EFTA00722250.txt

"As the general partner of the Fund, Zwim is liable for the breach"

"withdrawal of FTC's entire capital account"

"Zwim's management company had overcharged the Fund"

"on February 14, 2007, Epstein wrote the Fund a letter again demanding the complete withdrawal"

"the Fund had been borrowing money from D.B. Zwim Special Opportunities Fund, LTD... The advances totaled over $100 million"

"the Fund's former CFO recently sued Zwim"

"In July 2009, management of the Fund was taken over by Fortress Investment Group"

"Jeffrey Epstein ("Epstein"), through a firm he owned and managed named Financial Trust Company, Inc."

"Financial Trust Company, Inc. ("FTC"), made an $80 million investment in D.B. Zwim Special Opportunities Fund"

"Jeepers, Inc. is a wholly-owned subsidiary of FTC"

"Daniel Zwirn, who controlled the Fund"

"In 2002, Epstein was introduced to Daniel Zwim by Glenn Dubin"

"Dubin had a long-standing relationship with Epstein"

"Daniel Zwim controlled the Fund by virtue of his ownership of Zwim Holdings, LLC"

"Dubin and his partner Henry Swieca started Highbridge Capital"

"On November 13, 2006, Zwim and Dubin held a telephone conference with Epstein"

"Zwim started a hedge fund with Highbridge's sponsorship and assistance"

"Highbridge not only invested with the Fund but also took substantial direct and indirect ownership interests"

"During 2002 and 2003, FTC invested $60 million in the Fund"

"the Fund's Chief Financial Officer, Perry Gruss, had been terminated"

"In October 2006, Zwim contacted Epstein"

"Epstein telephoned Dubin to advise Dubin of Epstein's concerns"

"On or about November 13, 2006, Dubin, Epstein, and Zwim participated in a three-way call"

"The Fund breached these agreements by refusing to honor FTC's withdrawal requests"

"Zwim breached this fiduciary duty to FTC by, among other things, failing to make full disclosure"

"Attorneys for Respondent Counter-Claimants and Third-Party Claimants Financial Trust Company, Inc. ... Stephen D. Susman"

"Zwim and the Fund promised to honor FTC's November 13, 2006 request to withdrawal $80 million"

"Epstein wrote the Fund a letter again demanding the complete withdrawal of FTC's entire capital account"

"Epstein had repeatedly given Zwim notice of his demand for a complete withdrawal"

"Zwim relied on Dubin, as a principal of the Fund, to introduce him to Epstein"

"FTC's investment... Epstein believed that Zwim and the Fund would be closely monitored"

"more than $3 million in investor money had been used to pay for a private Gulfstream 400 jet for Zwirn"

"Zwim and the Fund were not honest with Epstein in the October 2006 about the scope of the Fund's problems"