EFTA01082182

LANKLER SIFFERT & WOHL LLP 
ATTORNEYS AT LAW 
330° FLOOR 
500 FIFTH AVENUE 
Ncw YORK, N. Y. 10110-3398 
WWW.L.SWLAW COM 
April 1, 2011 
BY E-MAIL AND BY HAND 
The Honorable Anthony J. Carpinello 
JAMS 
620 Eighth Avenue, 34th Floor 
New York, New York 10018 
TELEPHONE 
TELEFAX 
a 
Re: 
Fortress VRF I LLC & Fortress Value Recovery Fund I LLC v. Jeepers, Inc. 
JAMS Ref. No. 1425006537 
Dear Judge Carpinello: 
Daniel B. Zwim, D.B. Zwim & Co., L.P., DBZ GP, LLC, and Zwim Holdings, LLC 
submit this letter to address two discovery issues. First, we request permission to question 
Jeffrey Epstein at his deposition about the conviction, settlements, and investigations related to 
his sexual misconduct in light of both recent statements by Mr. Epstein about his offense and 
reports of ongoing government investigation into additional misconduct by Mr. Epstein. Second, 
we request that Mr. Epstein be compelled to produce documents concerning these subject areas 
to inform our questioning of him.' Although Your Honor previously indicated that Mr. Epstein 
did not have to produce any documents related to his misconduct beyond a record of his criminal 
conviction, Your Honor permitted us to file a formal application, which we now do. 
1. 
Deposing Mr. Epstein on His Misconduct 
We request permission to question Mr. Epstein at his deposition about the conviction, 
settlements, and investigations related to his sexual misconduct. These areas of inquiry are 
relevant under New York law. According to the Second Department, "[i]t is well established 
that a witness in a civil or criminal case . . . may be impeached by inquiry into prior acts of 
misconduct which tend to discredit the witness' character and show him or her to be unworthy of 
belief. Generally, a witness may be interrogated as to any immoral, vicious, criminal or 
wrongful act involving moral turpitude." People v. Hunter, 88 A.D.2d 321, 322 (2d Dep't 1982) 
(citing cases). 
Mr. Epstein's recent statements about his conviction bring his credibility into question. 
In a February 25, 2011 article in the New York Post, Mr. Epstein was quoted as saying, "I'm not 
a sexual predator, I'm an 'offender.' It's the difference between a murderer and a person who 
I Third-Party Respondents' First Set of Document Requests. fl 23-25 (Exhibit A). 
EFTA01082182

LANKLER SIFFERT & WOHL LLP 
The Honorable Anthony J. Carpinello 
April 1, 2011 
Page 2 
steals a bagel," and that "the crime that was supposedly committed in Florida is not a crime in 
New York."2 Mr. Epstein's refusal to acknowledge the criminal and immoral nature of his 
misconduct in itself bears on his credibility, is relevant to the bona fides of his claims, and 
should be admitted as evidence at the hearing. These statements demonstrate a lack of candor as 
to the prostitution felonies that Mr. Epstein pled guilty to and about which we are entitled to 
question Mr. Epstein. 
Recent news articles also report that Mr. Epstein has committed "wrongful act[s] 
involving moral turpitude" beyond the offenses that resulted in his conviction. A March 6, 2011 
article in the New York Post stated that the FBI is investigating new underage-sex charges 
against Mr. Epstein.3 Furthermore, several articles state that Mr. Epstein made numerous out-of-
court financial settlements with girls who leveled sexual allegations against him,4 raising the 
question of whether Mr. Epstein entered into such settlements to effectively silence potential 
witnesses in the federal investigation into his misconduct. Another report details Mr. Epstein's 
conduct with the government during its investigation, including his counsel's investigation of 
individual prosecutors and their families in an attempt to disqualify members of the prosecution 
team.5 These articles raise serious allegations involving Mr. Epstein's predatory behavior and 
relations with girls under the age of 17, and his attempts to shield himself from liability for his 
immoral and criminal misconduct. We should be permitted to depose Mr. Epstein not just about 
the fact that he was criminally convicted for his sexual relations with one of these young girls, 
but also about his misconduct with other minors, his communications with prosecutors 
concerning criminal investigations about this subject matter, communications with complainants 
in civil litigation in which he reportedly bought their silence by the payment of money. and about 
his lack of candor and lack of remorse. 
2. 
Documents Related to Mr. Epstein's Misconduct 
We further request that Mr. Epstein be compelled to produce all documents concerning 
his criminal conviction, all communications with prosecutors concerning criminal investigations. 
and all communications with complainants in civil litigation. We previously requested these 
documents.6 Your Honor previously indicated that Jeepers should produce the records of Mr. 
Epstein's conviction, but nothing else. Your Honor expressly allowed that we could make a 
formal application for these materials if deemed appropriate. We now do so. These documents 
2 See Amber Sutherland et al., Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. POST, Feb. 25, 
2011 (Exhibit B). 
3 See Candice M. Glove et at, &man sex rap looms, N.Y. POST, Mar. 6, 2011 (Exhibit C); see also Dan Mangan. 
Schoolgirl confidential, N.Y. POST, Mar. 9, 2011 (Exhibit D). 
See, e.g., Cathy Burke, Prince Andrew tours Manhattan with billionaire sex offender Jeffrey Epstein, N.Y. POST, 
Feb. 2I, 2011 (Exhibit E); Michelle Dargan, Lawsuit documents link Jeffrey Epstein to modeling agency owner Jean 
Luc Brunel, PALM BEACH DAILY NEWS, Oct. 15, 2010 (Exhibit F). 
5 See Conchita Samoff and Lee Aitken, Behind Pedophile Jeffrey Epstein's Sweetheart Deal. BUSINESS 
INSIDER/T'HE DAILY BEAST, Mar. 25, 2011 (Exhibit G). 
6 Third-Party Respondents' First Set of Document Requests, II 23-25 (Exhibit A). 
EFTA01082183

LANKLER SIFFERT & WOHL LLP 
The Honorable Anthony J. Carpinello 
April 1, 2011 
Page 3 
are relevant to Mr. Epstein's credibility and candor, and we respectfully submit that we are 
entitled to obtain them from Mr. Epstein to inform our questioning of him on these subject areas. 
Respectfully. 
4S. iffert 
Enclosures 
cc: 
Stephen D. Susman. Esq. (by email) 
Allan Arffa. Esq. (by email) 
William O'Brien, Esq. (by email) 
William Schwartz. Esq. (by email) 
EFTA01082184

Exhibit A 
EFTA01082185

JUDICIAL ARBITRATION AND MEDIATION SERVICE 
NEW YORK, NEW YORK 
FORTRESS VRF I LLC and 
FORTRESS VALUE RECOVERY FUND I LLC, 
Claimants, 
v. 
JEEPERS, INC. 
Respondents, 
and 
FINANCIAL TRUST COMPANY, INC., and 
JEEPERS, INC., 
Counter-Claimants and 
Third-Party Claimants, 
v. 
FORTRESS VALUE RECOVERY FUND I LLC, 
Counter-Respondents, 
D.B. ZWIRN PARTNERS, LLC, 
D.B. ZWIRN & CO, L.P., 
DBZ GP, LLC, ZWIRN HOLDINGS, LLC, 
and DANIEL ZWIRN, 
Third-Party Respondents. 
Ref. No.: 1425006537 
THIRD-PARTY RESPONDENTS' FIRST REOUEST FOR PRODUCTION 
D.B. Zwim Partners, LLC, D.B. Zwim & Co, L.P., DBZ GP, LLC, Zwim Holdings, 
LLC, and Daniel Zwim (together "Third-Party Respondents"), by and through undersigned 
counsel, hereby request that Financial Trust Co, Inc. and Jeepers, Inc. produce the documents 
EFTA01082186

and materials described below for inspection and copying at the offices of Cooley Godward 
Kronish LLP, 1114 Avenue of the Americas, New York, NY 10036. 
INSTRUCTIONS 
1. 
This is a continuing request. If, after making your initial responses, you obtain or 
become aware of any further information responsive to this request, you are required to 
supplement your responses and provide that information. 
2. 
These requests apply to all documents within the possession, custody, or control 
of Third-Party Claimants, including but not limited to Jeffery Epstein, Harry Beller, and Darren 
Indyke, and any affiliates, attorneys, agents, representatives, accountants, and employees of 
Third-Party Claimants, whether directly or indirectly, including documents within the 
possession, custody, or control of Glenn Dubin, whose affidavit accompanied the Third-Party 
Claimants' Statement of Counterclaim and Third-Party Claim in this case. 
3. 
For all documents withheld from production, state the date, authors, recipients, 
type of document, subject matter, number of pages, and the basis of the claim of privilege 
asserted. 
DEFINITIONS 
1. 
"Third-Party Claimants" means Jeffery Epstein, Financial Trust Company, Inc. 
and Jeepers, Inc. and includes all their directors, officers, employees, representatives, agents, 
parents, subsidiaries, predecessors, affiliates, divisions, and anyone else acting on their behalf. 
2. 
"Zwim Entities" means Daniel Zwim, D.B. Zwim Partners, LLC, D.B. Zwim & 
Co, L.P., DBZ GP, LLC, and Zwim Holdings, LLC, and includes all their members, employees, 
representatives, agents, predecessors, and anyone else acting on their behalf. 
3. 
"Fund" means D.B. Zwim Special Opportunities Fund n/k/a Fortress Value 
Recovery Fund I LLC and f/k/a Highbridge/Zwim Special Opportunities Fund and includes its 
2 
EFTA01082187

directors, officers, employees, representatives, agents, parents, subsidiaries, predecessors, 
affiliates, divisions, and anyone else acting on its behalf. 
4. 
"Third-Party Claim" means Jcepers, Inc.'s Response and Financial Trust 
Company, Inc.'s and Jeepers, Inc.'s Statement of Counterclaim and Third-Party Claim in this 
case filed on May 21, 2010. 
5. 
"2005 Side Letter Agreement" means the January 11, 2005 Letter from D.B. 
Zwim Partners, LLC to Financial Trust Company, Inc. regarding the latter's January 1 
Investment in D.B. Zwim Special Opportunities Fund , L.P. 
6. 
"L.P. Agreements" means the Ilighbridge/Zwim Special Opportunities Fund, L.P. 
Amended and Restated Limited Partnership Agreement dated May 1, 2003, and the D.B. Zwim 
Special Opportunities Fund, L.P. Second Amended and Restated Agreement of Limited 
Partnership dated May 27, 2005. 
7. 
"Confidential Memoranda" means the Flighbridge/Zwim Special Opportunities 
Fund, L.P. Confidential Memorandum dated May 2003 offering limited partnership interests in 
the Fund and D.B. Zwim & Co, L.P's Supplement to the Confidential Memorandum dated 
November 17, 2004. 
8. 
"Document" means any document including but not limited to correspondence, 
internal or external memoranda, letters, drafts, non-identical copies, notes including handwritten 
notes, minutes of meetings, call logs, records of conversations or messages, whether in writing or 
upon any mechanical, electrical, or electronic recording device, e-mail and voicemail, SMS, or 
text messages, tape or electronic recordings, videotapes, diaries, sketches or designs, 
appointment or telephone records, newspaper or magazine articles, press releases, banking 
records and notices, and information of whatever kind stored on computers, including computer 
3 
EFTA01082188

disks, hard drives, and other media. In all cases where originals or non-identical copies are not 
available, "documents" also means identical copies of original documents and copies of non-
identical copies. 
9. 
"Communication" means the transmittal of information (in the form of facts, 
ideas, inquiries or otherwise). 
10. 
"Concerning" means relating to, referring to, describing, evidencing or 
constituting. 
II. 
"Person" means any natural person or any business, legal or governmental entity 
or association. The term "person" includes both the singular and the plural. 
12. 
"Criminal Investigation" means any investigation of Jeffrey Epstein's conduct by 
the United States Department of Justice, the State of Florida, or the prosecutor's office of any 
other state, city or county. 
13. 
"Civil Litigation" means any lawsuit brought against Jeffrey Epstein containing 
allegations of sexual misconduct by Jeffrey Epstein. 
14. 
Rules of construction: "All" and "each" shall be construed as all and each; "and" 
and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the 
scope of this request all requests that might otherwise be construed to be outside its scope; the 
use of the singular form of any word includes the plural and vice versa; "any" includes and 
encompasses the words "each" and "all"; terms referring to or using one gender include both 
genders; terms used in the present tense include terms in the past tense and terms in the past 
tense include terms in the present tense. 
DOCUMENT REQUESTS 
1. 
All documents referred to or relied upon in the Third-Party Claim. 
2. 
All communications with the Fund. 
4 
EFTA01082189

3. 
All communications with any of the Zwirn Entities. 
4. 
All documents and communications concerning Third-Party Claimants' 
investments in the Fund. 
5. 
All documents and communications concerning any or all of the conversations 
alleged in ¶¶ 33, 34, 35, 36, and/or 37 of the Third-Party Claim. 
6. 
All documents and communications concerning any purported agreement or 
promise by Daniel Zwirn as alleged in ¶ 37 of the Third-Party Claim. 
7. 
All documents and communications concerning the allegation in ¶ 59 of the 
Third-Party Claim that "Zwim was well-aware in October 2006 of the improprieties detailed in 
the March 2007 report." 
8. 
All documents concerning the allegations contained in the first sentence of ¶ 71 of 
the Third-Party Claim that "Zwim and the Fund made false statements and omitted material 
information ... in the Fall of 2006, including, without limitation, misrepresentations about 
Zwim's knowledge and participation in the Fund's financial and accounting irregularities, the 
nature and scope of the problems, and the Fund's true intent not to honor FTC's request." 
9. 
All documents and communications concerning the assignment of Financial Trust 
Company, Inc.'s limited partnership interests in the Fund to Jeepers, Inc. 
10. 
All documents and communications concerning any actual or contemplated 
request to withdraw some or all of Third-Party Claimants' investments from the Fund. 
11. 
All documents and communications concerning the 2005 Side Letter Agreement. 
12. 
All documents and communications concerning the Confidential Memoranda. 
5 
EFTA01082190

13. 
All documents and•communications concerning Third-Party Claimants' rights or 
obligations under the L.P. Agreements, 2005 Side Letter Agreement, and/or Confidential 
Memoranda. 
14. 
All documents and communications concerning Third-Party Claimants' 
understanding of the terms of the L.P. Agreements, 2005 Side Letter Agreement, and/or 
Confidential Memoranda. 
15. 
All documents and communications concerning any rights of or restrictions on 
Third-Party Claimants with respect to withdrawing investments from the Fund. 
16. 
All documents and communications concerning Third-Party Claimants' 
understanding of any rights of or restrictions on Third-Party Claimants with respect to 
withdrawing investments from the Fund. 
17. 
All communications with any of the Fund's other investors or their 
representatives concerning any of the Zwirn Entities or the Fund. 
18. 
All communications with the Securities and Exchange Commission concerning 
any of the Zwirn Entities or the Fund. 
19. 
All documents and communications concerning Jeffrey Epstein's involvement in 
J.P. Morgan's investment in Highbridge Capital Management, including but not limited to the 
introduction of Glenn Dubin to Jes Staley. 
20. 
All documents and communications concerning the affidavit of Glenn Dubin 
attached to the Third-Party Claim, including but not limited to the statements made in the 
affidavit and the creation of the affidavit. 
21. 
All communications with Glenn Dubin concerning the Fund, any of the Zwim 
Entities, the Third-Party Claimants' investments in the Fund, and/or this arbitration 
6 
EFTA01082191

22. 
All documents concerning any damages alleged in the Third-Party Claim. 
23. 
All documents concerning any criminal conviction of Jeffrey Epstein. 
24. 
All communications with any prosecutor or prosecutor's office concerning any 
Criminal Investigation. 
25. 
All communications with any complainant or his or her attorney concerning any 
Civil Litigation, including but not limited to any settlement with any complainant. 
Dated: New York, New York 
August 17. 2010 
COOLEY LLP 
By: t eS 
apm 
Alan Levine 
William O'Brien 
Arastu K. Chaudhury 
1114 Avenue of the Americas 
New York New York 10036 
New York. New York 101 10 
LANKLER SIFFERT & WOHL LLP 
By: 
John S. Siffert 
Daniel E. Reynolds 
Andrew S. Lee 
500 Fifth Avenue 
Attorneys for Third-Party Respondents D. B. 
Zwirn Partners, LLC (n/k/a Irvington 
Associates, LLC), D.R. Zwirri & Co., L.P. 
(n/k/a Irvington Management, LP.), DBZ 
GP, LLC (n/k/a Irvington GP, LLC), and 
Zwirn Holdings, LLC (n/k/a Irvington 
Holdings, LW). 
7 
Attorneys for Third-Party Respondent 
Daniel Zwirn 
EFTA01082192

Exhibit B 
EFTA01082193

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EFTA01082194

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EFTA01082195

Exhibit C 
EFTA01082196

Pervy financier Jeffrey Epstein being investigated again by leds for sex with teens:report ... Page 1 of I 
CMUSl
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update sum. Ma- 6 201, 
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Bizman sex rap looms 
By CANDICE M GIOVE and TIM PERONE 
LOW Vp0.40 
HAM 
2011 
Peen, 1 IS sal 1.0sch a 2011 
The kids are set to probe new underage-sex charges against pervy financier Jeffrey Epstein. who has already served 18 
months for soliciting sex for minors it was reported last night 
Mother woman has told Britain's Daily Mail that Epstein introduced her to his dirty old pals when she was his teen 
"traveling masseuse" starting in 2000 
The FBI investigation is expected to bring further scrutiny on Epstein's friendship with British Prince Andrew - who has 
vowed to exile the Upper East Side pedophile from his court the paper said 
The new accuser 
claims she was recruited at age 15 to be Epstein's "prostitute for him and his friends 
who shared his interests in young girls: she told the Mail 
A source close the investigation told the paper. "This is being taken very seriously " 
She has previously described how she was brought into Epstein's creepy world by Ghislaine Maxwell, the daughter of the 
disgraced late media baron Robert Maxwell 
There is no suggestion that the prince had any sexual encounters while hanging out with Epstein 
Andrew, who has characterized his friendship with Epstein as "unwise." will no longer be keeping company with the 
pedophile. the newspaper said 
The Mail said it is "highly likely" that investigators will want to talk to Andrew — who may be forced to plead diplomatic 
immunity because of his role as business envoy for the British government 
An e-mail request to Epstein's lawyer. Alan Dershowitz. was not returned 
Meanwhile lawyers for other women bringing civil cases against Epstein have quizzed two of his former employees about 
Andrew 
The lemal employees refused to say if they even met the prince, reported another British paper, the News of the World 
and 
invoked their Fifth Amendment right against self-incrimination on almost every 
question, 
rding to the paper. 
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EFTA01082197

Exhibit D 
EFTA01082198

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EFTA01082199

Exhibit E 
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Seen around town: Prince Andrew and pery billionaire Jeffrey Epstein stroll around New ... Page 1 of 2 
Prince Andrew tours Manhattan with billionaire sex 
offender Jeffrey Epstein 
By CATHY BURKE 
unsve n )/ AM rwn.. 21 All I 
Po.v I 30 Am f.rwy>r x111 
Meet Manhattan's raunchy new odd couple 
the prince and the pervert 
Prince Andrew. the United Kingdom's special representative for international trade and investment. and convicted child-sex 
creep Jeffrey Epstein stroll through Central Park in December -- shortly after the hooker-loving hedge-fund honcho moved 
back to his $50 million Upper East Side town house from his Palm Beach. Fla mansion 
But this was no official business chat between the longtime pals 
Following their sedate park stroll and walk around the East Side. the pair got down to the business they both apparently 
prefer -- partying 
Epstein served an 18-month sentence in 2008 in Florida under a plea deal in which he confessed to two counts of soliciting 
a minor for prostitution and soliciting prostitution.
He spent part of it in a vacant wing of a Palm Beach jail, and the rest under house arrest 
His victim was identified in court papers as a 14-year-old girl identified only as "Jane Doe " 
Epstein. a Level Three sex offender. paid the youngster — one of a string of girls who allegedly visited him — $200 for a 
massage at his Palm Beach retreat in 2005 
She said he used a vibrator on her while he masturbated. according to the court papers.
During his New York visit. Randy Andy, 51. chilled for four days at Epstein's East 71st Street pad. where the 58-year-old 
businessman reportedly threw his own welcome-home bash for stuffed-shirt glitterati, including Katie Counc. Charlie Rose 
and George Stephanopoulos 
At the party. Page Six reported. the jet-setting prince - dubbed back home as "His Buffoon Highness." — jokingly compared 
himself to Ponce Harry 
"Like Harry. I'm just the younger brother," the paper quoted Andrew. brother of Prince Charles. as saying 
And when asked by Woody Allen about his ex-wife. Fergie. the prince replied. "She's very well — we live together " 
A team of Royal Protection officers and private security arranged by billionaire Epstein was on hand for Andrew's whole 
slay. Britain's News of the World reported 
Neighbors told the paper they witnessed a parade of stunning beauties come calling at Epstein's door during the princes 
stay. the tabloid reported 
And once. Andrew was even spotted kissing a glammy brunette on the doorstep 
The aging horndogs share a long history 
They were introduced around 2000 by a mutual friend. Ghislaine Maxwell, daughter of the late disgraced media tycoon 
Robert Maxwell 
And Andrew — who has come under scathing criticism at home for globetrotting on the taxpayers dime -- has enjoyed 
frequent holidays with Epstein 
On one trip. Andrew was seen sunbathing with a bevy of topless women off the Thar coast 
In return. Epstein — who famously rubbed elbows with ex-President Bill Clinton — got invited to Queen Elizabeth's Norfolk 
retreat. Sandringham. for a weekend and was a guest at her birthday at Windsor in 2000 
The princes decision to keep in touch with his party pal — appearances be damned — comes as British press questions 
some of his past moves. including the sale of the home he once shared with Fergie to a Kazakh billionaire for almost twice 
its value 
As for Epstein. his return has generated no less scrutiny — and an episode of "Law 8 Order Special Victims Unit" inspired 
by his crimes aired on Feb 2 
The real Epstein made 16 out-of-court financial settlements with other girls who had leveled similar sexual allegations 
against him. Britain's Daily Mad sad. 
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hup://www.nypost.com/f/print/news/localAnanhattan/perv_mogul_gets_royal_treatment_Q... 
3/7/2011 
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