement and Release 1/5/2010 JE 001552 371 Henry Bregstein Biography — — 372 Henry Bregstein Expert Report 6/24/2011 — 373 Sponsor B - Redacted Confidential Offering Memorandum _ BREGSTEIN 0000000] — 00000049 374 Sponsor C — Redacte

eslow & Kelli L Moll (January 18 2007) (emphasis added). There simply is no uniform practice. The proffered testimony of the Fund's expert witness, Henry Bregstein, is that in "my experience," funds "routinely" use a tranche-by-tranche 2 For example, the Prentice Capital Limited Partnership Agreement expressly