EFTA00613940.txt

"Jeepers, an investment vehicle controlled by Jeffrey Epstein"

"PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP ... Attorneys for Claimants Fortress VRF I LLC"

"PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP ... Attorneys for Claimants ... Fortress Value Recovery Fund 1 LLC"

"Jeepers's Five Subscriptions for Investments in the Fund"

"From April 2002 to January 2005, Jeepers made five separate investments in the Fund, totaling $80 million."

""admitted" Jeepers "as a limited partner [to the Fund] as of [the date of the investment].""

"Mr. Zwirn would have agreed to such a substantial withdrawal on behalf of the Fund and exercised any discretion granted the General Partner"

"Jeepers obtained the right to withdraw its Fourth Investment of $10 million and its Fifth Investment of $20 million, plus accrued earnings on both inv"

"Jeepers and the Fund entered into a settlement agreement (the "Settlement Agreement")"

"the Fund's independent auditor, PricewaterhouseCoopers LLP"

"VRF I LLC became the managing member of the Fund"

"Jeepers also filed claims for breach of fiduciary duty and negligent misrepresentation against Mr. Zwirn"

"Respondent Jeepers, Inc. is a U.S. Virgin Islands corporation that is owned and controlled by Jeffrey Epstein"

"FTC, Jeepers's parent entity, which is another investment vehicle that Mr. Epstein controls"

"Daniel Zwirn was the managing member of Zwirn Holdings LLC"

"Daniel Zwirn was the... managing partner of the Zwirn Investment Manager"

"Zwirn Holdings LLC was a holding company that held interests in the Zwirn Fund GP"

"Zwirn Holdings LLC was a holding company that held interests in... the Zwirn Investment Manager GP"

"having received an assignment of limited partnership interests in the Fund in 2006 from FTC, Jeepers's parent entity"

"Mr. Epstein's $80 million withdrawal"

"Jeepers could have withdrawn its investment"

"the specific nature of all three irregularities was fully disclosed in the second round of October calls to investors—including Mr. Epstein"

"the SEC investigated Mr. Zwirn for his role in the irregularities at the Fund"

"FTC, Jeepers's predecessor in interest"

"If an investor invests $10 million on May I, 2002 (as Jeepers did)"

"Harry Beller, Mr. Epstein's accountant"

"Glenn Dubin... a co-owner of the Fund's General Partner through an entity called Dubin & Swieca Asset Management, LLC"

"in his February 14, 2007 letter to Mr. Zwirn, Mr. Epstein argues that his $80 million request should be honored"

"Mr. Epstein is a close personal friend of Mr. Dubin's"

"and the godfather of Mr. Dubin's children"

"for which Mr. Dubin paid a $20 million "fee" to Mr. Epstein"

"Mr. Epstein invested in the Fund on the recommendation of Mr. Dubin"

"Fund employees David Lee and Elise Hubsher"

"Fund employees David Lee and Elise Hubsher"

"the Fund is winding up, a process being overseen by the Fund's current manager, VRF I LLC"

"Jeepers, however, takes the position that all of its multiple investments in the Fund"

"Mr. Epstein nonetheless elected to submit an invalid request for the "immediate" withdrawal of $80 million"

"Lawrence Cutler, the Fund's Chief Compliance Officer"

"David Proshan, the Fund's General Counsel"

"the Fund parted ways with its Chief Financial Officer, Perry Gruss"

"Jeepers's withdrawal demands void and of no effect, or valid for no more than $45 million"

"Daniel Zwirn, an executive at the Fund's former manager"

"Partial withdrawals may also be made at such other times with the consent of, and upon such terms of payment as may be approved by, the General Partne"

"On January 11, 2005, in connection with Jeepers's Fifth Investment, the General Partner agreed in a side letter"

"Mr. Epstein requested the General Partner's consent to transfer all of his limited partnership interests in the Fund from FTC to Jeepers, Inc."

"Mr. Epstein requested the General Partner's consent to transfer all of his limited partnership interests in the Fund from FTC to Jeepers, Inc."

"Jeepers, Inc. is a member of the Fund... owned and controlled by Jeffrey Epstein"

"PAUL, WEISS, RIFIUND, WHARTON & GARRISON LLP... Attorneys for Claimants Fortress VRF I LLC and Fortress Value Recovery Fund I LLC"

"The value of Jeepers's investments was in excess of $120 million as of March 30, 2007"

"the SEC specifically alleged that Gruss did not inform Mr. Zwirn of the 'Inter-fund Transfer practice' or of when 'client funds had been used for the "