EFTA00586232.txt

"the rolling two-year anniversary of the January 1, 2005 investment"

"Attorneys for Claimants Financial Trust Company, Inc."

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

"FTC decided to invest an additional $20 million... the investment would be made effective January 1, 2005"

"the Fund's Chief Financial Officer, Perry Gruss"

"In October 2006, Zwim contacted Epstein"

"Epstein, then, contacted Dubin"

"Dubin, who owned an interest in the Fund's General Partner and was Zwim's mentor and partner"

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

"Shulte Roth & Zabel (the Fund's outside counsel)"

"Claimants FTC and Jeepers were owned and managed by Jeffrey Epstein"

"Claimants FTC and Jeepers were owned and managed by Jeffrey Epstein"

"Claimant Jeepers Inc. was a wholly-owned subsidiary of FTC."

"Between 2002 and 2005, FTC invested a total of $80 million in various tranches in the Fund."

"D.B. Zwirn Special Opportunities Fund, L.P. ("Fund"), which was managed primarily by Daniel Zwim ("Zwim")."

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

"Epstein had a long-standing relationship with Dubin"

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

"Respondent Zwirn Holdings was the controlling member of the Fund's general partner D.B. Zwim Partners, LLC."

"Respondent D.B. Zwirn Partners, LLC, was the general partner of the Fund."

"management of the Fund was taken over by Fortress Investment Group, and Zwim was removed from direct involvement in the Fund"

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

"in November 2006, Zwim had begged FTC to refrain from making a complete withdrawal demand"

"$3 million in investor money had been used to pay for a private jet that Zwim owned personally"

"FTC sent by fax a written notice to Zwim demanding withdrawal of "$80 million of Financial Trust Company's interest in D.B. Zwim Special Opportunities"

"After working for Highbridge, in 2002, Zwirn started his own hedge fund"

"Epstein wrote the Fund a letter demanding a complete withdrawal of FTC's entire investment"