ur years. Thus, until the Fund's lengthy dissolution is complete, Jeepers is unable to withdraw any of its money from the Fund. 43. As a result of D.B. Zwirn's and Mr. Zwim's breach of fiduciary duty, manipulation of and outright fraud against Jeepers, Defendants have unlawfully seized control of over $144

d the right to withdraw all of its money (as Mr. Epstein originally demanded), but not some of its money (as Mr. Zwim urged FTC to demand). Instead, D.B. Zwirn's CFO specifically informed Jeepers that the November 13, 2006 withdrawal notice was invalid because Jeepers had no withdrawal rights whatsoever at t